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To: Mary Johnson, Jim Eddinger and Brian Shrager, EPA/SPPD 

From: Amanda Singleton and Roy Oommen, ERG 

Date: September 30, 2010 

Re: Minutes of September 22nd 2010 Meeting with Forest Products Industry

Meeting Agenda 

• Major Source Boiler Rule 

- Status update and schedule for Boiler MACT/GACT/CISWI 

- Health Based Emission Limits 

- MACT achievability concerns 

- Dioxin Furan Emission Limits 

- Data quality and Detection Levels 

- Limited use boilers 

- Stack testing logistics and costs 

• Area Source Boiler Rule 

Meeting Attendees 

Mary Johnson, EPA/SPPD 

Brian Shrager, EPA/SPPD 

Bob Wayland, EPA/SPPD 

Bill Maxwell, EPA/SPPD 

Ashok Jain, NCASI 

Annabeth Reitter, New Page Corporation 

Debra Lane, Rayonier 

Amy Marshall, URS 

Timothy Hunt, AF&PA 

Stephen Woock, Weyerhaeuser 

Roy Oommen, ERG 

Amanda Singleton, ERG 

Brian Mooney, Abitibi Bowater 

Rob Kaufmann, Koch Companies Public Sector 

Nick Hutson, EPA 

John Pinkerton, NCASI 

Corey Brandt, Smurfit-Stone Container Corporation 

Jim Eddinger, EPA/SPPD 

Amy Artmeier, Kapstone 

Jim Taylor, MWV 

Mike Curtis, Georgia Pacific 

Jeff Shumaker, International Paper 

Paul Noe, AF&PA (attending by phone) 
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Status Updates and Schedule 

Mr. Wayland discussed the current schedule for the promulgation package and a summary of major 

comment themes received to date on each of the four related proposals (Boiler MACT, Area Source 

Boilers, Non-hazardous secondary materials definition, and CISWI). 

In addition to the major comment summary provided by Mr. Wayland, Mr. Noe raised two other big 

issues concerning the major source boilers: 

• Biased phase II ICR data – OGC is looking into this. 

• Consideration of available data for fuel and load variability. 

Health Based Emission Limits 

Mr. Wayland noted that EPA is reviewing comments received on the health-based compliance alternative 

from the written docket comments and inquiries from Congress. 

MACT achievability and Control Integration Concerns 

Mr. Shumaker provided a specific example of concerns about the integration of up to five different 

control devices that could be required to meet the proposed limits. A CO catalyst has not been 

demonstrated on pulp mill biomass/combination boilers. In order for the control to work, the exhaust gas 

stream must be cleaned prior to introducing it to the catalyst. At a pulp mill, the exhaust gas stream is 

300F. In order to get CO control from the catalyst, a duct burner would need to be installed in order to 

heat the exhaust stream to 500-700F. In order for the catalyst to destroy the organic HAP, the exhaust 

stream would need to be heated to 700 – 800F. These duct burners would require additional energy and 

generate additional emissions. 

Mr. Jain noted that the competing needs to control different pollutants are in conflict with one another. 

The presence of sulfur in exhaust gas impacts mercury capture differently than it effects dioxin/furan 

formation. 

Several members of industry highlighted potential alternatives for revised MACT floor approaches and 

consideration of variability which are highlighted below: 

Alternative Approach

Ms. Marshall presented a summary of an alternative approach to estimate MACT floors using a sourceby-source approach instead of a pollutant-by-pollutant MACT floor analysis. 

CO Variability 

Mr. Pinkerton expressed concerns that while the proposed standards are based on short-term stack testing, 

units greater than or equal to 100 mmBtu/hr must demonstrate continuous compliance at all times use 

CEMS. EPA indicated that additional data has been received to demonstrate CO variability and it will 

consider this data in the final rule. 

