INDUSTRIAL BOILER MACT RULE (Title 40 CFR 63 Subpart DDDDD)

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INDUSTRIAL BOILER MACT RULE (Title 40 CFR 63
Subpart DDDDD)

• Annual DoD Conference
• Environmental Air Quality Workshop
• June 29, 2005

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IMPORTANT DATES

• Proposal Date January 13, 2003
• Promulgation Date September 13, 2004
• Effective Date November 12, 2004
• Additional Comment
• Period Notice - June 27, 2004- August 11,
  2005
• Initial Notification Dates
• March 12, 2005 Existing units
• 15 days after startup New units
• Compliance Date
• Existing units - September 13, 2007
• New units Startup

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INDUSTRIAL BOILER MACT

• Source categories covered
• Industrial Boilers
• Institutional/Commercial Boilers
• Process Heaters
• Indirect-fired combustion gases do not come in
  contact with process materials.
• Major source MACT only

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SUBCATEGORIES

• Three main subcategories
• Solid fuel units
• Liquid fuel units
• Gaseous fuel units
• Further subcategorized on size and use
• Large (gt 10 MM Btu/hr heat input)
• Small (all firetubes and others lt 10 MM Btu/hr)
• Limited-use (lt 10 capacity factor)
• Total of 9 subcategories

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WHAT UNITS ARE NOT COVERED?

• Any boiler and process heater listed as an
  affected source under another MACT
• For example,
• Fossil fuel-fired electric utility boilers
• Boilers burning municipal waste
• Boilers burning hazardous waste
• Boilers burning medical waste
• Black liquor recovery boilers
• Temporary/rental gas or liquid fuel boilers (lt180
  days)
• Hot water heaters
• Waste heat boilers
• Synthetic minors becomes an area source

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EMISSIONS LIMITSExisting Units

• Existing large solid fuel units
• PM -- 0.07 lb/million Btu, OR TSM 0.001
  lb/million Btu
• HCl -- 0.09 lb/million Btu ( 90 ppm)
• Hg 9 lb/trillion Btu
• Existing limited use solid fuel units
• PM -- 0.21 lb/million Btu, OR TSM 0.004
  lb/million Btu
• No emissions standards for
• existing small solid fuel units
• existing liquid fuel units
• existing gaseous fuel units

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EMISSION LIMITSand WORK PRACTICE STANDARDSNew
Units

• New solid fuel units
• PM -- 0.025 lb/million Btu, OR TSM 0.0003
  lb/million Btu
• HCl -- 0.02 lb/million Btu (20 ppm)
• Hg -- 3 lb/trillion Btu
• CO -- 400 ppm _at_ 7 oxygen (NOT FOR SMALL UNITS)
• New liquid fuel units
• PM -- 0.03 lb/million Btu
• HCl -- 0.0005 lb/million Btu (large units)
• 0.0009 lb/million Btu (small and
  limited use units)
• CO 400 ppm _at_ 3 oxygen (NOT FOR SMALL UNITS)
• New gaseous fuel-fired units
• CO 400 ppm _at_ 3 oxygen (NOT FOR SMALL UNITS)

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CONTROL TECHNOLOGY BASIS

• Existing Solid Fuel Boilers
• Large Units - Baghouse (PM/metals/Hg)/ Scrubber
  (HCl)
• Limited-Use Units ESP (PM/metals)
• New Units
• Based on NSPS and State Regulations
• Baghouse/ Scrubber / CO Limit

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COMPLIANCE OPTIONS

• Conduct stack emission tests
• Conduct fuel analysis
• Emissions averaging
• (large solid fuel units only)
• Health-based compliance alternatives for HCl and
  TSM

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COMPLIANCE TESTING

• Performance tests (stacks tests)
• Annual performance tests
• Based on average of 3 test runs
• OR
• Fuel analyses
• Initial and every 5 years
• Each new fuel type
• Based 90 confidence level of minimum 3 fuel
  samples

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COMPLIANCE MONITORING

• Continuous compliance based on monitoring and
  maintaining operating limits
• Operating limits
• For PM, TSM and mercury limits
• Opacity (for dry systems)
• Existing units 20 opacity (6 minute average)
• New units 10 opacity (1 hour block average)
• Control device parameters (for wet systems)
• Established during initial compliance test
• Fuel (type or mixture)
• When compliance based on fuel analysis
• For HCl
• Scrubber parameters (pH, pressure drop, liquid
  flow, sorbent injection rate)
• Established during initial compliance test
• Fuel (type or mixture)
• When compliance based on fuel analysis

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COMPLIANCE MONITORING (cont.)

• Monitoring
• Opacity (by COM) dry control systems
• Fuel (monthly records)
• Scrubber parameters
• CO (new units only)
• CEM for large units gt 100 million Btu/hr
• Annual CO tests for other new units
• Exempt data from lt50 load and based on 30-day
  average.

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What Subcategories Have Limited Requirements?

