Presentation on theme: "Boiler Area Source Rule"— Presentation transcript:
1Boiler Area Source Rule Kenya Stump,Environmental Assistance Branch Manager, DCAA Program of the Kentucky Division of Compliance Assistance
2Who We Are? Environmental Compliance Assistance Program (ECAP) Located in Division of Compliance Assistance (DCA)Provides assistance on air, water, and wasteDetailed assistance available to small businessesKenya Stump, Chad Von Gruenigen, & Emily Ohde
3Terminology?The “Boiler MACT” covers boilers and process heaters located at major sources of hazardous air pollutants (HAP). “ Subpart DDDDDThe “Boiler Area Source Rule” covers boilers at area sources of HAP. Subpart JJJJJJRule does NOT apply to boilers that are gas-fired (approximately 1.3 million units, or 87% of all area source boilers) or process heaters.Most units that are covered by this rule will be required to conduct a tune-up every other year and will not have to install pollution control equipment.Boilers burn fuel to produce steam that is used for heat or electricityProcess heaters heat raw or intermediate materials during an industrial processA major source is a facility that has the potential to emit 10 or more tons per year (tpy) of any single HAP or 25 tpy or more of any combination of HAP.An area source is a facility that has the potential to emit less than10 tons per year (tpy) of any single HAP or less than 25 tpy of any combination of HAP.HAP: Hazardous Air PollutantKyDAQ: Division for Air QualityEPA: Environmental Protection Agency
4Why Do We Have These Rules? These rules satisfy Clean Air Act requirements for air toxicsEPA is legally bound to issue these rulesDeveloped under Clean Air Act sections 112 and 129Require EPA to set technology-based standards for toxicsReflect levels achieved by best-performing existing sourcesGenerally may set less stringent standards for boilers at area sources.
5What if Sources Need Help? DCA and DAQ are providing ongoing compliance assistanceU.S. Dept. of Energy (DOE) and the U.S. Dept. of Agriculture (USDA)DEP and UK Compliance Assistance PartnershipKPPC
6Questions to Answer First! Do I have boiler?Is my boiler subject to the rule?Am I a major source for HAPs?What size are my boilers?What type of boiler do I have?What fuel do I combust?What are my installation dates on my boilers?
7Who is affected by the rules? Owners or operators of an industrial, commercial, or institutional boiler or process heaterBoiler means an enclosed device using controlled flame combustion and having the primary purpose of recovering thermal energy in the form of steam or hot water.Process heater means an enclosed device using controlled flame, and the unit's primary purpose is to transfer heat indirectly to a process material (liquid, gas, or solid) or to a heat transfer material for use in a process unit, instead of generating steam.
8Items Not CoveredGas-fired boilers (a boiler that primarily burns gas is still considered a gas-fired boiler even if it also burns oil or other liquid fuel during periods of gas curtailment, gas supply interruption, startups, or for periodic testing not to exceed 48 hours during any calendar year)Boilers that burn solid waste (these boiler are subject to incinerator standards)Hot water heatersWaste heat boilers(heat recovery steam generators)Temporary boilersResidential boilersElectric boilersElectric utility steam generating units (EGUs)
9Existing Or New?New source means that you commenced construction or reconstruction of the boiler or process heater after June 4, 2010 and you meet the applicability criteria at the time you commence construction.Existing source means you commenced construction or reconstruction of the boiler or process heater on or before June 4, 2010.
10Check your permit for your classification. Are you an area source?You must be an area source for Hazardous Air Pollutants (HAPs).Check your permit for your classification.CLICK The area source boiler rule is applicable to those sources that operate a industrial, commercial, or institutional boiler located at area sources of Hazardous air pollutants. There are more than 183,000 area source boilers used to generate heat in the United States. The individual emissions from these units may be small, but the total emissions from all boilers is significant. Air pollution from boilers includes particulate matter (PM 2.5), carbon monoxide, hydrochloric acid, mercury (from coal-fired boilers), and trace amounts of other heavy metals.If you do not know how you are classified, the quickest way is to consult your air permit to see how you are classified. For sources that do not have an air permit, you must determine your potential to emit. Division of Compliance Assistance staff can assist with this assessment. "Area" sources are those sources that emit less than 10 tons annually of a single hazardous air pollutant or less than 25 tons annually of a combination of hazardous air pollutants.CLICK: For example, Residential boilers are not covered by the rule, if located in dwellings of four or fewer family units, including boilers located in dwellings of four or fewer family units located at institutional facilities (e.g., universities) or commercial/industrial facilities (e.g., farms) or in single unit dwellings converted to apartments.Hot water boilers (e.g., not generating steam) rated at less than 1.6 million Btu per hour are not covered by the rule, under the revised definition of hot water heater for gas, oil, and biomass boilers.
