Boiler Major Source applies to a boiler in a facility with actual emissions of Hazardous Air Pollutants (HAPs) greater than 10 tons per year of a single HAP or greater than 25 tons per year of total HAPs combined. EPA dictates that Boiler Major Source facilities must use the Maximum Available Control Technologies (MACT) or management practices to reduce emissions of HAPs.
For facilities that had existing Boiler Major Sources, the Initial Notification Report and Notification of Compliance Status to the State and US EPA was due by May 31, 2013. Additionally, existing Boiler Major Sources had to conduct an Energy Assessment and initial tune-up by January 31, 2016.
However, 2016 was nearly a decade ago, and your facility may have installed, or is planning to install, a new boiler that must operate in compliance under Boiler MACT regulations.
What are my initial compliance requirements under Boiler MACT?
For a new boiler, the first thing you will want to do is ensure the boiler is accounted for in your facility’s air quality permit through the use of an air quality permit modification. If the entire facility will be new, an air quality permit will need to be applied for all air pollutant generating equipment, including the boiler. The air quality permit for the boiler must be issued before construction and operation of the boiler.
Once properly permitted, the facility must then submit an Initial Notification no later than 15 days after the actual date of startup of the boiler. The facility must then complete and submit the Initial Compliance Demonstration within 180 days after startup of the new boiler.
What is required in the Initial Compliance Demonstration?
The Initial Compliance Demonstration must be completed and submitted to the State Authority. Three things must be completed for compliance demonstration:
- The initial tune-up of the boiler must have been conducted and the associated certification report must have been completed.
- The one-time energy assessment must have been completed by a qualified energy assessor.
- Either a performance test or fuel analysis must have been completed to indicate compliance with all applicable emissions limits.
If a performance test is conducted, the compliance test results must be submitted to the State within 60 days of completion of the test.
Fuel analyses are only required if the boiler burns more than a single type of fuel.
What are the recurring compliance requirements?
After completion of initial compliance requirements, both existing and new boilers must continue to adhere to recurring compliance requirements for their boiler under Boiler MACT. There are three main recurring compliance requirements:
- Continuous monitoring of operating parameters or emissions.
- Annual (or 5-year) boiler tune-ups.
- Annual (or 3-year) performance tests.
Depending on the fuel type and compliance method, continuous monitoring will be required at the boiler. The continuous monitoring will need to collect and record various parameters to indicate the boiler is operating within limits that are established during the previous performance test.
Boiler tune-ups are required every year for boilers not equipped with an oxygen trim, and every 5 years for boilers equipped with an oxygen trim. The tune-ups should be conducted within 13 months (or 61 months for those qualifying for 5-years) of the previous tune-up and should have an associated certification report completed alongside the tune-up.
Performance tests are required every year for boilers. If two consecutive performance tests are at or below 75% of the emission limit for a pollutant, the facility may test for that pollutant every 3 years instead. Subsequent performance tests should be conducted within 13 months (or 37 months for those qualifying for 3-years) of the previous tune-up. Performance test reports must be submitted to the State authority within 60 days of completion of the stack test.
What does this mean for your facility?
Facilities operating under Boiler MACT regulations must be careful to ensure complete compliance with the various requirements. Any deviation is liable for violations issued on both the State and Federal levels.
Conversion Technology, Inc. (CTI) can provide consulting assistance to ensure that your facility is in compliance under Boiler MACT. CTI has had over 30 years of experience working with industrial facilities to assist with environmental compliance. This includes assisting with air permitting for the boiler, conducting the recurring boiler tune-ups, conducting the one-time energy assessments with our qualified experts, assisting with performance tests and ensuring your facility can maintain compliance with the consequential operating limits, and ongoing remote checks of the continuous monitoring system to ensure accurate and complete data recording. We will be happy to assist you with whatever consulting services you are in need of.