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INDUSTRIAL BOILER MACT RULE (Title 40 CFR 63 Subpart DDDDD) PowerPoint PPT Presentation


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INDUSTRIAL BOILER MACT RULE (Title 40 CFR 63 Subpart DDDDD). Annual DoD Conference Environmental Air Quality Workshop June 29, 2005. IMPORTANT DATES. Proposal Date – January 13, 2003 Promulgation Date – September 13, 2004 Effective Date – November 12, 2004 Additional Comment

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INDUSTRIAL BOILER MACT RULE (Title 40 CFR 63 Subpart DDDDD)

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INDUSTRIAL BOILER MACT RULE(Title 40 CFR 63 Subpart DDDDD)

Annual DoD Conference

Environmental Air Quality Workshop

June 29, 2005


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IMPORTANT DATES

  • Proposal Date – January 13, 2003

  • Promulgation Date – September 13, 2004

  • Effective Date – November 12, 2004

  • Additional Comment

    Period Notice- June 27, 2004- August 11, 2005

  • Initial Notification Dates

    • March 12, 2005– Existing units

    • 15 days after startup – New units

  • Compliance Date

    • Existing units - September 13, 2007

    • New units – Startup


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INDUSTRIAL BOILER MACT

  • Source categories covered:

    • Industrial Boilers

    • Institutional/Commercial Boilers

    • Process Heaters

      • Indirect-fired – combustion gases do not come in contact with process materials.

  • Major source MACT only


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SUBCATEGORIES

  • Three main subcategories:

    • Solid fuel units

    • Liquid fuel units

    • Gaseous fuel units

  • Further subcategorized on size and use

    • Large (> 10 MM Btu/hr heat input)

    • Small (all firetubes and others < 10 MM Btu/hr)

    • Limited-use (< 10% capacity factor)

  • Total of 9 subcategories


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WHAT UNITS ARE NOT COVERED?

  • Any boiler and process heater listed as an affected source under another MACT

    • For example,

      • Fossil fuel-fired electric utility boilers

      • Boilers burning municipal waste

      • Boilers burning hazardous waste

      • Boilers burning medical waste

      • Black liquor recovery boilers

      • Temporary/rental gas or liquid fuel boilers (<180 days)

      • Hot water heaters

      • Waste heat boilers

  • Synthetic minors –becomes an area source


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EMISSIONS LIMITSExisting Units

  • Existing large solid fuel units

    PM -- 0.07 lb/million Btu, OR TSM – 0.001 lb/million Btu

    HCl -- 0.09 lb/million Btu (~ 90 ppm)

    Hg – 9 lb/trillion Btu

  • Existing limited use solid fuel units

    PM -- 0.21 lb/million Btu, OR TSM – 0.004 lb/million Btu

  • No emissions standards for:

    • existing small solid fuel units

    • existing liquid fuel units

    • existing gaseous fuel units


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EMISSION LIMITSand WORK PRACTICE STANDARDSNew Units

  • New solid fuel units

    PM -- 0.025 lb/million Btu, OR TSM 0.0003 lb/million Btu

    HCl -- 0.02 lb/million Btu (20 ppm)

    Hg -- 3 lb/trillion Btu

    CO -- 400 ppm @ 7% oxygen (NOT FOR SMALL UNITS)

  • New liquid fuel units

    PM -- 0.03 lb/million Btu

    HCl -- 0.0005 lb/million Btu (large units)

    0.0009 lb/million Btu (small and limited use units)

    CO – 400 ppm @ 3% oxygen (NOT FOR SMALL UNITS)

  • New gaseous fuel-fired units

    CO – 400 ppm @ 3% oxygen (NOT FOR SMALL UNITS)


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CONTROL TECHNOLOGY BASIS

  • Existing Solid Fuel Boilers

    • Large Units - Baghouse (PM/metals/Hg)/ Scrubber (HCl)

    • Limited-Use Units – ESP (PM/metals)

  • New Units

    • Based on NSPS and State Regulations

    • Baghouse/ Scrubber / CO Limit


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COMPLIANCE OPTIONS

  • Conduct stack emission tests

  • Conduct fuel analysis

  • Emissions averaging

    • (large solid fuel units only)

  • Health-based compliance alternatives for HCl and TSM


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COMPLIANCE TESTING

  • Performance tests (stacks tests)

    • Annual performance tests

    • Based on average of 3 test runs

      OR

  • Fuel analyses

    • Initial and every 5 years

    • Each new fuel type

    • Based 90% confidence level of minimum 3 fuel samples


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COMPLIANCE MONITORING

  • Continuous compliance based on monitoring and maintaining operating limits

  • Operating limits

    • For PM, TSM and mercury limits

      • Opacity (for dry systems)

        • Existing units – 20% opacity (6 minute average)

        • New units – 10% opacity (1 hour block average)

      • Control device parameters (for wet systems)

        • Established during initial compliance test

      • Fuel (type or mixture)

        • When compliance based on fuel analysis

    • For HCl

      • Scrubber parameters (pH, pressure drop, liquid flow, sorbent injection rate)

        • Established during initial compliance test

      • Fuel (type or mixture)

        • When compliance based on fuel analysis


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COMPLIANCE MONITORING (cont.)

  • Monitoring

    • Opacity (by COM) – dry control systems

    • Fuel (monthly records)

    • Scrubber parameters

    • CO (new units only)

      • CEM for large units > 100 million Btu/hr

      • Annual CO tests for other new units

      • Exempt data from <50% load and based on 30-day average.


