Boiler Work Group Meeting October 30, 1997 DISCUSSION & DECISIONS • Jim Eddinger presented a completed milestone tracking timeline to be sent to the Coordinating Committee Milestone Tracking Committee. The Boiler Work Group concurred with the dates and descriptions incorporated in the table. • The Work Group discussed a more detailed schedule for completing milestones prepared by EPA. Members suggested a few changes to the dates, but generally concurred with the dates for preliminary analyses. EPA and ERG will revise the detailed timeline and provide the revised copy to the Work Group. • Ruth Mead from ERG updated the Work Group on the status of the ICR survey. Ms. Mead indicated that the scanning company would provide information in late November, and version 2.0 of the ICR survey responses database would be released in December. • Jim Eddinger updated the Work Group on the solid waste definition subgroup meetings. Mr. Eddinger indicated that the subgroup had agreed that fuels used for energy recovery are not solid wastes. Mr. Eddinger indicated that two more meetings would be held before the Coordinating Committee meeting, and a recommendation would be made at the November Coordinating Committee meeting. • After subgroup meetings, the Work Group re-convened to discuss progress in the subgroup meetings (see subgroup meeting notes for more detail). The Work Group did not reach consensus on a preliminary list of priority HAPs, and agreed that further discussion and rationale would be needed for excluding/including specific pollutants. • The Work Group discussed pollution prevention, but determined that more information is needed on activities that have been done or are being implemented before the Work Group can fully discuss this issue. Alex Johnson, John deRuyter, Coleman Kavanaugh, and Kim Davis volunteered to gather this information. • The Work Group discussed which subgroup should handle developing subcategories and model plants for units that are co-fired. The Work Group agreed that co-fired units firing non-fossil fuel would be dealt with by the non-fossil subgroup, and co-fired units firing fossil and wood only would be dealt with by the wood subgroup. ACTION ITEMS • EPA and ERG will revise the detailed milestone schedule as per the Work Groups comments and put these on the TTN. ab\ S:\ICCR\TTN\TTNFILES\BO30OC7S.WP6 1 ------- Alex Johnson, John deRuyter, Coleman Kavanaugh, and Kim Davis volunteered to gather pollution prevention information for the Work Group to consider when developing the standard. NEXT MEETING The next meeting will be held in Houston, Texas on November 20 in conjunction with the Coordinating Committee meeting. Agenda items include discussion of model plants, compounds of interest, pollution prevention, and co-fired units. ab\ S:\ICCR\TTN\TTNFILES\BO30OC7S.WP6 2 ------- FOSSIL FUEL SUBGROUP MEETING (October 30, 1997) Attendees Christy Presson MarkBryson Stanley B. Carter Gerald Doddington John deRuyter Jim Eddinger Bill Freeman Alex Johnson Virendra Trivedi Gunseli Sagun Shareef Discussions and Decisions • Initial draft of the protocol for determination of HAPs of concern, flowsheet of the procedure, and initial natural gas HAP list were reviewed. It was noted that the initial list will need refinement, and documentation will be developed regarding reasons for HAP elimination from the list. Initial lists will be prepared for oil and coal- to be available for the 11/97 meeting. • The EPA 112(k) list of HAP emissions was discussed, especially relative to the low total emissions of specific pollutants from all gas fired industrial boilers. • The relationship of the Urban Air Toxics initiative to the ICCR process was discussed. Other initiatives are relying on the ICCR to satisfy coverage of certain sources. • Model boilers were discussed. Tables of existing EPA model boilers were reviewed and modifications made. Further detail will be added to the list; Jim Eddinger will see if the Alternative Control Techniques Document for NOx includes additional data which can be used for the model boilers in order to minimize new work. Fuel variations will need to be applied to the model boilers as appropriate. • John deRuyter will start a list of control techniques, attempting to be broad and inclusive at this point. Information on the impact of coal cleaning on HAP emissions will be distributed to the group. Jim Eddinger will provide information on good combustion practices from the municipal waste combustors (MWC) regulations. Alex Johnson will provide information on other methods. Any other subgroup members that have input on control techniques should contact John deRuyter before the next meeting in Houston. • The subgroup will request that John Fanning, a Coordinating Committee member, provide his advice on good combustion practices and operator training to the subgroup for consideration of control techniques. ab\ S:\ICCR\TTN\TTNFILES\BO30OC7S.WP6 3 ------- • The utility HAP report will be reviewed by Alex Johnson and Mark Bryson regarding risk analysis. It is recognized that the approach may be difficult to apply to smaller industrial sources. Action Items • Jim Eddinger will pull together gas composition data along with DOE/EIA energy consumption data to