Air Curtain Incinerators

Transcription

1 BOARD PACKET ~ Page 86 of 215 Air Curtain Incinerators Alan Abbs Executive Director California Air Pollution Control Officers Association

2 BOARD PACKET ~ Page 87 of 215 What Are Air Curtain Incinerators? 1. Air curtain burner manifold and nozzles directing high velocity air flow 2. Refractory lined wall for self contained ACD or earthen wall for trench ACD 3. Waste material to be burned 4. Air flow forms a high velocity "curtain" over fire 5. Continued air flow overoxygenates fire keeping temperatures high and higher temperatures provide cleaner burn and more complete burn

3 BOARD PACKET ~ Page 88 of 215

4 BOARD PACKET ~ Page 89 of 215 Why use ACIs over Open Pile Burning? ACIs control emissions better than open pile burning by using forced air. Feed rate is more controllable. Fire is more contained. Operators can respond faster to changing weather using semienclosed device.

5 BOARD PACKET ~ Page 90 of 215 Current Status of ACIs in California ACIs have been intermittently permitted in California at the local district level for the last decade Use has been limited to State Parks, a few private operators, and an occasional USFS ACI. District permitting has varied from requiring only an agricultural burn permit, to a full authority to construct/permit to operate process, to a notification with no permit. Depends on status of attainment for ozone and particulate standards, existing district requirements, location of device usage, and district discretion. During Tree Mortality Emergency, CalFire purchased 10 ACIs. USFS additionally may bring units in from other parts of the country. Question was raised about permitting, notification, and consistency between districts on allowing operation in order to allow movement through different parts of the state.

6 BOARD PACKET ~ Page 91 of 215 Sounds Easy, BUT USEPA Region 9 informed CAPCOA and districts that New Source Performance Standards issued in 2006 require Title V Permits for Air Curtain Incinerators. 40 CFR 60 Subpart EEEE requires operation of ACIs that burn 35 tons or less of clean wood waste to have a Title V permit that includes opacity limits, monitoring and recordkeeping. Allows for a temporary 8 week exemption during emergencies upon request, and an additional 8 week exemption upon a second timely request, then a permit application is required. Letter dated April 12, 2016 from USEPA to CAPCOA provided 8 week exemption and contemplated an additional year to require ACIs to submit application because CalFire devices had not been previously subject to regulation. Districts would have time per Title V program to process and issue Title V permit. 8 week clock (and additional year) theoretically does not start until devices get first used To date, we are not aware that devices have triggered this clock.

7 BOARD PACKET ~ Page 92 of 215 Developing the Permit Easier said then done If a district issued a district specific permit, a device could not travel to another district and operate without getting a new permit. Title V permits themselves are complicated, require public notification, and require review by EPA staff before issuing. EPA has suggested a general permit which is used by many states to streamline certain Title V permits that may require less rigorous analysis. A general permit application and permit could be developed for use statewide that would be accepted at every district, if every district could agree on the forms and could incorporate their local conditions into the final permit. Process would likely still require one time notification to inform public of the existence of the general permit process. CAPCOA would likely form a group to develop the documents, or it could be developed and hosted by an individual district, such as San Joaquin.

8 BOARD PACKET ~ Page 93 of 215 Tree Mortality Task Force Activities Regulations Workgroup Developed proposed letter for Governor s signature, to EPA Headquarters, to request a long term exemption. Duration to be 5 years or until end of Emergency. Cited bureaucratic burden of Title V process on a process that is being used to reduce pollution impacts of open burning. California Health and Safety Code Section already allows APCOs to permit mechanized burners to process clean wood waste subject to opacity requirements. Given that district regulations require recordkeeping and monitoring within existing ag burning and prescribed fire programs, Title V requirement does not appear to reduce emissions or impacts to public health. Governor has not yet signed letter.

9 BOARD PACKET ~ Page 94 of 215 Questions? Thank you Alan Abbs Executive Director California Air Pollution Control Officers Association