A-97-45
lll-B-1
tes
Environmental Protection
SEP i '
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-456/R-98-005
August 1998
OAQPS AIR
DOCKET CONTROL ROOM
FPA Municipal Waste Combustion:
Background Information Document for
Federal Plan
Public Comments and Responses
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 606C4-3590
-------
0106-00-002-002
MUNICIPAL WASTE COMBUSTION:
BACKGROUND INFORMATION DOCUMENT FOR FEDERAL PLAN
PUBLIC COMMENTS AND RESPONSES
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
'August 20,1998 ,
-------
TABLE OF CONTENTS
Section Page
1.0 LIST OF COMMENTERS 1-1
2.0 GENERAL 2-1
3.0 DEFINITION OF INCREMENTS 3-1
3.1 Final Control Plan Requirements 3-1
3.2 State Plan Process 3-3
3.3 Title V Permitting 3-4
4.0 COMPLIANCE SCHEDULES 4-1
4.1 Dates on the Generic Schedules 4-1
4.2 Delaying the Increment 1 Date 4-2
4.3 Options 1,2, and 3 4-3
4.4 Dates Already Achieved 4-5
4.5 Site-Specific Schedules 4-6
5.0 COMPLIANCE DEADLINE 5-1
5.1 1995 vs. 1997 Limits 5-1
5.2 Final Compliance Date 5-2
5.3 Timing for Performance Test ; 5-3
6.0 NO, TRADING 6-1
7.0 DIOXIN TESTING SCHEDULE 7-1
8.0 EMISSION LIMITS 8-1
8.1 Fugitive Ash 8-1
8.2 Sulfur Dioxide 8-1
9.0 MONITORING 9-1
9.1 Carbon Feed Rate 9-1
9.2 CEM Performance Specifications for CO :'. 9-2
10.0 OPERATOR TRAINING 10-1
10.1 State Operator Training 10-1
10.2 Stand-in Provisions 10-1
10.3 States' Authority 10-2
11.0 CONTINUOUS EMISSIONS MONITORING SYSTEM DATA 11-1
12.0 STATE PLAN INFORMATION 12-1
iii
-------
1.0 LIST OF COMMENTERS
A list of the commenters, their affiliations, and the U.S. Environmental Protection
Agency (EPA) docket number assigned to their correspondence is given in table 1-1.
TABLE 1-1. LIST OF COMMENTERS FOR MUNICIPAL WASTE
COMBUSTOR FEDERAL PLAN
Docket
Number Commenter and affiliation
IV-D-01 J. M. Daniel, Jr., P. E., DEE,
Director of Technical Support
Department of Environmental Quality
Commonwealth of Virginia
Richmond, VA
IV-D-02 J. B. Britton, Esq., Counsel
Verner, Liipfert, Bernhard, McPherson, and Hand
Washington, D.C.
(for Alexandria/Arlington Resource Recovery Facility)
IV-D-03 M. P. Tracey, Director of Engineering
Connecticut Resources Recovery Authority
Hartford, CT
IV-D-04 M. Bamett, Environmental Compliance Engineer
Southeastern Public Service Authority of Virginia
Chesapeake, VA
F/-D-05 M. Swanson, Senior Environmental Analyst
Northern States Power Company
Minneapolis, MN
IV-D-06 B. Mathur, Chief, Bureau of Air
Illinois Environmental Protection Agency
Springfield, EL
1-1
-------
TABLE 1-1. LIST OF COMMENTERS FOR MUNICIPAL WASTE
COMBUSTION FEDERAL PLAN
Docket
Number Commenter and affiliation
IV-G-05 R. D. Fletcher, Chief
Emissions Assessment Branch
California Environmental Protection Agency
Sacramento, CA
1-3
-------
2.0 GENERAL
Comment: One commenter (IV-G-02) stated that it is important that the Municipal
Waste Combustor Federal plan (40 CFR part 62, subpart FFF) maintain full consistency with
the individual State plans as they are completed, submitted, and revised so that owners and
operators of large municipal waste combustors (MWCs) in States with State regulations but
without approved State plans are not subject to fluctuating requirements between the Federal
plan and the subsequently approved State plan. The commenter encouraged EPA to
minimize conflicting requirements or compliance schedules for implementing the emission
guidelines. Two commenters (TV-G-05, IV-D-08/IV-G-05) supported EPA's options for
determining the incremental dates for site-specific compliance schedules. Both commenters
agreed that the options are a good way of ensuring consistency between State plans and the
Federal plan.
