1. Rick Soucy GZA GeoEnvironmental, Inc.
Compliance with New Air Pollution Regulations for Boilers and Emergency Generators - The Basics of What Every Facilities Manager Should Know NEHES Fall Conference October 1, 2013
Rick Soucy
GZA GeoEnvironmental, Inc.

2. Overview Recent Federal Regulations Impact Hospital Operations
Affected Equipment – Boilers, Emergency Generators, Chiller Engines, Cogeneration Engines
Regulations Complex
Compliance Deadlines Looming
Basics to Know
Applicability
Compliance Requirements, i.e., How to Comply
Compliance Schedule, i.e., When to Comply By

3. Regulatory Background
CAAA of 1990 (Title III)
Mandated EPA to Develop Rules to Reduce Emissions of Hazardous Air Pollutants (HAPs)
National Emission Standards for Hazardous Air Pollutants for Source Categories (NESHAPs)
a.k.a. “MACT” (Maximum Achievable Control Technology) Standards
Promulgated at Federal Level by EPA
Enforcement May Be Delegated to States

4. Why Regulate HAP Sources?
Known or Suspected to Cause Cancer and Other Serious Health Effects
Aggravate Respiratory and Cardiovascular Disease
Changes in Lung Function
Adverse Effects on Child Development
Premature Deaths

5. HAPs and MACT Standards
187 HAPs Currently Regulated
MACT Standards for 133 Source Categories to Date
Today’s Focus:
Area Source Boiler MACT Rule - 40 CFR Part 63, Subpart JJJJJJ (“6J”)
Stationary RICE (Reciprocating Internal Combustion Engine) MACT Rule - 40 CFR Part 63, Subpart ZZZZ (“4Z”)

6. Clarification Area Source vs. Major Source
Major HAP Source: > 10 Tons/Year of Any Single HAP or > 25 Tons/Year of Total HAPs Area HAP Source: Any Facility That is Not Major

7. Area Source Boiler MACT 40 CFR Part 63, Subpart JJJJJJ
Applies to Industrial, Commercial, and Institutional Boilers at Area Sources
History
First Proposed by EPA on June 4, 2010
Thousands of Comments Received
Originally Finalized on March 21, 2011
Simultaneous Notice of Reconsideration
Another Notice of Reconsideration and Proposed Amendments on December 23, 2011
“Final” Rule on February 1, 2013
Lawsuits Filed by Environmental and Industry Groups

8. Area Source Boiler MACT 40 CFR Part 63, Subpart JJJJJJ
Q. Why Has Boiler MACT Been So Controversial?
A. There Are a Lot of Boilers ~ 1.5 million
Of These, EPA Estimates:
86% Are Clean and Not Covered by the Rule
13% Are Subject to Work Practice Standards
1% Are Subject to Numerical Emission Limits
Most Hospitals and Healthcare Facilities

9. What Boilers Are Exempt from Boiler MACT?
Gas-Fired Boilers
EPA Definition: Gas-Fired boiler includes any boiler that burns gaseous fuels not combined with any solid fuels and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel. Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year.

10. What Other Boilers Are Exempt from Boiler MACT?
Residential Boilers
Hot Water Heaters with Capacity < 120 gallons
Hot Water Boilers (Not Generating Steam) with Heat Input Capacity < 1.6 MMBtu/hr
Electric Boilers
Temporary Boilers
Must Be Portable
Must Not Remain at Same Location More Than 12 Consecutive Months

11. Area Source Boiler MACT
Applicable Compliance Requirements
Vary According to:
Size (capacity) of Boiler
When Constructed (before or after June 4, 2010)
Type of Fuel Combusted

12. Summary of Requirements
Summary of Area Source Boiler MACT Emission Limit and Work/Management Practice Requirements
Subcategory
Summary of Requirements
Existing large area source boilers
i.e., commenced construction or reconstruction of the boiler on or before June 4, 2010; greater than or equal to
10 MMBtu/hr
Gas (all types)
No requirements (not covered by the rule)
Coal (excluding limited-use boilers)
Numeric emission limits for mercury (Hg) and carbon monoxide (CO)
One-time energy assessment
Biomass or Oil
Initial tune-up
Subsequent tune-ups every other year or every 5 years
No numeric emission limits
Limited-use Coal
Subsequent tune-ups every 5 years
No energy assessment
Existing small area source boilers
i.e., commenced construction or reconstruction of the boiler on or before June 4, 2010; less than 10 MMBtu/hr
Coal, Biomass or Oil

