Environmental Compliance Hot Topics

Hardwood Plywood Veneer AssociationMay 25, 2010

Today’s Top 2

•SPCC•Boiler MACT

Spill Prevention, Control, and Countermeasure (SPCC)

Rule

SPCC Rule

• This impacts me if I have:– An underground storage of greater than 42,000

gallons; or– An aboveground storage of greater than 1,320 gallons

(only container of 55 gallons or greater are counted); and

– Due to location, could reasonably be expected to discharge oil in quantities that may be harmful into or upon “navigable waters” of the U.S.

– Must exclude consideration of manmade features like dikes, equipment and/or other structures

SPCC Rule Revisions

• On November 5, 2009, EPA issued revisions to the SPCC Rule

• The new deadline for compliance with the rule is November 10, 2010

• Expect to see increased inspection presence from EPA

• Typical fines for not having a plan $1000-$7000• If you have a release- escalates to the cost of

cleanup, and $$$$ in fines

Action to Take Now

• Prepare and/or Update your SPCC plan

• Follow the plan• Remember- compliance date is

November 10, 2010

Proposed Boiler MACT

What Happened?

• On April 29, 2010 EPA issued a proposed rule that would reduce toxic air pollutants from boilers and process heaters

• Provisions in the rule cover- essentially all boilers

• Currently proposed rule is out for public comment.

Will this Impact Me?

• If you have a boiler-YES• If you plan on installing a boiler –YES

Best Scenario

• You do not have a boiler• Your existing boiler is Natural gas fired

only (exempt)• Your existing boiler is small in size (<10

MMBTU/HR)• You have a temporary boiler only

(operates less than 180 consecutive days)(exempt)

What’s Required for the Best Scenario

• Biennial Tune-up– Inspect the burner-clean or replace components as

necessary– Inspect the flame pattern-make adjustments to

optimize– Inspect the system controlling the air-to-fuel ratio,

and ensure calibrated and functioning properly– Minimize the CO emissions following manufacturer

specifications– Measure CO emissions before and after adjustments

• Annual Report

Most Stringent Scenario

• You are a HAPS major source– Emit 10 tons or more of an individual HAP– Emit 25 tons or more of combined HAPs

• Focus on reductions for carbon monoxide, particulate, HCl, Mercury, and dioxin/furans.

• Standards are based on the fuel type for all parameters and both fuel type and boiler design for dioxin/furans and carbon monoxide standards.

What’s Required for the Most Stringent Scenario?

• Installation of Continuous Monitors• Installation of Controls• Energy Assessment• Initial and Annual Source Testing ($20-$30K)

Most Common Scenario

• You are not a HAPS Major but an “AREA SOURCE”– Emit less than 10 tons per year of any individual

HAP– Emit less than 25 tons per year of any combination

of HAPs

• Boilers are greater than 10 MMBTU/HR*

*(We’re not looking at coal for this scenario)

What’s Required for the Most Common Scenario?

• Initial and Annual Source Testing for Carbon Monoxide ($2500-$3000)

• New limits for particulate and CO for new sources of oil and biomass

• Particulate, CO, and mercury for coal sources• New limits for Carbon Monoxide for existing sources

– Will require “Generally Achievable Control Technology” (GACT).

– Methods, practices and techniques are commercially available and appropriate

• Energy Assessment

Energy Assessment Requirements• Energy assessment must be performed by

qualified personnel• A qualified specialist is someone:

– Who has successfully completed the Department of Energy’s Qualified Specialist Program for all systems or

– A professional engineer certified as a Certified Energy Manager by the Association of Energy Engineers.

Energy Assessment Requirements

• Complete a visual inspection and review of the boiler system.

• Establish operating parameters of the facility energy systems

• Identify the high energy sources, conservation measures, and potential savings

• Prepare a comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the timeline

Other Changes Proposed for the Boilers

• Proposed standards vary based on the fuel type• EPA is proposing either daily or monthly standards• Sources w/o wet scrubbers that have particulate

and mercury emission limits will require continuous opacity monitors

• Sources electing fuel sampling to comply with the mercury standard are required to sample monthly

• Recordkeeping and compliance reporting requirements

Compliance Timeline

• The final rule is to be complete by December 16, 2010.

• Compliance is required three years following the date of publication of the final rule.

Ways to send comments…

• Email: a-and-r-docket@epa.gov• Fax: 202-566-9744• Mail: EPA Docket Center Environmental Protection Agency

Mailcode: 2822T 1200 Pensylvania Av., NW Washington, DC 20460DOCKET- ID No. EPA-HQ-OAR-2006-0790

Separate but Related Action• EPA has proposed updated definitions of

nonhazardous wastes and fuels with respect to boilers dictating how a unit is regulated under the boiler MACT

• Majority of the fuels we use are clean biomass.• If the fuels are under the control of the

generator and not contaminated will be considered non-hazardous solid waste.

• Concerns-with the treated wood, painted wood, construction debris with contaminants, and materials generated somewhere else.

Heather BartlettPrincipal EngineerSLR International Corp

Address: 1800 Blankenship Road, Suite 440, West Linn, OR 97068

Office:  (503) 723-4423Facsimile: (503) 723-4436Email: hbartlett@slrcorp.comWebsite:

www.slrconsulting.com