# Boiler MACT- NHSM Issues November 9, 2011

# Overview Major issue for forest product manufacturers $7 Billion in capital to meet March rules 87,000 jobs at risk due to potential paper mill closures 

### Severe impacts on wood product mills as well 

## Non - Hazardous Secondary Material (NHSM) Roadblocks for biomass residuals and other common fuels 

## Boiler MACT – major issues Achievable limits – CO, dioxin, and new sources Boiler testing for CO, PM subcategories, and time to comply 2

# NHSM: Perverse Outcomes

Preamble identifies many materials as likely to be fuels, HOWEVER Rule language requires meeting “legitimacy criteria” contaminant level must be comparable to “traditional fuel” - coal, wood, etc. Ignores historical use of these alternative fuels Many biomass residuals will flunk test - turning boilers into “Incinerators” (3X cost) Resinated wood, wastewater and paper process residuals become solid wastes No health concerns – very small quantities and well controlled under MACT Many/Most facilities will stop burning, landfill materials and buy fossil fuels Millions of tons filling our landfills $660 million/year just for forest products – some mills won’t survive Failure to fix puts MACT floor analysis in jeopardy ... again. 3

# NHSM Fixes List residuals as non - waste fuels, including: 

## Biomass [such as, Resinated wood, Wastewater and Paper recycling residuals, used Railway Ties] TDF and used oil Urban wood (clean C&D) as traditional fuel/clean biomass Ensure contaminant legitimacy criteria do not prevent materials becoming fuel – make discretionary factor Create workable petition process for classifying other 

## NHSM as non - waste fuels Address contained gas to reflect comfort letter to AF&PA 4

# Boiler MACT: Unachievable

Unachievable biomass limits for Carbon Monoxide Problem : Many biomass boilers cannot consistently meet CO limit Solution : set feasible short term limits and alternative longer-term (monthly) limits that reflect data variability; mine existing data as much as possible ; use Upper Permissible Limit at 99.9% Biomass Stokers: ~900 ppm (3 - hr) and ~500 ppm (monthly) Biomass Fluidized bed: ~700 ppm (3 - hr) and ~350 ppm (monthly) Unachievable limits for Dioxin Problem : Data are below levels that can accurately be measured (see diagram); results are meaningless at extremely low levels ; limits more stringent than any MACT (see chart) Solution : Adopt reasonable work practices for all subcategories to sustain efficient combustion, as law provides
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## LQ 

## L D 

## LC

Cannot differentiate from background 

## LC 

## L D 

## LQ Critical Level Limit of Detection Limit of Quantitation

Can differentiate from background. Low confidence in detection. Analyte is detectable. Low confidence in quantity. The analyte is quantifiable with a known level of precision and bias



### Analyte Concentration 

# Method Sensitivity Benchmarks

(All dioxin detections are here -- below the level of confidence that the number is accurate)7

# Boiler MACT: Unachievable

Unachievable New Source Limits Problem : non - gas boilers can’t reliably meet; discourages replacement of older boilers/modernization including new biomass units Solution: test methods can’t measure at these levels so adjust limits to reflect quantitation limits

8 HAP/Surrogate Biomass Stokers Biomass Fluidized PM (lb/MM Btu) ~0.01 ~0.008 CO (3 - hr in ppm) 550 300 CO (monthly in ppm) ~400 ~250 Mercury (lb/T Btu) ~3.5 ~3.5

# Boiler Testing Four CO CEMs tests getting underway on top performing stoker and fluidized bed biomass boilers Best to have year of data given operational and fuel 

## changes – wettest biomass January to May If EPA finalizes in April, only have Nov-Jan test data will continue to test some units beyond January every extra month important depending on “mining” of existing data 

## Notice of Data Availability – consider late data 9

# Reasonable Particulate Limits The depressed housing market has hit the wood 

## product industry especially hard with 128,000 jobs lost since 2008 (28% of the work force) Banks will not lend money or companies cannot 

## commit capital for controls - mills will close PM limits based on the unique fuels, products and boiler designs could make the limits affordable and protective More compliance time, may see return to profitability

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# Adequate Time to Comply – Five Years

Three years insufficient given the investment of billions of 

### dollars – need 5 yrs; Incinerators get up to 5 yrs. Most complex set of requirements manufacturers have ever faced and in the worst economy since passage of the Act. 

### Evaluation of control strategies for five pollutants plus other obligations requires many engineering studies and planning. Competition fierce for control vendors and qualified consultants given other rules (e.g., Utility MACT, CSAPR) More time increases the odds that mills will return to profitability and be able to afford controls rather than close Periodically report progress – did in Paper Cluster MACT Ask for comment in the preamble on extra two years 11

# Other Reconsideration Issues Minimum of 90 day comment period to examine 

## floor data and multiple rules together PM CEMS not justified 

## Retain work practices for start- up and shutdown Achievable liquid fuel limits (very low CO and PM limits) – distillate and residual subcategories Defer energy audit for GACT sources by 2 years New Source date should be reset with this proposal

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