Major/Area Source Boiler MACT Rule

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Eric Swisher presented at the 23rd Virginia Environmental Symposium about the Major/Area Source Boiler MACT Rule. The presentation covered the regulatory framework of the rule including emission limitations, compliance options, work practice standards, startup, shutdown, and malfunction, and provided a summary of what the rule means to facilities.

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  • Most of you should already know if you are a major source of HAPs or not. Meaning that your facility has a potential to emit, considering controls, of 10 tons per year or more of any single HAP or 25 tons per year or more of any combination of HAPs. If you are not a major source of HAPs then you are an Area Source of HAPs.Since we will be comparing the ASBM and MSBM, I have assigned a visual representation of each rule. For the ASBM I choose the University of Virginia Cavalier and for the MSBM I have chosen the Virginia Tech University Hokie. We you see the Cavalier, it applies to the ASBM. When you see the Hokie, it applies to the MSBM. I did not have any reason for assigning these visual aids to their particular rule other than there is a lot of uncertainty of what the final MSBM is and what a Hokie is.
  • [Slide No. X – ENERGY OUTPUT REDUCTION EXAMPLE] – ~X min
  • [SLIDE X TUNE-UPS] – ~2.5 minWhat is required for a boiler tune-up. Let’s compare the ASBM and MSBM.[CLICK] – Burner inspections are required under the ASBM and MSBM with a distinct clarification. Let’s look at the requirement. Again, it is about the language. The ASBM has “but you must inspect each burner at least once every 36 months”. This was removed from the MSBM based on comments so that the boiler does not have to shutdown to complete the burner inspection. Area source boilers will have to shut down to perform the burner inspection.[CLICK] – Flame Pattern Inspection requirement is identical for the ASBM and MSBM. The requirement is to adjust the burner as necessary to optimize the flame patternconsistent with the manufacturer’s specifications.[CLICK] – Air-to-fuel controlling system requirement is identical for the ASBM and MSBM. The requirement is to inspect the system controlling the air-to-fuel ratio and ensurethat it is correctly calibrated and functioning properly.[CLICK] – Both the ASBM and MSBM require an CO optimization as part of the tune-up. An important note on the CO optimization requirement is that you are not trying to “lower” your CO emissions (especially if you are sacrificing NOX). The intent of the CO optimization is only for good combustion practices. This is noted in the preamble to the final ASBM and assumed that it can be applied to the MSBM. The CO and O2 concentration must be measured before and after the tune-up.[CLICK] – Both the ASBM and MSBM require information to be recorded as part of the tune-up. [CLICK] – However, only the MSBM requires the information to be submitted. NOCS.
  • ASBM (proposed amendments)Startup means the period between the state of no combustion in the boiler to the period where the boiler first achieves 25 percent load (i.e., a cold start).Shutdown means the period that begins when the boiler last operates at 25 percent load and ending with a state of no fuel combustion in the boiler.MSBMStartup means the period between the state of no combustion in the unit to the period where the unit first achieves 25 percent load (i.e., a cold start).Shutdown means the period that begins when a unit last operates at 25 percent load and ending with a state of no fuel combustion in the unit.
  • Major/Area Source Boiler MACT Rule

    1. 1. Major/Area SourceBoiler MACT RuleSpeaker:Eric Swisher23rd Virginia Environmental SymposiumApril 11, 2012 Your environmental compliance is clearly our business.
    2. 2. Overview  Ground Rules  Regulatory Framework  Regulated Pollutants  Emission Limitations  Compliance Options  Work Practice Standards  Startup, Shutdown, and Malfunction  Things to Take Away2
    3. 3. Ground Rules NHSM Rule Fuel is a Solid Waste Fuel is not a Solid Waste CISWI Boiler MACT Rule Rules Area Major3
    4. 4. General Information  Area or Major Source  New, Reconstructed, or Existing  Fuel Type  Design Type4
    5. 5. Comparison Area Source Major Source5
    6. 6. Facility Type Area Source Major Source  Not a Major Source  >10 tons per year any single HAP OR  > 25 tons per year of any combination of HAPs6
    7. 7. Regulatory Citation  40 CFR Part 63 – National Emission Standards for Hazardous Air Pollutants for Source Categories (NESHAP): • Subpart JJJJJJ – Area Source Boiler MACT (ASBM) • Subpart DDDDD – Major Source Boiler MACT (MSBM)7
