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Boiler MACT CISWI Rule. Wes Thornhill, Chief Industrial Chemicals Section Air Division. Boiler/CISWI MACT. On June 4, 2010, four interconnected proposed rules were published in the FR Major Source Boiler MACT Area Source Boiler MACT CISWI Section 129 Rule Definition of solid waste.

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boiler mact ciswi rule

Boiler MACTCISWI Rule

Wes Thornhill, Chief

Industrial Chemicals Section

Air Division

adem.alabama.gov

boiler ciswi mact
Boiler/CISWI MACT
  • On June 4, 2010, four interconnected proposed rules were published in the FR
    • Major Source Boiler MACT
    • Area Source Boiler MACT
    • CISWI Section 129 Rule
    • Definition of solid waste

adem.alabama.gov

boiler ciswi mact1
Boiler/CISWI MACT
  • Comment Period ends August 23rd.
  • Court ordered promulgation date of December 16, 2010.

adem.alabama.gov

boiler ciswi mact2
Boiler/CISWI MACT
  • What’s covered?
    • Major Source Boiler MACT
      • Boilers at sources that have the potential to emit more than 10/25 of HAPs
    • Area Source Boiler MACT
      • Boilers at sources that are not Major HAP Sources
    • CISWI Rule
      • A unit that burns ANY solid waste.
    • RCRA solid waste definition

adem.alabama.gov

boiler mact
Boiler MACT
  • Boiler MACT (major source)
    • For units greater than 10mmBTU/hr,

limits on the following

      • PM (surrogate for non-Hg metals)
      • Mercury
      • HCL (surrogate for acid gases)
      • CO (surrogate for non-dioxin organic HAPs)
      • Dioxin/Furan

adem.alabama.gov

boiler mact1
Boiler MACT
  • Boiler MACT (major source)
    • Anticipated control device train
      • Carbon Injection  Baghouse  Scrubber
      • And good combustion practices

adem.alabama.gov

boiler mact2
Boiler MACT
  • Boiler MACT (major source)
    • For ‘Gas 1’, Metal Process Furnaces and units less than 10 mmbtu/hr, a work practice standard (annual tune up).

adem.alabama.gov

boiler mact3
Boiler MACT
  • Boiler MACT (major source)
    • ‘Beyond the floor’
      • All major source facilities are to conduct an “Energy Assessment”
      • Energy Star

adem.alabama.gov

boiler mact4
Boiler MACT
  • Boiler MACT (major source)
    • Testing (varies based on size and fuel)
      • Initial – PM, Hg, HCl, THC, Dioxin
    • Monitoring
      • > 100 mmbtu/hr = CO CEMs
      • > 250 mmbtu/hr = PM CEMs (non-gas units)
      • Parametric monitoring (opacity, Delta P, etc…)
    • Compliance
      • 30 Day average for CEMs, shorter terms for parametric

adem.alabama.gov

boiler mact5
Boiler MACT
  • Boiler MACT (major source) Impact
    • EPA national estimates
      • Initial Cost = $9.5 Billion
      • Annualized cost = $2.9 Billion
    • Industry national estimates (AF&PA)
      • Initial Cost = $21 Billion
    • EPA benefits estimates
      • $17-$41 Billion in health benefits

adem.alabama.gov

boiler mact6
Boiler MACT
  • Boiler MACT (area source)
    • Limits
      • Coal fired units
        • Mercury
        • CO as a surrogate for POM
        • PM (new units)
      • Biomass and Oil fired units
        • CO as a surrogate for POM
        • PM (new units)
    • Beyond the floor
      • Energy assessment

adem.alabama.gov

boiler mact7
Boiler MACT
  • Boiler MACT (area source)
    • <10 mmbtu/hr
      • Annual tune up

adem.alabama.gov

boiler mact8
Boiler MACT
  • Boiler MACT (area source)
    • Testing (varies based on size and fuel)
      • Initial – PM, Hg, CO
    • Monitoring
      • > 100 mmbtu/hr = CO CEMs
      • Parametric monitoring (opacity, Delta P, etc…)
    • Compliance
      • Parametric

adem.alabama.gov

ciswi rule
CISWI Rule
  • Commercial and Industrial Solid Waste (CISWI) Rule
    • Burns ANY solid waste
  • Limits
    • Cd, CO, HCl, Hg, Pb, PM, SO2, NOx, dioxins/furans

adem.alabama.gov

ciswi rule1
CISWI Rule
  • CISWI Rule
    • Anticipated control device train
      • Carbon injection  Baghouse  Scrubber  SNCR  Afterburner
      • And good combustion practices

adem.alabama.gov

ciswi rule2
CISWI Rule
  • CISWI Rule
    • Testing
      • Initial and annual stack tests
      • Reduced testing frequency for good performance
    • Monitoring
      • CO CEMs
      • CO and PM CEMs for units >250 mmbtu/hr
      • Hg CEMs (kilns)
      • COMs (w/out scrubber)

adem.alabama.gov

ciswi rule3
CISWI Rule
  • CISWI Rule
    • Compliance
      • Hg monthly averages
      • Daily averages for other CEMs
      • 3-hour rolling averages for parametric
      • 6-minute for COMs
      • Annual control device inspections
      • Operator certification

adem.alabama.gov

waste
Waste
  • Solid Waste Definition
    • The following are NOT solid wastes
      • Material used as fuel that remains within control of generator
      • Material used as an ingredient in a manufacturing process
      • Material that has been SUFFICIENTLY processed to produce a fuel
      • Material that has been confirmed through a case-by-case basis

adem.alabama.gov

waste1
Waste
  • Solid Waste Definition
    • Wastes
      • Treated wood, construction debris, off-spec used oil, tires
    • Non-wastes
      • Resinated wood, WWTP sludge, TDF (chipped tires with steel removed), on-spec used oil

adem.alabama.gov

boiler ciswi mact3
Boiler/CISWI MACT
  • Concerns
    • Achievability, especially for smaller and area sources
      • FrankenMACT approach

adem.alabama.gov

boiler ciswi mact4
Boiler/CISWI MACT
  • Concerns
    • “Furthermore, we already

estimate no new CISWI sources will be

constructed due to the costs associated

with the MACT floor limits in the

proposed NSPS.”

EPA FR Vol. 75, No. 107, pg 31959

adem.alabama.gov

boiler ciswi mact5
Boiler/CISWI MACT
  • Concerns
    • Driving facilities away from wood and wood waste units, and towards natural gas
      • Wood is renewable
      • Wood is available
      • Wood may be considered carbon neutral
      • Woodwaste is not a consumer level fuel
      • Woodwaste may, otherwise, end up in landfills

adem.alabama.gov

boiler ciswi mact6
Boiler/CISWI MACT
  • Concerns
    • Accuracy of PM CEMs
    • Some limits approach the edges of detectability
      • (1 ppm CO limit on liquid fueled boilers)

adem.alabama.gov

boiler ciswi mact7
Boiler/CISWI MACT
  • Reminder!
    • Comment Period ends August 23rd.
    • Court ordered promulgation date of December 16, 2010.

adem.alabama.gov

boiler ciswi mact8
Boiler/CISWI MACT

Questions???

adem.alabama.gov