• Subject to ONLY Initial Notification
• Existing large and limited use gaseous fuel units
• Existing large and limited use liquid fuel units
• New small liquid fuel units that do not burn
  residual oil
• NOT subject to Initial Notification or any other
  requirements in General Provisions
• Existing small solid fuel units
• Existing small liquid fuel units
• Existing small gaseous fuel units
• New small gaseous fuel units

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Additional Compliance Provisions

• Emission Averaging
• Only existing large solid fuel units
• Initial compliance based on maximum capacity
• Continuous compliance on a 12-month rolling
  average basis
• Each monthly calculation based on monthly fuel
  use and previous compliance test results for each
  boiler
• Must submit emission averaging plan
• Must maintain, at a minimum, the emission
  controls employed on the effective date

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Additional Compliance Provisions

• Health-based HCl compliance alternative
• Alternative to complying with HCl MACT limit
• Must include appropriate units covered by subpart
  DDDDD
• Those that emit HCl and/or Cl2
• Must conduct HCl and chlorine emission tests or
  fuel analyses
• When conducting fuel analysis must assume any
  chlorine is emitted as CL2
• Must calculate total maximum hourly mass
  HCl-equivalent emission rate
• Compliance determine by using
• Lookup table
• Average stack height of appropriate subpart DDDDD
  units
• Minimum distance of any appropriate subpart DDDDD
  unit to property boundary
• Site-specific compliance demonstration
• Hazard Index (HI) can not exceed 1.0

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Additional Compliance Provisions

• Health-based TSM compliance alternative
• As alternative to complying with TSM limit based
  on 8 metals, may demonstrate compliance with TSM
  limit based on 7 metals by excluding manganese
• Must include appropriate units covered by subpart
  DDDDD
• Must conduct manganese emission tests or fuel
  analyses
• Must calculate the total maximum hourly mass
  manganese emission rate
• Eligible for demonstrating compliance based on 7
  metals excluding manganese by using
• Lookup table
• Average stack height of appropriate subpart DDDDD
  units
• Minimum distance to property boundary
• Site-specific compliance demonstration
• Hazard Quotient (HQ) can not exceed 1.0

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Additional Details of Health-Based Compliance
Alternatives

• Demonstrations filed with permitting authority
  and EPA along with certification of authenticity
  and accuracy
• No review or approval required EPA, permitting
  authority may audit a percentage
• Facility must apply for Title V permit
  modification to include parameters that defined
  the source (fuel type, control devices, stack
  parameters)
• Facilities must submit demos within 2 years, one
  year prior to compliance date

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Petitions For Reconsideration

• Three petitions for reconsideration were received
• General Electric Company
• Joint petition
• NRDC
• EIP (Environmental Integrity Project)
• EIP
• Two petitions for judicial review
• Jointly filed by NRDC, Sierra Club, and EIP
• Issues same as in reconsideration petition
• American Public Power-Ohio (and 6 municipalities)
• EPA exceeded its authority in imposing standards
  on small municipal utility boilers

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GE Petition

• Issue
• Requests clarification that the rule allows for
  testing at the common stack rather than each duct
  to the stack
• No opportunity to provide comments since the
  proposed rule did not contain regulatory text for
  the emissions averaging provision
• Common stack testing is handled on a case-by-case
  basis by OECA/Regions
• OECAs general policy is that each duct to a
  common stack must be tested

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NRDC EIP Petition

• Seeking reconsideration on
• Lack of standards for all HAP emitted on all
  subcategories
• Health-based compliance alternatives
• CAA does not authorize plant-by-plant risk-based
  exemptions
• Basis for development of health-based compliance
  alternatives
• Procedures for demonstrating compliance (Appendix
  A)

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Recent Federal Register Notice

• FR June 27, 2005, Vol. 70, Num. 122, pg
  36907-36915
• Request for comments on
• Tiered Risk assessment Methodology (appendix A)
• Look-up tables and Methodology (HCL, Mn,
  appendix A)
• Site Specific Risk Assessment Process (section 7,
  appendix A)
• HI or HQ of 1.0 for HCL, Cl, Mn (applicability
  cut off for RAs)
• Background concentrations (were not considered)
• Overall Adoption of Health based compliance
  alternative for Mn
• Exclusion of Mn from the TSM limit in table 1
• Correction
• Health based compliance alternatives for HCL
  TSM are applicable to any affected source (not
  only large solid fuel subcategory)

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Questions Received

• What does Equivalent mean in Table 6 ? (Fuel
  Analysis Requirements)
• Are hybrid boilers considered firetube or
  watertube boilers?
• Can a common stack be tested instead of the
  individual ducts?
• Are auxiliary boilers at power plants covered by
  subpart DDDDD?

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INFORMATION SITES

• Implementation tools (timelines, initial
  notification, state/local contacts, Q/A) and
  information on the MACT rulemaking for DDDDD is
  available on EPAs web site at
• www.epa.gov/ttn/atw/boiler/boilerpg.html
• An electronic version of public docket (including
  public comments) is available at
• www.epa.gov/edocket/
• Search for docket ID No. OAR-2002-0058

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Contacts

• Rule Development Compliance
• Jim Eddinger Greg Fried (OECA)
• 919-541-5426 202-564-7016
• eddinger.jim_at_epa.gov fried.greg_at_epa.gov
• Region 4
• Leonardo Ceron
• 404-562-9129
• ceron.leonardo_at_epa.gov

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The Effects of Asking Questions
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• ANY QUESTIONS?