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.
Most MACT problems come from preventable issues, such as incomplete or disorganized records or missed deadlines. Below are two of the most common MACT performance violations and practical ways to avoid them.
1. Planning, Notification or Procedure Issues
These violations often occur when pre-test steps are missed, late, or incomplete. Even if sampling is done correctly, these administrative gaps can trigger deviations that may lead to violations and force costly retests.
Start by building a backward schedule from the required submission deadline to ensure all steps are accounted for and scheduled. Remember to factor in contractor lead time and contingency dates. The stack test plan must be submitted at least 30 days prior to the performance testing date. Once a test date is confirmed with the stack testing company, coordinate with all relevant contractors to ensure proper operation of the unit and any air pollution control devices.
2. Reporting and Submission Mistakes
The U.S. Environmental Protection Agency’s (EPA) requires companies to submit all performance tests through the Compliance and Emissions Data Reporting Interface (CEDRI). Performance test results must be submitted 60 days after the date of the test. Periodic reports must be submitted semiannually or annually as applicable. While Boiler MACT requires periodic reports be submitted 30 days after the end of the reporting period, states have the authority to change the deadline to align with other periodic reports, such at the Title V Semiannual Reports. Check with your state-issued air quality permit for your specific deadlines.
Missing or late reports through this online tool can have costly consequences, so it is crucial to consider reporting time into your initial timeline for testing and submission. Ensure your report is complete and consistent, including the necessary data to support the final numbers. After submission, maintain records of all submitted MACT reports.
Most MACT testing violations are avoidable with disciplined planning and complete documentation from start to finish. Conversion Technology, Inc. (CTI) can help you put those practices in place. With more than 40 years of experience supporting industrial facilities to ensure compliance with Boiler MACT regulations, we can assist with recordkeeping, ensure monitors are collecting the relevant data, check that the stack test produces manageable operating parameter limits, perform boiler tune-ups and energy assessments, submit Boiler MACT results, and more. Contact CTI today to get started.
