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
· 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
Great summary, Bob. Cleaver-Brooks has also developed tools and tips to help boiler owners understand their registration and reporting requirements, including a simple decision tree. For more information visit http://bit.ly/r9Ub24
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