13. Summary of Requirements
Summary of Area Source Boiler MACT Emission Limit and Work/Management Practice Requirements
Subcategory
Summary of Requirements
New large area source boilers
i.e., commenced construction or reconstruction of the boiler after June 4, 2010; greater than or equal to 10 MMBtu/hr
Gas (all types)
No requirements (not covered by the rule)
Coal (excluding limited-use boilers)
Numeric emission limits for Hg, CO, and particulate matter (PM)
Biomass or Oil (excluding limited-use and seasonal boilers)
Numeric emission limit for PM*
Tune-up every other year or every 5 years
Limited-use Coal
Tune-up every 5 years
No numeric emission limits
Limited-use and Seasonal Biomass or Oil
New small area source boilers
i.e., commenced construction or reconstruction of the boiler after June 4, 2010; less than
10 MMBtu/hr
Coal, Biomass or Oil
*New oil-fired boilers that combust only oil with no more than 0.50 % sulfur (or a mixture of 0.50 % sulfur oil with other fuels not subject to a PM emission limit) are not subject to a PM emission limit provided they do not use emission controls (except a wet scrubber) to reduce PM or SO2 emissions.

14. Boiler MACT Tune-up Requirements
Conduct According to EPA Specifications
Tune-up on Fuel That Provided the Majority of the Heat Input to the Boiler Over Last 12 Months
Inspect Burner – Clean and Replace Components, as Necessary
Inspect Flame Pattern and Adjust Burner to Optimize
Inspect Air-to-Fuel Ratio Controller, if Equipped
Optimize CO Emissions Consistent with Manufacturer’s Specifications
Measure the Exhaust Concentration of CO and O2 Before and After Any Adjustments Made
Maintain Report That Identifies Measured Concentrations and Corrective Actions

15. Boiler MACT Energy Assessment Requirements
Must Be Performed By a Qualified Energy Assessor
Assessment Must Include:
Visual Inspection of Boiler System
Evaluation of Operating Characteristics and Specifications of the Boiler System
Inventory of Major Energy Use Systems Consuming Energy from the Boiler
Review of Architectural/Engineering Plans, Operations and Maintenance Procedures/Logs, and Fuel Usage
List of Major Energy Conservation Measures Within the Facility’s Control
List of the Energy Savings Potential of Energy Conservation Measures
Comprehensive Report Detailing Ways to Improve Efficiency, Cost of Specific Improvements, and Payback Periods

16. Boiler MACT Energy Assessments -Other Things to Know-
On-Site Technical Labor Hours Can be Limited – Depends on Total Annual Heat Input Capacity of the Boiler
Requirement Satisfied if Already Had Assessment Done After 1/1/2008 and if Met EPA Specifications
Requirement Satisfied if Facility Operates Under an Energy Management Program Compatible with ISO That Includes the Affected Boiler

17. Boiler MACT -Other Requirements-
Submit Notifications (as applicable)
Keep Records of Fuel Usage
Prepare Compliance Certification Reports
Boilers with Emission Limits:
Performance Tests
Fuel Analyses
Continuous Monitoring Systems

18. Boiler MACT Compliance Dates
Initial Notification: January 20, 2014 or Within 120 Days of When a New Boiler Becomes Subject
Initial Tune-ups and Energy Assessments: March 21, 2014
Emission Limits: March 21, 2014 (Performance Testing Required Within 180 Days)
Notification of Compliance Status for Tune-Ups and Energy Assessments: July 19, 2014
Prepare Annual Compliance Certifications by March 1 of Every Year
Note: Notifications may have to be sent electronically using CEDRI Interface.

