Transcript Cover title

Boiler GACT Update
Georgia AWMA Conference
October 2013
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Agenda - NESHAP Anatomy
Applicability and
Affected Sources
Schedule and
Definitions
Compliance
Assurance
Requirements
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Subcategories
and
Emission Limits
Compliance Options
The “Final” Combustion Source Rules
Promulgated again by US EPA on January 31 and February 1, 2013
Includes four (4) Interrelated Rules
 40 CFR 63 Subpart DDDDD – Major Source Boiler MACT
 40 CFR 63 Subpart JJJJJJ – Area Source Boiler GACT
 40 CFR 60 Commercial and Industrial Solid Waste Incineration (CISWI) Rule
 40 CFR 241 Non-Hazardous Secondary Materials (NHSM) Solid Waste
Identification Rule
Detailed Site-specific Action Plan Needed
 To gather data, assess applicability, determine emission limits, review
compliance status/options, and implement compliance strategy
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The Solution is a Process Issue…
Point of
Compliance
Each part of the process may be part of the answer!
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Boiler Area Source GACT Rule (Boiler GACT)
GACT = Generally Available Control Technology
Applicability - Applies to boilers that:
■
Burn a “fuel” material, not a “waste” as defined
by US EPA (“Fuel” = coal, oil, gas, biomass, tirederived fuel, others)
■
Located at an industrial, institutional, commercial
facility that is an “area source” (any source not
major) of Hazardous Air Pollutants (HAP)*
■
Does not include process heaters
*Note: A facility is an Area Source of HAP emissions if it emits less than 10 TPY
of any single regulated HAP, and less than 25 TPY of any combination of HAP’s
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Boiler GACT Applicability
 Applies to HAP Area Sources
 “Natural Gas” Boilers are Exempt
 Existing Sources (Commenced Construction Prior to
6/4/10)

Emission Limits Set Only for Coal Boilers

Fuel Oil and Biomass Units Only Subject to Work Practice
Standards

Fuel Switching After 6/4/10 May No Longer Trigger New Source
Status
 Initial Compliance Date 3/21/14 for existing sources
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Natural Gas Curtailment
 Period of gas curtailment or supply interruption means a period of
time during which the supply of gaseous fuel to an effected boiler is
restricted or halted for reasons beyond the control of the facility.
 The act of entering into a contractual agreement with a supplier of
natural gas established for curtailment purposes does not constitute a
reason that is under the control of a facility for the purposes of this
definition.
 An increase in the cost or unit price of natural gas due to normal
market fluctuations not during periods of supplier delivery restriction
does not constitute a period of natural gas curtailment or supply
interruption.
 On-site gaseous fuel system emergencies or equipment failures
qualify as periods of supply interruption when the emergency of failure
is beyond the control of the facility.
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Fuel Switching Improvement
63.11194(e) - An existing dual-fuel fired boiler meeting the definition
of gas-fired boiler, as defined in § 6.11237, that meets the applicability
requirements of this subpart after June 4, 2010 due to a fuel switch
from gaseous fuel to solid fossil fuel, biomass, or liquid fuel is
considered to be an existing source under this subpart as long as the
boiler was designed to accommodate the alternate fuel.
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Significant Improvements/Changes
■ Many Emissions Limits are Now Higher
■ Initial Tune-Up Deadline Delayed to 3/21/14
■ Tune-Ups Conducted Using Primary Fuel Over the Prior 12 Months
■ Natural Gas Curtailment Now Includes On-Site Fuel System Failures
■ Temporary, Seasonal and Limited Use Boiler Relaxation
■ CO Emission Limit and Potential CEMS for Oil Sources Removed
■ New Oil Sources Burning < 0.5 % Sulfur Are Exempt from PM Limit
■ Start-Up & Shutdown Definitions Changed and 25% “Bright Line”
Removed
■ Potential Hg Fuel Analysis Relaxation
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Initial and Continuous Compliance
Initial
Notification(s)
Stack Testing
or Fuel
Analysis for Hg
Stack O2
Monitor for
CO Limits
Periodic
Performance
Tests
Monitoring
of Operating
Parameters
for Control
Devices
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Work Practice
Standards
(Tune-Ups,
Energy
Assessment,
etc.)
Notification of
Compliance
Status
Report(s)
Boiler GACT Compliance
 Existing Source Initial Compliance Deadline 3/21/14
 Initial Tune-Up and One Time Energy Assessment
 Stack Testing for Applicable Boilers Due by 9/17/14
 Notification of Compliance Status Report(s) (7/19/14
and/or 11/17/14)
 Ongoing Compliance Assurance – Testing, Monitoring,
Recordkeeping and Reporting
 SSM Requirements ???
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Existing Coal Boilers
 Subject to Mercury (Hg) and CO Emission Limits
 Hg Compliance Based as Fuel Analysis or Stack
Testing
 CO Compliance Typically Based Only on Stack Testing
 Stack Testing Includes:

Both Initial and Ongoing Testing

Test Plan Approval by GA EPD

Monitoring and Establishing Hg, CO and Capacity Operating Limits

Developing/ Implementing a Site Specific Monitoring Plan

Conduct Initial and Periodic Continuous Parameter Monitoring
System Performance Evaluations – May Need a RATA!?

