Category: Boiler MACT

Common MACT Reporting Violations and How to Avoid Them

Posted on by Conversion Technology

Industrial boiler undergoing MACT emissions testing

If your business operates a boiler or process heater, you’ve likely encountered the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Major Sources, specifically 40 CFR Part 63, Subpart DDDDD, commonly known as Boiler MACT (Maximum Achievable Control Technology). These requirements govern how you test, document, and demonstrate compliance to help keep your facility operating safely and efficiently.

With the end of June fast approaching, another reporting period is soon coming to an end. Another Boiler MACT semiannual compliance report is due soon. Now is a good time to compile your records so you can begin preparing the semiannual report as soon as the reporting period ends, because missing or late submittals can lead to significant financial and legal consequences.

Continue reading “Common MACT Reporting Violations and How to Avoid Them” →

Boiler MACT Compliance Reminder

Posted on by Conversion Technology

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? Continue reading “Boiler MACT Compliance Reminder” →

EPA Allows Reclassification from A Major Source of Hazardous Air Pollutants (HAP) to An Area Source

Posted on by Adam Haroz, EIT

On July 26, 2019, the Environmental Protection Agency (EPA) proposed revisions that would allow an operating facility to be reclassified from a major source of hazardous air pollutants under Section 112 of the Clean Air Act to an area source, thus removing the policy commonly known as “once in, always in”. This revision could take a lot of pressure for capital investments and permitting off of facilities that are eligible.

Continue reading “EPA Allows Reclassification from A Major Source of Hazardous Air Pollutants (HAP) to An Area Source” →

EPA’s Proposed Revisions to Emission Limits for Boiler MACT

Posted on by Conversion Technology

On January 31, 2013, the U.S. Environmental Protection Agency (EPA) finalized amendments to the national emission standards (NESHAP) for the control of hazardous air pollutants (HAP) at major sources from new and existing industrial, commercial, and institutional (ICI) boilers and process heaters (Boiler MACT). Subsequently, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit), in a decision issued in July 2016, remanded several of the emission standards to the EPA based on the court’s review of the EPA’s approach to setting those standards. In response to these remands, this action proposes to amend several numeric emission limits for new and existing boilers and process heaters consistent with the court’s opinion and set compliance dates for these new emission limits. Continue reading “EPA’s Proposed Revisions to Emission Limits for Boiler MACT” →

EPA Proposes NESHAP Amendments to Withdraw “Once In, Always In” Policy for MACT Standards

Posted on by Conversion Technology

On July 26, 2019, the U.S. Federal Register published the Environmental Protection Agency’s (EPA) proposed amendments to the provisions in the National Emission Standards for Hazardous Air Pollutants (NESHAP). The primary purpose of the proposed amendments is to withdraw the “Once In, Always In” (OIAI) policy regarding the classification of facilities as major sources of hazardous air pollutants (HAPs) subject to Maximum Achievable Control Technology (MACT) standards. A major source is defined as any facility which emits at least 10 tons per year of any HAP or at least 25 tons per year of any combination of HAPs. A facility that is not classified as a major source is considered an area source. The OIAI policy, issued in 1995, required major source facilities that are subject to a MACT standard to permanently comply with that standard even if a facility reduces its HAP emissions below major source thresholds. The withdrawal of the OIAI policy was also previously discussed in EPA’s guidance memorandum issued on January 25, 2018. Continue reading “EPA Proposes NESHAP Amendments to Withdraw “Once In, Always In” Policy for MACT Standards” →

EPA Information Request for Kiln MACT Standard (40 CFR 63 Subpart DDDD)

Posted on by Jeff Davis, PE

EPA is working on the Information Collection Request (ICR) for Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants (NESHAP). The comment period for preparing the ICR ended on November 7, 2016. This is the MACT standard commonly referred to as the Kiln MACT as it will apply to lumber drying kilns in some fashion, in addition to plywood and composite wood products. Continue reading “EPA Information Request for Kiln MACT Standard (40 CFR 63 Subpart DDDD)” →

Submitting Results of Boiler MACT Performance Tests

Posted on by Conversion Technology

If you have elected to comply with the Boiler MACT regulation through performance testing, the deadline for the broad majority of existing boilers to complete the performance testing was July 29th, 2016. For the sake of this blog entry, we’ll assume you have done this. (If not, you should contact us immediately and we can get you up to speed!) Continue reading “Submitting Results of Boiler MACT Performance Tests” →

Court Rules on Lawsuit over EPA’s Boiler MACT Regulation

Posted on by Jeff Davis, PE

On July 29, 2016, the U.S. Court of Appeals for the D.C. Circuit ruled on the lawsuits over EPA’s Boiler MACT (40 CFR Part 63, Subpart DDDDD) and Boiler GACT (40 CFR Part 63, Subpart JJJJJJ) regulations. The lawsuit was the consolidation of multiple suits from industry and environmental groups. The split of the suits from industry versus environmental groups was stated by the court to be approximately 50/50. In summary, the court rejected all the industry petitions and granted some of the petitions from environmental groups. The most significant aspects of this ruling pertain to vacating portions of the standard and remanding additional portions of the standard to EPA to provide further explanation.

Under the Boiler MACT regulation, boilers are divided into subcategories based on the type of fuel utilized and the configuration of the combustion unit. Continue reading “Court Rules on Lawsuit over EPA’s Boiler MACT Regulation” →

Regulations: EPA Amends Rule Permitting Burning of Creosote-Treated Wood Under the Boiler MACT Rule

Posted on by PH Haroz

Under the previous EPA Non-Hazardous Secondary Materials (NHSM) rule, treated wood was prohibited from being used as boiler fuel; however, EPA recently issued an amendment permitting creosote-treated wood to be used as boiler fuel under special conditions.

Read the rest of our article in Waste Advantage Magazine online (http://goo.gl/8idkTR) or in the April 2016 digital edition (http://www.mazdigital.com/webreader/38250?page=35).

Webinar Replay – Boiler MACT Deadline is here. Are you in Compliance?

Posted on by PH Haroz

If you missed our free webinar on Boiler MACT Compliance, you can stream it online now on your own time. To view the webinar visit http://ehsdailyadvisor.blr.com/2015/12/6761/ and register to view (or enter your email if already registered).

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If you wanted to have the presentation slides from the webinar, we have made them available here: 2016 Boiler MACT Webinar Slides.

The Q/A for the webinar is available here: QA Boiler MACT Webinar.

If you have any questions or comments about Boiler MACT Compliance or the webinar, feel free to contact us at 770-263-6330 or cti@conversiontechnology.com