Presentation on theme: "Adjustments to the Air Toxics Standards for Major and Area Source Boilers 40 CFR Part 63, Subparts DDDDD and JJJJJJ Summary of Final Changes, Key Highlights."— Presentation transcript:
1Adjustments to the Air Toxics Standards for Major and Area Source Boilers CFR Part 63, Subparts DDDDD and JJJJJJ Summary of Final Changes, Key HighlightsSusan Lancey, U.S. EPA Region IPresentation for AWMA New England ChapterApril 9, 2013
2Regulatory Update Overview Key Highlights Recent AmendmentsNational Emission Standard for Hazardous Air Pollutants (NESHAP) for Major Source Industrial, Commercial, Institutional Boilers and Process Heaters, 40 CFR Part 63 Subpart DDDDD (5D), amendments published 1/31/13NESHAP for Area Sources: Industrial, Commercial, and Institutional Boilers, 40 CFR Part 63 Subpart JJJJJJ (6J), amendments published 2/1/13Resources for More Information2
3The Right Standards for the Right Boilers Of 1 The Right Standards for the Right Boilers Of 1.5 million boilers in the U.S., less than 1% will need to meet numerical emission limits<1% (about 2,300) would need to meet numerical emission limits to minimize toxics. Most of these are larger boilers located at industrial facilities.~197,000covered by rules13% (about 197,000) would need to follow work practice standards, such as annual tune ups, to minimize toxics.~1.3 million boilers not covered by rules86% are clean and not covered by these rules. Many of these boilers are at places like hospitals, schools and churches.3
4Reduces Toxic Emissions and Protects Human Health Burning biomass, coal, and oil results in emissions of mercury, dioxin, furans, formaldehyde, lead, and hydrochloric acid.The technologies to reduce toxic air pollution have largely been available and in use for decades.Health effects are significant:Mercury can cause adverse effects on children’s developing brains, including effects on IQ, learning and memory.Air toxics can cause cancer and other serious health effects in adults and children.Controlling air toxics will also reduce fine particle pollution and carbon monoxide.Fine particles are linked to serious cardiovascular and respiratory effects, even premature death.Carbon monoxide reduces oxygen delivery to heart and brain, can cause angina and other problems for people with heart disease.
5Key Adjustments Area Source Boilers Final Rule Amendments Published in the Federal Register 2/1/2013Adjusted emission limitsRevised Hg and CO emission limit for new and existing large coal-fired boilersAllowing the necessary time to implement the standardsRevised the deadline for initial notification for existing area source boilers to January 20, Sources who already submitted an initial notification do not need to resubmit.Delayed the initial tune-up compliance date by two years for existing boilers until March 21, 2014Deadline for submitting the notification of compliance status (NOCS) for tune-ups is now July 19, 2014Compliance date for boilers subject to emission limits and subject to the energy assessment requirement is still March 21, 20145
6Key Adjustments Area Source Boilers Added to and refined the list of subcategoriesAdded definitions for the following, not covered by the rule:Temporary boilers used temporarily in place of another boiler while that unit is being replaced or repaired, generally over an operational period of less than 12 months, unless an extension is approved.Residential boilers intended primarily for heat or power for a residential unit of up to four families, or a single unit residence that has been converted or subdivided into apartments or condosElectric boilersRevised definition for “boiler” to clarify that process heaters are not covered by the ruleRevised definition for “hot water heater” to clarify gas, oil, and biomass hot water boilers (e.g., not generating steam) rated at less than 1.6 million Btu per hour are not covered by the ruleAdded subcategories for seasonally-operated boilers and limited-use boilers6
7Key Adjustments Area Source Boilers Reduced tune-up frequency for certain boilersRequiring tune-ups every 5 years, instead of every 2 years, for:Seasonal boilers, oil and biomass boilers which undergo a shut down for at least 7 consecutive months each 12-month period due to seasonal conditions, except for period testing (not to exceed 15 days in the 7 month shutdown)Limited-use boilers with a federally enforceable annual average capacity factor of no more than 10 percentOil-fired boilers with heat input capacity < 5 MMBtu/hrBoilers with oxygen trim systemsInitial tune-ups are not required for new boilers7
8Key Adjustments Area Source Boilers Revised energy assessment provisionsMore clearly defined the scope and clarified the energy assessment is limited to only those energy use systems located on-site associated with the affected boilersSpecify that sources that operate under certain energy managements programs, e.g., ISO energy management system, that include the affected boilers satisfy the energy assessment requirementAdded a cap (not to exceed 160 hours) for on-site technical hours for large fuel use facilities8
9Energy AssessmentsEPA developed a Summary of Energy Assessment Requirements posted at:EPA Region I is developing a self-determined list of qualified energy assessors in New England posted at:In New England, for questions about energy assessments or to request to be added to the energy assessor list, contact Patrick Bird at (617) orFor additional information on energy assessments see the DOE website:
10Key Adjustments Area Source Boilers Added compliance alternative for PM for certain oil-fired boilersNew oil-fired units may combust low sulfur oil* as an alternative method of meeting the PM emission standard (provided the boiler does not use a post-combustion control technology (except a wet scrubber) to reduce PM or sulfur dioxide emissions).Providing continuous compliance alternative for CO emission limitAllowing CO CEMS as compliance alternative*< .5 weight percent sulfur content requirements10
