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INDUSTRIAL BOILERS

CUSTOMIZED ENVIRONMENTAL
TRAINING

WELCOME
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INSTRUCTOR

Insert Instructor Name Here

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OBJECTIVES
 Define Industrial Boiler Size.
 Discuss How Nitrogen Oxide (NOx) is Formed.
 Discuss Factors Affecting NOx.
 Discuss Boiler Operational Factors.
 Discuss NOx Controls.
 Discuss Other Environmental Considerations Concerning
Boilers.
 Discuss Burning Hazardous Waste in Boilers.
 Discuss Boiler Safety Precautions.
 Outline Safety and Environmental Inspection Items.
 Discuss Monitoring Requirements.
 Discuss Use of Contractors.
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GOALS

 Be Familiar With Records to Maintain.


 Understand What Is Considered an Industrial Boiler.
 Understand How Nitrogen Oxide (NOx) is Formed.
 Understand the Factors Affecting NOx.
 Be Familiar With Boiler Operational Factors.
 Understand the Different NOx Controls.
 Be Familiar With Other Environmental Considerations
Concerning Boilers.
 Understand the Requirements for Burning Hazardous Wastes.
 Be Familiar With Boiler Safety Precautions.
 Be Familiar With Safety and Environmental Inspection Items.
 Be Familiar With Monitoring Requirements.
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BACKGROUND
 In 1999, there were 5,489,423 tons of Nitrogen Oxide
(NOx) emitted into the atmosphere by industrial boilers.
NOx is instrumental in smog and acid rain formation
 On November 3, 1999, the Justice Department filed
seven lawsuits against electric utilities in the Midwest and
South charging them with violations of their NOx boiler
emissions
 43% of all boilers are subject to Nitrogen Oxide (NOx)
emission limits

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LEARNERS
 Supervisors
 Facility Engineers
 Maintenance Personnel
 Department Managers
 Building Occupants
 Process Specialists
 Environmental and Safety Committees

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OVERVIEW

The goal of this course is to provide supervisors


with the tools needed to properly manage industrial
boilers. It recommends practical, actions that can be
carried out by facility management, maintenance
personnel and building occupants. The course will
help you to integrate good industrial boiler
management activities into your existing
organization and identify which of your staff have
the necessary skills to carry out those activities.

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WHAT THIS COURSE DOES NOT DO

The course is not intended to provide information to


repair industrials boilers or to install or repair
monitoring equipment or control devices. These
specialties required training beyond the intended
scope of this course. Where this expertise is
needed, outside assistance should be solicited.

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CLEAN AIR ACT

 Clean Air Act Amendments (CAAA) of 1990,


amended Title I of the Clean Air Act (CAA) to address
ozone nonattainment areas
 Stationary sources that emit oxides of nitrogen (NOx)
which emit or have the potential to emit 25 tons per year
or more of such air pollutant

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APPLICABLE REGULATIONS

 40 CFR 63 – National Emission Standards For


Hazardous Air Pollutants For Source Categories

 40 CFR266-- Subpart H--Hazardous Waste Burned in


Boilers and Industrial Furnaces

 40 CFR 76 – Acid Rain Nitrogen Oxides Emission


Reduction Program

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INDUSTRIAL BOILERS

 Industrial boilers have been identified as a category


that emits more than 25 tons of oxides of nitrogen
(NOx) per year
 Boilers include steam and hot water generators with
heat input capacities from 0.4 to 1,500 MMBtu/hr (0.11
to 440 MWt).
 Primary fuels include coal, oil, and natural gas
 Other fuels include a variety of industrial, municipal,
and agricultural waste fuels

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BOILER SIZES

 Industrial boilers generally have heat input capacities


ranging from 10 to 250 MMBtu/hr (2.9 to 73 MWt). The
leading user industries of industrial boilers, ranked by
aggregate steaming capacity, are the paper products,
chemical, food, and the petroleum industries
 Those industrial boilers with heat input greater than
250 MMBtu/hr (73 MWt) are generally similar to utility
boilers
 Boilers with heat input capacities less than 10
MMBtu/hr (2.9 MWt) are generally classified as
commercial/institutional units

