Post on 17-Dec-2015
MCIC Workshop 2012 Complying with NC Air Quality Regulations
Boiler MACT/GACT and 112j
• Steve Schliesser• Division of Air Quality• Environmental Engineer• March 2012
BRUNSWICK
NEW HANOVER
COLUMBUS
PENDERBLADEN
RO BESON
CARTERETONSLOWSCOTLAND
DUPLIN
CU
MB
ERLA
ND
ANSONHO KERICHMOND
SAMPSONUNION
CLAY JONESPAMLICO
CHEROKEE MACONTRANSYLVANIA
CLEVELANDLENOIRLENOIRMECKLENBU RG
MONTGOM
ERY
CA
BA
RR
US
CRAVENGASTON
JACKSON MOOREPOLK STANLY
GRAHAM HARNETTHENDERSONRUTHERFORD
GREENELEELINCOLN
PITT
SWAIN
HAYWOODHYDEJOHNSTON
WAYNE
BEAUFORTBUNCOMBE
CATAWBACHATHAM
MCDOWELLRANDOLPH
ROWAN
BURKEDAREIR
EDEL
L
MARTIN WASHINGTON
WILSON
DAVIDSON TYRRELLWAKE
ALAMANCE
DAVIE EDGECOMBEMADISON YANCEY
ALEXA NDERCALDWELL
GUILFORD
MITC
HELL
BERTIENASH
AVERY
CH
OW
ANFORSYTH
FRANKLIN
PERQUIMANS
GR
AN
VIL
LE
ORANGE
WATAUGAWILKES
YADKIN
HALIFAX
CA
MD
EN
HERTFORD
SURRY WARREN
CURRITUCK
ASHECASWELL
GATESPERSONROCKINGHAMSTOKES
VANCE
ALLEGHANYNORTHAMPTON
DURHAM
PASQUOTANK
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Topics to be Covered
• Background - EPA Boiler MACT and GACT• Effects of Vacatur on EPA Stay of Boiler Rules• Current vs. Proposed 5D Boiler MACT• Current vs. Proposed 6J Boiler GACT
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Background on EPA Boiler MACT Rules
• Clean Air Act Requires National Emission Standards for Hazardous Air Pollutants (HAP)– Maximum Achievable Control Standards (MACTs)
for major facilities emitting one HAP > 10 ton/yr or multiple HAPS > 25 ton/yr
– Generally Available Control Standards (GACTs) for non-major facilities
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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)• NC has 2nd highest projected cost impact from
Boiler MACT -- > $1 billion
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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 2011• 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
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Recently (Re)Proposed Boiler MACT (BM)
• EPA stayed March Boiler MACT final rule in May 2011• U.S. Court vacated EPA stay in Jan 2012 - EPA had authority, just did not follow procedure • Slight national impact, but one NC facility with huge
impact -- 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
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• MACT procedure sets bar of top 12% -- for each boiler type/fuel sub-category and each HAP -- for others to meet
• Re-proposal 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
Recently (Re)Proposed Boiler MACT
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Proposed Changes to Final March 2011 Boiler MACT
• New subcategories for light and heavy industrial fuel oil to reflect boiler design disparity and improve achievability.
• New emissions limits for PM specific for each solid fuel (biomass, coal) to reflect actual differences.
• Alternative total selective metals emission limits in addition to using PM as surrogate, improving flexibility.
• New CO emissions limits and averaging time with new data showing high variability in short- and long-term measurements.
• Replace dioxin emission limits with work practice standards given most data were below detection.
