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Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended)
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Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended)

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Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended)

Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended)

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Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended) Presentation Transcript

  • 1. Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended) Tina Sanderson, B.Sc. Environmental Scientist and Hank Van Bakel, P.Eng. Manager, Compliance and Permitting Sarnia-Lambton Environmental Association May 13, 2008
  • 2. Opacity is currently legislated through Ontario Regulation 419/05 Section 34. Note: O. Reg. 419/05 has been amended by O. Reg. 516/07 which includes changes to Section 34 effective April 1, 2008. MOE Technical Bulletin (Draft) released in November 2007.
  • 3. Current Opacity Limits
    • Section 34(1) states:
    • No person shall cause or permit an emission into the air that, during a period of six minutes , obstructs the passage of light at any point by an average of more than 20%.
    • Limit applies to “out-of-stack” discharges.
    • C of A opacity limits take precedence over Section 34 as long as they are more stringent than the 20% opacity limit.
  • 4. Current Opacity Limits
    • Section 34(2) states:
    • Subsection (1) does not apply to an emission from a source of combustion that uses fuel with high ash content , if,
    • (a) during the six minute period referred to in subsection (1), the passage of light was not obstructed by an average of 40% or more at any point; and
    • (b) the six minute period referred to in subsection (1) was part of a period of 30 consecutive minutes in which there were four periods of six consecutive minutes during which the person complied with subsection (1); and
    • (c) the four periods referred to in clause (b) did not overlap with each other and did not overlap with the six minute period referred to in subsection (1)
  • 5. Current Opacity Limits
    • What does Section 34(2) mean?
    • If you operate combustion equipment that burns high ash fuels (coal, oil, wood, black liquor) periodic soot blowing may be required which can increase opacity for short periods.
    • In these situations there is an exception to the 20% opacity limit. Your opacity can increase up to 40% for a period of no more than 6 consecutive minutes in any 30 minute period.
  • 6. Exemption from the Opacity Limits
    • 20% opacity limit may not apply to a facility if;
    • - The facility is using equipment designed for the purpose of minimizing opacity.
    • - The equipment is required by a C of A.
    • - The Director is satisfied that the equipment effectively minimizes opacity.
  • 7. Current Alternate Methods for Minimizing Opacity
    • Fabric filters with a bag leak detection system.
    • Fabric filters with a bag leak detection system in combination with wet scrubbers with monitoring of pH, pressure drop and liquid flow rate.
    • ESPs with monitoring of voltage and secondary current in combination with wet scrubbers with monitoring of pH, pressure drop and liquid flow rate.
    • Other alternate methods must be approved via CofA, notice or some other formal approval.
  • 8. Notifying the MOE of Exceedences
    • A person who contravenes the opacity limit shall notify a provincial officer in writing as soon as practicable after the contravention occurs.
    • Unless;
    • A person contravenes the opacity limit more than once in a 24 hour period, the person may notify a provincial officer after the end of the 24 hour period of the number of contraventions.
    • Note: Confirm notification procedures with the Local District Office.
  • 9. Start-Up, Shut-Down and Maintenance
    • Opacity exceedences due to start-up, shut-down and maintenance do not have to be reported if the facility has a plan on-site to minimize conditions that lead to high opacity.
    • Note: Does not absolve the facility from meeting opacity limits.
  • 10. Plan to Minimize Opacity
    • What should be included in the Plan?
    • Sources that may exceed opacity
    • Opacity data if available
    • - Operation of each source (soot-blowing schedule)
    • - Maintenance schedule and records
    • Start-up and shut-down duration and records
    • How high opacity will be determined
    • How opacity will be minimized
  • 11. Potential Sources of Opacity to Consider for a Plan
    • Boilers and Heaters
    • Emergency Generators and Fire Pumps
    • Welding Operations
    • Cooling Towers
    • Flares
    • Burn Pits
    • Note: Section 34 does not specify or exempt any types of sources (e.g. fugitive, mobile)
  • 12. Summary Opacity Requirements
    • Note: All limits based on 6-minute block average
    Equipment detailed in CofA Opacity Plan None Other Requirements Exempt Exempt After exceedence or once every 24h Reporting Exceedences Exempt 40% (6 min every ½ h) 40% (6 min every ½ h) High Ash Fuel Opacity Limit Exempt 20% 20% Opacity Limit Sources with Alternate Methods Start-Up, Shut-Down and Maintenance Normal Operations
  • 13. Questions? ORTECH Environmental 2395 Speakman Drive Mississauga, ON L5K 1B3 Tel: 905-822-4120 Fax: 905-855-0406 Web: www.ortech.ca