Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 1 of 14 Eastman Chemical Company Supplemental Submittal T o Petition for Reconsideration, Amendment, and Administrative Stay of Commercial and Industrial Solid Waste Incineration Units (78 Fed. Reg. 9112)

Introduction : Eastman Chemical Company (Eastman) operates three of the four coal

- fired energy recovery units (ERUs) in the Commercial and Industrial Solid Waste Incineration Units (CISWI) final rule ’s coal

- ERU subcategory. See generally Commercial and Industrial Solid Waste Incineration Units: Reconsideration and Final Amendments , 78 Fed. Reg. 9112 (Feb. 7, 2013). Eastman’s three boilers (boiler numbers 18, 19, and 20) are identical boilers, burn the same coal and waste , and are identified by the U.S. Environmental Pro tection Agency (EPA) in the CISWI final rule as the coal

- ERU subcategory top performers.

I t is well settled that the EPA must set the maximum achievable control technology (MACT) floor for pollutants regulated under Clean Air Act Section s 112 and 129 at levels that the top performing unit can meet “every day and under all operating conditions.” Mossville Environmental Action Now v. EPA , 370 F.3d 1232, 1242 (D.C. Cir. 2004) ( Mossville) ; see also National Association of Clean Water Agencies v. EPA , 734 F.3d 1115, 1134

- 1135 (D.C. Cir. 2013) ( NACWA )

. As more fully described below, EPA erred in setting the CISWI coal

- ERU MACT floor for hydrogen chloride (HCl), sulfur dioxide (SO2) and nitrogen oxide (NOx) at levels Eastman’s top performing coal

- ERUs cannot meet “every day and under all operating conditions.” Accordingly, these standards are unlawful and are highly likely to be remanded by the United States Court of Appeals for the District of C olumbia Circuit in line with the court’s Mossville and NACWA decisio ns

. On April 5, 2013, Eastman submitted a petition to EPA to reconsider, amend, and administratively stay the effective date of the offending provisions in EPA’s CISWI final rule . To date, EPA has neither administratively granted nor denied Eastman’s pe tition. Eastman much prefers to work with EPA to resolve these issues without further litigation. To that end, Eastman submit s this document and the accompanying data to supplement its petition , respectfully requests that EPA grant this p etition and

corr ect the CISWI final rule.

Issue One

- Fuel Variability Factors : As fully explained in our petition, after repeated requests to include fuel variability in the setting of MACT floor emission standards for the coal ERUs subcategory, EPA has to

- date not done so. As we will further explain here, EPA’s logic for this decision is flawed and t wo of
t he resulting MACT floor standards are unlawful.
Five of the CISWI pollutants are fuel dependent. Those are: cadmium, lead, mercury, HCl, and SO2. For each of these five, one of Eastman ’s b oilers ( 18, 19, or 20 ) ha s been identified by EPA as the top performer in the coal ERU subcategory. Each of these three is an identical st oker boiler equipped with an electrostatic precipitator (ESP) and no air pollution control device to remove acid gases (HCl and SO2). Cadmium and lead are very effectively removed by the ESPs. Mercury has some nominal removal efficiency via the ESPs.Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 2 of 14 It is important to note that, for cadmium, lead , and HCl, MACT floor standards were based on o ne stack test . Mercury’s standard was based on two stack tests. The SO2 standard was based on seven days of CEMS data provided by Eastman. Thus, these standards are based on very short

- term periods while coal is proven to have variable levels of each of these contaminants (cadmium, lead, mercury, chlorine, and sulfur). Data provided by Eastman during the comment period on the June 4, 2010 proposed rule and supplemented with additional data in this submittal, proves beyond a doubt that this is true for the top performers (Eastman’s boilers) in the CISWI coal

- ERU subcategory.
In its response to comments on the December 23, 2011 reconsideration proposed rule , EPA stated the following in response to Eastman’s request to apply fuel variability factors:

“Furt hermore, our analysis indicates that the best performing sources in this subcategory, which are operated by the commenter, are able to meet the final emission limits, which indicates that we have adequately accounted for variability when establishing the e mission limits for this subcategory.”
EPA Summary of Public Comments and Responses for Commercial and Industrial Solid Waste Incineration Units: Final Rule Volume 1: CISWI, December 2012 at 185 (Document Control No. EPA

