Part 63 Boiler Rule for Area Sources

1. Part 63 Boiler Rule for Area Sources AWMA Conference September 11-14, 2012 Biloxi, MS Lee Page Air Toxics Assessment and Implementation Section U.S. Environmental Protection Agency Atlanta, Georgia

2. Topics to Cover • Rule Development • Promulgated Requirements • Amended Requirements • Outreach/Delegations • Guidance • Fuel Switching Example • Questions

3. Boiler Rule Development • March 21, 2011 - EPA promulgates final boiler rules for major and area sources • Subpart 5D for major sources • Subpart 6J for area sources • May 18, 2011 – EPA delays effective date of major source due to reconsideration • Effective date of the area source rule not delayed • December 23, 2011 - EPA issued proposed rule amendments for major source boilers and specific aspectsof area sources (will reset compliancedate for major sources). • January 9, 2012 - U.S. District Court for the DC Circuit vacated EPA's May 18, 2011, delay of effective datefor major sources • Rule amendments expected to be finalized by ______??_______ • EPA issues No Action Assurance Letters (NAAs) • EPA will exercise its enforcement discretion to not pursue enforcement action for violations of certain notification deadlines in the final Major Source Boiler rule (NAA dated 2/7/12) or final Area Source Boiler Rule (NAA dated 3/13/12 then extended until 12/31/12)

4. Primary Changes in Amendment • Revised standards based on generally available control technology • Greater flexibility to certain facilities in meeting requirements • Clarify certain requirements • Correct printing errors

5. 6J Boiler Requirements – As Promulgated Emission Limits (Triennial Performance Tests)

6. 6J Boiler Requirements – As Amended Emission Limits (Triennial Performance Test)

7. 6J Boiler Requirements – As Promulgated One-Time Energy Assessment

8. 6J Boiler Requirements – As Amended One-Time Energy Assessment

9. 6J Boiler Requirements – As Promulgated Biennial Tune-Ups

10. 6J Boiler Requirements – As Amended Biennial Tune-Ups ( * Every 5 Years)

11. EPA Outreach • R4 Initial Notification Database • Emails to various potentially affected sources • Staff led discussions at focus groups • National seminars & webinars • Rule Delegation • 8 States, 10 local agencies • EPA Regional Office Implementation • www.epa.gov/region4/air/airtoxic • Click on “Air Toxics Delegation”

12. Area Source Delegations

13. Boiler Rule Guidance • Web site: www.epa.gov/boilercompliance • Proposed and final rules • Example Initial Notification forms • Example Notification of Compliance Status forms • Rule brochures • Guidance on tune-ups • Common questions • Rule overview presentations • Small Entity Compliance Guidance • EPA Region 4 Activities • Quick reference tables • Timeline for required submittals • Issue resolutions (dual fired - fuel switching)

14. Dual Fired vs Fuel Switching • Dual fired boilers (gas/oil) account for a large portion of the area source boiler universe • 6J exempts gas units that only burn oil during: • Periods of gas curtailment • Gas supply emergencies • Periodic testing of liquid fuel • If oil is burned outside of exempted limits, these boilers will be considered new boilers in the oil subcategory (i.e., fuel switching) • Boilers could be subject to stringent emission limits • Must comply immediately

15. Fuel Switching • For flexibility, dual fired boilers may want to submit initial notification as an existing boiler in the oil subcategory • Existing oil fired boilers are not subject to emission limits/performance tests • Subject to a one-time energy assessment if boiler heat capacity is >10 MM Btu/hr • Will be subject to tune-up requirements • Example:

16. Dual Fired (Gas/Oil) Boilers • Hypothetical Area Source Operates the Following Boilers:(All 3 boilers burn primarily natural gas) #1 Existing Unit > 10 mm Btu/hr Nat. Gas/Oil#2 Existing Unit < 10 mm Btu/hr Nat. Gas/Oil#3 New Unit < 10 mm Btu/hr Nat. Gas/Oil • Options for Initial Notifications:Option A: Not subject due to special oil exemptions (gas curtailment, supply emergencies, testing)

17. Dual Fired Boilers • Option B: For flexibility, classify all 3 as oil units * Continue to burn natural gas in boilers * No applicable emission limits (only if new >10 mm) * Biennial tune-ups for all 3 boilers * One-time energy assessment for boiler #1 * Comply as required in 63.11196

18. Dual Fired Boilers • Option C: Only Classify Boiler #1 as existing Oil Unit; Boilers 2 & 3 remain as gas fired units * Boilers 2 & 3 are exempted from regulation * No applicable emission limits for Boiler #1 * Biennial tune-ups for Boiler #1 * One-time energy assessment for boiler #1 * Comply as required in 63.11196

19. Fuel Switching Example • Costs of fuels change - oil now cheaper than gas • Hypothetical source now thinks about switching fuel to reduce overhead • 63.11194(d): Boiler is a new affected source if you switch fuels from gas to oil

20. Results From Fuel Switching • Option A: All 3 Boilers are Gas Fired (Exempted) * All 3 boilers now considered new oil fired units * Boiler #1 (>10MM Btu) has to meet emission limits * Initial and triennial performance tests for boiler #1 * Biennial tune-ups for all 3 boilers * No one-time energy assessment required

21. Results From Fuel Switching • Option B: Boilers 1 & 2 are classified as existing oil fired Boiler 3 classified as new oil fired * No changes (continue with biennial tune-ups) * One time energy assessment already completed • Option C: Boiler #1 classified as existing oil fired; Boilers 2 & 3 exempted due to gas * Boilers 2 & 3 are now classified as new oil units * Biennial tune-ups for boilers 2 & 3 * No changes for boiler 1 (continue with tune-ups)

22. Message Area sources with dual-fired boilers should evaluate the impact of switching fuel now in order to potentially avoid issues related to implementing different rule requirements in the future.

23. Questions? www.epa.gov/ttn/atw www.epa.gov/boilercompliance www.epa.gov/region4/air/airtoxic Lee Page U.S. EPA; Atlanta, GA 404-562-9131