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Rick Soucy GZA GeoEnvironmental , Inc.

Rick Soucy GZA GeoEnvironmental , Inc. Compliance with New Air Pollution Regulations for Boilers and Emergency Generators - The Basics of What Every Facilities Manager Should Know NEHES Fall Conference October 1, 2013. Overview. Recent Federal Regulations Impact Hospital Operations

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Rick Soucy GZA GeoEnvironmental , Inc.

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  1. Rick Soucy GZA GeoEnvironmental, Inc. Compliance with New Air Pollution Regulations for Boilers and Emergency Generators - The Basics of What Every Facilities Manager Should KnowNEHES Fall ConferenceOctober 1, 2013

  2. Overview • Recent Federal Regulations Impact Hospital Operations • Affected Equipment – Boilers, Emergency Generators, Chiller Engines, Cogeneration Engines • Regulations Complex • Compliance Deadlines Looming • Basics to Know • Applicability • Compliance Requirements, i.e., How to Comply • Compliance Schedule, i.e., When to Comply By

  3. Regulatory Background • CAAA of 1990 (Title III) • Mandated EPA to Develop Rules to Reduce Emissions of Hazardous Air Pollutants (HAPs) • National Emission Standards for Hazardous Air Pollutants for Source Categories (NESHAPs) • a.k.a. “MACT” (Maximum Achievable Control Technology) Standards • Promulgated at Federal Level by EPA • Enforcement May Be Delegated to States

  4. Why Regulate HAP Sources? • Known or Suspected to Cause Cancer and Other Serious Health Effects • Aggravate Respiratory and Cardiovascular Disease • Changes in Lung Function • Adverse Effects on Child Development • Premature Deaths

  5. HAPs and MACT Standards • 187 HAPs Currently Regulated • MACT Standards for 133 Source Categories to Date Today’s Focus: • Area Source Boiler MACT Rule - 40 CFR Part 63, Subpart JJJJJJ (“6J”) • Stationary RICE (Reciprocating Internal Combustion Engine) MACT Rule - 40 CFR Part 63, Subpart ZZZZ (“4Z”)

  6. ClarificationArea Source vs. Major Source Major HAP Source: > 10 Tons/Year of Any Single HAP or > 25 Tons/Year of Total HAPs Area HAP Source: Any Facility That is Not Major

  7. Area Source Boiler MACT40 CFR Part 63, Subpart JJJJJJ Applies to Industrial, Commercial, and Institutional Boilers at Area Sources History • First Proposed by EPA on June 4, 2010 • Thousands of Comments Received • Originally Finalized on March 21, 2011 • Simultaneous Notice of Reconsideration • Another Notice of Reconsideration and Proposed Amendments on December 23, 2011 • “Final” Rule on February 1, 2013 • Lawsuits Filed by Environmental and Industry Groups

  8. Area Source Boiler MACT40 CFR Part 63, Subpart JJJJJJ Q. Why Has Boiler MACT Been So Controversial? A. There Are a Lot of Boilers ~ 1.5 million Of These, EPA Estimates: • 86% Are Clean and Not Covered by the Rule • 13% Are Subject to Work Practice Standards • 1% Are Subject to Numerical Emission Limits Most Hospitals and Healthcare Facilities

  9. What Boilers Are Exempt from Boiler MACT? Gas-Fired Boilers EPA Definition: Gas-Fired boiler includes any boiler that burns gaseous fuels not combined with any solid fuels and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel. Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year.