develop some estimates of potential HAP emissions. • The Western States Petroleum Association/California Air Resources Board (WSPA/CARB) data summary report is to be issued soon. Bill Freeman is to determine the status of that report and provide a copy as soon as available. • Jim Eddinger will check on the EPA PBT list. • Jim Eddinger will see if the Alternative Control Techniques Document for NOx includes additional data which can be used for the model boilers in order to minimize new work. • Jim Eddinger will provide information on good combustion practices from the MWC regulations. Alex Johnson will provide information on other methods. • Mark Bryson will look at the EPA utility HAP study to determine if it contains model plants that would be helpful to the ICCR process. • EPA and ERG will determine the hierarchy of the percent contribution of different ICCR source classificantion codes (SCCs) to the emissions of 112(k) pollutants using the 112(k) emission estimate report as a basis. • The latest summary of state HAP limits is to be provided to the Fossil Subgroup. Next Meeting The next Fossil Fuel subgroup meeting is scheduled for November 20. ab\ S:\ICCR\TTN\TTNFILES\BO30OC7S.WP6 4 ------- NON-FOSSIL FUEL SUBGROUP MEETING (October 30, 1997) Attendees Roy Oommen Todd Barker Coleman Kavanaugh Kerry Kelly John Pinkerton John Serumgard Paul Tucker Discussions and Decisions • The subgroup discussed preliminary model plants presented by Paul Tucker and Catherine Beahm from previous EPA studies and regulations. The subgroup concurred that members representing an industry would develop model plants using the EPA model plants as a basis. The subgroup agreed that the model plants should include the following information: fuel type, combustor type, boiler type, heat input (MMBtu/hr [ < 10, 10-50, 50-150, 150-250, and >250]), air pollution control (particulate, acid gas, NOx removal, or other), rationale for developing the model plant, and facility ID if correlating to an actual unit. • The subgroup discussed the preliminary list of HAPs to focus on developed by Jim Stumbar. Members suggested a few changes, but generally concurred with the list as the minimum number to initially focus on. • Jim Stumbar reviewed suggested subcategorization schemes based on boiler design and fuel provided at previous meetings. The subgroup agreed that members representing an industry would develop preliminary subcategories and provide those to Jim Stumbar to compile. Action Items • The subgroup requested that EPA and ERG run sorts on the ICR survey database in order to determine which non-fossil fuels are the most predominant. • Members of subgroup are to provide Paul Tucker and Catherine Beahm with their model plants on or before November 12 in a lotus compatible file. EPA and ERG will contact members not at the meeting to inform them of the subgroup's directions. • The subgroup requested that EPA provide a list of polynuclear aromatic hydrocarbons (PAH's) and poly cyclic organic compounds (POM's). • Paul Tucker and David Marrack volunteered to work with ERG and EPA in developing a list of control technologies for the next subgroup meeting. Catherine Beahm Tim McGrath Jim Stumbar David Cooper Davaid Marrack Prakasam Tata ab\ S:\ICCR\TTN\TTNFILES\BO30OC7S.WP6 5 ------- • Subgroup members are to provide subcategories for their industries to Jim Stumbar on or before November 12. EPA and ERG will contact members not at the meeting to inform them of the subgroup's directions. Next Meeting • The next Non-Fossil Fuel subgroup meeting is scheduled for November 20. ab\ S:\ICCR\TTN\TTNFILES\BO30OC7S.WP6 6 ------- WOOD SUBGROUP MEETING (Afternoon of May 22, 1997) Attendees Bob Palzer Delbert Cline Kim Davis Greg Gesell Discussion and Decisions Members of the wood subgroup met one week previous to the Work Group meeting. Members that attended the work group meeting continued discussion of subcategories, model plants, and pollution prevention. • The members decided to initially subcategorize by boiler type and grate system, and wood type (dry wood vs wet wood). • The wood subgroup reviewed the list of HAPs of interest provided to the Work Group at the September meeting. The review reduced the number of HAPs that the wood subgroup considered to be emitted from wood burning boilers. • The wood subgroup discussed pollution prevention, good combustion practices, and types of control devices found on wood fired boilers. The members concurred that additional discussion was needed. The members also requested that EPA provide available emissions data in order to identify cut-offs and effectively develop model plants and MACT floors. Action Items None Next Meeting The next wood Subgroup meeting is scheduled for November 20. ab\ S:\ICCR\TTN\TTNFILES\BO30OC7S.WP6 7 ------- ATTACHMENT Full Work Group Attendance List Todd Barker Catherine Beahm Mark Bryson Stanley Carter Delbert Cline David Cooper Kim Davis Jon Devine John deRuyter Gerald Doddington Jim Eddinger Bill Freeman Greg Gesell Alex Johnson Coleman Kavanaugh Kerry Kelly David Marrack Tom McGrath Ruth Mead Roy Oommen Bob Palzer John Pinkerton Christy Presson John Serumgard Gunseli Shareef James Stumbar Prakasam Tata Virendra Trivendi Paul Tucker Edwin Weaver ------- |