11Key Adjustments Area Source Boilers Reducing fuel sampling and performance testing requirements under certain circumstancesCoal boilers demonstrating initial compliance with the Hg emission limit: if Hg constituents in the fuel or fuel mixture are measured to < half of the Hg emission limit, no need to conduct further fuel analysis samplingBoilers demonstrating initial compliance with the PM emission limit: if the performance test results show that the PM emissions are < half of the PM emission limit, no need to conduct further PM emissions testingRevising provisions for dual-fuel fired boilersExisting dual-fuel fired boilers (i.e., commenced construction or reconstruction on or before June 4, 2010) that fuel switch fuels from gas to coal, biomass or oil after June 4, 2010 remain existing sources, as long as the boiler was designed to accommodate the alternate fuelNew dual-fuel fired boilers that make such a fuel switch would continue to be considered new sources11
12Key Adjustments Area Source Boilers Electronic Reporting:The final rule added electronic reporting of the notification of compliance status (NOCS) reports using the Compliance and Emissions Data Reporting Interface (CEDRI) through EPA’s Central Data Exchange (www.epa.gov/cdx) EPA is currently developing and testing a reporting template for the NOCS Report. Upon completion, expected in the fall of 2013, sources will be required to log into CEDRI and submit these reports.Electronic reporting of performance test results still required, for test methods listed on the electronic reporting tool (ERT) website (www.epa.gov/ttn/chief/ert/index.html)12
13Key Adjustments Major Source Boilers Final Rule Amendments Published in the Federal Register 1/31/2013, effective April 1, 2013Extended the compliance date for existing units to implement the standardsCompliance date for existing sources is January 31, 2016Adjusted emission limits based on new and corrected dataNew particulate matter (PM) emission limits for biomass fueled boilersNew carbon monoxide limits to address variabilityAdded an alternate CO CEMS-based limits for most subcategoriesAllowing metals emission limits as an alternative to using PM limit as a surrogate for metallic air toxicsReplaced dioxin limit with work practice standards – data shows dioxin emissions are below levels that can be accurately measured.Revising definitions, including those for “30-day rolling average” and “daily block average,” “energy assessment” and “qualified energy assessor,” and “startup” and “shutdown.”13
14Key Adjustments Major Source Boilers Added to and refined the list of subcategoriesFinal rule includes 18 subcategories of boilers based on fuel and designWork practices – Tune-up requirementRequirement to optimize CO emissions to manufacturers specifications and also to be consistent with any NOx requirementsAllow units with oxygen trim system, and gas and light liquid fuel boilers < 5 MMBtu/hr, to conduct tune-up every 5 yearsAllow delay of inspections for certain situationsWork practices – Startup & ShutdownRevised startup and shutdown definitions based on starting & stopping supplying steam rather than proposal based on operating loadRequires clean fuel at startup; and engaging control devices when coal, biomass or heavy oil is fired, except limestone injection in fluidized bed combustion boilers, dry scrubber, fabric filter, SNCR, SCR, which you must start as expeditiously as possible.14
15Key Adjustments Major Source Boilers Revised energy assessment provisionsMore clearly defined the scope and clarified the energy assessment is limited to only those energy use systems located on-site associated with the affected boilersSpecify that sources that operate under certain energy managements programs, e.g., ISO energy management system, that include the affected boilers satisfy the energy assessment requirementAdded a cap (not to exceed 160 hours) for on-site technical hours for large fuel use facilitiesRevised definition for “hot water heater” to clarify gas, oil, and biomass hot water boilers (e.g., not generating steam) rated at less than 1.6 million Btu per hour are not covered by the rule15
16Key Adjustments Major Source Boilers Compliance monitoring - increased flexibilityRemoved requirement for large biomass units to install PM CEMSReplaced requirement for large coal units to install PM CEMS with requirement to install a PM CPMS but have option to use PM CEMSAllow the use of SO2 CEMS as operating limit for demonstrating continuous compliance with the HCl limitContinue to allow units burning clean gases to qualify for work practice standards instead of numeric emission limitsRemoved hydrogen sulfide (H2S) fuel specification from the rule16
17Key Adjustments Major Source Boilers Electronic Reporting:The final rule added electronic reporting of ongoing compliance reports using the Compliance and Emissions Data Reporting Interface (CEDRI) through EPA’s Central Data Exchange (www.epa.gov/cdx), once EPA has developed the specific reporting form. Electronic reporting of performance test results and CEMS relative accuracy test audit (RATA) data still required, for test methods listed on the electronic reporting tool (ERT) website (www.epa.gov/ttn/chief/ert/index.html)17
18For Additional Information For Sources in New England: Susan Lancey, Patrick Bird, For area source boilers: For major source and area source boilers:
201 An existing dual-fuel fired boiler meeting the definition of gas-fired boiler that meets the applicability requirements of subpart JJJJJJ 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.
