Final Boiler MACT and Industrial Boiler Process Heater NESHAP

Written By: Caltha LLP | Published On: 22nd December 2012 | Category: Air Quality | RSS Feed

On December 21, 2012, the Environmental Protection Agency (EPA) released air pollution rules regulating hazardous air emissions from industrial boilers and process heaters. This package of combustion rules includes a revised version of the Industrial Boiler Maximum-Achievable Control Technology standard (Boiler MACT).

The final combustion rule package addresses major and area source industrial boilers, as well as commercial and industrial solid waste incinerators (CISWI). These rules provide new emissions limits, compliance dates and important clarifications on how the rules are to be implemented. The rule package also includes guidance for defining whether non-hazardous secondary materials (NHSM) are to be considered a solid waste or a fuel, which is a critical decision for determining whether combustion of such materials must be regulated under the generally more stringent incinerator CISWI rules or the revised Boiler MACT rules.

Some of the key changes from the March 2011 rules are :

Major Source Boilers

  • Compliance date extended to early 2016, and subject facilities will have an opportunity to request an additional year if needed.
  • New subcategories were created for light and heavy industrial liquids and for coal fluidized bed units.
  • New emission limits for particulate matter and carbon monoxide, allowing alternative total selective metals emission limits, and replacing numeric dioxin limits with work practice standards.
  • Adding alternative monitoring approaches for demonstrating compliance with particulate matter limits.

Area Source Boilers

  • Initial compliance date is extended to March 21, 2014, and subject facilities will have an opportunity to request an additional year if needed.
  • Initial notification must occur no later than January 20, 2014.
  • New subcategories were created for seasonal and limited use boilers.
  • Allowing existing dual-fuel fired units to retain the “existing unit” designation regardless of fuel switching.
  • Periodic tune-ups for seasonal/limited use and small oil-fired units are required every five years, instead of every two years.
  • Creating alternative compliance demonstrations for new boilers burning low sulfur oil and compliance incentives for boilers that perform well below emission standards.
  • Adding alternative monitoring approaches for demonstrating compliance with carbon monoxide (CO) limits.

CISWI

  • Compliance date for existing units is 2018
  • New incinerators need to meet the standards 180 days following publication of the rule in the Federal Register.
  • New emission limits for dioxin and mercury which EPA believes will result in better-defined and more achievable standards.

Non-hazardous Secondary Materials (NHSM)

  • Provides new standards and procedures for determining if NHSMs are “solid waste” under the Resource Conservation and Recovery Act when used as fuels in combustion units.
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