11Determining your requirements Emission limitationsEnergy assessmentsTune-up requirementsNow that you know the category, fuel type, and size of your boiler, you can now determine what requirements are applicable to your source.CLICK In general there are three types of requirements.CLICK You may click in the hyperlink in the yellow highlighted box to determine which of the three requirements are applicable to your source.It is important to note that Tune-ups are required every five years instead of every two years for seasonal use units, limited use units, oil-fired units with heat input capacity equal to or less than 5 MMBtu/hr and units with oxygen trim systems.Click here to see which of the threerequirements are applicable to your source.
12Important Compliance Dates Existing: March 21, 2014New: May 20, 2011 or upon startupCLICK Existing sources must be in compliance by March 21, 2014CLICK: If you start up a new affected source on or before May 20, 2011, you must achieve compliance with the provisions of this subpart no later than May 20, If you start up a new affected source after May 20, 2011, you must achieve compliance with the provisions of this subpart upon startup of your affected source.
13Important Reports Initial Notifications Notification of Compliance Status Reports (NOCS)Requires electronic submittalUp to three could be requiredTestingTune UpEnergy AssessmentCLICK Existing sources must be in compliance by March 21, 2014CLICK: If you start up a new affected source on or before May 20, 2011, you must achieve compliance with the provisions of this subpart no later than May 20, If you start up a new affected source after May 20, 2011, you must achieve compliance with the provisions of this subpart upon startup of your affected source.
14For More Information EPA Major Sources Division for Air Quality Brian ShragerEPA Area SourcesJim EddingerDivision for Air QualityJim Eubankext. 4419Division of Compliance AssistanceKenya Stump, Emily Ohde, or Chad Von GruenigenWebsites:
15Boiler MACT Tune-up Requirement Subpart JJJJJJ – NESHAP for area sourcesSubpart DDDD- NESHAP for major sourcesMy name is Chad Von Gruenigen and yes I was born and raised in Kentucky.Chad Von GruenigenCompliance Assistance Specialist
16The elephant in the room. I would like to reiterate the Environmental Protection Agency and the Division of Compliance Assistance are totally separate. EPA is federal and DCA is state but the differences don’t end there we do separate things. DCA is here solely to assist you just as the KFIA is here to assist you.Now I bet you’re thinking why me and what’s the point.
17Boiler MACT December 20, 2012 the EPA finalized the Boiler MACT. This means the rules officially take affect.The good news is there is time.You may have been hearing a lot of talk about the Boiler MACT. Well until December 20th, 2012 the rules were not finalized.The EPA after some labor pains has birthed the Boiler MACT and don’t try to claim it isn’t yours.
18What is a NESHAP?National Emission Standards for Hazardous Air PollutantsBasically it is an industry standard the EPA has established.
19What is a MACT? Maximum Achievable Control Technology. The Boiler MACT effects major and area sources for hazardous air pollutants (HAP)Basically it is an industry standard the EPA has established.
20Now what are major and area sources? Major source- emits 10 tons per year of any single HAP or 25 tpy of any combined HAPs.Area source- any stationary source of HAPs that is not a major source.If you don’t know what you are please refer to your air permit.Chances are most of you in this room have an area source facility.
21Whose not subject? Any gas-fired boiler Hot water heaters Temporary boilers (used for less than 12 months)Residential boilersElectric boilersWaste heat boiler (heat recovery steam generators)Boilers used as control devices for other standardsResearch and development boilersBoilers subject to other NESHAP standards.Don’t try to claim you have a research and development boiler when your researching and developing a way to get around this rule.
