1 CIBO Comments on EPA Draft Phase II Test Plan for Boiler MACT & CISWI January 9, 2008

The Council of Industrial Boiler Owners a ppreciates the opportunity to comment on

EPA’s draft Phase II Boiler MACT and CISWI Te sting 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 Summar y of Available Emissions Tests from Survey do not appear to matc h 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 Te sts 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 ju stify possible additional subcategorization for Boiler MACT, e.g., based on firing me thod, 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 exis ting available data and proposed additional data provide adequate information for EPA to determine if boiler design configuration influences emission rates, su ch as furnace heat release rate vs. CO

emission level? At least some of the units li sted as oil firing were at least originally solid fuel firing design with lower furnace h eat release rates than used for oil or gas firing design. That is the case for at leas t 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 fu el quality on emissions for Boiler MACT? For example, Coal Limited Use tests cove r 5 units firing bitu minous 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 indicat e data to be available. Th e inconsistency needs to be

corrected.

5. There are many conditions limiting the us e of boilers to <10% annual capacity factor, such as fuel availability, facili ty operation, weather conditions, etc. Since these conditions might severely limit boile r and fuel availability for testing, EPA should consider use of available emissions data from the large subcategory boilers2 of similar characteristics, controls, fuel s, 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 exis ting available data and propos ed 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 conducte d at maximum operating rate under steady state conditions could be significantly diffe rent than average operation. Will O2 be varied for each test? How long will tes ting be required in order to determine the

desired data? Can the selected boilers accommodate such a variation without problems? When will the boilers be sel ected for this comparative testing? The promulgated Subpart DDDDD rule appl ied 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 capacit y, 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 bo iler 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), cy clone, 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 compar ative 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 fa irness, but will very likely not be adequate. It will be necessary to ensure that randomly selected test units are representative of other un its 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 desi gn 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 firi ng configurations and fuel types.3 11. Jim Eddinger’s note and the sp readsheet 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 c onducted in a very short period of time.

EPA should rethink the need to require this level of emi ssions 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 a ny additional emissions testing, regardless

of emissions data that was or was not provided.

12. In both the Draft List of CISWI Test Faci lities 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 fo r conducting the emissions tests and providing data to EPA. EPA could then follow-up the proposa l with a NODA when

additional data and evaluation is availabl e. 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 su bcategories are. Many of th e 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 fina ncial crisis has put many companies and facilities under operationa l limits (including production shutdowns) so that unit operation, fuel feed mate rials, and operating rates may preclude emissions testing. EPA needs to take these factors into consideration when establishing the test plan.