19. Helpful Web Sites for Boiler MACT
EPA Region 1 List of Qualified Energy Assessors
General Information and Compliance Tools

20. RICE MACT 40 CFR Part 63, Subpart ZZZZ
Applies to Stationary Engines of All Types and Sizes
Existing and New
Emergency and Non-Emergency
Compression Ignition (CI)
Spark Ignition (SI)
Does Not Apply to Non-Road Engines or Motor Vehicle Engines

21. RICE MACT History
Originally Proposed by EPA on December 19, 2002: RICE > 500 HP at Major Sources
Revised and Expanded: January 18, 2008, March 3, 2010, August 20, 2010, March 9, 2011
“Final” Amendments on January 30, 2013
Notice of Reconsideration: September 5, 2013

22. RICE MACT Applicability to Hospitals and Healthcare Facilities
Emergency Engines (Generators and Fire Pump Engines)
Gas-Fired Chiller Engines
Gas-Fired Cogeneration Engines
Focus: Compliance Requirements at Area Sources

23. RICE MACT Compliance Requirements for Emergency Engines
GOOD NEWS !!
Existing Institutional Emergency Engines are Exempt
BUT…

24. RICE MACT Compliance Requirements for Emergency Engines
Must Operate in Accordance with EPA Definition of an Emergency Stationary RICE, i.e.,
Maximum 100 hr/yr Total for Maintenance/Testing, Emergency Demand Response, and > 5% Voltage/Frequency Deviations
50 Hours of the 100 hr/yr Allocation Allowed for Non-Emergency Situations (excluding peak shaving or financial arrangements, with limited exceptions)
Must Not Operate (or be contractually obligated to operate) More Than 15 hr/yr for Emergency Demand Response (EDR) * and >5% Voltage/Frequency Deviations
* “Energy Emergency Alert Level 2” Per Reliability Coordinator

25. RICE MACT Compliance Requirement for Emergency Engines
- No Limit on Emergency Operations -
WARNING!
Your State or Local Air Pollution Control Authority May Have More Stringent Operating Limits and Compliance Requirements

26. RICE MACT – Emergency Engines
What if Your Emergency RICE Operates or is Contractually Obligated >15 hr/yr for Emergency Demand Response?
ULS Fuel (<15 ppm) by January 1, 2015
Operate/Maintain Engine According to Manufacturer’s Instructions
Subject to Management Practices
Change Oil/Filter Every 500 Operating Hours, or Annually
Inspect Air Cleaner Every 1,000 Operating Hours, or Annually
Inspect Hoses and Belts Every 500 Operating Hours, or Annually
Inspect Spark Plugs Every 1,000 Operating Hours, or Annually

27. RICE MACT – Emergency Engines
What if Your Emergency RICE Operates or is Contractually Obligated >15 hr/yr for Emergency Demand Response?
If >100 HP, Submit Annual Report
Engine Rating/Model Year
Latitude/Longitude of Engine Location
Identify Contractual Obligations
Operating Hours for EDR and Voltage/Frequency Deviations (Dates, Start Times, Stop Times)
Reason for Each Dispatch
First Report Due 3/31/2016 for Calendar Year 2015

28. RICE MACT – Emergency Engines
What If Allowable Non-Emergency Operations Exceed 100 hr/yr?
SEVERE CONSEQUENCES
Management Practices (oil changes, inspections, etc.)
Emission Limits or Emission Reduction Requirements
Install Emission Control Equipment
Conduct Emission Performance Tests
Monitor Exhaust Catalyst Performance Parameters
Semi-Annual Compliance Reports
Notifications to EPA and State Authority

29. RICE MACT Applicability to “New” Emergency Engines
“New” If Construction Commenced On or After 6/12/2006
Must Instead Comply with Federal NSPS
40 CFR Part 60, Subpart IIII for CI Engines
40 CFR Part 60, Subpart JJJJ for SI Engines
General NSPS Requirements
Purchase a Certified Engine
Emission Performance Tests (Non-Certified SI)
Operate According to Emergency Engine Limitations
Non-Resettable Hour Meter
ULS Fuel (CI)
Install/Operate/Maintain According to Manufacturer’s Instructions

