Boiler Area Source Rule

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

2. 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

3. 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 yearand will not have to install pollution control equipment. • Boilers burn fuel to produce steam that is used for heat or electricity • Process heatersheat 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

4. 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.

5. 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

6. Questions to Answer First! • Do I have boiler? • Is my boiler subject to the rule? • Am I a major source for HAPs? • What size are my boilers? • What type of boiler do I have? • What fuel do I combust? • What are my installation dates on my boilers?

7. 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.

8. 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)

9. 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.

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

11. Determining your requirements • Emission limitations • Energy assessments • Tune-up requirements Click here to see which of the three requirements are applicable to your source.

12. Important Compliance Dates • Existing: March 21, 2014 • New: May 20, 2011 or upon startup

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

14. For More Information 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@ky.gov EPA Major Sources • Brian Shrager • 919-541-5689 • shrager.brian@epa.gov EPA Area Sources • Jim Eddinger919-541-5426eddinger.jim@epa.gov Websites: http://www.epa.gov/ttn/atw/boiler/boilerpg.html http://www.combustionportal.org/

15. Boiler MACT Tune-up Requirement Subpart JJJJJJ – NESHAP for area sources Subpart DDDD- NESHAP for major sources Chad Von Gruenigen Compliance Assistance Specialist

16. The elephant in the room.

17. 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.

18. What is a NESHAP? • National Emission Standards for Hazardous Air Pollutants

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

20. 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.

21. 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.

22. Is a tune-up required? * Provided the boiler uses an oxygen trim system that maintains an optimum air-to-fuel ratio, otherwise tune-ups required biennially.

23. 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.

24. 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.

25. Initial Notification of Applicability • Submit no later than January 20, 2014 • This one is easy and it’s hardcopy!

26. 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

27. 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.

29. 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.

30. 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.

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

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

33. Step 1 • Inspect the burner / boiler and clean or replace components necessary.

34. 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)

35. 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

36. Where do I get a meter? • For around $1,800 dollars you can get everything you need.

37. Step 4 • Optimize total emissions of carbon monoxide. This can even be done on a hot water heater as shown in the picture

38. 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

39. 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

40. 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)

41. “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

42. 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

43. 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.

44. 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.

45. 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/

46. 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.

47. Where do I go for help? • Don’t forget the Division of Compliance Assistance (DCA) is here for you. • Email: envhelp@ky.gov • Call: (800) 926-8111

48. Area Source Boiler Energy Assessment 40 CFR 63 Subpart 6J Emily Ohde Compliance Assistance Specialist

49. Who must conduct an Energy Assessment? * Commenced construction or reconstruction prior to June 4, 2010 When: March 21, 2014 Area Source of HAPs

50. 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)