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

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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.

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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

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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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Concentration in Relative Units

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Method Sensitivity Decision Points

LC LD LQ

Cannot differentiate

from background 

LC

LD

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)
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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

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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

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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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