Boiler MACT Deadline Is Here, Are You In Compliance? Sponsored by

Boiler MACT Deadline Is Here, Are You In Compliance? Sponsored by

2 Sponsored by: Boiler MACT Deadline Is Here, Are You In Compliance? Webinar Presentation January 21, 2016 PH Haroz President Conversion Technology Inc.

3 Sponsored by: About the Sponsors Hurst Boiler & Welding Company, Inc. has been manufacturing, designing, engineering and servicing gas, oil, coal, solid waste, wood, biomass and hybrid fuel-fired steam and hot water boilers since 1967, for thousands of satisfied customers. CTI is an Environmental and Safety consulting firm servicing a broad range of industrial facilities located across the United States since 1986.

4 What to take away from this webinar: 1. Ensure that your facility is in compliance. 2. Become better informed of what is and what is not applicable to your facility. 3. Gain a better understanding of what is still required to be done to be in compliance.

5 Agenda Regulatory Requirements Compliance Dates Emission Limits Recommendations for Coming Into Compliance Boiler MACT Reconsideration of the Final Rule Published on November 20, 2015

6 The Boilers & CISWI Rules EPA implemented three final National Emission Standards for Hazardous Air Pollutants (NESHAP) rules. Industrial, Commercial, and Institutional Boilers Area Sources 40 CFR Part 63 Subpart JJJJJJ Industrial, Commercial, and Institutional Boilers and Process Heaters Boiler MACT 40 CFR Part 63 Subpart DDDDD Commercial and Industrial Solid Waste Incineration Units (CISWI) 40 CFR Part 60 and 241

7 Definitions NESHAP National Emission Standards for Hazardous Air Pollutants MACT (Maximum Achievable Control Technology) refers to the EPA s NESHAP for Major Sources operating a boiler or process heater. GACT (Generally Achievable Control Technology) refers to the EPA s NESHAP for Area Sources that operate a boiler or process heater.

8 Definitions (cont.) HAP Hazardous Air Pollutants HAPs are materials that are known or suspected to cause cancer or other serious health effects, or adverse environmental effects. EPA has identified 187 HAPs. The purpose of the Boiler MACT rule is to minimize the emissions of HAPs into the air.

9 Definitions (cont.) NHSM Non-hazardous secondary material(s) that are allowed to be burned by units under Boiler MACT and Area Source rules. These are secondary materials that would not be considered solid waste under the Resource Conservation & Recovery Act (RCRA). These include traditional fuels such as coal, oil, biomass, and natural gas, as well as virgin biomass. If material is not considered a traditional fuel, it must meet legitimacy criteria: Must be managed as a valuable commodity, and Must have a meaningful heating value to be used as a fuel.

10 Definitions (cont.) Large vs. Small Boiler Small Boilers have a heat input capacity less than 10 MMBtu/hr. Large boilers have a heat input capacity greater than or equal to 10 MMBtu/hr. Existing vs. New Boiler Existing boilers commenced construction on or before June 4, 2010. New boilers commenced construction after June 4, 2010.

11 Major vs. Area Sources Major Source Emits 10 or more tons/year of any single HAP, or Emits 25 or more tons/year of any combination of HAPs. Area Source Emits less than 10 tons/year of any single HAP, and Emits less than 25 tons/year of any combination of HAPs.

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13 BOILER AREA SOURCE RULE

The following are NOT subject to the Boiler Area Source Rule: Any gas-fired boiler (including natural gas, process gas, landfill gas, coal-delivered gas, refinery gas, hydrogen, and biogas). Hot water heaters with a capacity of no more than 120 U.S. gallons or hot water boilers (i.e. not generating steam) with a heat input capacity of less than 1.6 MMBtu/hr burning gaseous, liquid, or biomass fuel. Temporary boilers units used in place of another boiler while that unit is being replaced or repaired, usually for less than 12 months, unless an extension is approved. 14

The following are NOT subject to the Boiler Area Source Rule: (Cont.) Residential boilers Electric boilers Waste heat boilers Boilers that are used as control devices for other standards, where at least 50 percent of the average annual heat input to the boiler during any 3 consecutive years is provided by the other regulated gas streams. 15

The following are NOT subject to the Boiler Area Source Rule: (Cont.) Research and development boilers. Boilers subject to other NESHAP standards, Section 129 standards, or hazardous waste boilers. 16

Summary of Area Source Compliance Dates All new and existing gas boilers are not subject to the rule (as discussed earlier). For all existing boilers (other than gas): Initial Notification of Applicability 1/20/2014 Initial Tune-up and Energy Assessment 7/19/2014 Tune-up Compliance Certification Report - 1st report by 3/1/2015, subsequent reports by March 1 of the year after a tune-up is completed. 17 All new boilers (other than gas): Initial Notification of Applicability within 120 days of startup Notification of Compliance Status within 60 days of conducting Performance Tests.