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HOW NOx IS FORMED

 NOx is a high-temperature byproduct of the


combustion of fuels with air
 NOx formation in flames has two principal sources
1. Thermal NOx is that fraction of total NOx that results
from the high-temperature reaction between the
nitrogen and oxygen in the combustion air
The rate of thermal Nox formation varies exponentially
with peak combustion temperature and oxygen
concentration
 When low-nitrogen fuels such as natural gas, higher
grade fuel oils, and some nonfossil fuels are used,
nearly all the NOx generated is thermal NOx

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HOW NOx IS FORMED

2. Fuel NOx is that fraction of total


NOx that results from the
conversion of organic-bound
nitrogen in the fuel to NOx
 When coal, low-grade fuel oils,
and some organic wastes are
burned, fuel NOx generally
becomes more of a factor because
of the higher levels of fuel-bound
nitrogen available

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PARAMETERS AFFECTING NOx

Principal among these are:


 The heat release rates and absorption profiles in the
furnace
 Fuel feed mechanisms
 Combustion air distribution
 Boiler operating loads

For example, steam pressure and temperature


requirements may mandate a certain heat release rate
and heat absorption profile in the furnace which changes
with the load of the boiler.

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PARAMETERS AFFECTING NOx

 Solid fuels can be introduced into the


furnace in several ways, each
influencing the rate of mixing with
combustion air and the peak combustion
temperature
 These parameters are very unit
specific and vary according to the design
type and application of each individual
boiler
 NOx emissions from boilers tend to be
highly variable.

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FACTORS AFFECTING NOx

The ranges in baseline NOx emissions


for boilers are due to several factors
including:
 Boiler design
 Fuel type
 Boiler operation

These factors usually influence baseline


NOx in combination with each other,
and often to different degrees
depending on the particular boiler unit.

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BOILER DESIGN TYPE

 The firing type of the


boiler influences the
overall NOx emission
level
 Even within a
particular type of boiler,
other design details may
influence baseline NOx

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BOILER DESIGN TYPE

For Pulverized Coal:


Boiler Type Average lb of NOx / MM Btu
Tangential 0.61
Wall-Fired 0.69
Cyclone 1.12

 Low NOx Burners, Natural Gas Reburning, and Low


NOx Burners with Staged Combustion Air are effective in
controlling NOx in these units

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BOILER DESIGN TYPE

For Coal:
Boiler Type Average lb of NOx / MM Btu
Overfeed Stoker 0.29
Circulating Fluidized Bed Combustion (FBC) 0.31
Bubbling FBC 0.32
Underfeed Stoker 0.39
Spreader Stoker 0.53

 Air staging in coal-fired FBC boilers is very effective in


reducing NOx from these units

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BOILER DESIGN TYPE

For Residual Oil:


Boiler Type Average lb of NOx / MM Btu
Firetube 0.31
Watertube (10-100 MM Btu/hr) 0.36
Watertube (>100 MM Btu/hr) 0.38

 Low NOx Burners, Flue Gas Recirculation, and Staged


Combustion Air have shown some reduction in NOx for
residual oil

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BOILER DESIGN TYPE

For Distillate Oil:


Boiler Type Average lb of NOx / MM Btu
Watertube (10-100 MM Btu/hr) 0.13
Firetube 0.17
Watertube (>100 MM Btu/hr) 0.21

 Low NOx Burners, Flue Gas Recirculation, and the


combination of Low NOx Burners with Flue Gas
Recirculation are used to control Distillate Oil NOx

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BOILER DESIGN TYPE

For Natural Gas:


Boiler Type Average lb of NOx / MM Btu
Firetube 0.10
Thermally Enhanced Oil Recovery
(TEOR) Steam Generator 0.12
Watertube (10-100 MM Btu/hr) 0.14
Watertube (>100 MM Btu/hr) 0.26

 Low NOx Burners, Flue Gas Recirculation, and Staged


Combustion Air and combinations of these methods are
all effective in reducing NOx for natural gas

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FUEL CHARACTERISTICS

 Boiler baseline NOx emissions are highly influenced


by the properties of the fuels burned
 Among each of fuel types, emissions will depend on
highly variable factors such as fuel grade and fuel
source
 In particular, studies have shown that fuel nitrogen
content — and for coal the oxygen content and the ratio
of fixed carbon to volatile matter — are key factors
influencing NOx formation

