1. Boiler GACT Update Georgia AWMA Conference
October 2013

2. 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

3. 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

4. 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!

5. 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

6. 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

7. 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.

8. Fuel Switching Improvement
(e) - An existing dual-fuel fired boiler meeting the definition of gas-fired boiler, as defined in § , that meets the applicability requirements of this subpart after June 4, 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.

9. 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

10. 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

11. 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 ???

12. 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

13. 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.

14. 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

15. 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.

16. 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

17. 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

18. 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

19. Questions?

20. Contact Information
David Dunn
ERM
3200 Windy Hill Road SE
Suite 1500W
Atlanta, GA 30339