Eric Swisher presented at the 23rd Virginia Environmental Symposium about the Major/Area Source Boiler MACT Rule. The presentation covered the regulatory framework of the rule including emission limitations, compliance options, work practice standards, startup, shutdown, and malfunction, and provided a summary of what the rule means to facilities.

1. Major/Area Source
Boiler MACT Rule
Speaker:
Eric Swisher
23rd Virginia Environmental Symposium
April 11, 2012
Your environmental compliance is clearly our business.

2. Overview
 Ground Rules
 Regulatory Framework
 Regulated Pollutants
 Emission Limitations
 Compliance Options
 Work Practice Standards
 Startup, Shutdown, and Malfunction
 Things to Take Away
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3. Ground Rules
NHSM
Rule
Fuel is a Solid Waste Fuel is not a Solid Waste
CISWI Boiler MACT
Rule Rules
Area Major
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4. General Information
 Area or Major Source
 New, Reconstructed, or Existing
 Fuel Type
 Design Type
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5. Comparison
Area Source Major Source
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6. Facility Type
Area Source Major Source
 Not a Major Source  >10 tons per year
any single HAP OR
 > 25 tons per year of
any combination of
HAPs
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7. Regulatory Citation
 40 CFR Part 63 – National Emission
Standards for Hazardous Air Pollutants for
Source Categories (NESHAP):
• Subpart JJJJJJ – Area Source Boiler MACT
(ASBM)
• Subpart DDDDD – Major Source Boiler MACT
(MSBM)
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8. History
Area Source Major Source
June 04, 2010  January 13, 2003

 March 21, 2011
• Proposed  December 23, 2011
• Proposed
• Comments Due March 14, 2003
• Comments Due July 19, 2010
•Promulgated •Proposed
 September 13, 2004
• Promulgated
 June 09, 2010 • Compliance Date September 13, 2007
• Comment Period Extended to August  October 31, 2005
 December 23, 2011
03, 2010  February 07, 2012
• Notice of Reconsideration
• Proposed Amendments
July 22, 2010
•Proposed Amendments •No Action Assurance
  December 28, 2005
• Final Rule (with Amendments)
• Comment Period Extended to August • Compliance Date September 13, 2007
23, 2010

 February 21, 2012
March 21, 2011

Letter
December 06, 2006
• Final Action on Reconsideration
June 04, 2010
• Promulgated

•Comments Due
• Proposed
 December 23, 2011 • Comments Due July 19, 2010
June 09, 2010
• Proposed Amendments

