Back in late 2012 and early 2013, the EPA finalized changes to the Clean Air Act standards for area source and major source boilers. (40 CFR 63, subparts JJJJJJ and subpart DDDDDD respectively). The deadline for completing initial tune-ups is coming up fast: March 21, 2014, and the deadline for submitting notification of compliance status for tune-ups is July 19, 2014.
Here's a recap from the RAECO Rents E-news, outlining the regulations. Most National Emission Standards for Hazardous Air Pollutions (NESHAP) requirements are operational (how often mandatory tune-ups are performed), and others are regulatory (reporting numeric rate of air toxic emissions).
Complying with EPA Rules for Toxic Boiler Emissions
According to EPA estimates, Americans will see $10 to $24 in health benefits for every dollar spent to meet the new standards. They also anticipate a reduction of more than 400,000 worker sick days annually due to the drop in toxic emissions, as compliance to the standards helps reduce medically harmful pollutants in the air.
The standards apply to two groups:
- Nearly 13,800 boilers and process heaters at refineries, chemical plants, and industrial facilities: These "major source" facilities are known to emit mercury, organic air toxics, and dioxins as their largest pollution sources, at an annual rate of 10 tons of any one toxic to 25 tons of all toxics combined.
- Nearly 187,000 boilers at universities, hospitals, hotels, and commercial buildings, "area sources" of air toxics. These boilers will be regulated based on generally available control technologies (a less stringent requirement than the original EPA plan), except for those that emit pollutants like mercury or polycyclic organic matter.
|Major Source Boilers||Area Source Boilers|
|Clean gas fuel||No numeric limitsTune-up every other year||No numeric limits Annual tune-up||Rule does not cover gas-fired area source boilers.|
|Coal||Numeric emission limits for 5 pollutants||No numeric limitsTune-up every other year||Numeric limits for 2 pollutants (3 for new boiler)|
|Biomass||New boilers: Numeric emission limit for particulate matter Existing: No numeric emission limits Tune-up every other year|
|Oil or dirty process gas|
|Compliance Dates||Existing: 3/21/2014 New: Within 15 days after startup||Existing: Tune-up required by 3/21/2012. Full compliance by 3/21/2014. New: Compliant at startup|
* Existing boilers only (in construction/use prior to June 4, 2010)
2 pollutants: Mercury, carbon monoxide
3 pollutants: Mercury, carbon monoxide, and particulate matter
5 pollutants: Mercury, carbon monoxide, particulate matter, hydrogen chloride, dioxin
Producing automated reports for EPA compliance
You can use Testo’s model 350 Advanced portable emissions analyzers during tune-up and testing, and generate your reports using their compatible software. The software suite consists of three parts: the USB driver so your PC can see the analyzer, Testo easyEmissions software for analyzer setup, real-time measurement, and data downloads, and Testo EasyReport, which takes the data and plugs it into Excel for simple, automated reporting.
The basic module of easyReport will log measurement data into Excel. The reporting module (locked by default, and requires registration with Testo for full operation), adds more compliance-reporting functionality.
Testo 350 and Reciprocating Internal Combustion Engines
The 350 analyzer is also great for EPA reporting on performance and emissions on major and area source internal combustion engines. Here's the recap of some key features Testo added to help with reciprocating internal combustion engine (RICE) compliance reporting.
RICE are common combustion sources that can have a significant impact on air quality and public health. Air toxins emitted from stationary engines include formaldehyde, acrolein, acetaldehyde and methanol. Toxic exposure may produce a variety of health difficulties including irritation of the eyes, skin and mucous membranes, and central nervous system problems. RICE engines also emit the conventional air pollutants created when fuel is burned including carbon monoxide (CO), nitrogen oxides (NOx), volatile organic compounds (VOCs), and particulate matter (PM). The health effects of these pollutants include a range of respiratory (breathing) issues, especially asthma among children and seniors.
Comply with Clean Air Act engine testing regulations
I read through National Emission Standards for Hazardous Air Pollutions (NESHAP) 40 CFR 63 Subpart ZZZZ (quad Z), and the New Source Performance Standards (NSPS) 40 CFR 60 Subpart JJJJ (quad J) to understand the requirements, and I realized that I might never fully understand the fine details of the Clean Air Act and how it applies to our customers.
But, what is becoming clear to me is that Testo has designed features into their 350 emissions analyzer to help customers more easily easily test and record for compliance to these latest regulations. The 350 electrochemical emissions analyzer can greatly reduce the hardware and software needed, and make datalogging and review easier.
The new regulation requires pre- and post-catalyst testing of the exhaust gas on a simultaneous basis. The typical solution in the past was to use two separate trucks with separate analyzers. Separate data acquisitions systems were also used to join the data for review and reporting.
With the Testo 350, two analyzers can be linked to display the catalyst measurements. It's simple, and the system cost is substantially lower than the traditional trailer mounted testing rigs.
It starts by connecting two probes and analyzer boxes to the exhaust stack. Each analyzer is specifically configured for the different gas conditions found in pre- and post-catalyst exhaust gas. Then both analyzers are connected to the handheld control unit. The high definition graphic display in the control unit shows the side-by-side measurements.
When you know the actual pre- and post-catalyst measurement in real time, data collection and interpretation is much easier. The next critical requirement, managing data, uses Testo easyEmission software’s power. It can display the simultaneous measurements in a variety of formats with simple two analyzer operation, it has the ability to display measurements of up to 16 analyzer boxes for the ultimate in simultaneous, multi-unit testing.
Our partners at Raeco.com have some great materials about using Testo easyEmissions software for engine testing. Watch a pre-recorded webinar and download the slides to learn more.
Want to learn more about the new standards for engine testing? Read more at EPA.gov.