EnviroExpo MACT Standards

1
EnviroExpo MACT Standards

• Summary of Proposed MACT Standards for Combustion
  Sources
• Presented at EnviroExpo 2003
• May 6, 2003
• Dale T. Raczynski, P.E.
• Principal
• Epsilon Associates, Inc.

2
Overview

• Three proposed MACT standards for Combustion
  Source Categories
• Industrial/Commercial/Institutional Boilers and
  Process Heaters
• Reciprocating Internal Combustion Engines
• Stationary Combustion Turbines
• Applicability/Compliance Dates
• Emission and Operating Limitations
• Monitoring, Recordkeeping, Reporting

3
General Applicability

• Combustion unit(s) at a site that is a major
  source of HAPs
• Major Emits or has potential to emit any single
  HAP at a rate of 10 tpy any combination of HAPs
  at a rate of 25 tpy.
• Combustion unit(s) themselves do not have to be
  major for MACT to apply, just the site.
• Applies to relatively small combustion sources.

4
Industrial/Commercial/Institutional Boilers and
Process Heaters

• Proposed Rule in Federal Register on January 13,
  2003 Subpart DDDD.
• Boiler Enclosed device using controlled flame
  combustion primary purpose of recovering
  thermal energy in the form of steam or hot water.
  Does not include waste heat boilers or hot water
  heaters.
• Process Heater Enclosed device using controlled
  flame combustion primary purpose of
  transferring heat indirectly to process streams
  (liquids, solids, gases).
• Excludes Municipal Waste Combustors Hospital
  Waste Incinerator Electric Utility Steam
  Generating Units (gt25 MW) Hazardous Waste
  Combustors, others (see definitions).
• Fuels Solid coal, wood, biomass, tires,
  plastic Liquid distillate oil, residual oil,
  waste oil, and process liquids Gaseous natural
  gas, process gas, refinery gas and biogas.

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Applicability

• No general size limit applicability different
  limits for large, small and limited use (lt10
  annual capacity factor federally enforceable).
  58,000 existing, 800 new per year (80-85 gas).
• New affected sources must comply by the date of
  publish of final rule or upon startup (whichever
  is later).
• Existing (commenced construction prior to
  1/13/03) affected sources comply no later than 3
  yrs after date of publish of final rule.
• Pollutants limited Particulate Matter (PM,)
  Hydrogen Chloride (HCl), Total Selected Metals,
  Mercury (Hg) and Carbon Monoxide (CO) surrogate
  for organic HAPs.
• Total Selected Metals is the combination of
  arsenic, beryllium, cadmium, chromium, lead,
  manganese, nickel and selenium.

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Emission Limits for Boilers and Process Heaters
(lb/MMBTU) Summary of Table 1 of DDDD
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Operating Limits

• Flexibility to meet limits with add-on control or
  limit levels of metals and chlorine in fuels.
• Appears to require wet or dry scrubber for HCl
  control on liquid fuels (costly for gas/oil fired
  units) unless chlorine level in fuel very low.
• Lengthy tables of Operating Limits some
  examples (from Table 2.A)
• For all large, limited use or small solid fuel
  units controlled with add-on control other than a
  wet or dry scrubber maintain opacity lt level
  established during performance test that
  demonstrated PM, metals and mercury limits, and
  maintain fuel chlorine level that demonstrated
  compliance with HCl limit.

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Operating Limits/Work Practice Standards

• Same category with wet scrubber maintain
  minimum pH, pressure drop and liquid flow rate at
  or above levels established during performance
  test that demonstrated PM, metals, mercury and
  HCl limits.
• Same category that is complying with alternative
  total selected metals emission limit instead of
  particulate emission limit maintain the fuel
  total selected metals, chlorine and mercury
  content to the level demonstrated in compliance
  test.
• Work practice standard for units with CO limit,
  continuously monitor CO emissions to maintain CO
  lt400 ppmvd, 3 O2, 1 calendar day avg.

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Performance Tests

• Initial and annual stack tests
• If controlling PM, measure PM by EPA Method 5 or
  17
• If complying with alternative total selected
  metals instead of PM, measure metals using EPA
  Method 29
• If need to measure opacity, establish a maximum
  opacity level(must not exceed 20)
• If not scrubbing, set an operating limit for HCl
  based on chlorine fuel input established during
  initial performance test
• Set an operating limit for Hg

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Monitoring/Recordkeeping

• Continuous Opacity Monitoring
• Daily records of fuel use and that the fuel is
  from the same supplier as the initial performance
  test if not, and new fuel has higher chlorine
  or metals, need to conduct new performance test
• Continuous CO monitoring
• Submit Compliance Reports semiannually
• Startup, shutdown and malfunction plan deviations
  by fax within two days

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Reciprocating Internal Combustion Engines (RICE)
-Applicability

• Proposed Rule in Federal Register on December 19,
  2002 Subpart ZZZZ.
• Stationary RICE only. Excludes (except initial
  notification)
• Emergency Power/Limited Use backup power source
  or less than 50 hours per year in non-emergency
  use
• RICE combusting digester or landfill gas as
  primary fuel.
• Excludes completely Existing spark ignition 2
  or 4 stroke lean burn (2/4SLB) or compression
  ignition (CI) RICE or the RICE has a
  manufacturers nameplate rating of less than 500
  brake horsepower.

