Boiler Area Source Rule

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Boiler Area Source Rule

• Kenya Stump,
• Environmental Assistance Branch Manager, DCA

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Who We Are?

• Environmental Compliance Assistance Program
  (ECAP)
• Located in Division of Compliance Assistance
  (DCA)
• Provides assistance on air, water, and waste
• Detailed assistance available to small businesses
• Kenya Stump, Chad Von Gruenigen, Emily Ohde

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Terminology?

• The Boiler MACT covers boilers and process
  heaters located at major sources of hazardous air
  pollutants (HAP). Subpart DDDDD
• The Boiler Area Source Rule covers boilers at
  area sources of HAP. Subpart JJJJJJ
• Rule does NOT apply to boilers that are gas-fired
  (approximately 1.3 million units, or 87 of all
  area source boilers) or process heaters.
• Most units that are covered by this rule will be
  required to conduct a tune-up every other year
  and will not have to install pollution control
  equipment.
• Boilers burn fuel to produce steam that is used
  for heat or electricity
• Process heaters heat raw or intermediate
  materials during an industrial process
• A major source is a facility that has the
  potential to emit 10 or more tons per year (tpy)
  of any single HAP or 25 tpy or more of any
  combination of HAP.
• An area source is a facility that has the
  potential to emit less than10 tons per year (tpy)
  of any single HAP or less than 25 tpy of any
  combination of HAP.
• HAP Hazardous Air Pollutant
• KyDAQ Division for Air Quality
• EPA Environmental Protection Agency

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Why Do We Have These Rules?

• These rules satisfy Clean Air Act requirements
  for air toxics
• EPA is legally bound to issue these rules
• Developed under Clean Air Act sections 112 and
  129
• Require EPA to set technology-based standards for
  toxics
• Reflect levels achieved by best-performing
  existing sources
• Generally may set less stringent standards for
  boilers at area sources.

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What if Sources Need Help?

• DCA and DAQ are providing ongoing compliance
  assistance
• U.S. Dept. of Energy (DOE) and the U.S. Dept. of
  Agriculture (USDA)
• DEP and UK Compliance Assistance Partnership
• KPPC

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Questions to Answer First!

1. Do I have boiler?
2. Is my boiler subject to the rule?
3. Am I a major source for HAPs?
4. What size are my boilers?
5. What type of boiler do I have?
6. What fuel do I combust?
7. What are my installation dates on my boilers?

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Who is affected by the rules?

• Owners or operators of an industrial, commercial,
  or institutional boiler or process heater
• Boiler means an enclosed device using controlled
  flame combustion and having the primary purpose
  of recovering thermal energy in the form of steam
  or hot water.
• Process heater means an enclosed device using
  controlled flame, and the unit's primary purpose
  is to transfer heat indirectly to a process
  material (liquid, gas, or solid) or to a heat
  transfer material for use in a process unit,
  instead of generating steam.

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Items Not Covered

• Gas-fired boilers (a boiler that primarily burns
  gas is still considered a gas-fired boiler even
  if it also burns oil or other liquid fuel during
  periods of gas curtailment, gas supply
  interruption, startups, or for periodic testing
  not to exceed 48 hours during any calendar year)
• Boilers that burn solid waste (these boiler are
  subject to incinerator standards)
• Hot water heaters
• Waste heat boilers
• (heat recovery steam generators)
• Temporary boilers

• Residential boilers
• Electric boilers
• Electric utility steam generating units (EGUs)

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Existing Or New?

• New source means that you commenced construction
  or reconstruction of the boiler or process heater
  after June 4, 2010 and you meet the applicability
  criteria at the time you commence construction.
• Existing source means you commenced construction
  or reconstruction of the boiler or process heater
  on or before June 4, 2010.

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Are you an area source?

• You must be an area source for Hazardous Air
  Pollutants (HAPs).
• Check your permit for your classification.

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Determining your requirements

• Emission limitations
• Energy assessments
• Tune-up requirements

Click here to see which of the three requirements
are applicable to your source.
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Important Compliance Dates

• Existing March 21, 2014
• New May 20, 2011 or upon startup

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Important Reports

• Initial Notifications
• Notification of Compliance Status Reports (NOCS)
• Requires electronic submittal
• Up to three could be required
• Testing
• Tune Up
• Energy Assessment

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For More Information

• EPA Major Sources
• Brian Shrager
• 919-541-5689
• shrager.brian_at_epa.gov
• EPA Area Sources
• Jim Eddinger919-541-5426eddinger.jim_at_epa.gov

• Division for Air Quality
• Jim Eubank
• 502-564-3999 ext. 4419
• Division of Compliance Assistance
• Kenya Stump, Emily Ohde, or Chad Von Gruenigen
• 800-926-8111
• envhelp_at_ky.gov

Websites http//www.epa.gov/ttn/atw/boiler/boiler
pg.html http//www.combustionportal.org/
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Boiler MACT Tune-up Requirement

• Subpart JJJJJJ NESHAP for area sources
• Subpart DDDD- NESHAP for major sources

Chad Von Gruenigen Compliance Assistance
Specialist
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• The elephant in the room.

