Transcript Managing Your Project to Minimize Permit Delays: Air

Compliance with New Air Pollution Regulations
for Boilers and Emergency Generators The Basics of What Every Facilities Manager
Should Know
NEHES Fall Conference
October 1, 2013
Rick Soucy
GZA GeoEnvironmental, Inc.
Overview
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Recent Federal Regulations Impact Hospital Operations
Affected Equipment – Boilers, Emergency Generators,
Chiller Engines, Cogeneration Engines
Regulations Complex
Compliance Deadlines Looming
Basics to Know
– Applicability
– Compliance Requirements, i.e., How to Comply
– Compliance Schedule, i.e., When to Comply By
Regulatory Background
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CAAA of 1990 (Title III)
Mandated EPA to Develop Rules to Reduce
Emissions of Hazardous Air Pollutants (HAPs)
National Emission Standards for Hazardous Air
Pollutants for Source Categories (NESHAPs)
– a.k.a. “MACT” (Maximum Achievable Control
Technology) Standards
– Promulgated at Federal Level by EPA
– Enforcement May Be Delegated to States
Why Regulate HAP Sources?
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Known or Suspected to Cause Cancer and Other
Serious Health Effects
– Aggravate Respiratory and Cardiovascular
Disease
– Changes in Lung Function
– Adverse Effects on Child Development
– Premature Deaths
HAPs and MACT Standards
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187 HAPs Currently Regulated
MACT Standards for 133 Source Categories to Date
Today’s Focus:
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2.
Area Source Boiler MACT Rule - 40 CFR Part 63,
Subpart JJJJJJ (“6J”)
Stationary RICE (Reciprocating Internal
Combustion Engine) MACT Rule - 40 CFR Part 63,
Subpart ZZZZ (“4Z”)
Clarification
Area Source vs. Major Source
Major HAP Source: > 10 Tons/Year of Any Single HAP
or > 25 Tons/Year of Total HAPs
Area HAP Source: Any Facility That is Not Major
Area Source Boiler MACT
40 CFR Part 63, Subpart JJJJJJ
Applies to Industrial, Commercial, and Institutional
Boilers at Area Sources
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History
First Proposed by EPA on June 4, 2010
Thousands of Comments Received
Originally Finalized on March 21, 2011
Simultaneous Notice of Reconsideration
Another Notice of Reconsideration and Proposed
Amendments on December 23, 2011
“Final” Rule on February 1, 2013
Lawsuits Filed by Environmental and Industry Groups
Area Source Boiler MACT
40 CFR Part 63, Subpart JJJJJJ
Q. Why Has Boiler MACT Been So Controversial?
A. There Are a Lot of Boilers ~ 1.5 million
Of These, EPA Estimates:
 86% Are Clean and Not Covered by the Rule
 13% Are Subject to Work Practice Standards
 1% Are Subject to Numerical Emission Limits
Most Hospitals and Healthcare Facilities
What Boilers Are Exempt from
Boiler MACT?
Gas-Fired Boilers
EPA Definition: Gas-Fired boiler includes any boiler
that burns gaseous fuels not combined with any solid
fuels and burns liquid fuel only during periods of gas
curtailment, gas supply interruption, startups, or
periodic testing on liquid fuel. Periodic testing of liquid
fuel shall not exceed a combined total of 48 hours
during any calendar year.
What Other Boilers Are Exempt from
Boiler MACT?
