Boiler GACT Update Georgia AWMA Conference

1. Boiler GACT UpdateGeorgia AWMA Conference October 2013

2. Agenda - NESHAP Anatomy Boiler MACT and GACT Structure Very Similar - More/Different Requirements for Major Sources

3. The “Final” Combustion Source Rules • Promulgated again by US EPA on January 31 and February 1, 2013 • 40 CFR 63 Subpart DDDDD – Major Source Boiler MACT • 40 CFR 63 Subpart JJJJJJ – Area Source Boiler GACT • 40 CFR 60 Commercial and Industrial Solid Waste Incineration (CISWI) Rule • 40 CFR 241 Non-Hazardous Secondary Materials (NHSM) Solid Waste Identification Rule • To gather data, assess applicability, determine emission limits, review compliance status/options, and implement compliance strategy • Includes four (4) Interrelated Rules • Detailed Site-specific Action Plan Needed

4. The Solution is a Process Issue… Point of Compliance Fuel Spec Supply Longevity Cost Fan Modification Combustion Mod Operating Flexibility Retrofit Addition Permitting Compliance Testing Cost Each part of the process may be part of the answer!

5. Boiler Area Source GACT Rule (Boiler GACT) • GACT = Generally Available Control Technology • Applicability- Applies to boilers that: • Burn a “fuel” material, not a “waste” as defined by US EPA (“Fuel” = coal, oil, gas, biomass, tire-derived fuel, others) • Located at an industrial, institutional, commercial facility that is an “areasource” (any source not major) of Hazardous Air Pollutants (HAP)* • Does not include process heaters *Note: A facility is an Area Source of HAP emissions if it emits less than 10 TPY of any single regulated HAP, and less than 25 TPY of any combination of HAP’s

6. Boiler GACT Applicability • Applies to HAP Area Sources • “Natural Gas” Boilers are Exempt • Existing Sources (Commenced Construction Prior to 6/4/10) • Emission Limits Set Only for Coal Boilers • Fuel Oil and Biomass Units Only Subject to Work Practice Standards • Fuel Switching After 6/4/10 May No Longer Trigger New Source Status • Initial Compliance Date 3/21/14 for existing sources

7. Natural Gas Curtailment • Period of gas curtailment or supplyinterruption means a period of time during which the supply of gaseous fuel to an effected boiler is restricted or halted for reasons beyond the control of the facility. • The act of entering into a contractual agreement with a supplier of natural gas established for curtailment purposes does not constitute a reason that is under the control of a facility for the purposes of this definition. • An increase in the cost or unit price of natural gas due to normal market fluctuations not during periods of supplier delivery restriction does not constitute a period of natural gas curtailment or supply interruption. • On-site gaseous fuel system emergencies or equipment failures qualify as periods of supply interruption when the emergency of failure is beyond the control of the facility.

8. Fuel Switching Improvement 63.11194(e) - An existing dual-fuel fired boiler meeting the definition of gas-fired boiler, as defined in § 6.11237, that meets the applicability requirements of this subpart after June 4, 2010 due to a fuel switch from gaseous fuel to solid fossil fuel, biomass, or liquid fuel is considered to be an existing source under this subpart as long as the boiler was designed to accommodate the alternate fuel.

9. Significant Improvements/Changes • Many Emissions Limits are Now Higher • Initial Tune-Up Deadline Delayed to 3/21/14 • Tune-Ups Conducted Using Primary Fuel Over the Prior 12 Months • Natural Gas Curtailment Now Includes On-Site Fuel System Failures • Temporary, Seasonal and Limited Use Boiler Relaxation • CO Emission Limit and Potential CEMS for Oil Sources Removed • New Oil Sources Burning < 0.5 % SulfurAre Exempt from PM Limit • Start-Up & Shutdown Definitions Changed and 25% “Bright Line” Removed • Potential Hg Fuel Analysis Relaxation

10. Initial and Continuous Compliance

11. Boiler GACT Compliance • Existing Source Initial Compliance Deadline 3/21/14 • Initial Tune-Up and One Time Energy Assessment • Stack Testing for Applicable Boilers Due by 9/17/14 • Notification of Compliance Status Report(s) (7/19/14 and/or 11/17/14) • Ongoing Compliance Assurance – Testing, Monitoring, Recordkeeping and Reporting • SSM Requirements ???

