CHP, Waste Heat & District Energy

Transcription

1 Electric Cooling T/E Ratio Electricity Consumption & Cooling T/E Ratio CHP, Waste Heat & District Energy Module 5: Biomass CHP Emissions Module 5 Topics Basics (focusing on biomass boiler based CHP) New Source Review PA specific requirements Conclusions Education Food Sales Food Service Inpatient Outpatient Lodging Retail non-mall Encl & Strip Mall Office Public Assembly Public Order/Safety Religious Worship Service W'house & Storage Trillion Btu Thermal-Electric Ratio Slide 2

2 Basics MYTHS My facility is too small No one told me I needed a permit My vendor says I do not need a permit I already have an air permit Since my CHP plant will save electricity, I get emissions from the grid FACTS Size does not matter Responsibility lies with the facility Vendors want to make a sale You may need more than one permit NO Slide 3 New Source Review Slide 4

3 How does NSR ensure environmental protection? By controlling increases in air emissions that could affect attainment or maintenance of the National Ambient Air Quality Standards (NAAQS). NAAQS have been set for: Ozone (smog) Nitrogen dioxide (NO 2 ) Carbon Monoxide (CO) Sulfur dioxide (SO 2 ) Particulate Matter (dust/soot) Lead For each of the NAAQS pollutants (Appendix( A to presentation), every area of the U.S. is designated into one of the following categories: Attainment air quality is lower than the NAAQS Nonattainment air quality is equal to or exceeds the NAAQS Unclassifiable no data on air quality; treated as attainment Slide 5 EPA New Source Performance Standards New Source Performance Standards Authorized by section 111 of the Clean Air ACT in 1970 First NSPS subpart D for fossil fuel fired steam generating units promulgated in 1971 Industry specific technology based standards applicable to new, modified or reconstructed facilities Best Demonstrated Technology (BDT) BDT is the best system of continuous emissions reduction that has been demonstrated to work in a given industry, considering economic costs and other factors, such as energy use. "LAER" standards are required when a new, stationary source is located in a non attainment air quality region. It is the most stringent air pollution standard above the Best Available Control Technology (BACT) and Reasonably Available Control Technology (RACT) standard. Slide 6

4 EPA NESHAP and MACT National Emission Standards for Hazardous Air Pollutants Section 112 of the 1970 CAA required EPA to identify and list all l air pollutants (not already identified as criteria pollutants) that "may reasonably be anticipated to result in an increase in mortality or an increase in serious irreversible or incapacitating reversible illness. lness. NESHAP standards were developed for certain pollutants that applied to certain existing sources Maximum Achievable Control Technology The 1990 CAA amendments renewed emphasis on controlling emissions of hazardous air pollutants (HAPs) from new and existing sources on the federal level by regulating a list of HAPs based on the maximum available control technology. Slide 7 Major source The term major source means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutant. Slide 8

5 What defines a major source in an attainment area? A source with emissions of any one air pollutant greater than or equal to a threshold of: 100 tons per year (tpy), if part of the 28 listed source categories (Appendix B). 250 tpy, for all other sources not part of the 28 listed source categories. Emissions based on potential to emit (PTE) PTE = Emissions if operated 24 hours per day, 365 days per year (8,760 hours/year); PTE includes the effect of add on emission control technology, if enforceable. Slide 9 Prevent significant deterioration (PSD) Permit Main requirements: Require installation of Best Available Control Technology (BACT) Perform Air Quality Analysis to preserve existing clean air Perform Additional Impacts Analysis Special protections for national parks and wilderness areas Opportunity for Public Involvement Slide 10

6 NSR program for major sources in nonattainment areas If an area is in nonattainment, the goal is to bring the area into attainment; in other words, improve the existing air quality. NA NSR applies to: Pollutants for which the area is designated nonattainment new major sources and major modifications at existing major sources Slide 11 What defines a major source in a nonattainment area? (NA NSR) Emissions of any one air pollutant greater than or equal to the major source thresholds in a nonattainment area. This threshold is generally 100 tpy (or lower depending on the nonattainment severity) for all sources, regardless of category. For a list of the other applicable thresholds depending on the nonattainment severity, (Appendix( C). C Slide 12

