INDUSTRIAL BOILER MACT (40 CFR 63 Subpart DDDDD) Atlanta, Georgia May 24, 2006

IMPORTANT DATES Proposal Date – January 13, 2003 Promulgation Date – September 13, 2004 Compliance Date Existing units - September 13, 2007 New units – startup

INDUSTRIAL BOILER MACT Source categories included: Industrial Boilers Institutional/Commercial Boilers Process Heaters Indirect-fired – combustion gases do not come in contact with process materials.

EMISSIONS LIMITS Existing Units Existing large solid fuel units PM -- 0.07 lb/million Btu, OR TSM – 0.001 lb/million Btu HCl -- 0.09 lb/million Btu (~ 90 ppm) Hg – 9 lb/trillion Btu Existing limited use solid fuel units PM -- 0.21 lb/million Btu, OR TSM – 0.004 lb/million Btu No emissions standards for: existing small solid fuel units existing liquid fuel units existing gaseous fuel units No work practice standards

EMISSION LIMITS and WORK PRACTICE STANDARDS New Units New solid fuel units PM -- 0.025 lb/million Btu, OR TSM 0.0003 lb/million Btu HCl -- 0.02 lb/million Btu (20 ppm) Hg -- 3 lb/trillion Btu CO -- 400 ppm @ 7% oxygen (NOT FOR SMALL UNITS) New liquid fuel units PM -- 0.03 lb/million Btu HCl -- 0.0005 lb/million Btu (large units) 0.0009 lb/million Btu (small and limited use units) CO – 400 ppm @ 3% oxygen (NOT FOR SMALL UNITS) New gaseous fuel-fired units CO – 400 ppm @ 3% oxygen (NOT FOR SMALL UNITS)

COMPLIANCE OPTIONS Conduct stack emission tests Conduct fuel analysis Emissions averaging (large solid fuel units only) Health-based compliance alternatives for HCl and TSM

COMPLIANCE TESTING Performance tests (stacks tests) Fuel analyses Annual performance tests Based on average of 3 test runs Based on worst fuel type or mixture AND/OR Fuel analyses Initial and every 5 years Each new fuel type Based 90% confidence level of minimum 3 fuel samples

COMPLIANCE TESTING Performance Tests Requirements Listed in Table 5 of Subpart DDDDD of Part 63 Common EPA test methods for PM, TSM, HCl, mercury, and CO limits EPA Method 1: sampling location/traverse points EPA Method 2: velocity/volumetric flowrate EPA Method 3: oxygen/CO2 concentration EPA Method 4: moisture content EPA Method 19: converting concentrations to lb/MMBtu by using F-factor For PM EPA Methods 5 or 17 For TSM EPA Method 29 For HCl EPA Method 26 or 26A For mercury EPA Method 29 or 101A ASTM D6522-00 or PTC 19, Part 10 For CO EPA Methods 10, 10A, or 10B ASTM D6522-00 (natural gas only)

COMPLIANCE TESTING Fuel Analysis Requirements Listed in Table 6 to Subpart DDDDD Required steps Collect samples (using procedure in 63.7521(c) or ASTM D2234-00 Composite fuel samples (63.7521(c)) Prepare composite samples (ASTM D2013-01) Determine heat content (ASTM D5865-03a) Determine moisture content (ASTM D3173-02) Determine HAP concentration (Listed method or equivalent) Convert HAP concentration to lb/million Btu

COMPLIANCE TESTING Fuel Analysis Requirements (cont.) Must use equation 8 to demonstrate compliance One-sided z-statistic test P90 = mean + (SD * t) P90 = 90th percentile confidence level Mean = Arithmetic average concentration in the fuel samples SD = Standard deviation in the fuel samples t = t distribution critical value for 90th percentile (0.1) probability for appropriate degrees of freedom (number of samples minus one) obtained from Distribution Critical Value Table. Based on worst fuel type or mixture

SPECIAL TESTING REQUIREMENTS New liquid fuel that burn only fossil fuel and do not burn residual oil (40 CFR 63.7506(a)) Not required to conduct performance tests for PM and HCl Must submit documentation Must still demonstrate compliance with CO limit Use of alternative test methods Must petition EPA for approval (40 CFR 63.7)

COMPLIANCE MONITORING Continuous compliance based on monitoring and maintaining operating limits Operating limits For PM, TSM and mercury limits Opacity (for dry systems) Existing units – 20% opacity (6 minute average) New units – 10% opacity (1 hour block average) Control device parameters (for wet systems) Established during initial compliance test Fuel (type or mixture) When compliance based on fuel analysis For HCl Scrubber parameters (pH, pressure drop, liquid flow, sorbent injection rate)

COMPLIANCE MONITORING (cont.) CO Monitoring (new units only) CEM for large units > 100 million Btu/hr Annual CO tests for other new units Exempt data from <50% load and based on 30-day average.