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FUEL CHARACTERISTICS

Nitrogen Content of Fuels

The following table gives ranges of nitrogen content for


different fuels:

Fuel % by Weight
Coal .8 – 3.5
Residual Oil .36
Distillate Oil <0.01
Natural Gas 0 – 12.9

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FUEL CHARACTERISTICS

Sulfur
Sulfur can combine with oxygen and water to form Sulfuric
Acid, H2SO4
Fuel % of Sulfur
Coal 1-4
Residual Oil 1.3
Distillate Oil .72
Natural Gas <0.001

Although lower sulfur content generally means lower


nitrogen, there is no apparent direct relationship between
these two fuel oil parameters

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FUEL CHARACTERISTICS

Fuel Ratio
 Fuel ratio is defined as the ratio of a coal's fixed carbon to
volatile matter
 Under unstaged combustion conditions, lower fuel ratios
(i.e. higher volatile content of the coal) correlate to higher
levels of NOx, because with higher volatile content coals,
greater amounts of volatile nitrogen are released in the high
temperature zone of the flame where sufficient oxygen is
present to form NOx
 Firing coal with high volatile content and lower fixed
carbon generally results in less solid carbon to be burned out
in the post-flame gases, meaning that the coal can be fired at
lower excess air before combustible losses became a
problem

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FUEL CHARACTERISTICS

Moisture
 Moisture content plays an important role
in the formation of uncombustible emissions
in Municipal Solid Waste boilers
 Non-combustible content of Municipal
Solid Waste can range from 5 to 30 percent
 Moisture content of Municipal Solid
Waste can range from 5 to 50 percent
 Nitrogen contents of Municipal Solid
Waste can range between 0.2 and 1.0
percent

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BOILER HEAT RELEASE RATE

 Boiler heat release rate per furnace area is another


influential variable affecting NOx formation
 As heat release rate increases, so does peak furnace
temperature and NOx formation
 Boiler heat release rate varies primarily with:
 Boiler firing type
 Primary fuel burned
 Operating load
 Boiler heat release rate per unit volume is often
related to boiler capacity

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BOILER OPERATIONAL FACTORS

 Chief among these operational factors are


the amount of excess oxygen in the flue
gases and the combustion air temperature
 Excess oxygen refers to the oxygen
concentration in the stack gases, and is
dependent on the amount of excess air
provided to the boiler for combustion
 Combustion air temperature, meanwhile,
is dependent on the degree of air preheat
used before the air is introduced into the
furnace or burner
 Air preheat is usually used to increase
furnace thermal efficiency

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BOILER OPERATIONAL FACTORS

 Operation on low excess oxygen or air is therefore


considered a fundamental part of good combustion
management of boilers
 Many boilers are typically fired with excess oxygen
levels which are more than adequate to assure
complete combustion and a margin of safety
 Units often are operated at unnecessarily high excess
oxygen levels that result in unnecessarily high NOx
emissions and losses in efficiency
 The greater degree that the air is preheated, the
higher the peak combustion temperature and the higher
the thermal NOx

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CONTROLS

 Retrofitting existing generating units with low-


NOx burners is the most frequently chosen
compliance control because it is an economical
way to limit the formation of NOx
 Low-NOx burners control fuel and air mixing
to create larger and more branched flames,
reduce peak flame temperatures and lower the
amount NOx formed
 The improved flame structure also improves
burner efficiency by reducing the amount of
oxygen available in the hottest part of the flame

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CONTROLS

In principle, there are three stages in a conventional low-


NOx burner:
1. Combustion - combustion occurs in a fuel-rich, oxygen-
deficient zone where the NOx is formed
2. Reduction - where hydrocarbons are formed and react
with the already formed NOx
3. Burnout - internal air staging completes the
combustion. Additional NOx formation occurs in the third
stage, but it can be minimized by an air-lean environment

Low-NOx burners can also be combined with overfire


air technologies to reduce NOx further

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CONTROLS

Natural Gas Reburning


 Another combustion modification technique involves
the staging of fuel, rather than combustion air
 By injecting a portion of the total fuel input downstream
of the main combustion zone, hydrocarbon radicals
created by the reburning fuel will reduce NOx emission
emitted by the primary fuel
 This reburning technique is best accomplished when
the reburning fuel is natural gas
 Application of these techniques on boilers has been
limited to some municipal solid waste (MSW) and coal-
fired stokers

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CONTROLS

Staged Combustion Air (SCA)


 A technique that reduces flame temperature and
oxygen availability by staging the amount of combustion
air that is introduced in the burner zone
 SCA can be accomplished by several means.
 For multiple burner boiler, the most practical approach
is to take certain burners out of service (BOOS) or biasing
the fuel flow to selected burners to obtain a similar air
staging effect
 Generally, SCA is not considered viable for retrofit to
packaged boiler units due to installation difficulties.