22Is a tune-up required? >10 MM Yes * Yes <10 MM Heat Capacity ( Btu/Hr)ExistingBiomassUnitsNew (June 4th 2010)Seasonalor limited use units>10 MMYes *Yes<10 MMThe * indicates, if boiler is equipped with an oxygen trim system then tune-ups are only required every 5 years.What is an oxygen trim system? Basically oxygen is measured and the damper is adjusted automatically to optimum operating range.* Provided the boiler uses an oxygen trim system that maintains an optimum air-to-fuel ratio,otherwise tune-ups required biennially.
23What is Seasonal or Limited Use? Seasonal- boiler that undergoes a shutdown for at least 7 consecutive months each 12 month period.Limited Use- boiler that burns any amount of solid or liquid fuels and has a federally enforceable average annual capacity of no more than 10 percent.
24How frequently must I perform a tune-up If the boiler is equipped with an oxygen trim system, is a seasonal or limited use every 5 years.Boilers without an oxygen trim system, aren’t seasonal or limited use every 2 years.What is an oxygen trim system?Basically a device that detects the amount of oxygen and adjusts the damper for optimum operating efficency.
25Initial Notification of Applicability Submit no later than January 20, 2014This one is easy and it’s hardcopy!Now that you know if the rule applies and you know the frequency of the tune-up, you must submit the initial notification of applicability.And if the rule doesn’t apply to you it doesn’t mean a tune-up isn’t a good idea.An example notification is on a website I will direct you to at the end of this slideshow.
26Where do I send the initial notification form? This one is a hard copy.Mail to:Kentucky Division for Air QualityProgram Planning BranchAttn: Jim Eubank200 Fair Oaks Lane, 1st FloorFrankfort, Kentucky 40601Jefferson County (only for Jefferson Co. facilities)Louisville Metro Air Pollution Control DistrictI will direct you to the website where this form and most materials you need are located at the end of this slideshow.
27Why perform a tune-up? The overall savings outweigh the initial costs. Less biomass burned = less time, money and product wasted.A tune-up extends the life of your boiler.Not to mention it’s a requirement.Besides tune-ups being a requirement they are also beneficial.Much like a car a boiler does not function properly if it isn’t maintained.If you replace your car filter it’s likely to run better, save you money in fuel costs and extend the life of the car. If it’s a truck it will have a longer life doing work on the farm.A boiler that has not had a tune-up won’t function properly and may burn more biomass with less efficiency costing time, money and wasted product. (Don’t burn the money tree).What this made me think of was chopping wood, if a tune-up would make my stove run more efficiently meaning I would have to chop 1 less rick of wood, I would most definitely perform a tune-up.Now some of you may see the wood you burn as waste and something that’s not costing you anything to burn. Well you can probably think of other uses for the wood waste you save. You could probably even sell what you don’t need, maybe you’re already doing that.
28The idea behind the boiler MACT is to prevent things like this from happening. Going back to the vehicle comparison, yes a vehicle run with this repair but it’s not likely to run well let alone efficiently.
29What if I already perform a tune-up If you conduct the tune-up early the next tune-up is due no later than 25 months or 61 months as applicable. (This is the same time frame allowed for new boilers)If the boiler is shutdown the tune-up must be conducted within 30 days of start up.Chances are you already perform tune-ups just to keep your boiler functioning properly.That means you’re getting good gas mileage or a phase I’ve coined, “wood burnage”
30Who can perform a tune-up? There is no certification requirement to conduct a boiler tune-up.You will likely need someone that has boiler experience.The EPA suggestions adjustments and modifications should be complete by qualified and experienced technicians.You may even be able to perform a tune-up. Use the manufacturer specifications where available.There are guidance documents for the tune-up which I will direct you to at the end of the slideshow.
31Before you begin Preparation Make as-found observations Identify intentAssemble boiler informationIdentify environmental regulationsIdentify measurement locationEstablish tune-up timeframe etc.Make as-found observationsAssemble: boiler drawings, data sheets, burner drawings, combustion control information.Observations: combustion and control components, examine burner, boiler conditions (maybe even take pictures)
32Document tune-up As-found conditions Post tune-up conditions Modifications and repairs completedRecommended investigations and modificationsIdentified shortcomings of equipment
33Step 1Inspect the burner / boiler and clean or replace components necessary.As I go through these steps some may not apply directly to your boiler just follow the steps as closely as possible where applicable.This is also a general overviewThis will likely be the most time consuming and work intensive part of the process.Removal of a small amount of soot can make a huge heating efficiency difference. Emily will mention this in her slideshow.
