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Boiler MACT and Other Air Developments 2011 Southern Section AWMA Conference Callaway Gardens, GA

Boiler MACT and Other Air Developments 2011 Southern Section AWMA Conference Callaway Gardens, GA. Dwight Wylie Eco-Systems, Inc. Environmental Engineers, Scientists, and Consultants. Eco-Systems, Inc. Terms and Acronyms. Major source boiler MACT – 40 CFR 63 Subpart DDDDD

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Boiler MACT and Other Air Developments 2011 Southern Section AWMA Conference Callaway Gardens, GA

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  1. Boiler MACT and Other Air Developments 2011 Southern Section AWMA Conference Callaway Gardens, GA Dwight Wylie Eco-Systems, Inc. Environmental Engineers, Scientists, and Consultants

  2. Eco-Systems, Inc. Terms and Acronyms • Major source boiler MACT – 40 CFR 63 Subpart DDDDD • Area source boiler MACT – 40 CFR 63 Subpart JJJJJJ • CISWI Rule – new source performance standards and existing source emissions guidance for commercial and industrial solid waste incinerators

  3. Eco-Systems, Inc. Subpart DDDDD • Promulgated March 21, 2011. • Affects boilers and process heaters at major sources of HAP emissions • Subcategories by fuel type (solid, liquid, gaseous) and size (large, limited use, and small)

  4. Eco-Systems, Inc. Subpart JJJJJJ • Promulgated March 21, 2011. • Affects Coal-fired, Biomass and Oil-fired boilers at area sources • Boiler sizes - Large boiler • Heat input equal to or greater than 10 million Btu/hr • Small boiler • Heat input is less than 10 million Btu/hr

  5. Eco-Systems, Inc. Notice of Reconsideration • On March 21, 2011, EPA also published a Notice of Reconsideration on Subparts JJJJJJ and DDDDD. • Issues where EPA indicates more public comment is appropriate: - Revision to the proposed subcategories in the major source boiler rule. - Establishment of a fuel specification in the major source boilers rule through which gas-fired boilers that use a fuel other than natural gas may be considered Gas 1 units. - Establishing work practice standards for limited use major source barriers. - Establishment of standards for biomass and oil-fired area source boilers based on generally available control technology.

  6. Eco-Systems, Inc. Postponement • On May 18, 2011, EPA postponed the effectiveness of the major source boiler MACT and the CISWI Rule until judicial review of these rules are complete or EPA reconsideration of the rules • Bill in Congress to extend the stay further for these two rules • Area source MACT effectiveness has not been extended • Notification of sources subject to JJJJJJ due September 17, 2011

  7. Eco-Systems, Inc. Subpart JJJJJJ New Boiler Requirements: • Large coal-fired boilers are required to meet emission limits for mercury, PM, and CO • Large biomass and oil-fired boilers are required to meet emission limits for PM • Small boilers must perform a boiler tune-up every two years • Natural gas-fired boilers exempt

  8. Eco-Systems, Inc. Subpart JJJJJJ Existing Boiler Requirements: • Large coal-fired boilers are required to meet emission limits for mercury and CO • Biomass, oil-fired and small coal-fired boilers are required to perform a boiler tune-up every two years • Facilities with large boilers are required to conduct an energy assessment • Natural gas-fired boilers exempt

  9. Eco-Systems, Inc. Subpart JJJJJ Compliance Dates: • March 21,2012 – Area sources only subject to tune-up work or management practices • March 21, 2014 – Existing sources • May 20, 2011 – New sources that started up before May 20, 2011 • Upon startup – New sources that started up after May 20, 2011

  10. Eco-Systems, Inc. Ozone NAAQS • Proposal to tighten national air-quality standards for ozone emissions to level between 60 ppb and 70 ppb.

  11. Eco-Systems, Inc. Ozone NAAQS • Single most expensive environmental regulation in U. S. History opined the July 26 Edition of the Wall Street Journal. • The agency’s ozone rule will be the most expensive in history – and isn’t required by law. (Wall Street Journal) • The EPA estimates these new standards could cost business anywhere from $20 billion to $90 billion annually. • EPA’s new standards are currently under review by the Office of Management and Budget but could end up on the president’s desk in the next few days.

  12. Eco-Systems, Inc. Ozone NAAQS • Up to 85% of the counties with revised Ozone NAAQS currently monitored by the EPA would fall into “nonattainment” status. • New or expanding companies in ozone non-attainment areas would be required to obtain emissions offsets and install controls. • Existing businesses in nonattainment areas would face expensive new retrofit requirements. • Implementation guidance won’t be published until the standards are finalized. • Guidance defines requirements.

  13. Eco-Systems, Inc.

  14. Eco-Systems, Inc. Cross-State Air Pollution Rule (CSPAR) • Originally proposed as Clean Air Transport • Allocations significantly lower than proposed in some states • Replaces Clean Air Interstate Rule (CAIR) • NOx and SO2 Transport

  15. Eco-Systems, Inc. Questions?

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