18 Deadline Extensions An Existing Area Source that becomes Major Source must comply within 3 years from the date that the source becomes a Major Source.

19 Area Source Emission Limits Some facilities will need to ensure they meet emission limits, depending on the size of the boiler and type of fuel burned. For area sources, there is no emission limits for existing biomass fueled boilers. Deviations from emission limits and corrective actions taken during reporting period must be submitted by March 15 of each calendar year when deviations occurred. Performance test results must be submitted to the EPA online through Compliance and Emissions Data Reporting Interface (CEDRI).

20 Boiler MACT Rule

21 The following major source units are not subject to the Boiler MACT: An electric utility steam generating unit (EGU) covered by subpart UUUUU of part 63. Hot water heaters with a capacity of no more than 120 U.S. gallons or hot water boilers (i.e. not generating steam) with a heat input capacity of less than 1.6 MMBtu/hr burning gaseous, liquid, or biomass fuel. Waste heat boilers, also known as heat recovery steam generators (these boilers recover traditionally unused energy and convert it to usable heat). Boilers that are used as control devices for other NESHAP standards, where at least 50 percent of the heat input to the boiler is provided by the NESHAP regulated gas stream.

22 The following major source units are not subject to the Boiler MACT: (cont.) Research and development boilers. Boilers subject to other NESHAP standards, boilers subject to Section 129 standards, or hazardous waste boilers. A recovery boiler or furnace covered by Subpart MM. Temporary boilers. Residential boilers.

Summary of Boiler MACT Compliance Dates 5/31/2013 Initial Notification of Applicability for all boilers 7/30/2013 For new large units (other than gas 1 units) or within 180 days after startup, whichever is later, demonstrate compliance with emission limits. 1/31/2016 Initial Tune-up Energy Assessment CMS, DAS and other recordkeeping are in operation. Startup/shutdown procedures are in place. 23

24 Summary of Boiler MACT Compliance Dates (cont.) 7/29/2016 Demonstrate compliance with emission limits. 9/30/2016 or within 60 days following completion of all performance tests and/or other compliance demonstration Submit Initial Notification of Compliance Status. Subsequent Requirements - Compliance Certification Reports need to be submitted by January 31st every year or every 5 years for boiler with O2 trim system.

25 Boiler MACT NOT Subject to Emission Limits Existing and new small boilers (<10 MMBtu/hr); Existing and new limited-use boilers Meaning boilers that have federally enforceable average annual capacity limit of 10% of its full capacity.

26 Boiler MACT Emission Limits and Work Practice Requirements Subcategory Existing large boilers and process heaters Existing small boilers and process heaters Summary of Requirement Clean Gas (Natural gas, refinery gas) Tune-up every year One-time energy assessment No numeric emission limits Coal, Biomass, Oil, and Process Gas Numeric emission limits for Hg, CO, HCl, and either PM or TSM Tune-up every year One-time energy assessment Limited-Use Tune-up every 5 years No numeric emission limits Coal, Biomass, Oil, and Gas Tune-up every other year One-time energy assessment No numeric emission limits Limited-Use Tune-up every 5 years No numeric emission limits

27 Boiler MACT Emission Limits and Work Practice Requirements (cont.) Subcategory Summary of Requirement Clean Gas (Natural gas, refinery gas) New large boilers and Coal, Biomass, Oil, process heaters and Process Gas New small boilers and process heaters Tune-up every year No numeric emission limits Numeric emission limits for Hg, CO, HCl, and either PM or TSM Tune-up every year Limited-Use Tune-up every 5 years No numeric emission limits Coal, Biomass, Oil, and Gas Tune-up every other year No numeric emission limits Limited-Use Tune-up every 5 years No numeric emission limits

28 To demonstrate compliance with emission limits, you should: During startup and shutdown periods minimize emissions according to work practice standards; Develop and follow site-specific testing and monitoring plans; Develop plan; and follow a site-specific fuel monitoring Conduct initial and annual performance tests for mercury (Hg), Carbon Monoxide (CO), Hydrochloric Acid (HCl), and either Particulate Matter (PM) or Total Selected Metals (TSM);

29 To demonstrate compliance with emission limits, you should: (cont.) Establish operating limits during the performance test; Conduct initial and monthly fuel analysis for each fuel type burned at the boiler; Monitor and collect data to demonstrate compliance with operating limits; and Conduct performance evaluations of your Continuous Monitoring System (CMS).