    8. 8. History Area Source Major Source June 04, 2010  January 13, 2003   March 21, 2011 • Proposed  December 23, 2011 • Proposed • Comments Due March 14, 2003 • Comments Due July 19, 2010 •Promulgated •Proposed  September 13, 2004 • Promulgated  June 09, 2010 • Compliance Date September 13, 2007 • Comment Period Extended to August  October 31, 2005  December 23, 2011 03, 2010  February 07, 2012 • Notice of Reconsideration • Proposed Amendments July 22, 2010 •Proposed Amendments •No Action Assurance   December 28, 2005 • Final Rule (with Amendments) • Comment Period Extended to August • Compliance Date September 13, 2007 23, 2010   February 21, 2012 March 21, 2011  Letter December 06, 2006 • Final Action on Reconsideration June 04, 2010 • Promulgated  •Comments Due • Proposed  December 23, 2011 • Comments Due July 19, 2010 June 09, 2010 • Proposed Amendments  • Comment Period Extended to August 03, 2010   March 13, 2012 February 21, 2012  July 22, 2010 • Comment Period Extended to August 23, 2010 • Comments Due •No Action Assurance  March 13, 2012  March 21, 2011 • Promulgated • No Action Assurance Letter Letter8
    9. 9. Act of Congress  March 08, 2012 Senate did not pass the Collins Amendment to the Highway Bill that would delay the MSBM.9
    10. 10. Current Status Area Source Major Source  Effective Now  Proposed Rule  Compliance Date •December 23, 2011 •March 21, 2014  Compliance Date  No Action Assurance •Date to Change Letter  No Action Assurance •March 13, 2012 Letter •February 07, 201210
    11. 11. Source Applicability Area Source Major Source  Boiler  Boiler  Exemptions  Process Heaters  Exemptions11
    12. 12. Regulated Pollutants Area Source Major Source  Mercury (Hg)  Mercury (Hg)  Non-Mercury Metallic  Non-Mercury HAP Metallic HAP  Non-Metallic Inorganic  Organic HAP HAP (including POM)  Non-Dioxin Organic HAP  Dioxins/Furans (D/F)12
    13. 13. Emission Limits Area Source Major Source  Mercury  Mercury  Carbon Monoxide  Carbon Monoxide  Particulate Matter  Particulate Matter OR Total Selected Metals (TSM)  Hydrogen Chloride13
    14. 14. Compliance Options 1. Comply with the Emission Standards Area Source Major Source  Fuel Sampling  Fuel Sampling  Emission Testing  Emission Testing14
    15. 15. Fuel Sampling Area Source Major Source  Hg  Hg, HCl, & TSM  Determine “Worst-  Determine “Worst- Case” Fuel Mixture Case” Fuel Mixture  Fuel Sampling & Analysis Plan  Monthly Fuel Analyses15
    16. 16. Emission Testing Area Source Major Source  PM  PM or TSM  Hg  Hg  CO  CO  HCl16
    17. 17. Compliance Options 2. Evaluate Emission Standard Alternatives Area Source Major Source  None  Emission Averaging  Output-based Emission Standard • Emission Reduction Credits17
    18. 18. Emission Averaging  PM, HCl, or Hg  Input or Output-based Emission Standards  Existing Boiler Only  Subcategory Requirements  10% Discount Factor  Common Stack Considerations  Emission Averaging Plan18
    19. 19. Compliance Options 3. Can Not Comply with the Emission Standards Area Source Major Source  Fuel Management  Fuel Management  Fuel Switching  Fuel Switching  Controls  Controls  Synthetic Minor  Energy Efficiency Improvements19
    20. 20. Output-based Emission Standards  Output-based Emission Standards • Incentivizes implementation of energy efficient technologies to minimize the generation of emissions20
    21. 21. Output-Based Emission Standards Fuel Steam Input Energy (lb Output Energy (lb pollutant per MMBtu pollutant per MMBtu heat input) steam output)21
    22. 22. Capital Investment Add-on Control Energy Efficiency Device(s) Project(s)22
    23. 23. Output-Based Emission Standards  How were they determined? • Boiler Efficiency • Heat-Input Based Limits Subcategory Hg Emission Hg Emission Boiler Limit Limit Efficiency (lb Hg per MMBtu (lb Hg per MMBtu (%) of heat input) of steam output) Existing Boiler Designed to Burn 3.10E-06 3.50E-06 88.6 Solid Fuel23
    24. 24. Output-Based Emission Standards  How are they used? • Determine Current Boiler Output-Based Emissions • Establish Output Energy “Benchmark” • Investigate Energy Efficiency Projects • Quantify Emission Reductions • Apply Percent Reduction to Current Boiler Output-Based Emissions24
    25. 25. Energy Output Reduction Example  Benchmark Year* = 2,175,000 MMBtu/yr  Year After* = 1,957,500 MMBtu/yr Tested Hg Tested Hg Adjusted Hg Emissions Emissions Emissions (lb Hg per MMBtu of (lb Hg per MMBtu of (lb Hg per MMBtu of heat input) steam output) steam output) 3.40E-06 3.84E-06 3.45E-06 (Limit 3.10E-06) (Limit 3.50E-06) *Production is assumed to be the same for both years.25
    26. 26. Energy Output Reduction Example Subcategory Hg Emission Hg Adjusted Result Limit Emissions (lb Hg per MMBtu (lb Hg per MMBtu of steam output) of steam output) Existing Boiler Designed to 3.50E-06 3.45E-06 PASS Burn Solid Fuel26
    27. 27. Output-Based Other Considerations  Implementation Plan  Pollutant-by-Pollutant Applicability  Emissions Averaging  Shutdown Boilers  Future Boiler Operations  Other Permitting Requirements  Energy Assessment27
