Anheuser-Busch, Inc. May 9, 2005 

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_____________________________________________ 

] 

Anheuser-Busch, Inc. ] FINAL RACT ORDER

221 Daniel Webster Highway ] ARD-05-001 

P.O. Box 610 ] May 9, 2005 

Merrimack, NH 03054-0610 ] 

_____________________________________________ ] 

A. Introduction

This NOx RACT Order is issued by the New Hampshire Department of Environmental Services, Air 

Resources Division, to Anheuser-Busch, Inc. pursuant to RSA 125-C. 

B. Parties

1. The New Hampshire Department of Environmental Services, Air Resources Division ("DES"), is a 

duly constituted administrative agency of the State of New Hampshire having its principal offices at 

29 Hazen Drive, Concord, NH 03301, telephone number (603) 271-1370. 

2. Anheuser-Busch, Inc., (“Anheuser-Busch”), is a Missouri corporation, registered with the NH 

Secretary of State, and has a mailing address of 221 Daniel Webster Highway, P.O. Box 610, 

Merrimack, NH 03054-0610. 

C. Statements of Fact and Law

1. Anheuser-Busch owns and operates a beer manufacturing facility located on a site bordered to the 

east and west by the Merrimack River and Daniel Webster Highway in Merrimack, New Hampshire. 

2. Anheuser-Busch’s significant NOx emitting sources include three Babcock & Wilcox boilers, fired by 

either natural gas or No. 6 fuel oil (maximum sulfur content of 1.0 percent sulfur by weight), and 

occasionally some on-site generated specification used oil is blended with the No. 6 fuel oil for 

combustion to provide process steam for the brewing process. 

3. Effective May 20, 1994, DES adopted PART Env-A 1211 NITROGEN OXIDES (NOx). 

4. Anheuser-Busch filed a "NOx RACT Compliance Schedule" dated September 12, 1994, indicating it 

planned on installing new low NOx burners (LNB) for firing fuel oil in each of the three boilers. 

Installation of the Todd low NOx oil burners was completed on October 10, 1995. Post LNB 

compliance testing of the three boilers was completed on October 11, 1995. 

DES conducted a technical evaluation of the LNB installed in the three boilers at Anheuser-Busch. 

Each boiler had a LNB score of 31 and a total score of 39. The evaluation indicated that the 

technology installed in all three boilers met the technical component requirements of a commercially 

available LNB (LNB score of at least 23). Based on the 1995 compliance stack tests after installation 
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of the LNB, DES set a NOx limit of 0.40 lb/MMBtu while firing fuel oil and 0.25 lb/MMBtu while 

firing natural gas. 

5. DES received a permit application from Anheuser-Busch on January 10, 2005, for the installation and 

operation of a wastewater treatment system, referred to as the Bio Energy Recovery System or 

“BERS” process. The BERS process will ultimately reduce biological oxygen demand (“BOD”) of 

the facility’s wastewater, which is sent to the Town of Merrimack Publicly Owned Treatment Works 

(POTW) wastewater treatment plant. The BERS process includes anaerobic reactors, with collection 

and treatment of biogas (largely methane with the remainder being mostly carbon dioxide and small 

amounts of hydrogen sulfide) generated in the reactors. The primary means of treatment of the biogas 

is supplemental combustion of the biogas with natural gas or No. 6 fuel oil in any of the three boilers, 

with a flare being added as a backup biogas combustion device in case the boilers are unavailable for 

service. 

6. In that the facility is subject to NOx RACT requirements, Anheuser-Busch submitted a NOx RACT 

Order application on February 7, 2005 for the installation and operation of the flare and also is 

seeking an alternative emission limit for the three boilers. The application was filed in accordance 

with Env-A 1211.14, Emission Standards and Control Options for Miscellaneous Stationary Sources

(for the flare), and Env-A 1211.15, Alternative RACT Emission Limits (for the three boilers). 

7. The flare will function as a backup control device to control hydrogen sulfide emissions when the 

boilers are not operating. 

Flares often serve as backup control devices for engines, boilers, turbines, or process heaters that fire 

waste gas. NOx emissions from flares are typically lower than the NOx emissions from the primary 

control devices. This is especially true with open flares, where the combustion occurs in the open and 

overall combustion temperatures would be expected to be lower than in most enclosed combustion 

devices. Furthermore, because of the design of open flares, the typical combustion controls applied to 

other combustion devices, such as staged combustion, are not feasible. Therefore, there are no 

technically feasible NOx control technologies for the proposed open flare. 

Emissions from open flares can not be tested with conventional testing methods because the 

combustion occurs in the open. Therefore, NOx emissions from the proposed flare are based on 

Table 13.5-1 in USEPA’s AP-42, which indicates an emission factor of 0.068 lb/MMBtu for 

industrial flares. 

Anheuser-Busch’s proposed NOx RACT emission limit for the flare is the AP-42 emission rate of 

0.068 lb/MMBtu. 