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CONTROLS

Flue Gas Recirculation (FGR)


 Involves recycling a portion of the combustion gases
from the stack to the boiler windbox
 These low oxygen combustion products, when mixed
with combustion air, lower the overall excess oxygen
concentration and act as a heat sink to lower the peak
flame temperature and the residence time at peak flame
temperature
 These effects result in reduced thermal NOx formation.
 It has little effect on fuel NOx emissions
 FGR is currently being used on a number of watertube
and firetube boilers firing natural gas

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CARBON MONOXIDE (CO)

 The CO emissions from boilers are normally near


zero, with the exception of a few boilers that have poor
combustion air control or burner problems
 Oil-fired units were found to have the lowest baseline
CO emissions than either coal- or gas-fired units
 CO emissions are generally caused by poor fuel-air
mixing, flame quenching, and low residence time at
elevated temperatures
 In some furnace designs, CO emissions can also
occur because of furnace gas leaks between furnace
tubes

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OTHER AIR POLLUTANTS

 Other air pollution emissions that are a concern when


NOx controls are applied to boilers are: ammonia (NH)
and nitrous oxide (NO), unburned hydrocarbon (HC),
particulate matter (PM), and air toxic emissions
 Ammonia and NO emissions are associated with the
use of the Selective Non-Catalytic Reduction (SNCR)
controls and with Selective Catalytic Reduction controls
to a lesser extent. With either urea or ammonia
hydroxide, unreacted ammonia emissions escape the
SNCR temperature window resulting in direct emissions
to the atmosphere

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OTHER AIR POLLUTANTS

 Increases in HC, particulate matter (PM) and air toxic


emissions are primarily of concern with the application
of combustion modification controls
 HC emissions do not change when NOx controls are
implemented
 HC emissions are the result of poor combustion
conditions such as inefficient fuel-air mixing, low
temperatures, and short residence time
 These emissions are most often preceded by large
increases in CO, soot, and unburned carbon content
 By limiting CO, smoke and unburned carbon in the
flyash, HC emissions are also suppressed

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OTHER AIR POLLUTANTS

Studies of industrial boilers and particulate matter (PM)


reveal the following trends:
 Low excess air reduced PM emissions on the order of
30 percent
 Staged combustion air increased PM by 20 to 95
percent
 Burner adjustments and tuning had no effect on PM
 Lower CO emission levels generally achieved with
these adjustments would tend to lower PM as well
 Flue gas recirculation resulted in an increase in PM
from oil-fired packaged boilers by 15 percent over
baseline levels

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SOLID WASTE

 NOx reduction techniques that have a


potential impact on the disposal of solid waste
are combustion controls for Pulverized Coal-
fired boilers and flue gas treatment systems
for all applicable boilers
 Combustion controls for Pulverized Coal-
fired boilers are principally Low NOx Burners.
These controls can result in an increase in the
carbon content of flyash that can preclude its
use in cement manufacturing.

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WATER USE AND WASTEWATER

 The only increase in water use is


associated with the use of Water
Injection or Steam Injection and
potentially with the use of flue gas
treatment NOx controls, especially
Selective Non-Catalytic Reduction
 The amount of water used does
often not exceed 50 percent of the
total fuel input on a weight basis

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HAZARDOUS WASTE

 Catalysts used in the Selective Catalytic Reduction


process can be hazardous
 Examples are vanadia and titania catalysts
 Many catalyst vendors recycle this material thus
avoiding any disposal problem for the user
 Some of the catalysts, especially those that use rare
earth material such as zeolites, are not hazardous and
their disposal does not present an adverse impact

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BURNING HAZARDOUS WASTE

 40 CFR 266.100, Subpart H allows


for burning hazardous waste in
industrial boilers
 Prior to burning hazardous waste in
a boiler, owner/operators must receive
a permit
 The destruction of hazardous waste
in a boiler is considered treatment
 A hazardous waste analysis must
be performed prior to receiving a
permit

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BURNING HAZARDOUS WASTE

General Requirements – Fugitive emissions.


