www.all4inc.comKimberton, PA | 610.933.5246Kennesaw, GA | 678.460.0324

Boiler MACT and Strategic Air Permitting

Mark Wenclawiak | mwenclawiak@all4inc.com | 678-460-0324July 10, 2013

Presented to A&WMA Southern Section Annual Meeting and Technical Conference by All4 Inc.

2 Your environmental compliance is clearly our business.

Drivers and tools• Boiler MACT• NSR Reform rules• Improve operational flexibility while decreasing actual

emissions• Reduce operating and compliance costs• Timing: Outages? Agency processing? Procurement?

Case study• Existing Kraft mill – increase pulp production, BLS rate• Boiler conversion – multi-fuel to gas, limited coal • PSD avoidance; reduced Boiler MACT obligations

Outline

Boiler MACT and Strategic Air Permitting

Drivers and Tools

4 Your environmental compliance is clearly our business.

Typical Boiler MACT project begins with:• Establishing your subcategory (initial notification)• Fuels combusted and design type • Design heat input capacity• Annual heat input basis 12-months prior to compliance event

Identify applicable emission limits• Install APC; TSM option; output based standards• Engineering testing for compliance strategy

Derating < 10 MMBtu/hr or retiring units Change fuel mix or introduce new fuels (e.g., TDF)

• Our project: Accept limitation on fuel usage to switch subcategory, and generate actual emission decreases

Drivers and Tools – Boiler MACT

5 Your environmental compliance is clearly our business.

NSR reform allows creative accounting, particularly for existing emission units• Identify modified and affected units

Projects with boilers: Boilers; Woodyard; Fuel handling equipment

Debottlenecking….More steam = more production? Baseline actual to projected actual test

• Testing: Opportunity to re-establish baselines based on engineering testing for Boiler MACT compliance or other updated data

• Historical factors < testing results = good thing

Drivers and Tools – NSR Reform

6 Your environmental compliance is clearly our business.

If production increase project exceeds PSD significance, Boiler MACT project can provide contemporaneous decreases to net out of PSD (case study)

Projected actual emissions• Consider multiple scenarios to maximum flexibility

Changes to types and rates of fuels and/or production materials• Excludable emissions – historical peak monthly levels during

baseline• Remember timing: consider outage schedules, permit

preparation and processing time, capital procurement process New units more limited: based on potential to emit (PTE)

• Consider air pollution control devices and fuel or production limitations to reduce PTE

Drivers and Tools – NSR Reform

7 Your environmental compliance is clearly our business.

Boiler MACT projects & contemporaneous decreases• Retired (past) units• Shutdown currently permitted units• Limited use units (e.g., change to a backup boiler)• Be careful with contemporaneous PSD avoidance projects!

Actual reductions to comply with MACT considered surplus for NSR netting and can be used (U.S. EPA memo)

Source obligation tracking Are additional regulations triggered (e.g., NSPS)? Don’t forget about NAAQS considerations

Drivers and Tools – NSR Reform

Boiler MACT and Strategic Air Permitting

Case Study

9 Your environmental compliance is clearly our business.

Existing unbleached Kraft pulp mill• Project to increase pulp production and BLS firing rate

Existing recovery furnace physically modified Affected sources: Recovery Area; Pulping System; Washing;

Paper Machines; Woodyard Causticizing & kiln unaffected due to historical operations Baseline actual to projected actual emissions

• Convert combination boiler to natural gas power boiler Consider various scenarios of coal firing for backup fuel Annual capacity factor limitation Key to viability: contemporaneous decrease

Case Study

10 Your environmental compliance is clearly our business.

Current combination boiler• Coal, wood, natural gas, fuel oil• Existing source with respect to Boiler MACT

Coal/solid fossil fuel, stoker subcategories Natural gas conversion project

• Natural gas and coal only Coal limited to annual capacity factor <10%

• Reclassified as Gas 2 (other) unit subcategory Comparison of Boiler MACT emission limits

Case Study

11 Your environmental compliance is clearly our business.

Boiler MACT emission limits comparison

Testing for HCl, Hg, PM (coal); CO (gas) Fuel sampling limited to 100% coal firing scenario

Case Study

Pollutant Coal Subcategory Gas 2 Subcategory

HCl 2.2E-02 lb/MMBtu 1.7E-03 lb/MMBtu

Hg 5.7E-06 lb/MMBtu 7.9E-06 lb/MMBtu

PM 4.0E-02 lb/MMBtu 6.7E-03 lb/MMBtu

CO 160 ppmvd @ 3% O2 130 ppmvd @ 3% O2

12 Your environmental compliance is clearly our business.

Existing emission units so….baseline actual emissions• NSR Reform

Consecutive 24-month period in 10-year look back Average annual rate for the 24-month period Influenced by use of non-natural gas fuels

Projected actual emissions• Based on reduced coal usage and elimination of fuel oil and

wood waste in boiler• Mill production levels based on maximum BLS firing with the

maximum amount of natural gas firing• Maintain some backup fuel capacity with coal• Excludable emissions not considered to conservatively estimate

projected actual emissions

Case Study

13 Your environmental compliance is clearly our business.

Project related increases significant for VOC, NOX, PM, PM10, and PM2.5

Netting of contemporaneous projects• Decreases consisted of reductions attributable to

boiler coal limitation• Decreases for all pollutants except VOC after netting

(though VOC net increase not significant)• PSD avoided

Case Study

Boiler MACT and Strategic Air Permitting

Conclusions

15 Your environmental compliance is clearly our business.

Increase in production achieved• ~15% increase in BLS firing rate over current limit• ~25% increase in pulp production over current limit

PSD avoidance Simpler Boiler MACT obligations

• No need for add-on control• Less complicated testing and fuel sampling

requirements

Conclusions

www.all4inc.comKimberton, PA | 610.933.5246Kennesaw, GA | 678.460.0324

Questions and Open Discussions

Mark Wenclawiak, CCM | mwenclawiak@all4inc.com | 678-460-0324