  10. What Other Boilers Are Exempt from Boiler MACT? • Residential Boilers • Hot Water Heaters with Capacity < 120 gallons • Hot Water Boilers (Not Generating Steam) with Heat Input Capacity < 1.6 MMBtu/hr • Electric Boilers • Temporary Boilers • Must Be Portable • Must Not Remain at Same Location More Than 12 Consecutive Months

  11. Area Source Boiler MACT Applicable Compliance Requirements • Vary According to: • Size (capacity) of Boiler • When Constructed (before or after June 4, 2010) • Type of Fuel Combusted

  12. Summary of Area Source Boiler MACT Emission Limit and Work/Management Practice Requirements

  13. Summary of Area Source Boiler MACT Emission Limit and Work/Management Practice Requirements *New oil-fired boilers that combust only oil with no more than 0.50 % sulfur (or a mixture of 0.50 % sulfur oil with other fuels not subject to a PM emission limit) are not subject to a PM emission limit provided they do not use emission controls (except a wet scrubber) to reduce PM or SO2 emissions.

  14. Boiler MACT Tune-up Requirements • Conduct According to EPA Specifications • Tune-up on Fuel That Provided the Majority of the Heat Input to the Boiler Over Last 12 Months • Inspect Burner – Clean and Replace Components, as Necessary • Inspect Flame Pattern and Adjust Burner to Optimize • Inspect Air-to-Fuel Ratio Controller, if Equipped • Optimize CO Emissions Consistent with Manufacturer’s Specifications • Measure the Exhaust Concentration of CO and O2Before and After Any Adjustments Made • Maintain Report That Identifies Measured Concentrations and Corrective Actions

  15. Boiler MACT Energy Assessment Requirements • Must Be Performed By a Qualified Energy Assessor • Assessment Must Include: • Visual Inspection of Boiler System • Evaluation of Operating Characteristics and Specifications of the Boiler System • Inventory of Major Energy Use Systems Consuming Energy from the Boiler • Review of Architectural/Engineering Plans, Operations and Maintenance Procedures/Logs, and Fuel Usage • List of Major Energy Conservation Measures Within the Facility’s Control • List of the Energy Savings Potential of Energy Conservation Measures • Comprehensive Report Detailing Ways to Improve Efficiency, Cost of Specific Improvements, and Payback Periods

  16. Boiler MACT Energy Assessments-Other Things to Know- • On-Site Technical Labor Hours Can be Limited – Depends on Total Annual Heat Input Capacity of the Boiler • Requirement Satisfied if Already Had Assessment Done After 1/1/2008 and if Met EPA Specifications • Requirement Satisfied if Facility Operates Under an Energy Management Program Compatible with ISO 50001 That Includes the Affected Boiler

  17. Boiler MACT-Other Requirements- • Submit Notifications (as applicable) • Keep Records of Fuel Usage • Prepare Compliance Certification Reports • Boilers with Emission Limits: • Performance Tests • Fuel Analyses • Continuous Monitoring Systems

  18. Boiler MACT Compliance Dates • Initial Notification: January 20, 2014 or Within 120 Days of When a New Boiler Becomes Subject • Initial Tune-ups and Energy Assessments: March 21, 2014 • Emission Limits: March 21, 2014 (Performance Testing Required Within 180 Days) • Notification of Compliance Status for Tune-Ups and Energy Assessments: July 19, 2014 • Prepare Annual Compliance Certifications by March 1 of Every Year Note: Notifications may have to be sent electronically using CEDRI Interface.

  19. Helpful Web Sites for Boiler MACT EPA Region 1 List of Qualified Energy Assessors http://www.epa.gov/boilercompliance/whereyoulive.html#region1 General Information and Compliance Tools http://www.epa.gov/boilercompliance/ http://www.epa.gov/airtoxics/boiler/boilerpg.html

  20. RICE MACT40 CFR Part 63, Subpart ZZZZ Applies to Stationary Engines of All Types and Sizes • Existing and New • Emergency and Non-Emergency • Compression Ignition (CI) • Spark Ignition (SI) Does Not Apply to Non-Road Engines or Motor Vehicle Engines

  21. RICE MACT History • Originally Proposed by EPA on December 19, 2002: RICE > 500 HP at Major Sources • Revised and Expanded: January 18, 2008, March 3, 2010, August 20, 2010, March 9, 2011 • “Final” Amendments on January 30, 2013 • Notice of Reconsideration: September 5, 2013

