EPA recently issued notification letters to approximately 300 sources requiring additional data for Part II of the EPA’s Information Collection Request (ICR) for the development of the new Boiler MACT and Commercial/Industrial Solid Waste Incinerator (CISWI) MACT Rules. These sources were selected to gather additional information about certain process units and fuel types that was either unavailable or insufficient from EPA’s Part I ICR.
The emissions testing and fuel sampling procedures are specific to each unit and depend on fuel type, combustor design, and emissions control device. For most sources, emissions test requirements include CO, HCl and HF, mercury, metals (antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, phosphorus and selenium), particulate matter (total PM, filterable PM2.5, and condensables), dioxins and furans, and SO2. Additional requirements for some boilers and process heaters include formaldehyde, total hydrocarbons, methane, and NOx. Many sources are also required to conduct a 30-day fuel sampling trial to assess variability of chlorine, fluorine, and metals constituents. A limited number of sources are required to conduct a 30-day continuous monitoring trial of CO and total hydrocarbons, which will require some sources to install, certify, and operate temporary analyzers.EPA requires the results of all stack tests, fuel analyses, and/or monitoring data to be submitted by October 15, 2009. Additional guidance on the test procedures, methods, and reporting requirements has been included with each notification letter although our review of these guidelines indicates that a number of clarifications would be helpful. EPA will be hosting a webinar on June 18, 2009 for affected sources and stakeholders to address some of these issues. Based on the ICR collection deadline, it is apparent that EPA will not be able to meet the July 15, 2009 deadline for the proposed Boiler MACT rule. However, at this point, EPA has not announced a new date for the proposed rule. RMB recommends that sources that are affected by the new ICR begin to investigate stack testing options and scheduling as soon as possible. Current work loads for stack test firms and analytical laboratories are pushing test dates into late-August and September 2009. Tests performed after mid-September 2009 may have difficulty meeting the October 15, 2009 deadline. If you do not believe you can meet EPA’s deadline or you do not believe you should have been selected as an ICR recipient, you should contact EPA immediately. Since many of these test methods are complicated and/or relatively new (OTM 27 and OTM 28), RMB recommends hiring a qualified testing contractor that has had sufficient prior experience with each method. Also, the ICR specifies that all test data must be submitted electronically using EPA’s Emissions Reporting Tool (ERT). Many testing firms may not be familiar with this software. Therefore, sources should allow sufficient time to convert and submit the data in the required format.
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