Division of Air Quality Update on EPA Boiler MACT Rules Steve Schliesser Environmental Engineer March 2012 NORTHAMPTON PERSON DAVIE IR ED EL L ALEXANDER MARTIN WAKE RANDOLPH CATAWBA WASHINGTON PITT BEAUFORT HYDE POLK CLEVELAND GASTON MECKLENBURG LEE STANLY M ON TG O M ER Y HARNETT WAYNE MOORE CRAVEN LENOIR LENOIR MACON CLAY RICHMOND UNION GREENE ANSON HOKE CU MB ER LA ND RUTHERFORD JACKSON TRANSYLVANIA CA BA RR US HENDERSON GRAHAM DARE WILSON CHATHAM JOHNSTON CHEROKEE TYRRELL ROWAN LINCOLN TA NK EDGECOMBE HAYWOOD SWAIN PE RQ PA UIM SQ AN UO S DURHAM DAVIDSON BURKE MCDOWELL BUNCOMBE BERTIE NASH CE AN M LA A K UC L EL CH IT M FRANKLIN GUILFORD CALDWELL HERTFORD HALIFAX ORANGE FORSYTH YANCEY GATES WARREN VANCE AN OW CH GR AN VIL LE CASWELL IT RR CU ROCKINGHAM YADKIN AVERY MADISON STOKES SURRY WILKES EN MD CA ALLEGHANY ASHE WATAUGA PAMLICO JONES SAMPSON DUPLIN ON SL OW SCOTLAND ROBESON BLADEN PENDER COLUMBUS NEW HANOVER BRUNSWICK T TERE CAR Topics to be Covered Background on EPA Boiler MACT Rules Highlights & Proposed Changes to Boiler MACT Highlights & Proposed Changes to Boiler GACT - EPA Boiler MACT and GACT Rulemaking process continues until at least May 2012 - Litigation expected after May 2012 final rule Background on EPA Boiler MACT Rules Clean Air Act Requires National Emission Standards for Hazardous Air Pollutants (HAP) Develop Maximum Achievable Control Standards (MACTs) for major facilities emitting one HAP > 10 ton/yr or multiple HAPS > 25 ton/yr Develop Generally Available Control Standards (GACTs) for non-major facilities emitting one HAP < 10 ton/yr or multiple HAPS < 25 ton/yr Boiler MACT Impact in North Carolina Affects 98 facilities and ~1,000 boilers All but one facility has 112(j) permit, shielding MACT compliance up to 8 yrs (2018/2019) State of NC has 2nd highest projected impact from Boiler MACT in U.S. with cost > $1 billion Boiler MACT Rulemaking Process Timetable EPA Proposed Rule in Jan 2003 EPA Promulgated Final Rule in Sept 2004 U.S. Court Vacated and Remanded Final Rule in June 2007 EPA Proposed Rule in June 2010 U.S. Court Denied EPA Time-Extension Request in Jan 2010 EPA Promulgated Final Rule in March 2011 EPA Stayed Effective Date of Final Rule in May 2011 EPA Proposed Amendments to Final Rule in Dec 2011 U.S. Court Vacated EPA Stay in Jan 2012 EPA Expects to Promulgate Final Rule by May 2012 Recently (Re)Proposed Boiler MACT U.S. Court vacated EPA stay in January 2012 Slight national impact, but one NC facility lost 112(j) permit since rule’s restored effective date occurred before permit was issued DAQ submitted comments on re-proposal in Feb 2012 EPA expects to finalize Boiler MACT in May 2012 Recently (Re)Proposed Boiler MACT MACT procedure sets the bar of top 12% -- for each boiler type/fuel sub-category and each HAP -- for remaining to meet Re-proposal changes offer more flexibility, less cost impact, with offsetting increases/decreases in HAP emissions Highlights of proposed changes Added new sub-categories for total of 19 New and alternative HAP emissions limits New work practice standards and provisions Modified clean gas specification for natural gas and equivalent gaseous fuels Synopsis of Boiler MACT Emission Standards for Existing Units HAP/ Fuel and/or Design Mercury - Biomass - Coal - Oil Hydrogen chloride - Biomass - Coal - Oil Particulate - Biomass Wet Stoker - Biomass Dry Stoker - Coal Pulverized - Heavy Liquid Oil - Light Liquid Oil Units lb / Trillion Btu lb / Million Btu lb / Million Btu Sept 2004 Final June 2010 May 2011 Proposal Final No limit 9 No limit 0.9 3 4 No limit 0.006 0.02 0.0009 Dec 2011 Proposal 4.6 3.1 3.5 26 0.035 0.022 0.0034 0.0012 0.07 0.02 0.039 No limit 0.004 0.0075 0.029 0.32 0.044 0.062 0.0034 Recently (Re)Proposed Boiler GACT GACT procedure uses generally available (not maximum achievable) control technologies or management practices Re-proposed rule eases requirements without changing emissions, costs, or benefits Affects 300 permitted facilities and 600 boilers > 90% conduct periodic tune-ups and some perform one-time energy assessment Remaining burn coal and must meet emission limits for mercury and carbon monoxide. For more details see http://www.epa.gov/airquality/combustion/docs/20111202asboilersfs.pdf Boiler GACT Emission and Work Practice Standards Source Category Fuel Category All Heat Input, MMBtu/hr PM, lb/MMBtu/hr < 10 Biomass 4.8E-6 ≥ 10 None Oil Coal New Biomass Oil CO, ppm ≥ 10 < 30 0.42 ≥ 30 0.03 ≥ 10 < 30 0.07 ≥ 30 0.03 ≥ 10 < 30 0.03 ≥ 30 0.03 400 @7% O2 None Boiler tune-up only 4.8E-6 400 @3% O2 None Work Practice Standard Boiler tune-up every two years None Coal Existing Mercury, lb/MMBtu/hr Boiler tuneup One time energy assessment No energy assessment Questions? Steve Schliesser Environmental Engineer 919-707-8701 Steve.Schliesser@ncdenr.gov http://www.ncair.org/