Additional Compliance Provisions Emission Averaging Only existing large solid fuel units Initial compliance based on maximum capacity Continuous compliance on a 12-month rolling average basis Each monthly calculation based on monthly fuel use and previous compliance test results for each boiler Must maintain, at a minimum, the emission controls employed on the effective date

Additional Compliance Provision Health-Based Compliance Alternatives Alternative compliance options available for the HCl limit and the total selected metals limit (TSM) HCl: emissions of HCl and Cl2 TSM: emissions of manganese Sources that comply with source-wide health-based alternative for HCl do not have to comply with the technology-based HCl limit on an individual boiler basis Sources that comply with source-wide health-based alternative for manganese can ignore manganese when determining compliance with the TSM limit on an individual boiler basis

How to Comply with Health-Based Compliance Options Lookup table analysis Site-specific risk assessment

How to Conduct a Lookup Table Analysis: Overview Determine maximum hourly emission rates from each appropriate subpart DDDDD boiler or process heater HCl and Cl2 or Mn Calculate total emission rate for source Locate appropriate allowable emission rate from lookup table Compare source’s emission rate with allowable emission rate

How to Conduct a Lookup Table Analysis: Emissions Determination Emissions tests HCl alternative: Must test for HCl and Cl2 TSM alternative: Must test for Mn Fuel analysis HCl alternative: Assume all chlorine detected emitted as Cl2 TSM alternative: Assume all Mn detected is emitted

How to Conduct a Site-Specific Risk Assessment Refer to EPA’s Air Toxics Risk Assessment Reference Library (http://www.epa.gov/ttn/fera/risk_atra_main.html) General outline of process: Collect emissions information (HCl, Cl2, Mn) Identify relevant source parameters for modeling stack heights, stack diameters, gas exit velocities, etc. Perform dispersion/exposure modeling Calculate an estimate of risk to the individual most exposed (Hazard quotient (HQ) for Mn and hazard index (HI) for HCl and Cl2) HQ: The ratio of a level of exposure for a single substance to a reference level (e.g., RfC) for that substance HI: The sum of more than one hazard quotient You are eligible for the alternative compliance option if your maximum chronic inhalation HI or HQ is < 1.0

Petitions For Reconsideration Three petitions for reconsideration were received General Electric Company Joint petition NRDC EIP (Environmental Integrity Project) EIP Two petitions for judicial review Jointly filed by NRDC, Sierra Club, and EIP Issues same as in reconsideration petition American Public Power-Ohio (and 6 municipalities) EPA exceeded its authority in imposing standards on small municipal utility boilers

GE Petition Issue Requests clarification that the rule allows for testing at the common stack rather than each duct to the stack No opportunity to provide comments since the proposed rule did not contain regulatory text for the emissions averaging provision Common stack testing is handled on a case-by-case basis by OECA/Regions OECA’s general policy is that each duct to a common stack must be tested Proposed amendment allowing testing of common stack in certain situation – October 31, 2005

NRDC – EIP Petition Seeking reconsideration on: Lack of standards for all HAP emitted on all subcategories Health-based compliance alternatives Granted petition and requested comment on June 27, 2005 Published final action on December 28, 2005 Retained health-based compliance alternatives

INFORMATION AND CONTACT Implementation tools (timelines, initial notification, state/local contacts, Q/A) and information on the MACT rulemaking for industrial, commercial, and institutional boilers and process heaters is available on EPA’s web site at: www.epa.gov/ttn/atw/boiler/boilerpg.html An electronic version of public docket (including public comments) is available at: www.regulations.gov Search for docket ID No. EPA-HQ-OAR-2002-0058 Contact: Compliance Contact: Jim Eddinger Greg Fried (OECA) 919-541-5426 202-564-7016 eddinger.jim@epa.gov fried.gregory@epa.gov Risk Contact Scott Jenkins 919-541-1167 jenkins.scott@epa.gov

ANY QUESTIONS? That concludes my presentation. I will take some questions and turn it over to Ken.