adem.alabama.gov

Boiler MACTCISWI Rule

Wes Thornhill, Chief

Industrial Chemicals Section

Air Division

adem.alabama.gov

Boiler/CISWI MACT

On June 4, 2010, four interconnected proposed rules were published in the FR Major Source Boiler MACT Area Source Boiler MACT CISWI Section 129 Rule Definition of solid waste

adem.alabama.gov

Boiler/CISWI MACT

Comment Period ends August 23rd.

Court ordered promulgation date of December 16, 2010.

adem.alabama.gov

Boiler/CISWI MACT

What’s covered? Major Source Boiler MACT

Boilers at sources that have the potential to emit more than 10/25 of HAPs

Area Source Boiler MACT Boilers at sources that are not Major HAP Sources

CISWI Rule A unit that burns ANY solid waste.

RCRA solid waste definition

adem.alabama.gov

Boiler MACT

Boiler MACT (major source) For units greater than 10mmBTU/hr,

limits on the following PM (surrogate for non-Hg metals) Mercury HCL (surrogate for acid gases) CO (surrogate for non-dioxin organic HAPs) Dioxin/Furan

adem.alabama.gov

Boiler MACT

Boiler MACT (major source) Anticipated control device train

Carbon Injection Baghouse Scrubber And good combustion practices

adem.alabama.gov

Boiler MACT

Boiler MACT (major source) For ‘Gas 1’, Metal Process Furnaces and

units less than 10 mmbtu/hr, a work practice standard (annual tune up).

adem.alabama.gov

Boiler MACT

Boiler MACT (major source) ‘Beyond the floor’

All major source facilities are to conduct an “Energy Assessment”

Energy Star

adem.alabama.gov

Boiler MACT

Boiler MACT (major source) Testing (varies based on size and fuel)

Initial – PM, Hg, HCl, THC, Dioxin Monitoring

> 100 mmbtu/hr = CO CEMs > 250 mmbtu/hr = PM CEMs (non-gas units) Parametric monitoring (opacity, Delta P, etc…)

Compliance 30 Day average for CEMs, shorter terms for

parametric

adem.alabama.gov

Boiler MACT

Boiler MACT (major source) Impact EPA national estimates

Initial Cost = $9.5 Billion Annualized cost = $2.9 Billion

Industry national estimates (AF&PA) Initial Cost = $21 Billion

EPA benefits estimates $17-$41 Billion in health benefits

adem.alabama.gov

Boiler MACT

Boiler MACT (area source) Limits

Coal fired units Mercury CO as a surrogate for POM PM (new units)

Biomass and Oil fired units CO as a surrogate for POM PM (new units)

Beyond the floor Energy assessment

adem.alabama.gov

Boiler MACT

Boiler MACT (area source) <10 mmbtu/hr

Annual tune up

adem.alabama.gov

Boiler MACT

Boiler MACT (area source) Testing (varies based on size and fuel)

Initial – PM, Hg, CO

Monitoring > 100 mmbtu/hr = CO CEMs Parametric monitoring (opacity, Delta P, etc…)

Compliance Parametric

adem.alabama.gov

CISWI Rule

Commercial and Industrial Solid Waste (CISWI) Rule Burns ANY solid waste

Limits Cd, CO, HCl, Hg, Pb, PM, SO2, NOx,

dioxins/furans

adem.alabama.gov

CISWI Rule

CISWI Rule Anticipated control device train

Carbon injection Baghouse Scrubber SNCR Afterburner

And good combustion practices

adem.alabama.gov

CISWI Rule

CISWI Rule Testing

Initial and annual stack tests Reduced testing frequency for good performance

Monitoring CO CEMs CO and PM CEMs for units >250 mmbtu/hr Hg CEMs (kilns) COMs (w/out scrubber)

adem.alabama.gov

CISWI Rule

CISWI Rule Compliance

Hg monthly averages Daily averages for other CEMs 3-hour rolling averages for parametric 6-minute for COMs Annual control device inspections Operator certification

adem.alabama.gov

Waste

Solid Waste Definition The following are NOT solid wastes

Material used as fuel that remains within control of generator

Material used as an ingredient in a manufacturing process

Material that has been SUFFICIENTLY processed to produce a fuel

Material that has been confirmed through a case-by-case basis

adem.alabama.gov

Waste

Solid Waste Definition Wastes

Treated wood, construction debris, off-spec used oil, tires

Non-wastes Resinated wood, WWTP sludge, TDF (chipped

tires with steel removed), on-spec used oil

adem.alabama.gov

Boiler/CISWI MACT

Concerns Achievability, especially for smaller and area

sources FrankenMACT approach

adem.alabama.gov

Boiler/CISWI MACT

Concerns “Furthermore, we already

estimate no new CISWI sources will be

constructed due to the costs associated

with the MACT floor limits in the

proposed NSPS.”

EPA FR Vol. 75, No. 107, pg 31959

adem.alabama.gov

Boiler/CISWI MACT

Concerns Driving facilities away from wood and wood

waste units, and towards natural gas Wood is renewable Wood is available Wood may be considered carbon neutral Woodwaste is not a consumer level fuel Woodwaste may, otherwise, end up in landfills

adem.alabama.gov

Boiler/CISWI MACT

Concerns Accuracy of PM CEMs Some limits approach the edges of

detectability (1 ppm CO limit on liquid fueled boilers)

adem.alabama.gov

Boiler/CISWI MACT

Reminder!

Comment Period ends August 23rd.

Court ordered promulgation date of December 16, 2010.

adem.alabama.gov

Boiler/CISWI MACT

Questions???