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). After further evaluation, Eastman agrees the emission limits set by EPA for cadmium, lead, and mercury adequately account for variability of these contaminants in our coal supply. We believe this is because (1) there was variability among the test runs (2) cadmium is not normally detected in our coal supply (3) lead is very well controlled by the ESPs, and (4) mercury is partially controlled by the ESPs.
However, EPA’s conclusions are flawed with regard to HCl and SO2, the two pollutants for which t he top performers have no air pollution control equipment and for which the emissions are totally dependent on the fuel content. The following discussion will explain why this is true and how EPA can lawfully remedy the flaw for each of the two pollutants

. Hydrogen chloride: Figure 1 shows how EPA determined the HCl emission standard for coal ERUs. The standard was based on one performance test (with three runs) for Eastman’s Boiler 20. The chlorine in the coal during this test is calculated as an avera ge of 80 ppm, a relatively low chlorine level for the coal Eastman burns

– Central Appalachian coal.Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 3 of 14 Figure 1 EPA MACT Floor Determination for HCl

– Coal ERUs

Reference: Appendix C to memorandum from ERG to EPA dated November 16, 2012: “CISWI Emission Limit Calculations for Existing and New Sources for the Reconsideration Final Rule” (Docket ID EPA

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- 2662) Figure 2 below superimposes the chlorine content of the coal burned during the performance test conducted in November 2004 onto the graph of historical chlorine content measured in Eastman’s coal supply for this powerhouse since 2004. It is apparent from this graph that coal burned during the performance test was at the very low en d of the range for chlorine content compared to the historical ranges. The data from which this graph was drawn is included with this submittal as attached Excel file “Eastman Coal Sulfur and Chlorine Data 2005

- 2013.xls”.
Using standard EPA conversion fac tors, we estimate that, for eastern bituminous coal having a heating value of 13,100 Btu/lb, burned in boilers such as Eastman’s with no HCl reduction device, 13 ppmvd HCl in the exhaust gas would be caused by coal having a chlorine content of 230 ppm. A gain, looking at Figure 2, it is clear there are many shipments of coal that Eastman’s top performing boilers have burned that have chlorine contents at or above 2 3 0 ppm.Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 4 of 14 Figure 2 Chlorine Content Variability Coal Supply to Boilers 18, 19, 20

2004

- 2013

For exactly the same reasons the agency included fuel variability factors (FVFs) in the MACT floors for mercury and HCl for solid fuel boilers in the Boiler MACT final rule, EPA must develop and apply similar FVFs for the CISWI coal ERU subcategory. In the Boiler MACT, EPA decided to use the average fuel variability ratio, rather t han the maximum ratio, as explained in th e following excerpt from the Revised MACT Floor Analysis (August 2012) memorandum from ERG for the Boiler MACT:
“Fuel analysis variability was calculated using the same methods and assumptions used in the previous analysis with one exception. For the soli d fuel subcategory the March 2011 final rule and reconsideration proposal did not adopt a fuel variability factor in the MACT floor emission limit. However, in response to petitions for reconsideration on this issue and the public comments received on the solid fuel subcategory a fuel variability factor was adopted in this analysis for the amended final rule, where data was available. Given that the solid fuel category does exhibit some heterogeneous fuel make

- up amongst the top performing units, the EPA adopted the average fuel variability ratio for each pollutant instead of the maximum fuel variability ratio. This average value, calculated from only those fuel samples where the FVF ratio 0 200 400 600 800 1000 1200 1400 1600 1800

09/29/04 09/29/05 09/29/06 09/29/07 09/29/08 09/29/09 09/29/10 09/29/11 09/29/12 ppm

Chlorine content during

top performer stack test 230 ppm chlorine coal ~ 13 ppmvd CISWI Coal ERU HCl Limit

1520 ppm chlorine coal ~ 86 ppmvd CISWI ERU HCl Limit

FVF = 6.6Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 5 of 14 was greater than one, was selected to not overestimate fuel variab ility for a subcategory that has a mix of biomass, coal, and other solid fossil stack test data factored into the 99% UPL calculations, but it recognizes that some additional fuel variability is present in the best performing units that may not be represen ted by the stack test data alone. While the 99% UPL calculation incorporates variability between test runs resulting from variability in measurements, unit operations, and control device operations and performance, the FVF ratio incorporates variability i n fuel feedstocks that occur at best performing units during periods not covered by the stack tests. The FVF ratio, as described in previous memoranda, compares the fuel constituents during the test with the fuel constituents during other periods of opera tion in order to evaluate the full range of fuels consumed by these best performing units.”

