Efforts in this area of NCASI’s program are oriented towards developing a) technical work products that inform regulatory agencies during rule development and b) rule summaries, guidance documents and implementation tools to assist members during rule implementation (Pulp & Paper Manufacturing and Wood Products Manufacturing).
NCASI technical resources related to the Boiler MACT rulemakings are available here. Notable NCASI work related to this topic includes an assessment of the performance of PM CEMS on wood-fired boilers, summary of Detection and Quantitation limits for mercury (Hg) measurement, guidance on fuel sampling and analysis and summary contaminant…
NCASI technical resources related to major rulemakings in the Pulp and paper sector, viz., the Subpart S (pulp and paper) MACT, Subpart S RTR, Subpart MM (chemical recovery) MACT and RTR are available here. Leading up to the Subpart S rulemakings, NCASI conducted an extensive sampling program to quantify HAP…
EPA issued the Plywood and Composite Wood Panel Maximum Achievable Control Technology (PCWP MACT, 40 CFR Part 63, Subpart DDDD) emission standards in July 2004. These standards established hazardous air pollutant (HAP) emission limits for certain panel plants and engineered lumber operations that are major sources. EPA is currently reconsidering…
Electronic Reporting Tool
All performance test results must be submitted to EPA’s Central Data Exchange (CDX) using the Electronic Reporting Tool (ERT).
The Test Plan portion of the ERT must be filled out first. Only after that will the Test Data section become available. Filling out the test plan portion pr
Fuel Sampling and Analysis Procedures
Boiler MACT provides facilities the option of demonstrating compliance with HCl, TSM and mercury (Hg) limits using fuel analysis. NCASI has developed whitepapers on
Fuel sampling procedures required by the rule, to be employed during initial performance tests
Clean Fuels for Startup
Can dry biomass satisfy the “Clean-Fuel” requirement as proposed in the reconsideration rule?
On January 21, 2015, EPA published a proposed rule announcing the reconsideration of specific issues related to the MACT standards for boilers and process heaters located at major sources.
Output Based Emission Limits
Output-based emission limits could be a viable compliance option for boilers that produce steam, electricity, or cogenerate steam with electricity. However, the prevalence of complex systems in our industry, where multiple boilers supply steam to common headers, that subsequently fee
CEMS for Combination Boiler Particulate Matter
§ 63.7525(b) requires solid and liquid fossil fuel boilers with heat inputs greater than 250 MMBtu per hour to install either a CPMS or CEMS in order to show ongoing compliance with PM emission limits. Other boilers may choose to install these systems in order to a
Non-Hazardous Secondary Material Self-Determination
Certain materials were granted categorical non-waste status (Scrap tires, resonated wood, coal refuse, and dewatered pulp and paper sludges that are combusted on-site) in the Federal Register on February 7, 2013 .
Three additional categories were proposed (c
Carbon Monoxide Floor Determinations
During the setting of the MACT floor for carbon monoxide, Ncasi added to EPA's understanding in several areas where the procedures originally used were not scientifically valid.
Alternative limits for boilers equipped with CO CEMS
The initially proposed Boiler MACT car