New England Healthcare Engineers’ Society
Recently Promulgated National
Air Quality Regulations and
How They Will Impact Hospitals
Cathy Beahm
Technical Assistance Specialist
NH DES, Air Resources
Presentation Overview


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Air Emission Basics
Boiler Regulations
Emergency Generator Regulations
Questions
Air Emission Basics

Criteria Pollutants


The Clean Air Act (CAA) requires EPA to identify sources
of Hazardous Air Pollutants (HAPs) and develop
regulations to limit these emissions.


Products of combustion: Nitrogen Oxides (NOx), Carbon
Monoxide (CO), Sulfur Dioxide (SO2), Particulate Matter (PM)
and Volatile Organic Compounds (VOC) or Non-methane
hydrocarbons (NMHC)
Boilers, Incinerators and Reciprocating Internal Combustion
Engines
Hazardous Air Pollutants

List of 188 HAPs from the CAA can be found at
http://www.epa.gov/oar/toxicair/newtoxics.html
Air Emission Basics (continued)

EPA has developed both Major and Area Source
National Emission Standards for Hazardous Air
Pollutants (NESHAPs) promulgated under 40 CFR 63

Major vs. Area Sources


Major sources have the Potential to Emit (PTE) greater than
10 tpy individual HAP and 25 tpy combined HAPs

Area sources are facilities that are not major sources - who do
not have PTE above these levels either due to permit limitations
or design capacity.
Majority of Sources in NH are Area Sources
Hospital Specifics

Hospitals in NH are area sources of HAPs based on the
boilers and emergency generators currently permitted.


Hospitals typically burn traditional fuels in their boilers
(coal, biomass, oil or gas) as opposed to solid waste.




To determine your facility’s classification, you must calculate
your PTE of HAPs from all devices at your facility (boilers,
emergency generators, ethylene oxide sterilizers, etc.)
Presentation today is not covering HIMWI (none in NH – few, if
any, in New England).
Almost 97% of the hospitals in NH burn fuel oil alone or
in combination with natural gas.
One facility in NH operates 2 small (<10 MMBtu/hr)
biomass boilers.
Over 70% have at least one boiler >10 MMBtu/hr.
Boiler Regulations
Overview of recent EPA actions affecting boilers
EPA issued three rules that reduce emissions of HAPs:

NESHAP for Industrial, Commercial, and Institutional Boilers and
Process Heaters (40 CFR 63, Subpart DDDDD) (“Boiler MACT”)

NESHAP for Area Sources: Industrial, Commercial, and
Institutional Boilers (40 CFR 63, Subpart JJJJJJ) (“Boiler Area
Source Rule”)

Section 129 NSPS and Emission Guidelines for Commercial and
Industrial Solid Waste Incinerators (CISWI)
EPA also issued a final rule that defines “solid waste”

Necessary to determine whether a source must meet boiler
standards or an incinerator standard

Overview of recent EPA actions affecting boilers
(cont.)
Schedule



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EPA has initiated reconsideration of certain aspects of the boiler and
CISWI rules


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Some of the comments raise difficult technical issues that would benefit from
additional public involvement.
Stakeholders have petitioned for reconsideration of other issues.
Stay


Proposals signed on April 29, 2010
Published in the Federal Register on June 4, 2010
Promulgations signed on February 21, 2011 (Court-ordered)
Published in the Federal Register on March 21, 2011
Effective Date: May 20, 2011
On May 18, 2011, EPA delayed the effective date of the Boiler MACT and
CISWI
Boiler Area Source Rule and Solid Waste Definition are in effect even
during the reconsideration process.

Facilities need to comply with rules as they were promulgated.
Focus of Today’s Presentation:
Boiler Area Source Rule
Area Sources burning Traditional Fuel (oil)
Boiler Area Source Rule


Rule is broken down based on:
Boiler size:

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Fuel type:
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Small (<10 MMBtu/hr)
Large (≥10 MMBtu/hr)
Coal-fired units
Biomass-fired units
Oil-fired units
Boiler Construction:


Existing prior to June 4, 2010
New or reconstructed after June 4, 2010
Are any boilers not subject to this subpart?

Any boiler covered by another part of 40 CFR 63

Any boiler covered by CISWI

Hazardous waste boilers

A boiler that is used specifically for research and
development.