212 A new or reconstructed dual-fuel gas-fired boiler that meets the applicability criteria of subpart JJJJJJ after June 4, 2010 due to a fuel switch from gaseous fuel to solid fossil fuel, biomass, or liquid fuel is considered to be a new source.3 New oil-fired boilers that combust only oil with no more than 0.50 weight % sulfur or a mixture of 0.50 weight % sulfur oil with other fuels and that do not use a post-combustion technology (except a wet scrubber) to reduce PM or SO2 emissions are not subject to the PM emission limit.
23Emission Limits for Existing Major Source Boilers Subcategory#UnitsLimits in 2011 Final Rule, lb/MMBtu unless notedLimits for Reconsideration Final Rule, lb/MMBtu, unless notedHg, lb/TBtuHClPMCO, ppmD/F, ng/dscm(CO CEMS-based)D/FCoal stoker3914.6Solid fuel subcat.0.0350.0392700.0035.70.0220.040160(340)Work practiceCoal fluid. Bed35820.002130(230)Coal PC1900.004(320)Biomass wet stoker—revised subcategory3044900.0050.0371,500(720)Biomass fuel cell1469040.0201,100Biomass fluid. Bed244300.020.11470(310)Biomass dutch oven/pile burner—revised subcategory0.20.28770(520)Biomass susp./grate183,5000.442,800(900)Biomass suspension—revised subcategory470.0512,400(2,000)Biomass dry stoker--new subcategory740.32460Heavy liquid-new subcategory3203.40.0075102.00.00110.062Light liquid-revised subcategory5810.0079Gas 2129130.00170.0439.00.087.90.0067Non-cont. liquid0.780.27New and existing small (<10 MMBtu/hr) units, natural gas-fired units, metal process furnaces, units combusting other clean gases,and limited use units will be subject to work practice standards.
24Emission Limits for New Major Source Boilers SubcategoryLimits in 2011 Final Rule, lb/MMBtu unless notedLimits for Reconsideration Final Rule, lb/MMBtu, unless notedHg, lb/TBtuHClPMCO, ppmD/F, ng/dscmHg, lb/Tbtu(CO CEMS-Based)D/FCoal stoker3.5Solid fuel subcat.0.00220.001160.0030.800.022130(340)Work practiceCoal fluid. bed180.002(230)Coal PC12140(150)Biomass wet stoker—revised subcategory1600.0050.030620(390)Biomass fuel cell4700.020910Biomass fluid. Bed2600.020.0098230(310)Biomass dutch oven/pile burner0.20.0032330(520)Biomass susp./grate1,5000.0261,100(900)Biomass suspension2,400(2,000)Biomass dry stoker460Heavy liquid0.210.001330.480.013Light liquidNew gas 27.90.00170.00670.08New non-cont. liquid0.78510.023New and existing small (<10 MMBtu/hr) units, natural gas-fired units, metal process furnaces, units combusting other clean gases,and limited use units will be subject to work practice standards.