30 If you are subject to emission limits, you must keep records of the following: Calculations and supporting documentation to demonstrate compliance with Hg, HCl, PM, and/or TSM limits; Fuel analysis; Type and amount of all fuels burned at each boiler; Site-specific test plan; Site-specific monitoring plan; and Inspection and monitoring data, including the person who conducted the monitoring, technique, or method used, operating conditions, results, and corrective actions taken.

31 RECOMMENDATIONS FOR COMING INTO COMPLIANCE

32 Boiler MACT Subcategories Your facility s boiler design as well as the type of fuel burned at the boiler will determine your boiler subcategory. Your boiler subcategory will determine what emission limits you must meet. Units in all subcategories designed to burn solid fuels must meet emission limits for HCl (0.022 lb/mmbtu) and Hg (0.0000057 lb/mmbtu).

33 Boiler Conversion Converting your boiler from one subcategory to another can ease the burden of emission limits imposed by the Boiler MACT rules. An example of Boiler MACT emission limits and the difference between subcategories follows in the next slide.

34 Boiler Conversion Boiler Subcategory (Existing Boilers) HCl (lb/mmbtu) Hg (lb/mmbtu) CO (ppm) PM (or TSM) (lb/mmbtu) Stokers / Sloped Grate/ Others designed to burn wet biomass fuel 0.022 0.0000057 1,500 0.037 (0.00024) Stokers / Sloped Grate / Others designed to burn kiln-dried fuel. 0.022 0.0000057 460 0.32 (0.004) Fluidized bed units designed to burn biomass/bio-based solid. 0.022 0.0000057 470 0.11 (0.0012) Suspension burners designed to burn biomass/bio-based solid. 0.022 0.0000057 2,400 0.051 (0.0065) Hybrid suspension grate units designed to burn biomass solid fuel exceeding 40% moisture content on as fired annual heat input basis. 0.022 0.0000057 2,800 0.44 (0.00045)

35 POLLUTION CONTROL EQUIPMENT

36 Pollution Control Equipment If performance tests indicate that your boiler will not meet emission limits, the facility will need to install pollution control equipment to reduce emissions. These include: Multiclone PM, TSM Wet scrubber PM, TSM, HCL, and some Hg Dry scrubber HCl Activated Carbon Injection - Hg Fabric filter PM, TSM Electrostatic precipitator (ESP) PM, TSM If you are installing a new pollution control device, you can apply to the state for a one year extension from the Boiler MACT compliance due dates.

Oxygen Trim An O2 Trim system is designed to continuously measure and maintain an optimum air-to-fuel ratio by maintaining excess air at the desired level. Boilers equipped with O2 trim systems operate more efficiently and therefore conserve fuel. Boilers equipped with O2 Trim must conduct a tune-up every 5 years instead of every 1 or 2 years. 37

38 Other Pollution Controls CO emissions can be optimized Using the 3 T s: 3 T s of combustion: Turbulence, Temperature, and Time. Facility should tune-up boiler to optimize 3 T s in order to minimize CO emissions.

39 CONTINUOUS MONITORING SYSTEM (CMS) & DATA ACQUISITION SYSTEM (DAS)

40 CMS and DAS Continuous Monitoring System (CMS) Includes CEMS, COMS, and CPMS Automatically measures emissions from a boiler system. Must be operated and maintained according to site-specific monitoring plan. Data Acquisition System (DAS) Electronic system that automatically records data required by Boiler MACT rule. Facility should ensure DAS has specific data reduction capabilities for each parameter monitored to demonstrate continual compliance. Each CMS/DAS is specific to your facility s boiler setup and pollution control equipment. Two examples of unique solutions follow.

Wet Scrubber Pollution Control CMS/DAS Setup 41

ESP Pollution Control CMS/DAS Setup 42

43 Boiler MACT and Your Air Permit The Boiler MACT requirements do not replace any requirements you may have under your current air permit. The two can be combined as shown in the next slide.

