Published on March 15, 2011
EPA Air Toxics Standards for Boilers
and Process Heaters
James A. Westbrook
March 15, 2011
Agenda Rule Introduction – Standards for Boilers and Process Heaters NOT cover Incinerators Applicability (and not applicable) Major and Area Sources Affected and Non-Affected, New & Existing Units Large and small units, by unit and fuel type Requirements – notification, limits, work practice requirements, testing, records and reporting Case Studies – Refinery and Biomass Plant
About BlueScape 20 years experience, air quality compliance Permits, air modeling, compliance for boilers and heaters, various fuels National Experience Solve tough air quality compliance issues: - Determining rule applicability - Assess how to reduce impacts, change status - Develop monitoring, recordkeeping and reporting protocols - Agency negotiations
Introduction to the Boiler Air Toxics Rules 40 CFR 63 Subpart DDDDD, NESHAP Finalized February 21, 2011 Effective 60 days from publish in Federal Register New and existing industrial, commercial and institutional boilers and process heaters Regulate HCl, Hg, PM, dioxins/furans, and CO Major Source Rule, 15 unit-based subcategories Area Source Rule, 4 general subcategories Parts will be reconsidered
Applicability Major or area source? Major Source = 10 tpy or more of any single HAP or 25 tpy or more of any combination of HAP Only boilers at area sources, not process heaters Affected source, New or Existing Collection of boilers and heaters at a source within a subcategory New or reconstructed, commence construction or reconstruction after June 4, 2010 Existing affected source, June 4, 2010 Fuel subcategory? Major source, 10% rule to determine source category and emission limits Area source, 15% rule to determine source category and emission limits
Not Applicable, Major Sources Electric utility steam generating unit Recovery boiler or furnace under Subpart MM Boiler or heater for research and development Hot water heater Refining kettle under Subpart X Ethylene cracking furnace Blast furnace stoves Boiler or process heater part of the affected source subject to another NESHAP Boiler of process heater used as a control device Temporary boilers Blast furnace gas fuel-fired boilers and process heaters Clean Air Act Section 129 and Solid Waste Disposal Act boilers
Major Source RequirementsLarge Boilers & Heaters (>= 10 MMBtu/hr) 7
Major Source RequirementsSmall Boilers & Heaters (< 10 MMBtu/hr) 8
Area Source RequirementsLarge Boilers & Heaters (>= 10 MMBtu/hr) 9
Area Source RequirementsSmall Boilers & Heaters (< 10 MMBtu/hr) 10
Tune-Up Program, Major Sources Inspect burner, clean replace components Inspect flame pattern, adjust Inspect system controlling air-to-fuel ratio, calibrate Optimize CO emissions per manufacturer Measure CO before and after adjustments Submit annual reports, CO ppm and fuel data
12 Emission Limits, Major Sources Reference: USEPA
13 Emission Limits, Area Sources Reference: USEPA
Emission Limit Comparisons 14 CO, ppm PM, lb/MMBtu
Startup, Shutdown & Malfunctions Applies to both boiler and process heaters at major sources and boilers at area sources Work practice standards Manufacturer’s recommended procedures Minimize emissions and prevent future malfunctions
Notification, Recordkeeping & Reporting Semiannual compliance reports Notification of compliance status report Records of compliance and tune-ups Records of continuously monitored data Electronic Reporting Tool (ERT) - Submission of test results
Compliance Schedule Boilers and process heaters, major sources - New, comply 60 days from rule date, or startup - Existing, 3 years from rule date Boilers located at an area source - New, comply 60 days from rule date, or startup - Existing, tune-up compliance no later than 1 year from rule date - Existing, emission limits no later than 3 years after rule date
Case Study: Refinery 3 boilers and 10 process heaters, existingMajor Source of HAPsCombust refinery gas, Gas 1 SubcategoryOne affected facility, all 13 unitsAnalysis:- Annual Tune-Up, 1-Time Energy Assessment (more extensive) - Minimizing Periods of Startup and Shutdown - Minimize and Correct Malfunctions Recordkeeping and Reporting
3 boilers and 10 process heaters, existing
Major Source of HAPs
Combust refinery gas, Gas 1 Subcategory
One affected facility, all 13 units
Recordkeeping and Reporting
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