• Comment Period Extended to August 03, 2010

 March 13, 2012
February 21, 2012  July 22, 2010
• Comment Period Extended to August 23, 2010
• Comments Due
•No Action Assurance
 March 13, 2012
 March 21, 2011
• Promulgated
• No Action Assurance Letter
Letter
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9. Act of Congress
 March 08, 2012 Senate did not
pass the Collins Amendment to
the Highway Bill that would delay
the MSBM.
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10. Current Status
Area Source Major Source
 Effective Now  Proposed Rule
 Compliance Date •December 23, 2011
•March 21, 2014  Compliance Date
 No Action Assurance •Date to Change
Letter  No Action Assurance
•March 13, 2012 Letter
•February 07, 2012
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11. Source Applicability
Area Source Major Source
 Boiler  Boiler
 Exemptions  Process Heaters
 Exemptions
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12. Regulated Pollutants
Area Source Major Source
 Mercury (Hg)  Mercury (Hg)
 Non-Mercury Metallic
 Non-Mercury HAP
Metallic HAP  Non-Metallic Inorganic
 Organic HAP HAP
(including POM)  Non-Dioxin Organic
HAP
 Dioxins/Furans
(D/F)
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13. Emission Limits
Area Source Major Source
 Mercury  Mercury
 Carbon Monoxide  Carbon Monoxide
 Particulate Matter  Particulate Matter
OR Total Selected
Metals (TSM)
 Hydrogen Chloride
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14. Compliance Options
1. Comply with the Emission Standards
Area Source Major Source
 Fuel Sampling  Fuel Sampling
 Emission Testing  Emission Testing
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15. Fuel Sampling
Area Source Major Source
 Hg  Hg, HCl, & TSM
 Determine “Worst-  Determine “Worst-
Case” Fuel Mixture Case” Fuel Mixture
 Fuel Sampling &
Analysis Plan
 Monthly Fuel
Analyses
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16. Emission Testing
Area Source Major Source
 PM  PM or TSM
 Hg  Hg
 CO  CO
 HCl
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17. Compliance Options
2. Evaluate Emission Standard Alternatives
Area Source Major Source
 None  Emission Averaging
 Output-based
Emission Standard
• Emission
Reduction Credits
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18. Emission Averaging
 PM, HCl, or Hg
 Input or Output-based Emission Standards
 Existing Boiler Only
 Subcategory Requirements
 10% Discount Factor
 Common Stack Considerations
 Emission Averaging Plan
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19. Compliance Options
3. Can Not Comply with the Emission Standards
Area Source Major Source
 Fuel Management  Fuel Management
 Fuel Switching  Fuel Switching
 Controls  Controls
 Synthetic Minor
 Energy Efficiency
Improvements
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20. Output-based Emission Standards
 Output-based Emission Standards
• Incentivizes implementation of energy
efficient technologies to minimize the
generation of emissions
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21. Output-Based Emission Standards
Fuel Steam
Input Energy (lb Output Energy (lb
pollutant per MMBtu pollutant per MMBtu
heat input) steam output)
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22. Capital Investment
Add-on Control Energy Efficiency
Device(s) Project(s)
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23. Output-Based Emission Standards
 How were they determined?
• Boiler Efficiency
• Heat-Input Based Limits
Subcategory Hg Emission Hg Emission Boiler
Limit Limit Efficiency
(lb Hg per MMBtu (lb Hg per MMBtu (%)
of heat input) of steam output)
Existing Boiler
Designed to Burn 3.10E-06 3.50E-06 88.6
Solid Fuel
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24. Output-Based Emission Standards
 How are they used?
• Determine Current Boiler Output-Based
Emissions
• Establish Output Energy “Benchmark”
• Investigate Energy Efficiency Projects
• Quantify Emission Reductions
• Apply Percent Reduction to Current
Boiler Output-Based Emissions
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25. Energy Output Reduction Example
 Benchmark Year* = 2,175,000 MMBtu/yr
 Year After* = 1,957,500 MMBtu/yr
Tested Hg Tested Hg Adjusted Hg
Emissions Emissions Emissions
(lb Hg per MMBtu of (lb Hg per MMBtu of (lb Hg per MMBtu of
heat input) steam output) steam output)
3.40E-06 3.84E-06
3.45E-06
(Limit 3.10E-06) (Limit 3.50E-06)
*Production is assumed to be the same for both years.
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26. Energy Output Reduction Example
Subcategory Hg Emission Hg Adjusted Result
Limit Emissions
(lb Hg per MMBtu (lb Hg per MMBtu
of steam output) of steam output)
Existing Boiler
Designed to 3.50E-06 3.45E-06 PASS
Burn Solid Fuel
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27. Output-Based Other Considerations
 Implementation Plan
 Pollutant-by-Pollutant Applicability
 Emissions Averaging
 Shutdown Boilers
 Future Boiler Operations
 Other Permitting Requirements
 Energy Assessment
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28. What is Left?
 Ground Rules
 Regulatory Framework
 Regulated Pollutants
 Emission Limitations
 Compliance Options
 Work Practice Standards
 Startup, Shutdown, and Malfunction
 Things to Take Away
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29. Work Practice Standards
Area Source Major Source
 Tune-up  Tune-up
 Energy  Energy
Assessment Assessment
 Startup  Good Combustion
 Shutdown Practices
 Startup
 Shutdown
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30. ASBM Tune-ups
Final Rule Amendments
ASBM (March 21, 2011) ASBM (December 23, 2011)
 Every 2 years  Every 2 years
 March 21, 2012  Every 5 years
 No Action Assurance (Seasonal Boilers)
Letter  March 21, 2013
 Fuel Type
Requirements
 Common Fuel Meter
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31. Tune-up Applicability
Area Source Major Source
 New or Existing  Limited-use Boilers
Coal-fired Boiler <10  Natural gas, Refinery
MMBtu/hr Gas or Gas 1 (Other)
 New or Existing Boilers < 5 MMBtu/hr
Biomass-fired Boiler  Gas 2 (Other), Light
 New or Existing Liquid Boilers
Oil-fired Boiler
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32. Tune-up Requirements
Area Source Major Source
 Burner Inspection  Burner Inspection
(1)Flame Pattern the

