Major/Area Source. Speaker: Eric Swisher. 23rd Virginia Environmental Symposium April 11, Your environmental compliance is clearly our business.

Transcription

1 Major/Area Source Boiler MACT Rule Speaker: Eric Swisher 23rd Virginia Environmental Symposium April 11, 2012 Your environmental compliance is clearly our business.

2 Overview Ground Rules Regulatory Framework Regulated Pollutants Emission Limitations Compliance Options Work Practice Standards Startup, Shutdown, and Malfunction Things to Take Away 2

3 Ground Rules NHSM Rule Fuel is a Solid Waste CISWI Rule Fuel is not a Solid Waste Boiler MACT Rules Area Major 3

4 General Information Area or Major Source New, Reconstructed, or Existing Fuel Type Design Type 4

5 Comparison Area Source Major Source 5

6 Facility Type Area Source Major Source Not a Major Source >10 tons per year any single HAP OR > 25 tons per year of any combination of HAPs 6

7 Regulatory Citation 40 CFR Part 63 National Emission Standards for Hazardous Air Pollutants for Source Categories (NESHAP): Subpart JJJJJJ Area Source Boiler MACT (ASBM) Subpart DDDDD Major Source Boiler MACT (MSBM) 7

8 History Area Source Major Source January 13, 2003 March December Proposed 23, 2011 Comments Due March 14, 2003 September 13, 2004 Promulgated June 04, 2010 Proposed Comments Due July 19, 2010 June Promulgated 09, 2010 Comment Period Extended to August 03, December , 2011 July 22, 2010 Comment Period Extended to August 23, 2010 March February 21, , 2012 Promulgated December Comments 23, 2011 Due Proposed Amendments February March 21, 13, Comments Due March 13, 2012 No Action Assurance Letter March 21, 2011 Proposed Amendments No Action Assurance Letter Proposed Compliance Date September 13, 2007 October 31, 2005 Notice of Reconsideration Proposed Amendments December 28, 2005 February 07, 2012 No Final Rule Action (with Amendments) Assurance Compliance Date September 13, 2007 December 06, 2006 Letter Final Action on Reconsideration June 04, 2010 Proposed Comments Due July 19, 2010 June 09, 2010 Comment Period Extended to August 03, 2010 July 22, 2010 Comment Period Extended to August 23, 2010 March 21, 2011 Promulgated 8

9 Act of Congress March 08, 2012 Senate did not pass the Collins Amendment to the Highway Bill that would delay the MSBM. 9

10 Current Status Area Source Major Source Effective Now Proposed Rule Compliance Date March 21, 2014 No Action Assurance Letter March 13, 2012 December 23, 2011 Compliance Date Date to Change No Action Assurance Letter February 07,

11 Source Applicability Area Source Major Source Boiler Boiler Exemptions Process Heaters Exemptions 11

12 Regulated Pollutants Area Source Major Source Mercury (Hg) Mercury (Hg) Non-Mercury Metallic Non-Mercury HAP Metallic HAP Non-Metallic Inorganic Organic HAP HAP (including POM) Non-Dioxin Organic HAP Dioxins/Furans (D/F) 12

13 Emission Limits Area Source Major Source Mercury Carbon Monoxide Mercury Carbon Monoxide Particulate Matter Particulate Matter OR Total Selected Metals (TSM) Hydrogen Chloride 13

14 Compliance Options 1. Comply with the Emission Standards Area Source Major Source Fuel Sampling Fuel Sampling Emission Testing Emission Testing 14

15 Fuel Sampling Area Source Major Source Hg Determine Worst- Case Fuel Mixture Hg, HCl, & TSM Determine Worst- Case Fuel Mixture Fuel Sampling & Analysis Plan Monthly Fuel Analyses 15

16 Emission Testing Area Source Major Source PM Hg CO CO PM or TSM Hg HCl 16

17 Compliance Options 2. Evaluate Emission Standard Alternatives Area Source Major Source None Emission Averaging Output-based Emission Standard Emission Reduction Credits 17

18 Emission Averaging PM, HCl, or Hg Input or Output-based Emission Standards Existing Boiler Only Subcategory Requirements 10% Discount Factor Common Stack Considerations Emission Averaging Plan 18

19 Compliance Options 3. Can Not Comply with the Emission Standards Area Source Major Source Fuel Management Fuel Switching Controls Controls Fuel Management Fuel Switching Synthetic Minor Energy Efficiency i Improvements 19

20 Output-based Emission Standards Output-based Emission Standards Incentivizes implementation of energy efficient technologies to minimize the generation of emissions 20

21 Output-Based Emission Standards Fuel Input Energy (lb pollutant per MMBtu heat input) Steam Output Energy (lb pollutant per MMBtu steam output) 21

22 Capital Investment Add-on Control Device(s) Energy Efficiency Project(s) 22

23 Output-Based Emission Standards How were they determined? Boiler Efficiency Heat-Input Based Limits Subcategory Hg Emission Limit (lb Hg per MMBtu of heat input) Hg Emission Limit (lb Hg per MMBtu of steam output) Boiler Efficiency (%) Existing Boiler Designed to Burn Solid Fuel 3.10E E

24 Output-Based Emission Standards How are they used? Determine Current Boiler Output-Based Emissions Establish Output t Energy Benchmark Investigate Energy Efficiency Projects Quantify Emission Reductions Apply Percent Reduction to Current Boiler Output-Based Emissions 24

