Boiler Sheltered Initiative Web cast May 15, 2008 May 29, 2008

Introduction and Logistics Presenters Barb Johnson and Ryan Hamel – K-State SBEAP Webcast logistics You will not be able to speak during the seminar Ask questions/comments by typing them into the long text box at the bottom of the screen and pressing enter. Slides will advance automatically. Questions? Call the help-desk at 785-532-7722

Overview Clarify EPA vs KDHE vs OSHA vs KDOL Small Business Environmental Assistance Program (SBEAP) Types of Kansas air regulations KDHE boiler sheltered initiative Emergency generator Future additions or modifications

Regulatory Agencies EPA – federal KDHE - state OSHA - federal Bureau of Air & Radiation Air emissions OSHA - federal KDOL - state Industrial Safety & Health Section Boiler Safety Inspection Unit Local ordinances

Small Business Environmental Assistance Program Similar program in every state-Clean Air Act req’d Provides air and haz waste-focused technical assistance to Kansas small- and medium-sized businesses/institutions Permitting and reporting requirements Regulatory compliance Emissions/waste reduction This is a program we operate under a specific contract with the Kansas Department of Health and Environment.

Where SBEAP fits… Kansas State University Engineering Extension Pollution Prevention Institute (PPI) Small Business Environmental Assistance Program (SBEAP)

Air Regulations

Types of Air Regulations KAR Air construction approval/permit Operating permit NSPS (New Source Performance Standards) adopted by reference PSD (Prevention of Significant Deterioration) NESHAP (National Emission Standard for Hazardous Air Pollutants) / MACT (Maximum Achievable Control Technology) adopted by reference

Potential to Emit (PTE) Basis for determining permitting requirements Represents the source’s maximum capacity or worst case scenario emissions The maximum amount of air pollution your facility can emit if: Each process operated at 100% of its capacity All equipment is operating 24/7 (8,760 hrs/yr) Materials that emit the most air pollution are processed 100% of the time No pollution control equipment is used

Calculating PTE Calculation methods Emission factors Material balances Other approved methods Computer programs Industry-specific emission factors Approved by KDHE on an individual basis

PTE Emission factors are used for calculating boiler emissions Manufacturer’s emission factors are best AP-42 is a compilation of factors for specific processes accepted by EPA www.epa.gov/ttn/chief/ap42/index.html Emission factors software and tools www.epa.gov/ttn/chief/efpac/efsoftware.html

Expedited Approval If your PTE exceeds these thresholds, then you’ll need an expedited approval: Source: What is the Kansas Air Quality Act? - www.sbeap.org/publications/airqual.pdf

Expedited Permit If your PTE exceeds these thresholds, then you’ll need an expedited permit: Proposed construction projects at new facilities and modifications at existing facilities need to be evaluated for the need for a construction permit or approval. Source: What is the Kansas Air Quality Act? - www.sbeap.org/publications/airqual.pdf

Operating Permit (Class I) Count PTE of all emission sources Required if PTE exceeds these thresholds: 100 tons per year NOX, SOX, PM10, VOC, CO 10 tons per year of any single hazardous air pollutant (HAP) 25 tons per year of combined HAPs Most likely will not apply to those on this call

Operating Permit (Class II) An option when actual emissions are below Class I thresholds but PTE is above Advantages minimal record keeping simpler cheaper If actual emissions are below the Class I thresholds but PTE is above – then limit your emissions and apply for a Class II operating permit A Class II permit requires minimal record keeping and is simpler (and cheaper) than maintaining a Class I permit

Small Boiler NSPS NSPS = New Source Performance Standards 40 CFR 60.42 subpart Dc Installed or modified after June 9, 1989 Heat input capacity is between 10 and 100 MMBTU/hr

KDHE Boiler “Sheltered” Initiative

KDHE Boiler “Sheltered” Initiative Applies to companies or institutions that have boiler(s) with heat input capacity between 10 and 100 MMBtu/hr and installed after June 9, 1989 Many small boilers out of compliance with these federal requirements

KDHE Boiler “Sheltered” Initiative Must evaluate whether new source performance standard (NSPS) applies Must evaluate need for air permit/approval Complete applicable permit applications Expedited approval and/or permit Must be in compliance by Sep. 30, 2008

Evaluating Permit Needs Identify for all boilers: Date of installation or modification Heat input capacity (typically in MMBTU/hour) Type of fuel (natural gas, fuel oil, etc) Evaluate using fuel with greater PTE Low NOX burner (for natural gas-fired boilers)

Evaluating Permit Needs Use information (from previous slide) Use AP-42 emission factors http://www.epa.gov/ttn/chief/ap42/ch03/index.html Emissions can be estimated with this info Don’t worry, we’ve done the calculations! See flow chart in packet received from KDHE

The heat input capacity of the boiler is between 10 and 100 MMBtu/hr Subject to NSPS? The boiler was constructed, modified, or reconstructed after June 9, 1989 The heat input capacity of the boiler is between 10 and 100 MMBtu/hr Complete the expedited KDHE boiler form Yes Yes No No The boiler is not subject to NSPS requirements

Subject to expedited approval/permit? Boilers burn natural gas Boilers have low NOX burners Total heat input capacity is 10 MMBtu/hr or greater No requirements Expedited approval needed Yes Total heat input capacity is less than 10 MMBtu/hr No Total heat input capacity is between 10 and 93 MMBtu/hr Total heat input capacity is 93 MMBtu/hr or greater Expedited permit needed Boilers burn fuel oil #1 or #2 or diesel Total heat input capacity is less than 3.8 MMBtu/hr Total heat input capacity is between 3.8 and 17.8 MMBtu/hr Total heat input capacity is 17.8 MMBtu/hr or greater Boilers burn residual oil #5 or #6 Total heat input capacity is less than 3.5 MMBtu/hr Total heat input capacity is between 3.5 and 16.1 MMBtu/hr Total heat input capacity is 16.1 MMBtu/hr or greater Contact KDHE Bureau of Air and Radiation (BAR)

Other possible sources

Emergency Generators Emergency generator definition Used only for back-up power (not to offset peak energy usage) For PTE calculations, assume 500 hours/year All emergency generators should be registered with KDHE Expedited form available

Source: www.kdheks.gov/air-permit/forms/Emergency_Gen_App.pdf Expedited Form Source: www.kdheks.gov/air-permit/forms/Emergency_Gen_App.pdf

Future Additions or Modifications Evaluate PTE for new or modified equipment If PTE exceeds construction approval or permit thresholds, contact KDHE Thresholds: www.sbeap.org/publications/airqual.pdf Forms: www.kdheks.gov/air-permit/download.html

Summary

In conclusion… You must determine your permitting needs. If assistance is needed, contact David Peter at 785-296-1104, Cheryl Evans at 785-296-1574, or SBEAP at 800-578-8898. Affected facilities must submit form(s) by September 30, 2008.

Air Permitting Web Site www.kdheks.gov/air-permit/download.html Includes forms for: Expedited approvals application Generator Boiler Expedited permits application Construction permit/approval application Operating permits application Reporting forms Equipment specific

Environmental Hotline Questions or Comments? KDHE contacts David Peter, 785-296-1104 Cheryl Evans, 785-296-1574 SBEAP Environmental Hotline 800-578-8898 www.sbeap.org