34Step 2Inspect the flame pattern and adjust the burner to optimize the flame pattern.A hot water heater is basically a small boiler. (Not regulated)A hot water heater is exempt this is just an example.Looks like someone might be taking a cold shower.
35Step 3Inspect the air-to-fuel ratio to ensure it is calibrated and functioning properly, if such a system is installed on the boiler.This is an example of someone conducting the testing on a hot water heater, once again this is not going to be a requirement for hot water heaters.No matter what fuel is being burnt, improper combustion effects carbon monoxide and oxygen levels.(if you don’t have boiler specs there are expected operating ranges available, which I will direct you to at the end of the slideshow.)Now I bet your asking, “where can I get one a flue gas meter and more importantly how much is it?”This can even be done on a hot water heater as shown in the picture
36Where do I get a meter?For around $1,800 dollars you can get everything you need.All you need is a meter that will measure oxygen and carbon monoxide.This model even includes 4 AA batteries. You know it’s expensive if it includes batteries.Now don’t panic. We got you covered DCA, the University of Kentucky are working on a partnership that should provide UK with a meter to assist industries such as yourself.
37Step 4 Optimize total emissions of carbon monoxide. This can even be done on a hot water heater as shown in the picture
38Step 5Measure the effluent stream of carbon monoxide and oxygen before and after adjustments.This is an important step to show before and after adjustments.This can even be done on a hot water heater as shown in the picture
39Step 6Maintain a report containing information highlighted in 40 CFRThis log will contain all of the information outlined in the previous steps.Currently there is an example tune-up guidance and example recordkeeping form which would be good to follow and when conducting a tune-up. I will direct you to that example form at the end of this slideshow.However the submittal of the initial tune-up information will now be electronic and it may be different from the existing document.This can even be done on a hot water heater as shown in the picture
40Initial Tune-up Compliance Complete no later than March 21, 2014Deadline for submitting the notification of compliance status (NOCS) July 19, 2014(This submittal will be electronic)These dates may seem far into the future but you know it will be here before you know it.
41“Yes I said the notification of compliance status (NOCS) is electronic Compliance and Emissions Reporting Interface (CEDRI)Central Data Exchange (CDX)The form isn’t ready yet but it should be available fall 2013
42What questions can you expect? Information about the tune-up conducted as described above. (comments / corrective actions)Carbon Monoxide (CO) levels (ppmv)Oxygen (O2) (%by volume)Fuel used or delivered 12 months preceding tune-upThese dates may seem far into the future but you know it will be here before you know it.
43Initial Tune-up Compliance Maintain records of dates and procedures of each boiler tune-up and the fuel used by the boiler.Required information highlighted in 40 CFRMaintain records on-site for the first two yeas and keep record for at least five years.Maintain records! This is a major part of any successful business.Again a useful document is the tune-up guidance and example recordkeeping form.
44Subsequent Tune-up Compliance Conduct the same performance tune-up as the initial tune-up in 40 CFRComplete the compliance certification for each tune-up. Currently this does not have to be submitted but now that submittal is electronic this will likely be a required submittal.40 CFR I have summed up in the steps above.
45Where do I go for help?Type in Boiler Compliance in Google and click boiler compliance at area sources.Type in Boiler MACT in Google and click on industrial/ commercial/ industrial boilers and process heaters
46Useful Materials Implementation tools Initial Notification of Applicability for AREA SourcesTune-up Guidance and Example Recordkeeping From- AREA SOURCESSmall Entity Compliance Guide for Area Source BoilersBoiler Tune-up Guide for Owners &OperatorsBoiler Tune-up Guide for Technicians.