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Residential Boilers
Hot Water Heaters with Capacity < 120 gallons
Hot Water Boilers (Not Generating Steam) with Heat
Input Capacity < 1.6 MMBtu/hr
Electric Boilers
Temporary Boilers
– Must Be Portable
– Must Not Remain at Same Location More Than
12 Consecutive Months
Area Source Boiler MACT
Applicable Compliance Requirements
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Vary According to:
– Size (capacity) of Boiler
– When Constructed (before or after June 4, 2010)
– Type of Fuel Combusted
Summary of Area Source Boiler MACT Emission Limit and
Work/Management Practice Requirements
Subcategory
Existing large
area source
boilers
Existing small
area source
boilers
i.e., commenced
construction or
reconstruction of the boiler
on or before June 4, 2010;
greater than or equal to
10 MMBtu/hr
i.e., commenced
construction or
reconstruction of the boiler
on or before June 4, 2010;
less than 10 MMBtu/hr
Summary of Requirements
Gas (all types)
• No requirements (not
covered by the rule)
Coal
(excluding
limited-use
boilers)
• Numeric emission limits for
mercury (Hg) and carbon
monoxide (CO)
• One-time energy assessment
Biomass or Oil
• Initial tune-up
• Subsequent tune-ups every
other year or every 5 years
• One-time energy assessment
• No numeric emission limits
Limited-use
Coal
• Initial tune-up
• Subsequent tune-ups every
5 years
• No energy assessment
• No numeric emission limits
Gas (all types)
• No requirements (not
covered by the rule)
Coal, Biomass
or Oil
• Initial tune-up
• Subsequent tune-ups every
other year or every 5 years
• No numeric emission limits
Summary of Area Source Boiler MACT Emission Limit and
Work/Management Practice Requirements
Subcategory
New large area
source boilers
New small area
source boilers
i.e., commenced construction
or reconstruction of the boiler
after June 4, 2010; greater
than or equal to 10 MMBtu/hr
i.e., commenced construction
or reconstruction of the boiler
after June 4, 2010; less than
10 MMBtu/hr
Summary of Requirements
Gas (all types)
• No requirements (not covered
by the rule)
Coal (excluding
limited-use
boilers)
• Numeric emission limits for Hg,
CO, and particulate matter (PM)
Biomass or Oil
(excluding
limited-use and
seasonal boilers)
• Numeric emission limit for PM*
• Tune-up every other year or
every 5 years
Limited-use Coal
• Tune-up every 5 years
• No numeric emission limits
Limited-use and
Seasonal
Biomass or Oil
• Tune-up every 5 years
• No numeric emission limits
Gas (all types)
• No requirements (not covered
by the rule)
Coal, Biomass or
Oil
• Tune-up every other year or
every 5 years
• No numeric emission limits
*New oil-fired boilers that combust only oil with no more than 0.50 % sulfur (or a mixture of 0.50 % sulfur oil
with other fuels not subject to a PM emission limit) are not subject to a PM emission limit provided they do
not use emission controls (except a wet scrubber) to reduce PM or SO2 emissions.
Boiler MACT Tune-up Requirements
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Conduct According to EPA Specifications
 Tune-up on Fuel That Provided the Majority of the Heat
Input to the Boiler Over Last 12 Months
 Inspect Burner – Clean and Replace Components, as
Necessary
 Inspect Flame Pattern and Adjust Burner to Optimize
 Inspect Air-to-Fuel Ratio Controller, if Equipped
 Optimize CO Emissions Consistent with Manufacturer’s
Specifications
 Measure the Exhaust Concentration of CO and O2
Before and After Any Adjustments Made
 Maintain Report That Identifies Measured
Concentrations and Corrective Actions
Boiler MACT Energy Assessment
Requirements
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Must Be Performed By a Qualified Energy Assessor
Assessment Must Include:
1. Visual Inspection of Boiler System
2. Evaluation of Operating Characteristics and Specifications of
the Boiler System
3. Inventory of Major Energy Use Systems Consuming Energy
from the Boiler
4. Review of Architectural/Engineering Plans, Operations and
Maintenance Procedures/Logs, and Fuel Usage
5. List of Major Energy Conservation Measures Within the
Facility’s Control
6. List of the Energy Savings Potential of Energy Conservation
Measures
7. Comprehensive Report Detailing Ways to Improve Efficiency,
Cost of Specific Improvements, and Payback Periods
Boiler MACT Energy Assessments
-Other Things to Know
On-Site Technical Labor Hours Can be Limited –
Depends on Total Annual Heat Input Capacity of the
Boiler
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Requirement Satisfied if Already Had Assessment
Done After 1/1/2008 and if Met EPA Specifications
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Requirement Satisfied if Facility Operates Under an
Energy Management Program Compatible with ISO
50001 That Includes the Affected Boiler
Boiler MACT
-Other Requirements
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Submit Notifications (as applicable)
Keep Records of Fuel Usage
Prepare Compliance Certification Reports
Boilers with Emission Limits:
– Performance Tests
– Fuel Analyses
– Continuous Monitoring Systems
Boiler MACT Compliance Dates
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Initial Notification: January 20, 2014 or Within 120
Days of When a New Boiler Becomes Subject
Initial Tune-ups and Energy Assessments:
March 21, 2014
Emission Limits: March 21, 2014 (Performance
Testing Required Within 180 Days)
Notification of Compliance Status for Tune-Ups and
Energy Assessments: July 19, 2014
Prepare Annual Compliance Certifications by
March 1 of Every Year
Note: Notifications may have to be sent electronically using CEDRI
Interface.
