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MEMORANDUM
TO:
Jim
Eddinger,
EPA/
ESD
FROM:
Roy
Oommen,
ERG/
MOR
DATE:
November
17,
2003
SUBJECT:
Summary
of
October
17,
2003
Boiler
Meeting
with
the
Sugarcane
Industry
A
meeting
between
the
U.
S.
Environmental
Protection
Agency
(
EPA)
and
the
sugarcane
industry
was
held
on
October17,
2003
in
Research
Triangle
Park,
NC.
The
purpose
of
the
meeting
was
to
discuss
the
sugarcane
industry's
comments
on
the
proposed
Industrial,

Institutional,
and
Commercial
Boiler
and
Process
Heater
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP).

Meeting
attendees
included
representatives
of
the
OAQPS
Emission
Standards
Division
of
the
Environmental
Protection
Agency
(
EPA)
and
AFMA.
A
complete
list
of
attendees
(
with
their
affiliation)
is
included
as
attachment
1.

Members
of
the
sugarcane
industry
discussed
comments
submitted
on
the
Boiler
NESHAP.
The
meeting
agenda
is
included
in
attachment
2.
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Attachment
1
Meeting
Attendance
List
Meeting
Attendance
List
Jose
Alvarez
Sugar
Cane
Growers
Cooperative
Dave
Buff
Golder
Associates
David
Cooper
University
of
Central
Florida
David
Dee
Landers
and
Parsons
Jim
Eddinger
U.
S.
Environmental
Protection
Agency
OAQPS
Dave
Guinnup
U.
S.
Environmental
Protection
Agency
OAQPS
Kathy
Lockhart
Sugar
Cane
Growers
Cooperative
Roy
Oommen
ERG
Draft
Agenda
for
EPA
Boiler
MACT
B
Florida
Sugar
Industry
Group
Meeting
October
17,
2003:
9
AM
to
11
AM
Location:
U.
S.
EPA,
Research
Triangle
Park,
N.
C.

Purpose
of
Meeting
and
Introductions
(
10
minutes)

Rule
Status
(
by
EPA)
(
10
minutes):

Current
state
of
rule
development
Deadline
for
submission
to
OMB
Deadline
to
publish
final
rule
Discussion
of
Major
Issues
for
Florida
Sugar
Industry
(
75
minutes)

Exemptions
for
bagasse
fuel
CO
limits
for
solid
fuel
category
Hg
limits
for
solid
fuel
category
Fuel
switching
provisions
Use
of
F­
Factor
for
determining
heat
input
Opacity
operating
limit
Bubble
provisions
Activated
carbon
injection
for
Hg
control
Rental/
Temporary
boilers
Risk­
based
option
for
Manganese
Monitoring,
Recordkeeping,
Reporting
Risk­
Based
options/
Hazard
Index
Operating
parameter
limits
Applicability
to
non­
major
boiler
Summary
and
Schedule
for
Additional
Information
(
10
minutes):

Next
steps
Summary
of
additional
information
needed
by
EPA
Schedule
for
supplying
information