44 Boiler MACT and Your Air Permit (cont.) It is possible to incorporate the recordkeeping required by your air permit into the recordkeeping requirements under Boiler MACT. For example, your current air permit required you to manually record the pressure drop across your scrubber twice a day. Boiler MACT requires continuous monitoring of pressure drop. The Boiler MACT requirement now satisfies the air permit requirement and no manual readings are necessary. The DAS software can also incorporate tables to record malfunctions, corrective actions, etc. with drop-down menus to increase efficiency and ease of use by operators.

45 RECENT UPDATES TO BOILER MACT

46 Recent Updates to Boiler MACT Boiler MACT Final Action on Reconsiderations of the Final Rule from January 21, 2015 was published on November 20, 2015 (referred to as Reconsideration Rule herein)

47 2015 Boiler MACT Reconsideration Rule The following issues were reconsidered: Work practices during startup and shutdown periods. A number of technical corrections and clarifications are addressed in the reconsideration.

48 Changes to Startup Definition Replaced the term Steam or Heat with Useful thermal energy. In the January 2013 rule, the startup ends when any amount of steam or heat is supplied. In the Reconsideration Rule, startup begins with either the first firing of fuel or after 4 hours from the supply of Useful thermal energy.

49 Useful Thermal Energy Discussed in the Reconsideration Rule Useful thermal energy is energy that meets thermal and physical characteristics required for operation of the equipment using the energy supplied by the boiler or process heater.

50 How does this change affect startup? With the 1/21/2015 rule, startup would begin upon the generation of any small amount of steam or heat. That amount might be insufficient for the operation of process equipment or the safe initiation of pollution control equipment, making it very difficult for a facility to meet emission limits during startup.

51 How does this change affect startup? (cont.) With the 11/20/2015 Reconsideration Rule, there are 2 alternatives: Alternative #1: Startup begins with the first-ever firing of fuel after shutdown in a boiler or process heater for the purpose of supplying useful thermal energy. Startup ends when any useful energy is supplied. Alternative #2: The startup period begins at the first firing of fuel after shutdown in the boiler or process heater for the purpose of supplying useful thermal energy, and ends 4 hours after the supply of thermal energy is initiated.

52 Work Practices Each alternative requires different startup work practices, including: Sequence of engaging pollution control Development of written startup & shutdown plans for Alternative #2 Extra recordkeeping requirements for Alternative #2 The list of Clean Fuels has been expanded to include additional gaseous clean fuels and fuels that meet appropriate Total Selected Metals (TSM), Hydrochloric Acid (HCl), and Mercury (Hg) emission standards based on fuel analysis. The EPA has added the phrase clean dry biomass for biomass fuel that is not stained, painted, or pressure treated with contaminants not to exceed those of virgin biomass material.

53 Opacity Maintain 10% opacity OR The highest hourly average opacity reading measured during the performance test, while demonstrating compliance with PM (or TSM) emission limits.

54 CO Monitoring and Moisture Corrections Define and clarify the scope of the subcategory for Hybrid Suspension/Grate Boilers. The moisture content threshold of 40% on as-fired annual heat input basis is to be determined by monthly fuel analysis. ph monitoring is required for an acid gas scrubber. ph monitoring is NOT required otherwise. For example: A scrubber using water to control PM for a biomass fueled boiler does NOT require ph monitoring.

55 Optimizing the Process of Coming into Compliance

56 Optimizing the Process of Coming into Compliance Understand how to determine what regulations are applicable to your facility. Ensure compliance with the applicable regulations as follows: Determine boiler size, type and subcategory Complete all applicable notifications and reports; Conduct one-time energy assessment; Conduct tune-ups; Request extension from the state if entitled; Comply with work practices requirements; and Demonstrate compliance with emission limits;

57 Optimizing the Process of Coming into Compliance (cont.) Find the most feasible way to come into compliance as follows: Determine which pollution control system to install; Evaluate whether to install oxygen trim to reduce tune-up frequency, improve thermal efficiency, and reduce CO emissions. Incorporate air permit recordkeeping requirements into Boiler MACT requirements. These rules are comprehensive and consist of many elements. I strongly recommend that a thorough Q/A be conducted to ensure that all the tasks are in place and completed by their deadlines.

For Additional Information 58 PH Haroz President Conversion Technology, Inc. (CTI) pharoz@conversiontechnology.com 770-263-6330 ext.102 www.conversiontechnology.com twitter.com/ctiengineers

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