The Industrial Boiler MACT - Impact and Control Options was the Hot Topic on Thursday March 10, 2011
Despite its request for more time, on February 23, EPA was forced by the courts to issue what they called “Sensible Standards” for Boilers and Certain Incinerators that “cut the cost of implementation by about 50 percent from an earlier proposal issued last year.” EPA's final Industrial Boiler and Process heater rule imposes a Maximum Achievable Control Standard 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. At the same time EPA said, “Because the final standards significantly differ from the proposals, EPA believes further public review is required.” This begs the question “What does all this mean and what does the future hold for the IBMACT?”
Yesterday six very knowledgeable speakers addressed this question and presented various options that boiler operators can consider to achieve compliance with the Industrial Boiler MACT. One point echoed by many of the speakers was that the Utility MACT will also be promulgated in the very near future and many of the vendors will soon become fully occupied with the larger potential of helping utilities comply. Therefore, boiler operators should not delay in arranging the consulting, testing and/or equipment they will require to comply with the Boiler MACT.
Our first speaker was Mack McGuffey. Mack practices environmental law as an associate in Troutman Sanders' Atlanta office and specializes in regulatory compliance under the Clean Air Act. Last November at the last webinar on the IBMACT before the rule was published, he gave a very good presentation on the status of the ruling and potential future litigation. Now that the rule is out, Mack was able to provide an overview of the MACT program, 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 EPA's final rule. A key point made was that although EPA indicated that because of concerns over the legality of the significant changes between proposed rule and final rule, EPA is taking comment on the final rule, any delay in or stay of the deadline for compliance is very unlikely. He also emphasized that affected boiler operators must do whatever is necessary to comply with the new emission limits. Just installing additional control equipment will not be sufficient.
Brian Higgins PhD., Vice-president of Technology for Nalco Mobotec, gave a good summary of the new MACT rule and potential compliance solutions for the five regulated pollutants - PM, CO, HCl, Hg, and dioxin/furan. Brian described the potential for boiler operators to control just HCl to become a “Synthetic Area Source” and effectively then need to only comply with the far less onerous Area Source regulations. He also discussed fuel categories, the RCRA definitions of solid wastes and CISWI MACT overlap.
Steve Baloga P.E., a Senior Environmental Consultant at Shaw Environmental & Infrastructure, described a process for economically reducing mercury emissions from boilers combusting bituminous or sub-bituminous coal. EMO™, a liquid brominated oxidant, is injected into the gas stream at the exit of the boiler or economizer to convert elemental mercury into the oxidized version that is more readily captured by existing control equipment. With very low injection rates, this can be an effective low cost solution to achieve the new lower limits required by the MACT. He presented data on several boiler trials that demonstrate the viability of this low cost approach.
Ajay Kasarabada, an Air Permitting Manager in Black & Veatch Energy Division's Environmental Management Services Section, and Diane Fischer, Manager of Business Development for Air Quality Control Projects for Black & Veatch’s Power Generation Services, described a method for avoiding the need to comply with the Boiler MACT – “the non-solid fuel pathway”. They presented a methodology by which boiler operators can evaluate the technical and economic issues related to converting boilers to operate on “Gas 1” or “Other Gas 1” as defined by the EPA or decommissioning solid fueled boilers and installing new gas-fired boilers or gas turbines. Gas 1 units, Other Gas 1 units and combustion turbines do not have to meet Boiler MACT emission limits. Diane’s portion of the presentation focused on the benefits of considering co-generation and provided a detailed methodology for evaluating this alternative. They indicated that Black and Veatch is involved in studying these alternatives for a number of boiler operators but they have not yet reached any firm conclusions. However, now that the Boiler MACT has been issued, they are moving forward rapidly.
Russell Price P.E., Marketing Manager for Stanley Consultants Inc., presented a structured five-step approach for boiler operator to define their available options and create a MACT compliance plan. In summary, the plan would define goals, gather data, evaluate compliance alternatives of each of the five regulated pollutants then develop composite solutions and evaluate them based on life cycle cost.
Ed Schindler, Vice President of Utility Sales at Combustion Components Associates, Inc., presented various strategies for reducing CO in existing boilers including CFD, burner tuning, burner modification, adjusting burners to get good fuel and air balance, replacing worn parts, upgrading atomizers and fuel injectors and, as a last resort, installing a CO catalyst. He gave examples of the results that can be obtained with various sized boilers using one or more of these strategies and stated that almost every boiler could achieve compliance with the MACT limits by utilizing one or more of these strategies.
The Bios, Photo and Abstracts are linked below.