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

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

3. 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.

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

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

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

7. 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

8. 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 D or PTC 19, Part 10
For CO
EPA Methods 10, 10A, or 10B
ASTM D (natural gas only)

9. COMPLIANCE TESTING Fuel Analysis Requirements
Listed in Table 6 to Subpart DDDDD
Required steps
Collect samples (using procedure in (c) or ASTM D
Composite fuel samples ( (c))
Prepare composite samples (ASTM D )
Determine heat content (ASTM D a)
Determine moisture content (ASTM D )
Determine HAP concentration (Listed method or equivalent)
Convert HAP concentration to lb/million Btu

10. 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

11. SPECIAL TESTING REQUIREMENTS
New liquid fuel that burn only fossil fuel and do not burn residual oil (40 CFR (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)

12. 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)

13. 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.

14. 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

15. 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

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

17. 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

18. 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

19. How to Conduct a Site-Specific Risk Assessment
Refer to EPA’s Air Toxics Risk Assessment Reference Library (
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

20. 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

21. 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

22. 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

23. 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:
An electronic version of public docket (including public comments) is available at:
Search for docket ID No. EPA-HQ-OAR
Contact: Compliance Contact:
Jim Eddinger Greg Fried (OECA)
Risk Contact
Scott Jenkins

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