the worlds leading sustainability consultancy boiler gact update georgia awma conference october...

The world’s leading sustainability consultancy

Boiler GACT UpdateGeorgia AWMA Conference

October 2013


Agenda - NESHAP Anatomy

Applicability and Affected Sources

Subcategories

and

Emission Limits

Compliance OptionsCompliance Assurance

Requirements

Schedule and Definitions

Boiler MACT and

GACT Structure

Very Similar -

More/Different

Requirements

for Major Sources


The “Final” Combustion Source Rules

40 CFR 63 Subpart DDDDD – Major Source Boiler MACT

40 CFR 63 Subpart JJJJJJ – Area Source Boiler GACT

40 CFR 60 Commercial and Industrial Solid Waste Incineration (CISWI) Rule

40 CFR 241 Non-Hazardous Secondary Materials (NHSM) Solid Waste Identification Rule

To gather data, assess applicability, determine emission limits, review compliance status/options, and implement compliance strategy

Promulgated again by US EPA on January 31 and February 1, 2013

Includes four (4) Interrelated Rules

Detailed Site-specific Action Plan Needed


The Solution is a Process Issue…

Point of Compliance

Fuel Spec

Supply

Longevity

Cost

Fan Modification

Combustion Mod

Operating Flexibility

Retrofit

Addition

Permitting

Compliance Testing

Cost

Each part of the process may be part of the answer!


Boiler Area Source GACT Rule (Boiler GACT)

GACT = Generally Available Control Technology

Applicability - 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


Boiler GACT Applicability

Applies to HAP Area Sources

“Natural Gas” Boilers are Exempt

Existing Sources (Commenced Construction Prior to 6/4/10)

Emission Limits Set Only for Coal Boilers Fuel Oil and Biomass Units Only Subject to Work Practice

Standards Fuel Switching After 6/4/10 May No Longer Trigger New Source

Status

Initial Compliance Date 3/21/14 for existing sources


Natural 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.


Fuel Switching Improvement

63.11194(e) - An existing dual-fuel fired boiler meeting the definition

of gas-fired boiler, as defined in § 6.11237, that meets the

applicability requirements of this subpart 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.


Significant Improvements/Changes

■ Many Emissions Limits are Now Higher

■ Initial Tune-Up Deadline Delayed to 3/21/14

■ Tune-Ups Conducted Using Primary Fuel Over the Prior 12 Months

■ Natural Gas Curtailment Now Includes On-Site Fuel System Failures

■ Temporary, Seasonal and Limited Use Boiler Relaxation

■ CO Emission Limit and Potential CEMS for Oil Sources Removed

■ New Oil Sources Burning < 0.5 % Sulfur Are Exempt from PM Limit

■ Start-Up & Shutdown Definitions Changed and 25% “Bright Line” Removed

■ Potential Hg Fuel Analysis Relaxation


Initial and Continuous Compliance

Initial Notification(s)

Work Practice Standards (Tune-Ups,

Energy Assessment,

etc.)

Periodic Performance

Tests

Notification of Compliance

Status Report(s)

Monitoring of Operating Parameters for Control Devices

Stack O2 Monitor for CO Limits

Stack Testing or Fuel

Analysis for Hg


Boiler GACT Compliance

Existing Source Initial Compliance Deadline 3/21/14

Initial Tune-Up and One Time Energy Assessment

Stack Testing for Applicable Boilers Due by 9/17/14

Notification of Compliance Status Report(s) (7/19/14 and/or 11/17/14)

Ongoing Compliance Assurance – Testing, Monitoring, Recordkeeping and Reporting

SSM Requirements ???


