Thursday, September 15, 2011

MACT Update

ABMA – American Boiler Manufacturers Association
E-Tech has, for the past two years, had the good fortune to be a member of the ABMA.  From its website, the Association proclaims,these pages are designed to not only serve the membership of the American Boiler Manufacturers Association -- the best of the boiler industry! -- they are intended, as well, to inform the public about the boiler and combustion equipment industry, its interests, its concerns and its cutting-edge, state-of-the-art technology.”
In my last blog, I gave an update on the boiler MACT and its potential impact on our industry.  The ABMA and its constituent members have had a vested interest in the promulgation of these regulations and, by extension, their implementation.  Having its location near Washington, D.C., the organization is in close contact with the decisions being made and the observance of the politics in trying to push this legislation through.  I needn’t remind anyone of the current fiasco in Washington.  I can say this without offending one side or another as most of us agree that the political standstill there is unhealthy to the future of our nation.  In his jobs creation speech, Obama stated that he was not going to let the economic crisis in our country ask our citizens to choose between their jobs and their safety while rolling back rules designed to protect our health.  These remarks indicate the Presidents backing of the November 16 deadline for the enforcement of MACT to limit boiler room emissions.
To that, on September 8, a top agency official told a congressional panel on September 8TH that USEPA neither needs nor wants an additional 15 months to issue emissions standards for boilers and incinerators.  As you would expect, some members of Congress have objected to these issues to the point of wanting to get rid of the EPA.  It’s not the purpose of my blog to support or oppose this as I have sworn to be apolitical in these matters.  However, the stance of the ABMA in particular and by extension, its membership, is (and I quote from the ABMA president and CEO) that “blocking the ICI-BMACT rules impedes job-creation in the boiler, combustion equipment and emissions controls industry!” 
I suspect that those of us in our lines of business, whether it be mechanical contractors, manufacturers’ representatives, consulting engineers and the like have a vested interest in seeing this move forward.  The House is expected to vote on the package of bills the week of October 3rd
For those interested in looking into the great work done by the ABMA, follow this link: ABMA Site
 Last, I have been admonished for not having included in last week’s blog my usual closing words of wisdom so I offer two from Thomas Jefferson. 
The care of human life and happiness, and not their destruction, is the first and only object of good government.
I predict future happiness for Americans if they can prevent the government from wasting the labors of the people under the pretense of taking care of them.

Thursday, September 1, 2011

MACT

 
MACT – Maximum Achievable Control Technology
The purpose of this article is to bring to light an EPA issue soon to be enacted that will impact many boiler room operations heretofore unaffected by environmental regulations.  Although it’s not possible to cover all of it within the scope of this blog, I will attempt to give you some overview of the program as well as resources that you may find helpful in determining what you may need to do; however, it is most important that you check the links I’ll provide to understand fully how this may impact you. 
Overview:
In March of 2011, the EPA published three final air emission standards that will reduce emissions from:
·         Boilers and process heaters at large sources of air toxics (“major sources”)
·         Boilers at small sources of air toxics (“area sources”)
·         Commercial and Industrial Solid Waste Incinerators (“CISWI”)

As the “major sources” component of this trio is on hold, it is important to realize that the “area sources” aspect is not!  And to make matters worse, these laws will apply to a large number of entities that operate boilers which prior to now have never been associated with air quality regulations.  With that in mind, I will concentrate on the “area sources” only.
Who is not affected by this rule?
·         The rule doesn’t apply to boilers that burn only gaseous fuels (examples are: natural gas, process gas, landfill gas, refinery gas, biogas, hydrogen) or solid waste.  For boilers that occasionally fire a liquid fuel during gas curtailment or supply emergencies or for periodic testing (not to exceed 48 hours per year), these are still considered gas-fired.
·         Hot water heaters with a capacity of nor more than 120 US gallons and pressures not exceeding 160 PSIG, and all controls necessary so as not to exceed a temperature of 210° F.
·         Waste heat boilers (HRSG) that recover traditionally unused energy and convert it to usable heat.
·         Research and development boilers
·         Hazard waste boilers

Am I subject to this rule?
You are subject to the Boilers Area Source NESHAP (National Emission Standards for Hazardous Air Pollutants) if you own or operate an industrial, commercial, or institutional boiler that is located at, or is part of, a facility that is classified as an area source of hazardous air pollutions (HAP).


When do I need to comply?
This is fairly general and the full notification requirements should be verified through the EPA. 
Initial notification of applicability:
·         September 17, 2011, if startup was before May 20, 2011.
·         September 17, 2011 or within 120 days after startup of a new source, whichever is later.

Initial notification of compliance status:
·         Existing sources subject to tune-up work practices – July 19, 2012
·         Existing sources subject to emission limits – July 19, 2014
·         Existing sources subject to energy assessment – July 19, 2014

Resources
·         Policies and Guidance:  http://www.epa.gov/compliance/resources/policies/civil
·         Civil Penalty Policies:  http://cfpub.epa.gov/compliance/resources/policies/civil/penalty
·         Enforcement Response Policies:  http://cfpub.epa.gov/compliance/resources/policies/civil/erp
·         FY2012 National Program Manager Guidance:  http://www.epa.gov/planandbudget/annualplan/FY12_OECA_NPM_Gdnce.pdf
·         Area Source Implementation Guidance:  http://www.epa.gov/compliance/resources/policies/monitoring/caa/areasource.pdf
·         E-Tech web site: E-Tech Downloads