Helpful Web Sites for Boiler MACT
EPA Region 1 List of Qualified Energy Assessors
http://www.epa.gov/boilercompliance/whereyoulive.html#region1
General Information and Compliance Tools
http://www.epa.gov/boilercompliance/
http://www.epa.gov/airtoxics/boiler/boilerpg.html
RICE MACT
40 CFR Part 63, Subpart ZZZZ
Applies to Stationary Engines of All Types and Sizes
 Existing and New
 Emergency and Non-Emergency
 Compression Ignition (CI)
 Spark Ignition (SI)
Does Not Apply to Non-Road Engines or Motor
Vehicle Engines
RICE MACT History
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Originally Proposed by EPA on December 19, 2002:
RICE > 500 HP at Major Sources
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Revised and Expanded: January 18, 2008, March 3,
2010, August 20, 2010, March 9, 2011
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“Final” Amendments on January 30, 2013
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Notice of Reconsideration: September 5, 2013
RICE MACT
Applicability to Hospitals and
Healthcare Facilities
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Emergency Engines (Generators and Fire Pump
Engines)
Gas-Fired Chiller Engines
Gas-Fired Cogeneration Engines
Focus: Compliance Requirements at Area Sources
RICE MACT Compliance Requirements
for Emergency Engines
GOOD NEWS !!
Existing Institutional Emergency Engines are Exempt
BUT…
RICE MACT Compliance Requirements
for Emergency Engines
Must Operate in Accordance with EPA Definition of an
Emergency Stationary RICE, i.e.,
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Maximum 100 hr/yr Total for Maintenance/Testing, Emergency
Demand Response, and > 5% Voltage/Frequency Deviations
 50 Hours of the 100 hr/yr Allocation Allowed for NonEmergency Situations (excluding peak shaving or financial
arrangements, with limited exceptions)
 Must Not Operate (or be contractually obligated to operate)
More Than 15 hr/yr for Emergency Demand Response (EDR) *
and >5% Voltage/Frequency Deviations
* “Energy Emergency Alert Level 2” Per Reliability Coordinator
RICE MACT Compliance Requirement
for Emergency Engines
- No Limit on Emergency Operations -
WARNING!
Your State or Local Air Pollution Control Authority May
Have More Stringent Operating Limits and Compliance
Requirements
RICE MACT – Emergency Engines
What if Your Emergency RICE Operates or is Contractually
Obligated >15 hr/yr for Emergency Demand Response?
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ULS Fuel (<15 ppm) by January 1, 2015
Operate/Maintain Engine According to Manufacturer’s
Instructions
Subject to Management Practices
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Change Oil/Filter Every 500 Operating Hours, or Annually
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Inspect Air Cleaner Every 1,000 Operating Hours,
or Annually
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Inspect Hoses and Belts Every 500 Operating Hours,
or Annually
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Inspect Spark Plugs Every 1,000 Operating Hours,
or Annually
RICE MACT – Emergency Engines
What if Your Emergency RICE Operates or is Contractually
Obligated >15 hr/yr for Emergency Demand Response?
4.
If >100 HP, Submit Annual Report
• Engine Rating/Model Year
• Latitude/Longitude of Engine Location
• Identify Contractual Obligations
• Operating Hours for EDR and Voltage/Frequency
Deviations (Dates, Start Times, Stop Times)
• Reason for Each Dispatch
• First Report Due 3/31/2016 for Calendar Year 2015
RICE MACT – Emergency Engines
What If Allowable Non-Emergency Operations
Exceed 100 hr/yr?
SEVERE CONSEQUENCES
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Management Practices (oil changes, inspections, etc.)
