NACAA Air Toxics Call
2/9/12
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EPA – Proposed Boiler MACT
o Bob Waylan, Jim Eddinger, Brian Shrager
o Changes in proposal
 New subcategories
 Light & heavy industrial liquids due to design differences
 Biomass stoker kiln dried vs. wet – design and control differences
 Biomass suspension and dutch oven – design differences
 Separate limits for each combustor design – PM
 Some more stringent and some less stringent
 Alternative for solid fuels and Gas 2 = Total Select Metals limit
o Should they use for liquid units? – taking comment on feasibility
 Fuel specification
 Remove Hydrogen Sulfide for gaseous fuels – not a HAP and not related
– now based on Hg levels
 PM CEMS – RATA doesn’t apply due to cost factors now PM CPMS
 Remove for biomass – not technologically ready
 SSM requirements
 More specific to minimize emissions
 Dioxan/Furan
 Work practice instead of limit – can’t measure reliably – consistent with
EGU MACT – annual tune-up of all units
 Carbon Monoxide monitoring
 Instead of oxygen in stack – oxygen in fire box
 CO CEMS
o Questions
 MACT floor new sources higher than existing?
 Emission limits aren’t higher, but statistics, variability, and amount of
data alter according to test data may make the Floor higher
 How much data are they receiving?
 Comment period not until 2/21/12 – won’t get them all until then
 American forest & paper assoc. testing units that were best performing
units on biomass to assess to the CO approach.
 PM CPMS & utility MACT?
 Operating parameter not emission rate
 Voltage level is measured during test and used for compliance – same as
utility
 If an emission limit is less stringent, no notice period?
 No, if the change is founded in public comment, considered logical
outgrowth & can make change as long as founded in data from public
comment
 If a new source limit becomes more stringent, additional compliance
time
 Request for extension of comment period?
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They want to alleviate pressure of vacatur. Intend to not extend it to
make April deadline.
No action letters signed yesterday and guidance distributed. Sent it to people
with boilers. Post on Boiler MACT website. Will send to NACAA. – no initial
notifications due.
Mfg. recommendations for work practices
 CO & dioxin – tune-up – refer to mfg. specs. For optimizing flame and
CO patterns – should be included in boiler specs.
 What happens if you don’t have it? Default to good engineering
judgment. Facilities need to ensure good combustion.
 Make comment on specificity.
190 existing pulverized coal in database
How are people handling Title V and vacatur?
 Not sure, not handled in no action assurance
 Came up recently
NACAA comments
o Due 2/16/12
o Reasonable? Balanced? Correct?
o Kansas – good letter with lots of technical info, helpful to go back and read the
preamble, may need to break up, so much information
 Bring up summary in cover letter and specifics to follow
o Setting MACT Floor
 EPA required to consider existing limitations
 Look at actual in use performance of top 12%, assign variability, and set
 Beyond the floor = BACT new source = LAER