ENGINEERING / HEATING & COOLING
FUEL BURNERS
5 strategies for boiler or furnace users in response to NAAQS revisions
By Christine Brenk, CHMM, Kleinfelder
Many plant owners and operators are bracing for the
biggest changes to the National Ambient Air Quality Stan-
dards (NAAQS) since the Clean Air Act was first enacted
in 1972. Those who are unprepared could face significant
permitting challenges.
The Clean Air Act sets NAAQS for six principal pollutants
considered harmful to public health. These include carbon
monoxide, lead, nitrogen dioxide (NO2), ozone, particulate
matter less than 10 microns and 2.5 microns (PM10 and
PM2.5), and sulfur dioxide (SO2). At the recommenda-
tion of the Clean Air Scientific Advisory Committee, EPA
has recently promulgated regulations that lower allowable
concentrations for these pollutants. The installation of new
equipment or significant modifications to existing equip-
ment requires a demonstration of compliance with the more
stringent NAAQS as part of an air permit application prior
to constructing or modifying these emission sources.
For those plant owners and operators who operate fuel burn-
ing equipment such as large boilers or furnaces or processes
that generate these pollutants, take note that these changes,
particularly those to the NO2 and SO2 standards, have tremen-
dous permitting implications. However, a little upfront plan-
ning and a comprehensive look at five basic strategies can help
to achieve compliance within reasonable time and cost.
ONE-HOUR STANDARD ADJUSTMENTS
EPA first adopted the NAAQS for criteria pollutants in the
early 1970s, setting both a primary standard to protect health
and a secondary standard to protect the public welfare. For
NO2 , the standard was set at 0.053 parts per million (53 ppb),
averaged annually. In 2010, EPA established a new one-hour
NO2 standard at a level of 100 ppb and retained the annual
average NO2 standard of 53 ppb (Table 1).
Similarly, EPA first set the NAAQS primary 24-hour stan-
dard for SO2 at 140 ppb and an annual average standard at 30
ppb to protect public health. EPA also set a three-hour average
secondary standard at 0.5 ppm to protect public welfare. In
2010, EPA revised the primary SO2 standard by establishing
a new one-hour standard at a level of 75 ppb and revoked the
two existing primary standards (24-hour and annual).
WWW.PLANTSERVICES.COM DECEMBER 2012 29
ENGINEERING / HEATING & COOLING

POLLUTANT
Lead (ug/m3) NO2 (ppm) SO2 (ppb) 8-hr Ozone (ppb) PM2.5 (ug/m3)
500 (3-hr)
65 (daily)
OLD STANDARD 1.5 (calendar qtr.) 0.053 (annual) 140 (24-hr) 84 (0.08 ppm)
15 (annual)
30 (ann.)
0.15 (rolling 35 (daily)
0.100 (hourly) 75 (hourly) 75 (2008)
NEW STANDARD 3-month avg.) 15 (annual)
(4/12/10) (8/23/10) 60-70 (proposed)
(1/29/09) (9/21/06)

Table 1. EPA first adopted the NAAQS for criteria pollutants in the early 1970s, setting both a primary standard to protect health and a
secondary standard to protect the public welfare.

ASSESSING ATTAINMENT STATUS
When a region within a state is designated as “nonattain-
ment” with NAAQS, the state regulatory authority must
prepare a state implementation plan (SIP) that lays out the
means for bringing the area into compliance. The repercus-
sions of nonattainment for a state or region are great.
One year from the date of a nonattainment designation,
federally funded highway and transit projects will not be al-
lowed to proceed unless the state demonstrates there will be
no increase in emissions associated with the projects. State au-
thorities usually target manufacturing facilities to ratchet down
emissions, and owners/operators of emission sources will often
be subject to more restrictive permitting requirements.
In order to obtain an air permit, new and upgraded facili-
ties that are classified as “major stationary sources” located
in or near nonattainment areas are required to install lowest
achievable emission reduction (LAER) for equipment/pro-
cesses. LAER is the most effective emissions reduction con-
trols without consideration of cost. In addition, mandatory
emissions offsetting could be required. Prior to permitting the
construction of new facilities, a state must offset any emis-
sions increases by achieving reductions at existing facilities.
States are currently making changes to the network of
ambient monitoring equipment and collecting ambient data
to determine the attainment status with respect to the new
standards. Since the one-hour standards are a new require-
ment, there is uncertainty as to the compliance status of a
region with the NO2 and SO2 NAAQS.

