October 12, 2011

Virtually all states that have nonattainment areas for ozone have passed a rule called nitrogen oxide (NOx) Reasonably Achievable Control Technology (RACT). With many regions not in attainment for ozone approaching 4 decades, several states have or are considering toughening this rule to reduce NOx emissions, a precursor for ozone. In New York, the NOx RACT rule, found in 6NYCRR Part 227-2, was amended in 2010. All large combustion sources must meet these “reasonable” standards, defined as standards that are technologically achievable and not overly expensive.

The revised rule in New York (which may be adopted by other states) contains new NOx emission limits for different fuels for different-sized boilers, any boiler with a maximum heat input of 25 mmBtu/hr or greater. Any boiler below that level must undergo a formal annual tune-up. The revised NOx RACT rule contains more stringent NOx emission limits, which will go into effect on July 1, 2014, for combustion of coal and of No. 6 fuel oil are particularly stringent. A number of boiler and burner vendors have told me that their equipment simply cannot meet the new limits. This is particularly telling as equipment vendors are usually optimistic that their units can meet stringent standards. If they admit their equipment cannot, then it really is believable that the limits cannot be met. Therefore, New York State may be using NOx RACT as a means of virtually eliminating the use of coal and No. 6 fuel oil altogether in the state.

What is a facility to do? First, one must recognize that this rule must be addressed promptly. Even a deadline date several years down the road gives little time to waste because of the time necessary to strategize, design, and order new equipment. In New York, the time is now. If a facility operates boilers combusting coal and/or No. 6 oil, it needs to review any old stack tests to determine how the units have performed in the past. It is likely that emissions measured would not meet the future limits. Simply saying that you will “clean the tubes” or otherwise tune-up your units will probably not achieve compliance. And as you saw above, even installing more modern burners will likely not achieve compliance either. So what are your choices? De-rating boilers such that they would be exempt from emission limits could work – if this gives you the proper operating flexibility. Proof of de-rating by some type of physical fuel flow restriction, such as a plate or nozzle, may be necessary. Another possibility is fuel switching to a different fuel and burner upgrades to attain the emission standard. Fuel switching will also cause decreases in emissions of other pollutants and CO2, a greenhouse gas.

CCES can help your facility in any state assess the NOx emissions of your boilers and strategize cost-effective options to lower them to comply with future regulations.

On July 6, 2011, the USEPA finalized a rule intended to reduce emissions from power plants of fine particulate matter and pollutants that are precursors to smog, indicated by ambient ozone. This new Cross-State Air Pollution Rule (CSAPR) will replace current Clean Air Interstate Rule (CAIR) on Jan. 1, 2012, and will require 27 states to regulate power plant emissions that are normally transported to and affect other states.

The Problem

Recent medical research is demonstrating that emissions of fine PM (particles with an aerodynamic diameter of 2.5 microns or less, PM2.5) may be causing greater adverse health effects in the U.S. than previously thought. PM2.5 can penetrate past our natural defenses (i.e., bronchial tube cilia) and get lodged within lung vesicles, in many cases leading to their reduced function. Also, with a large surface area to volume, PM2.5 can attract and ultimately transport other toxic pollutants deep into the lungs which can then be exchanged into our bloodstream for transport throughout the body. Some examples include sulfur dioxide (SO2, which in our blood is converted to the acidic form, sulfuric acid) and metals, causing greater exposure to these than in a PM2.5-free environment.

Nitrogen oxides (“NOx”) are known precursors of smog. Catalyzed by the sun, smog is composed of thousands of compounds, many of them toxic. Ozone is a lung irritant.
The Clean Air Act requires states generate real-time data of ambient air concentrations of these pollutants to determine whether regions attain national ambient air quality standards (NAAQS) or not. Much of the U.S. is non-attainment for ozone NAAQS, and has been so for decades despite stringent rules to reduce NOx emissions. There is evidence that continued elevated ozone levels are due to transport of NOx from other states, many of which are in attainment with ozone NAAQS and have little reason to stringently regulate emissions from power plants, a major source of these compounds.

What CSAPR Intends to Achieve

Basic information about CSAPR, including which states are covered, may be found at: http://www.epa.gov/airtransport/basic.html. CSAPR requires 23 states to reduce annual SO2 and NOx emissions to help downwind areas attain the PM2.5 NAAQS. 20 states are required to reduce NOX emissions during peak (summer) ozone season only to help downwind areas attain the 8-hour ozone NAAQS. CSAPR divides the states required to reduce SO2 into two groups with Group 1 states required to achieve additional emission reductions by 2014 because of their large contribution to downwind air quality problems.
CSAPR allows allowance trading among covered sources, utilizing an allowance market infrastructure based on allowances given to states based on the estimated baseline downwind impacts of their sources. The final rule allows sources to trade emission allowances with other sources within the same program (i.e., ozone season NOx) in the same or different states, while firmly constraining emission trading that may occur by requiring a strict emission limit in each state based on its budget plus a variability limit.

For prompt implementation, the USEPA is adopting a federal implementation plan (FIP) for each affected state; a state may replace its FIP with a State Implementation Plan (SIP) should it choose by 2014. The rule allows a state to modify its FIP, such as allowance allocations (crediting sources for allowances banked under earlier programs).

What This Means

As is commonplace in these days of political attacks on the USEPA, the agency has published substantial data to justify the new CSAPR on sound economic and health bases. According to the USEPA, CSAPR will, by 2014, reduce SO2 emissions from target power plants by 73% and NOx by 54% (2005 baseline) and annually avoid:
• 13,000 to 34,000 premature deaths
• 19,000 hospital and emergency room visits
• 1.8 million lost work days or school absences

Emission reductions will also lead to improvements in visibility in parks, and increased protection for ecosystems including lakes, streams, coastal waters, and forests.
The USEPA estimates that, by 2014, CSAPR will result in $120-$280 billion in annual health benefits, far outweighing its estimated additional annual cost of $800 million.

Get more useful information in our blog: www.CCESworld.com/blog
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This Environmental News for You is meant to provide background on the new CSAPR. Please obtain specific legal and technical advice before addressing specific provisions. CCES experts can help you in the technical aspects of your Air compliance program.