25 Energy Output Reduction Example Benchmark Year* = 2,175,000 MMBtu/yr Year After* = 1,957, MMBtu/yr Tested Hg Tested Hg Adjusted Hg Emissions (lb Hg per MMBtu of heat input) Emissions (lb Hg per MMBtu of steam output) Emissions (lb Hg per MMBtu of steam output) 3.40E-06 (Limit 3.10E-06) 3.84E-06 (Limit 3.50E-06) 3.45E-06 *Production is assumed to be the same for both years. 25

26 Energy Output Reduction Example Subcategory Hg Emission Limit (lb Hg per MMBtu of steam output) Hg Adjusted Emissions (lb Hg per MMBtu of steam output) Result Existing Boiler Designed to 3.50E E-06 PASS Burn Solid Fuel 26

27 Output-Based Other Considerations Implementation Plan Pollutant-by-Pollutant Applicability Emissions Averaging Shutdown Boilers Future Boiler Operations Other Permitting Requirements Energy Assessment 27

28 What is Left? Ground Rules Regulatory Framework Regulated Pollutants Emission Limitations Compliance Options Work Practice Standards Startup, Shutdown, and Malfunction Things to Take Away 28

29 Work Practice Standards Area Source Major Source Tune-up Tune-up Energy Energy Assessment Assessment Startup Good Combustion Shutdown Practices Startup Shutdown 29

30 ASBM ASBM Tune-ups Final Rule (March 21, 2011) ASBM Amendments (December 23, 2011) Every 2 years Every 2 years March 21, 2012 No Action Assurance Letter Every 5 years (Seasonal Boilers) March 21, 2013 Fuel Type Requirements Common Fuel Meter 30

31 Tune-up Applicability Area Source Major Source New or Existing Coal-fired Boiler <10 MMBtu/hr New or Existing Biomass-fired Boiler New or Existing Oil-fired Boiler Limited-use it Boilers Natural gas, Refinery Gas or Gas 1 (Other) Boilers < 5 MMBtu/hr Gas 2 (Other), Light Liquid Boilers 31

32 Tune-up Requirements Area Source Burner Inspection Flame Pattern, p y Inspection Air-to-fuel system Inspection CO Optimization Recordkeeping No Report Submittal (1) As applicable, inspect the burner, and clean or replace any components of the burner as necessary (you may delay the burner inspection until the next scheduled unit shutdown, but you must inspect each burner at least once every 36 months). Major Source Burner Inspection Flame Pattern Inspection Air-to-fuel system Inspection CO Optimization Recordkeeping Report Submittal (1) Inspect the burner and clean or replace any components of the burner as necessary. 32

33 Energy Assessment Why? When and how often? Who is qualified? What equipment or systems need to be included? What does cost-effective mean? What needs to be done? 33

34 Energy Assessment ASBM Existing Final Rule (March 21, 2011) 10 MMBtu/hr Boiler System Energy Use System Qualified Personnel Maximum Duration March 21, 2014 ASBM Amendments (December 23, 2011) Existing 10 MMBtu/hr Boiler System Energy Use System Onsite O i Only Qualified Personnel Maximum Duration March 21,

35 Energy Assessment Major Source Scope Maximum Time Compliance Date Date to Change Emission Reduction Credits 35

36 Good Combustion Practices O 2 Trim Systems Monitor Optimize Report Operator Training Startup Procedures Shutdown Procedures 36

37 Startup/Shutdown Periods Boiler MACT standards apply at all times. No exemptions from Boiler MACT standards during periods of Startup and Shutdown. U.S. EPA requires work practice standards for periods of Startupt and Shutdown in lieu of numerical emission limits. 37

38 Startup/Shutdown Area Source Major Source Minimize i i the boiler s startup and shutdown periods following the manufacturer s recommended procedures. Good Combustion Practices 38

39 Misc. Startup/Shutdown Area Source Major Source Startup/Shutdown t td Definitions Startup/Shutdown t td Definitions No SSM Plans No SSM Plans 39

40 Malfunction Malfunction means any sudden, infrequent, and not reasonably ypreventable failure of air pollution control and monitoring equipment, process equipment, or a process to operate in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be exceeded. Failures that are caused in part tby poor maintenance or careless operation are not malfunctions. 40

41 Periods of Malfunction Boiler MACT standards apply at all times. No exemptions from Boiler MACT standards during periods of Malfunction. U.S. EPA determines if a facility demonstrated a good faith effort to minimizing i i i emissions i and correcting a Malfunction. 41

42 Malfunction Process Notification of a Malfunction submitted to U.S. EPA within two (2) business days. Follow-up report submitted to U.S. EPA within 45 business days. U.S. EPA evaluates the reported information concerning the Malfunction to determine if further inquiry or enforcement action is required. Facility can only use Affirmative Defense in response to civil penalties if notification and report is submitted. 42

43 Affirmative Defense To use Affirmative Defense facilities must show a preponderance of evidence that: The excess emission was caused by a malfunction and was not preventable or reoccurring, and The facility expedited repairs, actions were documented in signed logs, and a root-cause analysis was completed. 43

44 SSM Plan No SSM Plan required; however may be more important now than ever due to potential enforcement action. 44

45 Things to Take Away The current status of the Boiler MACT rules? Where do I stand now? What are my compliance options? What are my compliance plans? Be in action! 45

46 Questions? Speaker Contact Info: Eric M. Swisher x17 All4 Inc Kimberton Road - P.O. Box Kimberton, PA