311 Industrial Boiler MACT - Impact and Control Options is Hot Topic on March 10, 2011

Industrial Boiler MACT - Impact and Control Options is Hot Topic on March 10, 2011

On February 23, 2011 the U.S. EPA issued “Sensible Standards” for Boilers and Certain Incinerators that “cut the cost of implementation by about 50 percent from an earlier proposal issued last year.”

“Because the final standards significantly differ from the proposals, EPA believes further public review is required. Therefore, EPA will reconsider the final standards under a Clean Air Act process that allows the agency to seek additional public review and comment to ensure full transparency. EPA's reconsideration will cover the emissions standards for large and small boilers and for solid waste incinerators.”

The following speakers will discuss how these new regulations differ from the original proposed rule, what the impact will be for operators of industrial boilers and incinerators and what the future may hold for revisions to this regulation. Speakers will also address potential control technologies and strategies available for operators to achieve compliance and the advantages and disadvantages of the various control technologies as well as criteria for selecting specific technologies – existing facility configuration, existing control equipment installed, fuel type and others.

Mack McGuffey, Associate at Troutman Sanders LLP an environmental law firm – “Despite its request for even more time to promulgate new emission standards for boilers, EPA was required by court order to issue its final rule to implement the National Emissions Standards for Hazardous Air Pollutants (NESHAP) from industrial, commercial, and institutional boilers and process heaters. EPA's final rule imposes a Maximum Achievable Control Standard (MACT) for five hazardous air pollutants or surrogates of hazardous air pollutants emitted from those sources, and will potentially require the installation of costly new pollution control equipment within a maximum expected compliance deadline of three years from the effective date of the rule. The presentation will provide a brief overview of the MACT program generally, explain how EPA's final Industrial Boiler MACT standards differ from the ones it originally proposed, and describe some of the legal issues associated with the EPA's final rule.”

Brian Higgins, Ph.D., Vice-president of Technology for Nalco Mobotec, will discuss the newly promulgated Boiler MACT rule and Nalco Mobotec’s solutions for PM, CO, HCl, Hg and dioxin/furan control. The focus will be on Major Sources firing solid fuels and synthetic Area Sources. Some of the rule’s twists and turns will be reviewed, including post-certification compliance requirements, the RCRA definitions of solid wastes, and CISWI MACT overlap. Demonstrated compliance testing with mobile equipment will be reviewed.

Steve Baloga, P.E., Senior Environmental Consultant at Shaw Environmental & Infrastructure - “The NESHAP ICI Boiler MACT will create significant challenges for many industrial boiler operators over the next 36 months as they decide what they will do to comply with lowered emission standards. Shaw has recently introduced several new technologies that provide an effective low cost solution to help achieve the new lower limits. Several boiler trials have proved the viability of these low cost technologies.

Ajay Kasarabada and Diane Fischer of Black & Veatch, will present “The Non-Solid Fuel Pathway for Compliance with Boiler MACT.” To comply with the final Boiler MACT rule, owners and operators of affected facilities can explore the following two primary pathways:

• Continue firing coal and/or biomass (solid fuel) in the boilers and utilize post-combustion control/combustion improvements to meet the future emission limitations.

• Cease combusting coal/biomass as a fuel and switch the current fuel mix from solid fuels to gaseous fuels that are fired either in the existing boilers or in new cogeneration systems that utilize gas fired combustion turbines.

The Boiler MACT was finalized on February 21, 2011 and the EPA has initiated an automatic reconsideration of these rules. It is very likely that as part of the reconsideration or other legal actions, the final rule and the target emission levels could change in the future. Owners and operators of affected facilities that are wary of this regulatory uncertainty can look into the non-solid fuel pathway for compliance. Boilers combusting Gas 1 or other Gas 1 fuels are exempt from meeting the Boiler MACT emission limits. Similarly gas-fired combustion turbines are not affected by the MACT rules. In other words, Boiler MACT emission limits (currently final or potentially revised later) are not a driver for these gaseous fuel-fired generation alternatives. However, these systems will need to not only replace the existing generation but also be in place and be up and running before - the Boiler MACT compliance date (Spring 2014). The overall objective of the presentation is to explore the non-solid fuel pathway for compliance with Boiler MACT that includes gas conversion and cogeneration. This presentation will highlight some of the technical and economic issues that will have to be considered while the technical and economic issues that will have to be considered while evaluating the non-solid fuel pathway for Boiler MACT compliance.

Russell Price, P.E., Vice President of Stanley Consultants, will present an approach to defining options and creating a compliance plan.

Edmund Schindler, Vice President, Utility Sales at Combustion Components Associates, Inc., will present various strategies for reducing CO in exiting boilers starting with the current regulations then, the strategies. They will include CFD, burner tuning, burner modification, Fuel and Air Balance, atomizers and fuel injectors, and SCR.

Ph: 847-784-0012 | Fax; 847-784-0061

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