Part 63 Boiler Rule for Area Sources AWMA Conference September 11-14, 2012 Biloxi, MS Lee Page Air Toxics Assessment and Implementation Section U.S. Environmental Protection Agency Atlanta, Georgia

Topics to Cover Rule Development Promulgated Requirements Amended Requirements Outreach/Delegations Guidance Fuel Switching Example Questions

March 21, EPA promulgates final boiler rules for major and area sources Subpart 5D for major sources Subpart 6J for area sources May 18, 2011 – EPA delays effective date of major source due to reconsideration Effective date of the area source rule not delayed December 23, EPA issued proposed rule amendments for major source boilers and specific aspects of area sources (will reset compliance date for major sources). January 9, U.S. District Court for the DC Circuit vacated EPA's May 18, 2011, delay of effective date for major sources Rule amendments expected to be finalized by ______??_______ 3 Boiler Rule Development EPA issues No Action Assurance Letters (NAAs) EPA will exercise its enforcement discretion to not pursue enforcement action for violations of certain notification deadlines in the final Major Source Boiler rule (NAA dated 2/7/12) or final Area Source Boiler Rule (NAA dated 3/13/12 then extended until 12/31/12)

Primary Changes in Amendment Revised standards based on generally available control technology Greater flexibility to certain facilities in meeting requirements Clarify certain requirements Correct printing errors

6J Boiler Requirements – As Promulgated Heat Capacity Btu/Hr Existing Coal Units New Coal Units Existing Oil U nits New Oil Units Existing Biomass Units New Biomass Units > 10 MM Yes No Yes No Yes < 10 MM No Emission Limits (Triennial Performance Tests)

6J Boiler Requirements – As Amended Heat Capacity Btu/Hr Existing Coal Units New Coal Units Existing Oil Units New Oil Units Existing Biomass Units New Biomass Units > 30 MM Yes No Yes No Yes > 10 < 30 Yes No Yes No Yes < 10 MM No Emission Limits (Triennial Performance Test)

6J Boiler Requirements – As Promulgated Heat Capacity Btu/Hr Existing Coal Units New Coal Units Existing Oil Units New Oil Units Existing Biomass Units New Biomass Units > 10 MM Yes No Yes No Yes No < 10 MM No One-Time Energy Assessment

6J Boiler Requirements – As Amended Heat Capacity Btu/Hr Existing Coal Units New Coal Units Existing Oil Units New Oil Units Existing Biomass Units New Biomass Units > 10 MM Yes No Yes No Yes No < 10 MM No One-Time Energy Assessment

6J Boiler Requirements – As Promulgated Heat Capacity Btu/Hr Existing Coal Units New Coal Units Existing Oil Units New Oil Units Existing Biomass Units New Biomass Units > 10 MM No Yes < 10 MM Yes Biennial Tune-Ups

6J Boiler Requirements – As Amended Heat Capacity Btu/Hr Existing Coal Units New Coal Units Existing Oil Units New Oil Units Existing Biomass Units New Biomass Units Existing Seasonal (Oil or Biomass) New Seasonal ( Oil or Biomass) > 10 MM No Yes Yes * < 10 MM Yes Yes * > 5 MM Yes < 5 MM Yes * Biennial Tune-Ups ( * Every 5 Years)

EPA Outreach R4 Initial Notification Database s to various potentially affected sources Staff led discussions at focus groups National seminars & webinars Rule Delegation 8 States, 10 local agencies EPA Regional Office Implementation Click on Air Toxics Delegation

Area Source Delegations Are Taking Delegation Are Not Taking Delegation Alabama 6D, 6E, 6F, 6G, 6Q 7A, 7C, 7D 5W, 6B, 6C, 6H, 6J, 6N, 6O, 6P, 6R, 6S, 6V, 6W, 6X, 7B, 7E Florida5Y, 5Z, 6D, 6E, 6F, 6G, 6L, 6M, 6N, 6O, 6P, 6Q, 6R, 6S, 6T 5W, 6B, 6C, 6H, 6J, 6W, 6X, 6V, 6Y, 6Z, 7A, 7B, 7C, 7D, 7E Georgia All Kentucky All Mississippi All North Carolina All South Carolina All Tennessee(All in Chattanooga)

Boiler Rule Guidance Web site: Proposed and final rules Example Initial Notification forms Example Notification of Compliance Status forms Rule brochures Guidance on tune-ups Common questions Rule overview presentations Small Entity Compliance Guidance EPA Region 4 Activities Quick reference tables Timeline for required submittals Issue resolutions (dual fired - fuel switching)

Dual Fired vs Fuel Switching Dual fired boilers (gas/oil) account for a large portion of the area source boiler universe 6J exempts gas units that only burn oil during: Periods of gas curtailment Gas supply emergencies Periodic testing of liquid fuel If oil is burned outside of exempted limits, these boilers will be considered new boilers in the oil subcategory (i.e., fuel switching) Boilers could be subject to stringent emission limits Must comply immediately

Fuel Switching For flexibility, dual fired boilers may want to submit initial notification as an existing boiler in the oil subcategory Existing oil fired boilers are not subject to emission limits/performance tests Subject to a one-time energy assessment if boiler heat capacity is >10 MM Btu/hr Will be subject to tune-up requirements Example:

Dual Fired (Gas/Oil) Boilers Hypothetical Area Source Operates the Following Boilers: (All 3 boilers burn primarily natural gas) #1 Existing Unit > 10 mm Btu/hr Nat. Gas/Oil #2 Existing Unit < 10 mm Btu/hr Nat. Gas/Oil #3 New Unit < 10 mm Btu/hr Nat. Gas/Oil Options for Initial Notifications: Option A: Not subject due to special oil exemptions (gas curtailment, supply emergencies, testing)

Dual Fired Boilers Option B: For flexibility, classify all 3 as oil units * Continue to burn natural gas in boilers * No applicable emission limits (only if new >10 mm) * Biennial tune-ups for all 3 boilers * One-time energy assessment for boiler #1 * Comply as required in

Dual Fired Boilers Option C: Only Classify Boiler #1 as existing Oil Unit; Boilers 2 & 3 remain as gas fired units * Boilers 2 & 3 are exempted from regulation * No applicable emission limits for Boiler #1 * Biennial tune-ups for Boiler #1 * One-time energy assessment for boiler #1 * Comply as required in

Fuel Switching Example Costs of fuels change - oil now cheaper than gas Hypothetical source now thinks about switching fuel to reduce overhead (d): Boiler is a new affected source if you switch fuels from gas to oil

Results From Fuel Switching Option A: All 3 Boilers are Gas Fired (Exempted) * All 3 boilers now considered new oil fired units * Boiler #1 (>10MM Btu) has to meet emission limits * Initial and triennial performance tests for boiler #1 * Biennial tune-ups for all 3 boilers * No one-time energy assessment required

Results From Fuel Switching Option B: Boilers 1 & 2 are classified as existing oil fired Boiler 3 classified as new oil fired * No changes (continue with biennial tune-ups) * One time energy assessment already completed Option C: Boiler #1 classified as existing oil fired; Boilers 2 & 3 exempted due to gas * Boilers 2 & 3 are now classified as new oil units * Biennial tune-ups for boilers 2 & 3 * No changes for boiler 1 (continue with tune-ups)

Message Area sources with dual-fired boilers should evaluate the impact of switching fuel now in order to potentially avoid issues related to implementing different rule requirements in the future.

Questions? Lee Page U.S. EPA; Atlanta, GA Lee Page U.S. EPA; Atlanta, GA