Fugitive emissions must be controlled by:
(A) Keeping the combustion zone totally sealed against
fugitive emissions; or
(B) Maintaining the combustion zone pressure lower
than atmospheric pressure; or
(C) An alternate means of control demonstrated to
provide fugitive emissions control equivalent to
maintenance of combustion zone pressure lower than
atmospheric pressure.

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BURNING HAZARDOUS WASTE

General Requirements – Automatic waste feed cutoff


 A boiler must be operated with a functioning system
that automatically cuts off the hazardous waste feed
when operating conditions deviate
 The permit limit for minimum combustion chamber
temperature must be maintained while hazardous waste
or hazardous waste residues remain in the combustion
chamber
 Exhaust gases must be ducted to the air pollution
control system
 Operating parameters for which permit limits are
established must continue to be monitored

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BURNING HAZARDOUS WASTE

General Requirements – Changes


 A boiler must cease burning hazardous
waste when changes in combustion
properties, or feed rates of the hazardous
waste, other fuels, or industrial furnace
feedstocks, or changes in the boiler or
industrial furnace design or operating
conditions deviate from the limits as
specified in the permit.

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ASBESTOS

 Asbestos was used in fire brick and gunnite used for


internal insulation of boilers and other vessels
 Asbestos is dangerous when it becomes “friable”
 Asbestos materials are health hazards because:
•Inhaled asbestos fibers can be trapped in the lungs
•Inhaled asbestos fibers have been linked to cancerous
cell growth in the lungs
 If asbestos is in your older boiler, have workman
alerted to its presence. Any friable asbestos should be
removed by qualified workers.

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BOILER SAFETY PRECAUTIONS

Safety Precautions
 An overheating boiler can quickly be identified by steam
or a mixture of steam and water being discharged at the
safety relief valve or from an open hot water faucet
 If this condition is found at a faucet, close the faucet
 Immediately shut down the water heater's source of
heat
 Allow the water heater to cool naturally without the
addition of excess cold water

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BOILER SAFETY PRECAUTIONS

An overheating boiler may exhibit the


following conditions:
1. A discharging safety relief valve.
2. Pressure and/or temperature
readings above the maximum
allowed for the boiler.
3. Low or no water in boilers
equipped with water-level gage
glasses.
4. Scorched or burning paint on the
skin casing.

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BOILER SAFETY PRECAUTIONS

When a water heater or boiler is


overheating, the only safe intervention is
to remove the heat source by stopping
the supply of fuel or air.
1. Do not try to relieve the pressure.
2. Do not add cool water into the vessel.
3. Do not try to cool the vessel with
water.
Let the vessel cool down naturally. Get
away from the vessel. Call a qualified
repair company.

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SAFETY INSPECTION ITEMS

1. Exterior shell and/or insulation - Look for indications


of overheating
2. Leaks - Look for water on the floor or steam escaping

3. Flue gas leaks - Look for black dust (soot) around


sheet-metal joints
4. Controls - Look for open panels, covers, and signs of
rewiring on floor or bottom of panels
5. Electrical - Ensure that covers are installed on
overlimit switches, temperature sensors, and controls

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SAFETY INSPECTION ITEMS

6. Safety valves - Ensure that a safety valve is installed


with full-sized discharge piping properly supported and
directed to a point of safe discharge
7. Fuel sources - Check for the ability to shut off the fuel
source to the vessel
8. Gauges - Make sure temperature and pressure
gauges are operational and are located for proper
monitoring
9. Proper piping - Check for proper supports and
allowance for expansion and contraction
10. Operating certificate - Observe certificate noting last
date of inspection and expiration date when required

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ENVIRONMENTAL INSPECTION
ITEMS
 Post a copy of the air operating permit near the boiler
 All boiler operators know how to operate the boiler
within the permit limits
 At the beginning of each shift, make sure the
equipment is operating properly
 Boiler operators should be familiar with the boiler’s
operating and maintenance manual
 Regular service should be performed on schedule
and recorded
 Operating records and inspection records should be
reviewed regularly to ensure compliance