I n th e CISWI context, since there is only one top performer and no mix of top performers as in Boiler MACT, the maximum FVF should be used so that any stack test at any operating condition (fuel variations) at the top performing unit will be in compliance.
Eastman notes that since there is no control device to monitor that assures compliance with a n HCl limit on our coal ERUs, that the compliance method would most likely be material balance. Even considering that the CISWI rule specifies a 30 day rolling average for compliance demonstration , the 2 3 0 ppm equivalent allowable chlorine content is not adequate for the top performer to meet every day under all operating conditions. This is evident from Figure 3 below where we have graphed both the monthly average coal chlorine content and superimposed the 2 3 0 ppm chlorine line.
Using EPA’s Boiler MACT methodology, we have calculated FVFs for chlorine using two differe nt datasets. EPA’s Boiler MACT methodology is summarized by the following steps: (1) determine chlorine concentration in coal during the top performer’s stack test; (2) determine the ratio of the concentration of chlorine in each coal sample from the top performer’s historical dataset divided by the result from step (1); (3) remove from the dataset as an outlier any ratio above the mean plus three standard deviations; (4) set the FVF as the highest remaining ratio. In the first analysis , we determined th e FVF from the dataset of ratios of each individual coal sample chlorine concentration is 6.6, reflecting the substantial variability of chlorine in the coal supply over time. In the second analysis, we determined the FVF from the dataset of ratios of the monthly average chlorine concentrations is 3.6, reflecting a dampened variability and matching up with the 30 day average compliance periods for material balance calculations. We ha ve included those FVF calculations in the attached Excel file “Coal ERU FVFs.xls ”

. We have shown the equivalent coal chlorine contents calculated app lying these FVFs on both Figure 2 (for the individual samples’ analyses) and Figure 3 (for the monthly average analyses ) . The FVF based on the individual samples is used for Figure 2 since it would be appropriate if the averaging time were 3 hours. The FVF based on the monthly averages is used for Figure 3 since it would be appropriate for a 30 day rolling average. The latter of these two methods is recommended since in this case the top performer has no control device for HCl and would use material balanc e as the compliance method. The revised HCl emission limit would be 47 ppmvd.Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 6 of 14 Figure 3

Sulfur dioxide (SO2): Figure 4 below shows the CEMS hourly emissions data from which the MACT floor emission standard for SO2 was set. Th ese data were provided by Eastman in response to EPA’s 2009 Information Data Collection (ICR) survey. Knowing we have a variable coal supply, we voluntarily supplied data from a temporary SO2 CEMS from a one week period rather than conduct a single stack test as requested by EPA. Since coal shipments are received for this powerhouse approximatel y once a week, there were only two different shipments (one with a sulfur content of 0.88 percent and the other with a sulfur content of 0.91 percent) burned during this 7 day period

. Accordingly, the SO2 emissions did not vary significantly over this on e week period.
Figure 5 below shows the historical data for sulfur content in Eastman’s coal supply. Shown also on this chart is the average sulfur content (0.9 percent) that resulted in the 650 ppmvd emission limit. Th ese data were submitted in our comments in 2010 and we have extended the data set into 2013 for this submittal. The data from which this graph was drawn are included with this submittal as attached Excel file “Eastman Coal Sulfur and Chlorine Data 200 5

- 2013.xls”. 0 100 200 300 400 500 600 700 800 900

Jan-05 May-05 Sep-05 Jan-06 May-06 Sep-06 Jan-07 May-07 Sep-07 Jan-08 May-08 Sep-08 Jan-09 May-09 Sep-09 Jan-10 May-10 Sep-10 Jan-11 May-11 Sep-11 Jan-12 May-12 Sep-12 Jan-13 May-13 Coal Chlorine Content (ppm) 

