Health Based Compliance Alternatives HBCA under MACT Maximum Achieveable Control Technology: Permitt

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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

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8 Florida Facilities Requested Site-Specific
HBCA for I/C/I Boiler MACT

• 3 Pulp Paper
• 2 Plywood
• 3 Sugar

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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

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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.

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Tools Developed

• Summary of Subpart DDDDD
• Checklist for HBCA Demonstration

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On-the-job Training

• OAQPS has been very helpful in answering
  questions about the HBCA as they arise.
• If you have questions, try contacting
• Morris.Mark_at_epamail.epa.gov
• Hirtz.James_at_epamail.epa.gov
• Eddinger.Jim_at_epamail.epa.gov

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On-the-job Training (contd)

• Sample of Permitting Questions and
• OAQPS Answers

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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?

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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.

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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?

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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.

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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?

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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.

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Q A

• Q4. Section 63.7521 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?

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Q A

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

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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?

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Q A

• A5. Yes. Annually if by stack test,
• or every 5 years if by fuel analysis.

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Examples of Permit Conditions

• Methods of Operation
• Permitted Capacity
• Stack Information
• Emissions Limits

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Examples of Permit Conditions (contd)

• 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 63.7500(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 63.7507(a).
• 40 CFR 63.7507(a)

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Examples of Permit Conditions (contd)

• 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 input1.
  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 bark0.014 lb/MMBtu, bark/wastewater wood
  residuals0.025 lb/MMBtu, No. 6 Fuel Oil3.6x10-3
  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.

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Examples of Permit Conditions (contd)

• (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, 450F (505K), 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.

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Examples of Permit Conditions (contd)

• (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

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Examples of Permit Conditions (contd)

• (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, 457.0 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.

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Examples of Permit Conditions (contd)

• (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 63.7507(a) 11(a) of Appendix A of 40
  CFR 63 Subpart DDDDD

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Examples of Permit Conditions (contd)

• 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.

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Examples of Permit Conditions (contd)

• A.9.d.(contd) 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

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Examples of Permit Conditions (contd)

• 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

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Examples of Permit Conditions (contd)

• 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

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Questions?

• Contact
• Cindy Phillips, P.E.
• FDEP Bureau of Air Regulation
• [phone]
• Cindy.Phillips_at_dep.state.fl.us