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Boilers, Engines, & Incinerators Oh My!. Fred P. Osman, P.E.,BCEE Osman Environmental Solutions Harrisburg, PA July 29, 2011. Permitting Boilers & Engines in PA DEP Requirements. P/A – Plan Approval or Construction Permit. GP – General Permit. Boiler Issues – EPA Boiler MACT.
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Boilers, Engines, & IncineratorsOh My! Fred P. Osman, P.E.,BCEE Osman Environmental Solutions Harrisburg, PA July 29, 2011
Permitting Boilers & Engines in PADEP Requirements P/A – Plan Approval or Construction Permit GP – General Permit
Boiler Issues – EPA Boiler MACT Major source vs. area source Determine whether facilityis major for HAPS Area sources burning NG are not subject to rule All other sources are (all major source and all area source boilers burning liquid or solid fuels)
Boiler MACTMajor/Area Rule Comparison *Coal-fired means burns any solid fuel, but <15% biomass Gas -1 is NG, refinery gas or other low Hg gas
Non-Hazardous Secondary Materials(NHSM) • Boilers burn fuel/Incinerators burn wastes • Fuel is: • Traditional fuels (coal, oil, NG, etc.) • Clean cellulosic biomass • Scrap tires managed under tire collection program • Resinated wood • Materials under the control of the generator* • Wastes processed into fuels* • Materials determined to be non-waste by EPA* *Must meet legitimacy criteria
EPA Stationary Reciprocating Internal Combustion Engine (RICE) Rule • EPA emission limits for new engines (Tier Limits) and New Source Performance (NSPS) • RICE rule regulates older engines’ emissions • (RICE still applies but generally defers to NSPS) • Compliance dates for area sources (CI - 5/3/13, SI - 10/19/13) • Emergency operation strictly defined
Are non-road Engines “stationary”? • Nonroadengine is any internal combustion engine: (iii) [t]hat, by itself or in or on a piece of equipment, is portable or transportable, meaning designed to be and capable of being carried or moved from one location to another. • Indicia of transportability include, but are not limited to, wheels, skids, carrying handles, dolly, trailer, or platform." • But a non-road engine that remains at one location for 12 months becomes forever “stationary” • One cannot simply relocate an engine solely to avoid it becoming a stationary engine; there must be some business purpose for the move.
EPA Stationary Reciprocating Internal Combustion Engine (RICE) Rule Different conditions for: • New, existing, or reconstructed engines • Area or Major Sources of Hazardous Pollutants • Emergency, non-emergency, limited use, landfill or digester gas • Engine size, hp and cylinder size • Compression or spark • Type of engine (2SLB, 4SLB, 2SRB, 4SRB) • Date of construction (date of order of engine).
EPA RICE - Existing CI >500bhp Engines-Area Sources (Example) • Limit CO to 23 ppmvd OR reduce CO by 70% • Stack test to prove compliance every 3 years or 8760 operating hours, if not using • If using catox, maintain ∆p ± 2” H2O from stack test and maintain 450 °F ≤ T ≤ 1350 °F • A Tier 3 certified engine or if above 560kW, Tier 2 can instead comply with the NSPS. • <30 liters/cylinder must use ULSD