Boiler NESHAP Requirements for ICI Boilers at Area
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) What is the Boiler NESHAP? • National Emission Standards for Hazardous Air Pollutants (NESHAP) • This rule applies to Industrial/Commercial/Institutional Boilers at HAP Area Sources (<10 TPY Single HAP; <25 TPY Total HAP). • Affects New and Existing Boilers that combust Oil, Coal and Biofuels • Does Not Apply to Natural Gas or Propane • Does Not Apply to Distillate Oil if used only during curtailment or emergencies (48 hours of annual testing allowed too). • Applies to Existing Boilers at all four U of M Campuses January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) What are the Boiler NESHAP Requirements? • • Notifications Start-up/Shutdown Procedures (Hg and CO, Coal Only) Emission Limits (Hg and CO, Coal Only) Performance Testing (Hg and CO, Coal Only) Boiler Tune-Ups (Oil and Biomass Only) Continuous Compliance (CEMS or O 2 Trim System) Energy Assessment (All Affected Boilers) Recordkeeping / Reporting / Annual Certification January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Which University Boilers are Affected? • UM – Crookston: • UM – Duluth: • UM – Morris: • UM – Twin Cities: January 31, 2014 Coal-Fired Boiler (Propane Boiler not Affected) All Boilers Biomass Boiler (Selected Curtailment-Only for gas/oil units) Southeast: CFB and Boiler # 4 (coal) St. Paul: Boilers #1, 2, 5 and 6 (Coal Boilers excluded if permit limits usage to less than 10 pecent annual capacity factor; Selected Curtailment-Only for gas/oil units)
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) What are the Boiler NESHAP Deadlines? • • Initial Notification Start-Up/Shutdown Procedures Emission Limits Performance Testing All Coal – Notification of Intent to Test – Testing – Test Report • CEMS or O 2 Trim System 60 days before test September 17, 2014 60 days after test Coal – Site-Specific Monitoring Plan – Initial Evaluation • • • Boiler Tune-Ups Energy Assessment Notification of Compliance January 31, 2014 January 20, 2014 March 21, 2014 60 days before test September 17, 2014 Oil/Biomass All March 21, 2014 Multiple Dates (later)
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Start-Up/Shutdown Procedures • • Coal March 21, 2014 Affects UM – Crookston and UM – Twin Cities Must Minimize Startup/Shutdown Must Follow Manufacturer Procedures or Similar Emission Limits do not Apply during Startup/Shutdown January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Emission Limits Coal March 21, 2014 • Affects UM – Crookston and UM – Twin Cities • Carbon Monoxide (CO) as Surrogate for Organic HAPs: – 420 ppm @ 3% O 2 ; 30 -day rolling average • Mercury (Hg) – 22 lb/trillion BTU @ 3% O 2 – Fuel Sampling: Calculate effective emission rate from boiler data • Current Compliance Status – UM – Crookston: Untested for CO, Emission Factors indicate Compliance Weekly Hg Data indicates Compliance @ < 50% of Emission Limit – UM – Twin Cities: All units tested for CO, indicate Compliance One fuel sample indicates Compliance with HG Limit
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Performance Testing Coal September 17, 2014 • Affects UM – Crookston and UM – Twin Cities • Carbon Monoxide (CO) as Surrogate for Organic HAPs: – 420 ppm @ 3% O 2 ; 30 -day rolling average – Representative Operating Load, Worst-Case Fuel – 3 Test Runs • Mercury (Hg) – 22 lb/trillion BTU @ 3% O 2 – Fuel Sampling during Testing – Minimum 3 Samples per Test Run, 3 Test Runs (see above) January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Continuous CO Compliance Coal O 2 Monitoring System • Affects UM – Crookston and UM – Twin Cities • May Monitor Either CO or O 2 • Oxygen (O 2) as Surrogate for CO: – May use Oxygen Trim System instead of CEMs – Must Maintain O 2 Levels at or above Tested Level (30 -day rolling average) – 3 Test Runs • Mercury (Hg) – 22 lb/trillion BTU @ 3% O 2 – Fuel Sampling during Testing – Minimum 3 Samples per Composite, 3 Composite Samples January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Continuous CO Compliance Coal O 2 Monitoring System • Affects UM – Crookston and UM – Twin Cities • May Monitor Either CO or O 2 • Oxygen (O 2) as Surrogate for CO: – May use Oxygen Trim System instead of CEMs – Must Maintain O 2 Levels at or above Tested Level (30 -day rolling average) – Must Evaluate Oxygen Trim System at time of Performance Testing • Site-Specific Monitoring Plan Required 60 days before test January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Continuous Hg Compliance Coal Fuel Sampling Affects UM – Crookston and UM – Twin Cities • Mercury (Hg) – If Initial Test indicates < 50% of Emission Limit, no further testing unless switching coals. – If Initial Test indicates > 50% of Emission Limit, Quarterly testing January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Tune-Ups Distillate Oil/Biomass March 21, 2014 • Affects UM – Duluth and UM – Morris • Other Campus Gas/Oil Units: Curtailment/Emergency Only are not Affected • Follow Tune-Up Guides and Forms Provided by EPA – Before/After Testing – Includes CO Measurements but may use hand-held analyzer • Current Compliance Status – UM – Duluth: Conducted test in 2012 – UM – Morris: Has not conducted test (operational? ) January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Energy Assessment All Units March 21, 2014 • Affects Regulated Units at ALL CAMPUSES • Level of Effort based on Thermal Input Capacity: UMM / UMC UMD UMTC NO ON-SITE ENERGY USE SYSTEMS ACCOUNT FOR THE THRESHOLD. ONLY IN-PLANT! January 31, 2014
Boiler NESHAP Requirements for ICI Boilers at Area Sources 40 CFR 63 Subpart JJJJJJ (6 J) Recordkeeping / Reporting All Units • Initial Notification of Applicability (COMPLETED) • Notification of Compliance Status: – Tune-Ups: – Energy Assessment: – Performance Test / Emission Limits: • Annual Compliance Certification July 19, 2014 September 17, 2014 (180 days after 3/21/14) March 1 each year, submit if requested Submit by March 15 if deviations. • Recordkeeping – All required reports, test data, fuel consumption, CMS data, certifications, etc… January 31, 2014
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