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Applicability/Compliance Dates

• EPA estimates 1800 existing, 1600 new per year
  affected units
• New affected sources must comply by the date of
  publish of final rule or upon startup (whichever
  is later).
• Existing (commenced construction prior to
  12/19/02) affected sources comply no later than 3
  yrs after date of publish of final rule.
• Pollutants limited Formaldehyde and Carbon
  Monoxide (CO) surrogate for organic HAPs.

13
Emission Limits for RICE Summary of Tables 1 and
2A of ZZZZ

• Existing and New Spark Ignition 4 Stroke Rich
  Burn (4SRB) Reduce formaldehyde emissions by 75
  or more using Non-Selective Catalytic Reduction
  (NSCR) or Limit concentration of formaldehyde in
  exhaust to 350 ppbvd at 15 O2.
• New 2SLB Reduce CO emissions by 60 or more
  with an oxidation catalyst or limit formaldehyde
  concentration to 17 ppmvd at 15 O2
• New 4SLB Reduce CO by 93 or more with
  oxidation catalyst or limit formaldehyde to 14
  ppmvd
• New CI Reduce CO by 70 or more with oxidation
  catalyst or limit formaldehyde to 580 ppvd

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Operating Limitations

• Tables 1B and 2B of ZZZZ examples
• 4SRB requirement of 75 reduction with NSCR
  a) maintain catalyst so that pressure drop across
  catalyst does not change gt 2 inches water from
  that during initial compliance test b) maintain
  catalyst so the temp rise across catalyst is no
  more than 5 different from that during initial
  test c) maintain temp fo exhaust so the catalyst
  inlet temp is gt750 F, lt1250 F
• 4SRB limit formaldehyde to 350 ppbvd a)
  maintain operating load gt 95 of that established
  in compliance test, b) maintain fuel flow rate
  gt95 test comply with any additional operating
  limitations approved by Administrator

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Performance Tests

• Initial Compliance -2SLB, 4SLB and CI with
  BHPlt5000 HP using oxidation catalyst measure
  avg reduction of CO, install a continuous
  parametric monitoring system (CPMS) for pressure
  drop and inlet temp record parameters during
  test
• Same units gt5000 HP Install a CEMs to monitor
  CO and CO2 or O2 at inlet and outlet.
• 4SRB using NSCR measure formaldehyde reduction,
  install CPMS for pressure drop and catalyst rise
• Any category limiting concentration of
  formaldehyde measure average formaldehyde
  reduction, install CPMS for operating load

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Monitoring/Recordkeeping

• lt5000 HP using oxidation catalyst quarterly
  performance tests and CPMS (4-hr rolling avg).
• gt5000 HP using oxidation catalyst use CEMs to
  show required reduction and annual RATA
• 4SRB using NSCR CPMS and semiannual performance
  test if gt5000 HP
• Any category reducing formaldehyde semiannual
  performance test, CPMS for operating load data
• Semiannual compliance reports
• Startup, shutdown and malfunction plan deviations
  by fax within two days

17
Stationary Combustion Turbines

• Proposed Rule in Federal Register on January 14,
  2003 Subpart YYYY.
• Excludes
• Turbines lt1.0 MW power output
• Emergency or Limited Use (lt50 hr/yr)
• Landfill or digester gas
• Existing Diffusion Flame Turbines

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Applicability/Compliance Dates

• EPA estimates 150 existing, 30 new per year
  affected units
• New affected sources must comply by the date of
  publish of final rule or upon startup (whichever
  is later).
• Existing (commenced construction prior to
  1/14/03) affected sources comply no later than 3
  yrs after date of publish of final rule.
• Pollutants limited Formaldehyde or Carbon
  Monoxide (CO) surrogate for Formaldehyde and
  other HAPs.

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Emission Limits/Compliance

• Reduce CO by at least 95 using an oxidation
  catalyst or limit concentration of formaldehyde
  in exhaust to 43 ppbv_at_ 15 O2
• If reducing CO, initial tests at inlet and outlet
  of catalyst and CEMs
• If not using oxidation catalyst for formaldehyde
  reduction, measure during initial test and
  continue to meet NOx limits and manufacturers
  guarantees

20
Questions/Contact

• Dale T. Raczynski, P.E.
• Principal
• Epsilon Associates, Inc.
• 150 Main StreetMaynard, MA 01754
• 978-461-6222
• draczyns_at_epsilonassociates.com
• www.epsilonassociates.com