Rick SoucyGZA GeoEnvironmental, Inc.

Compliance with New Air Pollution Regulations for Boilers and Emergency Generators -

The Basics of What Every Facilities Manager Should Know

NEHES Fall ConferenceOctober 1, 2013

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

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

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

HAPs and MACT Standards

187 HAPs Currently Regulated MACT Standards for 133 Source Categories to Date

Today’s Focus:

1. Area Source Boiler MACT Rule - 40 CFR Part 63, Subpart JJJJJJ (“6J”)

2. Stationary RICE (Reciprocating Internal Combustion Engine) MACT Rule - 40 CFR Part 63, Subpart ZZZZ (“4Z”)

ClarificationArea 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

Area Source Boiler MACT40 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

Area Source Boiler MACT40 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

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.

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

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

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 to10 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• One-time energy assessment• No numeric emission limits

Limited-use Coal

• Initial tune-up• Subsequent tune-ups every 5

years• No energy assessment• No numeric emission limits

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

Gas (all types) • No requirements (not covered by the rule)

Coal, Biomass or Oil

• Initial tune-up• Subsequent tune-ups every

other year or every 5 years• No numeric emission limits

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

• Tune-up every 5 years• No numeric emission limits

New small area source boilers

i.e., commenced construction or reconstruction of the boiler after June 4, 2010; less than 10 MMBtu/hr

Gas (all types) • No requirements (not covered by the rule)

Coal, Biomass or Oil

• Tune-up every other year or every 5 years

• No numeric emission limits

*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.

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

Boiler MACT Energy Assessment Requirements

Must Be Performed By a Qualified Energy Assessor Assessment Must Include:

1. Visual Inspection of Boiler System

2. Evaluation of Operating Characteristics and Specifications of the Boiler System

3. Inventory of Major Energy Use Systems Consuming Energy from the Boiler

4. Review of Architectural/Engineering Plans, Operations and Maintenance Procedures/Logs, and Fuel Usage

5. List of Major Energy Conservation Measures Within the Facility’s Control

6. List of the Energy Savings Potential of Energy Conservation Measures

7. Comprehensive Report Detailing Ways to Improve Efficiency, Cost of Specific Improvements, and Payback Periods

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 50001 That Includes the Affected Boiler

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

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.

Helpful Web Sites for Boiler MACT

EPA Region 1 List of Qualified Energy Assessorshttp://www.epa.gov/boilercompliance/whereyoulive.html#region1

General Information and Compliance Tools

http://www.epa.gov/boilercompliance/

http://www.epa.gov/airtoxics/boiler/boilerpg.html

RICE MACT40 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

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

RICE MACTApplicability 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

RICE MACT Compliance Requirements for Emergency Engines

GOOD NEWS !!

Existing Institutional Emergency Engines are Exempt

BUT…

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

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

RICE MACT – Emergency Engines

What if Your Emergency RICE Operates or is Contractually Obligated >15 hr/yr for Emergency Demand Response?

1. ULS Fuel (<15 ppm) by January 1, 2015

2. Operate/Maintain Engine According to Manufacturer’s Instructions

3. 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

RICE MACT – Emergency Engines

What if Your Emergency RICE Operates or is Contractually Obligated >15 hr/yr for Emergency Demand Response?

4. 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

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

RICE MACTApplicability 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

RICE MACTCompliance Requirements for Existing

Non-Emergency Engines Gas-Fired Chiller Engines Gas-Fired Cogeneration Engines

Five Gas-Fired Engine Categories

1. 2SLB

2. 4SLB < 500 HP

3. 4SRB < 500 HP

4. 4SLB > 500 HP

5. 4SRB > 500 HP

RICE MACT Compliance RequirementsExisting 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

RICE MACT Compliance RequirementsExisting 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

RICE MACT Compliance RequirementsExisting 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

RICE MACT Compliance RequirementsExisting 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:

1. Average CO Emission Reduction > 93%, or

2. 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

RICE MACT Compliance RequirementsExisting 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

RICE MACT Compliance RequirementsExisting 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:

1. Average CO Emission Reduction > 75%, or

2. Average CO Concentration < 270 ppmvd at 15% O2, or

3. 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

RICE MACTApplicability 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

Helpful Web Sites for RICE MACT

General Information and Compliance Tools

EPA Region I – New England

http://www.epa.gov/region1/rice/

EPA Technology Transfer Network

http://www.epa.gov/ttn/atw/icengines/

Questions???

Compliance with New Air Pollution Regulations for Boilers and Emergency Generators –

The Basics of What Every Facilities Manager Should Know

NEHES Fall ConferenceOctober 1, 2013

Contact: Rick SoucyGZA GeoEnvironmental, Inc.655 Winding Brook Drive, Suite 402Glastonbury, CT 06033Phone: (860) 858-3163Fax: (860) 652-8590rick.soucy@gza.comwww.gza.com