7 NA NSR permits Main requirements: Require installation of Lowest Achievable Emission Rate (LAER). Emission Offsets Opportunity for Public Involvement Slide 13 4 How is NA NSR applicability different from PSD? NA NSR major source threshold is 100 tpy (or lower in some NA areas) for ALL sources. It is irrelevant what category the source belongs to because listed source categories do not exist for nonattainment NSR. At a new major source, NA NSR applies only to the NA pollutants with PTE above the major source threshold. This is unlike PSD, which applies to all attainment pollutants with w significant emissions at a major source. In other words, the Major for one, major for all concept does not apply for NA NSR. Slide 14

8 What defines a minor source? Emissions less than the major source threshold of a pollutant <100/250 tpy in attainment areas or <100 tpy in non attainment areas Slide 15 Minor NSR NSR program for minor sources in attainment AND nonattainment areas Applies to: New minor sources Modifications at minor sources Minor modifications at major sources Applies in BOTH attainment and nonattainment areas Can be used to create synthetic minor sources this allows sources to avoid major source permitting requirements like NSR and Title V (For more information on Title V, Appendix D) D Slide 16

9 What is a synthetic minor source? A source with PTE greater than or equal to the major source threshold, but has actual emissions below that level and brings PTE below the major source threshold by accepting enforceable limits on emissions or operating conditions Emissions (tpy) Major Source Threshold Actual PTE Slide 17 Who Regulates Air in PA? Pennsylvania Department of Environmental Protection (PADEP) responsible for implementing PA air regulations and is administrator for most Federal air rules. Philadelphia Air Management Services (AMS) and Allegheny County (ACHD) have autonomous programs with rules that are similar or the same as PADEP s EPA Region 3 out of Philadelphia has direct oversight for PA Slide 18

10 What Air Emissions Sources Require a Construction Permit? An air quality permit to install a source is required for ANY air emission sources unless: The source type is listed in the PADEP rules or on the exemption list OR PADEP makes a case by by case determination that the source does not require installation approval Permit to Install/Permit to Construct is required before emissions units can be installed or modified Permit to Operate/Operating Permit is needed to operate equipment once installation or modification is completed Slide 19 Pennsylvania Air Quality Permits Plan Approvals (Construction Permits) State Only Operating Permits (Minor Source) Title V Operating Permits (Major Source) Slide 20

11 Step 1: Define The Project Does this project result in the use of new and/or greater quantities of raw materials? For Biomass it is likely any existing permit does not provide for biomass as a permitted fuel for the combustion unit! Will this project involve changes to existing pollutant control systems? Will this project increase my production capacity? Slide 21 Step 1: Define The Project Will the project require an exhaust stack? Will this project result in a production increase? Will this project remove any existing production constraints? (Debottleneck) Does this project require a physical change to an existing process? Slide 22

12 Step 2: Check The Air Regulations Federal New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) Maximum Achievable Control Technology (MACT) Standards Slide 23 Step 2: New EPA MACT Rules Maximum Achievable Control Technology (MACT) Standards 40 CFR Part 63 EPA Boiler MACT will issue on January 16, 2011 Major and area sources of HAP Emission limits, testing, monitoring, recordkeeping and reporting requirements Lots of possible litigation and delays Slide 24

13 Step 2: BAT / BACT A PSD BACT review will require performance of a Top Down analysis Determine what control technologies are feasible vs. technically infeasible Rank feasible controls according to their effectiveness Evaluate operating costs on $/ton basis Slide 25 Step 2: Check The Air Regulations Pennsylvania requires that all new or modified sources are subject to review for: Best Available Technology (BAT) And Major Air Emission Sources can be subject to review for: Best Available Control Technology (BACT) Lowest Achievable Emission Reductions (LAER) Slide 26

