Commenter
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Category
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Comments
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ACC
AF&PA
CIBO
Occidental
Alexander Baldwin
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Cost Estimates
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Missing Costs
Steam loss
(many units never operate at maximum rate)
Cost to shut
one boiler down and purchase electricity
Capital and
Start-up costs associated with constructing ports, platforms and
duct configuration, outages. CAMR rule ICR emphasized no
capital/start-up costs which is not true in this ICR.
Collecting
data on fuel feed rates, control device operating parameters
(every 15 min.), opacity readings, CEMS data (assume full time
staff person throughout test period)
Feedback and
revisions on pre and post test reports
State/Local/Federal
Agency attending random tests
Standby
maintenance worker and process engineer, assuming overtime for 2
to 3 hours per day
If required to
conduct inlet testing, or if facility doesn’t have
accessible ports:
Pre-test
(most will not meet Method 1 requirements); $6,200
If source
must create a port, $1,500 for scaffolding and $2,250 for
cutting the port
Waivers for
test methods
May require
spike with known pollutant quantities, similar to cost of
hazardous waste trial burns
Rush orders
from testing lab, due to short schedule
Underestimated
Costs
Labor: 8-hour
work day should be 10 to 12 hours
Outlet testing
only for PCDD/PCDF/PAH, metals, PM, HCl = $225,000
Analytical
work for organic test methods estimated at $100,000 per test,
plus labor for 6 to 8 people if all pollutants are tested for.
$33,500 is low
compared to 2006 costs of inlet/outlet testing on two coal
boilers
Estimate
$100,000 if both traditional and Section 129 pollutants must be
tested for
$150,000
compliance test for vacated DDDDD standard for both boiler
stacks. The $150,000 did not include tests for non-MACT
pollutants.
$30,000-50,000
for PM and CO testing only; 100 technical hours, 5 management, 3
legal
$100,000 if
you include additional tests; $160,000 - $170,000 if you require
paired sampling
Cost to secure
a vendor(s) is increased when you have multiple emissions tests
Fuel sampling
should be 20 min/test run not 30 minutes total
Fuel analyses
should include costs for HHV, S%, ash, moisture in addition to
listed analyses
Dioxin/Furan
testing could exceed $100,000, an order of magnitude above the
$5,000. Precise estimate was not given
For facilities without automatic data
recorders/trenders, additional labor needed to gather and
aggregate data after the test.
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ACC
Occidental
Florida Sugar
CIBO
Amp-Ohio
NACAA
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Criteria for Selecting Test Sites
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Only test
at facilities with units that have emission data gaps
Consider
presence, accessibility of stack test ports, inlet duct
dimensions, and locations and feasibility/safety of test at a
certain site. ACC states not to ask for this data in the
questionnaire component, as it would add significant cost.
Instead let the smaller subset of potential test sites submit
this data to EPA. Amp-Ohio requests that EPA include a question
on available access points in the questionnaire.
Exclude units
that are scheduled for shutdown
Exclude units
that were already tested to support compliance with vacated
standard
Common Stacks
A certain
portion of tests should be dedicated to identifying a
correlation between HAP emissions and HAP surrogates used in the
vacated standard.
Limit testing to 2 random plants owned by
any single entity (large or small)
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AF&PA
CIBO
Amp-Ohio
NACAA
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De-couple survey from testing component of the ICR.
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ACC
CIBO
Occidental
Amp-Ohio
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Incentives/Competitive Edge
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If a facility is selected or volunteers for a stack test:
Exempt from
another performance test to demonstrate compliance if test met
final standard
Opt out of
testing if facility’s test cost estimate exceeds EPA’s
cost estimate by XX%
EPA funded
test program for small entities
EPA funded
program or method to spreading the costs among all potentially
affected sources
Waive all or
part of compliance test with new rule
Enforcement
discretion
Certified
compliance status for a certain amount of time
Number of tests should be proportional to
the size of the business
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AF&PA
ACC
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Need for new data
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ACC
FL Sugar
CIBO
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Need for Paired Testing (Inlet/Outlet)
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Identify
where outlet only is sufficient.
