Environmental Compliance Hot Topics Hardwood Plywood Veneer Association May 25, 2010
Mar 31, 2015
Environmental Compliance Hot Topics
Hardwood Plywood Veneer AssociationMay 25, 2010
Today’s Top 2
•SPCC•Boiler MACT
Spill Prevention, Control, and Countermeasure (SPCC)
Rule
SPCC Rule
• This impacts me if I have:– An underground storage of greater than 42,000
gallons; or– An aboveground storage of greater than 1,320 gallons
(only container of 55 gallons or greater are counted); and
– Due to location, could reasonably be expected to discharge oil in quantities that may be harmful into or upon “navigable waters” of the U.S.
– Must exclude consideration of manmade features like dikes, equipment and/or other structures
SPCC Rule Revisions
• On November 5, 2009, EPA issued revisions to the SPCC Rule
• The new deadline for compliance with the rule is November 10, 2010
• Expect to see increased inspection presence from EPA
• Typical fines for not having a plan $1000-$7000• If you have a release- escalates to the cost of
cleanup, and $$$$ in fines
Action to Take Now
• Prepare and/or Update your SPCC plan
• Follow the plan• Remember- compliance date is
November 10, 2010
Proposed Boiler MACT
What Happened?
• On April 29, 2010 EPA issued a proposed rule that would reduce toxic air pollutants from boilers and process heaters
• Provisions in the rule cover- essentially all boilers
• Currently proposed rule is out for public comment.
Will this Impact Me?
• If you have a boiler-YES• If you plan on installing a boiler –YES
Best Scenario
• You do not have a boiler• Your existing boiler is Natural gas fired
only (exempt)• Your existing boiler is small in size (<10
MMBTU/HR)• You have a temporary boiler only
(operates less than 180 consecutive days)(exempt)
What’s Required for the Best Scenario
• Biennial Tune-up– Inspect the burner-clean or replace components as
necessary– Inspect the flame pattern-make adjustments to
optimize– Inspect the system controlling the air-to-fuel ratio,
and ensure calibrated and functioning properly– Minimize the CO emissions following manufacturer
specifications– Measure CO emissions before and after adjustments
• Annual Report
Most Stringent Scenario
• You are a HAPS major source– Emit 10 tons or more of an individual HAP– Emit 25 tons or more of combined HAPs
• Focus on reductions for carbon monoxide, particulate, HCl, Mercury, and dioxin/furans.
• Standards are based on the fuel type for all parameters and both fuel type and boiler design for dioxin/furans and carbon monoxide standards.
What’s Required for the Most Stringent Scenario?
• Installation of Continuous Monitors• Installation of Controls• Energy Assessment• Initial and Annual Source Testing ($20-$30K)
Most Common Scenario
• You are not a HAPS Major but an “AREA SOURCE”– Emit less than 10 tons per year of any individual
HAP– Emit less than 25 tons per year of any combination
of HAPs
• Boilers are greater than 10 MMBTU/HR*
*(We’re not looking at coal for this scenario)
What’s Required for the Most Common Scenario?
• Initial and Annual Source Testing for Carbon Monoxide ($2500-$3000)
• New limits for particulate and CO for new sources of oil and biomass
• Particulate, CO, and mercury for coal sources• New limits for Carbon Monoxide for existing sources
– Will require “Generally Achievable Control Technology” (GACT).
– Methods, practices and techniques are commercially available and appropriate
• Energy Assessment
Energy Assessment Requirements• Energy assessment must be performed by
qualified personnel• A qualified specialist is someone:
– Who has successfully completed the Department of Energy’s Qualified Specialist Program for all systems or
– A professional engineer certified as a Certified Energy Manager by the Association of Energy Engineers.
Energy Assessment Requirements
• Complete a visual inspection and review of the boiler system.
• Establish operating parameters of the facility energy systems
• Identify the high energy sources, conservation measures, and potential savings
• Prepare a comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the timeline
Other Changes Proposed for the Boilers
• Proposed standards vary based on the fuel type• EPA is proposing either daily or monthly standards• Sources w/o wet scrubbers that have particulate
and mercury emission limits will require continuous opacity monitors
• Sources electing fuel sampling to comply with the mercury standard are required to sample monthly
• Recordkeeping and compliance reporting requirements
Compliance Timeline
• The final rule is to be complete by December 16, 2010.
• Compliance is required three years following the date of publication of the final rule.
Ways to send comments…
• Email: [email protected]• Fax: 202-566-9744• Mail: EPA Docket Center Environmental Protection Agency
Mailcode: 2822T 1200 Pensylvania Av., NW Washington, DC 20460DOCKET- ID No. EPA-HQ-OAR-2006-0790
Separate but Related Action• EPA has proposed updated definitions of
nonhazardous wastes and fuels with respect to boilers dictating how a unit is regulated under the boiler MACT
• Majority of the fuels we use are clean biomass.• If the fuels are under the control of the
generator and not contaminated will be considered non-hazardous solid waste.
• Concerns-with the treated wood, painted wood, construction debris with contaminants, and materials generated somewhere else.
Heather BartlettPrincipal EngineerSLR International Corp
Address: 1800 Blankenship Road, Suite 440, West Linn, OR 97068
Office: (503) 723-4423Facsimile: (503) 723-4436Email: [email protected]:
www.slrconsulting.com