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

7 6 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

southw est 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 bo ilers ; 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 pulverize d coal and coal stoker units at

our facilities.

PARTICULATE MATTER AS A SURROGATE FOR NON

- MERCURY

METALLI C HAPS

A. EPA Fails to Support Its D ecision to Us e 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

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

reasonable correlation between metallic HAP’s and PM emi ssions, 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 remainin g metals). If EPA is 

# FMC Alkali Chemicalssincere 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 instal lation, 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

perce nt 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 te sts. 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

co ntinuous 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 standa rds 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

a ddition, 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 c ost 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 prov ides 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 stack s. 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.

Add itional 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 employ s 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 b e 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 emi t 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 non

mercury metallic HAPs . Obviously, sulfates captured in the Method 5 sample

train are not metal lic HAPs and would positively bias the result

.

“ To demonstrate continuous compliance w ith 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 requiremen ts by requiring a Method 5B for a coal

- fired boiler system with an

FGD.