Response: The EPA agrees that the MWC Federal plan should be as consistent as
practical with State plans. Because the Federal plan is an interim action until a State plan is
approved, EPA designed the Federal plan to be consistent with the 40 CFR part 60, subparts
B and Cb requirements for State plans. The Federal plan contains the same required elements
as a State plan. To ensure a smooth transition from Federal plan to State plan, EPA requested
that States and owners and operators submit compliance schedules that were already
negotiated and agreed upon. During the comment period, several States submitted
compliance schedules (from State plans) to include in the Federal plan. Adding site-specific
schedules in the Federal plan ensures that owners and operators are progressing with their
retrofits and assures the Federal plan is as consistent as practical with State plans.
2-1
-------
3.0 DEFINITION OF INCREMENTS
3.1 Final Control Plan Requirements
Comment: Two commenters (IV-G-01, IV-D-05) believe that the requirements that
describe the final control plan are burdensome to facilities. One commenter (IV-D-05)
requested that EPA retain the "old" definition of final control plan. Several commenters
(IV-D-05, IV-D-09, IV-G-01, IV-G-04) stated that the final control plan requirements are not
consistent with what they envisioned while considering how to comply with 40 CFR part 60,
subparts B and Cb.
One commenter (TV-G-01) was specifically concerned with the requirements for
engineering specifications and drawings. To provide the level of detail for the final control
plan in the Federal plan, the commenter (IV-G-01) might have to prematurely make a
technology choice in order to submit the specifications and drawings before the final control
plan compliance date. The commenter (TV-G-01) noted that bid-level drawings are
extremely expensive and suggested that it may not be possible to provide the specifications
and drawings for a reasonable cost. Some MWC owners rely on in-house engineering staff,
particularly if the retrofits require modifications or replacement of existing components and
the staff may use only sketches or catalogue drawings to describe the necessary work. Some
MWC owners may rely on vendor documents, or have established relationships with
contractors and equipment suppliers where plans and specifications are never prepared. The
commenter (IV-G-01) specifically questioned the utility of the requirement to provide
engineering specifications and drawings, and questioned EPA's goal in making this
requirement.
Two commenters (IV-G-04, IV-D-09) contended that the Federal plan requirements
for a final control plan go well beyond the requirements specified in EPA's "Municipal
Waste Combustion: Summary of the Requirements for Section 11 l(d)/129 State Plans for
3-1
-------
3.2 State Plan Process
Comment: Two commenters (IV-G-01, IV-G-02) contended that the Federal plan
requirements would disrupt the State plan process to implement the emission guidelines.
One commenter (IV-G-02) requested that EPA modify the Federal plan so that the definitions
of final control plan and begin on-site construction are consistent with the State plan
guidance document (EPA-456R-96-003). The commenter (IV-G-02) noted that operators,
State agencies, and client communities have been planning capital improvements to be fully
compliant with the emission guidelines (as noted in the schedules they submitted and the
State's section 11 l(d) State plan) based on EPA's State plan guidance document. One
commenter (F/-D-05) noted that the compliance schedules they previously submitted were
not based on the Federal plan definition of final control plan.
One commenter (F/-D-09) noted that States that already have approved State plans
were held to the final control plan description in the State plan guidance document. The
commenter (F/-D-09) recommended that the State plan guidance document definition should
be incorporated into the Federal plan to ensure consistency between currently approved State
plans, the Federal plan, and State plans approved after promulgation of the Federal plan.
Consistency will avoid increasing the stringency of future State plan approval and
jeopardizing future State plan approvals, if plans did not incorporate the final control
requirements described in the Federal plan.
One commenter (TV-GT02) believes that if the Federal plan criteria for the increments
is adopted in the final Federal plan, the State implementation process would need to be
changed. Another commenter (IV-G-01) stated that the control plan requirements in the
Federal plan would complicate that transition from the Federal plan to a State plan. If these
requirements remain in the Federal plan, then facilities would be required to begin work on
them. For example, owners and operators of MWC facilities would begin preparing detailed
drawings and specifications even though the State plan does not have the same requirements.
The result will cause unnecessary expense and the potential for facilities to fail to meet some
requirements because of having two dissimilar sets of requirements.
Response: The EPA agrees that the Federal plan should be as consistent as practical
with State plans and EPA's State plan guidance document. As intended when the guidance
3-3
-------
source will use to comply with the emission limits and other requirements (see section 3.1).
Any technique that will meet the emission limits can be used.