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What Subcategories Have Limited Requirements?

  • Subject to ONLY Initial Notification

    • Existing large and limited use gaseous fuel units

    • Existing large and limited use liquid fuel units

    • New small liquid fuel units that do not burn residual oil

  • NOT subject to Initial Notification or any other requirements in General Provisions

    • Existing small solid fuel units

    • Existing small liquid fuel units

    • Existing small gaseous fuel units

    • New small gaseous fuel units


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Additional Compliance Provisions

  • Emission Averaging

    • Only existing large solid fuel units

    • Initial compliance based on maximum capacity

    • Continuous compliance on a 12-month rolling average basis

      • Each monthly calculation based on monthly fuel use and previous compliance test results for each boiler

    • Must submit emission averaging plan

    • Must maintain, at a minimum, the emission controls employed on the effective date


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Additional Compliance Provisions

  • Health-based HCl compliance alternative

    • Alternative to complying with HCl MACT limit

      • Must include appropriate units covered by subpart DDDDD

        • Those that emit HCl and/or Cl2

      • Must conduct HCl and chlorine emission tests or fuel analyses

        • When conducting fuel analysis must assume any chlorine is emitted as CL2

      • Must calculate total maximum hourly mass HCl-equivalent emission rate

    • Compliance determine by using:

      • Lookup table

        • Average stack height of appropriate subpart DDDDD units

        • Minimum distance of any appropriate subpart DDDDD unit to property boundary

      • Site-specific compliance demonstration

        • Hazard Index (HI) can not exceed 1.0


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Additional Compliance Provisions

  • Health-based TSM compliance alternative

    • As alternative to complying with TSM limit based on 8 metals, may demonstrate compliance with TSM limit based on 7 metals by excluding manganese

      • Must include appropriate units covered by subpart DDDDD

      • Must conduct manganese emission tests or fuel analyses

      • Must calculate the total maximum hourly mass manganese emission rate

    • Eligible for demonstrating compliance based on 7 metals excluding manganese by using:

      • Lookup table

        • Average stack height of appropriate subpart DDDDD units

        • Minimum distance to property boundary

      • Site-specific compliance demonstration

        • Hazard Quotient (HQ) can not exceed 1.0


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Additional Details of Health-Based Compliance Alternatives

  • Demonstrations filed with permitting authority and EPA along with certification of authenticity and accuracy

    • No review or approval required; EPA, permitting authority may audit a percentage

  • Facility must apply for Title V permit modification to include parameters that defined the source (fuel type, control devices, stack parameters)

  • Facilities must submit demos within 2 years, one year prior to compliance date


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Petitions For Reconsideration

  • Three petitions for reconsideration were received

    • General Electric Company

    • Joint petition

      • NRDC

      • EIP (Environmental Integrity Project)

    • EIP

  • Two petitions for judicial review

    • Jointly filed by NRDC, Sierra Club, and EIP

      • Issues same as in reconsideration petition

    • American Public Power-Ohio (and 6 municipalities)

      • EPA exceeded its authority in imposing standards on small municipal utility boilers


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GE Petition

  • Issue

    • Requests clarification that the rule allows for testing at the common stack rather than each duct to the stack

    • No opportunity to provide comments since the proposed rule did not contain regulatory text for the emissions averaging provision

    • Common stack testing is handled on a case-by-case basis by OECA/Regions

      • OECA’s general policy is that each duct to a common stack must be tested


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NRDC – EIP Petition

  • Seeking reconsideration on:

    • Lack of standards for all HAP emitted on all subcategories

    • Health-based compliance alternatives

      • CAA does not authorize plant-by-plant risk-based exemptions

      • Basis for development of health-based compliance alternatives

      • Procedures for demonstrating compliance (Appendix A)


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Recent Federal Register Notice

  • FR June 27, 2005, Vol. 70, Num. 122, pg 36907-36915

  • Request for comments on:

    • Tiered Risk assessment Methodology (appendix A)

      • Look-up tables and Methodology (HCL, Mn, appendix A)

      • Site Specific Risk Assessment Process (section 7, appendix A)

      • HI or HQ of 1.0 for HCL, Cl, Mn (applicability cut off for RA’s)

    • Background concentrations (were not considered)

    • Overall Adoption of Health based compliance alternative for Mn

    • Exclusion of Mn from the TSM limit in table 1

  • Correction

    • Health based compliance alternatives for HCL & TSM are applicable to any affected source (not only large solid fuel subcategory)


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Questions Received

  • What does “Equivalent” mean in Table 6 ? (Fuel Analysis Requirements)

  • Are “hybrid boilers” considered firetube or watertube boilers?

  • Can a common stack be tested instead of the individual ducts?

  • Are auxiliary boilers at power plants covered by subpart DDDDD?


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INFORMATION SITES

  • Implementation tools (timelines, initial notification, state/local contacts, Q/A) and information on the MACT rulemaking for DDDDD is available on EPA’s web site at:

    • www.epa.gov/ttn/atw/boiler/boilerpg.html

  • An electronic version of public docket (including public comments) is available at:

    • www.epa.gov/edocket/

    • Search for docket ID No. OAR-2002-0058


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Contacts

Rule DevelopmentCompliance

Jim EddingerGreg Fried (OECA)

919-541-5426 202-564-7016

[email protected]@epa.gov

Region 4

Leonardo Ceron

404-562-9129

[email protected]


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The Effects of Asking Questions


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ANY QUESTIONS?


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