47Where do I go for help?Don’t forget the Division of Compliance Assistance (DCA) is here for you.Call: (800)
49Who must conduct an Energy Assessment? ≥ 10 MMBtu/hrExisting*BiomassCoalOilYESWho must conductCompliance Date* Commenced construction or reconstruction prior to June 4, 2010When: March 21, 2014Area Source of HAPs
50Exceptions…♦ Limited-use units (exemption) ♦ Facilities that have already completed Energy Assessment meeting the rule requirements on or after 1/1/2008 (satisfies requirement) ♦ Facilities operating under Energy Management System compatible with ISO that includes affected units (satisfies requirement)
51Not Required? Opportunities!! Energy Savings Better Operating PracticesSustainabilityHealth & SafetyFinancial Savings!If your facility is not required to conduct the one time energy assessment, I am sure you are asking CLICK where is the door. But you might not want to leave just yet because even if the facility is not required to conduct the entire energy assessment and follow the protocols, there are still good reasons to conduct an energy assessment or at least portions. CLICK. There are multiple benefits that come from energy assessments including energy savings, implementing better operating practices, sustainability opportunities, and ensuring health and safety, and the one that may be the biggest motivator CLICK the financial savings for the facility$$$$
52Achieving Savings Locating and eliminating leaks Adjust operational procedures/equipmentIdentify recovery opportunitiesConserving flash steamReturning condensateEnergy efficiencyCombined Heat and Power systemsSome of the ways in which energy and financial savings may be achieved include locating leaks, correcting any applications, identifying recovery opportunities, maximizing efficiency, installing combined heat and power systems
53Qualified Energy Assessor DefinitionsQualified Energy AssessorBoiler SystemEnergy Use System
54Qualified Energy Assessor Combustion ManagementThermal energy recoveryBlowdown thermal energy recoveryResource selection (fuel switching & applied vs direct-fired)Insulation issuesSteam trap and leak mgtCondensate recoverySteam end-use mgtDemonstrated capabilities to evaluate opportunities for steam generation and major energy use systems including:
55Qualified Energy Assessor Assessment activities, data analyses, and report preparationFamiliarity with O&MSystem improvementCogeneration systemsIndustry specific end-useCapabilities & Knowledge including:QEA may be a company employee or outside specialist
56Directly connected to & serving the energy use system Boiler SystemBoiler and associated componentsFeedwater systemsCombustion air systemsFuel systems (includingburners)Blowdown systemsCombustion control systemsSteam systemsCondensate return systemsDirectly connected to & serving the energy use system
57Located on the site of the affected boiler Energy Use SystemProcess heating; compressed air systems; machine drive (motors, pumps, fans); process cooling; facility heating, ventilation, and AC; hot heater system; building envelope; lightingOther systems that useSteam, hot water, or electricity(provided by the boiler)Only systems using energy clearly produced by affected boiler(s)Located on the site of the affected boiler
58The Requirements Visual inspection of boiler system Evaluation of operating characteristicsInventory of energy consuming systemsReview of plans, operations, and maintenanceEnergy Conservation MeasuresEnergy savings from conservation measuresComprehensive reportIf the facility is required to conduct the one time energy assessment, there are seven key requirements which are required to be conducted by a qualified energy assessor
59Duration Requirements Annual Heat Input (Trillion Btu/yr)Annual Input in 8760 hoursLength of assessment not to exceedℓ…On-site energy use systems that account for the following % of the energy product from affected boiler< 0.3< 34.28 hoursAt least 50%0.3 – 1.024 hoursAt least 33%> 1.0114.224 hours for 1st TBtu +8 hours for each additional TBtu*At least 20%*Not to exceed 160 hoursℓOn-site technical labor hours
601. Visual Inspection Cracks Corrosion Leaks Insulation Visual examinationNo examination is more valuable than the one performed using the eyes of an experienced inspector. In fact, many of the methods simply provide an enhanced or volumetric view for the eyes of the inspector to analyze. Direct visual examination is the key to ensuring welding operations are performed in accordance with the governing codes and procedures. Visual examination is performed during in-service examinations of piping, vessels, tanks, boilers, and other equipment to detect a wide range of conditions and may be supplemented by mechanical measurements, photography, magnification, or chemical etching or response methods.is often used to detect mechanical damage or wear due to harsh service conditions experienced by certain boiler typesMany inaccessible areas can be visibly examined using one of several remote viewing devices available to our personnel such as videoprobes, zoom cameras, or camera crawlers.Do you see any blistering or pock marks? This is an indication that there is corrosion due to condensation of flue gasses. This condensation creates an acidic solution that can eat away at your furnace and tubes. Soot is a byproduct of combustion and can seriously reduce heat transfer in your boiler. Poor heat transfer means poor efficiency. Another way to check on sooting is to install a stack thermometer. When the stack temperature rises above normal operating conditions you can be fairly certain it is time to clean the tubes.Also check the gaskets used to seal the boiler up. If they are at all suspect, replace them. It is easier to do this now than later when you are firing the boiler.