30. RICE MACT Compliance Requirements for Existing Non-Emergency Engines
Gas-Fired Chiller Engines
Gas-Fired Cogeneration Engines
Five Gas-Fired Engine Categories
2SLB
4SLB < 500 HP
4SRB < 500 HP
4SLB > 500 HP
4SRB > 500 HP

31. RICE MACT Compliance Requirements Existing Non-Emergency 2SLB Engines
Change Oil/Filter Every 4,320 Operating Hours, or Annually
Inspect Spark Plugs Every 4,320 Operating Hours, or Annually (Replace as Necessary)
Inspect Hoses/Belts Every 4,320 Operating Hours, or Annually (Replace as Necessary)
Operate to Minimize Emissions

32. RICE MACT Compliance Requirements Existing Non-Emergency 2SLB Engines (continued)
Maintain Engine and Control Device According to Manufacturer’s Instructions, or Develop Maintenance Plan
Minimize Idling Time During Start-up
Limit Start-up Time to 30 Minutes
Keep Maintenance Records
Must Comply by October 19, 2013

33. Compliance Date: October 19, 2013
RICE MACT Compliance Requirements Existing Non-Emergency 4SLB and 4SRB Engines < 500 HP
Same Requirements as for 2SLB, Except:
Maintenance Interval = Every 1,440 Operating Hours, or Annually
Compliance Date: October 19, 2013

34. RICE MACT Compliance Requirements Existing Non-Emergency 4SLB Engines > 500 HP
Initial Notification Was Due on February 16, 2011
Install Oxidation Catalyst by October 19, 2013
Conduct Initial Compliance Demonstration by April 18, 2014
Must Demonstrate:
Average CO Emission Reduction > 93%, or
Average CO Concentration < 47 ppmvd at 15% O2
Submit Notification of Intent at Least 60 Days Prior to Test
Submit Notification of Compliance Status Within 60 Days After Initial Compliance Demonstration
Subsequent Annual Compliance Demonstrations

35. RICE MACT Compliance Requirements Existing Non-Emergency 4SLB Engines > 500 HP (continued)
Install CPMS for Catalyst Inlet Temperature or Automatic Shutdown Device if Catalyst Inlet Temperature > 1,350˚F (by October 19, 2013)
If CPMS, Maintain 4-hour Rolling Average Inlet Temperature Between 450 ˚F and 1,350˚F
Submit Semi-Annual Compliance Reports

36. Same Requirements as for 4SLB > 500 HP, Except:
RICE MACT Compliance Requirements Existing Non-Emergency 4SRB Engines > 500 HP
Same Requirements as for 4SLB > 500 HP, Except:
Must Install NSCR (3-Way Catalyst) by October 19, 2013
Must Demonstrate:
Average CO Emission Reduction > 75%, or
Average CO Concentration < 270 ppmvd at 15% O2, or
Average THC Emission Reduction > 30%
Install CPMS for Catalyst Inlet Temperature or Automatic Shutdown Device if Catalyst Inlet Temperature > 1,250˚F
If CPMS, Maintain 4-Hour Rolling Average Inlet Temperature Between 750˚F and 1,250˚F

37. RICE MACT Applicability to “New” Cogeneration or Chiller Engines
“New” if Construction Commenced On or After 6/12/2006
Instead Comply with NSPS – 40 CFR 60, Subpart JJJJ
Purchase a Certified Engine (if you can)
Non-Certified Engines
Requirements Depend on Size, Type, and Manufacture Date
Emission Limits (NOx, CO, VOC)
Initial and Subsequent Performance Tests
Notifications, Recordkeeping, and Reporting

38. Helpful Web Sites for RICE MACT
General Information and Compliance Tools EPA Region I – New England EPA Technology Transfer Network

39. Questions ???

40. Compliance with New Air Pollution Regulations for Boilers and Emergency Generators – The Basics of What Every Facilities Manager Should Know NEHES Fall Conference October 1, 2013
Contact: Rick Soucy
GZA GeoEnvironmental, Inc.
655 Winding Brook Drive, Suite 402
Glastonbury, CT 06033
Phone: (860)
Fax: (860)