INDUSTRIAL BOILER MACT INDUSTRIAL BOILER MACT RULE RULE (Title 40 CFR 63 Subpart DDDDD) (Title 40 CFR 63 Subpart DDDDD) Annual Annual DoD DoD Conference Conference Environmental Air Quality Workshop Environmental Air Quality Workshop June 29, 2005 June 29, 2005
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INDUSTRIAL BOILER MACT RULE - InfoHouseinfohouse.p2ric.org/ref/34/33951.pdfTemporary/rental gas or liquid fuel boilers ... New small liquid fuel units that do not burn residual oil
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•• Process HeatersProcess HeatersIndirectIndirect--fired fired –– combustion gases do not combustion gases do not come in contact with process materials. come in contact with process materials.
Major source MACT onlyMajor source MACT only
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SUBCATEGORIESSUBCATEGORIESThree main subcategories:Three main subcategories:•• Solid fuel unitsSolid fuel units•• Liquid fuel unitsLiquid fuel units
•• Gaseous fuel unitsGaseous fuel units
Further subcategorized on size and useFurther subcategorized on size and use•• Large (> 10 MM Btu/hr heat input)Large (> 10 MM Btu/hr heat input)•• Small (all Small (all firetubesfiretubes and others < 10 MM Btu/hr)and others < 10 MM Btu/hr)•• LimitedLimited--use (< 10% capacity factor)use (< 10% capacity factor)
Total of 9 subcategoriesTotal of 9 subcategories
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WHAT UNITS ARE NOT COVERED?WHAT UNITS ARE NOT COVERED?Any boiler and process heater listed as an Any boiler and process heater listed as an affected source under another MACTaffected source under another MACT•• For example,For example,
Fossil fuelFossil fuel--fired electric utility boilersfired electric utility boilers
Boilers burning municipal wasteBoilers burning municipal waste
0.0009 lb/million Btu (small and limited use units)0.0009 lb/million Btu (small and limited use units)CO CO –– 400 400 ppmppm @ 3% oxygen (NOT FOR SMALL UNITS)@ 3% oxygen (NOT FOR SMALL UNITS)
New gaseous fuelNew gaseous fuel--fired unitsfired unitsCO CO –– 400 400 ppmppm @ 3% oxygen (NOT FOR SMALL UNITS)@ 3% oxygen (NOT FOR SMALL UNITS)
•• Large Units Large Units -- Baghouse (PM/metals/Hg)/ Scrubber (HCl)Baghouse (PM/metals/Hg)/ Scrubber (HCl)
•• LimitedLimited--Use Units Use Units –– ESP (PM/metals)ESP (PM/metals)
New UnitsNew Units•• Based on NSPS and State RegulationsBased on NSPS and State Regulations•• BaghouseBaghouse/ Scrubber / CO Limit/ Scrubber / CO Limit
•• (large solid fuel units only)(large solid fuel units only)
HealthHealth--based compliance alternatives for based compliance alternatives for HCl and TSM HCl and TSM
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COMPLIANCE TESTINGCOMPLIANCE TESTING
Performance tests (stacks tests)Performance tests (stacks tests)•• Annual performance testsAnnual performance tests•• Based on average of 3 test runsBased on average of 3 test runs
OROR
Fuel analysesFuel analyses•• Initial and every 5 yearsInitial and every 5 years•• Each new fuel typeEach new fuel type•• Based 90% confidence level of minimum 3 Based 90% confidence level of minimum 3
fuel samplesfuel samples
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COMPLIANCE MONITORING COMPLIANCE MONITORING Continuous compliance based on monitoring and Continuous compliance based on monitoring and maintaining operating limitsmaintaining operating limitsOperating limitsOperating limits•• For PM, TSM and mercury limits For PM, TSM and mercury limits
Opacity (for dry systems)Opacity (for dry systems)•• Existing units Existing units –– 20% opacity (6 minute average)20% opacity (6 minute average)•• New units New units –– 10% opacity (1 hour block average)10% opacity (1 hour block average)
Control device parameters (for wet systems)Control device parameters (for wet systems)•• Established during initial compliance testEstablished during initial compliance test
Fuel (type or mixture)Fuel (type or mixture)•• When compliance based on fuel analysisWhen compliance based on fuel analysis
•• Opacity (by COM) Opacity (by COM) –– dry control systemsdry control systems
•• Fuel (monthly records)Fuel (monthly records)
•• Scrubber parametersScrubber parameters
•• CO (new units only)CO (new units only)
CEM for large units > 100 million Btu/hrCEM for large units > 100 million Btu/hrAnnual CO tests for other new units Annual CO tests for other new units Exempt data from <50% load and based on 30Exempt data from <50% load and based on 30--day average.day average.
