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Division of Air Quality Update on EPA Boiler MACT Rules
Steve Schliesser
Environmental Engineer
March 2012
BRUNSWICK
NEW HANOVER
COLUMBUS
PENDERBLADEN
RO BESON
SCOTLAND
DUPLINANSON
HO KERICHMONDSAMPSONUNION
CLAY JONESPAMLICO
CHEROKEE MACONTRANSYLVANIA
CLEVELANDLENOIRLENOIRMECKLENBU RG
CRAVENGASTON
JACKSON MOOREPOLK STANLY
GRAHAM HARNETTHENDERSONRUTHERFORD
GREENELEELINCOLN
PITT
SWAIN
HAYWOODHYDEJOHNSTON
WAYNE
BEAUFORTBUNCOMBE
CATAWBACHATHAM
MCDOWELLRANDOLPH
ROWAN
BURKEDARE
MARTIN WASHINGTON
WILSON
DAVIDSON TYRRELLWAKE
DAVIE EDGECOMBEMADISON YANCEY
ALEXA NDERCALDWELL
GUILFORD BERTIENASH
AVERY FORSYTHFRANKLIN
ORANGE
WATAUGAWILKES
YADKIN
HALIFAXHERTFORD
SURRY WARRENASHE
CASWELLGATESPERSONROCKINGHAMSTOKES
VANCE
ALLEGHANYNORTHAMPTON
DURHAM
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
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
Recently (Re)Proposed Boiler MACT
HAP/ Fuel and/or Design Units Sept 2004 Final
June 2010 Proposal
May 2011 Final
Dec 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 0.0390.029
- Biomass Dry Stoker 0.32- Coal Pulverized 0.044- Heavy Liquid Oil
No limit 0.004 0.00750.062
- Light Liquid Oil 0.0034
Synopsis of Boiler MACT Emission Standards for Existing Units
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.
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 NoneBoiler tune-upevery two years
Existing
Coal
≥ 10 None
4.8E-6 400 @7% O2
One time energy assessment
Biomass
None Boiler
tune-up onlyOil
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