POWER March 2013 - 38

FUELS
The Regulatory History
The recent promulgation of the CISWI (Dec. 20,
2012) is an update of a decade-old rule. On Dec.
1, 2000, the EPA promulgated NSPS and EG for
CISWI units. On Jan. 30, 2001, the Sierra Club
filed a petition challenging the CISWI rule. As a
result of a federal court decision that addressed
the method by which the EPA set MACT floors
(see Cement Kiln Recycling Coalition v. EPA
[255 F.3d 855, DC Cir. 2001]), the EPA voluntarily
vacated the CISWI. On Sept. 22, 2005, the
EPA issued the CISWI Definition Rule to better
define the term " solid waste. "
Almost two years after promulgation of
the CISWI Definition Rule, on June 8, 2007,
the courts vacated and remanded it due to its
inclusion of all facilities combusting any solid
waste material. The December 2012 final
decision incorporates updates to the Definitions
Rule and the voluntary vacatur of the
2000 CISWI (Table 1).
Solid Waste Classification
If C&D were to be granted a classification
change from a solid waste to a biomass fuel,
facilities wishing to use the fuel for power
generation would have less-stringent emission
limitations. These facilities would be regulated
by the recently promulgated (Dec. 21, 2012)
National Emission Standards for Hazardous Air
Pollutants for Major/Area Sources: Industrial,
Commercial, and Institutional Boilers and Process
Heaters (Boiler MACT) under Section 112
of the CAA. This is a significant change, as the
Boiler MACT regulations for biomass combustion
are far less onerous than the limits imposed
by the CISWI for burning the same materials
(see Tables 2 to 5 for a comparision of the difference
in emission limits).
As part of the Non-Hazardous Secondary
Material Rule (NHSMR), C&D can be reclassified
from a solid waste to " clean " C&D
if it can pass the EPA's " Legitimacy Criteria "
evaluation. The requirements to reclassify
C&D fuel as a nonwaste fuel are fourfold:
the material must be " managed as a valuable
commodity; have a meaningful heating value;
be used as a fuel in a combustion unit that
recovers energy; and contain contaminants at
levels comparable to or lower than those in
traditional fuels which the combustion unit is
designed to burn. "
The first NHSMR test requires a fuel management
plan that shows C&D waste is a " valuable
commodity. " This plan must meet three
standards as outlined by the EPA:
■ The storage of the nonhazardous secondary
material (C&D) prior to use must not
exceed reasonable time frames.
■ Where there is an analogous fuel, the nonhazardous
secondary material must be managed
in a manner consistent with the analogous
38
Table 1. The long history of the CISWI Rule. Source: EPA
Section 129 of the Clean Air Act created
CISWI Rule promulgated
Voluntary EPA vacatur of CISWI Rule
CISWI Definition Rule promulgated
CISWI Definition Rule vacated and remanded
CISWI Rule (voluntary vacatur & definition rule) promulgated
Table 2. CISWI emission limits for existing units. Source: EPA
Pollutants
HCl (ppmv)
CO (ppmv)
Pb (mg/dscm)
Cd (mg/dscm)
Hg (mg/dscm)
PM, filterable (mg/dscm)
Dioxin, furans, total (ng/dscm)
Dioxin, turans, TEQ (ng/dscm)
NOx (ppmv)
SO2 (ppmv)
Incinerators
29
17
0.015
0.0026
0.0048
34
4.6
0.13
53
11
0.20 (biomass units)
/ 13 (coal units)
260 (biomass units)
/ 95 (coal units)
0.014 (biomass units)
/ 0.14 (coal units)
0.0014 (biomass units)
/ 0.0095 (coal units)
0.0022 (biomass units)
/ 0.016 (coal units)
11 (biomass units) /
160 (coal units)
0.52 (biomass units)
/ 5.1 (coal units)
0.12 (biomass units)
/ 0.075 (coal units)
290 (biomass units)
/ 340 (coal units)
7.3 (biomass units) /
650 (coal units)
ERUs, solids Waste-burning kilns
3.0
110 (long kilns) / 790
(preheater/precalciner)
0.014
0.0014
0.011
4.6
1.3
0.075
630
600
Small, remote
incinerators
300
64
2.1
0.95
0.0053
270
4,400
180
190
150
1990 2000 2001 2005 2007 2012
■
■
■
■
■
■
Table 3. Boiler MACT emission limits for existing biomass units. Source: EPA
Pollutants
HCl (ppmv)
CO (ppmv)
Pb (mg/dscm)
Cd (mg/dscm)
Hg (mg/dscm)
PM, filterable (mg/dscm)
Dioxin, furans, total (ng/dscm)
Dioxin, furans, TEQ (ng/dscm)
NOx (ppmv)
SO2 (ppmv)
Incinerators
0.091
17
0.015
0.0023
0.00084
18
0.58
0.13
23
11
0.20 (biomass units)
/ 13 (coal units)
240 (biomass units)
/ 95 (coal units)
0.014 (biomass units)
/ 0.14 (coal units)
0.0014 (biomass units)
/ 0.0095 (coal units)
0.0022 (biomass units)
/ 0.016 (coal units)
5.1 (biomass units) /
160 (coal units)
0.52 (biomass units)
/ 5.1 (coal units)
0.076 (biomass units)
/ 0.075 (coal units)
290 (biomass units)
/ 340 (coal units)
7.3 (biomass units) /
650 (coal units)
www.powermag.com
ERUs, solids Waste-rurning kilns
3.0
90 (long kilns) / 190
(preheater/precalciner)
0.014
0.0014
0.0037
2.2
0.51
0.075
200
28
Small, remote
incinerators
200
13
2.0
0.67
0.0035
270
1,800
31
170
1.2
POWER | March 2013
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POWER March 2013

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