3-5
-------
4.0 COMPLIANCE SCHEDULES
4.1 Dates on the Generic Schedules
Comment: Two commenters (IV-D-09, F/-G-04) requested that the increment 1
through 4 compliance dates should "float" relative to publication of the final rule in the
Federal Register (i.e., each date would be a certain number of months after publication in the
Federal Register) or float relative to issuance of any revised construction permits. The
commenters believe that floating the dates would provide facilities more flexibility
considering the late timing of the final Federal plan. States without approved plans would
have more time to submit their implementation plans or obtain EPA approval of permits.
Therefore, floating the dates would eliminate the potential for facilities to be in violation of
the generic Federal plan schedule while waiting for approval of the State plan or receipt of
State construction permits. One commenter (IV-G-04) contended that facilities may not meet
the incremental compliance dates because of circumstances beyond their control. A delay
would provide facilities more flexibility that will assist in achieving more timely compliance.
Two commenters (IV-D-09, IV-G-04) requested that if floating the dates is not an option,
then all dates should be delayed 6 months.
Response: The EPA maintains that the dates in the generic compliance schedule are
achievable for MWC facilities for several reasons: the generic schedule is based on actual
retrofits; owners and operators may submit site-specific alternative dates (with a justification)
if they wish to differ from the generic schedule; and owners and operators have received
adequate notice to begin retrofits. The EPA contends that facilities can meet the generic
compliance schedule in the Federal plan. The generic compliance schedule and increments of
progress are based on case studies of four MWC plants that either completed or are in the
process of completing retrofits. To develop a realistic generic schedule, EPA reviewed the
4-1
-------
Federal plan is published in the Federal Register. However, the overall generic compliance
schedule for the MWC Federal plan is not changing: MWC owners and operators subject to
the generic schedule are still bound by the final compliance date (increment 5) of
December 19,2000 and the dates for meeting increments 2 through 4 are still the same. In
addition, the EPA revised the Federal plan definition of final control plan to be consistent
with the State plan guidance document (see section 3.1). The revised control plan definition
and submittal date allow MWC owners and operators to meet the increment 1 date.
4.3 Options 1.2. and 3
Comment: One commenter (IV-G-05/IV-D-08), a State agency, supported option 2
(State submits alternative dates for increments 1,2,3, and 4) because it allows the Federal
plan to maintain consistency with the increments of progress that the local air pollution
control authorities have already established for each facility in the State. The commenter
stated that this option makes the most sense for the State since it allows each facility to have
a compliance schedule that is specifically tailored to its individual needs while still meeting
the statutory deadlines. The commenter (TV-G-05/IV-D-08) submitted compliance schedules
for two facilities in the State to be included in the final Federal plan. The commenter noted
that Including these schedules in the Federal plan allows the affected facilities to follow a
consistent compliance schedule that continues when the State plan is approved.
One commenter supported (IV-D-03) option 3 (State or owner or operator submits
alternative dates for increments 2, 3, and 4). The commenter noted that allowing MWC
owners or operators to define the increment dates ensures maximum flexibility and increases
regulatory efficiency without affecting human health or the environment. The commenter
claimed that it is essential that the Federal plan provide this flexibility so that the regulating
authority can follow its regular budgeting, procurement and construction procedures in a
manner that neither disrupts operation of the facilities under its control, nor imposes undue
hardships on the municipalities which are served by, and ultimately pay for the resource
recovery facilities in the State.
One commenter (IV-D-09) claimed that option 3 is not realistic since the time
required to receive alternative date approval may still put the facility in violation of the
Federal plan.
4-3
-------
In addition, the EPA contends that facilities can meet the increment 1 date for the
following reasons:
• Facilities have known about the emission guidelines since they were
promulgated in December 1995, and most have started planning their controls.
• Facilities have known about the generic increment date since proposal of the
Federal plan (1/23/98);
• EPA moved the compliance date back by at least 2 months from the proposed
increment 1 date; and
• EPA simplified the required content for the increment 1 final control plan.
Regarding the process and timing of EPA approval of alternative dates, the EPA will
review and approve or disapprove the alternative compliance dates in a timely manner. If a
State chose option 2 (State submits alternative dates for increments 1,2, 3, and 4 during the
comment period), the EPA reviewed schedules and approved or disapproved them prior to
adopting the Federal plan. Approved schedules are included in the adopted Federal plan. If a
• State or owner or operator chooses option 3 (State or owner or operator submits alternative
dates for increments 2,3, and 4 on or before the generic increment 1 date), EPA will review
the compliance schedule as quickly as possible. In order to facilitate EPA review, the site-
specific schedule requests should include a justification describing why the site-specific
schedule is needed and should show that the site-specific schedule will lead to achieving final
compliance no later than December 19,2000. The generic schedule will apply until a site- ;
specific schedule is approved. (See section 4.5 of this document and docket A-97-45, IV-A-1
for a discussion of EPA's review of compliance schedules.)
