Transcript Document

Environmental Compliance Hot Topics
Hardwood Plywood Veneer Association
May 25, 2010
Today’s Top 2
•SPCC
•Boiler MACT
Spill Prevention, Control, and
Countermeasure (SPCC) Rule
SPCC Rule
• This impacts me if I have:
– An underground storage of greater than 42,000 gallons; or
– An aboveground storage of greater than 1,320 gallons (only
container of 55 gallons or greater are counted); and
– Due to location, could reasonably be expected to discharge
oil in quantities that may be harmful into or upon “navigable
waters” of the U.S.
– Must exclude consideration of manmade features like
dikes, equipment and/or other structures
SPCC Rule Revisions
• On November 5, 2009, EPA issued revisions to the
SPCC Rule
• The new deadline for compliance with the rule is
November 10, 2010
• Expect to see increased inspection presence from EPA
• Typical fines for not having a plan $1000-$7000
• If you have a release- escalates to the cost of
cleanup, and $$$$ in fines
Action to Take Now
• Prepare and/or Update your SPCC plan
• Follow the plan
• Remember- compliance date is
November 10, 2010
Proposed Boiler MACT
What Happened?
• On April 29, 2010 EPA issued a proposed rule that
would reduce toxic air pollutants from boilers and
process heaters
• Provisions in the rule cover- essentially all boilers
• Currently proposed rule is out for public comment.
Will this Impact Me?
• If you have a boiler-YES
• If you plan on installing a boiler –YES
Best Scenario
• You do not have a boiler
• Your existing boiler is Natural gas fired only
(exempt)
• Your existing boiler is small in size (<10
MMBTU/HR)
• You have a temporary boiler only (operates
less than 180 consecutive days)(exempt)
What’s Required for the Best Scenario
• Biennial Tune-up
– Inspect the burner-clean or replace components as
necessary
– Inspect the flame pattern-make adjustments to optimize
– Inspect the system controlling the air-to-fuel ratio, and
ensure calibrated and functioning properly
– Minimize the CO emissions following manufacturer
specifications
– Measure CO emissions before and after adjustments
• Annual Report
Most Stringent Scenario
• You are a HAPS major source
– Emit 10 tons or more of an individual HAP
– Emit 25 tons or more of combined HAPs
• Focus on reductions for carbon monoxide,
particulate, HCl, Mercury, and dioxin/furans.
• Standards are based on the fuel type for all
parameters and both fuel type and boiler design
for dioxin/furans and carbon monoxide standards.
What’s Required for the Most Stringent
Scenario?
•
•
•
•
Installation of Continuous Monitors
Installation of Controls
Energy Assessment
Initial and Annual Source Testing ($20-$30K)
Most Common Scenario
• You are not a HAPS Major but an “AREA SOURCE”
– Emit less than 10 tons per year of any individual HAP
– Emit less than 25 tons per year of any combination of
HAPs
• Boilers are greater than 10 MMBTU/HR*
*(We’re not looking at coal for this scenario)
What’s Required for the Most Common
Scenario?
• Initial and Annual Source Testing for Carbon Monoxide
($2500-$3000)
• New limits for particulate and CO for new sources of oil and
biomass
• Particulate, CO, and mercury for coal sources
• New limits for Carbon Monoxide for existing sources
– Will require “Generally Achievable Control Technology” (GACT).
– Methods, practices and techniques are commercially available
and appropriate
• Energy Assessment
Energy Assessment Requirements
• Energy assessment must be performed by
qualified personnel
• A qualified specialist is someone:
–
Who has successfully completed the Department of
Energy’s Qualified Specialist Program for all systems or
– A professional engineer certified as a Certified
Energy Manager by the Association of Energy
Engineers.
Energy Assessment Requirements
• Complete a visual inspection and review of the
boiler system.
• Establish operating parameters of the facility
energy systems
• Identify the high energy sources, conservation
measures, and potential savings
• Prepare a comprehensive report detailing the
ways to improve efficiency, the cost of specific
improvements, benefits, and the timeline
Other Changes Proposed for the Boilers
• Proposed standards vary based on the fuel type
• EPA is proposing either daily or monthly standards
• Sources w/o wet scrubbers that have particulate
and mercury emission limits will require continuous
opacity monitors
• Sources electing fuel sampling to comply with the
mercury standard are required to sample monthly
• Recordkeeping and compliance reporting
requirements
Compliance Timeline
• The final rule is to be complete by December
16, 2010.
• Compliance is required three years following
the date of publication of the final rule.
Ways to send comments…
• Email: [email protected]
• Fax: 202-566-9744
• Mail: EPA Docket Center
Environmental Protection Agency
Mailcode: 2822T
1200 Pensylvania Av., NW
Washington, DC 20460
DOCKET- ID No. EPA-HQ-OAR-2006-0790
Separate but Related Action
• EPA has proposed updated definitions of
nonhazardous wastes and fuels with respect to
boilers dictating how a unit is regulated under the
boiler MACT
• Majority of the fuels we use are clean biomass.
• If the fuels are under the control of the generator
and not contaminated will be considered nonhazardous solid waste.
• Concerns-with the treated wood, painted wood,
construction debris with contaminants, and
materials generated somewhere else.
Heather Bartlett
Principal Engineer
SLR International Corp
Address: 1800 Blankenship Road,
Suite 440, West Linn, OR 97068
Office: (503) 723-4423
Facsimile: (503) 723-4436
Email: [email protected]
Website: www.slrconsulting.com