Final IB-MACT and CISWI Rules (2/23/11)
On February 23, EPA unveiled
the final IB-MACT Rules for area sources and major sources and the
final CISWI NSPS and revised definition of solid waste. At the
same time, EPA also issued the final NSPS for sewage sludge
incinerators. As EPA stated in their press release after the
January 20 court ruling extending the deadline for the final rules, the
final IB-MACT rule contains a number of significant changes from the
proposed rule although not all of these changes are good news to many
industrial sources. The following is a summary of several key
issues based on our initial review of the new rule:
Startup/shutdown - Perhaps the most significant
change in the final rule is that the numeric standards no longer apply
during periods of startup and shutdown. Instead, the rule imposes
a work practice standard for those periods of operation.
New subcategories - The new rule includes a
single solid-fuel subcategory for the fuel-based pollutants (PM, HCl,
Hg), which was intended to benefit biomass sources.
New alternative standards - The rule now
includes alternative output based standards for each pollutant (lb/mmBtu
Changes in emissions standards for new/existing
New biomass units, while the limits for mercury and CO
(for FBCs) increased significantly, the PM, HCl, and CO limits (for
stokers/suspension burners) decreased even further.
For existing biomass units, while the limits
for PM, HCl, Hg, and CO (for FBCs) increased significantly, the CO
limits decreased slightly for suspension burners and stokers.
For existing PC-fired coal units, all units
showed significant increases.
For existing liquid-fired units, the PM and
CO limits increased and the HCl and mercury limits decreased.
All D/F limits were about the same or increased
significantly. However, the fact that there are numeric standards for
D/F instead of a work practice standard suggests that EPA may not have
properly handled non-detect values in their analysis.
Risk-based compliance alternatives - In the
final rule, EPA elected not to include health-based compliance
alternatives for any of the standards.
CEMS - EPA removed the requirement for CO CEMS
but retained the PM CEMS requirement for large units > 250
mmBtu/hr. Compliance is based on a 30-day average instead of a
24-hour average as proposed.
ERT Reporting - EPA maintained the requirement to use the
ERT software for submitting compliance test data.
EPA plans to address a number of unresolved issues with the
final rules through the reconsideration process. A copy of the
unpublished final rules and information regarding EPA's notice of
reconsideration can be found in our
For further information, please contact Rob Barton at 919-791-3129.
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RMB Consulting &
February 22, 2013