# Adjustment to Coal ERU HCl Limit Using Fuel Variability Factors

Monthly Average Cl 230 ppm Chlorine in Coal ~ 13 ppmvd CISWI Coal ERU Emission Limit (99% UPL)

830 ppm chlorine in coal ~ 47 ppmvd CISWI Coal ERU Emission Limit

FVF = 3.6Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 7 of 14 As can be seen from Fi gure 5, a 65 0 ppm standard would not be adequate to cover this top performer’s emissions every day under all operating conditions. Similarly to our presentation above for HCl, we also include Figure 6 to show that at even a 30 day average, a 650 ppm stand ard is not adequate.
As discussed above for HCl, FVFs need to be developed and applied so that the emission standard will adequately cover the fuel variability experienced by the top performer. As we have done for HCl, we have determined the FVF ratios an d included those calculations in the attached Excel file “Coal ERU FVFs.xls”. The FVF using the individual coal samples is 1. 3 and the FVF using the monthly averages is 1. 2

. As in the HCl analysis, the latter of these two methods is recommended for SO2 s ince in this case the top performer has no control device for SO2 and would use material balance as the compliance method. The revised SO2 emission limit would be 780 ppmvd.Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 8 of 14 0 100 200 300 400 500 600 700 CEMS SO2 Hourly Averages (ppm) 

## Figure 4

Eastman SO2 Hourly Averages August 23

- 30, 2009

Hours Aug 23 - 30, 2009 CISWI Coal ERU LimitEastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 9 of 14 0.00 0.20 0.40 0.60 0.80 1.00 1.20 1.40

09/29/04 09/29/05 09/29/06 09/29/07 09/29/08 09/29/09 09/29/10 09/29/11 09/29/12 Coal Sulfur Content % 

## Figure 5 Sulfur Content Variability Coal Supply to Boilers 18, 19, 20

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% Sulfur 0.9% Sulfur Content During 7

Day MACT Floor Period CISWI Limit Adjusted for FVF =1.3Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 10 of 14 Figure 6

Issue T wo - MACT Floor Analysis: As explained in our petition , Eastman is concerned that EPA’s MACT floor analysis does not fully account for actual operating conditions of the top performers when the units are not combusting solid waste. More specifically, Eastman is concerned that th e NOx emission standard set for coal ERUs in Table 7 of the final rule does not meet the requirements of section 129(a)(2).
For the coal ERU subcategory, Eastman’s Boiler 18 was identified by EPA as the top performer and, in fact, is the only unit in thi s very small subcategory for which EPA has NOx emission data in its CISWI database . Eastman provided the data from which the MACT floor was established in response to EPA’s 2009 ICR request. Rather than provide data from just one performance stack test a s requested by EPA, Eastman voluntarily operated a temporary NOx CEMS for a one week period from August 23

– 30, 2009 and submitted hourly average concentrations corrected to 7 percent oxygen. EPA used this data to set a MACT floor based emission standard of 340 ppmvd (corrected to 7 percent oxygen). 0.00 0.20 0.40 0.60 0.80 1.00 1.20

Jan-05 May-05 Sep-05 Jan-06 May-06 Sep-06 Jan-07 May-07 Sep-07 Jan-08 May-08 Sep-08 Jan-09 May-09 Sep-09 Jan-10 May-10 Sep-10 Jan-11 May-11 Sep-11 Jan-12 May-12 Sep-12 Jan-13 May-13 

# Adjustment to Coal ERU SO2 Limit Using Fuel Variability Factors

Montly Average % Sulfur 0.9 % Sulfur in Coal ~ 650 ppmvd CISWI Coal ERU Limit 1.1% Sulfur in Coal ~ 780 ppmvd CISWI Coal ERU Limit

FVF = 1.2Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 11 of 14 As we were planning this data collection, during consultation with the former EPA CISWI rule

- writer, we were instructed not to submit data from periods when the boiler was not burning solid waste. These thr ee coal

