part 63 boiler rule for area sources awma conference september 11-14, 2012 biloxi, ms lee page air...
TRANSCRIPT
Part 63 Boiler Rule for Area Sources
AWMA ConferenceSeptember 11-14, 2012
Biloxi, MS
Lee PageAir Toxics Assessment and Implementation SectionU.S. Environmental Protection AgencyAtlanta, Georgia
Topics to Cover
Rule Development Promulgated Requirements Amended Requirements Outreach/Delegations Guidance Fuel Switching Example Questions
March 21, 2011 - EPA promulgates final boiler rules for major and area sources Subpart 5D for major sources
Subpart 6J for area sources
May 18, 2011 – EPA delays effective date of major source due to reconsideration Effective date of the area source rule not delayed
December 23, 2011 - EPA issued proposed rule amendments for major source boilers and specific aspectsof area sources (will reset compliancedate for major sources).
January 9, 2012 - U.S. District Court for the DC Circuit vacated EPA's May 18, 2011, delay of effective datefor major sources
Rule amendments expected to be finalized by ______??_______
3
Boiler Rule Development
EPA issues No Action Assurance Letters (NAAs)
EPA will exercise its enforcement discretion to not pursue enforcement
action for violations of certain notification deadlines in the final Major Source Boiler
rule (NAA dated 2/7/12) or final Area Source Boiler Rule (NAA dated 3/13/12
then extended until 12/31/12)
Primary Changes in Amendment
Revised standards based on generally available control technology
Greater flexibility to certain facilities in meeting requirements
Clarify certain requirements
Correct printing errors
6J Boiler Requirements – As Promulgated
Heat
Capacity
Btu/Hr
Existing
Coal
Units
New
Coal
Units
Existing
Oil
Units
New
Oil
Units
Existing Biomass
Units
New
Biomass Units
> 10 MM Yes Yes No Yes No Yes
< 10 MM No No No No No No
Emission Limits (Triennial Performance Tests)
6J Boiler Requirements – As Amended
Heat
Capacity
Btu/Hr
Existing
Coal
Units
New
Coal
Units
Existing
Oil
Units
New
Oil
Units
Existing Biomass
Units
New Biomass
Units
> 30 MM Yes Yes No Yes No Yes
> 10 < 30 Yes Yes No Yes No Yes
< 10 MM No No No No No No
Emission Limits (Triennial Performance Test)
6J Boiler Requirements – As Promulgated
Heat
Capacity
Btu/Hr
Existing
Coal
Units
New
Coal
Units
Existing
Oil
Units
New
Oil
Units
Existing Biomass
Units
New Biomass
Units
> 10 MM Yes No Yes No Yes No
< 10 MM No No No No No No
One-Time Energy Assessment
6J Boiler Requirements – As Amended
Heat
Capacity
Btu/Hr
Existing
Coal
Units
New
Coal
Units
Existing
Oil
Units
New
Oil
Units
Existing Biomass
Units
New Biomass
Units
> 10 MM Yes No Yes No Yes No
< 10 MM No No No No No No
One-Time Energy Assessment
6J Boiler Requirements – As Promulgated
Heat
Capacity
Btu/Hr
Existing
Coal
Units
New
Coal
Units
Existing
Oil
Units
New
Oil
Units
Existing Biomass
Units
New Biomass
Units
> 10 MM No No Yes Yes Yes Yes
< 10 MMYes Yes Yes Yes Yes Yes
Biennial Tune-Ups
6J Boiler Requirements – As Amended
Heat
Capacity
Btu/Hr
Existing
Coal
Units
New
Coal
Units
Existing
Oil
Units
New
Oil
Units
Existing Biomass
Units
New Biomass
Units
Existing
Seasonal
(Oil or Biomass)
New
Seasonal
( Oil or Biomass)
> 10 MM No No Yes Yes Yes * Yes *
< 10 MM Yes Yes Yes Yes Yes * Yes *
> 5 MM Yes Yes
< 5 MM Yes * Yes *
Biennial Tune-Ups ( * Every 5 Years)
EPA Outreach
R4 Initial Notification Database
Emails to various potentially affected sources
Staff led discussions at focus groups
National seminars & webinars
Rule Delegation 8 States, 10 local agencies EPA Regional Office Implementation www.epa.gov/region4/air/airtoxic
Click on “Air Toxics Delegation”
Area Source Delegations
Are Taking Delegation
Are Not Taking Delegation
Alabama 6D, 6E, 6F, 6G, 6Q 7A, 7C, 7D
5W, 6B, 6C, 6H, 6J, 6N, 6O, 6P, 6R, 6S, 6V, 6W, 6X, 7B, 7E
