MAR 2 0 2015 

STATE OF MICHIGAN 

DEPARTMENT OF ENVIRONMENTAL QUALITY DE€1 

RICK SNYDER 

GOVERNOR 

Mr. George Czerniak, Director 

Air and Radiation Division 

LANSING 

March 13, 2015 

United States Environmental Protection Agency 

Region 5 

77 West Jackson Boulevard (A-18J) 

Chicago, Illinois 60604-3507 

Dear Mr. Czerniak: 

DAN WYANT 

DIRECTOR 

SUBJECT: Supplement to the Michigan State Implementation Plan (SIP) Submittal of 

Revisions to Part 3 Rules 

The Michigan Department of Environmental Quality (MDEQ) is providing the enclosed 

technical support information to supplement a SIP revision submittal dated 

December 13, 2013. The SIP revision request included the addition of revised 

Rule 336.1310 of the Michigan Air Pollution Control Rules, and the removal of 

Rules 336.1330 and 336.1349 from Michigan's SIP. 

We intend for this additional analysis to further demonstrate that the requested SIP 

revisions will not interfere with the maintenance of the NAAQS as required under 

Section 11 0(1) of the Clean Air Act. 

If you have any questions on the MDEQ's supplement to the 2013 SIP submittal, they may 

be directed to Mr. Tracey McDonald, Air Quality Division, at 517-284-6756 or 

mcdonaldt@michigan.gov; or MDEQ, P.O. Box 30260, Lansing, Michigan 48909-7760; or 

you may contact me. 

Enclosure 

Sincerely, 

er or&-LJ�J;_ 

Lynn Fiedler, Acting Chief 

Air Quality Division 

517-284-677 4 

cc/enc: Ms. Carolyn Persoon, Region 5, USEPA 

Ms. Mary Maupin, MDEQ 

Mr. Tracey McDonald, MDEQ 

CONSTITUTION HALL • 525 WEST ALLEGAN STREET • P.O. BOX 30473 • LANSING, MICHIGAN 48909-7973 ww

.michigan.gov/deq • (800) 662-9278 
MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

ADDITIONAL TECHNICAL SUPPORT AND ANALYSIS REGARDING 

SIP SUBMITTAL OF DECEMBER 13, 2013 

March 13, 2015 

Additional analysis of Rule 336.1310 (Rule 310) 

For the reasons stated below, it is our position that maintenance of the particulate National 

Ambient Air Quality Standards (NAAQS) will not be impacted by the modifications of Rule 310. 

• Rule 31 O(a). Promulgated changes to the rule include more restrictive constraints on open 

burning from 1 or 2 family dwellings for purposes of waste disposal. Plastic, rubber, foam, 

chemically treated wood, etc. are now prohibited from being burned. The change in this 

portion of the rule will decrease particulate emissions to the environment. 

• Rule 31 O(f). Changes made to R 310 allow the burning of untreated wooden fruit or 

vegetable storage crates for disease and/or pest control. These materials cannot be 

burned in or near a city or village nor in a priority I or II area. After researching several 

potential users of wooden bins in the Michigan agriculture sector, we determined only 

apple growers use wooden crates extensively. Many growers (potato) have created ways 

to avoid the use of containers altogether for their material handling. Some growers 

(cucumbers) have converted to plastic. Others (melons, pumpkins, squash, etc.) use 

cardboard. There are a few exceptions; for example, small quantity users (asparagus), but 

to our knowledge apple growers use the most wooden crates by far, and are therefore 

expected to be the only significant agricultural segment to use this exemption. 

According to a contact at the Michigan Agricultural Cooperative Marketing Association, 

Michigan Processing Apple Growers Division, annual apple sales in Michigan are about 

25,000,000 bushels. Most bins hold approximately 18 bushels, thus 1.39 million bins are 

used in a year. Expectations are that no more than 5% will become unrepairable and 

infested/infected in any given year. Less than 70,000 wooden bins may be eligible 

annually for burning under the exemption. Each bin weighs approximately 100 lbs., so total 

maximum untreated wood burned annually is 7,000,000 lbs. A wide variety of emission 

factors exist, but Chapter 2.5 (Solid Waste Disposal) in AP-42 indicates forest residues 

emit 17 lbs/ton of particulate emissions. This indicates a maximum of approximately 

30 tons of total particulate would be emitted statewide from these sources annually. 

Although most monitors in Michigan are located in urban areas, monitored 24-hour PM2.5 

in the west and middle Lower Peninsula of Michigan, the agricultural area in the state, 

ranges from concentrations of 16.8 to 23.5 ug/m3 (981h percentile, 2011-2013). This is well 

below the 35 ug/m3 in the NAAQS. Away from urban areas where this burning may occur, 

actual background values are most likely lower still. Also, particulate matter (PM) from 

open burning is mostly direct PM with very localized impacts. We conclude that there is an 

extremely low risk of exceeding the daily PM2.5 in the NAAQS due to the rare burning of 

fruit and vegetable crates, and maintenance of the PM2.5 in the NAAQS will not be an 

issue with this change in Rule 31 O(f). 

Additional analysis of Rule 336.1330 (Rule 330) 

The state is seeking removal of Rule 330 from its State Implementation Plan (SIP). The 

following discussion points summarize the issue and explain Michigan's position that there will 

be no reduction in protection of the NAAQS for PM resulting from removal of Rule 330. 

