Boiler Sheltered Initiative

1. Boiler Sheltered Initiative Web cast May 15, 2008 May 29, 2008

2. Introduction and Logistics • Presenters • Barb Johnson and Ryan Hamel – K-State SBEAP • Webcast logistics • You will not be able to speak during the seminar • Ask questions/comments by typing them into the long text box at the bottom of the screen and pressing enter. • Slides will advance automatically. • Questions? Call the help-desk at 785-532-7722

3. Overview • Clarify EPA vs KDHE vs OSHA vs KDOL • Small Business Environmental Assistance Program (SBEAP) • Types of Kansas air regulations • KDHE boiler sheltered initiative • Emergency generator • Future additions or modifications

4. Regulatory Agencies • EPA – federal • KDHE - state • Bureau of Air & Radiation • Air emissions • OSHA - federal • KDOL - state • Industrial Safety & Health Section • Boiler Safety Inspection Unit • Local ordinances

5. Small Business Environmental Assistance Program • Similar program in every state-Clean Air Act req’d • Provides air and haz waste-focused technical assistance to Kansas small- and medium-sized businesses/institutions • Permitting and reporting requirements • Regulatory compliance • Emissions/waste reduction

6. Where SBEAP fits… Kansas State University Engineering Extension Pollution Prevention Institute (PPI) Small Business Environmental Assistance Program (SBEAP)

7. Air Regulations

8. Types ofAir Regulations • KAR • Air construction approval/permit • Operating permit • NSPS (New Source Performance Standards) adopted by reference • PSD (Prevention of Significant Deterioration) • NESHAP (National Emission Standard for Hazardous Air Pollutants) / MACT (Maximum Achievable Control Technology) adopted by reference

9. Potential to Emit (PTE) • Basis for determining permitting requirements • Represents the source’s maximum capacity or worst case scenario emissions • The maximum amount of air pollution your facility can emit if: • Each process operated at 100% of its capacity • All equipment is operating 24/7 (8,760 hrs/yr) • Materials that emit the most air pollution are processed 100% of the time • No pollution control equipment is used

10. CalculatingPTE Calculation methods • Emission factors • Material balances • Other approved methods • Computer programs • Industry-specific emission factors • Approved by KDHE on an individual basis

11. PTE Emission factors are used for calculating boiler emissions • Manufacturer’s emission factors are best • AP-42 is a compilation of factors for specific processes accepted by EPA • www.epa.gov/ttn/chief/ap42/index.html • Emission factors software and tools • www.epa.gov/ttn/chief/efpac/efsoftware.html

12. ExpeditedApproval If your PTE exceeds these thresholds, then you’ll need an expedited approval: Source: What is the Kansas Air Quality Act? - www.sbeap.org/publications/airqual.pdf

13. Expedited Permit If your PTE exceeds these thresholds, then you’ll need an expedited permit: Source: What is the Kansas Air Quality Act? - www.sbeap.org/publications/airqual.pdf

14. Operating Permit (Class I) • Count PTE of all emission sources • Required if PTE exceeds these thresholds: • 100 tons per year NOX, SOX, PM10, VOC, CO • 10 tons per year of any single hazardous air pollutant (HAP) • 25 tons per year of combined HAPs

15. Operating Permit (Class II) • An option when actual emissions are below Class I thresholds but PTE is above • Advantages • minimal record keeping • simpler • cheaper

16. Small Boiler NSPS • NSPS = New Source Performance Standards • 40 CFR 60.42 subpart Dc • Installed or modified after June 9, 1989 • Heat input capacity is between 10 and 100 MMBTU/hr

17. KDHE Boiler “Sheltered” Initiative

18. KDHE Boiler “Sheltered” Initiative Applies to companies or institutions that have boiler(s) with heat input capacity between 10 and 100 MMBtu/hr and installed after June 9, 1989

19. KDHE Boiler “Sheltered” Initiative • Must evaluate whether new source performance standard (NSPS)applies • Must evaluate need for air permit/approval • Complete applicable permit applications • Expedited approval and/or permit • Must be in compliance by Sep. 30, 2008

20. Evaluating Permit Needs • Identify for all boilers: • Date of installation or modification • Heat input capacity (typically in MMBTU/hour) • Type of fuel (natural gas, fuel oil, etc) • Evaluate using fuel with greater PTE • Low NOX burner (for natural gas-fired boilers)

21. Evaluating Permit Needs • Use information (from previous slide) • Use AP-42 emission factors • http://www.epa.gov/ttn/chief/ap42/ch03/index.html • Emissions can be estimated with this info • Don’t worry, we’ve done the calculations! • See flow chart in packet received from KDHE

23. Subject to NSPS? The boiler was constructed, modified, or reconstructed after June 9, 1989 The heat input capacity of the boiler is between 10 and 100 MMBtu/hr Complete the expedited KDHE boiler form Yes Yes No No The boiler is not subject to NSPS requirements

24. Yes No Boilers burn natural gas Yes Boilers have low NOX burners Total heat input capacity is 10 MMBtu/hr or greater No requirements Yes Expedited approval needed No No Total heat input capacity is less than 10 MMBtu/hr No requirements Expedited approval needed Total heat input capacity is between 10 and 93 MMBtu/hr Total heat input capacity is 93 MMBtu/hr or greater Expedited permit needed Total heat input capacity is less than 3.8 MMBtu/hr No requirements Boilers burn fuel oil #1 or #2 or diesel Yes Total heat input capacity is between 3.8 and 17.8 MMBtu/hr Expedited approval needed No Total heat input capacity is 17.8 MMBtu/hr or greater Expedited permit needed Total heat input capacity is less than 3.5 MMBtu/hr No requirements Boilers burn residual oil #5 or #6 Yes Total heat input capacity is between 3.5 and 16.1 MMBtu/hr Expedited approval needed No Total heat input capacity is 16.1 MMBtu/hr or greater Expedited permit needed Contact KDHE Bureau of Air and Radiation (BAR) Subject to expedited approval/permit?

25. Other possible sources

26. Emergency Generators • Emergency generator definition • Used only for back-up power (not to offset peak energy usage) • For PTE calculations, assume 500 hours/year • All emergency generators should be registered with KDHE • Expedited form available

27. Expedited Form Source: www.kdheks.gov/air-permit/forms/Emergency_Gen_App.pdf

28. Future Additions or Modifications • Evaluate PTE for new or modified equipment • If PTE exceeds construction approval or permit thresholds, contact KDHE • Thresholds: www.sbeap.org/publications/airqual.pdf • Forms: www.kdheks.gov/air-permit/download.html

29. Summary

30. In conclusion… • You must determine your permitting needs. • If assistance is needed, contact David Peter at 785-296-1104, Cheryl Evans at 785-296-1574, or SBEAP at 800-578-8898. • Affected facilities must submit form(s) by September 30, 2008.

31. Air Permitting Web Site www.kdheks.gov/air-permit/download.html Includes forms for: • Expedited approvals application • Generator • Boiler • Expedited permits application • Boiler • Construction permit/approval application • Operating permits application • Reporting forms • Equipment specific

32. Questions or Comments? KDHE contacts David Peter, 785-296-1104 Cheryl Evans, 785-296-1574 SBEAP Environmental Hotline 800-578-8898 www.sbeap.org