4.4 Dates Already Achieved
Comment: Two commenters (IV-D-09, IV-G-04) requested that EPA revise Table 6
of subpart FFF to show that the Westchester RESCO facility in Westchester County,
New York and the Baltimore RESCO facility in Baltimore, Maryland started retrofit
construction. The commenters noted that the increment 3 (start construction) dates for
Westchester (1/1/98) and Baltimore (4/1/98) will have passed before promulgation of the
4-5
-------
subpart Cb. The commenter (IV-D-02) noted that the proposed compliance schedule for
Alexandria/Arlington accelerated by 14 months the allowable final compliance date of
December 19, 2000. The commenter (IV-D-02) noted that the facility's operator intends to
retrofit all three combustion units in order to comply with 40 CFR part 60, subpart Cb. The
operator is physically unable to meet the proposed compliance date. The retrofit includes the
installation of scrubbers, baghouses, a carbon injection system, and systems for the control of
mercury and nitrogen oxides. The commenter (IV-D-02) noted that to accomplish such a
retrofit requires approximately two and a half years for the securing of financing, bidding for
equipment and construction contracts, procurement, and actual construction.
One commenter (IV-D-11) requested that EPA remove the site-specific compliance
schedule for the Savannah Energy Systems Company in Savannah, Georgia. The commenter
noted that the facility has proactively engaged in an accelerated program to install air
pollution control devices and implement process changes necessary to ensure compliance
with the emission, guidelines. For example, the facility has already installed a new
continuous monitoring system which was used for diagnostic purposes in selecting the
particular devices or process changes needed for compliance. They also recently completed
on-site construction of new spray dryer absorbers, baghouses, selective non-catalytic
reduction systems, and carbon injection systems for both MWC units at the facility. The
commenter believes that these new air pollution control systems are sufficiently complex that
a commitment to meet a deadline other than the statutory deadline of December 19,2000 is
not warranted.
Three commenters (IV-D-01, IV-G-02, IV-G-03) requested that EPA modify the
proposed compliance schedule for the 1-95 Energy/Resource Recovery Facility in Lorton,
Virginia. One commenter (TV-D-01) requested that EPA modify the schedule to
accommodate the construction schedules for the facility while still allowing Virginia to
comply with the emission reduction requirements of § 182(c)(2) of the Clean Air Act. All
three commenters provided the same schedule as follows: Increment 1 (March 1, 1999),
Increment 2 (October 15, 1999), Increment 3 (March 1, 2000), Increment 4 (November 19,
2000), and Increment 5 (December 19, 2000).
4-7
-------
the approved schedules are published in the final Federal plan. A detailed discussion of the
review is documented in a memo to the docket (A-97-45, IV-A-1). The EPA reviewed these
schedules for acceptability along with schedules previously received. In its review, EPA
considered the comments summarized above. The EPA determined a compliance schedule's
acceptability based on the following criteria: Does the schedule meet the final compliance
deadline of December 19, 2000? Does the schedule require 1 year to comply with the
mercury and dioxin limits for MWC units that commenced construction after June 26, 1987?
Does the schedule meet the revised generic increment 1 date? (See the response in section
4.3.) Are the increment 2, 3, and 4 dates earlier than or the same as the increment 2, 3, and 4
dates in the generic schedule? If any of the increment 1 through 4 dates were later than the
generic compliance schedule, EPA contacted the State and discussed any questions. The
EPA accepted dates later than the generic dates for increments 2,3, and 4, if the State
submitted a justification letter to explain why the increment 2,3, and 4 dates are later than
the generic compliance schedule. Note that this approach is consistent with option 3. Under
option 3 (State or owner or operator submits a site-specific compliance schedule on or before
the generic increment 1 date), the State or owner or operator must submit a justification for
an increment 2, 3, or 4 date that is later than the generic schedule in the Federal plan.
Acceptable compliance schedules are included hi the final Federal plan. Site-specific
compliance schedules that did not meet EPA's criteria or for which EPA did not receive a
justification letter are not included in the final Federal plan. Facilities without site-specific
compliance schedules are subject to the generic compliance schedule in the Federal plan until
a State plan is approved that includes those facilities.
