A Guide to Calculating Your Boiler Emissions. A step-by-step manual for your convenience

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1 A Guide to Calculating Your Boiler Emissions A step-by-step manual for your convenience

2 Contents The Importance of Emissions Calculations... 3 Why You Need to Calculate Your Boiler Emissions... 4 The Newest Boiler Regulations... 5 Getting Started: Collecting the Information You Will Need... 8 SCC Numbers... 8 AP42 Emission Factors... 9 Total Amount of Fuel Used Control Efficiency How to Calculate Your Boiler Emissions List of Equation Variations Sample Calculations Summing Up Your Boiler Emissions How to Ease Your Responsibilities

3 First Things First 2

4 The Importance of Emissions Calculations One of the most significant struggles for owners and operators of industrial, commercial, and institutional boilers is calculating and reporting their hazardous air pollutant (HAP) emissions to their regional and federal authorities. The biggest hurdle for Site Managers in today s lean manufacturing environment is a lack of time to compile the necessary information and accurately calculate the emissions for each and every type of boiler and each type of air pollutant in their facilities. ERA Environmental Consulting has prepared this step-by-step guide to help you understand how to correctly calculate and report the emissions produced by your boilers. Inside you ll find: How to find the data you ll use for your calculations Formulas you ll need to calculate your boiler emissions Information about the most recent boiler regulations Examples to help you do your calculations How to make your emission calculating easier and faster 3

5 Why You Need to Calculate Your Boiler Emissions Industrial, commercial, and institutional boilers in the United States are all subject to the rules and the regulations determined by the Environmental Protection Agency (EPA). The EPA is mandated by law to regulate boiler emissions in order to enforce the U.S. Clean Air Act (CAA). These boiler standards are known as NESHAPs National Emission Standards for Hazardous Air Pollutants. Each industry has its own specific set of standards that restrict the amount of pollutants boilers are allowed to emit into the environment. The EPA determines these air emission limits using a maximum achievable control technology (MACT) approach, which compares the best functioning boilers across a specific industry to find an achievable standard of air emission reduction. For more detailed information about the science behind the EPA s NESHAPs and MACT standards, download ERA s free Guide Getting to Grips With MACTs and NESHAPs. In order to demonstrate your compliance with the EPA s NESHAP emission limits, you will need to calculate your total boiler emissions and report the results to your relevant reporting authority. 4

6 The Newest Boiler Regulations Recently, the EPA passed a new set of boiler MACT regulations, directed at area source and major source boilers. An area source of air emissions is defined by EPA as any stationary source, or group of stationary sources, that annually emits in aggregate less than 10 tons of any single hazardous air pollutant (HAP) or less than 25 tons of multiple HAPs. A major source is defined as any stationary source, or group of stationary sources, that annually emits in aggregate at least 10 tons of any single HAP or at least 25 tons of multiple HAPs. These new regulations would institute new emissions limits and work practices for every type of boiler across every sector of industry. However, following public outcry and a flood of commentary from boiler owners and the public, the EPA has announced it is officially delaying the effective date of its major source boiler regulations so that it can reconsider the new rules. Owners and operators of area source boilers are still required to comply with the newest EPA boiler MACT standards. The compliance date for area boilers subject to tune-ups is March , and for area source boilers subject to emission limits is March Substances that are affected by these new emission limits for area source boilers include mercury, particulate matter (PM), and carbon monoxide. 5

7 In order to demonstrate compliance with these new limits, you need to calculate your boiler s air emissions and have the information ready to report. For a complete list of all the newest boiler MACT standards, including compliance dates, background information about the EPA s official reconsideration, exceptions, and how they affect your business now, download ERA s free white paper: A Guide to the New Boiler MACT Regulations. 6

8 Getting Started... 7

9 Getting Started: Collecting the Information You Will Need The first step in properly determining your total boiler emissions is gathering the necessary preliminary data that you will use during your calculations. Some of this necessary information will come from an outside authority, but some of it you are obliged to provide for yourself from your own records and stack testing. This section will tell you all of the raw data you ll need to collect and where to find it. Before you can begin your calculations you will need to determine: The SCC Number for each of your boilers All of the AP 42 Emission Factors associated with each SCC number The Total Amount of Fuel Used in all of your boilers, for each type of fuel The Control Efficiency of all your control technology that has an impact on your boiler emissions SCC Numbers Each and every boiler used in your facilities has an SCC number, also known as a Source Classification Code. The SCC number is based on many factors, including: the type of boiler, heat input capacity, process, fuel used, and control technologies. Your equipment records may already list your facility s SCC numbers. However, if you do not know the SCC number for each of your boilers you will need to search this information out. 8

