1. Wes Thornhill, Chief Industrial Chemicals Section Air Division
Boiler MACT CISWI Rule
Wes Thornhill, Chief
Industrial Chemicals Section
Air Division
adem.alabama.gov

2. 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

3. Boiler/CISWI MACT Comment Period ends August 23rd.
Court ordered promulgation date of December 16, 2010.
adem.alabama.gov

4. 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

5. 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

6. Boiler MACT Boiler MACT (major source)
Anticipated control device train
Carbon Injection  Baghouse  Scrubber
And good combustion practices
adem.alabama.gov

7. 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

8. Boiler MACT Boiler MACT (major source) ‘Beyond the floor’
All major source facilities are to conduct an “Energy Assessment”
Energy Star
adem.alabama.gov

9. 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

10. 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

11. Boiler MACT Boiler MACT (area source) Limits Beyond the floor
Coal fired units
Mercury
CO as a surrogate for POM
PM (new units)
Biomass and Oil fired units
Beyond the floor
Energy assessment
adem.alabama.gov

12. Boiler MACT Boiler MACT (area source) <10 mmbtu/hr Annual tune up
adem.alabama.gov

13. 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

14. CISWI Rule Commercial and Industrial Solid Waste (CISWI) Rule Limits
Burns ANY solid waste
Limits
Cd, CO, HCl, Hg, Pb, PM, SO2, NOx, dioxins/furans
adem.alabama.gov

15. CISWI Rule CISWI Rule Anticipated control device train
Carbon injection  Baghouse  Scrubber  SNCR  Afterburner
And good combustion practices
adem.alabama.gov

16. CISWI Rule CISWI Rule Testing Monitoring
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

17. 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

18. 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

19. Waste Solid Waste Definition Wastes Non-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

20. Boiler/CISWI MACT Concerns
Achievability, especially for smaller and area sources
FrankenMACT approach
adem.alabama.gov

21. 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

22. 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

23. 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

24. Boiler/CISWI MACT Reminder! Comment Period ends August 23rd.
Court ordered promulgation date of December 16, 2010.
adem.alabama.gov

25. Boiler/CISWI MACT
Questions???
adem.alabama.gov