SLMA Meeting. Boiler MACT and Related Rules. Atlanta, GA March 2, Martin Rollins, P. E. H. M. Rollins Company, Inc. Gulfport, Mississippi

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1 SLMA Meeting Atlanta, GA March 2, 2011 Boiler MACT and Related Rules Martin Rollins, P. E. H. M. Rollins Company, Inc. Gulfport, Mississippi

2 Boiler MACT and Related Rules EPA Had Requested 15 Month Delay Court Refused 4 Related Proposed Rules Signed 2/21/2011 Major Source Boiler and Industrial Furnace MACT Rule Area Source Boiler MACT Rule Commercial, Industrial Solid Waste Incinerator (CISWI) Rule Definition of Non-Hazardous Solid Waste Rule

3 Boiler MACT and Related Rules The Three Air Rules Will Be Reconsidered If Proceeds as Expected Could Take Months to Publish New Proposal NHSW Rule Not Being Reconsidered Unless Petitioned By Industry and Granted Legal Action Must Be Filed in 60 Days Significant Political Pressure on Agency

4 Boiler MACT and Related Rules Final Rules Made Some Changes Retained Pollutant By Pollutant Approach Generally Raised Limits for Hg, HCL, PM and Dioxins Generally Lowered Limits for CO EPA Believes It Cut Total Cost in Half

5 Area Source Rule Biomass Less than 10 MMBtu/hr Work Practice Biennial Tune-ups Area Source Biomass Boilers CO Limit Was Removed Proposal Had Limits that Could Not Be Met Replaced with Work Practices Energy Assessment Startup and Shutdown Practices Wood Products Industry Can Probably Live With

6 Energy Assessment 4. Existing coal, biomass, or oil (units with heat input capacity of 10 million Btu per hour and greater) Must have a one-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this table satisfies the energy assessment requirement. The energy assessment must include: (1) A visual inspection of the boiler system. (2) An evaluation of operating characteristics of the facility, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints, (3) Inventory of major systems consuming energy from affected boiler(s), (4) A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage, (5) A list of major energy conservation measures, (6) A list of the energy savings potential of the energy conservation measures identified, (7) A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments,

7 Major Source Facilities Biomass Less than 10 MMBtu/hr Work Practice Biennial Tune-ups No Health Based Compliance Option Biomass Larger than 10 MMBtu/hr Numerical Limits CO Limits Lower than Proposal Added New Suspension Burner/Grate Category Raised Hg, HCL, and Dioxin Limits Energy Assessment

8 Biomass (AND Coal) Subcategory New and Existing Fuel Based HAP Limits HAP PM, lb/10 6 Btu HCl, lb/10 6 Btu Mercury, lb/10 12 Btu (Vacated Rule: existing/new) New Units Proposed New Units final rule Existing units Proposed Existing units Final rule (0.07/.025) (0.09/.02) (9.0/3.0)

9 Biomass Subcategory New and Existing Limits for CO and Dioxin/Furan HAP (Vacated rule: existing/new) CO, ppm at 3% O 2 (none/400) D/F, ng/dscm TEQ at 7% O 2 (none) New stokers Now 160 (560 proposed) (B ) Existing stokers Now 490 (560 proposed) (0.004) New fluidized bed 260 (40 proposed) 0.02 (0.007) Existing fluidized bed 430 (250 proposed) 0.02 (same) New Suspension burners /Dutch ovens Existing suspension burners/dutch oven 470 (1,010 proposed) 0.2 (0.03) 470 (1,010) 0.2 (0.03) New fuel cells 470 (270 ) (0.0005) Existing fuel cells 690 (270) 4 (0.02) Suspension grate 3500; 1500 (new) 0.2; 0.2 (new)

10 Suspension Boiler Suspension boiler means a unit designed to feed the fuel by means of fuel distributors. The distributors inject air at the point where the fuel is introduced into the boiler in order to spread the fuel material over the boiler width. The drying (and much of the combustion) occurs while the material is suspended in air. The combustion of the fuel material is completed on a grate or floor below. Suspension boilers almost universally are designed to have high heat release rates to dry quickly the wet fuel as it is blown into the boilers.

