9/9/2015
NESHAPs for Boilers: Boiler MACT and the Area Source Boiler Rule Indiana Environmental Permitting and Reporting Conference September 3, 2015
The Rules • NESHAP for Area Sources: Industrial, Commercial, and Institutional Boilers (Subpart JJJJJJ of part 63) (“Boiler Area Source Rule”) – Boilers at small (“area”) sources of HAP
• NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (Subpart DDDDD of part 63) (“Boiler MACT”) – Boilers at large (“major”) sources of HAP
• Section 129 NSPS and Emission Guidelines for Commercial and Industrial Solid Waste Incinerators (“CISWI”) – Boilers that burn solid waste at industrial and commercial facilities Source: Jim Eddinger, CIBO Industrial Emissions Control Technology Conference, August 4, 2015
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BOILER AREA SOURCE RULE (NESHAP subpart JJJJJJ)
Boiler Area Source Rule • Three subcategories based on design type: – Coal‐fired units • 3,700 units – 2% of area source boilers – 89% less than 10 million Btu/hr
– Biomass‐fired units • 11,000 units – 6% of area source boilers – 93% less than 10 million Btu/hr
– Liquid fuel‐fired units • 168,000 units – 92% of area source boilers – 95% less than 10 million Btu/hr Source: Jim Eddinger, CIBO Industrial Emissions Control Technology Conference, August 4, 2015
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Compliance Requirements ‐ Area Source Boilers •
Large boilers (>=10mm/BTU) – Coal‐fired • New – Numeric emission limits for 3 pollutants (Hg, CO, PM) • Existing – Numeric emission limits for 2 pollutants (Hg, CO) • New/Existing – Tune‐up every other year • Existing – Energy assessment – Biomass‐fired, Oil‐fired • New – Numeric emission limit for 1 pollutant ‐ PM
•
• New/Existing – Tune‐up every other year • Existing – Energy assessment – Gas‐fired • No requirements, Not covered by rule Small boilers (=10mm/BTU) – Gas‐fired (“Gas 1”)
• Annual tune‐up • No numeric emission limits • Energy assessment (existing units only) – Coal, Biomass, Oil, Process gas (“Gas 2”)
• Annual tune‐up • Numeric emission limits for 4 pollutants mercury, PM (or TSM), HCl, CO • Energy assessment (existing units only)
• Small boilers ( 500 hp and ≤ 500 hp
Identification of Potential Source • Started with a list of known IC engines • Reviewed ALL locations, including permitted and sources for which permits are not required • Identified which are area sources and which are major sources of HAPs
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Engine Operation • Determined usage profile for each engine – Understand the different engine types and performed objective analysis – Identified how the engine is currently operated – Determined if it is possible to operate within the given constraints for the NESHAP usage profile
• Peak shaving • Demand response
Numerical Emission Limits • Based on date ordered, installed, and model year, determined applicability of: – Subpart ZZZZ (Part 63) – Subpart IIII (Part 60) – CI Engines – Subpart JJJJ (Part 60) – SI Ignitions
• Identified engine types with numerical emission limits in rules
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NSPS 40 CFR 60 Subpart IIII Subpart JJJJ Do not assume your new engine is EPA certified; confirm it! (Especially for “old” new engines) Ensure compliance with 40 CFR 63, Subpart ZZZZ
Subpart ZZZZ Challenges • Table 2a – Emission Limits: Major Source New / Recon. 2SLB and CI > 500 hp & New / Recon. 4SLB ≥ 250 hp – 3 categories
• Table 2b – Op. Limits: Major Source New/Recon. 2SLB & CI > 500 hp and 4SLB ≥ 250 hp; Existing CI > 500 hp – 3 categories
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Subpart ZZZZ Challenges • Table 2c – Major Source existing CI and SI ≤ 500 hp – 12 categories
• Table 2d – Area Source existing RICE – 13 categories
• Table 5 – Initial compliance with emission limits and other requirements – 14 categories
• Table 6 – Continuous compliance with emission limits and other requirements – 15 categories
Maintenance • Annual or operation based maintenance requirements • “Annual” – Calendar – 12‐months
• Unplanned usage, e.g. emergency
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Maintenance Scheduling Challenges Engine
Oil/Filter
NE CI ≤ 300 hp
Air Cleaner
Hoses/Belts
Spark Plugs
1,000 hrs
1,000 hrs
500 hrs
N/A
Em CI
500 hrs
1,000 hrs
500 hrs
N/A
Em SI; NE 4SLB/4SRB > 500 hp operating 500 hp
2,160 hrs
N/A
2,160 hrs
2,160 hrs
NE 4SRB ≤ 500 hp
1,440 hrs
N/A
1,440 hrs
1,440 hrs
Oil Change / Analysis • Annual or operation based oil change requirements • Large engines use large volumes of oil ($$$) • Using the oil analysis alternative – “[W]hen new”: Supplier data or analyze before use? – If not running, change prior to restarting OR within 2 business days (whichever is later) – If running, change within 2 business days – Shutdown engine on critical system to change oil?
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A Few Paths to Compliance • Compliance guide for responsible personnel and include preformatted logs for recording required information • Identify maintenance requirements on a per‐ engine basis, including option for oil analysis • Train appropriate personnel on requirements for which they have responsibility
Communication is Key • The regulations are complex so ensure regular and open communication. • Make sure everyone understands their responsibilities and how they fit into ensuring compliance. • Be available to address questions or concerns. • Continually improve process as difficulties and opportunities are identified.
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Drew McClay, P.E. Environmental Stewardship Citizens Energy Group
[email protected]
QUESTIONS?
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