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MONITORING REQUIREMENTS

 EPA’s Acid Rain Program has established special


monitoring and reporting requirements for all units over
25 megawatts and new units under 25 megawatts that
use fuel with a sulfur content greater than .05 percent by
weight
 The new units under 25 megawatts using clean fuels
are required to certify their eligibility for an exemption
every five years
 All existing coal-fired units serving a generator greater
than 25 megawatts and all new coal units must use CEM
for SO2, NOx, flow, and opacity.
 Units burning natural gas may determine SO2 mass
emissions by three ways

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MONITORING REQUIREMENTS

Units burning oil may monitor SO2


mass emissions by one of the
following methods:
1. daily manual oil sampling and
analysis plus oil flow meter (to
continuously monitor oil usage)
2. sampling and analysis of diesel fuel
oil as-delivered plus oil flow meter
3. automatic continuous oil sampling
plus oil flow meter
4. SO2 and flow CEMs.

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MONITORING REQUIREMENTS

 Gas-fired and oil-fired base-loaded units must use


NOx CEMs.
 Gas-fired peaking units and oil-fired peaking units
may either estimate NOx emissions by using site-
specific emission correlations and periodic stack testing
to verify continued representativeness of the
correlations, or use NOx CEMS
 All gas-fired units using natural gas for at least 90
percent of their annual heat input and units burning
diesel fuel oil are exempt from opacity monitoring
 For CO2 all units can use either (1) a mass balance
estimation, or (2) CO2 CEMs, or (3) O2 CEMs in order
to estimate CO2 emissions

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MONITORING REQUIREMENTS

CEM systems include:


 An SO2 pollutant concentration monitor
 A NOx pollutant concentration monitor
 A volumetric flow monitor
 An opacity monitor
 A diluent gas (O2 or CO2) monitor
 A computer-based data acquisition and handling
system (DAHS) for recording and performing calculations
with the data
CEM systems must be in continuous operation and be
able to sample, analyze, and record data at least every 15
minutes and reduce flow data to 1-hour averages.

Industrial Boilers 58/ 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC
RECORDKEEPING

The CEM rule includes requirements for notification,


recordkeeping, and reporting for the Acid Rain Program,
such as:
 Submission of monitoring plans
 Written notifications of monitor certification tests
 Report of certification test results in a "certification
application“
 Recording and maintaining of hourly emissions data,
flow data, and other information
 Quarterly reports of emissions, flow, unit operation, and
monitoring performance data.

Industrial Boilers 59/ 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC
RECORDKEEPING

 The owner or operator also must


report the data in a standard electronic
format available through the Acid Rain
Hotline
Unless otherwise specified by your
regulators or permit conditions, it is
recommended to keep these records
for a minimum of 3 years unless the
boiler destroys hazardous waste, then
the records must be kept through
closure of the boiler

Industrial Boilers 60/ 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC
TIPS FOR USING CONTRACTORS

 Remember, You Control Your Facility or Area!


 Review Procedures With Them Before Starting the Job!
 Ensure They Are Properly Trained!
 Determine Their Environmental Compliance Record!
 Determine Who Is in Charge of Their People!
 Determine How They Will Affect Your Facility’s
Environmental Compliance!

Industrial Boilers 61/ 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC
ELEMENTS OF A SUCCESSFUL
INDUSTRIAL BOILER PROGRAM

1. DETAILED WRITTEN INDUSTRIAL BOILER INSPECTION


GUIDELINES.
2. DETAILED WRITTEN INDUSTRIAL BOILER BEST MANAGEMENT
PRACTICES.
3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS
4. PERIODIC REINFORCEMENT OF TRAINING
5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION
6. PERIODIC FOLLOW-UP

Industrial Boilers 62/ 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC
THE IMPORTANCE OF A
CLEAN ENVIRONMENT

“I would ask all of us to remember


that protecting our environment is
about protecting where we live and
how we live. Let us join together to
protect our health, our economy,
and our communities -- so all of us
and our children and our Carol Browner
grandchildren can enjoy a healthy
and a prosperous life.” Former
EPA
Administrator

Industrial Boilers 63/ 63 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC

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