Boilers NESHAP Proposal - April 2010

"Boiler operators would be required to reduce mercury emissions by 50 percent as part of two new proposed rules to control air toxics from large and small boilers released by the Environmental Protection Agency April 30."

Would require annual testing for major and area sources. Existing small boilers and process heaters (L.T.E 10 MMBtu/hr) would need biannual tuning. Existing large boilers (area sources > 10 MMBtu/hr) would have to perform an energy assessment. Will cover boilers that burn coal, oil, biomass, and other non-hazardous materials. AWMA article includes link to EPA web site.

AWMA article

Trinity article

Of Boiler Rules and Biofuels
Martin Law article added 8/20/2010. Includes concise background and good short discussion of hazardous waste issue. Here's an excerpt:

"The key is whether the unit burns any “solid waste.” This leads to the question: when is biomass also solid waste? EPA’s original approach to this question was to exempt most materials that would be considered biomass (e.g., wood, food, agricultural byproducts – even manure, if burned) because they had not been “discarded.” However, EPA has now changed its rule to include an additional criterion: these materials are only exempted from treatment as solid waste if they remain in control of the generator. If these materials leave the point of generation, operators are now required to petition EPA for a “non-waste determination.”

EPA has indicated it will grant a non-waste determination if the boiler operator can establish that market participants treat the biomass stock as a fuel rather than a solid waste, and that the fuel stock has a chemical and physical identity comparable to commercial fuels, will be used in a reasonable timeframe, and has air emissions when burned comparable to traditional fuels. EPA’s determination is subject to notice, comment and hearing requirements, and, presumably, judicial review. Depending on how EPA handles this process, it could pose a significant administrative burden and uncertain time delays for fuel supply contracts between biomass energy project developers and timberland managers, farmers, and other suppliers of biomass."


Proposed Area Source Boiler MACT:
Here are some graphical outlines of the area source boiler MACT proposal. There are three graphics files: one overview and two subcategory expansions. The original file was created in a free mind mapping application called XMind which can be downloaded from this address: http://www.xmind.net/

XMind mind map

Overview jpg

Emission Standards jpg

Continuous Compliance jpg

Here are the proposed rules as published in the Federal Register. To access them, you'll have to log into Cyber Regs. You can use username 'kevinmathews' and password 'bisoneng'.

Major Source Boilers

Area Source Boilers

RCRA Waste Definition

CISWI NSPS Modification

Here's an MDEQ summary presented to CAAAC in July 2010:

MDEQ Summary Presentation

Coal Ash Proposed Rule

Pre-publication proposal released 5/4.

Coal Combustion Residuals Industrial Waste US EPA


E-mail from EPA to Grant regarding proposed rule's applicability to other fuel residues:


From: Livnat.Alexander@epamail.epa.gov [mailto:Livnat.Alexander@epamail.epa.gov]
Sent: Monday, May 10, 2010 1:15 PM
To: Grant Rodway
Cc: Souders.Steve@epamail.epa.gov
Subject: Re: Clarification on the Definition of CCR in the Proposed Rule to Regulate CCR Under RCRA

Mr. Rodway,

Your conclusion about the narrow definition of FFCs, to the effect that 'Waste from the combustion of oil, natural gas, and petroleum coke would not be subject to this proposed rule" is correct. This goes back to the May 2000 Regulatory Determination on Wastes from the Combustion of Fossil Fuels (http://www.epa.gov/fedrgstr/EPA-WASTE/2000/May/Day-22/f11138.htm) where we said that fossil fuel combustion wastes do not warrant regulation under subtitle C: "The Agency has concluded that no additional regulations are warranted for coal combustion wastes that are used beneficially (other than for minefilling) and for oil and gas combustion wastes (emphasis added)....However, EPA has also determined national regulations under subtitle D of RCRA are warranted for coal combustion wastes when they are disposed in landfills or surface impoundments...". This is the reason why since the 2000 Regulatory Determination we have focused on coal combustion wastes/residuals.

Regards,

Alex Livnat, Ph.D
Materials Recovery and Waste Management Division
Office of Resource Conservation and Recovery
US EPA (MC: 5304P)
1200 Pennsylvania Ave, NW
Washington, DC 20460-0001
Tel: (703) 308-7251
Fax: (703) 605-0595
Email: livnat.alexander@epa.gov