U.S. EPA ICRs require HAP and other emissions tests on combustion units

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Source: Custom Stack Analysis, LLC.

In early June 2009, U.S. EPA issued Information Collection Request (ICR) letters to facilities requiring hazardous air pollutant (HAP) and other emission tests on more than 300 industrial, commercial and institutional boilers and process heaters and on commercial/industrial solid waste incinerators (CISWI). The request is enforceable under Section 114 of the federal Clean Air Act. Facilities have until mid-October 2009 to complete the tests and submit results to EPA. The ICR results from EPA's court-ordered (2007) reconsiderations of the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for industrial, commercial and institutional boilers and process heaters (�Boiler MACT,� 40 CFR 63 Subpart DDDDD) and the CISWI Definitions Rule (part of New Source Performance Standards, NSPS, 40 CFR 60 Subpart CCCC and Emission Guidelines, EG, 40 CFR 60 Subpart DDDD). EPA will use the test results to develop Maximum Achievable Control Technology (MACT) standards for boilers and heaters and rethink the CISWI rules. Test requirements vary among the facilities, but include tests for the HAPs and other parameters shown in the tables below. Note the use of extractive FTIR (EPA Method 320) for formaldehyde and potentially other measurements. Some units also are required to monitor CO, NOX, and SO2 continuously for 30 days. Fuels sampling and analysis is required for liquid solid fuels. Process operating data is required for all units. Details on the testing requirements can be found at http://www2.ergweb.com/projects/combustion/combustiontesting.html and http://www.epa.gov/ttn/emc/guidlnd.html (documents listed as GD-051, GD-051a, GD-051b, & GD-051c)

Also, on July 2, 2009 EPA announced plans for an ICR for survey information and emissions testing on oil- and coal-fired electric utility steam generating units (EGUs). Facilities would have 3 months to complete the survey and 6 months to complete testing after receiving the ICR letter, expected later this year. EPA estimates 1325 units at 555 facilities will need to respond. EPA is seeking comments on the ICR plans by August 31, 2009. Detailed HAP emission test requirements have not been announced thus far, but are expected to be substantial. See http://www.epa.gov/EPA-AIR/2009/July/Day-02/ for the Federal Register announcement.

Both of these ICRs stem in part from a court decision in 2008 remanding the Brick MACT rule to EPA on the grounds that EPA can not develop NESHAPs without appropriate emissions data. Several other MACT rules also are under reconsideration.

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