12. Existing Coal Boilers • Subject to Mercury (Hg) and CO Emission Limits • Hg Compliance Based as Fuel Analysis or Stack Testing • CO Compliance Typically Based Only on Stack Testing • Stack Testing Includes: • Both Initial and Ongoing Testing • Test Plan Approval by GA EPD • Monitoring and Establishing Hg, CO and Capacity Operating Limits • Developing/ Implementing a Site Specific Monitoring Plan • Conduct Initial and Periodic Continuous Parameter Monitoring System Performance Evaluations – May Need a RATA!? • Need to Run at Maximum Capacity – 110% Operating Limit • Report Results Via New US EPA WebFire Database

13. One-time Energy Assessment (EA) • Required for All Existing Affected Boilers > 10 MM Btu Except Limited Use • Higher Fuel Efficiency means Reduced Air Pollutants Emitted to the Atmosphere • EA to Identify and Evaluate Cost Effective Energy Conservation Measures – Not a Regulatory “Deliverable” • EA will cover the Boilers and the Energy Use Systemwithin the Sources’ property(compressed air, machine drive, process cooling, hot water, HVAC, building envelope) • Requires an evaluation of the facilities “energy management practices” and required EA Duration is dependent on total heat input capacity • EA to follow prescribed procedures and assessor qualifications relaxed, and existing assessments can now be amended as needed to comply.

14. Permitting Considerations • Will Generic Placeholder Conditions Suffice? • Trade-off of Generic vs. Specific Conditions Approach • Typical Issues With Agencies: • Approval of Alternative Operating Limits • Approval of Multiple Compliance Options • Testing of Worst Case Fuel for Each Pollutant • Title V Versus GACT Inconsistencies • Verify if Site Specific Monitoring Plan Needs to be Submitted • Need for Multiple NOCSR Submittals • Does Annual Compliance Report Need Submittal

15. Permitting Considerations (continued) • What Permit Applications are Needed and When? • < 10/25 TPY HAP Emission Limits • New/Modified Emission Control Device Construction, Operation, and/or Operating Limits • New Boiler(s) and/or Fuel Switching • Compliance Option Definition • Need to Ensure Compliance Plan is Enforceable! • Solid Fuel Variability is a Challenge/Risk for Both Area Source Status and Boiler GACT Compliance • Request to See a “Pre-Public” Draft Amendment • Other Potential Implications– NSR, NAAQS, NSPS, GHG, etc.

16. Case Study Example • Major HAP Source With One Large Coal Boiler, Four Natural Gas Boilers and Very Low Process HAP’s • Looking at Area Source HAP Status Via Limiting Boiler HCl Emissions • Lime Injection Into Baghouse or Add-On Wet Scrubber • Potential Fuel Switching From Coal • Addition of Fuel Oil to Manage Natural Gas “Risk” • Conducting Stack Testing and Fuel Analysis • Completing “What If” Emission Testing • Setup Ongoing Hg Fuel Analysis • Evaluating Hg and/or CO Compliance Options • Fuel Vendor Contract Limits and Operating Restriction/Controls • Trade off of CO Management Versus NOx Permit Limits • Development of Long Term Compliance Strategy and Schedule • Operating Costs, Impacts and Uncertainties • Build Results Into Site Budgeting Cycle • Ongoing GA EPD discussions/negotiations

17. Boiler MACT Planning TimelineBased on January, 2016 Initial Compliance Date

18. What’s Next for You?

19. Questions?

20. Contact Information ERM 3200 Windy Hill Road SE Suite 1500W Atlanta, GA 30339 678.486.2700 David Dunn david.dunn@erm.com