8. Env-A 1211.05(d)(3)b. and c. specify an emission limit of 0.25 lb/MMBtu when co-firing oil and gas. 

The low NOx oil burners, which have a firing capacity of 138 MMBtu/hr, operate at a NOx emission 

level between 0.35 and 0.40 lb/MMBtu when firing No. 6 fuel oil. The biogas, which is functionally 

equivalent to natural gas, is expected to generate NOx emissions on the order of 0.25 lb/MMBtu. The 

biogas will be co-fired as a supplementary fuel, and will typically comprise about 10 to 15% of the 

fuel being fired on a heat input basis (expected average of 11 MMBtu/hr). The boilers, therefore, can 

not meet an emission limit of 0.25 lb/MMBtu when co-firing No. 6 fuel oil with biogas. To the extent 

that the biogas displaces oil, there is an expected NOx reduction of approximately 0.15 lb/MMBtu of 
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biogas fired, but at the low firing rate of biogas, this lower NOx emission rate would reduce the 

overall NOx emissions on a lb/MMBtu basis only slightly. Furthermore, the biogas firing rate varies 

somewhat, and the exact ratio of oil to biogas firing at any given time will not be predictable. 

Add-on NOx control technologies, such as ammonia or urea injection, would render the use of the 

biogas for a supplemental fuel as economically infeasible. The firing of biogas in the boiler is a 

beneficial use of the byproduct (biogas) from the wastewater treatment process. Use of biogas will 

reduce NOx and sulfur dioxide (SO2) emissions to the extent that the biogas displaces oil firing in the 

boilers and will reduce consumption of non-renewable fossil fuels to the extent that both natural gas 

and oil firing is displaced by biogas firing in the boilers. 

Anheuser-Busch proposed the following alternative NOx RACT limits for co-firing of biogas in the 

boilers: 

• NOx emissions when firing natural gas or a combination of natural gas and biogas will be 

limited to less than or equal to 0.25 lb/MMBtu on a 24-hour calendar day average; 

• NOx emissions when firing oil or a combination of oil and biogas will be limited to less 

than or equal to 0.40 lb/MMBtu on a 24-hour calendar day average and the use of the 

existing low NOx burners; and 

• With the exception of pilot gas to light off the boilers, natural gas and oil will not be cofired in any of the boilers. 

D. Order

Based upon the above findings and determinations, DES hereby orders Anheuser-Busch as follows: 

1. Comply with a limit of less than or equal to 0.068 lb NOx/MMBtu, for the proposed open flare. 

2. Comply with a limit of less than or equal to 0.40 lb NOx/MMBtu on a 24-hour calendar day average 

and use of the existing, DES approved, low NOx burners, when firing oil or a combination of oil and 

biogas in each of the three boilers. 

3. Comply with a limit of less than or equal to 0.25 lb NOx/MMBtu on a 24-hour calendar day average, 

 when firing natural gas or a combination of natural gas and biogas in each of the three boilers. 

4. With the exception of pilot gas to light off the boilers, natural gas and oil will not be co-fired in any 

of the boilers. 

5. Within 60 days of achieving maximum operating rate on the BERS process and not later than 180 

days after initial startup of the BERS process, conduct initial performance testing and subsequent 

periodic NOx RACT testing of the three boilers in accordance with Temporary Permit TP-BP-0695 

for the following fuels: No. 6 fuel oil only; No. 6 fuel oil and biogas; natural gas only; and natural 

gas and biogas. 
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6. Perform annual tune-ups for each of the boilers, separately for fuel oil alone and natural gas alone, in 

accordance with Env-A 1211.05(b). 

7. Comply with the monitoring requirements in Temporary Permit TP-BP-0695, including, but not 

limited to: 

• Monitor and record the monthly biogas fed to each of the Boilers and the Flare; 

• Monitor and record the hours of operation of the Flare on a monthly basis; 

• Monitor and record monthly, the hours of time biogas is fed to each of the Boilers; 

• Inspect the flare before May 1st of each year to verify that the flare continues to be operated 

in accordance with the manufacturer’s specifications for the operation of the flare. 

8. Maintain at the facility and make available for review by DES and/or EPA upon request a copy of the 

manufacturer’s maintenance specifications for the flare. 

9. Maintain records of any manufacturer-specified maintenance conducted on the flare. 

10. Comply with the record keeping and reporting requirements of Env-A 900. 

Please address any correspondence and communication in reference to this Order to: 

Mr. Douglas C. Laughton 

NHDES, Air Resources Division 

Stationary Source Management Bureau 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-1370 

_____________________________ 

Robert R. Scott, Director 

Department of Environmental Services 

Air Resources Division 

cc: Timothy Drew, PIP Office 

David Conroy, US EPA 

Town Selectmen 

RRS/dcl 

finalNOxRACTOrderMay092005.doc