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Boiler MACT

• December 20, 2012 the EPA finalized the Boiler
  MACT.
• This means the rules officially take affect.
• The good news is there is time.

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What is a NESHAP?

• National Emission Standards for Hazardous Air
  Pollutants

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What is a MACT?

• Maximum Achievable Control Technology.
• The Boiler MACT effects major and area sources
  for hazardous air pollutants (HAP)

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Now what are major and area sources?

• Major source- emits 10 tons per year of any
  single HAP or 25 tpy of any combined HAPs.
• Area source- any stationary source of HAPs that
  is not a major source.

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Whose not subject?

• Any gas-fired boiler
• Hot water heaters
• Temporary boilers (used for less than 12 months)
• Residential boilers
• Electric boilers
• Waste heat boiler (heat recovery steam
  generators)
• Boilers used as control devices for other
  standards
• Research and development boilers
• Boilers subject to other NESHAP standards.

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Is a tune-up required?
Heat Capacity ( Btu/Hr) Existing Biomass Units New (June 4th 2010) Biomass Units Existing Seasonal or limited use units New (June 4th 2010) Seasonal or limited use units
gt10 MM Yes Yes Yes Yes
lt10 MM Yes Yes Yes Yes
Provided the boiler uses an oxygen trim system
that maintains an optimum air-to-fuel ratio,
otherwise tune-ups required biennially.  
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What is Seasonal or Limited Use?

• Seasonal- boiler that undergoes a shutdown for at
  least 7 consecutive months each 12 month period.
• Limited Use- boiler that burns any amount of
  solid or liquid fuels and has a federally
  enforceable average annual capacity of no more
  than 10 percent.

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How frequently must I perform a tune-up

• If the boiler is equipped with an oxygen trim
  system, is a seasonal or limited use every 5
  years.
• Boilers without an oxygen trim system, arent
  seasonal or limited use every 2 years.

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Initial Notification of Applicability

• Submit no later than January 20, 2014
• This one is easy and its hardcopy!

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Where do I send the initial notification form?

• This one is a hard copy.
• Mail to
• Kentucky Division for Air Quality
• Program Planning Branch
• Attn Jim Eubank
• 200 Fair Oaks Lane, 1st Floor
• Frankfort, Kentucky 40601
• Jefferson County (only for Jefferson Co.
  facilities)
• Louisville Metro Air Pollution Control
  District

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Why perform a tune-up?

• The overall savings outweigh the initial costs.
• Less biomass burned less time, money and
  product wasted.
• A tune-up extends the life of your boiler.
• Not to mention its a requirement.

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What if I already perform a tune-up

• If you conduct the tune-up early the next tune-up
  is due no later than 25 months or 61 months as
  applicable. (This is the same time frame allowed
  for new boilers)
• If the boiler is shutdown the tune-up must be
  conducted within 30 days of start up.

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Who can perform a tune-up?

• There is no certification requirement to conduct
  a boiler tune-up.
• You will likely need someone that has boiler
  experience.

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Before you begin

• Preparation
• Identify intent
• Assemble boiler information
• Identify environmental regulations
• Identify measurement location
• Establish tune-up timeframe etc.
• Make as-found observations

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Document tune-up

• As-found conditions
• Post tune-up conditions
• Modifications and repairs completed
• Recommended investigations and modifications
• Identified shortcomings of equipment

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Step 1

• Inspect the burner / boiler and clean or replace
  components necessary.

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Step 2

• Inspect the flame pattern and adjust the burner
  to optimize the flame pattern.
• A hot water heater is basically a small boiler.
  (Not regulated)

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Step 3

• Inspect the air-to-fuel ratio to ensure it is
  calibrated and functioning properly, if such a
  system is installed on the boiler.

This can even be done on a hot water heater as
shown in the picture
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Where do I get a meter?

• For around 1,800 dollars you can get everything
  you need.

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Step 4

• Optimize total emissions of carbon monoxide.

This can even be done on a hot water heater as
shown in the picture
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Step 5

• Measure the effluent stream of carbon monoxide
  and oxygen before and after adjustments.

