1Boiler GACT Update Georgia AWMA Conference October 2013
2Agenda - NESHAP Anatomy Applicability and Affected SourcesSubcategoriesandEmission LimitsCompliance OptionsCompliance Assurance RequirementsSchedule and DefinitionsBoiler MACT and GACT Structure Very Similar -More/Different Requirementsfor Major Sources
3The “Final” Combustion Source Rules Promulgated again by US EPA on January 31 and February 1, 2013Includes four (4) Interrelated RulesDetailed Site-specific Action Plan Needed40 CFR 63 Subpart DDDDD – Major Source Boiler MACT40 CFR 63 Subpart JJJJJJ – Area Source Boiler GACT40 CFR 60 Commercial and Industrial Solid Waste Incineration (CISWI) Rule40 CFR 241 Non-Hazardous Secondary Materials (NHSM) Solid Waste Identification RuleTo gather data, assess applicability, determine emission limits, review compliance status/options, and implement compliance strategy
4The Solution is a Process Issue… Point ofComplianceFuel SpecSupplyLongevityCostFan ModificationCombustion ModOperating FlexibilityRetrofitAdditionPermittingCompliance TestingCostEach part of the process may be part of the answer!
5Boiler Area Source GACT Rule (Boiler GACT) GACT = Generally Available Control TechnologyApplicability - Applies to boilers that:Burn a “fuel” material, not a “waste” as defined by US EPA (“Fuel” = coal, oil, gas, biomass, tire- derived 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
6Boiler GACT Applicability Applies to HAP Area Sources“Natural Gas” Boilers are ExemptExisting Sources (Commenced Construction Prior to 6/4/10)Emission Limits Set Only for Coal BoilersFuel Oil and Biomass Units Only Subject to Work Practice StandardsFuel Switching After 6/4/10 May No Longer Trigger New Source StatusInitial Compliance Date 3/21/14 for existing sources
7Natural 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.
8Fuel Switching Improvement (e) - An existing dual-fuel fired boiler meeting the definition of gas-fired boiler, as defined in § , that meets the applicability requirements of this subpart after June 4, 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.
9Significant Improvements/Changes Many Emissions Limits are Now HigherInitial Tune-Up Deadline Delayed to 3/21/14Tune-Ups Conducted Using Primary Fuel Over the Prior 12 MonthsNatural Gas Curtailment Now Includes On-Site Fuel System FailuresTemporary, Seasonal and Limited Use Boiler RelaxationCO Emission Limit and Potential CEMS for Oil Sources RemovedNew Oil Sources Burning < 0.5 % Sulfur Are Exempt from PM LimitStart-Up & Shutdown Definitions Changed and 25% “Bright Line” RemovedPotential Hg Fuel Analysis Relaxation
10Initial and Continuous Compliance Initial Notification(s)Work Practice Standards (Tune-Ups, Energy Assessment, etc.)Periodic Performance TestsNotification of Compliance Status Report(s)Monitoring of Operating Parameters for Control DevicesStack O2 Monitor for CO LimitsStack Testing or Fuel Analysis for Hg
11Boiler GACT Compliance Existing Source Initial Compliance Deadline 3/21/14Initial Tune-Up and One Time Energy AssessmentStack Testing for Applicable Boilers Due by 9/17/14Notification of Compliance Status Report(s) (7/19/14 and/or 11/17/14)Ongoing Compliance Assurance – Testing, Monitoring, Recordkeeping and ReportingSSM Requirements ???
12Existing Coal Boilers Subject to Mercury (Hg) and CO Emission Limits Hg Compliance Based as Fuel Analysis or Stack TestingCO Compliance Typically Based Only on Stack TestingStack Testing Includes:Both Initial and Ongoing TestingTest Plan Approval by GA EPDMonitoring and Establishing Hg, CO and Capacity Operating LimitsDeveloping/ Implementing a Site Specific Monitoring PlanConduct Initial and Periodic Continuous Parameter Monitoring System Performance Evaluations – May Need a RATA!?Need to Run at Maximum Capacity – 110% Operating LimitReport Results Via New US EPA WebFire Database
13One-time Energy Assessment (EA) Required for All Existing Affected Boilers > 10 MM Btu Except Limited UseHigher Fuel Efficiency means Reduced Air Pollutants Emitted to the AtmosphereEA 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 capacityEA to follow prescribed procedures and assessor qualifications relaxed, and existing assessments can now be amended as needed to comply.
14Permitting Considerations Will Generic Placeholder Conditions Suffice?Trade-off of Generic vs. Specific Conditions ApproachTypical Issues With Agencies:Approval of Alternative Operating LimitsApproval of Multiple Compliance OptionsTesting of Worst Case Fuel for Each PollutantTitle V Versus GACT InconsistenciesVerify if Site Specific Monitoring Plan Needs to be SubmittedNeed for Multiple NOCSR SubmittalsDoes Annual Compliance Report Need Submittal
15Permitting Considerations (continued) What Permit Applications are Needed and When?< 10/25 TPY HAP Emission LimitsNew/Modified Emission Control Device Construction, Operation, and/or Operating LimitsNew Boiler(s) and/or Fuel SwitchingCompliance Option DefinitionNeed to Ensure Compliance Plan is Enforceable!Solid Fuel Variability is a Challenge/Risk for Both Area Source Status and Boiler GACT ComplianceRequest to See a “Pre-Public” Draft AmendmentOther Potential Implications– NSR, NAAQS, NSPS, GHG, etc.
16Case Study ExampleMajor HAP Source With One Large Coal Boiler, Four Natural Gas Boilers and Very Low Process HAP’sLooking at Area Source HAP Status Via Limiting Boiler HCl EmissionsLime Injection Into Baghouse or Add-On Wet ScrubberPotential Fuel Switching From CoalAddition of Fuel Oil to Manage Natural Gas “Risk”Conducting Stack Testing and Fuel AnalysisCompleting “What If” Emission TestingSetup Ongoing Hg Fuel AnalysisEvaluating Hg and/or CO Compliance OptionsFuel Vendor Contract Limits and Operating Restriction/ControlsTrade off of CO Management Versus NOx Permit LimitsDevelopment of Long Term Compliance Strategy and ScheduleOperating Costs, Impacts and UncertaintiesBuild Results Into Site Budgeting CycleOngoing GA EPD discussions/negotiations
17Boiler MACT Planning Timeline Based on January, 2016 Initial Compliance Date Now3/20149/20141/20153/20159/20151/2016Data Gathering and Initial PlanningBoiler Stack Testing CompletedEngineering Evaluation and Fuel Supplier ReviewTechnology/ Vendor Selection and DesignPermitting and Regulatory NegotiationsFabrication, Construction, Check Out and TrainingOngoing NESHAP Compliance Activities
18What’s Next for You? Assess if you have boilers/process heaters potentially subject to CISWI versus MACT/GACTIdentifyapplicable emission limits and if you can comply with these limitsGatherneeded fuel analysis and/or stack test data (develop/implement test plan)Evaluatethe need for additional emissions controls, perform economic analyses and plan for future budget cyclesDetermineif need additional monitoring systemsConsideroperational, process and/or fuel changes to reduce the regulatory burdenDevelopan overall compliance strategy and schedulePlanfor tune-ups and facility-wide energy assessment