- fired boilers, along with four other coal

- fired boilers in the same powerhouse that are permitted as RCRA hazardous waste treatment units (and, thus exempt from definition as CISWI affected units), combust coal along with, at times, a solid waste ( biosolids from Eastman’s on

- site biological industrial wastewater treatment facility). However, the three CISWI units (Boilers 18, 19, and 20) only burn the solid waste during a small percentage of their operating hours. Since two of the other four boilers are equipped with NOx CEMS (since they are part of the EPA’s NOx Trading Program in 40 CFR Part 96), Eastman was aware that the combustion of the biosolids along with coal re sults in a suppression of NOx emissions due to the high moisture content (approximately 12 percent) of the biosolids. For this reason, we were concerned that if Boilers 18, 19, and 20 were identified as top performers by EPA, a MACT floor determination us ing just data derived from periods of combustion of solid waste would not reflect emissions of these top performers during the coal

- only mode of operation. However, we followed EPA’s instructions and did not collect NOx data during the coal

- only mode of

o peration.
Understanding this could be a problem, Eastman included in our comments to the June 4, 2010 proposed rule a request that EPA allow a CISWI unit to comply with Boiler MACT (40 CFR 63 Subpart DD D DD) during periods when solid waste is not combusted (see page 16 of Eastman comments dated August 23, 2010) similar to provisions in the Hazardous Waste Combustor MACT 1

. We cited our example of differing NOx emissions during the two modes of operation in our comments. EPA did not adopt our suggestion in the March 21, 2011 final rule but did include new provisions to switch from CISWI to Boiler MACT, but only after 6 months have passed since ceasing to burn solid waste . EPA’s reasoning for allowing only limited rule switching is stated at 76 FR at 15714:
“EPA acknowledges that sources may stop and start burning solid waste in their combustion units, and that regulatory procedures are necessary to guide sources through the changes in applicability that may result due to a switch in combustion materials. Ne w provisions in the final rule account for the fact that facilities may start and stop burning solid waste and ensure that any resulting changes in applicability between section 129 and section 112 rules do not occur with so much frequency that sources are unable to demonstrate continuing compliance with the applicable standards. To ensure that frequent switching does not impede our ability to determine continuous compliance and create undue permitting and testing burdens, sources remain subject to CISWI f or a minimum of six months. ”

U nsatisfied with these changes, numerous petitioners requested reconsideration o f this issue, EPA grant ed reconsideration and accepted comments during the comment period on the December 23, 2011

1 Throughout the rulemaking process Eastman and other commenters have reminded EPA of the precedent set in the Hazardous Waste Combustor MACT that allows those units to comply with otherwise applicable requirements during periods when hazardous waste is not in the unit. In fact, EPA discussed this provision in multiple Federal Registers ( see e.g. 64 Fed. Reg. 52828, 52904 (Sept. 30, 1999) , 66 Fed. Reg. 35090, 35145 (July 3, 2001), 67 Fed. Reg. 6968, 6979 (Feb. 14, 2002), 69 Fed. Reg. 21198, 21203 (April 20, 2004), and 70 Fed. Reg. 54498, 54499 (Oct, 12, 2005)) and has maintained the position that a unit can remain subj ect to one MACT sta ndard (e.g. HWC MACT), but comply with otherwise applicable requirements in either section 112 or 129, while remaining a MACT affected source.Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 12 of 14 reconsideration proposed rule (s ee 76 FR at 80458) . Trade Associations, including the American Chemistry Council and the Council of Industrial Boiler Operators (Eastman is a member of both) repeated urgings for EPA to allow units to frequently switch back

- and

- forth between CISWI and Boi ler MACT. EPA made no changes to these provisions and repeated its concern s about frequent switching and associated compliance burdens and enforcement concerns . EPA also rationalized erroneously in its response that the HWC MACT approach should not be adopted because it only involves switching between standards promulg ated pursuant to section 112 when clearly the rule language says sections 112 or 129 of the Clean Air Act (see EPA Summary of Public Comments and Responses for Commercial and Industrial So lid Waste Incineration Units: Final Rule Volume 1: CISWI, December 2012 at 185 (Doc ument Control No. EPA