Emission Limits or Emission Reduction Requirements
Install Emission Control Equipment
Conduct Emission Performance Tests
Monitor Exhaust Catalyst Performance Parameters
Semi-Annual Compliance Reports
Notifications to EPA and State Authority
RICE MACT
Applicability to “New” Emergency Engines
“New” If Construction Commenced On or After 6/12/2006
 Must Instead Comply with Federal NSPS
– 40 CFR Part 60, Subpart IIII for CI Engines
– 40 CFR Part 60, Subpart JJJJ for SI Engines
 General NSPS Requirements
– Purchase a Certified Engine
– Emission Performance Tests (Non-Certified SI)
– Operate According to Emergency Engine Limitations
– Non-Resettable Hour Meter
– ULS Fuel (CI)
– Install/Operate/Maintain According to Manufacturer’s
Instructions
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RICE MACT
Compliance Requirements for Existing
Non-Emergency Engines
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Gas-Fired Chiller Engines
Gas-Fired Cogeneration Engines
Five Gas-Fired Engine Categories
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2SLB
4SLB < 500 HP
4SRB < 500 HP
4SLB > 500 HP
4SRB > 500 HP
RICE MACT Compliance Requirements
Existing Non-Emergency 2SLB Engines
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Change Oil/Filter Every 4,320 Operating Hours, or
Annually
Inspect Spark Plugs Every 4,320 Operating Hours,
or Annually (Replace as Necessary)
Inspect Hoses/Belts Every 4,320 Operating Hours,
or Annually (Replace as Necessary)
Operate to Minimize Emissions
RICE MACT Compliance Requirements
Existing Non-Emergency 2SLB Engines
(continued)
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Maintain Engine and Control Device According to
Manufacturer’s Instructions, or Develop
Maintenance Plan
Minimize Idling Time During Start-up
Limit Start-up Time to 30 Minutes
Keep Maintenance Records
Must Comply by October 19, 2013
RICE MACT Compliance Requirements
Existing Non-Emergency 4SLB and 4SRB
Engines < 500 HP
Same Requirements as for 2SLB, Except:
 Maintenance Interval = Every 1,440 Operating
Hours, or Annually
Compliance Date: October 19, 2013
RICE MACT Compliance Requirements
Existing Non-Emergency 4SLB Engines > 500 HP
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Initial Notification Was Due on February 16, 2011
Install Oxidation Catalyst by October 19, 2013
Conduct Initial Compliance Demonstration by April 18, 2014
Must Demonstrate:
1. Average CO Emission Reduction > 93%, or
2. Average CO Concentration < 47 ppmvd at 15% O2
Submit Notification of Intent at Least 60 Days Prior to Test
Submit Notification of Compliance Status Within 60 Days
After Initial Compliance Demonstration
Subsequent Annual Compliance Demonstrations
RICE MACT Compliance Requirements
Existing Non-Emergency 4SLB Engines > 500 HP
(continued)
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Install CPMS for Catalyst Inlet Temperature or
Automatic Shutdown Device if Catalyst Inlet
Temperature > 1,350˚F (by October 19, 2013)
If CPMS, Maintain 4-hour Rolling Average Inlet
Temperature Between 450 ˚F and 1,350˚F
Submit Semi-Annual Compliance Reports
RICE MACT Compliance Requirements
Existing Non-Emergency 4SRB Engines > 500 HP
Same Requirements as for 4SLB > 500 HP, Except:
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Must Install NSCR (3-Way Catalyst) by October 19, 2013
 Must Demonstrate:
1. Average CO Emission Reduction > 75%, or
2. Average CO Concentration < 270 ppmvd at 15% O2, or
3. Average THC Emission Reduction > 30%
 Install CPMS for Catalyst Inlet Temperature or Automatic
Shutdown Device if Catalyst Inlet Temperature > 1,250˚F
 If CPMS, Maintain 4-Hour Rolling Average Inlet
Temperature Between 750˚F and 1,250˚F
RICE MACT
Applicability to “New” Cogeneration or
Chiller Engines
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“New” if Construction Commenced On or After 6/12/2006
Instead Comply with NSPS – 40 CFR 60, Subpart JJJJ
Purchase a Certified Engine (if you can)
Non-Certified Engines
– Requirements Depend on Size, Type, and
Manufacture Date
– Emission Limits (NOx, CO, VOC)
– Initial and Subsequent Performance Tests
– Notifications, Recordkeeping, and Reporting
Helpful Web Sites for RICE MACT
General Information and Compliance Tools
EPA Region I – New England
http://www.epa.gov/region1/rice/
EPA Technology Transfer Network
http://www.epa.gov/ttn/atw/icengines/
Questions
???
Compliance with New Air Pollution Regulations
for Boilers and Emergency Generators –
The Basics of What Every Facilities Manager
Should Know
NEHES Fall Conference
October 1, 2013
Contact:
Rick Soucy
GZA GeoEnvironmental, Inc.
655 Winding Brook Drive, Suite 402
Glastonbury, CT 06033
Phone: (860) 858-3163
Fax: (860) 652-8590
[email protected]
www.gza.com