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Show • Review different reference sources to develop an initial list. Example references examined included recommendations from the ICCR Testing and Monitoring Protocol W o r k Group, Great Waters Program, EPA's proposed list of 40 priority H A P s under the Urban Air Toxic Program and the assessment of the I C C R dioxin primer[4]. Emissions data from API, W S P A , the I C C R dioxin primer, AP-42, E P A Utility Boiler H A P s study were also considered. H A Ps were put on the original list if they were considered high toxic risks or if they were detected during emissions testing or if there was not enough data to support a recommendation. • From available emissions data, determine the magnitude of HAPs emissions from boilers of 10 million BTU/hr (MMBTU/hr), 100 MMBTU/hr, and 250 M M B T U / h r firing rates. • Compare the actual emissions with de minimus limits derived from a very conservative stack model provided by the N e w Hampshire Department of Environmental Service (NHDES). Eliminate those compounds that were emitted at levels below the de minimus limit. • Perform a second screening of HAPs for a 250 MMBTU/hr boiler using more realistic assumptions. These emissions were compared to the N H D E S model levels, the Florida Ambient reference concentrations, and the E P A Boiler Industrial Furnace (BIF) Levels. • The final list of HAPs of Interest for fossil fuel fired boilers consisted of; HAPs that exceeded the models' screening levels H A P s that were considered high toxic risks (added on the insistence of the environmental stakeholders). H A P s that did not have sufficient emissions data to support a recommendation. The final HAPs of Interest are listed in Tables 3, 4, 5, and 6. Plan to Conduct Emissions Testing For Boilers - The purpose of the Test Plan is to assess fuel characteristics and determine emissions from the co-firing of nonfossil materials. The E P A will use the fuel characterization data to help with subcategorization of boilers that fire nonfossil fuels. Fuels that show similar characteristics will be placed in a single category. Some nonfossil fuels may be similar to fossil or wood materials. Table 7 lists the proposed fuel characterization data. With knowledge of the halogen content and metals composition, H A P s of Interest for nonfossil fuels can be refined. The Boiler Work Group has determined that the effect of co-firing fuels on emissions is not well understood. Although there are many other data gaps involving H A P emissions and their control from Boilers, the Boiler W o r k Group believed that testing of a co-fired unit would provide the highest benefit within the constraints of a limited budget. The agency will use the emissions test data to help determine where co-fired units should be placed, either with the primary fuel (coal or wood) subcategory or the should they be placed in a nonfossil subcategory. The testing should also provide information to determine possible de Minimus levels for co-firing wastes regulated by Section 129 and fuels regulated by Section 112. The proposed test matrix included: D:\jps\ica\bwg\boilerwg 7 |