Need to Run at Maximum Capacity – 110% Operating Limit

Report Results Via New US EPA WebFire Database
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One-time Energy Assessment (EA)
 Required for All Existing Affected Boilers > 10 MM Btu
Except Limited Use
 Higher Fuel Efficiency means Reduced Air Pollutants Emitted
to the Atmosphere
 EA to Identify and Evaluate Cost Effective Energy Conservation
Measures – Not a Regulatory “Deliverable”
 EA will cover the Boilers and the Energy Use System within the
Sources’ property (compressed air, machine drive, process cooling,
hot water, HVAC, building envelope)
 Requires an evaluation of the facilities “energy management
practices” and required EA Duration is dependent on total
heat input capacity
 EA to follow prescribed procedures and assessor qualifications
relaxed, and existing assessments can now be amended as
needed to comply.
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Permitting Considerations
■ Will Generic Placeholder Conditions Suffice?
 Trade-off of Generic vs. Specific Conditions Approach
■ Typical Issues With Agencies:
 Approval of Alternative Operating Limits
 Approval of Multiple Compliance Options
 Testing of Worst Case Fuel for Each Pollutant
 Title V Versus GACT Inconsistencies
 Verify if Site Specific Monitoring Plan Needs to be Submitted
 Need for Multiple NOCSR Submittals
 Does Annual Compliance Report Need Submittal
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Permitting Considerations (continued)
■
What Permit Applications are Needed and When?
 < 10/25 TPY HAP Emission Limits
 New/Modified Emission Control Device Construction, Operation,
and/or Operating Limits
 New Boiler(s) and/or Fuel Switching
 Compliance Option Definition
■
Need to Ensure Compliance Plan is Enforceable!
 Solid Fuel Variability is a Challenge/Risk for Both Area Source
Status and Boiler GACT Compliance
■
Request to See a “Pre-Public” Draft Amendment
■
Other Potential Implications– NSR, NAAQS, NSPS, GHG, etc.
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Case Study Example
Major HAP Source With One Large Coal Boiler, Four Natural Gas Boilers and
Very Low Process HAP’s
■ Looking at Area Source HAP Status Via Limiting Boiler HCl Emissions
■ Lime Injection Into Baghouse or Add-On Wet Scrubber
■ Potential Fuel Switching From Coal
■ Addition of Fuel Oil to Manage Natural Gas “Risk”
■ Conducting Stack Testing and Fuel Analysis
■ Completing “What If” Emission Testing
■ Setup Ongoing Hg Fuel Analysis
■ Evaluating Hg and/or CO Compliance Options
■ Fuel Vendor Contract Limits and Operating Restriction/Controls
■ Trade off of CO Management Versus NOx Permit Limits
■ Development of Long Term Compliance Strategy and Schedule
■ Operating Costs, Impacts and Uncertainties
■ Build Results Into Site Budgeting Cycle
■ Ongoing GA EPD discussions/negotiations
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Boiler MACT Planning Timeline
Based on January, 2016 Initial Compliance Date
Now
3/2014
9/2014
1/2015
3/2015
9/2015
1/2016
Data
Gathering
and Initial
Planning
Boiler Stack
Testing
Completed
Engineering
Evaluation and
Fuel Supplier
Review
Technology/
Vendor
Selection and
Design
Permitting and
Regulatory
Negotiations
Fabrication,
Construction,
Check Out and
Training
Ongoing
NESHAP
Compliance
Activities
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What’s Next for You?
Assess
if you have boilers/process heaters potentially subject to
CISWI versus MACT/GACT
Identify
applicable emission limits and if you can comply with these
limits
Gather
needed fuel analysis and/or stack test data
(develop/implement test plan)
Evaluate
the need for additional emissions controls, perform
economic analyses and plan for future budget cycles
Determine
if need additional monitoring systems
Consider
operational, process and/or fuel changes to reduce the
regulatory burden
Develop
an overall compliance strategy and schedule
Plan
for tune-ups and facility-wide energy assessment
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Questions?
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Contact Information
David Dunn
[email protected]
ERM
3200 Windy Hill Road SE
Suite 1500W
Atlanta, GA 30339
678.486.2700
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