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).
See the Q&A for the Pulp & Paper ICR.
Regulatory Support
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…
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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…
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This NCASI Excel-based tool was developed to audit test reports that utilize US EPA Method 5 to determine particulate matter emissions from a stationary source.
Learn MoreInitial Performance Tests NCASI has hosted several workshops on designing initial performance tests for multi-fuel boilers at various regional meetings. These workshops were held in the form of interactive panel discussions, with illustrative case studies also provided as discussion aids. Please contact Vipin
Learn MoreEPA Method 30B to Determine Mercury (Hg) Emissions Among the methods approved for mercury emissions performance testing in the Boiler MACT rule, only EPA Method 30B offers the combination of low detection limits, ease of implementation and low implementation costs. Given these benefits, there is an incentive in
Learn MoreElectronic 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
Learn MoreFuel 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 Fuel
Learn MoreClean 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.
Learn MoreOutput 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
Learn MoreUseful EPA Links Small Entity Compliance Guide for Major Source Boilers and Process Heaters Boiler MACT: Questions and Answers (Updated 6/10/15) Energy assessment requirements
Learn MoreCEMS 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
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