Preliminary
Assessment
of
Comments
Received
on
Industrial
Boiler
and
Process
Heater
MACT
OMB
Briefing
October
23,
2003
2
STATUS

Current
Activities:


revising
rule
language

drafting
promulgation
preamble

Schedule

Draft
responses
completed
 
end
of
September
2003

Draft
promulgation
package
 
end
of
October
2003

FAR
(
WG
closure)
­
November
6,
2003

OMB
review
­
late­
November
2003

Promulgation
 
February
28,
2004
3
Proposed
Subcategories

Three
main
subcategories
based
on
fuel
type:


Solid
fuel­
fired
units

Liquid
fuel­
fired
units

Gaseous
fuel­
fired
units

Additional
subcategories

based
on
size

Large
(
Greater
than
10
MM
Btu/
hr
heat
input)


Small
(
all
firetubes
and
others
less
than
10
MM
Btu/
hr
heat
input)


based
on
use

Limited­
use
(
less
than
10%
capacity
factor)


Total
of
9
subcategories
4
Proposed
MACT
Levels
 
Existing
Units

Existing
large
solid
fuel­
fired
units
PM
­­
0.07
lb/
million
Btu
HCl
­­
0.09
lb/
million
Btu
(~
90
ppm)

Hg
 
7
lb/
trillion
Btu

technology
basis
­
baghouse
(
metals/
Hg)/
scrubber
(
HCl)


Existing
limited
use
solid
fuel­
fired
units
PM
­­
0.2
lb/
million
Btu

technology
basis
­
ESP
(
metals)


No
emissions
standards
for
existing
small
solid
fuel
units
or
any
existing
liquid
and
gaseous
fuel­
fired
units
5
Proposed
MACT
Levels
 
New
Units

New
solid
fuel­
fired
units
PM
­­
0.026
lb/
million
Btu
HCl
­­
0.02
lb/
million
Btu
(
20
ppm)

Hg
 
3
lb/
trillion
Btu
CO
 
400
ppm
@
3%
oxygen
(
not
for
small
units)


New
liquid
fuel­
fired
units
PM
­­
0.03
lb/
million
Btu
HCl
­­
0.0005
lb/
million
Btu
CO
 
400
ppm
@
3%
oxygen
(
not
for
small
units)


New
gaseous
fuel­
fired
units
CO
 
400
ppm
@
3%
oxygen
(
not
for
small
units)
6
Proposed
Testing
and
Monitoring
Requirements

Testing:


Initial
compliance
tests
(
PM,
HCl,
mercury)


Annual
performance
tests

Monitoring

Process
parameters
(
opacity,
pressure
drop,
CO,

sorbent
injection
rate,
fuel,
etc.)


Continuous
Compliance

Demonstrated
by
maintaining
operating
limits
(
process
parameters)


Based
on
averages
set
during
compliance
test
7
Additional
Proposal
Provisions

Alternate
metal
standard

Solid
fuel­
fired
units
subcategories
only

minimize
impacts
on
small
businesses

sum
of
8
selected
metals:
arsenic,
beryllium,

cadmium,
chromium,
lead,
manganese,
nickel,

and
selenium

Proposed
limit
is
0.001
lb/
million
Btu

Facility
could
elect
to
comply
with
either
the
PM
limit
or
the
alternate
metal
standard
8
Specific
Comments
Requested

Not
in
proposed
rule
but
preamble
requested
comments
on
these
provisions

Bubbling
Compliance
Alternative

Facility
set
limits
for
each
unit
such
that
the
total
emissions
from
all
units
are
equal
to
or
less
than
the
MACT
limit.


