Proposed regulations for control of emissions from indirect heat exchangers were recently filed by the Kentucky Division for Air Quality (DAQ) on September 14, 2017.  The regulations are revisions of existing regulations for both existing and new indirect heat exchangers.  “Indirect heat exchanger” means a piece of equipment, apparatus, or contrivance used for the combustion of fuel in which the energy produced is transferred to its point of usage through a medium that does not come in contact with or add to the products of combustion.  In general, existing heat exchangers include heat exchangers installed before April 9, 1972 and “new” heat exchangers include any heat exchangers installed after that date.

For existing heat exchangers (401 KAR 61:015), emission standards for particulate matter are established in Appendix A (lb/MMBtu) and opacity is restricted to 20% or less for Priority I classified regions and 40% or less for Priority II or III classified regions.  There are no substantial changes to the particulate matter emissions standards including the allowable pound of particulate per million Btu actual heat input and percent opacity restriction.  There are no substantial changes to sulfur dioxide standards.

For new heat exchangers (401 KAR 59:105), emission standards for particulate matter are established in Section 4 of 401 KAR 59:015 and are based on the total heat input for affected facilities.  Opacity is restricted to 20% except for specific scenarios as stated in the regulation.  There are no substantial changes to the particulate matter emissions standards including the allowable pound of particulate per million Btu actual heat input and percent opacity restriction.  There are no substantial changes to sulfur dioxide standards.  Standards for nitrogen oxides have been removed from the regulation and the proposed regulation for new heat exchangers reflects this change.

Work practice standards during a startup period or shutdown period have been added to both regulations, and these additions represent the substantial difference between current regulations and the proposed regulations.  During periods of startup and shutdown, indirect heat exchangers are to be operated with good air pollution control practices for minimizing emissions.  “Good air pollution control practices” is also called the “general duty” clause which means the regulatory expectation is that operators are to follow manufacturer recommendations.  The frequency and duration of startup and shutdown periods are to be minimized as much possible.  Documented records such as logs are to be kept for each action associated with startup or shutdown period.  Definitions for “startup period” and “shutdown period” are included in the proposed regulations.  The work practice standards are based on the general provisions of the federal regulations for National Emission Standards for Hazardous Air Pollutants for Source Categories as listed in Subpart A of 40 CFR Part 63.  Specific federal regulations for work practice standards during periods of startup and shutdown are referenced in the proposed regulations for boilers at major sources of emissions, boilers at area sources of emissions, and boilers at coal and oil-fired electric utility steam generating units.  For boilers at area sources (excluding natural gas fired boilers), facilities must comply with Table 2 of Subpart JJJJJJ during periods of startup and shutdown.  For boilers at major sources, facilities must comply with items 5 and 6 of Table 3 of Subpart DDDDD during periods of startup and shutdown.

Please contact Smith Management Group at (859) 231-8936 or (502) 587-6482 if you would like more information or need assistance with air permitting or environmental compliance strategies for sources located in Kentucky.

(Note:  Sources within Jefferson County are not subject to these particular regulations; however, sources in Jefferson County are subject to similar regulations and are regulated by the Louisville Metro Air Pollution Control District.)