1 
• Every source that was previously regulated by Rule 330 is currently covered by a Title V 

permit. a Source Wide Permit To Install (PTI) and Rules 301 and 331. Requirements in 

these permits and rules, specifically particulate and opacity limitations, make proper 

operation of the electrostatic precipitator (ESP) a necessity. ESP contractors and 

operators have stated that automatic control systems are necessary to make compliance 

with many limits achievable. Rescinding Rule 330 has no impact on emissions because 

facilities must use the automatic control systems to achieve SIP-approved particulate and 

opacity rule limits or more stringent NSR permitted limits. The Source Wide PTI, Rule 301 

and Rule 331 are federally enforceable. 

• Rule 330 was applicable to few sources. Through emissions data reported in 2013 and 

staff surveys, we have determined that 23 facilities were subject to Rule 330 (see attached 

table). That number is expected to continue to decrease over time due to more shutdowns 

and modifications to processes. Several facilities have announced plans to replace ESPs 

with baghouses, or have added or plan to add baghouses in series with the ESPs, have 

converted units to eliminate the use of coal as a fuel, or plan to decommission emission 

units connected to ESPs in the next few years. According to our survey, two facilities use a 

basic oxygen furnace. At most, three facilities use a Kraft recovery boiler. The remaining 

18 have the ability to burn coal in their boilers, and 16 of those 18 are electrical-generating 

facilities. 

• Rule 330 was an antiquated rule, and as worded, could result in additional emissions. This 

rule was promulgated 34 years ago. Advances in our understanding of ESPs and the 

technology used in them have occurred. As our knowledge of ESPs has grown, we 

determined that maximizing current in an ESP can result in re-entrainment of particulate. 

The rule requires the automatic controller "be set to provide maximum power." By 

removing this rule and allowing facilities to focus on control efficiency, in some cases, they 

could reduce emissions below those allowed by "maximum power." Maximizing power 

when it does not improve control efficiency is also a waste of energy. This energy is often 

produced through coal combustion to create electricity. 

• Most emission units contained on this list are subject to additional federal regulations. 

These federal regulations, such as the Boiler MACT, Utility MACT, Iron and Steel MACT, 

etc., contain limits that use particulate as a surrogate for contaminants they are regulating. 

To achieve the level of control necessary to meet the limits of these regulations, ESPs will 

have to be operated efficiently. ESP contractors and operators have stated that units 

without automatic control systems would not be able to meet limits required in several 

federal regulations. Therefore often federal regulations necessitate automatic control 

systems without the requirement in Rule 330. 

• Equipping transformer-rectifier sets with automatic control systems may reduce costs for 

the facilities. Some facilities have found it in their best interest to have automatic control 

systems as it reduces power consumption. Overpowering the ESP to achieve a control 

efficiency that can be achieved by using less power more effectively is an energy expense. 

Again, rescinding Rule 330 did not cause these facilities to change their ESP control 

systems. Per permit and/or by rule, they are required to run their ESP, so reducing power 

consumption by using an automatic control system is cost-effective. Reducing power 

consumption likely reduces particulate emissions at the source of electrical generation. 

2 
• Rule 330 contained ambiguous wording. Automatic controllers are required to be set to 

provide "optimal power" rather than maximum power when in spark mode. It is not clear if 

the intention is to optimize control efficiency, opacity, power consumption, equipment 

wear, etc., or some combination. This ambiguity causes this portion of the rule to be less 

effective at ensuring satisfactory operation. 

• Spark-limiting mode is standard programming in automatic control systems. Sparking 

causes a significant decrease in control efficiency. An automatic control system is very 

effective at controlling sparking, which is a necessity when trying to meet current 

standards and limits. Rule 330(2) required that the control systems were capable of 

running in spark-limited mode. Today's automatic control systems are programmed to do 

this. 

• Meters and displays required in Rule 330 did little to ensure proper operation. The 

regulated entities indicated that the facilities' computers log the data most relevant to the 

operation of the ESP, and displaying this data is not useful for individual operators. With 

the advent of microprocessors, metering beyond that required by Rule 330 is standard for 

ESPs. 

• Rule 330(3) allowed for requirements in Rule 330(2) to be waived. These requirements 

were in place for purposes of giving the regulated community flexibility, and are neutral in 

meeting NAAQS standards. 

• Rule 910 is preferable to Rule 330. Finally, Michigan has Rule 910, a SIP-approved rule, 

which requires any air cleaning devices to be installed, maintained, and operated in 

accordance with the rules and law. It is not as prescriptive as Rule 330, but is broader in 

what it requires ("installed, maintained, and operated" as compared to "equipped" and 

"set"), and allows AQD staff more flexibility to react to changing circumstances, 

technology, etc. It is easier for regulatory staff and the regulated community to understand 

and implement, making it more effective. It is our position that Rule 910 is superior to 

Rule 330. 

For these reasons, Rule 330 was no longer a necessary regulation. Rule 331 and NSR 

determinations continue to require the same federally-enforceable particulate emission limits. 

Rule 910 allows for more effective regulatory oversight, and no increase in emissions will occur 

if Rule 330 is removed from the SIP. Given the use of Rule 910, the trend away from ESPs and 

coal-fired power plants, other federal regulations, existing permit conditions, and the ubiquitous 

use of automatic control systems to meet existing limits and minimize energy consumption, 

there will be no effect on NAAQS standards by the removal of this rule from the SIP. 

Below is a table containing what we believe to be all facilities/emission units utilizing an ESP in 

Michigan and those units subject to Rule 330 prior to rule rescission. The table also contains a 

variety of notes we believe are useful for this analysis. 

3 
#of sources with ESP's 40 

Emission units subject to R330 

#of sources with R330 ESP's 

4 

23