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What Subcategories Have Limited What Subcategories Have Limited Requirements?Requirements?
Subject to ONLY Initial NotificationSubject to ONLY Initial Notification•• Existing large and limited use gaseous fuel unitsExisting large and limited use gaseous fuel units•• Existing large and limited use liquid fuel unitsExisting large and limited use liquid fuel units•• New small liquid fuel units that do not burn residual oilNew small liquid fuel units that do not burn residual oil
NOT subject to Initial Notification or any other NOT subject to Initial Notification or any other requirements in General Provisionsrequirements in General Provisions•• Existing small solid fuel unitsExisting small solid fuel units•• Existing small liquid fuel unitsExisting small liquid fuel units•• Existing small gaseous fuel unitsExisting small gaseous fuel units•• New small gaseous fuel unitsNew small gaseous fuel units
•• Alternative to complying with HCl MACT limit Alternative to complying with HCl MACT limit
Must include appropriate units covered by subpart DDDDDMust include appropriate units covered by subpart DDDDD
•• Those that emit HCl and/or Cl2Those that emit HCl and/or Cl2
Must conduct HCl and chlorine emission tests or fuel analysesMust conduct HCl and chlorine emission tests or fuel analyses
•• When conducting fuel analysis must assume any chlorine When conducting fuel analysis must assume any chlorine is emitted as CL2is emitted as CL2
Must calculate total maximum hourly mass HClMust calculate total maximum hourly mass HCl--equivalent equivalent emission rateemission rate
•• Compliance determine by using:Compliance determine by using:
Lookup table Lookup table
•• Average stack height of appropriate subpart DDDDD unitsAverage stack height of appropriate subpart DDDDD units
•• Minimum distance of any appropriate subpart DDDDD unit Minimum distance of any appropriate subpart DDDDD unit to property boundaryto property boundary
•• As alternative to complying with TSM limit based on 8 As alternative to complying with TSM limit based on 8
metals, may demonstrate compliance with TSM limit metals, may demonstrate compliance with TSM limit
based on 7 metals by excluding manganese based on 7 metals by excluding manganese Must include appropriate units covered by subpart DDDDDMust include appropriate units covered by subpart DDDDD
Must conduct manganese emission tests or fuel analysesMust conduct manganese emission tests or fuel analyses
Must calculate the total maximum hourly mass manganese Must calculate the total maximum hourly mass manganese emission rateemission rate
•• Eligible for demonstrating compliance based on 7 metals Eligible for demonstrating compliance based on 7 metals
excluding manganese by using:excluding manganese by using:Lookup table Lookup table
•• Average stack height of appropriate subpart DDDDD unitsAverage stack height of appropriate subpart DDDDD units
•• Minimum distance to property boundaryMinimum distance to property boundary
•• Hazard Quotient (HQ) can not exceed 1.0Hazard Quotient (HQ) can not exceed 1.0
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Additional Details of HealthAdditional Details of Health--Based Based Compliance AlternativesCompliance Alternatives
Demonstrations filed with permitting Demonstrations filed with permitting authority and EPA along with certification authority and EPA along with certification of authenticity and accuracyof authenticity and accuracy•• No review or approval required; EPA, No review or approval required; EPA,
permitting authority may audit a percentagepermitting authority may audit a percentage
Facility must apply for Title V permit modification Facility must apply for Title V permit modification to include parameters that defined the source to include parameters that defined the source (fuel type, control devices, stack parameters)(fuel type, control devices, stack parameters)
Facilities must submit demos within 2 Facilities must submit demos within 2 years, one year prior to compliance dateyears, one year prior to compliance date
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Petitions For ReconsiderationPetitions For ReconsiderationThree petitions for reconsideration were Three petitions for reconsideration were receivedreceived•• General Electric CompanyGeneral Electric Company•• Joint petitionJoint petition
•• EIPEIPTwo petitions for judicial reviewTwo petitions for judicial review•• Jointly filed by NRDC, Sierra Club, and EIPJointly filed by NRDC, Sierra Club, and EIP