This can even be done on a hot water heater as
shown in the picture
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Step 6

• Maintain a report containing information
  highlighted in 40 CFR 63.11224

This can even be done on a hot water heater as
shown in the picture
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Initial Tune-up Compliance

• Complete no later than March 21, 2014
• Deadline for submitting the notification of
  compliance status (NOCS) July 19, 2014
• (This submittal will be electronic)

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Yes I said the notification of compliance status
(NOCS) is electronic.

• Compliance and Emissions Reporting Interface
  (CEDRI)
• Central Data Exchange (CDX)
• www.epa.gov/cdx

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What questions can you expect?

• Information about the tune-up conducted as
  described above. (comments / corrective actions)
• Carbon Monoxide (CO) levels (ppmv)
• Oxygen (O2) (by volume)
• Fuel used or delivered 12 months preceding tune-up

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Initial Tune-up Compliance

• Maintain records of dates and procedures of each
  boiler tune-up and the fuel used by the boiler.
• Required information highlighted in 40 CFR
  63.11224
• Maintain records on-site for the first two yeas
  and keep record for at least five years.

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Subsequent Tune-up Compliance

• Conduct the same performance tune-up as the
  initial tune-up in 40 CFR 63.11223
• Complete the compliance certification for each
  tune-up. Currently this does not have to be
  submitted but now that submittal is electronic
  this will likely be a required submittal.

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Where do I go for help?

• Type in Boiler Compliance in Google and click
  boiler compliance at area sources.
• Type in Boiler MACT in Google and click on
  industrial/ commercial/ industrial boilers and
  process heaters
• http//www.epa.gov/airtoxics/boiler/boilerpg.html
  

http//www.epa.gov/boilercompliance/
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Useful Materials

• Implementation tools
• Initial Notification of Applicability for AREA
  Sources
• Tune-up Guidance and Example Recordkeeping From-
  AREA SOURCES
• Small Entity Compliance Guide for Area Source
  Boilers
• Boiler Tune-up Guide for Owners Operators
• Boiler Tune-up Guide for Technicians.

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Where do I go for help?

• Dont forget the Division of Compliance
  Assistance (DCA) is here for you.
• Email envhelp_at_ky.gov
• Call [phone]

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Area Source Boiler Energy Assessment

• 40 CFR 63 Subpart 6J

Emily Ohde Compliance Assistance Specialist
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Who must conduct an Energy Assessment?
10 MMBtu/hr Existing Existing Existing
10 MMBtu/hr Biomass Coal Oil
10 MMBtu/hr YES YES YES
Commenced construction or reconstruction prior
to June 4, 2010
When March 21, 2014 Area Source of HAPs
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Exceptions

• ? Limited-use units (exemption)
• ? Facilities that have already completed Energy
  Assessment meeting the rule requirements on or
  after 1/1/2008 (satisfies requirement)
• ? Facilities operating under Energy Management
  System compatible with ISO 50001 that includes
  affected units (satisfies requirement)

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Not Required?

• Opportunities!!
• Energy Savings
• Better Operating Practices
• Sustainability
• Health Safety
• Financial Savings!

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Achieving Savings

• Locating and eliminating leaks
• Adjust operational procedures/equipment
• Identify recovery opportunities
• Conserving flash steam
• Returning condensate
• Energy efficiency
• Combined Heat and Power systems

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Definitions

• Qualified Energy Assessor
• Boiler System
• Energy Use System

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Qualified Energy Assessor

• Combustion Management
• Thermal energy recovery
• Blowdown thermal energy recovery
• Resource selection (fuel switching applied vs
  direct-fired)
• Insulation issues
• Steam trap and leak mgt
• Condensate recovery
• Steam end-use mgt

• Demonstrated capabilities to evaluate
  opportunities for steam generation and major
  energy use systems including

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Qualified Energy Assessor

• Assessment activities, data analyses, and report
  preparation
• Familiarity with OM
• System improvement
• Cogeneration systems
• Industry specific end-use

• Capabilities Knowledge including

QEA may be a company employee or outside
specialist
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Boiler System

• Boiler and associated components
• Feedwater systems
• Combustion air systems
• Fuel systems (including
• burners)
• Blowdown systems
• Combustion control systems
• Steam systems
• Condensate return systems

Directly connected to serving the energy use
system
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Energy Use System

• Process heating compressed air systems machine
  drive (motors, pumps, fans) process cooling
  facility heating, ventilation, and AC hot heater
  system building envelope lighting
• Other systems that use
• Steam, hot water, or electricity
• (provided by the boiler)
• Only systems using energy clearly produced by
  affected boiler(s)

