HomeMy WebLinkAbout06.c. Receive update regarding the cost analysis for the furnace and related improvements for Clean Air Act requirementsItem 6.c.
J uly 20, 2021
T O: R E A L E S TAT E, E NV I R O NME NTA L A ND P L A NNI NG C O MMI T T E E
F RO M :L O R I S C HE C T E L , E NV I R O NME NTA L A ND R E G UL ATO RY C O MP L I A NC E
D I V I S I O N MA NA G E R
J E A N-MA R C P E T I T, D I R E C TO R O F E NG I NE E R I NG A ND T E C HNI C A L
S E RV I C E S
RE V IE WE D B Y:R O G E R S. B A I L E Y, G E NE R A L MA NA G E R
S UB J E C T: R E C E I V E A N UP D AT E R E G A R D I NG T HE C O S T A NA LYS I S F O R T HE
F UR NA C E A ND R E L AT E D I MP R O V E ME NT S F O R C L E A N A I R A C T
R E Q UI R E ME NT S
An update will be provided to the C ommittee.
Strategic Plan Tie-I n
G O A L TW O: Environmental Stewardship
Strategy 1 – Achieve 100% compliance in all regulations
AT TAC HM E NT S :
D escription
1. P resentation
July 20, 2021 Special REEP Committee Meeting Agenda Packet - Page 61 of 71
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129 REGULATIONS UPDATES
Real Estate, Environmental and Planning Committee Meeting
July 20, 2021
Jean-Marc Petit, P.E.
Director of Engineering and Technical Services
Lori Schectel
Environmental and Regulatory Compliance Division Manager
40 CFR (Code of Federal Regulations)
Part 62 Subpart LLL (129 Rule)
•50% cost threshold:
•If the cumulative cost of changes over the life of the multiple hearth furnaces
(MHFs) exceeds 50% of the original cost of constructing the MHFs, the MHFs must
meet the emissions limits for “new/modified” MHFs
•Emissions limits for “existing” MHFs are less stringent than the emissions limits for
“new/modified” MHFs
•The projected costs of the Solids Handling Project should not cause the cumulative
cost of changes over the life of the MHFs to exceed 50% of the original cost
•The MHFs should be subject to the same emissions limits for “existing” MHFs after
the Solids Handling Project
129 Emission Limits
Pollutant (corrected to 7% O2)Existing
MHFs
New/Modified
MHFs
Cadmium, mg/dscm 0.095 0.0024
Carbon Monoxide, ppmvd 3,800 52
Hydrogen Chloride, ppmvd 1.2 1.2
Mercury, mg/dscm 0.28 0.15
Oxides of Nitrogen, ppmvd 220 210
Lead, mg/dscm 0.30 0.0035
Dioxins/Furans (Toxic Equivalency Basis), ng/dscm 0.32 0.0022
Dioxins/Furans (Total Mass Basis), ng/dscm 5.0 0.045
Particulate Matter, mg/dscm 80 60
Sulfur Dioxide, ppmvd 26 26
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July 20, 2021 Special REEP Committee Meeting Agenda Packet - Page 62 of 71
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129 RULE 50% COST TRIGGERS
1 originally classified as likely exempt, reclassified as exempt
2 not included in Solids Handling Project
3 originally classified as non‐exempt, reclassified as exempt, reclassified again as non‐exempt
4 originally classified as exempt, reclassified as non‐exempt
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129 RULE 50% COST TRIGGERS
1 originally classified as likely exempt, reclassified as exempt
2 not included in Solids Handling Project
3 originally classified as non‐exempt, reclassified as exempt, reclassified again as non‐exempt
4 originally classified as exempt, reclassified as non‐exempt
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July 20, 2021 Special REEP Committee Meeting Agenda Packet - Page 63 of 71
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ESTIMATES OF PERCENTAGE
Description Estimated Costs
Percentage of
Original Cost
Original MHF Installation (Commissioned in 1984)$102.2 M
(Million)
100%
50% of Original MHF Installation $51.1 M 50%
Cumulative Non-Exempt Improvements (Between 1984 - 2019)$6.8 M 6.7%
Solids Project Planned Non-Exempt Improvements (*)$33.3 M 32.6%
Remaining Balance Before Exceeding 50% Cost Threshold $11.0 M 10.8%
* Based on May 1, 2020, 90% Design Opinion of Project Cost Estimate
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RESPONSE TO CLEAN AIR ACT SECTION 114(A) INFORMATION
REQUEST FOR CENTRAL CONTRA COSTA SANITARY DISTRICT
Prior References to 50% cost analysis item to Board meetings:
•June 20, 2016: Comprehensive Wastewater Master Plan Board
Workshop
•January 27, 2017: Capital Improvement Program (CIP) and Capital
Improvement Budget (CIB) Board Workshop
•March 13, 2018: Engineering & Operations Committee Meeting
Position Paper for Solids Project Design
•April 26, 2018: Board Meeting Position Paper for Solids Project Design
•May 1, 2020: Submittal to United States Environmental Protection
Agency (USEPA) on Modification Cost Analysis
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July 20, 2021 Special REEP Committee Meeting Agenda Packet - Page 64 of 71
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Potential Enhanced Air Pollution Control Technologies Required for 129 Compliance
Air Pollution Control Device Target Pollutants
Existing MHF
Limits
New MHF
Limits
Venturi Scrubber*
Hg, Pb, Cd,
Filt PM, HCl, SO2
Dioxins/Furans
XX
Low‐NOX Afterburners* NOx XX
Mercury Modules Hg, SO2
Wet Electrostatic Precipitator
(WESP)1
Pb, Cd,
Fine PM X
Zero Hearth2 CO X
Carbon Adsorption3 Dioxins/Furans X
Selective Catalytic Reduction NOx
*Included in Solids Handling Project
1Total Estimated Equipment Cost, 2 units: $1.2M
2Total Estimated Equipment Cost, 2 units: $1.5M
3Total Estimated Equipment Cost, 2 units: $3.2M
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QUESTIONS
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July 20, 2021 Special REEP Committee Meeting Agenda Packet - Page 65 of 71
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MACT
•What is a MACT standard? The Maximum Achievable
Control Technology (MACT) standard is a level of control
that was introduced by Title III of the 1990 Clean Air Act
Amendments. The purpose of these Amendments was to
expedite the development of standards that would reduce
hazardous air pollutant (HAP) emissions.
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July 20, 2021 Special REEP Committee Meeting Agenda Packet - Page 66 of 71
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