    28. 28. What is Left?  Ground Rules  Regulatory Framework  Regulated Pollutants  Emission Limitations  Compliance Options  Work Practice Standards  Startup, Shutdown, and Malfunction  Things to Take Away28
    29. 29. Work Practice Standards Area Source Major Source  Tune-up  Tune-up  Energy  Energy Assessment Assessment  Startup  Good Combustion  Shutdown Practices  Startup  Shutdown29
    30. 30. ASBM Tune-ups Final Rule Amendments ASBM (March 21, 2011) ASBM (December 23, 2011)  Every 2 years  Every 2 years  March 21, 2012  Every 5 years  No Action Assurance (Seasonal Boilers) Letter  March 21, 2013  Fuel Type Requirements  Common Fuel Meter30
    31. 31. Tune-up Applicability Area Source Major Source  New or Existing  Limited-use Boilers Coal-fired Boiler <10  Natural gas, Refinery MMBtu/hr Gas or Gas 1 (Other)  New or Existing Boilers < 5 MMBtu/hr Biomass-fired Boiler  Gas 2 (Other), Light  New or Existing Liquid Boilers Oil-fired Boiler31
    32. 32. Tune-up Requirements Area Source Major Source  Burner Inspection  Burner Inspection (1)Flame Pattern the  As applicable, inspect (1)Flame Pattern clean or  Inspect the burner and burner, and clean or replace any replace any components of the Inspection components of the burner as Inspection burner as necessary.  Air-to-fuel system necessary (you may delay the  Air-to-fuel system Inspection burner inspection until the next Inspection scheduled unit shutdown, but  CO Optimization  CO Optimization you must inspect each burner  Recordkeeping at least once every 36 months).  Recordkeeping  No Report Submittal  Report Submittal32
    33. 33. Energy Assessment  Why?  When and how often?  Who is qualified?  What equipment or systems need to be included?  What does “cost-effective” mean?  What needs to be done?33
    34. 34. Energy Assessment Final Rule Amendments ASBM (March 21, 2011) ASBM (December 23, 2011)  Existing  Existing  ≥ 10 MMBtu/hr  ≥ 10 MMBtu/hr  Boiler System  Boiler System  Energy Use System  Energy Use System •Onsite Only  Qualified Personnel  Qualified Personnel  Maximum Duration  Maximum Duration  March 21, 2014  March 21, 201434
    35. 35. Energy Assessment Major Source  Scope  Maximum Time  Compliance Date •Date to Change  Emission Reduction Credits35
    36. 36. Good Combustion Practices  O2 Trim Systems • Monitor • Optimize • Report  Operator Training • Startup Procedures • Shutdown Procedures36
    37. 37. Startup/Shutdown Periods  Boiler MACT standards apply at all times.  No exemptions from Boiler MACT standards during periods of Startup and Shutdown.  U.S. EPA requires work practice standards for periods of Startup and Shutdown in lieu of numerical emission limits.37
    38. 38. Startup/Shutdown Area Source Major Source  Minimize the boiler’s  Good Combustion startup and Practices shutdown periods following the manufacturer’s recommended procedures.38
    39. 39. Misc. Startup/Shutdown Area Source Major Source  Startup/Shutdown  Startup/Shutdown Definitions Definitions  No SSM Plans  No SSM Plans39
    40. 40. Malfunction  Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control and monitoring equipment, process equipment, or a process to operate in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be exceeded. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.40
    41. 41. Periods of Malfunction  Boiler MACT standards apply at all times.  No exemptions from Boiler MACT standards during periods of Malfunction.  U.S. EPA determines if a facility demonstrated a “good faith effort” to minimizing emissions and correcting a Malfunction.41
    42. 42. Malfunction Process  Notification of a Malfunction submitted to U.S. EPA within two (2) business days.  Follow-up report submitted to U.S. EPA within 45 business days.  U.S. EPA evaluates the reported information concerning the Malfunction to determine if further inquiry or enforcement action is required.  Facility can only use Affirmative Defense in response to civil penalties if notification and report is submitted.42
    43. 43. Affirmative Defense  To use Affirmative Defense facilities must show a “preponderance” of evidence that: • The excess emission was caused by a malfunction and was not preventable or reoccurring, and • The facility expedited repairs, actions were documented in signed logs, and a root-cause analysis was completed.43
    44. 44. SSM Plan  No SSM Plan required; however may be more important now than ever due to potential enforcement action.44
    45. 45. Things to Take Away  The current status of the Boiler MACT rules?  Where do I stand now?  What are my compliance options?  What are my compliance plans?  Be in action!45
    46. 46. Questions? Speaker Contact Info: Eric M. Swisher eswisher@all4inc.com 610.933.5246 x17 All4 Inc. - 2393 Kimberton Road - P.O. Box 299 - Kimberton, PA 19442 610.933.5246 - www.all4inc.com46

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