**Re: Status of Changes to Boilers rules since 2011** Notes Link **Jim Eddinger** to

: Higgins, Cortney Cc : RobertJ Wa yland, Mary Johnson

From: Jim Eddinger/RTP/USEPA/US To: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> Cc: RobertJ W ayland/RTP/USEPA/US@EPA, Mary Johnson/RTP/USEPA/US@EPA Cortney, Here are updated lists of changes for Boiler MACT and Boiler Area Sources. **Changes from the 2011 Final Rules Boiler MACT (Major Source)**   Compliance date for existing units extended to 3 years after promulgation of final amended rule.  Dioxin work practices o Work practice standards, in lieu of numeric emission limits, for dioxin/furan emissions for all subcategories  Work practice for startup/shutdown o Revised definitions of startup and shutdown

` o Revise work practice from following manufacturer's recommended procedures to starting up on clean fuels and engaging controls once coal, biomass, or heavy oil is fired.  Reduced the frequency of tune - ups from annual to every 5 years for limited use units and <5 MMBtu/h units in the gas and light oil subcategories.  Removing requirement that new boilers must conduct an initial tune - up  PM now considered a combustion - based pollutant for biomass o Separate PM emission limits for each design -based biomass subcategory instead of single limit for all units firing biomass  Total selected metals o Alternate TSM emission limits (to PM emission limits) for subcategories  CO CEMS o Alternate CO CEMS -based emission limits (to stack test

– based limits) for subcategories with CEMS data, couple with CEM S -based monitoring  Emission limit changes o Changes due to new data, QA of old data, Shifting of units between subcategories, and a 99% UPL for CO instead of 99.9% o Existing source emission limits: HCl - 10 limits are more stringent, 3 are less stringent, and 1 is the sameMercury - 3 limits are more stringent, 11 are less stringent PM - 2 limits are more stringent, 7 are less stringent, and 5 are the same CO - 4 limits are more stringent, 10 are less stringent o New source emission limits: HCl - 13 are less stringent, and 1 is the same Mercury - 11 limits are more stringent, 2 are less stringent, and 1 is the same PM - 9 are less stringent, and 5 are the same CO - 3 limits are more stringent, 11 are less stringent  S ubcategory changes o Separate subcategories for units designed to combust light or heavy liquids instead of single liquid fuel subcategory o Separate subcategories for kiln - dried biomass stokers and wet biomass stokers instead of a single biomass stoke r subcategory o A new coal fluidized bed with fluidized bed heat exchanger subcategory  More clearly defining the scope of the energy assessment and allowing for more streamlined assessments, including allowing sources already operating under certain energy management programs to satisfy the assessment requirement  Applicability - clarified that the exemption for boilers used in R&D inclide boilers used for testing the propulsion systems of naval vessels.  Monitoring changes o Proposing the use of O 2 trim systems instead of O 2 CEMS o 30 - day rolling averages for most parameter monitori ng instead of 12 - hour block averages o PM CEMS requirement removed for biomass units o PM CEM requirement for other large units changed to a parameter monitoring system o Added alternate method for demonstrating continuous compliance with the HCl emiss ion limit by allowing using SO2 CEMS if source has acid - gas control technology. **Boiler Area Source Rule**

 Revising provisions for existing dual - fuel fired units that fuel switch from gas to coal, biomass or oil such that they would still be considered existing sources  Clarifying that electric boilers, residential boilers and temporary boilers are not part of the source categories being regulated  Providing subcategories for seasonally - operated boilers and limited - use boilers  Am ending the mercury and CO e mission limits for coal fired boilers  Am ending emissions limits o Mercury limit changing from 4.8 lb/TBtu to 22 lb/TBtu o CO limit changing from 400 ppm to 420 ppm  Removing requirement that new boilers must conduct an initial tune - up  Extending by two years the initial compliance date for existing area source boilers subject to the tune up requirement  Requiring tune - ups every five years, instead of every two, for certain area source boilers: seasonally operated boilers, limited - use boilers, oil - fire d boilers with heat capacity equal to or less than 5 MMBtu/hr and boilers with oxygen trim systems  Clarifying that, as part of the tune - up, CO measurements may be taken with a portable CO analyzer  Allowing use of oxygen trim systems Revising averaging peri od for parameter monitoring and compliance to a 30 - day rolling average

instead of a 12 - hour block average  Revising PM emission limit requirements such that combustion of oil meeting certain sulfur content requirements by new oil - fired boilers is considered an alternative method of meeting the PM emission standard and that such units are not required to meet the PM emission limit  Reducing the fuel sampling and performance testing requirements such that after demonstration of initial compliance, under certain circumstances, further fuel sampling for boilers subject to a mercury emission limit and further PM performance testing for boilers subject to a PM emission limit is not required  Providing the option of continuous emissions monitoring to demonstrate conti nuous compliance with the CO emission limit  More clearly defining the scope of the energy assessment and allowing for more streamlined assessments, including allowing sources already operating under certain energy management programs to satisfy the assessm ent requirement  Revising the deadline for initial notification for existing area source boilers to no later than January 20, 2014  Revising notification requirement for instances where a boiler switched fuels, made a physical change, or took a permit limit such that the notification is due within 30 days of the change rather than 30 days prior to the change  Revising various definitions including "startup," "shutdown" and "period of gas curtailment or supply interruption" Jim