This exemption does not include boilers that solely or primarily
provide steam (or heat) to a process or for heating at a research and
development facility.
Any boiler that is used as a control device to comply with
another Subpart of 40 CFR 63, provided that at least 50
percent of the heat input to the boiler is provided by the gas
stream that is regulated under another subpart.
Are any boilers not subject to this subpart?
(continued)

A hot water heater as defined in this subpart.


Hot water heater means a closed vessel with a capacity of no more
than 120 U.S. gallons in which water is heated by combustion of
gaseous or liquid fuel and is withdrawn for use external to the vessel
at pressures not exceeding 160 psig, … and … water temperatures
exceeding 210°F.
A gas-fired boiler as defined in this subpart.

Gas-fired boiler includes any boiler that burns gaseous fuels not
combined with any solid fuels, burns liquid fuel only during periods
of gas curtailment, gas supply emergencies, or periodic testing on
liquid fuel. Periodic testing of liquid fuel shall not exceed a combined
total of 48 hours during any calendar year.
Fuel Switching Rule Provisions

A boiler is a new affected source if you commenced fuel switching from
natural gas to solid fossil fuel, biomass, or liquid fuel after June 4, 2010.

If you intend to switch fuels, and this fuel switch may result in the
applicability of a different subcategory or a switch out of Subpart JJJJJJ
due to a switch to 100 percent natural gas, you must provide 30 days
prior notice of the date upon which you will switch fuels.

If you own or operate an industrial, commercial, or institutional boiler and
would be subject to this subpart except for the exemption for units
covered by the CISWI rules, and you cease combusting solid waste, you
must be in compliance with this subpart on the effective date of the waste
to fuel switch.

If you intend to commence or recommence combustion of solid waste,
you must provide 30 days prior notice of the date upon which you will
commence or recommence combustion of solid waste.
Area Source Requirements – Oil and Biomass Units Only
Industrial, Commercial, and Institutional Boilers
40 CFR Part 63, Subpart JJJJJJ
Do the Emission Limits Requirements Apply?
≥ 10 MM
Btu/hr
< 10 MM
Btu/hr
Existing
Oil
Units
New
Oil
Units
Existing
Biomass
Units
New
Biomass
Units
No
Yes
No
Yes
No
No
No
No
Do I do a One-Time Energy Assessment?
≥ 10 MM
Btu/hr
< 10 MM
Btu/hr
Existing
Oil
Units
New
Oil
Units
Existing
Biomass
Units
New
Biomass
Units
Yes
No
Yes
No
No
No
No
No
Do I do a Biennual (every other year) Tune-Up?
≥ 10 MM
Btu/hr
< 10 MM
Btu/hr
Existing
Oil
Units
New
Oil
Units
Existing
Biomass
Units
New
Biomass
Units
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Emission Limits for Area Source Boilers
Oil and Biomass Only
Subcategory
Emission Limits
PM (lb/MMBtu)
10 – 30 MMBtu/hr
>30 MMBtu/hr
New
Biomass
0.07
0.03
New Oil
0.03
0.03
Existing
Biomass
-
-
Existing Oil
-
-
Energy Assessment
[40 CFR 63, Subpart JJJJJJ - Table 2]



One-time energy assessment performed by a qualified energy assessor.
An energy assessment completed on or after January 1, 2008, that
meets or is amended to meet the energy assessment requirements
satisfies the energy assessment requirements.
The energy assessment must include:


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
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A visual inspection of the boiler system,
An evaluation of operating characteristics of the facility, specifications of
energy using systems, operating and maintenance procedures, and unusual
operating constraints,
Inventory of major systems consuming energy from affected boiler(s),
A review of available architectural and engineering plans, facility operation
and maintenance procedures and logs, and fuel usage,
A list of major energy conservation measures,
A list of the energy savings potential of the energy conservation measures
identified,
A comprehensive report detailing the ways to improve efficiency, the cost of
specific improvements, benefits, and the time frame for recouping those
investments.
Tune-up Requirement [63.11223(b)]

As applicable, inspect the burner, and clean or replace any
components of the burner as necessary (you may delay the burner
inspection until the next scheduled unit shutdown, but you must inspect
each burner at least once every 36 months).

Inspect the flame pattern, as applicable, and adjust the burner as
necessary to optimize the flame pattern. The adjustment should be
consistent with the manufacturer’s specifications, if available.

