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