11 Hybrid Suspension Grate Boiler Hybrid suspension grate boiler means a boiler designed with air distributors to spread the fuel material over the entire width and depth of the boiler combustion zone. The drying and much of the combustion of the fuel takes place in suspension, and the combustion is completed on the grate or floor of the boiler.

12 Both Suspension boiler means a unit designed to feed the fuel by means of fuel distributors. The distributors inject air at the point where the fuel is introduced into the boiler in order to spread the fuel material over the boiler width. The drying (and much of the combustion) occurs while the material is suspended in air. The combustion of the fuel material is completed on a grate or floor below. Suspension boilers almost universally are designed to have high heat release rates to dry quickly the wet fuel as it is blown into the boilers. Hybrid suspension grate boiler means a boiler designed with air distributors to spread the fuel material over the entire width and depth of the boiler combustion zone. The drying and much of the combustion of the fuel takes place in suspension, and the combustion is completed on the grate or floor of the boiler.

13 Dioxin unknown cost Assume meet dioxin if meet Hg and PM (fabric filter and carbon injection) Dioxin slightly higher but still great uncertainty Single performance test if pass then OK, any non-detect = zero if don t pass then unclear what action Oxygen compliance monitoring unclear Still good candidate for work practices

14 Boiler MACT Costs Comparison Proposal to Final for Wood Products HAPs/ Surrogates by Fuel type PM/ metals HCl (acid gases) Mercury/ Dioxin Carbon Monoxide (CO) Total Biomass $584M ($622M) $0M ($740M) $0M ($224M) $98M ($100M) $682M ($1.7B) Coal $14M ($14M) $0M ($16M) $6M ($6M) $12M ($12M) $32M ($49M) Oil $19M ($19M) $3M ($21M) $6M ($7M) $12M ($14M) $40M ($61M) Gas2 NA NA NA NA Total $617M ($655M) $3M ($776M) $12M ($237M) $122M ($126M) $754M ($1.8B) Figures in () are Proposed Rule costs

15 Boiler MACT Costs for Forest Products for Final Rule HAPs/ Surrogates by Fuel type Biomass PM/metals $1.2B ($1.4B) HCl (acid gases) $40M ($1.5B) Mercury/ Dioxin $11M ($301M) Carbon Monoxide (CO) $124M ($118M) Total $1.4B ($3.2B) Coal $415M ($576M) $360M ($896M) $51M ($126M) $222M ($238M) $1.0B ($1.9B) Oil $413M ($422M) $18M ($499M) $61M ($68M) $130M ($142M) $620M ($1.1B) Gas2 $12M ($12M) $0M ($13) $2M ($2M) $4M ($4M) $18M ($31M) Total $2.1B ($2.4B) $419M ($2.9B) $125M ($497) $480M ($502M) $3.1B ($6.3B) Figures in () are Proposed Rule costs

16 Solid Waste Rule Clean Biomass Is Fuel Treated Wood (Except Borates) Is Waste Most Things If Generated and Burned Onsite Will Be Fuel EPA Deviated from Historic If Not Discarded Its Not a Waste Position Now Even If Not Discarded Will Be Waste If Burned for Fuel Unless It Meets 3 Legitimacy Requirements

17 Solid Waste Rule Legitimacy Requirements Managed as Valuable Commodity in Manner that Prevents Release to the Environment Have Sufficient Heating Value Have Contaminants Comparable to Those in Traditional Fuels that Boiler is Designed to Burn

18 More to Follow After Further Review Questions?

SMALL ENTITY COMPLIANCE GUIDE FOR MAJOR SOURCE BOILERS AND PROCESS HEATERS

SMALL ENTITY COMPLIANCE GUIDE F MAJ SOURCE BOILERS AND PROCESS HEATERS National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and