Inspect the system controlling the air-to-fuel ratio, as applicable, and
ensure that it is correctly calibrated and functioning properly.

Optimize total emissions of carbon monoxide. This optimization
should be consistent with the manufacturer’s specifications, if available.
Tune-up Requirement [63.11223(b)]
(continued)

Measure the concentrations in the effluent stream of carbon
monoxide in parts per million, by volume, and oxygen in volume
percent, before and after the adjustments are made (measurements
may be either on a dry or wet basis, as long as it is the same basis
before and after the adjustments are made).

Maintain onsite and submit, if requested, biennial report containing the
following information:




The concentration of CO in the effluent stream in ppm, by volume, and
oxygen in volume percent, measured before and after the tune-up of the
boiler.
A description of any corrective actions taken as a part of the tune-up of the
boiler.
The type and amount of fuel used over the 12 months prior to the biennial
tune-up of the boiler.
If the unit is not operating on the required date for a tune-up, the tune-up
must be conducted within one week of startup.
Notifications and Reporting
Timeline
Existing Biomass and Oil-Fired Boilers
<10 MMBtu/hr
Initial Notification of Applicability Report
≥10 MMBtu/hr
By September
Initial Compliance Date
17, 2011
First biennial tune-up by March 21, 2012
One Time Energy Assessment
NA
By March 21, 2014
Notification of Intent to Conduct a
Performance Test
NA
NA
Initial Compliance Testing
NA
NA
By July 19, 2012
By July 19, 2012 for initial tune-up;
By July 19, 2014 for one-time energy
assessment
Initial Notification of Compliance Status
Report
Continuing Compliance –Biennial Tuneup
Continuing Compliance –Triennial Testing
Biennial Compliance Certification Report
– Biennial Tune-up
Annual Compliance Certification Report
Subsequent tune-ups should be completed no later than 25
months after the previous tune-up
NA
NA
Prepare first report by March 1, 2015 with subsequent reports
prepared biennially by March 1st
NA
NA
Notifications and Reporting
Timeline
New Biomass and Oil-Fired Boilers Installed
between 6/4/10 and 5/20/11
<10 MMBtu/hr
Initial Notification of Applicability Report
≥10 MMBtu/hr
By September 17, 2011
Initial Compliance Date
First biennial tune-up by May 20, 2011
One Time Energy Assessment
NA
NA
Notification of Intent to Conduct a
Performance Test
NA
At least 60 days before performance stack
test is scheduled to begin
Initial Compliance Testing
NA
By May 20, 2011
By September 17,
2011
Within 60 days of completing the
performance test
Initial Notification of Compliance Status
Report
Continuing Compliance –Biennial Tune-up
Continuing Compliance –Triennial Testing
Biennial Compliance Certification Report –
Biennial Tune-up
Annual Compliance Certification Report
Subsequent tune-ups should be completed no later than 25
months after the previous tune-up
NA
No more than 37 months after the previous
test
Prepare first report by March 1, 2012 with subsequent reports
prepared biennially by March 1st
NA
Prepare first report by March 1, 2012 with
subsequent reports prepared annually by
March 1st
Notifications and Reporting
Timeline
New Biomass and Oil-Fired Boilers Installed
after 5/20/11
<10 MMBtu/hr
Initial Notification of Applicability Report
≥10 MMBtu/hr
Within 120 days of startup of the boiler
Initial Compliance Date
First biennial tune-up upon startup
One Time Energy Assessment
NA
NA
Notification of Intent to Conduct a
Performance Test
NA
At least 60 days before performance stack
test is scheduled to begin
Initial Compliance Testing
NA
Within 180 calendar days of startup
Within 120 days of
startup of the boiler
Within 60 days of completing the
performance test
Initial Notification of Compliance Status
Report
Continuing Compliance –Biennial Tune-up
Continuing Compliance –Triennial Testing
Biennial Compliance Certification Report –
Biennial Tune-up
Annual Compliance Certification Report
Subsequent tune-ups should be completed no later than 25
months after the previous tune-up
NA
No more than 37 months after the previous
test
Prepare first report by March 1st of the year immediately following
startup of the boiler with subsequent reports prepared biennially
by March 1st
NA
Prepare first report by March 1st of the year
immediately following startup of the boiler
with subsequent reports prepared annually
by March 1st
Notification and Reporting Guidance


