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State Implementation of Risk-Based MACT Exemptions Region 4 Permit Managers Meeting. Rhonda B. Thompson, P.E., Director Engineering Services Division SC DHEC - Bureau of Air Quality. Presentation Overview. Boiler MACT Health-Based Compliance Alternative (HBCA)

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State Implementation of Risk-Based MACT ExemptionsRegion 4 Permit Managers Meeting

Rhonda B. Thompson, P.E., Director

Engineering Services Division

SC DHEC - Bureau of Air Quality

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Presentation Overview

  • Boiler MACT Health-Based Compliance Alternative (HBCA)

  • Plywood MACT Low-risk Subcategory

  • Ongoing Litigation

  • Other Related Issue

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  • 144 facilities subject to Boiler MACT

    • 42 facilities have solid-fuel fired boiler

  • 16 facilities submitted HBCA demonstrations

    • 19 wood-fired boilers

    • 4 coal-fired boilers

    • 28 mixed fuel-fired boilers

  • 17 boiler demonstrations for Mn (TSM)

  • 37 boiler demonstrations for HCl

  • 14 used stack testing, 2 used fuel analysis

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Health-based Compliance Alternative (HBCA)

  • States not required to review HBCA demonstrations (optional)

  • SC will review HBCA demonstrations before incorporating into TV permit

    • Uncomfortable incorporating HBCA limits into TV without some level of review

    • TV regulations require states to set forth the “legal and factual basis” for permit conditions (§70.7(a)(5))

    • Expecting some challenges of HBCA permit conditions

    • EPA only reviewing 1 HBCA – Clemson University

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HBCA Preview Procedures

  • 13 facilities used look-up tables

  • 3 facilities submitted a site-specific risk assessment (EPA’s Air Toxics Risk Assessment Reference Library, Volume 2; AERMOD modeling)

    • Stack Testing group reviewing test protocols and results

    • Air Toxics group reviewing modeling and risk equations

    • Permitting group will incorporate HBCA conditions into TV

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HBCA Review Procedures

  • E-mail to facilities February 14, 2007

    • Complete HBCA reviews by March 30, 2007

    • Notify facilities of approvals or problems

    • Discuss possible monitoring parameters for TV permit

    • Compliance extension requests expected if controls are needed

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Most Common Problems Found

  • Test protocols not submitted prior to testing or fuel analysis – testing not done correctly

    • Protocol required by state regulations, not by Appendix A

  • Facilities not testing at maximum worst-case scenario, as low as 20% capacity

    • Testing shows emissions not linear with production

  • Facilities not including all HCl/Cl2 or Mn emitting sources on-site (e.g., oil-fired units, small solid-fired units)

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Most Common Problems Found

  • Facilities waiting to hear from State/EPA before purchasing compliant fuels or ordering control devices – may ask for extensions

  • Public facilities (universities, etc.) not considering on-site residents (dorms) as most exposed individuals

  • No soot blowing, grate cleaning done during stack test (part of normal operation)

  • Facilities needing to retest quickly, before compliance date

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Incorporating HBCA in TV Permits

  • Major modification to TV permit

  • Public notice required

  • Most will be incorporated at permit renewal

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Plywood Low-risk Subcategory

  • 25 facilities subject to Plywood MACT

    • MDF, OSB, Plywood, Particleboard facilities more likely to submit demonstrations

  • 1 Preliminary demonstration submitted, used by EPA as the template

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Plywood Low-risk Subcategory Review Procedures

  • EPA will review all low-risk demonstrations

  • SC will also review demonstrations, will notify EPA of any issues/concerns

    • SC more familiar with facility processes

  • Same review procedures as Boiler MACT HBCA

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Plywood Low-risk Subcategory Common Questions

  • Facilities required to maintain test conditions after demonstration approved?

    • Example: Temporary hoods and stacks installed to determine concentration and conduct modeling

  • Can facility request Routine Control Device Maintenance Exemption (RCDME) after they risk-out?

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Ongoing Litigation

  • HBCA and risk-based exemptions being challenged by environmental groups, states

    • Boiler MACT hearings started

  • EPA’s petition to DC Circuit to vacate and remand parts of the Boiler and Plywood MACT standards

    • Response to vacatur of Brick and Clay MACT

    • EPA requesting the HBCA and risk-based exemption litigation cases continue separately

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Other Plywood MACT Issue

  • Routine Control Device Maintenance Exemption (RCDME) – §63.2251

    • Allows processes to run uncontrolled during routine maintenance (0.5 - 3% of reporting period)

    • States have discretion to approve/disapprove

  • SC disapproved request for a new facility

    • Can’t meet State VOC LAER rules without control device

  • Decision was appealed (may go to administrative law court hearing)

    • Basis: Can State rules be more stringent than Federal??

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Elizabeth Basil – Air Toxics Manager


[email protected]

Rhonda Thompson - Permit Director

(803) 898-4391

[email protected]