612. Evaluation of Operating Characteristics Specifications of energy use systemsOperating and maintenance procedures, &Unusual operating constraints
623. Inventory of energy consuming systems Power Generation UnitHeat Recovery SystemElectric ChillerAbsorption ChillerHeatingCoilBoilerExhaustEpEecEpguFpguFbFmQbQFQFCQrhQhQcQecQacEEgridBuilding
634. Review of plans, operations, and maintenance Architectural and Engineering plansFacility wide operation & maintenance proceduresLogs & fuel use
645. Energy Conservation Measures 6. Energy SavingsComprehensive tune-ups and correcting excessive air losses, high stack temperatures, and excessive smokingCan result in fuel savings up to 20%.Installing insulation on hot water and steam pipes over 120FEnsure excessive heat is not lost in transmissionCombustion efficiency analysesA 3% decrease in flue gas O2 typically produces boiler fuel savings of 2%.Reset hot water supply temperatureFor every 11 deg F that the entering feed-water temperature is increased, the boiler’s fuel use is reduced by 1%.
655. Energy Conservation Measures 6. Energy SavingsAn upgraded boiler maintenance program including optimizing air-to-fuel ratio, burner maintenance, and tube cleaningCan save about 2% of a facility’s total energy use with an average simply payback of 5 monthsEvery 40 deg F reduction in net stack temperature (outlet temperature minus inlet combustion air temperature is estimated to save 1% to 2% of a boiler’s fuel use.Removing a 1/32 inch deposit on boiler heat transfer surfaces can decrease a boiler’s fuel use by 2%; removal of a 1/8 inch deposit can decrease boiler fuel use by over 8%.List of cost effective energy conservation measures that are within the facility’s control
665. Energy Conservation Measures 6. Energy SavingsInstallation or conversion to combined heat and power systems (co-generation)Use heat generated instead of heat dissipation to cooling towers (wasting energy)Use for comfort/space heating or process heat, replacing other energy inputsWaste Heat = Power (economizer)Combined heat and power (CHP), or co-generation, is the simultaneous generation of usable heat and electricity. Conventional power generation plants usually dissipate the heat generated using cooling towers, wasting a considerable amount of energy. Combined heat and power systems consider outputs in thermal terms instead of electrical. With CHP, this heat is used for domestic or industrial space heating or for process heat.
677. Comprehensive Report Improve efficiency Costs and Benefits of specific improvementsTime frame for recuperation of investments
68ResultsEncouraged but not required to use results of the energy assessment to increase energy-efficiency and cost-efficiency of the boiler systemActivities that instill energy efficiencyControl over heat & power resourcesIncreased reliability of operationsGreater productivity & more revenue
69Cost? Varies dependent on system(s) extent and complexity Conduct energy assessmentHire a consultant (as needed)Improvements:Payback within 2 years or lessA simple boiler-system audit costs about $2,000, while a complete site audit, depending on the number of steam traps, the amount of other equipment, and the size of the plant, can cost several thousand dollars
70ProvidersDOE's Clean Energy Application Centers (CEACs) will offer technical assistance, site visits to discuss strategies, and provide information on potential funding and financing opportunities to assist with CHP, boiler tune-ups and/or energy assessments.KPPCPrivate CompanyUniversitiesInquiry……a qualified energy assessor to conduct the one-time energy assessment in accordance with the boiler MACT for a biomass boiler.
71Energy Assessment Completed Now What? Submit Notification of Compliance StatusIf the facility must demonstrate compliance with emission limits:Different NOCS (has checkbox for EA NOCS)EL NOCS submitted within 60 days of completionDue By: July 19, 2014
72Resources Emission Reductions: How to, Benefits, and Costs EPA Air Toxics Web Site: Industrial/Commercial/Institutional Boilers and Process HeatersEPA Boiler Compliance at Area SourcesEPA Combined Heat and Power PartnershipDOE Boiler MACT Technical Assistance
73Any QuestionsContact Information: Division of Compliance Assistance