Sample Initial Notifications, Notifications of Compliance Status, and
Tune-up Guidance and Example Recordkeeping Forms for Area
Sources can be found under “Implementation Tools” at:
http://www.epa.gov/ttn/atw/boiler/boilerpg.html
Send copies of paperwork to
EPA Region 1 US Environmental Protection Agency
5 Post Office Square, Suite 100, Mail code: OES04-2,
Boston MA 02109-3912
Attention: Air Clerk
and in the case of NH sources
New Hampshire Department of Environmental Services
Air Resources Division
29 Hazen Drive
P.O. Box 95
Concord, NH 03302-0095
Attention: Section Supervisor, Compliance Bureau
Contacts
Regulation Contact
Boiler MACT
Office
Brian Shrager USEPA
Headquarters OAQPS
Telephone E-mail
Number
(919) 541-7689
Shrager.brian@epa.gov
Susan
Lancey
USEPA –
Region 1
(617) 918-1656
Lancey.susan@epa.gov
Jim Eddinger
USEPA
Headquarters OAQPS
(919) 541-5426
Eddinger.jim@epa.gov
Susan
Lancey
USEPA –
Region 1
(617) 918-1656
Lancey.susan@epa.gov
CISWI
Toni Jones
USEPA
Headquarters NRCG
(919) 541-0316
Jones.toni@epa.gov
Solid Waste
Definition
George
Faison
USEPA
(703) 305-7652
Headquarters –
RCRA
Faison.george@epa.gov
Jui-Yu Hsieh
USEPA Region 1
Hsieh.juiyu@epa.gov
Boiler Area
Source Rule
(617) 918-1646
Permitting Guidance

NH Permit Applicability
Device
Design gross heat input
(BTU/hr)
External Combustion ≥10,000,000
Device (Boiler)

Fuel
Gaseous fuel, LPG,
distillate fuel (#2 fuel
oil) or diesel fuel, any
combination
≥4,000,000
#4 fuel oil
≥2,000,000
Solid fuel, residual fuel
(#6 fuel oil), used oil,
any combination
NH Permit Approaches

Individual Permits (Temporary, State, Title V)
Emergency Generator
Regulations
Overview of recent EPA actions affecting
emergency generators

EPA issued three rules that regulate
emissions from reciprocating internal
combustion engines (RICE):

NSPS for Stationary Compression Ignition (CI) Internal
Combustion Engines (40 CFR 60, Subpart IIII) (“Quad I”)

NSPS for Stationary Spark Ignition (SI) Internal Combustion
Engines (40 CFR 60, Subpart JJJJ) (“Quad J”)

NESHAP for Stationary Reciprocating Internal Combustion
Engines (RICE) (40 CFR 63, Subpart ZZZZ) (“Quad Z”)
How do these three rules compare?
(Information is for comparison purposes only)
Regulation
Fuel Type
Manufacture
Date of Engine1
Pollutants
Regulated
Quad I
Diesel
Beginning in model
year 2007 and later
NOx, PM, CO,
NMHC
Quad J
Gasoline
Beginning in model
year 2007 and later
NOx, PM, CO,
NMHC
Quad Z
Both fuels
All engines
HAPs
1
Manufacture date varies with size of engine. See rule for more accurate
information on the dates.
NSPS for Stationary CI Internal
Combustion Engines (“Quad I”)



Affects new, modified, and reconstructed
stationary CI engines [diesel fired engines]
Initially promulgated on July 11, 2006
Amendments signed June 8, 2011
Who is Subject to Quad I?

Manufacturers of 2007 model year or later
stationary CI engines <30 liters/cylinder
displacement


Model years differ for fire pump engines (2008-2011
depending on size)
Owners/operators of engines



Constructed (ordered) after 7/11/2005 and
manufactured after 4/1/2006
Constructed after 7/1/2006 for fire pump engines
Modified/reconstructed after 7/11/2005
Quad I - Emission Standards





Phased in over several years and have Tiers
with increasing levels of stringency
Output-based, units of g/kW-hr (g/HP-hr)
Pollutants: NOx, PM, CO, NMHC
SOx reduced through use of low sulfur fuel
Modeled after EPA’s standards for non-road and
marine engines
Quad I - Compliance

