Boiler GACT Update Georgia AWMA Conference October 2013

Agenda - NESHAP Anatomy Applicability and Affected Sources Subcategories and Emission Limits Compliance Options Compliance Assurance Requirements Schedule and Definitions Boiler MACT and GACT Structure Very Similar - More/Different Requirements for Major Sources

The “Final” Combustion Source Rules Promulgated again by US EPA on January 31 and February 1, 2013 Includes four (4) Interrelated Rules Detailed Site-specific Action Plan Needed 40 CFR 63 Subpart DDDDD – Major Source Boiler MACT 40 CFR 63 Subpart JJJJJJ – Area Source Boiler GACT 40 CFR 60 Commercial and Industrial Solid Waste Incineration (CISWI) Rule 40 CFR 241 Non-Hazardous Secondary Materials (NHSM) Solid Waste Identification Rule To gather data, assess applicability, determine emission limits, review compliance status/options, and implement compliance strategy

The Solution is a Process Issue… Point of Compliance Fuel Spec Supply Longevity Cost Fan Modification Combustion Mod Operating Flexibility Retrofit Addition Permitting Compliance Testing Cost Each part of the process may be part of the answer!

Boiler Area Source GACT Rule (Boiler GACT) GACT = Generally Available Control Technology Applicability - Applies to boilers that: Burn a “fuel” material, not a “waste” as defined by US EPA (“Fuel” = coal, oil, gas, biomass, tire- derived fuel, others) Located at an industrial, institutional, commercial facility that is an “area source” (any source not major) of Hazardous Air Pollutants (HAP)* Does not include process heaters *Note: A facility is an Area Source of HAP emissions if it emits less than 10 TPY of any single regulated HAP, and less than 25 TPY of any combination of HAP’s

Boiler GACT Applicability Applies to HAP Area Sources “Natural Gas” Boilers are Exempt Existing Sources (Commenced Construction Prior to 6/4/10) Emission Limits Set Only for Coal Boilers Fuel Oil and Biomass Units Only Subject to Work Practice Standards Fuel Switching After 6/4/10 May No Longer Trigger New Source Status Initial Compliance Date 3/21/14 for existing sources

Natural Gas Curtailment Period of gas curtailment or supply interruption means a period of time during which the supply of gaseous fuel to an effected boiler is restricted or halted for reasons beyond the control of the facility. The act of entering into a contractual agreement with a supplier of natural gas established for curtailment purposes does not constitute a reason that is under the control of a facility for the purposes of this definition. An increase in the cost or unit price of natural gas due to normal market fluctuations not during periods of supplier delivery restriction does not constitute a period of natural gas curtailment or supply interruption. On-site gaseous fuel system emergencies or equipment failures qualify as periods of supply interruption when the emergency of failure is beyond the control of the facility.

Fuel Switching Improvement 63.11194(e) - An existing dual-fuel fired boiler meeting the definition of gas-fired boiler, as defined in § 6.11237, that meets the applicability requirements of this subpart after June 4, 2010 due to a fuel switch from gaseous fuel to solid fossil fuel, biomass, or liquid fuel is considered to be an existing source under this subpart as long as the boiler was designed to accommodate the alternate fuel.

Significant Improvements/Changes Many Emissions Limits are Now Higher Initial Tune-Up Deadline Delayed to 3/21/14 Tune-Ups Conducted Using Primary Fuel Over the Prior 12 Months Natural Gas Curtailment Now Includes On-Site Fuel System Failures Temporary, Seasonal and Limited Use Boiler Relaxation CO Emission Limit and Potential CEMS for Oil Sources Removed New Oil Sources Burning < 0.5 % Sulfur Are Exempt from PM Limit Start-Up & Shutdown Definitions Changed and 25% “Bright Line” Removed Potential Hg Fuel Analysis Relaxation

Initial and Continuous Compliance Initial Notification(s) Work Practice Standards (Tune-Ups, Energy Assessment, etc.) Periodic Performance Tests Notification of Compliance Status Report(s) Monitoring of Operating Parameters for Control Devices Stack O2 Monitor for CO Limits Stack Testing or Fuel Analysis for Hg

Boiler GACT Compliance Existing Source Initial Compliance Deadline 3/21/14 Initial Tune-Up and One Time Energy Assessment Stack Testing for Applicable Boilers Due by 9/17/14 Notification of Compliance Status Report(s) (7/19/14 and/or 11/17/14) Ongoing Compliance Assurance – Testing, Monitoring, Recordkeeping and Reporting SSM Requirements ???