Located on the site of the affected boiler
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The Requirements

1. Visual inspection of boiler system
2. Evaluation of operating characteristics
3. Inventory of energy consuming systems
4. Review of plans, operations, and maintenance
5. Energy Conservation Measures
6. Energy savings from conservation measures
7. Comprehensive report

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Duration Requirements
Annual Heat Input (Trillion Btu/yr) Annual Input in MMBtu/hr _at_ 8760 hours Length of assessment not to exceedl On-site energy use systems that account for the following of the energy product from affected boiler
lt 0.3 lt 34.2 8 hours At least 50
0.3 1.0 34.2-114.2 24 hours At least 33
gt 1.0 114.2 24 hours for 1st TBtu 8 hours for each additional TBtu At least 20
Not to exceed 160 hours lOn-site technical labor
hours
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1. Visual Inspection

• Cracks
• Corrosion
• Leaks
• Insulation

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2. Evaluation of Operating Characteristics

• Specifications of energy use systems
• Operating and maintenance procedures,
• Unusual operating constraints

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3. Inventory of energy consuming systems
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4. Review of plans, operations, and maintenance

• Architectural and Engineering plans
• Facility wide operation maintenance procedures
• Logs fuel use

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5. Energy Conservation Measures 6. Energy Savings
Comprehensive tune-ups and correcting excessive air losses, high stack temperatures, and excessive smoking Can result in fuel savings up to 20.
Installing insulation on hot water and steam pipes over 120F Ensure excessive heat is not lost in transmission
Combustion efficiency analyses A 3 decrease in flue gas O2 typically produces boiler fuel savings of 2.
Reset hot water supply temperature For every 11 deg F that the entering feed-water temperature is increased, the boilers fuel use is reduced by 1.
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5. Energy Conservation Measures 6. Energy Savings
An upgraded boiler maintenance program including optimizing air-to-fuel ratio, burner maintenance, and tube cleaning Can save about 2 of a facilitys total energy use with an average simply payback of 5 months
An upgraded boiler maintenance program including optimizing air-to-fuel ratio, burner maintenance, and tube cleaning Every 40 deg F reduction in net stack temperature (outlet temperature minus inlet combustion air temperature is estimated to save 1 to 2 of a boilers fuel use.
An upgraded boiler maintenance program including optimizing air-to-fuel ratio, burner maintenance, and tube cleaning Removing a 1/32 inch deposit on boiler heat transfer surfaces can decrease a boilers fuel use by 2 removal of a 1/8 inch deposit can decrease boiler fuel use by over 8.
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5. Energy Conservation Measures 6. Energy Savings
Installation or conversion to combined heat and power systems (co-generation) Use heat generated instead of heat dissipation to cooling towers (wasting energy)
Installation or conversion to combined heat and power systems (co-generation) Use for comfort/space heating or process heat, replacing other energy inputs
Installation or conversion to combined heat and power systems (co-generation) Waste Heat Power (economizer)
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7. Comprehensive Report

• Improve efficiency
• Costs and Benefits of specific improvements
• Time frame for recuperation of investments

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Results

• Encouraged but not required to use results of the
  energy assessment to increase energy-efficiency
  and cost-efficiency of the boiler system

Activities that instill energy efficiency
Control over heat power resources
Increased reliability of operations
Greater productivity more revenue
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Cost?

• Varies dependent on system(s) extent and
  complexity
• Conduct energy assessment
• Hire a consultant (as needed)
• Improvements
• Payback within 2 years or less

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Providers

• DOE's Clean Energy Application Centers (CEACs)
  will offer technical assistance, site visits to
  discuss strategies, and provide information on
  potential funding and financing opportunities to
  assist with CHP, boiler tune-ups and/or energy
  assessments.
• KPPC
• Private Company
• Universities

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Energy Assessment CompletedNow What?

• Submit Notification of Compliance Status
• If the facility must demonstrate compliance with
  emission limits
• Different NOCS (has checkbox for EA NOCS)
• EL NOCS submitted within 60 days of completion

Due By July 19, 2014
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Resources

• Emission Reductions How to, Benefits, and Costs
• EPA Air Toxics Web Site Industrial/Commercial/Ins
  titutional Boilers and Process Heaters
• EPA Boiler Compliance at Area Sources
• EPA Combined Heat and Power Partnership
• DOE Boiler MACT Technical Assistance

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Any Questions

• Contact Information
• Division of Compliance Assistance
• 800-926-8111
• www.dca.ky.gov
• envhelp_at_ky.gov