Health Based Compliance Alternatives (HBCA) under MACT (Maximum Achieveable Control Technology): Permitting Challenges Cindy Phillips, P.E. FDEP Bureau of Air Regulation 2007 Southeastern Permitting Workshop Tampa, Florida May 11, 2007

8 Florida Facilities Requested Site-Specific HBCA for I/C/I Boiler MACT 3 Pulp & Paper 2 Plywood 3 Sugar

HBCA Review Modeling reviewed by Bureau of Air Regulation (BAR) 7 Permit applications/HBCA reviewed by 3 different FDEP District Offices with parallel review by BAR 1 Permit application/HBCA reviewed by BAR 3 of the HBCA demonstrations to be audited by EPA

Challenges Florida permitting timeclock does not coincide with EPA review time for the 3 facilities being audited. Most permitting staff have not had risk assessment training. Though I/C/I boiler MACT training was offered by Region 4 in May 2006, – it was not detailed risk assessment training (none of the district permitting staff were able to go to it anyway); and – example permit conditions were not provided.

Tools Developed Summary of Subpart DDDDD Checklist for HBCA Demonstration

On-the-job Training OAQPS has been very helpful in answering questions about the HBCA as they arise. If you have questions, try contacting   

On-the-job Training (cont’d) Sample of Permitting Questions; and OAQPS Answers

Q & A Q1. If the maximum modeled manganese concentration is shown to be within a plant's property boundary, are they still required to show a plot plan of nearby residences, or show a comparison of the HQ HI to the limit of 1.0 at locations where people live or congregate? Does the inhalation exposure for the most exposed individual need to be determined?

Q & A A1. No. Many of the submittals OAQPS has received do not specify locations of residence (or congregation) but instead locate receptors along the fenceline and use a Cartesian grid for all offsite locations, then take the highest value of all receptors. OAQPS thinks this more than adequately covers locations of residence and cong.

Q & A Q2. Though manganese testing was not performed at worst-case scenario, the applicant wants to demonstrate future compliance with an annual manganese limit by complying with their current PM limit and BTU design rate, and assuming the manganese/PM ratio is the same as during the non-worst-case stack testing. Is this acceptable?

Q & A A2. This question has come from several States. OAQPS is currently discussing this with the Office of Enforcement and Compliance Assurance and Office of General Counsel. [OAQPS will get back to us on this.]

Q & A Q3. Fuel oil analyses from 2005 were used. Is this acceptable? No analysis of the on-plant recycled fuel oil is given at all because it is considered insignificant and was not quantified during stack testing. Is this acceptable?

Q & A A3. If the fuel testing is acceptable for MACT compliance, OAQPS thinks it is acceptable to use in the HBCA. Is the recycled oil used in small quantities relative to virgin oil? Is the AP-42 emission factor significantly different from the fuel test results? Seems like if is truly used in small quantities that a permit condition limiting it could be possible.

Q & A Q4. Section requires that a fuel analysis plan be submitted no later than 60 days before the date that you intend to demonstrate compliance. Applicants state that since the compliance date is September 13, 2007, they do not have to submit these plans yet. Would OAQPS agree that this is true even for facilities that have submitted health-based eligibility demonstrations?

Q & A A4. No. Appendix A to subpart DDDDD section8.(a)(3) requires that the demonstration must include the fuel analysis.

Q & A Q5. If a facility uses the HBCA to get out of including manganese in the TSM limit, do they still have to determine compliance with the TSM limit?

Q & A A5. Yes. Annually if by stack test, or every 5 years if by fuel analysis.

Examples of Permit Conditions Methods of Operation Permitted Capacity Stack Information Emissions Limits

Examples of Permit Conditions (cont’d) A.9.a. Hydrogen Chloride. Except as provided in Conditions A.9.b. and c., hydrogen chloride emissions shall not exceed 0.09 lb per MMBtu of heat input. [40 CFR (a)(1); Table 1 to Subpart DDDDD of Part 63 - Emissions Limits and Work Practice Standards: #9.b] A.9.b. Hydrogen Chloride - Health Based Compliance Alternative (HBCA). For this emissions unit, the permittee has self-certified that they are eligible to use the Health Based Compliance Alternative (HBCA) for hydrogen chloride emissions utilizing the procedures prescribed in Appendix A of 40 CFR 63 Subpart DDDDD and as authorized in 40 CFR (a). [40 CFR (a)]

Examples of Permit Conditions (cont’d) A.9.c. Hydrogen Chloride - Health Based Compliance Alternative (HBCA). The chlorine emissions from this emissions unit shall not exceed 0.05 lb per MMBtu of boiler heat input 1. This emissions limit is based on an annual average. The emissions unit is assumed to be in compliance with this chlorine emissions limit when the following conditions are met; 1 From January 2005 & January 2007 Fuel Analyses, potential HCl emission rate from fuels: bark=0.014 lb/MMBtu, bark/wastewater wood residuals=0.025 lb/MMBtu, No. 6 Fuel Oil=3.6x10-3 lb/MMBtu. Applicant utilized a safety factor of 2 to bark/wastewater wood residuals results (highest) due to potential variability in chlorine content of bark and wastewater wood residuals.