Manufacturers must certify 2007 model year and
later engines with a displacement <30
liters/cylinder


Certification = EPA Certificate of Conformity
Owner/operator of emergency generators
complies by:




Purchasing certified engine
Install, configure, operate and maintain engine per
manufacturer’s instructions or manufacturer-approved
procedures
Install a non-resettable hour meter prior to startup
Owner/operator operates unit with ultra low sulfur
fuel after October 1, 2010 (<15 ppm sulfur content)
Quad I - Notification and Recordkeeping




Emergency Generators not required to submit
an initial notification.
Maintain documentation from the manufacturer
certifying that the engine complies with the
applicable emission standards of Quad I
Record the time of operation of the engine and
the reason the engine was in operation during
that time.
Keep records of the sulfur content of the fuel
burned in the device.
NSPS for Stationary SI Internal
Combustion Engines (“Quad J”)



Affects new, modified, and reconstructed
stationary SI engines [gas fired engines]
Initially promulgated on January 18, 2008
Amendments signed June 8, 2011
Who is Subject to Quad J?

Manufacturers of stationary SI engines:



≤25 HP and manufactured on/after 7/1/2008
>25 HP, gasoline or rich burn LPG, manufactured
on/after 7/1/2008 (on/after 1/1/2009 for emergency
engines)
>25 HP, not gasoline or not rich burn LPG, voluntary
certified engines manufacture on/after




7/1/2007
1/1/2008
7/1/2008
1/1/2009
>500 HP (except lean burn 500≤HP<1,350)
lean burn 500≤HP<1,350
<500 HP
emergency engines
Who is Subject to Quad J? (continued)

Owners/operators of stationary SI engines:

Constructed after 6/12/2006 and





≥500 HP manufactured on/after 7/1/2007 (except lean burn
500≤HP<1,350)
Lean burn 500≤HP<1,350 manufactured on/after 1/1/2008
<500 HP manufactured on/after 7/1/2008
Emergency >25 HP manufactured on/after 1/1/2009
Modified/reconstructed after 6/12/2006
Quad J - Emission Standards






Phased in over several years and have Tiers
with increasing levels of stringency
Output-based, units of g/kW-hr (g/HP-hr)
ppmvd@15% O2, standards for some engines
Pollutants: NOx, CO, VOC
Sulfur limit on gasoline
Some standards modeled after EPA’s standards
for non-road SI engines
Quad J - Compliance

Manufacturers must certify engines ≤25 HP,
gasoline engines, and rich burn LPG engines
Manufacturers can elect to certify other engines

Owner/operator complies by either:



For certified engines: Install, configure, operate and
maintain engine per manufacturer’s instructions or
manufacturer-approved procedures
For uncertified engines: Conduct performance test
(requirements vary depending on engine size)
Quad J - Notification and Recordkeeping


Owners/operators of uncertified SI RICE ≥500
HP must submit an initial notification.
Owners/operators of all SI RICE must keep
records of:




All notifications
All maintenance conducted on the engine
For certified engines: Documentation from the
manufacturer certifying that the engine complies with
the applicable emission standards of Quad J
For uncertified engines or certified engines operating
in a non-certified manner: Documentation that the
engine meets the emission standards.
NESHAP for Stationary Reciprocating
Internal Combustion Engines (RICE)
(“Quad Z”)


New or reconstructed stationary RICE located at
an area source must meet the requirements of
Quad I or Quad J. No further requirements
apply under Quad Z.
Existing (1/1/2009) institutional emergency
stationary RICE located at an area source of
HAP emissions do not have to meet the
requirements of Quad Z or the General
Provisions of 40 CFR 63.
Permitting Guidance

NH Permit Applicability
Device
Design gross heat input
(BTU/hr)
One or more Internal
Combustion Devices
(Engines)

Fuel
Individual
Combined
150,000
1,500,000
Liquid fuel oil
1,500,000
10,000,000
NG or LPG
NH Permit Approaches

General State Permit (up for renewal April 2013)





On-line permitting (http://des.nh.gov)
Easy, fast, less paperwork
Initial permit is free
Emission-based fees still apply
Individual Permits (Temporary, State, Title V)
Questions?
Contact:
Cathy Beahm
N.H. Department of Environmental Services
Air Resources Division
catherine.beahm@des.nh.gov
(603) 271-2822