1. EPA Air Toxics Standards for Boilers
and Process Heaters
James A. Westbrook
March 15, 2011

2. Agenda
Rule Introduction Standards for Boilers and Process Heaters
NOT cover Incinerators
Applicability (and not applicable)
Major and Area Sources
Affected and Non-Affected, New & Existing Units
Large and small units, by unit and fuel type
Requirements notification, limits, work practice requirements, testing, records and reporting
Case Studies Refinery and Biomass Plant
3. About BlueScape
20 years experience, air quality compliance
Permits, air modeling, compliance for boilers and heaters, various fuels
National Experience
Solve tough air quality compliance issues:
- Determining rule applicability
- Assess how to reduce impacts, change status
- Develop monitoring, recordkeeping and reporting protocols
- Agency negotiations
4. Introduction to the Boiler Air Toxics Rules
40 CFR 63 Subpart DDDDD, NESHAP
Finalized February 21, 2011
Effective 60 days from publish in Federal Register
New and existing industrial, commercial and institutional boilers and process heaters
Regulate HCl, Hg, PM, dioxins/furans, and CO
Major Source Rule, 15 unit-based subcategories
Area Source Rule, 4 general subcategories
Parts will be reconsidered
5. Applicability
Major or area source?
Major Source = 10 tpy or more of any single HAP or 25 tpy or more of any combination of HAP
Only boilers at area sources, not process heaters
Affected source, New or Existing
Collection of boilers and heaters at a source within a subcategory
New or reconstructed, commence construction or reconstruction after June 4, 2010
Existing affected source, June 4, 2010
Fuel subcategory?
Major source, 10% rule to determine source category and emission limits
Area source, 15% rule to determine source category and emission limits
6. Not Applicable, Major Sources
Electric utility steam generating unit
Recovery boiler or furnace under Subpart MM
Boiler or heater for research and development
Hot water heater
Refining kettle under Subpart X
Ethylene cracking furnace
Blast furnace stoves
Boiler or process heater part of the affected source subject to another NESHAP
Boiler of process heater used as a control device
Temporary boilers
Blast furnace gas fuel-fired boilers and process heaters
Clean Air Act Section 129 and Solid Waste Disposal Act boilers
7. Major Source RequirementsLarge Boilers & Heaters(>= 10 MMBtu/hr)
7
8. Major Source RequirementsSmall Boilers & Heaters(< 10 MMBtu/hr)
8
9. Area Source RequirementsLarge Boilers & Heaters(>= 10 MMBtu/hr)
9
10. Area Source RequirementsSmall Boilers & Heaters(< 10 MMBtu/hr)
10
11. Tune-Up Program, Major Sources
Inspect burner, clean replace components
Inspect flame pattern, adjust
Inspect system controlling air-to-fuel ratio, calibrate
Optimize CO emissions per manufacturer
Measure CO before and after adjustments
Submit annual reports, CO ppm and fuel data
12. 12
Emission Limits, Major Sources
Reference: USEPA
13. 13
Emission Limits, Area Sources
Reference: USEPA
14. Emission Limit Comparisons
14
CO, ppm
PM, lb/MMBtu
15. Startup, Shutdown & Malfunctions
Applies to both boiler and process heaters at major sources and boilers at area sources
Work practice standards
Manufacturers recommended procedures
Minimize emissions and prevent future malfunctions
16. Notification, Recordkeeping & Reporting
Semiannual compliance reports
Notification of compliance status report
Records of compliance and tune-ups
Records of continuously monitored data
Electronic Reporting Tool (ERT) - Submission of test results
17. Compliance Schedule
Boilers and process heaters, major sources
- New, comply 60 days from rule date, or startup
- Existing, 3 years from rule date
Boilers located at an area source
- New, comply 60 days from rule date, or startup
- Existing, tune-up compliance no later than 1 year from rule date
- Existing, emission limits no later than 3 years after rule date
18. Case Study: Refinery

3 boilers and 10 process heaters, existing

19. Major Source of HAPs 20. Combust refinery gas, Gas 1 Subcategory 21. One affected facility, all 13 units 22. Analysis:- Annual Tune-Up, 1-Time Energy Assessment (more extensive)
- Minimizing Periods of Startup and Shutdown
- Minimize and Correct Malfunctions

Recordkeeping and Reporting