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new standards, it is important to analyze permit strategies well
in advance. The solutions are based on site-specific conditions,
such as opportunities for fuel modifications and equipment

 modifications to reduce energy consumption, and air disper-

 sion modeling and sensitivity analyses to determine ways to

 reduce ambient concentrations at the facility’s property bound-



 ary. The following details five potential strategies to consider.


 1. Cost/no cost options

 An emission reduction option that may not have been feasible
in the past might be feasible in light of the new NAAQS. In a
Repaired or Replaced nonattainment area, LAER requirements, which are the most
 for  years, stringent emission limitations achieved in practice for such
for  reason.* class or category of source without consideration for econom-
ic impact, could be required. An investment to keep facility-
wide emissions below the “major source” thresholds under
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and see what you’ve been missing. associated with the rigorous federal permitting scheme. Ex-
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ENGINEERING / HEATING & COOLING

FOOD PROCESSING FACILITY’S NAAQS CHALLENGE AND SOLUTION 2. Energy efficiency improvements
Energy efficiency improvements can
A food processing facility was considering a major expansion that would be a benefit on several fronts. In one
increase production by approximately 30%. The facility operated three example, a facility redesigned fan
boilers, one large coal-fired boiler that was used as the primary heat blades to improve blade pitch and
source and two smaller natural gas-fired boilers that provided back-up improved the fan efficiency. The new
heat to ovens throughout the facility. Since the boilers were constructed fan design resulted in a slight increase
20 years ago, the permit was issued without a demonstration of the in manufacturing cost. However,
new NAAQS. Preliminary modeling was conducted that highlighted two this cost was offset by lower energy
challenges: background ambient data was relatively high because the use that reduced emissions below
facility was located in an urban area and the property boundary was emission thresholds of concern. The
within 150 ft of the stacks, offering very little buffer to dilute concen- initial focus was on reducing criteria
trations beyond the fenceline. pollutants, but as a bonus, the facility
To avoid the construction of costly air pollution control equipment, reduced its carbon footprint.
the plant looked at two options. The first option was to increase the use
of the existing boilers at a higher capacity. With this option, the facility 3. Fuel modifications
could retrofit the coal-fired boiler to burn natural gas and apply for a PAL If a facility is currently using coal or
permit that sets permitted emission limits at a higher level than what is fuel oil for boilers or cogeneration units,
needed for emissions associated with burning natural gas. The boiler ret- an investment to switch to a cleaner
rofit modification results in a net decrease in emissions, thereby avoiding burning fuel may become attractive on
modeling and rigorous permit submittals. If modeling was required, both several fronts. The use of a cleaner burn-
SO2 and NO2 are both significantly lower when burning natural gas, which ing fuel could allow a facility to avoid
would result in a demonstration of compliance with the NAAQS. multiple new regulatory requirements,
The second option was to construct direct-fired ovens instead of rely- including the National Emission Stan-
ing on the boilers for heat. Each of the ovens have their own associated dards for Hazardous Air Pollutants that
stack, and pollutant concentrations are diluted by virtue of lower emis- is currently being promulgated for boil-
sion rates from several stacks across the roof plain and a greater distance ers burning oil or coal; the greenhouse
to the property boundary. gas tailoring rule that requires best
In this case, the latter option was chosen as the most feasible, high- available control technology for carbon
lighting the importance of pre-planning and preliminary air dispersion dioxide and other global warming gases;
modeling. and a major source modification and the
ensuing LAER requirements altogether.

