CIBO-OMB Meeting Industrial Boiler MACT, Area Source, CISWI, and NHSM Rules

Page 1 of 13 15 June 2012 June 15, 2012

AGENDA
11:30 AM Lunch Prep Meeting Taberna Del Alabardero 1776 I Street NW

202-429-2200

2:00 PM OMB Meeting New Executive Office Building 725 17th Street, NW Room 10103 Contact: Mabel Echols

Attendees: Robert D. Bessett John C. deRuyter

Lisa M. Jaeger Fred Cleveland Rob Kaufmann Bryan Dierlam

Bob MorrowCIBO-OMB Meeting Industrial Boiler MACT, Area Source, CISWI, and NHSM Rules

Page 2 of 13 15 June 2012 Executive Summary

 Keep work practice approaches

 Need achievable limits for liquid units – only 3 units can comply with no cost

 Need consideration of solid fuel variabi lity in setting Hg and HCl limits for new and existing units

 Set work practices for CO for fossil units – industria l boiler CO and hydrocarbon data are in same range as EGU data. At a minimum, do not set CO limits <100 ppm.

 Need more time to comply

 Need more flexibility in emissions averaging

 Need fixes to NHSM rule so less materials are regulated as solid waste

 Other small fixes needed to boiler rules on technical issues
Boiler MACT Rule 1. CIBO strongly supports the improvements in corporated in the Dec. 23 proposed rule & strongly urges EPA to follow through with incorporating those in the final rule. Specific improvements include:

 Work practices for dioxin/furan emissions control

o Similar to Utility MATS approach.

 Work practices generally for Gas 1 units

 Dropping the H 2 S specification for Gas 2 fuels to be considered as Gas 1.

o Great help to continue and increase beneficial use of landfill gas.

 30-day rolling average peri ods for operating limits. 2. Achievability: Liquid Fuels

 Floor setting methodology relative to liquid fuels is a problem.

 CIBO’s analysis shows problems exist wit h achievability of liquid standards.
o Heavy Oil: 3 of 295 can m eet all standards simultaneously
o Light Oil: 0 of 262 units

o Non-Continental: 0 of 19

 Simple alternative compliance mechanism or work practice could be provided by EPA under its current authority fo r units that must fire oil.
o Use of ultra-low sulfur distillate /diesel fuel oil constitutes MACT

o Compliance demonstrated by fuel supplier certification.

 Best performers are in most cases usi ng fuel oils with lo w pollutant content (i.e. they are not in the floor due to use of add-on emission controls).

 Liquid fuels meeting the Comparabl e Fuels specification of 261.38 should also be included in this approach.

 If that cannot be done by definition, allow for a petition process to demonstrate the specific Comparable Fuel is similar in composition and combustion characteristics to ultra lo w sulfur distillate/diesel fuel oil.

 Need the alternative HCl compliance appr oach for liquid fired units based on fuel oil water content as provided in MATS.

o Same as MATS, no BMACT liquid top HCl performers utilized HCl emissions controls.CIBO-OMB Meeting Industrial Boiler MACT, Area Source, CISWI, and NHSM Rules

Page 3 of 13 15 June 2012 3. Achievability: Solid fuels HCl and Hg

 Solid fuel characteristics and variabili ty need to be considered for both new and existing units in order to estab lish workable and achievable standards.

 Proposed rule solid fuel approach wit h no fuel variability factor applied imposes a bias against coal fired units.

 Not reflective of demonstrated perfo rmance of the diverse combination of equipment and fuels.

 Data in the EPA database on all solid fuels provides insight on the range of fuel quality for Cl and Hg ac ross regulated sources.
o Decidedly different char acteristics of coal vs biomass, as well as the relative emissions control level requi red to meet the proposed limits.

 URS-generated charts from the EPA dat abase highlight the range of fuel quality that existing sources utilize.
o Page 7 - average facility fuel Hg and Cl data, respectively.

o Page 8 - maximum facility fuel Hg and Cl data, respectively.

 Coal quality varies consider ably across different mines and even within a specific mine and seam. Biomass characteristics also vary widely. Fuel variabi lity is absolutely critical when considering coal quality and its impact on fuel-based emissions.
o Existing boiler designs are based on specific fuel characteristics for proper combustion, to maintain oper ating efficiency, and achieve good emissions control system performance. Therefore, many facilities have limited fuel choice availability.
o Very low Hg and HCl emission limits ma ke it technically challenging at best to consistently achieve the emission limits with DSI/ACI technology; retrofit application of full scrubbing is technically infeasible in some cases due to congested facilit ies and wastewater limitations.