_______________ Jam es A . Eddinger Energy Strategies Group Sector Policies and Programs Division 919 - 541 - 5426

From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> To: RobertJ W ayland/RTP/USEPA/US@EPA Cc: Jim Eddinger/RTP/USEPA/US@EPA Date: 12/11/2012 03:06 PM Subject: Status of Changes to Boilers rules since 2011 Hi Bob and Jim, Can you update the following list of changes made since the 2011 final Boilers rules? This is a list based on the May draft of the rule, and I was hoping you could help me update it to the curren t draft of the rule. Thanks! **Changes from the 2011 Final Rules Boiler MACT (Major Source)**   Compliance date for existing units extended to 3 years after promulgation of final amended rule. Dioxin work practices o Work practice standards, in lieu of numeric emission limits, for dioxin/furan emissions for all subcategories  Work practice for startup/shutdown o Revised definitions of startup and shutdown

` o Revise work practice from following manufacturer's recommended procedure s to starting up on clean fuels and engaging controls once coal, biomass, or heavy oil is fired.  Reduced the frequency of tune - ups from annual to every 5 years for limited use units and <5 MMBtu/h units in the gas and light oil subcategories.  Removing requirement that new boilers must conduct an initial tune - up  PM now considered a combustion - based pollutant for biomass o Separate PM emission limits for each design -based biomass subcategory instead of single limit for all units firing biomass  Total selected metals o Alternate TSM emission limits (to PM emission limits) for subcategories  CO CEMS o Alternate CO CEMS -based emission limits (to stack test

– based limits) for subcategories with CEMS data, couple with CEMS -based m onitoring  Emission limit changes o Changes due to new data, QA of old data, Shifting of units between subcategories, and a 99% UPL for CO instead of 99.9% o Existing source emission limits: HCl - 10 limits are more stringent, 3 are less stringent, and 1 is the same Mercury - 3 limits are more stringent, 11 are less stringent PM - 2 limits are more stringent, 7 are less stringent, and 5 are the same CO - 4 limits are more stringent, 10 are less stringent o New source emission limits: HCl - 13 are less stringent, and 1 is the same Mercury - 11 limits are more stringent, 2 are less stringent, and 1 is the same PM - 9 are less stringent, and 5 are the same CO - 3 limits are more stringent, 11 are less stringent  Subcategory changes o Separate subcategories for units designed to combust light or heavy liquids instead of single liquid fuel subcategory o Separate subcategories for kiln - dried biomass stokers and wet biomass stokers instead of a single biomass stoker subcategory o A new coal fluidized bed with fluidized bed heat exchanger subcategory  More clearly defining the scope of the energy assessment and allowing for more streamlined assessments, including allowing sources already operating under certain energy management programs to satisfy the assessment requirement  Applicability - clarified that the exemption for boilers used in R&D inclide boilers used for testing the propulsion systems of naval vessels.  Monitoring changes o Proposing the use of O 2 trim systems instead of O 2 CEMS o 30 - day rolling averages for most parameter monitoring instead of 12 - hour block averages o PM CEMS requirement removed for biomass units o PM CEM requirement for other large units changed to a parameter monitoring systemo Added alternate method for demonstrating continuous compliance with the HCl emission limit by allowing using SO2 CEMS if source has acid - gas control technology. **Boiler Area Source Rule**  Created a new subcategory for seasonally operated boilers o Required to complete a tune - up every five years, instead of on a biennial basis as is required for non - seasonal boilers  Amending rule to specify that all existing boilers subject to the tune - up requirement would have three ye ars (by March 21, 2014) in which to demonstrate initial compliance, instead of one year to demonstrate initial compliance.  Amending the monitoring requirements to allow sources subject to a carbon monoxide emission limit the option to install, ope rate and maintain a carbon monoxide and oxygen continuous emission monitoring system.  Changing the requirement for subsequent tune - ups only for oil - fired boilers equal to or less than 5 MMBtu/hr to a tune - up once every 5 years.  Adding res idential boilers and electric boilers to the list of boilers not subject to subpart JJJJJJ to clarify that boiler used in residences located at commercial (farms) and institutional (universities) facilities are not subject to the rule. Also ddded temporar y boilers to this list.  Revising the definition for “Hot water heater” to include small not water boilers.  Amending the mercury and CO emission limits for coal fired boilers. o Mercury limit changing from 4.8 lb/TBtu to 22 lb/TBtu o CO limit changing from 400 ppm to 420 ppm