Existing Coal Boilers

Subject to Mercury (Hg) and CO Emission Limits

Hg Compliance Based as Fuel Analysis or Stack Testing

CO Compliance Typically Based Only on Stack Testing

Stack Testing Includes: Both Initial and Ongoing Testing Test Plan Approval by GA EPD Monitoring and Establishing Hg, CO and Capacity Operating Limits Developing/ Implementing a Site Specific Monitoring Plan Conduct Initial and Periodic Continuous Parameter Monitoring

System Performance Evaluations – May Need a RATA!? Need to Run at Maximum Capacity – 110% Operating Limit Report Results Via New US EPA WebFire Database


One-time Energy Assessment (EA) Required for All Existing Affected Boilers > 10 MM Btu

Except Limited Use

Higher Fuel Efficiency means Reduced Air Pollutants Emitted to the Atmosphere

EA 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 capacity

EA to follow prescribed procedures and assessor qualifications relaxed, and existing assessments can now be amended as needed to comply.


Permitting Considerations■ Will Generic Placeholder Conditions Suffice?

Trade-off of Generic vs. Specific Conditions Approach

■ Typical Issues With Agencies: Approval of Alternative Operating Limits Approval of Multiple Compliance Options Testing of Worst Case Fuel for Each Pollutant Title V Versus GACT Inconsistencies Verify if Site Specific Monitoring Plan Needs to be Submitted Need for Multiple NOCSR Submittals Does Annual Compliance Report Need Submittal


Permitting Considerations (continued)

■ What Permit Applications are Needed and When? < 10/25 TPY HAP Emission Limits New/Modified Emission Control Device Construction, Operation,

and/or Operating Limits New Boiler(s) and/or Fuel Switching Compliance Option Definition

■ Need to Ensure Compliance Plan is Enforceable! Solid Fuel Variability is a Challenge/Risk for Both Area Source

Status and Boiler GACT Compliance

■ Request to See a “Pre-Public” Draft Amendment

■ Other Potential Implications– NSR, NAAQS, NSPS, GHG, etc.


Case Study ExampleMajor HAP Source With One Large Coal Boiler, Four Natural Gas Boilers and Very Low Process HAP’s

■ Looking at Area Source HAP Status Via Limiting Boiler HCl Emissions■ Lime Injection Into Baghouse or Add-On Wet Scrubber

■ Potential Fuel Switching From Coal

■ Addition of Fuel Oil to Manage Natural Gas “Risk”

■ Conducting Stack Testing and Fuel Analysis■ Completing “What If” Emission Testing

■ Setup Ongoing Hg Fuel Analysis

■ Evaluating Hg and/or CO Compliance Options■ Fuel Vendor Contract Limits and Operating Restriction/Controls

■ Trade off of CO Management Versus NOx Permit Limits

■ Development of Long Term Compliance Strategy and Schedule■ Operating Costs, Impacts and Uncertainties

■ Build Results Into Site Budgeting Cycle

■ Ongoing GA EPD discussions/negotiations


Boiler MACT Planning Timeline Based on January, 2016 Initial Compliance Date

Now 3/2014 9/2014 1/2015 3/2015 9/2015 1/2016

Data Gathering and Initial Planning

Boiler Stack Testing

Completed

Engineering Evaluation and Fuel Supplier

Review

Technology/ Vendor

Selection and Design

Permitting and Regulatory

Negotiations

Fabrication, Construction, Check Out and

Training

Ongoing NESHAP

Compliance Activities


What’s Next for You?

Assess if you have boilers/process heaters potentially subject to CISWI versus MACT/GACT

Identifyapplicable emission limits and if you can comply with these limits

Gather needed 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 cycles

Determine if need additional monitoring systems

Consider operational, process and/or fuel changes to reduce the regulatory burden

Develop an overall compliance strategy and schedule

Plan for tune-ups and facility-wide energy assessment


Questions?


Contact Information

ERM 3200 Windy Hill Road SE

Suite 1500WAtlanta, GA 30339

678.486.2700

David Dunn [email protected]

mailto:[email protected]

the worlds leading sustainability consultancy boiler gact update georgia awma conference october...

Documents

fuel switch

primary fuel

liquid fuel

fuel material

alternate fuel

slide forms

supply of gaseous fuel

existing dualfuel