 Our analysis indicates only 5 of 378 coal stoker fired boilers (1.3%) can meet all December 2011 emission limits si multaneously with no capital cost expenditure. Draf t May 2012 emission limits can only be met by 10 of 387 units with no capital cost expenditure.
o This is the largest subcategory of solid fuel fired sources and the lowest percent of units t hat can meet the limits.
o This is a problem that EPA must address.

 CIBO supports EPA applying Fuel Vari ability Factors to address this achievability problem.
o EPA has adequate data to apply well-s upported fuel variability factors in order to accommodate the vari ation in fuels used across all regulated sources, especia lly coal fired units.
o EPA should consider looking at an “above the Floor” analysis if necessary to reach achievable standards.
o EPA should apply the same FVF to new source limits as applied to existing source limits.CIBO-OMB Meeting Industrial Boiler MACT, Area Source, CISWI, and NHSM Rules

Page 4 of 13 15 June 2012 4. Carbon Monoxide Standards: Wo rk practice vs emission limits

 Coal-fired EGU’s have a cost-effectiv e approach in the MATS rule, while Industrial coal-fired units have aggr essive emissions standards with enormous cost implications.
o 560,000 jobs tied to Utilities (NAICS 22)

o 11,930,000 jobs tied to Industr ial Manufacturers (NAICS 31-33) 1

 MATS work practice approach using tune-ups is equally applicable to ICI units because combustion characteristics related to CO formation are similar.

o CO and THC emission characteristics for ICI units are similar to those of utility units per MATS data.

o Pilot study for coal-fired units developed for MATS rule is equally applicable to industrial coal-fired units

 URS-generated charts compare total hydrocarbon (Page 9) and CO (Page 10) emissions for both ICI and utility pulverized coal fired units.

 Very low CO emission limits are u nattainable, unsupportable, and will not demonstrate lower HAP emissions.
o Driving CO down will increase NOx emissions

o Use of CO catalyst may control CO, but will not control HAP emissions

 and may require additional fossil fuel to reheat stack gases.

 At a minimum, if work practices are not established for CO for fossil fuel units, do not set any CO limit < 100 ppm. EPA data does not support low CO limits based on HAP emission reductions.
o Example case-coal fired spreader st oker boiler ICR 30-day emissions testing charts (Page 11).

 CO was < 100 ppm (< 10 to > 90 ppm) during the 30 day test, but THC and formaldehyde showed no correlation with CO during that time.

 Higher CO level data not available for this boiler.

 If EPA proceeds with CO limits, they need to provide additional flexibility for units that cannot meet final limits wit hout major combustor changes or add-on controls that would likely not reduce HAP emissions.

1 March, 2012, employment statistics per BLS : http://www.bls.gov/iag/tgs/iag22.htm, http://www.bls.gov/iag/tgs/iag31-33.htm (6/1/2012).CIBO-OMB Meeting Industrial Boiler MACT, Area Source, CISWI, and NHSM Rules

Page 5 of 13 15 June 2012 5. Timing

 Statute mandates three years for comp liance, but allows EPA the discretion to add a fourth year.

 Industrial facilities and universities wil l be in direct competition with electric utilities for limited supply of engine ering, fabrication and construction resources.
o Supply and demand: Prices will rise
o Some valuable engineer ing and fabrication work will be off-shored

 Congress never intended to force Industr ial facilities and Universities to compete directly with regulated ut ilities for the same resources.

 EPA should make it clear (e.g. preambl e language) that the fourth year is automatic when making boiler modification s, installing controls, or switching fuels. 6. Emissions averaging

 Emissions averaging for repowered boile rs (e.g., coal units converted to 100% natural gas) could provide cost -effective compliance flexibility and additional emission reductions.

 Emissions averaging should be allo wed across subcategories-there is precedent in other MACT rules (e.g ., Hazardous Organic NESHAP).

 Subcategory of a boiler upon the propos ed rule publication date (December 23, 2011) could determine its subcategory relative to emissions averaging.

 Conversion of a boiler to natural gas should allow use of 3 x RM DL emission rates to be used for that converted boile r in the emissions average if one-time actual emissions are < DL.