Florida 5Y, 5Z, 6D, 6E, 6F, 6G, 6L, 6M, 6N, 6O, 6P, 6Q, 6R, 6S, 6T
5W, 6B, 6C, 6H, 6J, 6W, 6X, 6V, 6Y, 6Z, 7A, 7B, 7C, 7D, 7E
Georgia All
Kentucky All
Mississippi All
North Carolina All
South Carolina All
Tennessee (All in Chattanooga)
Boiler Rule Guidance
Web site: www.epa.gov/boilercompliance Proposed and final rules Example Initial Notification forms Example Notification of Compliance Status forms Rule brochures Guidance on tune-ups Common questions Rule overview presentations Small Entity Compliance Guidance
EPA Region 4 Activities Quick reference tables Timeline for required submittals Issue resolutions (dual fired - fuel switching)
Dual Fired vs Fuel Switching
Dual fired boilers (gas/oil) account for a large portion of the area source boiler universe
6J exempts gas units that only burn oil during: Periods of gas curtailment Gas supply emergencies Periodic testing of liquid fuel
If oil is burned outside of exempted limits, these boilers will be considered new boilers in the oil subcategory (i.e., fuel switching)
Boilers could be subject to stringent emission limits Must comply immediately
Fuel Switching
For flexibility, dual fired boilers may want to submit initial notification as an existing boiler in the oil subcategory
Existing oil fired boilers are not subject to emission limits/performance tests
Subject to a one-time energy assessment if boiler heat capacity is >10 MM Btu/hr
Will be subject to tune-up requirements
Example:
Dual Fired (Gas/Oil) Boilers
Hypothetical Area Source Operates the Following Boilers:(All 3 boilers burn primarily natural gas)
#1 Existing Unit > 10 mm Btu/hr Nat. Gas/Oil
#2 Existing Unit < 10 mm Btu/hr Nat. Gas/Oil
#3 New Unit < 10 mm Btu/hr Nat. Gas/Oil
Options for Initial Notifications:
Option A: Not subject due to special oil exemptions (gas curtailment, supply emergencies, testing)
Dual Fired Boilers
Option B: For flexibility, classify all 3 as oil units
* Continue to burn natural gas in boilers
* No applicable emission limits (only if new >10 mm)
* Biennial tune-ups for all 3 boilers
* One-time energy assessment for boiler #1
* Comply as required in 63.11196
Dual Fired Boilers
Option C: Only Classify Boiler #1 as existing Oil Unit; Boilers 2 & 3 remain as gas fired units
* Boilers 2 & 3 are exempted from regulation
* No applicable emission limits for Boiler #1
* Biennial tune-ups for Boiler #1
* One-time energy assessment for boiler #1
* Comply as required in 63.11196
Fuel Switching Example
Costs of fuels change - oil now cheaper than gas
Hypothetical source now thinks about switching fuel to reduce overhead
63.11194(d): Boiler is a new affected source if you switch fuels from gas to oil
Results From Fuel Switching
Option A: All 3 Boilers are Gas Fired (Exempted)
* All 3 boilers now considered new oil fired units
* Boiler #1 (>10MM Btu) has to meet emission limits
* Initial and triennial performance tests for boiler #1
* Biennial tune-ups for all 3 boilers
* No one-time energy assessment required
Results From Fuel Switching
Option B: Boilers 1 & 2 are classified as existing oil fired Boiler 3 classified as new oil fired
* No changes (continue with biennial tune-ups) * One time energy assessment already completed
Option C: Boiler #1 classified as existing oil fired; Boilers 2 & 3 exempted due to gas
* Boilers 2 & 3 are now classified as new oil units* Biennial tune-ups for boilers 2 & 3
* No changes for boiler 1 (continue with tune-ups)
Message
Area sources with dual-fired boilers should evaluate the impact of switching fuel now in order to potentially avoid issues related to implementing different rule requirements in the future.
Questions?
www.epa.gov/ttn/atw
www.epa.gov/boilercompliance
www.epa.gov/region4/air/airtoxic
Lee PageU.S. EPA; Atlanta, GA
404-562-9131
Lee PageU.S. EPA; Atlanta, GA
404-562-9131