Existing Coal Boilers Subject to Mercury (Hg) and CO Emission Limits Hg Compliance Based as Fuel Analysis or Stack Testing CO Compliance Typically Based Only on Stack Testing Stack Testing Includes: Both Initial and Ongoing Testing Test Plan Approval by GA EPD Monitoring and Establishing Hg, CO and Capacity Operating Limits Developing/ Implementing a Site Specific Monitoring Plan Conduct Initial and Periodic Continuous Parameter Monitoring System Performance Evaluations – May Need a RATA!? Need to Run at Maximum Capacity – 110% Operating Limit Report Results Via New US EPA WebFire Database

One-time Energy Assessment (EA) Required for All Existing Affected Boilers > 10 MM Btu Except Limited Use Higher Fuel Efficiency means Reduced Air Pollutants Emitted to the Atmosphere EA to Identify and Evaluate Cost Effective Energy Conservation Measures – Not a Regulatory “Deliverable” EA will cover the Boilers and the Energy Use System within the Sources’ property (compressed air, machine drive, process cooling, hot water, HVAC, building envelope) Requires an evaluation of the facilities “energy management practices” and required EA Duration is dependent on total heat input capacity EA to follow prescribed procedures and assessor qualifications relaxed, and existing assessments can now be amended as needed to comply.

Permitting Considerations Will Generic Placeholder Conditions Suffice? Trade-off of Generic vs. Specific Conditions Approach Typical Issues With Agencies: Approval of Alternative Operating Limits Approval of Multiple Compliance Options Testing of Worst Case Fuel for Each Pollutant Title V Versus GACT Inconsistencies Verify if Site Specific Monitoring Plan Needs to be Submitted Need for Multiple NOCSR Submittals Does Annual Compliance Report Need Submittal

Permitting Considerations (continued) What Permit Applications are Needed and When? < 10/25 TPY HAP Emission Limits New/Modified Emission Control Device Construction, Operation, and/or Operating Limits New Boiler(s) and/or Fuel Switching Compliance Option Definition Need to Ensure Compliance Plan is Enforceable! Solid Fuel Variability is a Challenge/Risk for Both Area Source Status and Boiler GACT Compliance Request to See a “Pre-Public” Draft Amendment Other Potential Implications– NSR, NAAQS, NSPS, GHG, etc.

Case Study Example Major HAP Source With One Large Coal Boiler, Four Natural Gas Boilers and Very Low Process HAP’s Looking at Area Source HAP Status Via Limiting Boiler HCl Emissions Lime Injection Into Baghouse or Add-On Wet Scrubber Potential Fuel Switching From Coal Addition of Fuel Oil to Manage Natural Gas “Risk” Conducting Stack Testing and Fuel Analysis Completing “What If” Emission Testing Setup Ongoing Hg Fuel Analysis Evaluating Hg and/or CO Compliance Options Fuel Vendor Contract Limits and Operating Restriction/Controls Trade off of CO Management Versus NOx Permit Limits Development of Long Term Compliance Strategy and Schedule Operating Costs, Impacts and Uncertainties Build Results Into Site Budgeting Cycle Ongoing GA EPD discussions/negotiations

Boiler MACT Planning Timeline Based on January, 2016 Initial Compliance Date Now 3/2014 9/2014 1/2015 3/2015 9/2015 1/2016 Data Gathering and Initial Planning Boiler Stack Testing Completed Engineering Evaluation and Fuel Supplier Review Technology/ Vendor Selection and Design Permitting and Regulatory Negotiations Fabrication, Construction, Check Out and Training Ongoing NESHAP Compliance Activities

What’s Next for You? Assess if you have boilers/process heaters potentially subject to CISWI versus MACT/GACT Identify applicable emission limits and if you can comply with these limits Gather needed fuel analysis and/or stack test data (develop/implement test plan) Evaluate the need for additional emissions controls, perform economic analyses and plan for future budget cycles Determine if need additional monitoring systems Consider operational, process and/or fuel changes to reduce the regulatory burden Develop an overall compliance strategy and schedule Plan for tune-ups and facility-wide energy assessment

Questions?

Contact Information David Dunn david.dunn@erm.com ERM 3200 Windy Hill Road SE Suite 1500W Atlanta, GA 30339 678.486.2700