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
3
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.
4
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
5
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
• Residential boilers
• Waste heat boilers
• Electric boilers
– (heat recovery steam generators)
• Temporary 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 three
requirements 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 Information
EPA Major Sources
Division for Air Quality
– Brian Shrager
– 919-541-5689
– shrager.brian@epa.gov
– 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 Area Sources
– Jim Eddinger
919-541-5426
eddinger.jim@epa.gov
Websites:
http://www.epa.gov/ttn/atw/boiler/boilerpg.html
http://www.combustionportal.org/
14
Boiler MACT
Tune-up Requirement
Subpart JJJJJJ – NESHAP for area sources
Subpart DDDD- NESHAP for major sources
Chad Von Gruenigen
Compliance 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?
Existing
Biomass
Units
>10 MM
Yes
*
Yes
*
Yes
Yes
<10 MM
Yes
*
Yes
*
Yes
Yes
*
New (June Existing
4th 2010)
Seasonal
Biomass
or limited use units
Units
New (June 4th 2010)
Seasonal
or limited use units
Heat
Capacity
( Btu/Hr)
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 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
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.
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)
Step 3
• Inspect the air-tofuel 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
Where do I get a meter?
• For around $1,800
dollars you can get
everything you need.
Step 4
• Optimize total
emissions of
carbon monoxide.
This can even be done on a hot water heater as
shown in the picture
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
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
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 tuneup 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 tuneup. 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.
http://www.epa.gov/boilercompliance/
• Type in Boiler MACT in Google
and click on industrial/
commercial/ industrial boilers
and process heaters
http://www.epa.gov/airtoxics/boiler/boilerpg.html
Useful Materials
• Implementation tools
– Initial Notification of Applicability for AREA Sources
– Tune-up Guidance and Example Recordkeeping FromAREA 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: envhelp@ky.gov
– Call: (800) 926-8111
Area Source Boiler
Energy Assessment
40 CFR 63 Subpart 6J
Emily Ohde
Compliance Assistance Specialist
Who must conduct an
Energy Assessment?
Existing*
≥ 10
MMBtu/hr
Biomass
Coal
Oil
YES
YES
YES
* Commenced construction or reconstruction
prior to June 4, 2010
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
Demonstrated
capabilities to
evaluate
opportunities for
steam generation and
major energy use
systems including:
– 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
Qualified Energy Assessor
– Assessment activities, data
analyses, and report
preparation
Capabilities &
Knowledge including: – Familiarity with O&M
– System improvement
– Cogeneration systems
– Industry specific end-use
QEA may be a company employee or outside specialist
Boiler System
• Boiler and associated components
– Feedwater systems
– Combustion air systems
Directly connected
– Fuel systems (including
to & serving the
burners)
energy use system
– Blowdown systems
– Combustion control systems
– Steam systems
– Condensate return systems
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)
Located on the site
of the affected
boiler
• Only systems using energy clearly produced by
affected boiler(s)
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 Requirements
Annual
Heat Input
(Trillion
Btu/yr)
Annual Input in
MMBtu/hr @
8760 hours
Length of
assessment not
to exceedℓ…
< 0.3
0.3 – 1.0
> 1.0
< 34.2
34.2-114.2
114.2
8 hours
24 hours
24 hours for 1st
TBtu +
8 hours for each
additional TBtu*
On-site energy use
systems that account for
the following % of the
energy product from
affected boiler
At least 50%
At least 33%
At least 20%
*Not to exceed 160 hours
ℓOn-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
Exhaust
Egrid
Epgu
Ep
Power
Generation
Unit
Fm
Eec
Electric
Chiller
Heat
Recovery
System
Fpgu
Fb
E
Absorption
Chiller
QF
Boiler
Qec
Qc
Building
Qac
QFC
Qb
Qrh
Heating
Coil
Qh
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
An upgraded boiler maintenance
program including optimizing
air-to-fuel ratio, burner
maintenance, and tube cleaning
6. Energy Savings
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
Installation or conversion to
combined heat and power
systems (co-generation)
6. Energy Savings
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
operations
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.
Inquiry…
…a qualified energy assessor to
conduct the one-time energy
• Private Company assessment in accordance with the
boiler MACT for a biomass boiler.
• Universities
• KPPC
Energy Assessment Completed
Now What?
• Submit Notification of Compliance Status
Due By: July 19, 2014
• If the facility must demonstrate
compliance with emission limits:
– Different NOCS (has checkbox for EA NOCS)
– EL NOCS submitted within 60 days of completion
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
800-926-8111
www.dca.ky.gov
envhelp@ky.gov