Area vs. Major Source Data 

Mr. Pinkerton questioned whether or not only area source data can be used to establish the standard for 

area sources given the paucity of the dataset. EPA is reviewing comments submitted on this topic to 

make a decision. 
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Fuel Variability

Mr. Jain and others disagreed with the removal of fuel analysis outliers using an inter-quartile range 

(IQR) analysis. Industry was concerned that given the limited types of data EPA is considering as viable 

for inputs in the fuel variability analysis that the IQR analysis is inappropriate. Mr. Pinkerton referenced 

the previous bark fuel analysis study from NCASI that was performed for the vacated boiler MACT and 

requested that EPA consider additional data sources for fuel variability. 

Combination Boiler Issues

Ms. Artemeir and others presented the industry’s proposed approach for addressing combination boilers. 

She referenced the AF&PA written comments and indicated that combination boilers could be subject to 

the coal limits for fuel based HAP since coal is the predominant fuel source for mercury and chlorine. On 

the other hand, since biomass fuels are more variable and subject to larger swings in CO emissions, 

combination boilers should be subject to the biomass limits for CO. 

Ms. Reitter expressed concern that EPA’s claim that boilers can be designed to burn only a single fuel is 

flawed. She noted that the pulp and paper industry have many combination fuel boilers and even 

combinations of combustor designs (e.g., a combination PC/stoker boiler). 

Dioxin/Furans 

Many industry representatives in the room noted that the dioxin formation and controlling dioxins at 

biomass boilers is uncertain. Industry representatives requested EPA to review the data supporting the 

Tulane Environmental Law Center report to determine if dioxin/furans at boilers are above the practical 

quantitation limit (PQL). Debra Lane of Rayonier noted precedent in the Clean Water Act for using PQLs 

for a standard of whether or not the pollutant is present. 

If Dioxin/Furan remains a concern from boilers, Mr. Hunt noted that EPA and AF&PA’s economic 

analysis did not assume any cost for dioxin furan and that these costs would need to be investigated. 

Many representatives also questioned the legality of regulating dioxin/furans under Section 112 of the 

CAA, or whether only the 2, 3, 7, 8 –TCDD congener was the only dioxin listed under Section 112. 

Data Quality: Detection Levels 

Mr. Jain expressed concern about the range of detection levels in the database for both mercury and 

dioxin/furan data. He added that the concern of detection levels is magnified for mercury and 

dioxin/furan because there are 5 separate fractions of mercury and 17 different fractions for congeners. He 

reiterated concerns about how detection levels were reported differently under phase I and phase II of the 

ICR. He added that sources will have difficulty demonstrating compliance because both D/F and Hg have 

proposed limits less than the PQL for the reference methods. 

Aside from detection level concerns, Debra Lane and others expressed concerns about the data in general. 

EPA indicated that many data corrections have been received and data is being updated and revised as 

appropriate. 
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Limited Use Units 

Several members of industry requested EPA to reconsider a limited use subcategory, similar to the 

subcategory included in the 2004 vacated standard. 

Stack Testing Costs and Frequency 

Several members of industry were concerned with the frequency and expense of an annual testing 

program for all five regulated pollutants. They expressed concern on the extent of steam outages these 

frequent tests would cause and the considerable amount of pre-test planning and coordination time that 

did not appear to be considered in the cost estimates of the proposal. Industry also noted that due to the 

extremely low numeric emission limits, which often fall below the detection levels of test method 

capabilities, the reduced testing frequency allowance for units with emissions below 90 percent of limit 

would not provide any significant relief from annual testing. 

Area Source Boiler Rule 

Tim Hunt inquired on whether or not a POM limit (using CO as a surrogate) is necessary for biomass and 

liquid boilers in order to meet the 90 percent reduction requirement under the 1990 112(c)(6) inventory. 

As an alternative to exemption from the standard, Mr. Hunt laid out the case that the CAA does not 

require EPA to establish numerical emission limits for area source boilers and work practices are 

warranted under 112(d)(5). Mr. Hunt added that if a numerical limit is retained at area source biomass and 

liquid boilers, EPA should consider new data, additional subcategories, and more variability as well as the 

related limits of the corresponding major source boiler rule.