www.all4inc.comKimberton, PA | 610.933.5246Kennesaw, GA | 678.460.0324
Boiler MACT and Strategic Air Permitting
Mark Wenclawiak | [email protected] | 678-460-0324July 10, 2013
Presented to A&WMA Southern Section Annual Meeting and Technical Conference by All4 Inc.
2 Your environmental compliance is clearly our business.
Drivers and tools• Boiler MACT• NSR Reform rules• Improve operational flexibility while decreasing actual
emissions• Reduce operating and compliance costs• Timing: Outages? Agency processing? Procurement?
Case study• Existing Kraft mill – increase pulp production, BLS rate• Boiler conversion – multi-fuel to gas, limited coal • PSD avoidance; reduced Boiler MACT obligations
Outline
Boiler MACT and Strategic Air Permitting
Drivers and Tools
4 Your environmental compliance is clearly our business.
Typical Boiler MACT project begins with:• Establishing your subcategory (initial notification)• Fuels combusted and design type • Design heat input capacity• Annual heat input basis 12-months prior to compliance event
Identify applicable emission limits• Install APC; TSM option; output based standards• Engineering testing for compliance strategy
Derating < 10 MMBtu/hr or retiring units Change fuel mix or introduce new fuels (e.g., TDF)
• Our project: Accept limitation on fuel usage to switch subcategory, and generate actual emission decreases
Drivers and Tools – Boiler MACT
5 Your environmental compliance is clearly our business.
NSR reform allows creative accounting, particularly for existing emission units• Identify modified and affected units
Projects with boilers: Boilers; Woodyard; Fuel handling equipment
Debottlenecking….More steam = more production? Baseline actual to projected actual test
• Testing: Opportunity to re-establish baselines based on engineering testing for Boiler MACT compliance or other updated data
• Historical factors < testing results = good thing
Drivers and Tools – NSR Reform
6 Your environmental compliance is clearly our business.
If production increase project exceeds PSD significance, Boiler MACT project can provide contemporaneous decreases to net out of PSD (case study)
Projected actual emissions• Consider multiple scenarios to maximum flexibility
Changes to types and rates of fuels and/or production materials• Excludable emissions – historical peak monthly levels during
baseline• Remember timing: consider outage schedules, permit
preparation and processing time, capital procurement process New units more limited: based on potential to emit (PTE)
• Consider air pollution control devices and fuel or production limitations to reduce PTE
Drivers and Tools – NSR Reform
7 Your environmental compliance is clearly our business.
Boiler MACT projects & contemporaneous decreases• Retired (past) units• Shutdown currently permitted units• Limited use units (e.g., change to a backup boiler)• Be careful with contemporaneous PSD avoidance projects!
Actual reductions to comply with MACT considered surplus for NSR netting and can be used (U.S. EPA memo)
Source obligation tracking Are additional regulations triggered (e.g., NSPS)? Don’t forget about NAAQS considerations
Drivers and Tools – NSR Reform
Boiler MACT and Strategic Air Permitting
Case Study
9 Your environmental compliance is clearly our business.
Existing unbleached Kraft pulp mill• Project to increase pulp production and BLS firing rate
Existing recovery furnace physically modified Affected sources: Recovery Area; Pulping System; Washing;
Paper Machines; Woodyard Causticizing & kiln unaffected due to historical operations Baseline actual to projected actual emissions
• Convert combination boiler to natural gas power boiler Consider various scenarios of coal firing for backup fuel Annual capacity factor limitation Key to viability: contemporaneous decrease
Case Study
10 Your environmental compliance is clearly our business.
Current combination boiler• Coal, wood, natural gas, fuel oil• Existing source with respect to Boiler MACT
Coal/solid fossil fuel, stoker subcategories Natural gas conversion project
• Natural gas and coal only Coal limited to annual capacity factor <10%
• Reclassified as Gas 2 (other) unit subcategory Comparison of Boiler MACT emission limits
Case Study
11 Your environmental compliance is clearly our business.
Boiler MACT emission limits comparison
Testing for HCl, Hg, PM (coal); CO (gas) Fuel sampling limited to 100% coal firing scenario
Case Study
Pollutant Coal Subcategory Gas 2 Subcategory
HCl 2.2E-02 lb/MMBtu 1.7E-03 lb/MMBtu
Hg 5.7E-06 lb/MMBtu 7.9E-06 lb/MMBtu
PM 4.0E-02 lb/MMBtu 6.7E-03 lb/MMBtu
CO 160 ppmvd @ 3% O2 130 ppmvd @ 3% O2
12 Your environmental compliance is clearly our business.
Existing emission units so….baseline actual emissions• NSR Reform
Consecutive 24-month period in 10-year look back Average annual rate for the 24-month period Influenced by use of non-natural gas fuels
Projected actual emissions• Based on reduced coal usage and elimination of fuel oil and
wood waste in boiler• Mill production levels based on maximum BLS firing with the
maximum amount of natural gas firing• Maintain some backup fuel capacity with coal• Excludable emissions not considered to conservatively estimate
projected actual emissions
Case Study
13 Your environmental compliance is clearly our business.
Project related increases significant for VOC, NOX, PM, PM10, and PM2.5
Netting of contemporaneous projects• Decreases consisted of reductions attributable to
boiler coal limitation• Decreases for all pollutants except VOC after netting
(though VOC net increase not significant)• PSD avoided
Case Study
Boiler MACT and Strategic Air Permitting
Conclusions
15 Your environmental compliance is clearly our business.
Increase in production achieved• ~15% increase in BLS firing rate over current limit• ~25% increase in pulp production over current limit
PSD avoidance Simpler Boiler MACT obligations
• No need for add-on control• Less complicated testing and fuel sampling
requirements
Conclusions
www.all4inc.comKimberton, PA | 610.933.5246Kennesaw, GA | 678.460.0324
Questions and Open Discussions
Mark Wenclawiak, CCM | [email protected] | 678-460-0324