 Converted boiler thereafter treated as a Gas 1 boiler: requir ed tune-ups, etc.CIBO-OMB Meeting Industrial Boiler MACT, Area Source, CISWI, and NHSM Rules

Page 6 of 13 15 June 2012 CISWI Rule 7. Transitioning should be allowed between Boiler MACT and CISWI more often than on a 6-month basis

 Many problems could be avoided if pe rmits could include requirements under both BMACT and CISWI for energy recove ry units combusting traditional fuels and NHSM.

 Applicability determined simply by w hether NHSM solid waste materials are being fired at the time.
o When firing 100% traditional fuels, comply with Boiler MACT standards

o When firing any NHSM, comply with CISWI standards

 Problems with startups/shutdowns under CISWI would be resolved since most units utilize fossil fuel for st artup and shutdown and only burn NHSM during normal operation.

 It is easy to document when NH SM is burned and thereby determine requirement applicability and compliance.

 This would be a straight-forward means of providing oper ational flexibility without losing any compliance demonstration capability.

 CISWI ERU subcategory fuel-bas ed definitions would need to be changed slightly to be consistent with Boiler MACT respective unit definitions. 8. Restore the 2000 rule “contained gaseous material” definition to make it clear that process gases in pipes and ducts are not contained gaseous materials, as proposed.

 Previously, EPA defined “contained gaseous materials” (which are NOT solid waste) as gases that are in a container when the container is combusted. That definition made it abs olutely clear that venti ng of process gases burned for energy recovery or in control dev ices did not constitute solid waste incineration.

 The elimination of the contained gas eous material definition has caused regulatory confusion and has led one stat e to conclude that new process gas and landfill gas flares are so lid waste incinerators.

 EPA “fixed” the problem by issuing lette rs to several trade groups stating that EPA has not changed its position on contained gaseous material.

 The letters filled the immediate gap. However, industry needs long-term regulatory certainty on this point. EPA’s interactions with States on this point may not always be consistent, and interpretive letters can be changed at any time and challenged as non-bindi ng statements of policy.CIBO-OMB Meeting Industrial Boiler MACT, Area Source, CISWI, and NHSM Rules

Page 7 of 13 15 June 2012 Non-Hazardous Secondary Materials (NHSM) Rule 9. Additional materials which have been fully evaluated by EPA should be included categorically as non-waste materials.

 Pulp and Paper Wastewater Treatment Residuals (WWTR) should be listed as non-waste materials in 241.4(a).

 Each facility should not be required to separately evaluate or submit rulemaking petitions for a non-waste determination for these common materials

 87 million tons of these materials are produced every year imposing an unnecessary burden on manufacturing facilities. 10. Regulatory certainty and the ability to co mply with regulations with a high level of assurance requires an efficient and time ly petition and determination process. 11. Need clarity that process gases being burned in combustion units (either for energy recovery or as a result of c ontrol requirements under other regulations) are not solid waste.

 With return of the 2000 CISWI “cont ained gaseous material” definition, regulatory certainty would be advanced by including similar wording or references in the final NHSM preamble. Other Technical Issues of Concern (as time allows) 12. Boiler MACT start up/shutdown definition.

 CIBO provided a recommended approac h for management of startup and shutdown periods in comments and discussed in detail with OAQPS.

 Comments addressed the pr oblem with trying to apply a one-size-fits-all approach to regulated units that ar e extremely diverse in design and operation.

 Unit specific startup and shutdown procedures are most appropriate and provide flexibility for sources to pr actically and safely operate units.
o Procedures are reviewable, approvable, and enforceable.
o Furthermore, states have much ex perience in approving and enforcing site specific provisions for startup, shutdown, and malfunction. Most states have been doing this since the 1970’s.

 Procedures should be used as a guide for operations to purposefully move through the startup and shutdown process.
o Each startup and shutdown should be documented relative to elapsed time and timing of actions prescribed in the procedures so problems can be identified and corrected in a timely manner.
o Deviations from procedur es should be reported.