The EPA removed the site-specific compliance schedules in the final plan for
facilities in Georgia, Minnesota, and New York because the State plans were approved.
MWC units covered by these State plans will follow the compliance schedule and other
requirements in the approved State plan.
The EPA did not include the site-specific schedule for the Tulsa Resource Recovery
Facility in Tulsa, Oklahoma; the Bristol Resource Facility in Bristol, Connecticut; and the
Mid-Connecticut Resource Recovery Facility in Hartford, Connecticut because these
schedules were submitted by an owner/operator under option 2. Only States may submit
4-9
-------
5.0 COMPLIANCE DEADLINE
5.1 1995 vs. 1997 Limits
Comment: One commenter (IV-D-05) requested that EPA keep the staggered
compliance schedule for sulfur dioxide, hydrogen chloride, lead, and nitrogen oxides. The
commenter pointed out that the 1997 amendments to 40 CFR part 60, subparts Cb and Eb,
require staggered compliance with the emission limits for sulfur dioxide, hydrogen chloride,
lead, and nitrogen oxides: December 1995 limits by December 19, 2000 and August 1997
limits by August 25,2002. The commenter believes that compliance with the limits should
remain staggered, rather than requiring the more strict standards earlier. The commenter
noted that although it may require the same equipment to meet both the year 2000
requirements and the year 2002 requirements, from an operational perspective, there may be a
significant cost associated with requiring the more strict standards earlier. The commenter
did not provide further information.
Response: The final Federal plan requires compliance with all limits by
December 19,2000. The same types of air pollution control technology that served as the
basis for the 1995 limits achieved the 1997 amended limits: spray dryer/fabric filter or
electrostatic precipitator (ESP), carbon injection, and selective non-catalytic reduction
(SNCR) for non-refractory combustor types. Large MWC units would need to install these
controls by December 19, 2000 to meet the original 1995 limits. As soon as the controls are
installed, they will also meet the final, amended 1997 limits. The EPA's test data used to
develop the emission guidelines shows that these controls reduce emission levels to well
below the 1995 and 1997 limits (dockets A-89-08, A-90-45). The 1997 limits are only
slightly different than the 1995 limits and would neither require major operational changes
nor significantly increase costs. The commenters were not able to provide any specific
5-1
-------
promulgation. Compliance for the remaining pollutants and associated monitoring must be
achieved by December 19, 2000.
5.3 Timing for Performance Test
Comment: One commenter (IV-G-01) contended that the last sentence in 40 CFR
62.14108(a)(5) could be interpreted to say a facility can be out of compliance during the
180 days between the final compliance date and the performance test.
Section 62.14108(a)(5) says "On and after the date the initial performance test is completed
or is required to be completed, whichever is earlier, no pollutant may be discharged into the
atmosphere from an affected facility in excess of the emission limits of this subpart." The
commenter requested that EPA edit 40 CFR 62.14108(a)(5) to clarify that facilities may not
be out of compliance during the 180 days after installation of equipment. The commenter
cited section 129(b)(2) of the Clean Air Act, which says that units must be in compliance
with requirements no later than 5 years after promulgation of the emission guidelines.
However, the commenter believes it is appropriate to allow up to 180 days after installation
of equipment for performance testing (as is granted in New Source Review and New Source
Performance Standards). The commenter pointed out that 40 CFR 62.14108(a)(5.) could
cause debate between States and affected facilities of exactly when facilities are supposed to
be in compliance.
Response: The EPA maintains that if a facility has retrofitted all air pollution control
equipment and the equipment is operating as designed, then the facility has reached
compliance and should meet all emission limits. As defined in § 62.14108(a)(5), by the final
compliance date, a facility must have incorporated all process changes or completed retrofit
construction as designed in the final control plan and connected the air pollution control
equipment or process changes with the affected facility identified in the final control plan
such that if the affected facility is brought on line, all necessary process changes or air
pollution control equipment are operating fully. The EPA maintains that facilities meeting
this definition will produce emissions well below the emission limits in the Federal plan.
Consistent with section 129(b)(2) of the Clean Air Act, the MWC Federal plan requires final
compliance by December 19, 2000, which is five years after promulgation of the emission
guidelines.
5-3
-------
6.0 NOX TRADING
Comment: One commenter (IV-D-03) requested that EPA include a provision to
allow States that currently have active NOX trading programs to continue to trade under these
programs until their State plans are approved. The commenter (IV-D-03) strongly supports
EPA's decision to allow States to establish programs to allow owners or operators of existing
MWC units to trade NOX emission credits. The commenter stated that EPA's proposed
requirement for the State and EPA to approve NOX trading programs on a case-by-case basis
is time consuming and unnecessary. The commenter believes that it is in the best interest of
EPA, the State, and the commenter to avoid the administrative burden and expense of
preparing, finalizing, and approving new trading agreements and orders on a caserby-case
basis for each of the MWC units.