Risk­
Based
Exemptions

Applicability
cutoff
(
subcategory
delisting)


HCl
applicability
cutoff
(
exempt
only
from
the
HCl
MACT
limit)
9
Public
Comments

190
submitted

100
by
industry
companies

42
by
trade
associations

18
by
State
and
local
agencies

12
by
municipalities

6
by
universities

4
by
environmental
organizations

3
by
federal
agencies
(
DOE,
DOD,
NASA)
10
Major
Comments
Received

Need
minimum
size
threshold
for
applicability

Risk­
based
exemptions

Will
cause
severe
economic
impacts
on
certain
facilities
(
municipalities,
universities,
furniture,
textile)
request
exemption
or
separate
subcategory

Extend
the
compliance
period

Requested
broad
definition
as
in
General
Provision

Supported
bubbling
provision
(
emission
averaging)


Mercury
emission
limit

CO
limit
and
monitoring
requirement

Fuel
analysis
testing
requirements

Operating
limits
11
Preliminary
Assessments

Need
minimum
size
threshold
for
applicability

No
size
cutoff,
MACT
covers
all
units
at
major
source,

however
will
add
provisions
exempting
all
existing
small
units
from
all
reporting
requirements
and
require
existing
large
gas
and
oil
units
only
initial
notification
(
no
SSM
plan)


Risk­
based
exemptions

Waiting
decision
 
preliminary
HCl
assessment
been
conducted
(
See
next
slide)


Will
cause
severe
economic
impacts
on
certain
facilities
(
municipalities,
universities,
furniture,
textile)
request
exemption
or
separate
subcategory

No
technical
justification
for
creating
additional
special
subcategories
(
similar
to
boilers
in
other
industries).

Preliminary
analysis
indicates
little
benefit
(
to
the
source)
of
creating
these
separate
subcategories.
12
Preliminary
HCl
Modeling
Results

Combined
(
HCl,
HF,
Cl2)
Hazard
Index

Utility
boilers
 
maximum
HI

Large
­
0.046
(
acute)
and
0.195
(
chronic)


Small
­
0.038
(
acute)
and
0.160
(
chronic)


Industrial
boilers
 
maximum/
minimum
HI

Coal
 
5.65
­
0.018
(
acute)
and
179.2
­
0.581
(
chronic)


Wood
­
0.415
 
0.0002
(
acute)
and
25.6
­
0.004(
chronic)


Conclusions:


Utility
Boilers
 
Uncontrolled
units
unlikely
to
have
adverse
effects.


Industrial
Boilers
 
Maximum
HI
are
above
1.0
for
several
HAP
based
on
most
conservative
parameters.
Minimum
are
well
below
1.0
except
for
chronic
CL
from
coal
units.
13
Preliminary
Assessments
(
Cont.)


Extend
the
compliance
period

Will
extend
compliance
period
from
3
to
4
years.
Municipalities,

and
others,
requested
extension
to
be
more
in
line
with
utility
MACT
schedule
since
they
will
be
competing
with
utilities
for
the
limited
manpower
and
their
budgetary
process.


Requested
broad
definition
as
in
General
Provisions

Will
revise
definition
of
affected
source
to
the
broad
definition
as
in
General
Provisions.


Supported
bubbling
provision
(
emission
averaging)


Will
add
emissions
averaging
provision
(
modeled
after
Boat
Manufacturing
MACT)


Allowed
only
among
existing
sources
in
same
subcategory

Mercury
emission
limit

No
change
in
MACT
floor
approach.
Have
redone
MACT
floor
analysis
with
new
additional
(
3)
emission
data.
Limit
likely
to
go
slightly
higher
(
approx.
9
lbs/
TBtu).
14
Preliminary
Assessments
(
Cont.)


CO
limit
and
monitoring
requirement

Will
clarify
that
exceedance
is
not
an
emission
violation
but
a
deviation
and
a
trigger
for
corrective
action.
Due
to
costs,
will
revise
rule
to
require
CO
CEM
for
only
larger
units
(>
100
MMBtu/
h),
smaller
units
will
be
required
to
conduct
annual
CO
test.


Fuel
analysis
testing
requirements

Will
revise
to
allow
option
of
either
fuel
analysis
or
stack
testing
to
demonstrate
compliance.


Will
revise
to
require
new
fuel
analysis
only
if
add
new
fuel
type
or
from
a
new
supplier
of
certain
fuel
type
(
treated/
painted
wood)


Will
revise
to
require
fuel
analysis
testing
every
5
years.


Operating
limits

Will
revise
to
allow
for
effect
of
operating
at
low
loads.
For
CO,

exempt
data
from
<
50%
load.
For
control
device
parameters,
will
allow
range
(
90%
of
compliance
test
level,
as
in
other
MACTs)
15
ANY
QUESTIONS?
