AQ_F_0800107_20110526_GEN_FileNotes

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Division of Air Quality
Washington Regional Office
Memorandum:
TO: File
FROM: Betsy Huddleston 04
DATE: May 26, 2011
SUBJECT: Boiler GACT Questions
W.E. Partners II
Premise 0800081, Permit 10126R00
With the GACT in mind, W.E. Partners II has decided to install an ESP rather than a multielone
on the new Lewiston biomass boilers. Garald Cottrell emailed the following question,
"As the individual units at Lewiston are less than 30 MMBtu (but there are three units
with common exhaust ducting to a common ESP), the Area Standard is .07 lb/MMBtu for
units of less than 30 MMBtu input. Our concern is that if we proceed with the installation
of an ESP capable of 0.07 and the EPA/NCDAQ'dictate a change in the future and treat
this as one system requiring a 0.03 standard, the incremental cost to replace the ESP is
very expensive.
As an additional question,what do we do as we have the Lewiston operation/construction
permit in-hand? Do we proceed and just install the ESP or, do we document the change
when I submit our permit modification request to add the cotton gin/peanut hulls and
soybeans?"
I called Steve Schliesser on May 25 h for some guidance on the rule(Steve coordinated DAQ's
comments on the draft rule to EPA). First, he confirmed that while the boiler MACT has been
stayed, the GACT is still moving forward. He also confirmed that the rule applies the 0.07
lb/MMBtu particulate limit to each boiler in the 10 to 30 MMBtu/hr category. The firing rates
are not aggregated.
We noted that there is an opacity monitoring requirement for the boilers. For an ESP, the
company can track aspects of the ESP operation instead of installing a COM. Monitoring
parameters will have to bet set when the company performs the initial test for particulate.
I called Garald and relayed Steve's responses. I also told Garald to submit an application for the
ESP. He will include a request for additional biomass fuels in that application as well.
Steve followed up with an email that contained some food for thought.
"On page 15564 of the GACT rule, it says:
In this final rule, the PM emission limits for new area source boilers have been revised
based on the size category. For new boilers in the coal, biomass, and oil subcategories
with a heat input capacity less than 10 MMBtu/h, GACT is a management practice of a
tune-up. For new boilers between 10 and 30 MMBtu/h heat input, the PM limit has been
revised [from 0.03 up to 0.07 lb/MMBtu] to reflect the performance of GACT, which is a
multielone.

This suggests a multiclone wvuld/could meet the 0.07 lb/MMBtu G,�f biomass limit.
Maybe they could investigate a multiclone, a less costly technology than ESP?
On the other hand, their webpage shows Wellons as a mfg of ESPs, and their ESP description
reflects a good design with modern features, such as rigid electrodes, etc. See
http://www.wellons.com/esp.html."
W.E. Partners applied a 0.38 lb/MMBtu particulate emission factor from a multiclone. I wonder
where EPA got such low test values to use for basis of their GACT limit?