1. Boiler Sheltered Initiative
Web cast
May 15, 2008
May 29, 2008

2. Introduction and Logistics
Presenters
Barb Johnson and Ryan Hamel – K-State SBEAP
Webcast logistics
You will not be able to speak during the seminar
Ask questions/comments by typing them into the long text box at the bottom of the screen and pressing enter.
Slides will advance automatically.
Questions? Call the help-desk at

3. Overview Clarify EPA vs KDHE vs OSHA vs KDOL
Small Business Environmental Assistance Program (SBEAP)
Types of Kansas air regulations
KDHE boiler sheltered initiative
Emergency generator
Future additions or modifications

4. Regulatory Agencies EPA – federal KDHE - state OSHA - federal
Bureau of Air & Radiation
Air emissions
OSHA - federal
KDOL - state
Industrial Safety & Health Section
Boiler Safety Inspection Unit
Local ordinances

5. Small Business Environmental Assistance Program
Similar program in every state-Clean Air Act req’d
Provides air and haz waste-focused technical assistance to Kansas small- and medium-sized businesses/institutions
Permitting and reporting requirements
Regulatory compliance
Emissions/waste reduction
This is a program we operate under a specific contract with the Kansas Department of Health and Environment.

6. Where SBEAP fits… Kansas State University Engineering Extension
Pollution Prevention Institute (PPI)
Small Business Environmental Assistance Program (SBEAP)

7. Air Regulations

8. Types of Air Regulations
KAR
Air construction approval/permit
Operating permit
NSPS (New Source Performance Standards) adopted by reference
PSD (Prevention of Significant Deterioration)
NESHAP (National Emission Standard for Hazardous Air Pollutants) / MACT (Maximum Achievable Control Technology) adopted by reference

9. Potential to Emit (PTE)
Basis for determining permitting requirements
Represents the source’s maximum capacity or worst case scenario emissions
The maximum amount of air pollution your facility can emit if:
Each process operated at 100% of its capacity
All equipment is operating 24/7 (8,760 hrs/yr)
Materials that emit the most air pollution are processed 100% of the time
No pollution control equipment is used

10. Calculating PTE Calculation methods Emission factors Material balances
Other approved methods
Computer programs
Industry-specific emission factors
Approved by KDHE on an individual basis

11. PTE Emission factors are used for calculating boiler emissions
Manufacturer’s emission factors are best
AP-42 is a compilation of factors for specific processes accepted by EPA
Emission factors software and tools

12. Expedited Approval
If your PTE exceeds these thresholds, then you’ll need an expedited approval:
Source: What is the Kansas Air Quality Act? -

13. Expedited Permit
If your PTE exceeds these thresholds, then you’ll need an expedited permit:
Proposed construction projects at new facilities and modifications at existing facilities need to be evaluated for the need for a construction permit or approval.
Source: What is the Kansas Air Quality Act? -

14. Operating Permit (Class I)
Count PTE of all emission sources
Required if PTE exceeds these thresholds:
100 tons per year NOX, SOX, PM10, VOC, CO
10 tons per year of any single hazardous air pollutant (HAP)
25 tons per year of combined HAPs
Most likely will not apply to those on this call

15. Operating Permit (Class II)
An option when actual emissions are below Class I thresholds but PTE is above
Advantages
minimal record keeping
simpler
cheaper
If actual emissions are below the Class I thresholds but PTE is above – then limit your emissions and apply for a Class II operating permit
A Class II permit requires minimal record keeping and is simpler (and cheaper) than maintaining a Class I permit

16. Small Boiler NSPS NSPS = New Source Performance Standards
40 CFR subpart Dc
Installed or modified after June 9, 1989
Heat input capacity is between 10 and 100 MMBTU/hr

17. KDHE Boiler “Sheltered” Initiative

18. KDHE Boiler “Sheltered” Initiative
Applies to companies or institutions that have boiler(s) with heat input capacity between 10 and 100 MMBtu/hr and installed after June 9, 1989
Many small boilers out of compliance with these federal requirements

19. KDHE Boiler “Sheltered” Initiative
Must evaluate whether new source performance standard (NSPS) applies
Must evaluate need for air permit/approval
Complete applicable permit applications
Expedited approval and/or permit
Must be in compliance by Sep. 30, 2008

20. Evaluating Permit Needs
Identify for all boilers:
Date of installation or modification
Heat input capacity (typically in MMBTU/hour)
Type of fuel (natural gas, fuel oil, etc)
Evaluate using fuel with greater PTE
Low NOX burner (for natural gas-fired boilers)

21. Evaluating Permit Needs
Use information (from previous slide)
Use AP-42 emission factors
Emissions can be estimated with this info
Don’t worry, we’ve done the calculations!
See flow chart in packet received from KDHE

23. The heat input capacity of the boiler is between 10 and 100 MMBtu/hr
Subject to NSPS?
The boiler was constructed, modified, or reconstructed after June 9, 1989
The heat input capacity of the boiler is between 10 and 100 MMBtu/hr
Complete the expedited KDHE boiler form
Yes
Yes No No
The boiler is not subject to NSPS requirements

24. Subject to expedited approval/permit?
Boilers burn natural gas
Boilers have low NOX burners
Total heat input capacity is 10 MMBtu/hr or greater
No requirements
Expedited approval needed
Yes
Total heat input capacity is less than 10 MMBtu/hr No
Total heat input capacity is between 10 and 93 MMBtu/hr
Total heat input capacity is 93 MMBtu/hr or greater
Expedited permit needed
Boilers burn fuel oil #1 or #2 or diesel
Total heat input capacity is less than 3.8 MMBtu/hr
Total heat input capacity is between 3.8 and 17.8 MMBtu/hr
Total heat input capacity is 17.8 MMBtu/hr or greater
Boilers burn residual oil #5 or #6
Total heat input capacity is less than 3.5 MMBtu/hr
Total heat input capacity is between 3.5 and 16.1 MMBtu/hr
Total heat input capacity is 16.1 MMBtu/hr or greater
Contact KDHE Bureau of Air and Radiation (BAR)

25. Other possible sources

26. Emergency Generators Emergency generator definition
Used only for back-up power (not to offset peak energy usage)
For PTE calculations, assume 500 hours/year
All emergency generators should be registered with KDHE
Expedited form available

27. Source: www.kdheks.gov/air-permit/forms/Emergency_Gen_App.pdf
Expedited Form
Source:

28. Future Additions or Modifications
Evaluate PTE for new or modified equipment
If PTE exceeds construction approval or permit thresholds, contact KDHE
Thresholds:
Forms:

29. Summary

30. In conclusion… You must determine your permitting needs.
If assistance is needed, contact David Peter at , Cheryl Evans at , or SBEAP at
Affected facilities must submit form(s) by September 30, 2008.

31. Air Permitting Web Site
Includes forms for:
Expedited approvals application
Generator
Boiler
Expedited permits application
Construction permit/approval application
Operating permits application
Reporting forms
Equipment specific

32. Environmental Hotline
Questions or Comments?
KDHE contacts
David Peter,
Cheryl Evans,
SBEAP
Environmental Hotline