The commenter (IV-D-03) requested that the Federal plan should be the mechanism
to assure that the NOx trading can continue if the State plan is not approved by May 1, 1999.
The commenter (IV-D-03) noted that the MWC units in Connecticut currently have Trading
Agreements and Orders that have been issued by the Connecticut Department of
Environmental Protection. The Trading Orders were also approved by EPA as part of the
State Implementation Plan (SIP) revision submitted by the State (62 FR 52016, October 6,
1997). Connecticut's State plan that will be submitted by the State will include a program to
codify the trading concepts included in the Agreements and Orders. Since the existing
Trading Agreements and Orders remain in effect only until May 1, 1999, the commenter
requested that the Federal plan allow NOX trading in case the Connecticut State plan is not
approved by May 1, 1999.
Response: The EPA has reviewed Connecticut's existing Trading Agreements and
Orders and has included them in the Federal plan. However, EPA has not included a
6-1
-------
Response: The EPA agrees to allow any New Jersey facility intending to comply with
the NOX emission limits by use of NOX trading to reserve the NOX portion of the final control
plan as described above because EPA supports open market concepts, including trading,
especially when they can be harnessed to achieve environmental limits, minimize costs, and
EPA can ensure the technical validity and track the parameters of the trade. The reserved
NOX portions of the control plans must be submitted by December 15, 1999. New Jersey will
need to promptly amend and submit their OMET program to EPA in order to allow sufficient
time (approximately 12 months) for EPA to review the program and follow the necessary
administrative procedures, including proposal and promulgation notices in the
Federal Register. The final compliance date for NOX remains December 19, 2000. Also,
there is no guarantee that owners and operators will be able to rely on OMET to meet the
NOX emission limits. MWC owners and operators subject to the Federal plan must decide the
best means of reaching final compliance by December 19,2000.
6-3
-------
7.0 DIOXIN TESTING SCHEDULE
Comment: One commenter (F/-D-04) requested that EPA revise the schedule for the
alternative dioxin testing to allow testing of one unit each calendar year, rather than testing of
a unit within 12 months of the previous test. The commenter operates four MWC units at a
single MWC plant. Each year, the facility is required by law to shut down and inspect each
of the four units, perform maintenance, and conduct stack testing. To accommodate these
requirements, their current schedule is to test Units 1 and 3 in October and test Units 2 and 4
in April. The plant has already tested all four units for 2 consecutive years and all four units
achieved dioxin levels less than 15 nanograms per dry standard cubic meter (ng/dscm),
qualifying the plant for alternative (reduced) dioxin testing under 40 CFR 62.14109 of
subpart FFF. With their current maintenance/testing schedule, the "not more than 12 months
following the previous performance test" interval in the proposed Federal plan is problematic.
For example, if the facility tests Unit 1 in October (including a dioxin test), their next
scheduled test (if the commenter tests the units in order -1,2, 3, then 4) for Unit 2 would be
in April (6 months later). The commenter contends that in order to meet the "no more than
12 months" requirement, the facility would have to test a unit each 6 months. The current
commenter believes that this runs counter to EPA's intent when the alternative testing
scenario was allowed, the intent being to reduce the cost of stack testing required of facilities
that have minimized their dioxin emissions.
Response: The commenter notes, and EPA confirms, the MWC plant in question
achieves low dioxin emissions (less than 15 ng/dscm) and the MWC plant qualifies for the
alternative (reduced) dioxin testing schedule under 40 CFR 62.14109(d). The current
maintenance/testing schedule selected by the MWC facility does not result in a 12-month
interval between maintenance of all four units. Because a full 12-month interval does not
7-1
-------
8.0 EMISSION LIMITS
8.1 Fugitive Ash
Commenter: One commenter (IV-G-02) requested that EPA identify additional
maintenance activities for exemption from the fugitive ash emission standard. (The
commenter refers to the fugitive ash emission standards in 40 CFR 60.55b of subpart Eb,
which are the same as the fugitive ash standards in the MWC Federal plan, 40 CFR 62.14106
of subpart FFF.) The commenter noted that the fugitive ash emission standard includes a
specific exemption when the ash handling equipment is off-line (not operating) for
maintenance. Because this standard specifically applies to emissions discharged from
buildings and enclosures of ash conveying systems during facility operations, the commenter
suggested that periods of time when the MWC boiler is not operating also should be exempt
because emissions will occur through the boiler door during cleaning.