Examples of Permit Conditions (cont’d) (1)Exhaust gases shall be released through a vertical stack with a release height of 257 feet (78.3 meters), 11.0 feet (3.35 meters) in diameter, 450°F (505°K), 235,000 acfm gas flow rate, and 41.2 fps (12.6 mps) velocity. The stack location is UTM Zone 17, E.456,274.5, N.3,394,248.9.

Examples of Permit Conditions (cont’d) (2)Operate a multicyclone (without flyash reinjection) followed by an ESP. (3)Fire carbonaceous fuel (including wastewater wood fiber residuals, No. 6 Fuel Oil, No. 2 Fuel Oil, On-Specification Fuel Oil as stated in Condition A.2. above;

Examples of Permit Conditions (cont’d) (4)For the purposes of the HCl HBCA, the worse-case fuel mix has been identified as the combination of carbonaceous fuel (bark and wastewater wood fiber residuals) and No. 6 Fuel Oil. This mix consists of a maximum of 25 tons per hour2,3 from bark and wastewater wood residuals and 348 MMBtu/hr3,4 from No. 6 Fuel Oil, and 2 Based on 9,137 Btu/lb for bark and wastewater wood fiber residuals “sludge from sludge press” from January 2005 submitted fuel analysis from HBCA eligibility. 3 Maximum firing rate of any combination of fuels, as identified in Condition A.2. above, MMBtu/hr of carbonaceous fuel and 348 MMBtu/hr of No. 6 Fuel Oil. 4 Based on 150,257 Btu/gallon for No. 6 Fuel Oil from January 2005 submitted fuel analysis from HBCA eligibility.

Examples of Permit Conditions (cont’d) (5)Maximum boiler heat inputs [as stated in Condition A.2. above]. Should the emission unit not meet any one of the stated above criteria, the owner or operator shall update the HBCA eligibility demonstration as stated in Condition A.9.d. [40 CFR (a); #11(a) of Appendix A of 40 CFR 63 Subpart DDDDD]

Examples of Permit Conditions (cont’d) A.9.d. Updated HBCA Eligibility Demonstration and Resubmittal. The HBCA eligibility demonstration must be updated and resubmitted each time that any of the parameters that defined the boiler as eligible for the HBCA changes in a way that could result in increased HAP emissions or increased risk from exposure to emissions. These parameters include, but are not limited to, fuel type, fuel mix (annual average), type of control devices, HAP emission rate, stack height, process parameters (e.g., heat input capacity), relevant reference values, and locations where people live). If the HBCA eligibility demonstration is being updated to account for an action described above that is under the control of the facility (e.g. change in heat input capacity of the boiler), the revised eligibility demonstration must be submitted to the Department prior to making the change. The Permittee shall apply for and obtain a Title V Permit Revision in order to incorporate the change into the Title V Operation Permit.

Examples of Permit Conditions (cont’d) A.9.d.(cont’d) Should it be determined that the emissions unit is no longer eligible for the HBCA, then the Permittee shall comply with the applicable emission limits, operating limits, and compliance requirements in 40 CFR 63 Subpart DDDDD prior to making the process change and revising the permit. If the HBCA eligibility demonstration is being updated to account for an action described above that is outside of the control of the facility (e.g. change in a reference value), and that change causes the boiler to no longer be able to meet the criteria for the HBCA, the Permittee shall comply with the applicable emission limits, operating limits, and compliance requirements in 40 CFR 63 Subpart DDDDD within 3 years. [#11(a) and #11(b) of Appendix A of 40 CFR 63 Subpart DDDDD]

Examples of Permit Conditions (cont’d) A.9.e. Updated HBCA Eligibility Demonstration Review. The revised eligibility demonstration may be reviewed by the Department or EPA to verify that the demonstration meets the requirements of Appendix A of 40 CFR 63, Subpart DDDDD and is technically sound (i.e. use of the look-up tables is appropriate or the site-specific assessment is technically valid). If the Permittee is notified by the Department or EPA of any deficiencies in the submission, the emissions unit will not remain eligible for the HBCA until the Department or EPA verifies that the deficiencies are corrected. [#11(c) of Appendix A of 40 CFR 63 Subpart DDDDD]

Examples of Permit Conditions (cont’d) A.9.f. HBCA - Recordkeeping. Records of the information used in developing the HCl HBCA Eligibility Demonstration for this boiler must be kept, including all of the information specified in Section 8 of Appendix A of 40 CFR 63 Subpart DDDDD. [#12 of Appendix A of 40 CFR 63 Subpart DDDDD]

Questions? Contact: Cindy Phillips, P.E. FDEP Bureau of Air Regulation (850)