A variety of combustion sources are used to power and heat drinking water and wastewater facilities. For example, back-up generators and reciprocating engines find wide application in municipal water supply and wastewater treatment heat and power generation. These sources are now regulated by the U.S. Environmental Protection Agency (EPA) and may require additional permits from the Department for Environmental Protection. These issues are addressed in the following article, which was published in the winter 2012 issue of Land, Air & Water by Kenya Stump, manager of the Division of Compliance Assistance’s Environmental Assistance Branch.
Often Overlooked Combustion Sources Now Regulated by the EPA
Whether it is a boiler located at a school or a back-up emergency generator located at a wastewater treatment plan, combustion sources come in a variety of forms. These combustion sources, through the burning of fuel, emit pollutants including air toxics. In recent years, the U.S. Environmental Protection Agency (EPA) as part of its Urban Air Toxics Strategy has issued regulations affecting these types of sources that may have previously been considered insignificant or “exempt.” The National Emission Standards for Hazardous Air Pollutant (NESHAP) Area Source Rules focus on those sources that emit less than 10 tons annually of a single hazardous air pollutant or less than 25 tons annually of a combination of hazardous air pollutants. Such sources are often overlooked because of their physical location or the size and type of unit. For many people, air quality regulations are those that affect manufacturing facilities or other industrial activities, but these new NESHAP regulations can affect sources located at sources not traditionally thought of as air pollutant sources, such as hospitals, schools or municipal governments, for example.
40 CFR Part 63, subpart ZZZZ (NESHAP Area Source RICE Rule)
A stationary reciprocating internal combustion engine (RICE) is any internal combustion engine that uses reciprocating motion to convert heat energy into mechanical work and is not mobile. In general industry, these engines provide shaft power to drive process equipment, compressors, pumps, standby generator sets and other machinery. Agricultural uses are similar, with many engines driving irrigation pumps. Reciprocating engines find wide application in municipal water supply and wastewater treatment and in commercial and institutional emergency power generation. In 2010, the EPA amended existing regulations for these types of engines to include all horsepower engines located at area sources, but did exempt those engines under this regulation located at existing institutional, commercial or residential facilities. For those sources affected by this rule, requirements may include compliance with emission and work practice standards, as well as recordkeeping and reporting requirements. If you are a source that thinks you may be affected, please contact the Environmental Compliance Assistance Program at 800-926-8111 or via email at envhelp@ky.gov. For more information on this rule, please visit the EPA’s Combustion Portal at http://www.combustionportal.org/rice.cfm.
40 CFR Part 63, subpart JJJJJJ (NESHAP Area Source Boiler Rule)
Industrial, Commercial, and Institutional (ICI) boilers can use a number of different fuels including coal (bituminous, sub bituminous, anthracite, lignite), fuel oil, natural gas, biomass (wood residue, bagasse), liquefied petroleum gas and a variety of process gases and waste materials. These boilers are often used to produce heat indirectly for uses in process machinery, as comfort heating, for hot water, and for steam for electricity. The National Emission Standards for Hazardous Air Pollutants (NESHAP) for area source boilers was published in the Federal Register on March 21, 2011, and became effective on May 20, 2011. This rule covers boilers located at area source facilities that burn coal, oil, or biomass or nonwaste materials. For those sources affected by this rule, requirements may include compliance with emission and work practice standards, pollution prevention audits, testing and tune-ups, as well as recordkeeping and reporting requirements. If you are a source that thinks you may be affected, please contact the Environmental Compliance Assistance Program at 800-926-8111 or via email at envhelp@ky.gov. For more information on this rule, please visit the EPA’s Boiler Compliance page at http://www.epa.gov/boilercompliance/.
Other Reminders
The above regulations are not inclusive of all combustion-related regulations that could apply to your facility. If you are a facility that has combustion sources, you are encouraged to evaluate all air pollution sources at your facility, even noncombustion sources, to determine if additional regulations apply and/or if you may need an air quality permit from the Kentucky Division for Air Quality. For information on the Kentucky Division for Air Quality, please visit http://air.ky.gov/Pages/default.aspx. For assistance related to your regulatory obligations, please visit http://dca.ky.gov/complianceassistance/Pages/default.aspx or via email at envhelp@ky.gov.
Kenya Stump
Environmental Assistance Branch Manager
Division of Compliance Assistance
Operation Matters 