Boiler Area Source Rule Kenya Stump, Environmental Assistance Branch Manager, DCA A Program of the Kentucky Division of Compliance Assistance.

Boiler Area Source Rule

Kenya Stump, Environmental Assistance Branch

Manager, DCA

A Program of the Kentucky Division of Compliance Assistance

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

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?

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• 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.

What if Sources Need Help?

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• 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

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?

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.

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)

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.

Are you an area source?

• You must be an area source for Hazardous Air Pollutants (HAPs).

Check your permit for your classification.

Determining your requirements

• Emission limitations• Energy assessments• Tune-up requirements

Click here to see which of the threerequirements are applicable to your source.

Important Compliance Dates

• Existing: March 21, 2014

• New: May 20, 2011 or upon startup

Important Reports

• Initial Notifications• Notification of Compliance Status Reports

(NOCS)– Requires electronic submittal– Up to three could be required

• Testing• Tune Up• Energy Assessment

For More InformationDivision 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– [email protected]

EPA Major Sources– Brian Shrager – 919-541-5689– [email protected]

EPA Area Sources– Jim Eddinger

[email protected]

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Websites:http://www.epa.gov/ttn/atw/boiler/boilerpg.html

http://www.combustionportal.org/

Boiler MACT Tune-up Requirement

Subpart JJJJJJ – NESHAP for area sourcesSubpart DDDD- NESHAP for major sources

Chad Von GruenigenCompliance Assistance Specialist

The elephant in the room.

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.

What is a NESHAP?

• National Emission Standards for Hazardous Air Pollutants

What is a MACT?

• Maximum Achievable Control Technology.

• The Boiler MACT effects major and area sources for hazardous air pollutants (HAP)

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.

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.

Is a tune-up required? Heat Capacity ( Btu/Hr)

ExistingBiomassUnits

New (June 4th 2010)BiomassUnits

ExistingSeasonal or limited use units

New (June 4th 2010)Seasonal or limited use units

>10 MM Yes *

Yes * Yes Yes

<10 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.

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.

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, aren’t seasonal or limited use every 2 years.

Initial Notification of Applicability

• Submit no later than January 20, 2014

• This one is easy and it’s hardcopy!

Where do I send the initial notification form?

• This one is a hard copy.• Mail to:

– Kentucky Division for Air QualityProgram Planning BranchAttn: Jim Eubank200 Fair Oaks Lane, 1st Floor Frankfort, Kentucky 40601

– Jefferson County (only for Jefferson Co. facilities) Louisville Metro Air Pollution Control District

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 it’s a requirement.

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.

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.

Before you begin

• Preparation– Identify intent– Assemble boiler information– Identify environmental regulations– Identify measurement location– Establish tune-up timeframe etc.

• Make as-found observations

Document tune-up

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

Step 1

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

• Inspect the flame pattern and adjust the burner to optimize the flame pattern.

• A hot water heater is basically a small boiler. (Not regulated)

Step 2

• 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

Step 3

Where do I get a meter?

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

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

Step 4

• Optimize total emissions of carbon monoxide.

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

Step 5

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

• Maintain a report containing information highlighted in 40 CFR 63.11224

Step 6

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

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)

“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

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

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.

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.

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/

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.

Where do I go for help?

• Don’t forget the Division of Compliance Assistance (DCA) is here for you.

– Email: [email protected]– Call: (800) 926-8111

Area Source Boiler Energy Assessment

40 CFR 63 Subpart 6J

Emily OhdeCompliance Assistance Specialist

Who must conduct an Energy Assessment?

≥ 10 MMBtu/hr

Existing*

Biomass Coal Oil

YES YES YES

* Commenced construction or reconstruction prior to June 4, 2010

When: March 21, 2014 Area Source of HAPs

When: March 21, 2014 Area Source of HAPs

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)

Not Required?

Opportunities!!

– Energy Savings– Better Operating Practices– Sustainability– Health & Safety

Financial Savings!$$

$$

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

Definitions

Qualified Energy Assessor

Boiler System

Energy Use System

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:

Qualified Energy Assessor

– Assessment activities, data analyses, and report preparation

– Familiarity with O&M

– System improvement

– Cogeneration systems

– Industry specific end-use

Capabilities & Knowledge including:

QEA may be a company employee or outside specialist

QEA may be a company employee or outside specialist

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

Directly connected to &

serving the energy use

system

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

Located on the site of the

affected boiler

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

Duration RequirementsAnnual

Heat Input (Trillion Btu/yr)

Annual Input in MMBtu/hr

@ 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

< 0.3 < 34.2 8 hours At least 50%0.3 – 1.0 34.2-114.2 24 hours At least 33%> 1.0 114.2 24 hours for 1st

TBtu + 8 hours for

each additional TBtu*

At least 20%

*Not to exceed 160 hoursℓOn-site technical labor hours

1. Visual Inspection

• Cracks• Corrosion• Leaks• Insulation

2. Evaluation of Operating Characteristics

• Specifications of energy use systems

• Operating and maintenance procedures, &

• Unusual operating constraints

3. Inventory of energy consuming systems

Power Generation

Unit

Heat Recovery System

Electric Chiller

Absorption Chiller

HeatingCoil

Boiler

Exhaust

Ep EecEpgu

Fpgu

FbFm Qb

QF QFC

Qrh

Qh

Qc

Qec

Qac

EEgrid

Building

4. Review of plans, operations, and

maintenance• Architectural and Engineering plans• Facility wide operation &

maintenance procedures – Logs & fuel use

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 boiler’s fuel use is reduced by 1%.

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 facility’s total energy use with an average simply payback of 5 months

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 boiler’s fuel use.

Removing a 1/32 inch deposit on boiler heat transfer surfaces can decrease a boiler’s fuel use by 2%; removal of a 1/8 inch deposit can decrease boiler fuel use by over 8%.

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)

Use for comfort/space heating or process heat, replacing other energy inputs

Waste Heat = Power (economizer)

7. Comprehensive Report

• Improve efficiency

• Costs and Benefits of specific improvements• Time frame for recuperation of

investments

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 operation

s

Greater productivity & more revenue

Cost?

• Varies dependent on system(s) extent and complexity– Conduct energy assessment– Hire a consultant (as needed)

• Improvements: – Payback within 2 years or less

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

Inquiry……a qualified energy assessor to conduct the one-time energy

assessment in accordance with the boiler MACT for a biomass boiler.

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

Due By: July 19, 2014

Resources

• Emission Reductions: How to, Benefits, and Costs

• EPA Air Toxics Web Site: Industrial/Commercial/Institutional Boilers and Process Heaters

• EPA Boiler Compliance at Area Sources

• EPA Combined Heat and Power Partnership

• DOE Boiler MACT Technical Assistance

Any Questions

Contact Information:Division of Compliance Assistance

[email protected]