Response: The EPA notes that the fugitive ash emission standards apply only to "ash
conveyance systems." Because the boiler doors are part of the boiler and are not part of the
ash conveying system, the fugitive ash standard would not apply to the boiler doors.
Furthermore, the emission limits for the boiler exhaust do not apply when the boiler is not
operating.
8.2 Sulfur Dioxide
Comment: Three commenters (IV-D-05, F/-D-10, F/-D-04) noticed an error in
Table 4 of the preamble. Compliance with the sulfur dioxide emission limit should be
29 ppm or 75 percent removal, not 80 percent removal. Seventy-five percent removal is
consistent with the amendments to 40 CFR part 60, subpart Cb, published in the Federal
Register on August 25, 1997 (62 FR 45116).
8-1
-------
9.0 MONITORING
9.1 Carbon Feed Rate
Comment: Two commenters (IV-D-09, IV-G-04) requested a clarification on whether
short term dips or temporary interruptions in carbon feed rates would be considered
violations of 40 CFR 60.58b(m)(2). Examples of such interruptions would be when the
carbon injection system is not operating for calibration, maintenance, malfunction, or other
unavoidable conditions. The commenters suggested that quarterly carbon estimates are the
appropriate method for determining continuous compliance with the carbon feed levels
established during performance tests.
Response: The EPA determined that interruptions in operation of the carbon injection
system are not automatically violations because the carbon injection feed rate established
during the performance test is not an instantaneous average. The baseline carbon feed rate is
the average feed rate during the mercury (or dioxin) performance test. To determine
compliance, this average carbon feed rate is compared to the average carbon feed rate during
subsequent MWC operations; an instantaneous average is not used. For example, if a large
MWC unit is equipped with carbon injection and a performance test is conducted, the
performance test would take about 8 hours and the carbon feed during the test would be about
15 pounds. The carbon injection rate over the 8-hour period would average 1.9 pounds per
hour (15/8=1.9). During subsequent MWC operations, 15 pounds of carbon should be
injected during each 8-hour operating period and would average 1.9 pounds per hour. If the
screw feeder for the carbon injection system has to be taken off line for calibration for two
hours, the carbon that is not injected during the downtime must be injected after restart.
Therefore, 15 pounds of carbon would be injected during the remaining 6 hours of operation
in the 8-hour period resulting in the same 1.9 pound per hour average feed rate over the
9-1
-------
These changes to PS 4A would address the concerns raised by the cornmenter while still
retaining the response time specifications requirements. In addition to these changes, EPA
also intends to amend PS 4A to define relative accuracy in terms of a percentage of the
applicable emission standard in addition to the current options to use 10 percent of the mean
value of the reference method test data or 5 ppm. The EPA is in the process of amending and
reformatting a number of test methods to make technical corrections, including these to
PS 4A. The EPA expects to promulgate these amendments in the fall of 1998.
9-3
-------
10.0 OPERATOR TRAINING
10.1 State Operator Training
Commenter: One commenter (IV-G-01) submitted the State's current rule regarding
operator training and certification. The commenter also enclosed a proposed State rule
incorporating Federal requirements for full certification of operators. The proposed rule is
scheduled to become effective May 4,1998. Minnesota has developed waste combustor
training and has adopted examination and certification rules for waste combustor operators.
Operators of large.MWCs in Minnesota have chosen to obtain State certification rather than
ASME certification.
Response: The EPA emission guidelines allow for State operator training, and State
certification as alternatives to the EPA training course and ASME certification. Because
Minnesota has developed these programs, the final Federal plan will allow State operator
training and State certification for MWCs in Minnesota. The Federal plan also allows State
operator training in Connecticut and State certification in Connecticut and Maryland.
10.2 Stand-in Provisions
Comment: One commenter (TV-G-02) requested that EPA develop guidance to
identify certain circumstances where a provisionally certified shift supervisor may fill in for a
fully certified operator. (The commenter cites 40 CFR 60.54b of subpart Eb, which is cross-
referenced in both the emission guidelines [40 CFR part 60, subpart Cb] and the Federal plan
[40 CFR part 62, subpart FFF].) Such circumstances might include vacation, sick leave,
medical leave, family leave, training and miscellaneous employment issues covering hiring,
firing, promoting, retiring and transferring employees.
