From Tom Mattei and EM magazine:
Due Diligence for Documentation Provided by Stack Testers Relative to 40 CFR, Part 75-Affected Sources

http://lnkd.in/EhpwmG

More Reasons Not To Store Dust In Your Dust Collector Hopper

Guest Post from Dominick DalSanto of Baghouse.com 

Clogged machinery,  exposure to hazardous chemicals, and disruptions in plant processes,  are just a few of the problems that come from using your dust collector hopper for dust storage.

Article Link:
http://www.baghouse.com/2012/02/27/more-reasons-not-to-store-dust-in-your-dust-collector-hopper/

EPA Proposes Changes to Clean Air Act Standards for Boilers and Incinerators

WASHINGTON – The U.S. Environmental Protection Agency (EPA) is proposing changes to Clean Air Act standards for boilers and certain incinerators based on analysis, review and consideration of data and input from states, environmental groups, industry, lawmakers and the public.

The proposed reconsideration targets public health protection through significant reductions in toxic air pollutants, including mercury and soot, while increasing the rule’s flexibility and addressing compliance concerns raised by industry and labor groups.

The changes also propose to cut the cost of implementation by nearly 50 percent from the original 2010 proposed rule while maintaining health benefits. These standards are pursuant to requirements laid out in the 1990 Clean Air Act Amendments.

http://t.co/SeEyx8qg

Nitric Acid Plants: Proposed NSPS Revisions

PROPOSED REVISIONS TO NEW SOURCE PERFORMANCE STANDARDS
(NSPS) FOR NITRIC ACID PLANTS

• On September 30, 2011, the U.S. Environmental Protection Agency (EPA) proposed to
strengthen air pollution limits for nitric acid plants. Most nitric acid is used to produce
fertilizer. 

• The proposed standards, known as New Source Performance Standards (NSPS), would limit
emissions of nitrogen oxides (NOx) from new, modified, and reconstructed nitric acid plants. 
NOx is a key ingredient in the formation of ground-level ozone (smog).  It also contributes to
the formation of fine particle pollution.  

• Currently, the NOx emissions limit is 3.0 pounds of NOx per ton of nitric acid produced. The
Agency is proposing to lower the limit to 0.50 pounds NOx per ton of nitric acid produced. 
EPA estimates that this proposed rule would reduce NOx emissions from these facilities by
2,000 tons per year.

• Nitric acid plants are likely to use selective catalytic reduction (SCR) as the control
technology to meet these limits.

• There are an estimated 40 nitric acid plants in the US.  This rule would only apply to those
facilities if they modified their production facilities.  EPA estimates that six new facilities
will come on line over the next 5 years and be subject to these requirements.  

• EPA will take public comment on the proposal for 45 days following publication in the
Federal Register.  EPA will hold a public hearing, if one is requested.  

EPA Fact Sheet:
http://www.epa.gov/ttn/oarpg/t3/fact_sheets/20110930NitricAcidNSPSfs.pdf

Proposed Rule:
http://www.epa.gov/ttn/oarpg/t3/fr_notices/20110930NitricAcidNSPS.pdf

Condensable Particulate Matter - Exceptions to the Rule

With the recent revisions to Method 202 for condensable particulate matter (CPM), the US EPA included an exception to the requirement to extract the CPM filter (the secondary filter that is located between the “warm” and “cold” sections of the impinger train).  The exception is subject to the following conditions:

1.       The source temperature is less than 85°F;

2.       Sampling is done using an in-stack filter (Method 17 or Method 201A)

3.       The analytical laboratory is able to obtain a stable weight for the CPM filter (suggesting a lack of high vapor pressure sulfate species).

Sampling for CPM under essentially ambient stack conditions is somewhat unusual, and is not something the analytical laboratory is likely to expect.  Testers collecting samples under these circumstances should take care to notify the laboratory, both on the chain of custody and by way of a separate note or phone call.

EPA Admits Error in Proposed Mercury MACT Rule

May 25, 2011 - Power News (http://bit.ly/iC00D9):

The Environmental Protection Agency (EPA) has acknowledged in a letter to non-profit power trade organization Utility Air Regulatory Group (UARG) that it made a conversion error in the way mercury emissions data was calculated to set limits for the agency’s mercury maximum achievable control technology (MACT) floor in the proposed Mercury and Air Toxics Standards (MATS) rule. 

EPA Assistant Administrator for Air and Radiation Gina McCarthy wrote that the error would be corrected and results presented within a week, but that the corrections were not expected to have an “appreciable impact” on the pollution controls required to meet the new standards. 

