Combustion Webinar June 9, 2010 Frequently Asked Questions

Are boilers located at electric utilities covered by the proposed boiler rules? This will depend on the characteristics of each boiler.

 A boiler will be covered by th e utility MACT if it meets the definition of an “electric utility steam generating unit” (EGU) contained in section 112(a)(8).

 A boiler is not an EGU if it does not meet th e definition of an EGU contained in section 112(a)(8) (i.e., combustion unit of equal to or less than 25 MW or do not produce electricity for sale). This boiler will be c overed under the boiler MACT or boiler area

source rule.

 A boiler that does not burn any coal or oil, regardless of size, w ill be covered under the

boiler MACT or boiler area source rule.

 We have not made a determination on combustion units of more than 25 MW that co-fire coal and/or oil with biomass (o r anything else that isn't clas sed as a "solid waste"), in whatever respective quantities. This determ ination will be made as the Utility MACT rulemaking package is developed and reviewed.

How are natural gas-fired units regulated? In the proposed major source boiler rule, new and existing natural gas-fired boilers are regulated with a work practice standard re quiring that an annual tune-up be conducted for units equal to or greater than 10 MMBtu/hr and a biennial tune-up for un its less than 10 MMBtu/hr.

Natural gas-fired boilers ar e not regulated by the proposed area source boiler rule.

How is the initial fuel category of a unit established? In the proposed major and area sour ce boiler rules, the definitions of the coal, biomass, and oil subcategories establish the initial fuel subcat egory under which each boiler would be regulated.

Can a unit be switched to another fuel category or will it always have to meet those limits? The proposed boiler major source rule covers ma jor source boilers and pr ocess heaters that do not burn solid waste material. Similarly, the pro posed boiler area source rule covers area source

boilers that do not burn solid wast e material. A major source boiler or process heater, or an area source boiler, would no longer be covered by these rules if it began burning solid waste. Instead, that unit would be covered by rule s for solid waste incinerators.

In the proposed boiler major source rule, we ar e requesting comment on wh ether the owner of a boiler or process heater which has been burning solid waste should be able to choose coverage by the boiler rule (instead of the waste incinerato r rules) if the owner ag rees to an enforceable

restriction that the unit will not burn solid waste in the future.What is a traditional fuel?

Traditional fuels are fuels that have been histor ically managed as valuable fuel products rather than being managed as waste materials. Examples include fossil fuels (e. g., coal, oil, including used-oil meeting on-specification levels, natural gas), and their derivatives (e.g., petroleum coke, bituminous coke, coal tar oil, refinery gas, synt hetic fuel, heavy recycle, asphalts, blast furnace gas, recovered gaseous butane, coke oven gas), as well as clea n cellulosic biomass (e.g., green wood, forest thinnings, sawdust, bagasse, peanut shells, etc.). Tradit ional fuels are unused products that have not been discarded and ther efore are not solid wastes. We are requesting comment in the proposed rule on whether there are other traditional fuels that we have not

identified.

What are some examples of ingredients bur ned for energy recovery that would not be

considered solid waste?

An ingredient in a manufacturing process (whether by the generator or a th ird party) that meets the legitimacy criteria (i.e., be managed as a valuable commodity, provid e a useful contribution, be used to make a valuable product, and contain contaminants that are comparable or lower than in traditional products), would not be considered a solid waste. Examples include materials such as cement kiln dust, coal ash, and foundry sand th at are used as ingredients in manufacturing processes (e.g., in cement kilns), so long as th ey satisfy the legitimacy criteria. For more information, please see the Flow Chart for Dete rmining Whether Non-Hazardous Materials Used

as Fuel In Combustion Units are Solid Waste

<http://www.epa.gov/epawaste/nonhaz/define/flow-fuel.htm >

and

Flow Chart for Determining Whether Non-Hazardous Secondary Material Ingredients Burned In

Combustion Units are Solid Waste

<http://www.epa.gov/epawaste/nonhaz/define/flow-ingredient.htm >

Which rule would apply to units that burn mo stly traditional fuels but also some solid

waste? A unit that burns mostly traditional fuels but also some solid waste would be subject to the Combustion and Solid Waste Incinerator (CISWI) rule. By definition, a CISWI unit is any distinct operating unit of any comm ercial or industrial facility that combusts any solid waste pursuant to Subtitle D of Resource C onservation and Recovery Act (RCRA).Does the CISWI, Boiler Major Source Rule, or Boiler Area Source Rule apply to units that

burn coal and clean biomass? Depending on the major source status of the facil ity, the boiler major source rule or boiler area

source rule would apply to boilers burn ing coal and pure biomass.

What is meant by "contaminated" construction & demolition debris? By “contaminated,” EPA means the material cont ains contaminants at levels that are not comparable or lower in concentration than traditional fuels. The proposal defines “contaminants” as all hazardous air pollutants (HAPs) listed under CAA section 112(b), as well as the nine pollutants required to be regul ated under CAA section 129. An example of

contaminated construction and demolition material is wood painted with lead-based paint that has not been sufficiently processed to produce a legitimate product (by removing the lead-based paint).

How are qualifying cogeneration facilities and qualifying small power producers that combust a homogeneous waste stream covered under these rules? The CISWI Rule contains an exemption fo r qualifying small power producers, qualifying cogeneration units and metals reco very units pursuant to Section 129( g)(1) of the Clean Air Act.

If a unit otherwise fits the defini tion of a major source boiler or pr ocess heater or an area source boiler, it would be subject to either the ma jor source boiler or area source boiler rule.

What rules/testing is required for boilers under 10 MMBtu/hr? In the proposed area source boiler rule, new boi lers under 10 MMBtu/hr are subject to emission limits. New coal-fired boilers are subject to mercury (Hg), carbon monoxide (CO), and particulate matter (PM) limits, and new biomass-fire d boilers and oil-fired boilers are subject to

CO and PM limits. Initial and annual emissions testing are required for all boilers subject to

emission limits.

In the proposed major source boiler rule, new boilers, except for units in the “Gas 1” subcategory, under 10 MMBtu/hr are subject to emission limits for Hg, CO, PM, dioxin, and HCl. Initial and annual emissions testing are requ ired for all boilers subj ect to emission limits.

When do these rules take effect? Existing affected boilers must achieve complian ce with the applicable provisions in 40 CFR 63.7485 of subpart DDDDD (National Emission St andards for Hazardous Air Pollutants (NESHAP) for Industrial, Commer cial, and Institution Boilers and Process Heaters) for major source boilers, and in 40 CFR 63.11193 of subpa rt JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Industrial, Commercia l, and Institutional Boilers Area Sources) for area source boilers, no later than 3 years after publication of the final rule. New affected boilers that start up on or before the publ ication of the final rule must achieve compliance no later than the date of publication of the final rule. New affe cted boilers that start up after publication of the final rule must achieve compliance upon startup.For the CISWI Rule, the NSPS for new incinerati on units become effective six months after promulgation (i.e., December 16, 2010). The EG for existing incineration units become effective no later than three years after EPA approves a stat e plan implementing the EG or five years after the date they are promulgated, whichever is earlier.

Are "new" units identified by th e proposed rule determined by publication date or by the publication date of the final rule?

New boilers and CISWI units are determined ba sed on the date of publication of the proposed rule (i.e., June 4, 2010).

Where can I find the presentation mate rials from the June 9, 2010 webinar? The webinar and presentation materials are available at http://www.epa.gov/apti/bro adcast.html#boilers060910