10 The best source for determining SCC numbers is the Environmental Protection Agency s online application WebFIRE. This online tool makes it possible for you to find for your SCC number using a simple search tool. While the SCC number is not used in the actual air emissions formula, you will use the list of your SCC numbers to determine all of the relevant emission factors and pollutants that you will have to report. AP42 Emission Factors An emission factor relates amount of a hazardous air pollutant (HAP) that is released into the environment per unit of fuel burned. The emission factors associated with each of your SCC numbers tell you which pollutants you need to report for and the values you will use in your final calculations. For example, one emission factor associated with a wood burning boiler with a SCC of is: 1.50 Lb of Nitrogen Oxide (NOx) per ton of wood/bark burned. If you have a boiler with the same SCC, you will need to calculate and report your total NOx emissions. The EPA provides a list of emission factors for most of the common fuel types on their WebFIRE online app. You can use this tool to find the list of pollutants and emission factors that you will need to use while calculating your boiler emissions. It is important to note that the EPA emission factors are simply estimates based on the long-term emission averages for all facilities using the same category of source. EPA provides emission factors for the most common fuel types, but these are just estimates based on long-term averages for all facilities in the source category. The EPA s estimates may not accurately reflect your actual emissions, which may be lower or higher depending on your facility and boiler technology. For this reason, whenever possible, it is preferable to perform stack testing for each of your boiler s emission points. This testing may show that your boilers have a different set of emission factors than the EPA s guidelines. 9

11 If the fuel you use is uncommon, then you will need to determine your own unique set of emission factors through stack testing as well. It is possible that your facility with only one or a few boilers will have hundreds of emission factors to keep track of. It is essential that you keep highly organized documentation or use time-saving EHS software so that you do not lose track of an emission factor and have to find it again from a long list of data. The average site manager spends dozens of hours researching and documenting this type of data each reporting season. Total Amount of Fuel Used As part of your calculations, you will need to determine the total amount of fuel used during your facility s processes according to type of fuel and boiler. You will need to make sure to convert the fuel usage into the measurement indicated by that fuel s emission factors (including tons, gallons, cubic feet, etc.). Your standard inventory records should indicate how much of each fuel you have used, making this value available at most facilities. Remember, you only need to report the actual emissions of the fuel burned, not the total potential emissions of your site including fuel kept in storage. Ensure that the data you use in your calculations is usage data and not simply inventory data. Control Efficiency Control efficiency indicates the capability of your control technologies to reduce the emission of HAPs into the environment. 10

12 These technologies play a part in how you calculate your total boiler emissions because you are only obliged to report the emissions that enter the environment. Any pollutants removed or destroyed by your control technology are excluded from your final emissions. The EPA s WebFIRE app includes SCC numbers for boilers that take into account the most common forms of control technology. However, you are still responsible for providing the numerical value of your control efficiency when calculating your final emissions. You should keep track of this information along with any modifications you do to your equipment in your product specifications and personal records. 11

13 How To Do the Calculations 12

14 How to Calculate Your Boiler Emissions The general base equation for calculating your boiler emissions is: E = A x EF x (1 ER / 100) Where: E is your total boiler emission for a specific pollutant from a specific boiler A is the total amount of fuel used in the boiler EF is the emission factor of a specific pollutant ER is your total emission reduction efficiency/control efficiency (in a decimal value) for a specific source of emissions When an emission factor is measured in lbs/ton you can use this base equation to calculate your emissions, but if not you will need to use a modified version of the base equation from the following list of variations. List of Equation Variations Please refer to the following list of equations to determine which variation should be used when determining your boiler emissions. Note that the following equations calculate your emissions in lbs, which you can convert to tons easily (2000 lbs per 1 ton). 13

15 For wood or coal burning boilers with an emission factor measured in lbs/mmbtu: For fuel oil burning boilers with an emission factor measured in lbs/10 3 gallons: For fuel oil burning boilers with an emission factor measured in lbs/mmbtu: For natural gas or propane burning boilers with an emission factor measured in lbs/10 6 cubic feet: 14

