Hot Topic Hour March 22 Covered More Changes to the Industrial Boiler MACT

At the March 22 Hot Topic Hour the following speakers helped us understand the current situation of the Industrial Boiler MACT and suggested how boiler operators might deal with the impact of the current and proposed rule.

Connie Senior, Director of Technology Development ADA Environmental Solutions, discussed “Low Capex Solutions for Compliance with Industrial Boiler MACT.” Integration of sorbent injection with particulate control can provide control of both mercury and HCl, if care is taken to select the right sorbents and design the system correctly. Often a combination of alkaline sorbents and activated carbon injected separately may be the best answer.

HCl

§  0-90 percent control required for coal-fired units – less reduction (if any) for biomass-fired units

§  Bituminous coals have higher chlorine and require higher reductions

Mercury

• 65-90 percent control required for coal-fired units – less reduction (if any) for biomass-fired units
• Achievable on most subbituminous and biomass units
• Limits may be challenging on units with higher sulfur coals and may require SO₃ mitigation

Total PM

• May result in new fabric filters or hot- to cold-side ESP conversions.

Katherine (Kate) L. Vaccaro, Associate at Manko, Gold, Katcher & Fox LLP, focused on some of the key aspects of EPA's Proposed Reconsideration of the Boiler MACT, including certain relevant compliance deadlines. She highlighted some of the principal concerns voiced by industry in response to EPA's proposal. Many of these have been addressed in the most recent revisions. However, when EPA issues the final reconsideration next month, there is likely to be further challenge from industry.

David South, President of Technology & Market Solutions, LLC, a consulting firm, discussed some compliance activities boiler operators could be doing now. While Boiler MACT emission reduction requirements and schedule are still uncertain, the rulemaking specifies several compliance activities that are less contentious and would improve boiler operations regardless of the ultimate emission requirements. Tune-up steps include:

• Inspect burner and clean/replace any components as necessary
• Adjust the burner as necessary to optimize the flame pattern
• Inspect the air-to-fuel ratio control system to ensure it is calibrated and functioning properly
• Optimize emissions of CO consistent with manufacturer’s specifications
• Measure CO and O₂ levels in exhaust before/after tune-up
• Record type/amount of fuel used for previous 12 months
• Submit a signed statement documenting tune-up.

Mack McGuffey, Partner at Troutman Sanders LLP Atlanta office and a specialist in regulatory compliance under the Clean Air Act, reviewed history which shows that there have been substantial changes in the proposed limits each time the proposed rule has been revised. He speculated that some more changes are likely to be reflected in the newest version. But here are some changes in the present version from the previous.

• For “new” biomass boilers:
  • PM: Went from an unachievable 0.0011 lb/MMBtu to 0.029 (stokers) / 0.0098 (BFB)
  • HCl: Went from a difficult 0.0022 lb/MMBtu to 0.022 lb/MMBtu
  • CO: Went from an unachievable 160 ppm (stokers) to 590 ppm / 410 ppm

Reconstructed boilers cost over 50 percent of the cost of a comparable new source and are technically and economically feasible to meet standards.

• Mercury is more stringent except for liquid-fueled units
• CO for existing coal is more stringent (160 ppm to 41 / 28 ppm).

Mack pointed out that existing boilers become new if “reconstructed.”

The Bios, Abstracts and Photos information is linked below.

Bios, Abstracts, Photos - 3-22-12