INDUSTRIAL BOILER MACT (40 CFR 63 Subpart DDDDD)

Atlanta, Georgia

May 24, 2006

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IMPORTANT DATES

• Proposal Date – January 13, 2003

• Promulgation Date – September 13, 2004

• Compliance Date – Existing units - September 13, 2007

– New units – startup

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INDUSTRIAL BOILER MACT

• Source categories included:

– Industrial Boilers

– Institutional/Commercial Boilers

– Process Heaters• Indirect-fired – combustion gases do not come

in contact with process materials.

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EMISSIONS LIMITSExisting Units

• Existing large solid fuel unitsPM -- 0.07 lb/million Btu, OR TSM – 0.001 lb/million BtuHCl -- 0.09 lb/million Btu (~ 90 ppm)Hg – 9 lb/trillion Btu

• Existing limited use solid fuel unitsPM -- 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

• No work practice standards

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EMISSION LIMITSand WORK PRACTICE STANDARDS

New Units

• New solid fuel unitsPM -- 0.025 lb/million Btu, OR TSM 0.0003 lb/million BtuHCl -- 0.02 lb/million Btu (20 ppm)Hg -- 3 lb/trillion BtuCO -- 400 ppm @ 7% oxygen (NOT FOR SMALL UNITS)

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

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

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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– Based on worst fuel type or mixture

AND/OR

• Fuel analyses– Initial and every 5 years– Each new fuel type– Based 90% confidence level of minimum 3 fuel

samples– Based on worst fuel type or mixture

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COMPLIANCE TESTING Performance Tests Requirements

• Listed in Table 5 of Subpart DDDDD of Part 63

• Common EPA test methods for PM, TSM, HCl, mercury, and CO limits– EPA Method 1: sampling location/traverse points– EPA Method 2: velocity/volumetric flowrate– EPA Method 3: oxygen/CO2 concentration– EPA Method 4: moisture content– EPA Method 19: converting concentrations to lb/MMBtu by using F-factor

• For PM– EPA Methods 5 or 17

• For TSM– EPA Method 29

• For HCl– EPA Method 26 or 26A

• For mercury– EPA Method 29 or 101A– ASTM D6522-00 or PTC 19, Part 10

• For CO– EPA Methods 10, 10A, or 10B– ASTM D6522-00 (natural gas only)

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COMPLIANCE TESTINGFuel Analysis Requirements

• Listed in Table 6 to Subpart DDDDD• Required steps

1. Collect samples (using procedure in 63.7521(c) or ASTM D2234-00

2. Composite fuel samples (63.7521(c))

3. Prepare composite samples (ASTM D2013-01)

4. Determine heat content (ASTM D5865-03a)

5. Determine moisture content (ASTM D3173-02)

6. Determine HAP concentration (Listed method or equivalent)

7. Convert HAP concentration to lb/million Btu

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COMPLIANCE TESTINGFuel Analysis Requirements (cont.)

• Must use equation 8 to demonstrate compliance– One-sided z-statistic test– P90 = mean + (SD * t)

• P90 = 90th percentile confidence level • Mean = Arithmetic average concentration in the fuel samples• SD = Standard deviation in the fuel samples• t = t distribution critical value for 90th percentile (0.1)

probability for appropriate degrees of freedom (number of samples minus one) obtained from Distribution Critical Value Table.

• Based on worst fuel type or mixture

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SPECIAL TESTING REQUIREMENTS

• New liquid fuel that burn only fossil fuel and do not burn residual oil (40 CFR 63.7506(a))– Not required to conduct performance tests for

PM and HCl– Must submit documentation– Must still demonstrate compliance with CO limit

• Use of alternative test methods – Must petition EPA for approval (40 CFR 63.7)

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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.)

• CO Monitoring (new units only)• CEM for large units > 100 million Btu/hr• Annual CO tests for other new units • Exempt data from <50% load and based on 30-day

average.

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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 maintain, at a minimum, the emission controls

employed on the effective date

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Additional Compliance ProvisionHealth-Based Compliance Alternatives

• Alternative compliance options available for the HCl limit and the total selected metals limit (TSM)– HCl: emissions of HCl and Cl2– TSM: emissions of manganese

• Sources that comply with source-wide health-based alternative for HCl do not have to comply with the technology-based HCl limit on an individual boiler basis

• Sources that comply with source-wide health-based alternative for manganese can ignore manganese when determining compliance with the TSM limit on an individual boiler basis

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How to Comply with Health-Based Compliance Options

• Lookup table analysis

• Site-specific risk assessment

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How to Conduct a Lookup Table Analysis: Overview

• Determine maximum hourly emission rates from each appropriate subpart DDDDD boiler or process heater– HCl and Cl2 or Mn

• Calculate total emission rate for source• Locate appropriate allowable emission

rate from lookup table• Compare source’s emission rate with

allowable emission rate

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How to Conduct a Lookup Table Analysis: Emissions Determination

• Emissions tests – HCl alternative: Must test for HCl and Cl2 – TSM alternative: Must test for Mn

• Fuel analysis – HCl alternative: Assume all chlorine detected

emitted as Cl2 – TSM alternative: Assume all Mn detected is

emitted

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How to Conduct a Site-Specific Risk Assessment

• Refer to EPA’s Air Toxics Risk Assessment Reference Library (http://www.epa.gov/ttn/fera/risk_atra_main.html)

• General outline of process:– Collect emissions information (HCl, Cl2, Mn) – Identify relevant source parameters for modeling

• stack heights, stack diameters, gas exit velocities, etc.

– Perform dispersion/exposure modeling– Calculate an estimate of risk to the individual most exposed

(Hazard quotient (HQ) for Mn and hazard index (HI) for HCl and Cl2)

• HQ: The ratio of a level of exposure for a single substance to a reference level (e.g., RfC) for that substance

• HI: The sum of more than one hazard quotient

– You are eligible for the alternative compliance option if your maximum chronic inhalation HI or HQ is < 1.0

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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

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

• Proposed amendment allowing testing of common stack in certain situation – October 31, 2005

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NRDC – EIP Petition

• Seeking reconsideration on:– Lack of standards for all HAP emitted on all

subcategories– Health-based compliance alternatives

• Granted petition and requested comment on June 27, 2005

• Published final action on December 28, 2005

– Retained health-based compliance alternatives

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INFORMATION AND CONTACT• Implementation tools (timelines, initial notification, state/local contacts,

Q/A) and information on the MACT rulemaking for industrial, commercial, and institutional boilers and process heaters is available on EPA’s web site at:

– www.epa.gov/ttn/atw/boiler/boilerpg.html

• An electronic version of public docket (including public comments) is available at:

– www.regulations.gov – Search for docket ID No. EPA-HQ-OAR-2002-0058

• Contact: Compliance Contact:– Jim Eddinger Greg Fried (OECA)– 919-541-5426 202-564-7016– eddinger.jim@epa.gov fried.gregory@epa.gov

Risk ContactScott Jenkins 919-541-1167

jenkins.scott@epa.gov

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ANY QUESTIONS?