INDUSTRIAL BOILER MACT INDUSTRIAL BOILER MACT RULERULE

(Title 40 CFR 63 Subpart DDDDD)(Title 40 CFR 63 Subpart DDDDD)

Annual DoD ConferenceAnnual DoD ConferenceEnvironmental Air Quality WorkshopEnvironmental Air Quality Workshop

June 29, 2005June 29, 2005

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IMPORTANT DATESIMPORTANT DATES Proposal Date Proposal Date – January 13, 2003– January 13, 2003 Promulgation Date Promulgation Date – September 13, 2004– September 13, 2004 Effective Date Effective Date – November 12, 2004– November 12, 2004 Additional CommentAdditional Comment

Period NoticePeriod Notice - June 27, 2004- August 11, 2005- June 27, 2004- August 11, 2005

Initial Notification DatesInitial Notification Dates• March 12, 2005March 12, 2005 – Existing units– Existing units

• 15 days after startup 15 days after startup – New units– New units

Compliance DateCompliance Date

• Existing units Existing units - - September 13, 2007September 13, 2007

• New units New units – S– Startup tartup

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INDUSTRIAL BOILER MACTINDUSTRIAL BOILER MACT

Source categories covered:Source categories covered:

• Industrial BoilersIndustrial Boilers

• Institutional/Commercial BoilersInstitutional/Commercial Boilers

• Process HeatersProcess Heaters Indirect-fired – combustion gases do not Indirect-fired – 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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SUBCATEGORIESSUBCATEGORIES Three 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 firetubes and others < 10 MM Btu/hr)Small (all firetubes and others < 10 MM Btu/hr)• Limited-use (< 10% capacity factor)Limited-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 fuel-fired electric utility boilersFossil fuel-fired electric utility boilers Boilers burning municipal wasteBoilers burning municipal waste Boilers burning hazardous wasteBoilers burning hazardous waste Boilers burning medical wasteBoilers burning medical waste Black liquor recovery boilersBlack liquor recovery boilers Temporary/rental gas or liquid fuel boilers (<180 days)Temporary/rental gas or liquid fuel boilers (<180 days) Hot water heatersHot water heaters Waste heat boilersWaste heat boilers

Synthetic minors –becomes an area sourceSynthetic minors –becomes an area source

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EMISSIONS LIMITSEMISSIONS LIMITSExisting UnitsExisting Units

Existing large solid fuel unitsExisting large solid fuel unitsPM -- 0.07 lb/million Btu, PM -- 0.07 lb/million Btu, OROR TSM – 0.001 lb/million Btu TSM – 0.001 lb/million BtuHCl -- 0.09 lb/million Btu (~ 90 ppm)HCl -- 0.09 lb/million Btu (~ 90 ppm)Hg – 9 lb/trillion BtuHg – 9 lb/trillion Btu

Existing limited use solid fuel unitsExisting limited use solid fuel unitsPM -- 0.21 lb/million Btu, PM -- 0.21 lb/million Btu, OROR TSM – 0.004 lb/million Btu TSM – 0.004 lb/million Btu

No emissions standards for:No emissions standards for:• existing small solid fuel units existing small solid fuel units • existing liquid fuel unitsexisting liquid fuel units• existing gaseous fuel unitsexisting gaseous fuel units

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EMISSION LIMITSEMISSION LIMITSand WORK PRACTICE STANDARDSand WORK PRACTICE STANDARDS

New UnitsNew Units New solid fuel unitsNew solid fuel units

PM -- 0.025 lb/million Btu, PM -- 0.025 lb/million Btu, OROR TSM 0.0003 lb/million Btu TSM 0.0003 lb/million BtuHCl -- 0.02 lb/million Btu (20 ppm)HCl -- 0.02 lb/million Btu (20 ppm)Hg -- 3 lb/trillion BtuHg -- 3 lb/trillion BtuCO -- 400 ppm @ 7% oxygen (NOT FOR SMALL UNITS)CO -- 400 ppm @ 7% oxygen (NOT FOR SMALL UNITS)

New liquid fuel unitsNew liquid fuel unitsPM -- 0.03 lb/million BtuPM -- 0.03 lb/million BtuHCl -- 0.0005 lb/million Btu (large units)HCl -- 0.0005 lb/million Btu (large units) 0.0009 lb/million Btu (small and limited use units)0.0009 lb/million Btu (small and limited use units)CO – 400 ppm @ 3% oxygen (NOT FOR SMALL UNITS)CO – 400 ppm @ 3% oxygen (NOT FOR SMALL UNITS)

New gaseous fuel-fired unitsNew gaseous fuel-fired unitsCO – 400 ppm @ 3% oxygen (NOT FOR SMALL UNITS)CO – 400 ppm @ 3% oxygen (NOT FOR SMALL UNITS)

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CONTROL TECHNOLOGY BASISCONTROL TECHNOLOGY BASIS

Existing Solid Fuel BoilersExisting Solid Fuel Boilers

• Large Units - Baghouse (PM/metals/Hg)/ Scrubber (HCl)Large Units - Baghouse (PM/metals/Hg)/ Scrubber (HCl)

• Limited-Use Units – ESP (PM/metals)Limited-Use Units – ESP (PM/metals)

New UnitsNew Units• Based on NSPS and State RegulationsBased on NSPS and State Regulations

• Baghouse/ Scrubber / CO LimitBaghouse/ Scrubber / CO Limit

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COMPLIANCE OPTIONSCOMPLIANCE OPTIONS