25Emission Limits for Area Source Boilers Subcategory2011 Final Rule Emission LimitsReconsideration Final Rule Emission LimitsHg, lb/TBtuCO, ppmPM, lb/MMBtu3% oxygenNew Coal≥ 10 MMBtu/h4.84000.03 (≥ 30 MMBtu/h)0.42 (10 to 30 MMBtu/h)22.0420No ChangeNew Biomass-0.07 (10 to 30 MMBtu/h)New Oil0.03Existing Coal(600 units)< 10 MMBtu/h(3,100 units)Existing Biomass(168,000 units)Existing Oil(11,000 units)New and existing small (<10 MMBtu/h) coal-fired boilers, new and existing biomass-fired boilers, and new and existing oil-fired boilers are subject to a biennial tune-up requirement.New and existing seasonal boilers, limited-use boilers, oil-fired boilers with heat input capacity ≤ 5 MMBtu/h, and boilers with an oxygen trim system are subject to a 5-year tune-up requirement.Existing coal-fired, biomass-fired, or oil-fired boilers with heat input capacity ≥ 10 MMBtu/h (not including limited-use boilers) are subject to a one-time energy assessment requirement.
26Emission Limits for Existing CISWI Units Pollutant (units) 1CISWI Subcategories2Incinerators3Energy Recovery Units - Liquid/GasEnergy Recovery Units - Liquid/Gas3Energy Recovery Units - SolidsWaste-burning kilnsSmall, Remote Incinerators32011 Final RuleReconsid. FinalHCl (ppmv)29140.450.20 (biomass units) / 13 (coal units)253.0 220300CO (ppmv)361735490 (biomass units)/59 (coal units)260 (biomass units) / 95 (coal units)110110 (long kilns) /790 (preheater/precalciner) 2064Pb (mg/dscm)0.00360.0150.0960.014 (biomass units) /0.14 (coal units) 0.00260.0142.72.1Cd (mg/dscm)0.023(biomass units) / (coal units)0.00140.610.95Hg (mg/dscm)0.00540.00480.00130.0024(biomass units) /0.016 coal units0.00790.0110.00570.0053PM, filterable (mg/dscm)3425011 (biomass units) / 160 (coal units) 6.24.6230270Dioxin, Furans, total (ng/dscm)2.90.350.52 (biomass units) / 5.1 (coal units) 0.21.31,2004400Dioxin, Furans, TEQ (ng/dscm)0.130.320.0590.12 (biomass units) /0.075 (coal units) 0.0070.07557180NOx (ppmv)5376290 (biomass units)/340 (coal units)290 (biomass units) / 340 (coal units)540630240190SO2 (ppmv)117206.2 (biomass units)/650 (coal units)7.3 (biomass units) / 650 (coal units)38600420150Emission Limits for Existing CISWI UnitsAll emission limits are measured at 7% oxygen.Number of units in each subcategory: 27 incinerators; 6 ERUs-liquid/gas; 22 ERUs-solids (18 biomass/4 coal); 23 waste-burning kilns; and, 28 small, remote incinerators.3 Emission limits did not change from final to reconsideration proposal for this subcategory.26
27Emission Limits for New CISWI Sources Emission Limits for New CISWI UnitsPollutant (units) 1CISWI SubcategoriesIncinerators2Energy Recovery Units - Liquid/GasEnergy Recovery Units - Liquid/Gas2Energy Recovery Units - SolidsEnergy Recovery Units - SolidsWaste-burning KilnsSmall, Remote Incinerators22011 Final RuleReconsid. FinalReconsid. Final21011 Final RuleReconsid. FInal Reconsid. FinalHCl (ppmv)0.091140.450.20 (biomass units ) /13 (coal units)3.0200CO (ppmv)12173635160 (biomass units)/46 (coal units)240 (biomass units ) /95 (coal units)9090 (long kilns) /190 (preheater/ precalciner)13Pb (mg/dscm)0.00190.0150.0960.00310.014 (biomass units) /0.14 (coal units) 0.00260.0140.262.0Cd (mg/dscm)0.00230.023(biomass units) /(coal units)0.00140.610.67Hg (mg/dscm).0022 (biomass units) /0.016 (coal units)0.00620.00370.0035PM, filterable (mg/dscm)181102505.1 (biomass units) /160 (coal units)2.52.2230270Dioxin, Furans, total (ng/dscm)0.0520.58(no limit)0.0680.52 (biomass units) / 5.1 (coal units) 0.0900.511,2001,800Dioxin, Furans, TEQ (ng/dscm)0.130.0020.0930.0110.076 (biomass units) /0.075 (coal units) 0.00300.07531NOx (ppmv)2376290 (biomass units)/340 (coal units)290 (biomass units) / 340 (coal units)200 78170SO2 (ppmv)117206.2 (biomass units)/650 (coal units)7.3 (biomass units) / 650 (coal units)38281.2Emission Limits for New CISWI SourcesAll emission limits are measured at 7% oxygen.2 Emission limits did not change from final to reconsideration proposal for this subcategory.27