The group had said in a May 6 letter to the EPA that the MACT rule is one of the "most far-reaching and expensive rules" the agency had ever proposed under the Clean Air Act. The EPA asked for information of "unprecedented size and scope," including historic information on hazardous air pollutants that required electric generating units to conduct more than $100 million of stack sampling for emissions. 

The UARG said it was concerned that the EPA had not allotted enough time to review all the data collected. A review of the information in the "limited time" made available for public comment showed several errors that "warrant withdrawal of the current proposal, re-analysis of the data, and re-proposal once the errors have been addressed." 

One glaring error regarding MACT standards for mercury was that the EPA concerned how the EPA converted historical emissions data to common emission units. "Specifically, the conversion factor EPA used to convert measurements reported in terms of lb/GWh to lb/MWh is incorrect by a factor of 1,000," the group asserted. "As a result, the emissions of the unit chosen as the single best performing mercury source are actually 1,000 times higher than those EPA assumed in setting the new source MACT limit for mercury." 

The group also charged that the conversion error pervades EPA's mercury MACT floor analysis for existing units. "At least half of the 40 units identified as 'best performing' have actual emissions 1,000 times higher than EPA used in its MACT floor analysis."  

The UARG also found errors in the EPA's MACT limits for mercury for units designed to burn coal. For units burning coal of more than 8,300 BTH/hour, the limit is 1.0 lb/10 BTU or 0.008lb/GWh. But the "required heat rate to convert from the proposed input limit to the proposed output limit is 8,000 BTU/KWh, which is unrealistically low value for a coal-fired power plant," the group said. 

Addressing that concern, McCarthy said in her letter on Thursday that revised calculations resulted in only a slight increase of that limit, however, from 1.0 to 1.2 pounds per BTU. "We estimate that this change will lessen our expected mercury reductions by about half of a ton, not changing our projected 90 percent reduction from the mercury in the coal used by power plants." 

McCarthy also acknowledged the UARG's concerns as "possible discrepancies" regarding the EPA's calculations, and she said the EPA would "fully consider" the UARG's comments and other comments provided during the comment period. 

"We have revised these mercury calculations and will include them in the docket this week to ensure that this information is publicly available," she wrote. "We do not expect this change to have any appreciable impact on the controls that will be needed for compliance or on the analyses underlying the proposal."

Sources: POWERnews, EPA, UARG, www.vnf.com

Boiler MACT Effective Date Delayed...

May 16, 2011 - The EPA has announced the next step on air toxics standards for boilers and certain incinerators. The agency is allowing time to seek and review additional public input on new standards.  Potential compliance activities for the rule include work practice standards, fuel analysis (additional options currently under consideration) and performance testing (stack tests).

Boiler MACT site: http://www.epa.gov/airquality/combustion


Fact Sheet: http://www.epa.gov/airquality/combustion/docs/20110516nextstepfs.pdf

Notice: http://www.epa.gov/airquality/combustion/docs/20110516nextstep.pdf

Action:

• On May 16, 2011, EPA announced its next step in allowing time to seek and review additional public input on the final standards for boilers and certain solid waste incinerators issued in February 2011.
• Following the April 2010 proposals, the agency received more than 4,800 comments from businesses and communities, including a significant amount of information that industry had not provided prior to the proposals. 
• Based on this input, EPA made extensive revisions to the standards. For example, EPA made revisions to the proposed subcategories and to some of the proposed emissions limits.  
• In December 2010, EPA requested additional time for review to ensure the public’s input was fully addressed.  However, the court granted EPA only an additional 30 days, resulting in the February 2011 final rules.
• The agency is reconsidering the standards because the public did not have sufficient opportunity to comment on these changes, and, as a result, further public review and feedback is required to meet the legal obligations under the Clean Air Act.   
• EPA is also issuing a stay to delay the effective date of the standards for major source boilers and commercial and industrial solid waste incinerators. The stay will allow the agency to seek additional public comment before requiring thousands of facilities across multiple, diverse industries to make investments that may not be reversible if the standards are revised following reconsideration and a full evaluation of all relevant data.  
• The stay will remain in place until the proceedings for judicial review of these rules are completed or EPA completes its reconsideration of the standards, whichever is earlier. 
• EPA understands that members of the public may wish to submit additional data. Any additional data and information related to affected sources and their emissions that the public would like the agency to consider should be submitted by e-mail to combustionsurvey@erg.com by July 15, 2011.   
• This approach will help ensure that the final standards are protective, cost-effective, practical to implement and consistent with the requirements of the Clean Air Act.