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4. Air dispersion modeling
considerations
Well in advance of a project, consider
conducting preliminary air disper-
sion modeling to assess the expected
concentrations of pollutants beyond
the property boundary and assess the
compliance status with the NAAQS.
If model compliance is not initially
demonstrated for peak or desired fa-
cility operations, a modeling sensitiv-
ity analysis could be conducted that
assesses what effect a change in certain
parameters has on off-site concentra-
tions. For example, the sensitivity
model runs would determine the effect
of raising the stack height or moving
equipment farther from the property
boundary, for better dilution and
minimizing downwash influences
from nearby building structures, on
non-compliant receptor points. One of
the benefits to conducting a sensitivity
analysis is the determination of pa-
rameters that most effectively reduce
off-site concentrations and allow for
planning of the most feasible plant
design or operations strategies.
Further, the accuracy of model in-
put parameters becomes more critical
when a facility is faced with demon-
strating compliance for a standard that
IT INFRASTRUCTURE
PERMISSION GRANTED
CO2e Emissions (TPY)
200,000
150,000
100,000
50,000
0
2004 2006 2008 2010 2012
Actual Emissions PAL Permit
Figure 1. A PAL permit is often most feasible if historic emissions from a plant are high
and then become lower for various reasons such as reduced manufacturing or use of a
cleaner burning fuel.
has become more stringent. While use assess whether the ambient concentra-
of worst-case data, such as using pub- tion of background air quality data,
lished emission factors for estimating from agency-operated monitoring
process emissions or applying readily stations, is representative of air quality
available high ambient background in the vicinity of your facility. Most
concentration data, may have allowed agencies publish background data
a facility to show compliance from from a regional network of monitors.
an historical perspective, the new Sometimes these monitors are many
tighter standards may not allow much miles away, often located in an urban
room for taking shortcuts. With these area. Often the monitors are cited as
tighter standards, it is important to part of a compliance demonstration
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ENGINEERING / HEATING & COOLING
for monitoring maximum concentra-
tions from a particular facility and
therefore are not representative of
background air quality levels. If your
plant is in a rural area and the nearest
monitor, say 15 miles from the facility,
is in an urban area, this background
data may not be appropriate to use as
part of the analysis.
The emission rates of the process/
equipment are another critical input
parameter for the model. Typically,
direct source measurements such as
stack testing can provide more accu-
rate information than other estima-
tion techniques, such as the use of
EPA’s published emission factors for
given processes. If preliminary model-
ing does not demonstrate compliance,
consider the source of the emission
information provided.
5. Plant-wide applicability limit (PAL)
For those facilities that are currently
“major sources”, a PAL permit is an
option that can allow significant flex-
ibility. This provision of the Clean Air
Act is underutilized by industry. EPA
allows a plant-wide emission limit for
one or multiple pollutants, and the limit
is set based on the highest 24-month
average emissions reported over the
past five years plus potential emissions
of processes installed after a chosen
baseline period. The limit is set for roll-
ing 12-month emission caps. As long as
a facility stays under the annual PAL for
the given pollutant, new installations
or modifications can be made without
triggering a permit review or NAAQS
compliance demonstration (Figure 1).
A PAL permit is often most feasible if
historic emissions from a plant are high
and then become lower for reasons
such as reduced manufacturing or use
of a cleaner burning fuel.
Christine K. Brenk, CHMM, is project
manager at the Charlotte, North Carolina,
office of Kleinfelder (www.kleinfelder.
com), an industrial consulting firm. She
can be reached at (704) 598-1049, ext.
©2012 The Diamond Chain Company. AD PS0022012 451, or cbrenk@kleinfelder.com.
Calculations based on a Diamond series #80 roller chain.
Test results are available at http://www.diamondchain.com/diamond-series.php.