• Removed PM CEMS requirements for biomass units given variability in PM characteristics
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MACT Floor Methodology
• Pool of top performers (average of top 12%) will set MACT floor for each sub-category
- Review MACT floor pool test reports for valid data - Finding invalid data or re-categorizing will produce another
pool and MACT floor • Account for performance variability of top 12%;
- previously variability factor ranged from of 3-10.• MACT emission limit = Floor average * Variability factor
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HAP/ Fuel - Design Units 2004 “Final” 2010
Proposal2011 “Final” 2011
Proposal
Mercury - Biomass
lb /Trillion Btu
No limit 0.94.6 3.1
- Coal 9 3 - Oil No limit 4 3.5 26 Hydrogen chloride - Biomass
lb /Million Btu
No limit0.006
0.035 0.022 - Coal 0.02 - Oil 0.0009 0.0034 0.0012 Particulate
- Biomass Wet Stoker
lb / Million Btu
0.07 0.02 0.039
0.029- Biomass Dry Stoker 0.32
- Coal Stoker 0.028- Heavy Liquid Oil
No limit 0.004 0.00750.062
- Light Liquid Oil 0.0034
Short List of Boiler MACT Emission Standards for Existing Units
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Why Mercury Limit High forExisting Liquid Fuel Oil Boilers?
• MACT floor based on 10 sources burning 2, 4, 6, recycle oil • Fuel oil floor avg = 0.37 lb/TBtu, MACT limit = 26 - Variability factor = 70, outside normal range of 3-10• Solid fuel floor avg = 0.40, MACT limit = 3.1
- Variability factor = 8, within normal range of 3-10• Previous MACT fuel oil limits = 3.5 – 4.0• Mercury in virgin fuel oil -- <1.0 lb/TBtu• Of 71 fuel oil sources for which EPA has data,
only 4 would reduce mercury emissions.
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(Re)Proposed Boiler GACT
• GACT procedure uses generally available (not maximum achievable) control technologies or management practices
• Re-proposal eases burden without changing emissions, costs, benefits
• Affects 300 permitted facilities and 600 boilers in NC• > 90% burn gas, oil, or biomass will conduct only periodic tune-ups
and some perform one-time energy assessment• Remaining that burn coal must meet mercury and CO limits. • Delay March 2012 tune-up deadline 1-year until March 2013. - EPA no-action-assurance memo delays tune-up deadline til Oct 2012
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Boiler GACT Emission and Work Practice Standards
Source Category
Fuel Category
Heat Input, MMBtu/hr
PM,lb/MMBtu/hr
Mercury,lb/MMBtu/hr
CO,ppm
Work Practice Standard
All < 10 None Tune-upevery 2 years
Existing
Coal
≥ 10 None
4.8E-6
400 @7%
O2
One time energy
assessmentBiomass
None Boiler
tune-up Oil
New
Coal
≥ 10 < 30 0.42
4.8E-6
400 @3%
O2 No energy assessment
≥ 30 0.03
Biomass≥ 10 < 30 0.07
NoneBoiler tuneup
≥ 30 0.03
Oil≥ 10 < 30 0.03
≥ 30 0.03
For more details see http://www.epa.gov/airquality/combustion/docs/20111202asboilersfs.pdf
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Boiler MACT and GACT Future Schedule
• Rules promulgated (3rd time) in May 2012• Effective 60 days after Fed Reg publication (~July ‘12)• Expect litigation, possibly from both sides• Compliance date for 112(j) permitted facilities :◦ May be > MACT rule compliance date (~July ‘15)◦ Must be within a reasonable period of time; and◦ Cannot exceed 8 years from (last) promulgation date.
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DAQ Comment on EPA NESHAP Rules
• EPA submittals on Boiler MACT, GACT, CISWI and Non Hazardous Solid Waste Definition
• Focus on implementation, compatibility, and program management issues
• Few comments helped to effect rule changes• Sent NACAA letter stating their comments do not
reflect DAQ interests and concerns
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Questions?Steve SchliesserEnvironmental Engineer919-707-8701Steve.Schliesser@ncdenr.govhttp://www.ncair.org/
EPA boiler rules website: http://www.epa.gov/airquality/combustion/index.html
EPA Boiler MACT docket, go to www.regulations.gov then enter EPA–HQ–OAR–2002–0058
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