www.all4inc.com | philadelphia | atlanta | houston | washington dc boiler mact compliance plans:...
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www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Boiler MACT Compliance Plans: Failure to Develop Plans Is Planning to Fail
Susie Bowden| [email protected] | 334-855-3382 August 19, 2015
Presented to A&WMA Southern Section Annual Meeting
2 Your environmental compliance is clearly our business.
Agenda Who Is Required to Develop Plans? Performance Test Plan Site-Specific Monitoring Plan Site-Specific Fuel Sampling Plan Optional Plans Proposed Plan Questions and Open Discussions
3 Your environmental compliance is clearly our business.
Facilities subject to the emissions limits and/or operating limits in Tables 1 or 2 or 11 through 13 of the Rule
Facilities with Gas 1 boilers do not have emissions limits or operating limits = NO PLANS
Who Is Required to Develop Plans?
Performance Test Plan
5 Your environmental compliance is clearly our business.
Performance Test Plan 40 CFR §63.7520(a) [Develop and submit upon request] Plan Requirements [§63.7(c)]:
• Program Contact and Responsibilities• Test Program Schedule• Test Conditions• Test Method Performance Audit (PA)• Unit/Process Operation and Parameter Monitoring• Control Device Operation and Monitoring• Stack Sampling Location• Pollutant-specific Reference Methods• Emission Test Data Reduction
6 Your environmental compliance is clearly our business.
If requested, must be submitted at least 60 calendar days before date of the performance test.
The level of complexity will go up depending on the following:• Number of worst-case fuel mixtures• Number of boilers in the test program• Number of control devices
Performance Test Plan
Site-Specific Monitoring Plan
8 Your environmental compliance is clearly our business.
Site-Specific Monitoring Plan 40 CFR §63.7505(d) [Develop and submit upon request] Required for CMS (i.e., CEMS, COMS, and/or CPMS) Plan Requirements:
• Initial and subsequent calibration• Determination and adjustment of the calibration drift• Preventative maintenance, including spare parts inventory• Accuracy audit procedures, including sampling and analysis
methods• Program of corrective action for a malfunctioning CMS• Basis for selection of measurement location relative to each
affected source such that the measurement is representative
9 Your environmental compliance is clearly our business.
Site-Specific Monitoring Plan• Equipment and specifications of the CMS, which include:
Sample interface Pollutant concentration or parametric signal analyzer Data collection and reduction systems
• Procedures for the ongoing Operation and Maintenance (O&M), data quality assurance, and ongoing recordkeeping and reporting
If requested, must be submitted at least 60 calendar days before date of the performance test.
10 Your environmental compliance is clearly our business.
The level of complexity will go up depending on the following:• Lack of existing QA plans• Lack of manufacturer/performance specifications• Lack of O&M procedures or SOPs• Number of control devices• Number of boilers
Site-Specific Monitoring Plan
Site-Specific Fuel Sampling Plan
12 Your environmental compliance is clearly our business.
Site-Specific Fuel Sampling Plan 40 CFR §63.7521(b) [Develop and submit for approval if
using an alternative analytical method other than those listed in Table 6 of Subpart DDDDD]
Plan Requirements:• Identification of the fuels that are to be combusted• Determination of who will be conducting the fuel analysis• Detailed description of the sample locations and procedures for
collecting and preparing the samples• Specification of the analytical methods, along with minimum
detection levels, to be used• Presentation of the calculations and supporting documentation
13 Your environmental compliance is clearly our business.
The level of complexity will go up depending on the following:• Number of fuels• Number and type of sampling locations• Number of boilers• Need to use alternative analytical method, triggering the need
to submit to U.S. EPA• Using total select metals (TSM) in lieu of PM
Site-Specific Fuel Sampling Plan
Optional Plans
15 Your environmental compliance is clearly our business.
Emissions Averaging Plan [40 CFR §63.7522(g)]• If emissions averaging is chosen as the compliance option, then
plan required that details: Identification of boilers in averaging group Identification of monitored process parameter for each group Specific control technology or pollution prevention methods used for
each boiler Test plan for measurement of emissions
Optional Plans
16 Your environmental compliance is clearly our business.
Optional Plans Energy Efficiency Implementation Plan [40 CFR
§63.7533(d)]• If an existing boiler meets the criteria to take credit for
implementing energy conservation measures identified during the energy assessment, then an implementation plan must be developed and include:
Identification of boilers to include in applying efficiency credits Description of the energy conservation measures implemented along
with the energy savings Explanation of the criteria utilized for determining the energy savings
Proposed Plan
18 Your environmental compliance is clearly our business.
Startup/Shutdown Plan• Part of the proposed reconsiderations• Plan describing work practices and procedures to be following
during periods of startup and shutdown
Proposed Plan
www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Questions & Open Discussions
Susie Bowden| [email protected] | 334-855-3382 August 19, 2015