Conduct stack emission testsConduct stack emission tests

Conduct fuel analysisConduct fuel analysis

Emissions averagingEmissions averaging

• (large solid fuel units only)(large solid fuel units only)

Health-based compliance alternatives for Health-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 limits Operating limitsOperating limits

• For PM, TSM and mercury limits For PM, TSM and mercury limits Opacity (for dry systems)Opacity (for dry systems)

• Existing units – 20% opacity (6 minute average)Existing units – 20% opacity (6 minute average)• New units – 10% opacity (1 hour block average)New units – 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

• For HClFor HCl Scrubber parameters (pH, pressure drop, liquid flow, Scrubber parameters (pH, pressure drop, liquid flow,

sorbent injection rate)sorbent injection rate)• 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

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COMPLIANCE MONITORING (cont.)COMPLIANCE MONITORING (cont.)

MonitoringMonitoring

• Opacity (by COM) – dry control systemsOpacity (by COM) – dry 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/hr Annual CO tests for other new units Annual CO tests for other new units Exempt data from <50% load and based on 30-Exempt 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

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Additional Compliance Additional Compliance Provisions Provisions

Emission AveragingEmission Averaging

• Only existing large solid fuel unitsOnly existing large solid fuel units

• Initial compliance based on maximum capacity Initial compliance based on maximum capacity

• Continuous compliance on a 12-month rolling Continuous compliance on a 12-month rolling

average basisaverage basis Each monthly calculation based on monthly fuel use Each monthly calculation based on monthly fuel use

and previous compliance test results for each boilerand previous compliance test results for each boiler

• Must submit emission averaging planMust submit emission averaging plan

• Must maintain, at a minimum, the emission Must maintain, at a minimum, the emission

controls employed on the effective datecontrols employed on the effective date

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Additional Compliance Provisions Additional Compliance Provisions Health-based HCl compliance alternativeHealth-based HCl compliance alternative

• 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 HCl-equivalent Must calculate total maximum hourly mass HCl-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 Site-specific compliance demonstrationSite-specific compliance demonstration

• Hazard Index (HI) can not exceed 1.0Hazard Index (HI) can not exceed 1.0

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Additional Compliance ProvisionsAdditional Compliance Provisions Health-based TSM compliance alternativeHealth-based TSM compliance alternative

• 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 Eligible for demonstrating compliance based on 7

metals excluding manganese by using:metals 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 Site-specific compliance demonstrationSite-specific compliance demonstration

• Hazard Quotient (HQ) can not exceed 1.0Hazard Quotient (HQ) can not exceed 1.0

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Additional Details of Health-Based Additional Details of Health-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 Reconsideration Three petitions for reconsideration were Three petitions for reconsideration were

receivedreceived• General Electric CompanyGeneral Electric Company• Joint petitionJoint petition

NRDCNRDC EIP (Environmental Integrity Project)EIP (Environmental Integrity Project)

• EIPEIP Two 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 Power-Ohio (and 6 American Public Power-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 Petition IssueIssue

• 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 case-by-Common stack testing is handled on a case-by-case basis by OECA/Regionscase basis by OECA/Regions

OECA’s general policy is that each duct to a common stack OECA’s general policy is that each duct to a common stack must be testedmust be tested

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NRDC – EIP PetitionNRDC – EIP 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• Health-based compliance alternativesHealth-based compliance alternatives

CAA does not authorize plant-by-plant risk-CAA does not authorize plant-by-plant risk-based exemptionsbased exemptions

Basis for development of health-based Basis for development of health-based compliance alternativescompliance alternatives

Procedures for demonstrating compliance Procedures for demonstrating compliance (Appendix A) (Appendix A)

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Recent Federal Register NoticeRecent Federal Register Notice FR June 27, 2005, Vol. 70, Num. 122, pg 36907-36915FR June 27, 2005, Vol. 70, Num. 122, pg 36907-36915

Request for comments on:Request for comments on:• Tiered Risk assessment Methodology (appendix A)Tiered Risk assessment Methodology (appendix A)

Look-up tables and Methodology (HCL, Mn, appendix A)Look-up tables and Methodology (HCL, Mn, 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, Cl, Mn (applicability cut off for RA’s)HI or HQ of 1.0 for HCL, Cl, Mn (applicability cut off for RA’s)

• Background concentrations (were not considered) Background concentrations (were not considered) • Overall Adoption of Health based compliance alternative for MnOverall Adoption of Health based compliance alternative for Mn• Exclusion of Mn from the TSM limit in table 1Exclusion of Mn from 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 firetube or Are “hybrid boilers” considered firetube or watertube boilers?watertube 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:

• www.epa.gov/ttn/atw/boiler/boilerpg.htmlwww.epa.gov/ttn/atw/boiler/boilerpg.html

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. OAR-2002-0058Search for docket ID No. OAR-2002-0058

ContactsContacts

Rule DevelopmentRule Development ComplianceCompliance

Jim EddingerJim Eddinger Greg Fried (OECA)Greg Fried (OECA)

919-541-5426 919-541-5426 202-564-7016202-564-7016eddinger.jim@epa.goveddinger.jim@epa.gov fried.greg@epa.govfried.greg@epa.gov

Region 4Region 4

Leonardo CeronLeonardo Ceron

404-562-9129404-562-9129ceron.leonardo@epa.govceron.leonardo@epa.gov

The Effects of Asking Questions

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ANY ANY QUESTIONS?QUESTIONS?