16 Sample Calculations We have included a few sample calculations to be used as a guide during your own facility s emissions calculations. Note that every boiler s calculations will differ depending on fuel type, emission factors, control technologies, etc. 1. Wood or Coal Burning Boilers For wood or coal, fuel amounts are measured in tons. Emission factors are generally provided in lbs/ton or lbs/mm Btu. Example calculation Fuel type: Coal Amount of fuel burned: 518 tons Emission factor: 5.0 lbs of CO emitted per ton Control technology: None 518 tons of coal used x 5.0 lb/ton x (no control technology) = 2590 lbs of CO emitted 2590 lbs 2000 lbs per ton = (1.30) tons of CO emitted 2. Fuel Oil Burning Boilers For fuel oils, fuel amounts are measured in gallons. Emission factors are typically provided in units of in lbs/10 3 gallons or lbs/mmbtu. Example calculation Fuel type: Fuel oil Amount of fuel burned: 150,000 gallons Emission factor: 71 lbs of SO2 emitted per 10 3 gallons Control technology: 95% efficient 15

17 150,000 gallons 1000 x 71 lbs/10 3 x (1-0.95) = lbs of SO2 emitted lbs 2000 lbs per ton = tons emitted 3. Natural Gas or Propane Burning Boilers For natural gas and propane boilers, fuel amounts are measured in cubic feet. Emission factors are typically provided in units of lbs/10 6 cubic feet. Example calculation Fuel type: Propane Amount of fuel burned: 5,000,000 cubic feet Emission factor: 7.6 lbs of Particulate Matter (PM) emitted per 10 6 cubic feet Control technology: None 5,000,000 cubic feet 10 6 x 7.6 lbs/10 6 cubic feet x (no control technology) = 38 lbs of PM emitted 38 lbs 2000 lbs/ton = tons of PM emitted Summing Up Your Boiler Emissions You will need to perform this calculation many times, once for each reportable pollutant from each of your boilers. Even if you only have one boiler, you may need to do dozens or even hundreds of calculations, depending on how many emissions factors your boiler s SCC number indicates. If you have multiple boilers, you will need to calculate the total emissions of each pollutant from every single boiler. If your permit requires you to demonstrate your total emissions as a facility, you will then need to sum up all of the emissions of a specific 16

18 pollutant, for each relevant HAP. If your permit only requires you to report your emissions per boiler, this final addition is not necessary. Ultimately, the price of calculating your own boiler emissions is paid in the countless hours of repetitive work. While the calculations are not highly complex, the collection of data and calculations are time consuming and have a steep opportunity cost. 17

19 How To Ease Your Responsibilities 18

20 How to Ease Your Responsibilities Calculating your total boiler emissions can be an enormous hassle: there are countless details to keep track of, hundreds of equations to complete, data to collect from outside sources and your own records, and dozens of hours of labour time involved. Some site managers employ a spreadsheet to automate these calculations. While spreadsheets can work as a temporary solution, oftentimes they become so unruly that they take more time than they save. With all of the data needed to calculate boiler emissions, spreadsheets often fail to organize data and calculate emissions correctly. It takes a great deal of training and experience to be able to create a spreadsheet that can do everything you need it to that also contains failsafe solutions to ensure calculations are correct. Not only does this mean you ve wasted hours of precious time, but you could also face hefty noncompliance fines. Many of ERA s customers stopped using spreadsheets when they realized their spreadsheets were either under- or over-reporting their emissions. ERA Environmental Consulting has worked for over a decade to create a software tool that reduces the amount of time you ll spend reporting your emissions by up to 75%. Our Environmental Management System comes built-in with all of the SCC codes and emission factors your business could need, documents your facility s control technologies, and keeps track of your fuel usage. Calculating your entire site s boiler emissions takes only moments. Section Headline 19

21 Comprehensive EMS Software from ERA s Platform ERA has been providing comprehensive EMS software to the manufacturing industry for nearly 2 decades. We offer an All-in-One Environmental Management & Compliance Software that gives you the tools you need to effectively do your job, by eliminating redundancy and letting you focus on the Real Work of improving your environmental performance. These essential tools form the four main modules of our software that you need to improve your environmental performance. If you would like to find out more about ERA s Environmental Management Software solutions and how they can help you manage your facilities more efficiently and with less frustration, call us +1 (866) or visit 20

22 References [1] EPA s WebFIRE online tool: Disclaimer: All information contained in this fact sheet is accurate as of February ERA accepts no liability for the content of this fact sheet, or for the consequences of any actions taken on the basis of the information provided. To ensure the accuracy of the information provided, please contact the Environment Canada. For a more recent revision of this document, please contact ERA at +1 (866)

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