FMC Corporation 

 PO Box 872

Green River, WY 82935

 

 Westvaco Facility 

 307.875.2580 phone

 www.fmc.com

FMC Corporation

Comments on National Emission Standards for Hazardous Air Pollutants for 

Major Sources: Industrial, Commercial, and Institutional Boilers and Process 

Heaters

76 Fed. Reg. 15,608 (March 21, 2011)

Docket No. EPA-HQ-OAR-2002-0058

INTRODUCTION

FMC Corporation is a producer of soda ash, also known as sodium carbonate, which 

is located in Southwest Wyoming. Soda ash is the largest inorganic chemical 

exported from the United States. FMC has mined and processed trona ore in rural 

southwest Wyoming for over 60 years. The dry trona mining is done underground by 

electric mining machines. Once on the surface, this energy intensive process involves 

calcining the trona, dissolving, filtering and evaporating, and drying. FMC uses 

industrial boilers; primarily coal stoker and pulverized coal; to provide industrial 

steam and electricity for its onsite processing operations.

EMISSION IMPROVEMENTS FROM JUNE 2010 PROPOSED RULE

FMC would like to recognize the EPA for the improvements that it has made in the 

final rule for various emission limits to coal fired boilers. The emission limits are

more realistic and achievable for the existing pulverized coal and coal stoker units at

our facilities.

PARTICULATE MATTER AS A SURROGATE FOR NON-MERCURY 

METALLIC HAPS

A. EPA Fails to Support Its Decision to Use PM as a Surrogate

In the Final Rule, EPA elected to use particulate matter (“PM”) as a surrogate 

for the emissions of non-mercury metallic HAPs from industrial boilers and 

process heaters. However, as EPA acknowledges, metallic HAP emissions are 

“fuel based pollutants” that are direct results of contaminants in the fuels that 

are combusted. 76 Fed. Reg. 15612. Contaminants in a fuel do not establish a 

reasonable correlation between metallic HAP’s and PM emissions, and in the 

absence of such a correlation the use of a surrogate is not justified. Therefore, 

EPA should provide for an alternative emission limit for the non-mercury 

HAP metals as was done in the prior Subpart DDDDD rule, measured by 

Total Selected Metals, or TSM. Sources should then be allowed to 

demonstrate compliance via fuel analysis or by conducting stack testing using 

EPA Reference Method 29 (this test is already required for Hg compliance 

demonstration and can provide results for the remaining metals). If EPA is 

FMC Alkali Chemicals
 

sincere in its sensitivity to costs, this is a very cost-effective alternative as 

compared to installation and operation of PM CEMS.

B. EPA Incorrectly Estimates the Burden on Sources of PM Monitoring

The Final Rule requires the installation, certification, maintenance and 

operation of a CEMS for PM Emissions. Final §63.7525 (b). Such a 

requirement is excessive and the capital, operating and maintenance costs 

cannot be justified given the non-mercury metallic HAPs represent only 6 

percent of the total HAPs regulated by this NESHAP. EPA should eliminate 

the requirement for PM CEMS and impose the same standard for all sources; 

that is, units with heat input capacities greater than 250 MMBTU/hr, i.e. initial 

and annual performance stack tests. Similarly, the Final Rule requires 

parameter monitoring for PM control equipment for units less than 250 

MMBTU/hr, bag leak detectors for fabric filters and voltage and current for 

ESPs. Requiring parameter monitoring for larger units would provide 

continuous monitoring regarding PM control, a reasonable alternative to a 

CEMS.

EPA justifies the use of PM as a surrogate for non-mercury metallic HAPs on 

the basis that it “will also eliminate the cost of performance testing to comply 

with numerous standards for individual non-mercury metals.” However, the 

supposed cost savings is illusory because PM CEMS certification is 

expensive. PM CEMS require a rigorous initial certification per 40 CFR 60 

Appendix B Performance Specification 11, in which fifteen (15) Reference 

Method tests are conducted to develop the PM analyzer correlation. In 

addition, a Relative Response Audit must be conducted annually and a 

Response Correlation Audit must be performed every three years. The cost of 

initial certification could cost tens of thousands of dollars per unit with 

subsequent audits costing $5K to $8K per year. The option of using TSM as a 

HAP metals surrogate, coupled with initial and annual stack test requirements 

for TSM, is a cost-effective alternative that also provides a better correlation 

between the surrogate TSM measure and total HAP metals. 

EPA states that PM CEMS are required on only the largest units and it 

“considers its assumption that large facilities already have platform and utility 

access” on its stacks. 76 Fed. Reg. 15649. This assumption should be 

considered invalid due to these larger sources already having numerous 

monitoring equipment; i.e. COMS, CEMS, and CERMS to comply with 

NSPS requirements, which limits the space for additional equipment. 

Additional platform and utility access will need to be installed on stacks to 

accommodate the additional PM CEMS requirement.
 

C. Existing COMS Systems

The requirement of CEMS will require sources to impose additional, 

unnecessary equipment. FMC already employs continuous opacity monitoring 

systems (COMS) as an NSPS requirement. Mandating PM CEMS for those 

sources that already have COMS will indeed result in duplicating the 

monitoring requirement for particulate emissions.

D. Testing and Compliance Requirements for Particulate (PM) Surrogate

To determine initial PM compliance, testing must be conducted with Method 

5 or 17. 76 Fed. Reg. 15614. Method 5 testing is not appropriate on a coal 

fired boiler with an FGD. Method 5B was developed to eliminate the sulfate 

weight in the Method 5 sample train which EPA concluded should not be 

included in particulate emission measurements. In Document EPA-450/3-83-

021, EPA evaluated the use of Method 5B on a coal-fired boiler. In it, EPA 

stated, “Because these sources can emit significant amounts of condensible 

sulfates that are not controllable by even the best emission reduction systems, 

particulate emissions measured by Method 5, which is capable of collecting 

condensable matter, could vary widely as a result of fuel sulfur content or 

process changes. EPA decided that condensible sulfates should not be 

included in particulate emission standards or measurements.” Per 40 CFR 

60.46, Method 5B is therefore required for particulate compliance for a coal 

fired boiler with an FGD.

The rationale for the PM surrogate is to determine compliance for nonmercury metallic HAPs. Obviously, sulfates captured in the Method 5 sample 

train are not metallic HAPs and would positively bias the result. 

“To demonstrate continuous compliance with a PM CEMS, conduct Method 5 

or 5B performance correlation tests.” §63.7540(a) (9) (ii). This is the proper 

testing citation for the continuous compliance requirement. It is 

recommended that the Final Rule be consistent across all particulate testing 

requirements by requiring a Method 5B for a coal-fired boiler system with an 

FGD.