Issues same as in reconsideration petition Issues same as in reconsideration petition •• American Public PowerAmerican Public Power--Ohio (and 6 Ohio (and 6
municipalities)municipalities)EPA exceeded its authority in imposing standards on EPA exceeded its authority in imposing standards on small municipal utility boilerssmall municipal utility boilers
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GE PetitionGE PetitionIssueIssue•• Requests clarification that the rule allows for Requests clarification that the rule allows for
testing at the common stack rather than each testing at the common stack rather than each duct to the stackduct to the stack
•• No opportunity to provide comments since the No opportunity to provide comments since the proposed rule did not contain regulatory text proposed rule did not contain regulatory text for the emissions averaging provisionfor the emissions averaging provision
•• Common stack testing is handled on a caseCommon stack testing is handled on a case--byby--case basis by OECA/Regionscase basis by OECA/Regions
OECA’sOECA’s general policy is that each duct to a common stack general policy is that each duct to a common stack must be testedmust be tested
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NRDC NRDC –– EIP PetitionEIP Petition
Seeking reconsideration on:Seeking reconsideration on:•• Lack of standards for all HAP emitted Lack of standards for all HAP emitted
on all subcategorieson all subcategories•• HealthHealth--based compliance alternativesbased compliance alternatives
CAA does not authorize plantCAA does not authorize plant--byby--plant plant riskrisk--based exemptionsbased exemptionsBasis for development of healthBasis for development of health--based based compliance alternativescompliance alternativesProcedures for demonstrating compliance Procedures for demonstrating compliance (Appendix A) (Appendix A)
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Recent Federal Register NoticeRecent Federal Register NoticeFR June 27, 2005, Vol. 70, Num. 122, pg 36907FR June 27, 2005, Vol. 70, Num. 122, pg 36907--3691536915
Request for comments on:Request for comments on:•• Tiered Risk assessment Methodology (appendix A)Tiered Risk assessment Methodology (appendix A)
LookLook--up tables and Methodology (HCL, up tables and Methodology (HCL, MnMn, appendix A), appendix A)Site Specific Risk Assessment Process (section 7, appendix A)Site Specific Risk Assessment Process (section 7, appendix A)HI or HQ of 1.0 for HCL, HI or HQ of 1.0 for HCL, ClCl, , MnMn (applicability cut off for RA’s)(applicability cut off for RA’s)
•• Background concentrations (were not considered) Background concentrations (were not considered) •• Overall Adoption of Health based compliance alternative for Overall Adoption of Health based compliance alternative for MnMn•• Exclusion of Exclusion of MnMn from the TSM limit in table 1from the TSM limit in table 1
CorrectionCorrection•• Health based compliance alternatives for HCL & TSM are Health based compliance alternatives for HCL & TSM are
applicable to any affected source (not only large solid fuel applicable to any affected source (not only large solid fuel subcategory)subcategory)
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Questions Received Questions Received What does “Equivalent” mean in Table 6 ? What does “Equivalent” mean in Table 6 ? (Fuel Analysis Requirements) (Fuel Analysis Requirements)
Are “hybrid boilers” considered Are “hybrid boilers” considered firetubefiretube or or watertubewatertube boilers?boilers?
Can a common stack be tested instead of Can a common stack be tested instead of the individual ducts?the individual ducts?
Are auxiliary boilers at power plants Are auxiliary boilers at power plants covered by subpart DDDDD?covered by subpart DDDDD?
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INFORMATION SITESINFORMATION SITES
Implementation tools (timelines, initial notification, Implementation tools (timelines, initial notification, state/local contacts, Q/A) and information on the state/local contacts, Q/A) and information on the MACT rulemaking for DDDDD is available on EPA’s MACT rulemaking for DDDDD is available on EPA’s web site at:web site at:
An electronic version of public docket An electronic version of public docket (including public comments) is available at:(including public comments) is available at:•• www.epa.gov/edocket/www.epa.gov/edocket/•• Search for docket ID No. OARSearch for docket ID No. OAR--20022002--00580058