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.
Marc Karell is the owner of Climate Change & Environmental Services. Read more useful material in the company’s blog: www.CCESworld.com/blog. CCES has the technical knowledge and real life experience to help all kinds of firms set up “green”, climate change, and sustainability programs that result in many of the benefits listed here. We can help you organize your program, as well as gain the maximum financial benefits possible. And we can help you get the most publicity out of the program results and train you to run your own program independently in the future.