 The startup/shutdown co mments and issues are applicable to both BMACT and Area Source units with app licable emission limits.CIBO-OMB Meeting Industrial Boiler MACT, Area Source, CISWI, and NHSM Rules

Page 8 of 13 15 June 2012 13. Oxygen Trim Systems

 Need for flexibility if O2 trim systems are required
o Accommodate required desi gn and operating latitude
o Accommodate furnace safety requirements 14. Parametric Monitoring Systems

 Need for flexibility to optimize oper ations over full combustion unit and associated equipment operating ranges
o Operating parameters.

o Sorbent injection rates.

o Operation with use of CEMs. 15. Definition of “gas curtailm ent or supply interruption”

 Remaining issue with “period of gas curtailment or supply interruption” definition to not prevent use of ava ilable natural gas purchase contract and tariff arrangements.Page 9 of 13 15 June 2012 Boiler MACT Solid Fuel HCl and Hg Fuel Analysis Data – Average Content per Facility by Frequency

0 2 4 6 8 10 12 14 16 18 201.00E-101.00E-083.00E-077.00E-071.10E-061.50E-061.90E-062.30E-062.70E-063.10E-063.50E-063.90E-064.30E-064.70E-065.50E-066.50E-067.50E-068.50E-069.50E-061.05E-051.15E-051.25E-051.35E-051.45E-051.75E-052.25E-052.75E-05

Mercury content, lb/MMBtu 

## Biomass and Coal Mercury Fuel Content Data in BMACT Database, Average By Facility

bio freq coal freq top biomass top coal existing limit new limit

0 5 10 15 20 25 30 35 40 45 501.00E-061.00E-051.00E-041.00E-033.00E-035.00E-037.00E-039.00E-031.00E-022.00E-023.00E-024.00E-025.00E-026.00E-027.00E-028.00E-029.00E-021.00E-011.10E-012.00E-013.00E-014.00E-015.00E-016.00E-017.00E-018.00E-019.00E-011.00E+00More

Chloride, lb/MMBtu 

## Coal and Biomass Chloride Content Data from BMACT Database, Average by Facility

bio freq coal freq top biomass top coal existing and new limitPage 10 of 13 15 June 2012 Boiler MACT Solid Fuel HCl and Hg Fuel Analysis Data – Maximum Content per Facility by Frequency

0 5 10 15 20 25 301.00E-101.00E-083.00E-077.00E-071.10E-061.50E-061.90E-062.30E-062.70E-063.10E-063.50E-063.90E-064.30E-064.70E-065.50E-066.50E-067.50E-068.50E-069.50E-061.05E-051.15E-051.25E-051.35E-051.45E-051.75E-052.25E-052.75E-05

Mercury content, lb/MMBtu 

## Biomass and Coal Mercury Fuel Data in BMACT Database, Maximum By Facility

bio freq coal freq top biomass top coal existing limit new limit

0 10 20 30 40 50 601.00E-061.00E-051.00E-041.00E-033.00E-035.00E-037.00E-039.00E-031.00E-022.00E-023.00E-024.00E-025.00E-026.00E-027.00E-028.00E-029.00E-021.00E-011.10E-012.00E-013.00E-014.00E-015.00E-016.00E-017.00E-018.00E-019.00E-011.00E+00More

Chloride, lb/MMBtu 

## Coal and Biomass Chloride Content Data from BMACT Database, Maximum by Facility

bio freq coal freq top biomass top coal existing and new limitPage 11 of 13 15 June 2012 0 5 10 15 20 25

0 20 40 60 80 100ppm Total Hydrocarbon



## Boiler Data Point Number 

## Total Hydrocarbon Test Data for Pulverized Coal Units From EPA MACT Databases

Boiler MACT Values

Utility MACT ValuesPage 12 of 13 15 June 2012 0 50 100 150 200 250 300 350 400

0 50 100 150 200ppmCO



## Boiler Data Point Number 

## Boiler CO Test Data for Pulverized Coal Units From EPA MACT Databases

Reported Industrial Boiler Values

EPA Adjusted Industrial Boiler Values

Utility Boiler Reported Values (19 values over 400 ppm)Page 13 of 13 15 June 2012 DuPont Washington Works Boiler 5 Total Hydrocarbon versus CO Data (in Boiler MACT Database)

DuPont Washington Works Boiler 5 Formaldehyde versus CO Data (in Boiler MACT Database) y = 0.0013x + 0.1864 R2 = 0.0035

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5

0 10 20 30 40 50 60 70 80 90THC,ppm

CO, ppm 

# WWks Boiler 5 THC vs CO

y = 0.0008x + 0.5007 R2 = 0.0009

0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4

0 10 20 30 40 50 60 70 80 90HCOH,ppm

CO, ppm 

# WWks Boiler 5 HCOH vs CO