As applicable, inspect (1)Flame Pattern clean or

Inspect the burner and
burner, and clean or replace any replace any components of the
Inspection
components of the burner as
Inspection
burner as necessary.
 Air-to-fuel system
necessary (you may delay the  Air-to-fuel system
Inspection
burner inspection until the next Inspection
scheduled unit shutdown, but
 CO Optimization  CO Optimization
you must inspect each burner
 Recordkeeping
at least once every 36 months).  Recordkeeping
 No Report Submittal  Report Submittal
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33. Energy Assessment
 Why?
 When and how often?
 Who is qualified?
 What equipment or systems need to be
included?
 What does “cost-effective” mean?
 What needs to be done?
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34. Energy Assessment
Final Rule Amendments
ASBM (March 21, 2011) ASBM (December 23, 2011)
 Existing  Existing
 ≥ 10 MMBtu/hr  ≥ 10 MMBtu/hr
 Boiler System
 Boiler System
 Energy Use System
 Energy Use System
•Onsite Only
 Qualified Personnel  Qualified Personnel
 Maximum Duration  Maximum Duration
 March 21, 2014  March 21, 2014
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35. Energy Assessment
Major Source
 Scope
 Maximum Time
 Compliance Date
•Date to Change
 Emission Reduction
Credits
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36. Good Combustion Practices
 O2 Trim Systems
• Monitor
• Optimize
• Report
 Operator Training
• Startup Procedures
• Shutdown Procedures
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37. Startup/Shutdown Periods
 Boiler MACT standards apply at all times.
 No exemptions from Boiler MACT
standards during periods of Startup and
Shutdown.
 U.S. EPA requires work practice standards
for periods of Startup and Shutdown in
lieu of numerical emission limits.
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38. Startup/Shutdown
Area Source Major Source
 Minimize the boiler’s  Good Combustion
startup and Practices
shutdown periods
following the
manufacturer’s
recommended
procedures.
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39. Misc. Startup/Shutdown
Area Source Major Source
 Startup/Shutdown  Startup/Shutdown
Definitions Definitions
 No SSM Plans  No SSM Plans
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40. Malfunction
 Malfunction means any sudden, infrequent,
and not reasonably preventable failure of
air pollution control and monitoring
equipment, process equipment, or a process
to operate in a normal or usual manner which
causes, or has the potential to cause, the
emission limitations in an applicable standard
to be exceeded. Failures that are caused in
part by poor maintenance or careless
operation are not malfunctions.
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41. Periods of Malfunction
 Boiler MACT standards apply at all times.
 No exemptions from Boiler MACT
standards during periods of Malfunction.
 U.S. EPA determines if a facility
demonstrated a “good faith effort” to
minimizing emissions and correcting a
Malfunction.
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42. Malfunction Process
 Notification of a Malfunction submitted to
U.S. EPA within two (2) business days.
 Follow-up report submitted to U.S. EPA
within 45 business days.
 U.S. EPA evaluates the reported information
concerning the Malfunction to determine if
further inquiry or enforcement action is
required.
 Facility can only use Affirmative Defense in
response to civil penalties if notification and
report is submitted.
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43. Affirmative Defense
 To use Affirmative Defense facilities
must show a “preponderance” of evidence
that:
• The excess emission was caused by a
malfunction and was not preventable or
reoccurring, and
• The facility expedited repairs, actions were
documented in signed logs, and a root-cause
analysis was completed.
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44. SSM Plan
 No SSM Plan required; however may be
more important now than ever due to
potential enforcement action.
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45. Things to Take Away
 The current status of the Boiler MACT
rules?
 Where do I stand now?
 What are my compliance options?
 What are my compliance plans?
 Be in action!
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46. Questions?
Speaker Contact Info:
Eric M. Swisher
eswisher@all4inc.com
610.933.5246 x17
All4 Inc. - 2393 Kimberton Road - P.O. Box 299 - Kimberton, PA 19442
610.933.5246 - www.all4inc.com
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