Conference speaker addresses MACT rules
David Minott, senior consultant for Environmental Resources Management, has a lot to say regarding the future repercussions of the U.S. EPA’s impending rulemaking on Maximum Achievable Control Technology provisions for biomass boilers. But most of what he has to say is nothing new to those following the rulemaking process.
Minott was joined by two other panelists during a session at the 2012 International Biomass Conference & Expo in Denver, Colo., April 16-19 titled, “Understanding and Complying with Increasingly Stringent Emissions Regulations.” During the session, each panelist provided updates on several emissions testing provisions. “No matter what type of biomass you use or where you use it, there is a regulation headed your way,”Minott said
Minott and fellow speaker Michael Readey, managing director for consulting firm AeriNOx Inc., view the MACT legislation as uncertain and unclear. Based on statutory evolution, judicial intervention and political objectives, the EPA hasn’t been able to create a feasible version of Boiler MACT provisions, Minott said. His presentation was fittingly titled “20 Years and 2,000 pages of Rulemaking in 20 minutes.”
Minott provided some useful reminders and planning objectives for those who could be affected. First, he explained, biomass facility operators need to understand which category their feedstock falls into. For clean biomass used as fuel, Boiler MACT will be the governing provision. For biomass that falls in the waste material category, it will be the Commercial and Industrial Solid Waste Incinerator (CISWI) rules. For utility coal boilers that co-fire biomass, the provision will be either Mercury and Toxic Standards or National Emissions Standards For Hazardous Air Pollutants. And for municipal solid waste feedstock, the applicable regulation provision will be the New Source Performance Standard.
To illustrate the importance of understanding which category a biomass feedstock falls into, Minott explained that a pulp and paper mill that uses residual scrap and saw dust to power a boiler would classify that biomass as clean fuel. But if that same mill collected that wood waste and transported for use at a furniture manufacturing facility, that biomass would be classified as waste material.
The Boiler MACT provisions are scheduled for release this month, and new boilers installed since June 2010 must comply upon startup. Existing biomass boiler users that classify their biomass as fuel have three years to comply, but a facility that classifies its biomass as a waste material has five years.
Until then, Minott said, a biomass user needs to first make the proper identification of its biomass. Then, the user needs to research possible emission control upgrades, and develop a cost plan for implementing any changes to help cope with risk sooner than later.