Response: The EPA addressed questions about circumstances where a provisionally
certified shift supervisor may fill in for a fully certified operator in a May 14, 1998 Guidance
10-1
-------
11.0 CONTINUOUS EMISSIONS MONITORING SYSTEM DATA
Comment: The commenter (F/-G-02) addressed the emission guidelines
(40 CFR part 60, subpart Cb), not the Federal plan (40 CFR part 62, subpart FFF) and
requested clarification on § 60.58b(e)(8). (Section 62.14109 of the MWC Federal plan cross
references § 60.58b(e)(8) of the emission guidelines.) The commenter believes
§ 60.58b(e)(8) was intended to establish a certain minimum data collection requirement
(75 percent). This 75 percent standard does not adequately address a 4-hour standard such as
applied to carbon monoxide (CO). Also, the commenter believes the rule could be
interpreted to mean that a single valid data point could represent any reporting period
including daily averages. The commenter proposed that the 75 percent standard apply to any
discrete reporting period.
Response: For pollutants measured by Continuous Emissions Monitoring Systems
(CEMS), including CO, there are two separate requirements: (1) an emission limit, and (2) a
minimum data collection requirement. The intent of the emission limit requirement is to
assure that emissions do not exceed the emission limit. The intent of the minimum data
collection requirement is to ensure that the CEM is properly and continuously operated.
These separate requirements are further described below to provide clarification of the CEMS
requirements. No changes are being made to the Federal plan.
For CO, compliance with the emission limit is based on 4-hour or 24-hour block
averages, depending on combustor type, as specified in § 60.58b(i)(l) and (2). The 4-hour or
24-hour average is calculated as the average of 1-hour arithmetic averages. As specified in
§ 60.58b(i)(4), the 1-hour arithmetic averages are calculated using the data points generated
by the CEMS, and at least two data points must be used to calculate each 1-hour average. All
valid data measured during each 4-hour or 24-hour period is used to determine compliance,
11-1
-------
12.0 STATE PLAN INFORMATION
Comment: Several commenters (IV-D-06, F/-D-08/IV-G-05, IV-D-07, IV-D-10)
representing State agencies provided updates on the status of their State plan submittals. One
commenter (IV-D-06) requested that EPA change the status of Illinois in the Federal plan.
The commenter, the State agency, submitted its State plan for large MWCs on June 23, 1997.
On December 29, 1997, the EPA approved the Illinois State plan through a direct final
rulemaking (62 FR 67570). The EPA received no adverse comments and the State plan
became effective on February 27, 1998. One commenter (W-D-07), the Ohio EPA,
documented that they have not submitted a negative declaration letter. The commenter
enclosed a copy of a consent order that requires the two MWC facilities in the State to meet
the requirements of 40 CFR 60, subpart Cb before being resurrected. Two commenters
(IV-D-OS/IV-G-OS, IV-D-10) representing State agencies provided current annual emissions
for-their States.
Response: The promulgated Federal plan must apply to all States that do not have an
approved State plan in order to assure that all MWCs meet the emission guidelines. When a
State plan is approved, the Federal plan will no longer apply. Prior to promulgation, the EPA
approved the State plans for Florida, Georgia, Illinois, Minnesota, New York, Oregon, South
Carolina and Tennessee. MWC units covered in the approved State plans are listed in the
exclusion table in subpart FFF. The exclusion table is provided as a matter of convenience
and is not controlling in determining whether a large unit is subject to the Federal plan. As
State plans are approved, EPA will periodically amend the exclusion table in § 62.14102 of
subpart FFF to identify MWC units covered in EPA approved and currently effective State
plans. The emissions data submitted by the commenters is available in the comment letters in
docket A-97-45.
12-1
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse be fort completing)
REPORT NO.
EPA 456/R-98-005
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Municipal Waste Combustion
Background Information Document For Federal Plan
Public Comments and Responses
5. REPORT DATE
5. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Julie McClintock, ITPID, OAQPS
B. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
dAQPS (MD-12)
411 W. Chapel Hill St.,
Durham, N. C. 27701
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
411 W. Chapel Hill St.,
Durham, N. C. 27701
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
This document addresses the comments raised during the comment period for
the Federal Plan Proposal for the Large Municipal Waste Combustors. The
rule was adopted November 12, 1998.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Fidd/ClOUp
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tliis Report)
21. NO. OF PAGES
20. SECURITY CLASS (Tinspage)
22. PRICE
EPA Fofm 2220-1 (R«». 4-77) PREVIOUS EDITION is OBSOLETE
------- |