  22. RICE MACTApplicability to Hospitals and Healthcare Facilities • Emergency Engines (Generators and Fire Pump Engines) • Gas-Fired Chiller Engines • Gas-Fired Cogeneration Engines Focus: Compliance Requirements at Area Sources

  23. RICE MACT Compliance Requirements for Emergency Engines GOOD NEWS !! Existing Institutional Emergency Engines are Exempt BUT…

  24. RICE MACT Compliance Requirements for Emergency Engines Must Operate in Accordance with EPA Definition of an Emergency Stationary RICE, i.e., • Maximum 100 hr/yr Total for Maintenance/Testing, Emergency Demand Response, and > 5% Voltage/Frequency Deviations • 50 Hours of the 100 hr/yr Allocation Allowed for Non-Emergency Situations (excluding peak shaving or financial arrangements, with limited exceptions) • Must Not Operate (or be contractually obligated to operate) More Than 15 hr/yr for Emergency Demand Response (EDR) * and >5% Voltage/Frequency Deviations * “Energy Emergency Alert Level 2” Per Reliability Coordinator

  25. RICE MACT Compliance Requirement for Emergency Engines - No Limit on Emergency Operations - WARNING! Your State or Local Air Pollution Control Authority May Have More Stringent Operating Limits and Compliance Requirements

  26. RICE MACT – Emergency Engines What if Your Emergency RICE Operates or is Contractually Obligated >15 hr/yr for Emergency Demand Response? • ULS Fuel (<15 ppm) by January 1, 2015 • Operate/Maintain Engine According to Manufacturer’s Instructions • Subject to Management Practices • Change Oil/Filter Every 500 Operating Hours, or Annually • Inspect Air Cleaner Every 1,000 Operating Hours, or Annually • Inspect Hoses and Belts Every 500 Operating Hours, or Annually • Inspect Spark Plugs Every 1,000 Operating Hours, or Annually

  27. RICE MACT – Emergency Engines What if Your Emergency RICE Operates or is Contractually Obligated >15 hr/yr for Emergency Demand Response? • If >100 HP, Submit Annual Report • Engine Rating/Model Year • Latitude/Longitude of Engine Location • Identify Contractual Obligations • Operating Hours for EDR and Voltage/Frequency Deviations (Dates, Start Times, Stop Times) • Reason for Each Dispatch • First Report Due 3/31/2016 for Calendar Year 2015

  28. RICE MACT – Emergency Engines What If Allowable Non-Emergency Operations Exceed 100 hr/yr? SEVERE CONSEQUENCES • Management Practices (oil changes, inspections, etc.) • Emission Limits or Emission Reduction Requirements • Install Emission Control Equipment • Conduct Emission Performance Tests • Monitor Exhaust Catalyst Performance Parameters • Semi-Annual Compliance Reports • Notifications to EPA and State Authority

  29. RICE MACTApplicability to “New” Emergency Engines • “New” If Construction Commenced On or After 6/12/2006 • Must Instead Comply with Federal NSPS • 40 CFR Part 60, Subpart IIII for CI Engines • 40 CFR Part 60, Subpart JJJJ for SI Engines • General NSPS Requirements • Purchase a Certified Engine • Emission Performance Tests (Non-Certified SI) • Operate According to Emergency Engine Limitations • Non-Resettable Hour Meter • ULS Fuel (CI) • Install/Operate/Maintain According to Manufacturer’s Instructions

  30. RICE MACTCompliance Requirements for Existing Non-Emergency Engines • Gas-Fired Chiller Engines • Gas-Fired Cogeneration Engines Five Gas-Fired Engine Categories • 2SLB • 4SLB < 500 HP • 4SRB < 500 HP • 4SLB > 500 HP • 4SRB > 500 HP