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Eastman raises these points because if EPA had allowed frequent switching, we would not have an issue with the promulgated NOx emission standard. Since we have the need to burn solid waste in these boilers only on a periodic basis, the moment we stop burning solid waste we will not be able to comply with the NOx emission limit and the standard switching provi sion requires that we remain subject to CISWI for six months. Under these circumstances, the CISWI coal ERU NOx emission standard is unlawful because the top performer cannot comply “every day under all operating conditions

. ”
Therefore, Eastman requests that the NOx emission standard be such that the top performers (Boilers 18, 19, and 20) can comply under both the coal

- only operating condition a s well as the coal and waste operating condition . Since EPA previously declined to accept NOx data from periods when Eastman’s top performing coal ERUs were burning coal only (and no solid waste ) , Eastman is now submitting th ese NOx data so that EPA may establish a lawful MACT floor for that constituent

. From May 3

– June 10 , 2013, East man operated a temporary NOx CEMS on Boiler 20 , the only boiler of the three available during this time frame. Since Boilers 18, 19, and 20 are identical, th ese data are representative of any of the three. The boiler was operated at various steam loads a nd included periods under both modes of operation (coal only and coal plus biosolids). The raw hourly data is included in an attached Excel file titled “ Eastman Boiler 20 NOx Data May

- June 2013.xls ” and a quality assurance document to accompany the data i s included as Appendix A

. U sing EPA’s methodology for setting MACT floors, Eastman include d another spreadsheet with the resulting emission limit ( titled “ Eastman Boiler 20 NOx MACT Floor Determination.xls ” ). Using all the data from this period, the NOx limit would be 480 ppmvd (corrected to 7 percent oxygen).
Figure s 7 and 8 are shown below to illustrate the differences in NOx emissions with and without burning solid waste (biosolids) and at various steam loads. Th ese graph s clearly demonstrate that E astman’s top performer cannot comply with the emission standard every day under all operating conditions. Further, they demonstrate that because it is not possible to even introduce the biosolids to the combustion chamber below a minimum steam load, it is not possible to comply and operate the boiler to meet operational needs even if we could burn the solid waste at all times

.Eastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 13 of 14 Figure 7 Eastman Coal ERUs NOx Corrected to 7%O2 vs Steam Load Minute Data from ICR Data and May 3

- June 10, 20 13

0 100 200 300 400 500

60 80 100 120 140 160 NOX ppmvd@ 7% O2

Steam Load, kpph NOx @ 7% O2 WITH Burning Waste NOx @ 7% O2 WITHOUT Burning Waste ICR Data (WITH Burning Waste)

Current NOx Limit Cannot burn waste below 100 kpphEastman CISWI Petition Supplement

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- 0119 January 21 , 2013 Page 14 of 14 Figure 8 Eastman Coal ERUs NOx Corrected to 7%O2 vs. Steam Load Hourly Average Data from May 3

– June 10, 2013

Conclusion : For the foregoing reasons, Eastman respectfully requests that EPA grant its petition to reconsider, amend, and administratively stay the effective date of the offending provisions in EPA’s CISWI final rule so that the agency can reset the CISWI coal

- ERU MACT floor for HCl, SO2 and NOx at levels that Eastman’s top performing units can meet “every day and under all operating conditions.” Based on the data provided in this document, the HCl emission standard should be changed to 47 ppmvd, the SO2 emission s tandard should be changed to 780 ppmvd, and the NOx emission standard should be changed to 480 ppmvd.

Enclosures:

Excel file: Eastman Coal Sulfur and Chlorine Data 2005

- 2013.xls Excel file: Coal ERU FVFs.xls Excel file: Eastman Boiler 20 NOx Data May

- June 2013.xls Appendix A: NOx CEMS Quality Assurance Document Excel file: Eastman Boiler 20 NOx MACT Floor Determination 0 100 200 300 400 500

60 80 100 120 140 160 NOX ppmvd @ 7% O2

Steam Load, kpph NOXCORR (with sludge) NOXCORR (no sludge) Calculated New NOx Limit (480 ppmvd)

Current NOx Limit (340 ppmvd)