Inlet is only
applicable for semivolatile trains
Inlet is
unneccessary and overly burdensome. MACT is based on controlled
emissions, not % reductions.
Request to explain the need for inlet
testing.
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AF&PA
CIBO
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Pollutants to be Tested For (What)
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Should test
for HAP or potential surrogates for HAP
Should test
for 129 pollutants only when a potential waste material is
combusted
Why are you
testing for CO2 and O2? Using current rationale of combustion
efficiency, CO2 and O2 should be tested for at the burner
instead of the stack. Additional CO2 and O2 measurements at full
capacity stack tests are not indicative of normal operation.
Specify the
number and types of tests required for each strata
Should justify and limit testing for HCB
and PCB to non-fossil fuels only
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CIBO
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QAPP
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Does the
generic QAPP have to go to OMB for approval along with the other
ICR components?
Request for
EPA to specify a QAPP modification process with deadlines for
response and resolution of disagreements.
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AF&PA
ACC
CIBO
Amp-Ohio
FL Sugar
Alexander Baldwin
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Schedule
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Schedule unrealistic too short
Request 180
days for test
Request waiver
for 60 days if sources already have scheduled shutdowns,
changeovers
Request
revised timeframe and systematic process for identifying
seasonally-operated units
Request 120
days for test – must go through public procurement process
to select test company
Request 6
months (especially for seasonal units)
60 days is
impossible for seasonal or normal operating units
Nationally,
only 20 test firms with enough resources to do tests, less than
5 of these have capability to do semivolatile trains
CAMR ICR was 3
tests over 1-year period for mercury only. Boiler ICR is
multi-pollutant in 60 days.
State/Local
oversight required in some areas for testing. Minimum notice
prior to testing is required. Indiana: 35 days. Other states 60
days.
Test timeline:
Stack test contractor 2 months prior to test, test notification
sent to EPA 30 days before test, conduct test, 21-30 days
analysis, 7 to 14 day review. Request 60 days to submit test
report from time test is complete. Request 120 day minimum, 6
month maximum.
Request
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AF&PA
CIBO
ACC
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Solid Waste Definition
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Solid Waste Definition proposal should come before units are
required to test; ideally the definition should be promulgated.
If not possible:
Allow for
opt-out if a ceases to burn possible waste material in order to
avoid compliance costs associated with 129 compared with 112.
Process to opt-out could include a trade-off analysis of fuel
cost, testing cost, 129 compliance cost.
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AF&PA
FL Sugar
CIBO
ACC
NACAA
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Strata/Sample Design
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Number of
facilities required to test should be a function of the number
of unit subcategories EPA anticipates
Strata should
include combustor type, size, and fuel. Note that within a
multi-fuel category the blends can have a very large range.
Add a strata
category “coal/wood/NFF liquid/NFFsolid/FF liquid”
Sample size
should be identified according to units within each strata, not
on entire boiler population
Selection
should not be random. Industry will assist in identifying
statistically significant pools of units that meet specific
criteria. Industry agrees that they will not self select
individual units.
Define strata
prior to test program
Maintain a
random selection of test sites to avoid industry-self selection
Clearly indicate items that the Agency
anticipates may need to be modified after the Phase I survey
results are analyzed.
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CIBO
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Submitting Test Data
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Do not use the Electronic Reporting Tool (ERT) for submitting
test data. Currently undergoing beta testing and industry finds
it inaccessible, and not user-friendly.
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AF&PA
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Test Plan
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Request
that the tests are done at 3 common operation conditions, spaced
over two or more weeks, for each unit tested. Cited Brick MACT
decision and EPA’s authority to look at intra-unit
variability.
Request that EPA develop a HAP testing
plan as it has done for CISWI units
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ACC
Occidental
Amp-Ohio
NACAA and NDRC
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Types of Sources to be Tested For (Authority/Justification)
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EPA has
authority to request for stack test data from 112 units. Noted
the minimum amount of data: at least five data sources for small
subcategories (<30 sources). Implies that it must have at
least five data sources for small, then additional data sources
would be justified for larger subcategories. Also listed
explicit authority under Section 114.
EPA should test units that were modified
to attain compliance with the vacated Boiler MACT.
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