  31. RICE MACT Compliance RequirementsExisting Non-Emergency 2SLB Engines • Change Oil/Filter Every 4,320 Operating Hours, or Annually • Inspect Spark Plugs Every 4,320 Operating Hours, or Annually (Replace as Necessary) • Inspect Hoses/Belts Every 4,320 Operating Hours, or Annually (Replace as Necessary) • Operate to Minimize Emissions

  32. RICE MACT Compliance RequirementsExisting Non-Emergency 2SLB Engines (continued) • Maintain Engine and Control Device According to Manufacturer’s Instructions, or Develop Maintenance Plan • Minimize Idling Time During Start-up • Limit Start-up Time to 30 Minutes • Keep Maintenance Records • Must Comply by October 19, 2013

  33. RICE MACT Compliance RequirementsExisting Non-Emergency 4SLB and 4SRB Engines < 500 HP Same Requirements as for 2SLB, Except: • Maintenance Interval = Every 1,440 Operating Hours, or Annually Compliance Date: October 19, 2013

  34. RICE MACT Compliance RequirementsExisting Non-Emergency 4SLB Engines > 500 HP • Initial Notification Was Due on February 16, 2011 • Install Oxidation Catalyst by October 19, 2013 • Conduct Initial Compliance Demonstration by April 18, 2014 • Must Demonstrate: • Average CO Emission Reduction > 93%, or • Average CO Concentration < 47 ppmvd at 15% O2 • Submit Notification of Intent at Least 60 Days Prior to Test • Submit Notification of Compliance Status Within 60 Days After Initial Compliance Demonstration • Subsequent Annual Compliance Demonstrations

  35. RICE MACT Compliance RequirementsExisting Non-Emergency 4SLB Engines > 500 HP (continued) • Install CPMS for Catalyst Inlet Temperature or Automatic Shutdown Device if Catalyst Inlet Temperature > 1,350˚F (by October 19, 2013) • If CPMS, Maintain 4-hour Rolling Average Inlet Temperature Between 450 ˚F and 1,350˚F • Submit Semi-Annual Compliance Reports

  36. RICE MACT Compliance RequirementsExisting Non-Emergency 4SRB Engines > 500 HP Same Requirements as for 4SLB > 500 HP, Except: • Must Install NSCR (3-Way Catalyst) by October 19, 2013 • Must Demonstrate: • Average CO Emission Reduction > 75%, or • Average CO Concentration < 270 ppmvd at 15% O2, or • Average THC Emission Reduction > 30% • Install CPMS for Catalyst Inlet Temperature or Automatic Shutdown Device if Catalyst Inlet Temperature > 1,250˚F • If CPMS, Maintain 4-Hour Rolling Average Inlet Temperature Between 750˚F and 1,250˚F

  37. RICE MACTApplicability to “New” Cogeneration or Chiller Engines • “New” if Construction Commenced On or After 6/12/2006 • Instead Comply with NSPS – 40 CFR 60, Subpart JJJJ • Purchase a Certified Engine (if you can) • Non-Certified Engines • Requirements Depend on Size, Type, and Manufacture Date • Emission Limits (NOx, CO, VOC) • Initial and Subsequent Performance Tests • Notifications, Recordkeeping, and Reporting

  38. Helpful Web Sites for RICE MACT General Information and Compliance Tools EPA Region I – New England http://www.epa.gov/region1/rice/ EPA Technology Transfer Network http://www.epa.gov/ttn/atw/icengines/

  39. Questions???

  40. Contact: Rick Soucy GZA GeoEnvironmental, Inc. 655 Winding Brook Drive, Suite 402 Glastonbury, CT 06033 Phone: (860) 858-3163 Fax: (860) 652-8590 rick.soucy@gza.com www.gza.com Compliance with New Air Pollution Regulations for Boilers and Emergency Generators –The Basics of What Every Facilities Manager Should KnowNEHES Fall ConferenceOctober 1, 2013

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