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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| sbowden@all4inc.com | 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

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Questions & Open Discussions

Susie Bowden| sbowden@all4inc.com | 334-855-3382 August 19, 2015