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CIBO Comments on EPA Draft Phase II Test Plan for Boiler MACT & CISWI 

January 9, 2008 

The Council of Industrial Boiler Owners appreciates the opportunity to comment on 

EPA’s draft Phase II Boiler MACT and CISWI Testing Plan. In addition to the specific 

comments below, we will follow up next week with any additional material that may be 

helpful. 

1. The numbers in the Word document Summary of Available Emissions Tests from 

Survey do not appear to match those in the spreadsheets or the Draft Test Plan. For 

example, see the Coal Limited Use figures- Excel file Draft Test Plan, Coal-Limited 

Use sheet shows 10 individual boilers with PM test data as does the Draft Test Plan, 

but the Summary of Available Emissions Tests from Survey shows 3 boilers and 10 

data points. 

2. Will existing available test data and proposed additional data provide adequate 

information to EPA to investigate and justify possible additional subcategorization 

for Boiler MACT, e.g., based on firing method, boiler/process heater designs, 

baseload versus load-following operation, or further fuel type differentiation when 

it is indicated as appropriate? 

In addition, for oil fired units, will existing available data and proposed additional 

data provide adequate information for EPA to determine if boiler design 

configuration influences emission rates, such as furnace heat release rate vs. CO 

emission level? At least some of the units listed as oil firing were at least originally 

solid fuel firing design with lower furnace heat release rates than used for oil or gas 

firing design. That is the case for at least one of the Oil Limited Use proposed test 

units. 

3. Will existing available data and proposed additional testing provide adequate 

information to assess the impact of fuel quality on emissions for Boiler MACT? 

For example, Coal Limited Use tests cover 5 units firing bituminous coal and one 

firing subbituminous coal. No fuel analyses appear to be available for 5 of those 

units and the one with data (#6) lists coal with 0.7%S and 40-50 ppb Hg. This 

appears inadequate to allow for fuel variability unless a subsequent fuel variability 

correction/analysis is conducted. 

4. The Draft Test Plan for Biomass Limited Use indicates no data available, but the 

spreadsheet for those four units shows some data is available and the specific tests 

identified for each unit indicate data to be available. The inconsistency needs to be 

corrected. 

5. There are many conditions limiting the use of boilers to <10% annual capacity 

factor, such as fuel availability, facility operation, weather conditions, etc. Since 

these conditions might severely limit boiler and fuel availability for testing, EPA 

should consider use of available emissions data from the large subcategory boilers 
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of similar characteristics, controls, fuels, etc., as being indicative of limited use 

boiler performance to the extent possible. This approach could also lower the 

burden and cost of obtaining emissions test data. We support EPA's use of fuel 

analysis data to the extent possible for uncontrolled oil fired units as a means to 

minimize costs. 

6. Where emissions testing for HCl is required on solid fuel fired units, is there value 

in using Method 26A so that simultaneous PM data can be obtained along with the 

HCl data? 

7. For oil fired units, will existing available data and proposed additional data provide 

adequate information for EPA to quantify emissions differences between various oil 

grades (at least Distillate vs. Residual)? 

8. For the proposed testing for CO and VOC/HC emissions comparative testing (Coal 

Large, Biomass Large, Oil Large, Gas Large), how will the testing be conducted to 

consider the variation in those emissions vs operating O2 levels and other normal 

operating variables? Test runs conducted at maximum operating rate under steady 

state conditions could be significantly different than average operation. Will O2 be 

varied for each test? How long will testing be required in order to determine the 

desired data? Can the selected boilers accommodate such a variation without 

problems? When will the boilers be selected for this comparative testing? The 

promulgated Subpart DDDDD rule applied the CO limit on a 30-day rolling 

average basis excluding data when the unit is operating at less than 50% of rated 

capacity. Reflecting this approach, we recommend that EPA conduct this 

comparative testing across a range of loads above 50% of capacity, so that the data 

is representative of normal boiler operation. 

9. EPA's approach to the CO/HC issue does not appear to capture its complexities. 

CO is highly dependent on boiler type. For the data to be dependable, EPA should 

have separate standards for each major coal-fired boiler type: stoker, PC (perhaps 

broken down into tangentially fired and wall fired), cyclone, and CFB. AP-42 

illustrates it well. In Table 1.1-3, there is a factor of 5 lb/ton for stokers and 0.5 

lb/ton for PC boilers. EPA needs to gather data in each of these categories and it 

needs to be extended over several weeks to ensure coverage of all operational 

variation. 

10. For the large boiler CO and VOC/HC comparative testing, will 5 units of each type 

be adequate to cover the different boiler firing methods and fuel types within the 

subcategories? Selecting at random will provide some fairness, but will very likely 

not be adequate. It will be necessary to ensure that randomly selected test units are 

representative of other units in the subcategory with recognition that inherent 

variability still needs to be addressed since all units cannot be tested. Will EPA 

investigate the impact of boiler design type/firing method on those emissions 

characteristics? For example, AP-42 Tables 1.1-3 and 1.1-19 indicate different 

emissions characteristics for various firing configurations and fuel types. 
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11. Jim Eddinger’s note and the spreadsheet Draft List of CISWI Test Facilities appears 

to imply that emissions testing will be required for all 176 listed units and pollutants 

for which data has not been provided, but that conclusion has not been made 

apparent in that table (compared to the Additional Unit list). If that is the case, that 

is a tremendous amount of testing to be conducted in a very short period of time. 

EPA should rethink the need to require this level of emissions testing. At the very 

least, consideration should be given to not requiring testing for pollutants that are 

not expected to be emitted in significant quantities based on unit design, operation, 

and feed analysis. 

 

In addition, units already permitted under and complying with the existing CISWI 

rule should not be required to perform any additional emissions testing, regardless 

of emissions data that was or was not provided. 

12. In both the Draft List of CISWI Test Facilities and the Draft List of Additional 

CISWI Test Facilities, it appears some of those units are batch fed- how will those 

be tested? It is not appropriate to consider batch fed unit emissions as 

representative of continuous fed units firing other materials or vice versa. 

13. It appears that EPA will not receive emission test results with adequate time to 

evaluate them prior to the rule proposal date, but rather, EPA may need to set out 

various options or ranges in the proposed rule. If that is the case, EPA should 

consider extending the time allowed for conducting the emissions tests and 

providing data to EPA. EPA could then follow-up the proposal with a NODA when 

additional data and evaluation is available. The additional time could also allow 

design and test for additional intra-unit variability information/data after it is more 

clear where the top 12% and subcategories are. Many of the CISWI units will likely 

need additional time in order to be able to test based on feed availability and 

operational constraints. In addition, the current financial crisis has put many 

companies and facilities under operational limits (including production shutdowns) 

so that unit operation, fuel feed materials, and operating rates may preclude 

emissions testing. EPA needs to take these factors into consideration when 

establishing the test plan.