14 Step 3: Determine Emission Increase New Sources: Potential To Emit Max Capacity at 8760 hrs/yr unless otherwise restricted Existing Major Facilities or Where the Emission Increase Will Be Major Itself Modified Sources Projected Actual Emissions minus Slide 27 Step 3: Existing Modified Sources Calculate Baseline Actual Emissions (BAE) Determine a Future Projected Actual Emissions (PAE) Slide 28

15 Step 4: Dispersion Modeling Required for PSD Major Source Permits New NAAQS for NO X is very low and problematic to demonstrate compliance Screen modeling simple, conservative, overestimates ambient concentrations Refined modeling more complex, very expensive & causes significant project time delays Slide 29 Woody Biomass Emissions Particulates Function of ash concentration in fuel and firing method (typically ly stokers/cyclones have 70 80% of ash retained on grate or bottom ash; suspension fired units have 70 80% of ash as flyash) SO 2 Function of sulfur content in fuel; typically very low for all biomass b fuels NO x Typically a function of fuel nitrogen and temperature; low for woody w biomass Slide 30

16 Proposed EPA Rule for Biomass Boilers On June 4, 2010, the U.S. Environmental Protection Agency (EPA) released a Proposed Rule for Area Source Boilers that threatens to severely curtail the future growth of the biomass thermal industry and place prohibitively expensive emissions requirements on existing equipment. Status Size PM (lbs./mmbtu) CO 7% 02) Existing >10mmBtu/hr N/A 160 Existing <10 mmbtu/hr N/A Biennial tune up N/A Biennial tune up New >10mmBtu/hr New <10 mmbtu/hr Slide 31 Conclusions Biomass fired boilers have emissions that vary as a function of Type of boiler Firing conditions Type of biomass fuel Large scale biomass fired boilers emit less than woodfired stoves, fireplaces, and other residential systems Biomass fired boilers can emit more or less than coal fired fired boilers depending upon fuel characteristics and post combustion controls Slide 32

17 Slide 33 Larry Burton Pennsylvania and West Virginia PENN STATE UNIVERSITY UNIVERSITY PARK, PA TEL: E MAIL: lcb2@psu.edu Gearoid Foley New Jersey 50 WASHINGTON ROAD PRINCETON JUNCTION, NJ TEL: E MAIL: guf@psu.edu Richard Sweetser Virginia, DC and Maryland MEADOWVILLE COURT HERNDON, VIRGINIA TEL: E MAIL: rss27@.psu.edu James Freihaut, Director Mid Atlantic Clean Energy Application Center 104 ENGINEERING UNIT A UNIVERSITY PARK, PA TEL: E MAIL: jdf11@psu.edu Bill Valentine Delaware THE PHILADELPHIA NAVY YARD 4801 SOUTH BROAD STREET PHILADELPHIA, PA TEL: E MAIL: wjv3@psu.edu

18 Appendices Slide 35 Appendix A National Ambient Air Quality Standards (NAAQS) Values

19 Appendix B PSD source categories with 100 tpy major source thresholds Appendix C Major source thresholds for NA areas

20 Appendix D Title V Title V operating permit program for major sources where permitting authorities issue legally enforceable documents (permits to operate). The program is commonly known as Title V because the requirements for these permits come from Title V of the Clean Air Act Amendments of Most title V permits are issued by State and local permitting authorities.. Standards for State permit programs are found in the Code of Federal Regulations at 40 CFR part 70.. However, the EPA also issues title V permits to sources in Indian country and in other situations, as needed. EPA issued permits are called part 71 permits. Major sources that become synthetic minor sources avoid Title V requirements. Appendix E Significant Emission Rates (SERs) Significant Emission Rate a rate of emissions that would equal or exceed any of the above rates. Slide 40