Meeting Compliance Schedule and Requirements for Boiler MACT

Boiler Area Source applies to a boiler in a facility with actual emissions of Hazardous Air  Pollutants (HAP) less than 10 tons per year of any single HAP or less than 25 tons per year of all HAPs combined. EPA allows Boiler Area Source facilities the use of Generally Available Control Technologies (GACT) or management practices to reduce emissions of hazardous air pollutant (as compared to Boiler MACT facilities explained later requiring stricter practices). If your facility is an Area Source, you should have submitted the Initial Notification Report and Notification of Compliance Status to the State and US EPA by May 31, 2013.

The Boiler MACT rule applies to new and existing boilers and process heaters having actual emissions of HAPs in excess of 10 tons per year of any single HAP or 25 tons per year of all HAPs combined. If your facility possesses a Title V or Part 70 (Major Source) Air Quality Permit, this does not necessarily mean that the Boiler MACT applies to you. A Title V Air Quality Permit signifies that actual emissions of at least one criteria pollutant (e.g. particulate matter, carbon monoxide, volatile organic compounds, etc.) exceed 100 tons per year for non-HAP pollutants or the 10/25 ton per year HAP thresholds previously stated. If permitted emissions of HAPs are below the major source thresholds, Boiler MACT does not apply to you; however, Boiler GACT may. If your facility falls under Boiler MACT, you should have submitted the Initial Notification Report and Notification of Compliance Status to the State and US EPA by May 31, 2013.

For both Boiler MACT and Boiler Area Source, all facilities must conduct regular tune-ups and perform a onetime boiler energy assessment of at least one boiler.

The deadline to complete the Energy Assessment and Tune-up for Boiler Area Source was March 21, 2014 and for Boiler MACT it is January 31, 2016.

Many of you have already completed the one time energy assessment and boiler tune-up. That was the easy part. Now, you need to be able to meet the emission limits set out by the Boiler MACT rule. These emissions limits can be more stringent than the limits specified in your state Air Permit.

In order to meet these emission limits, you could be required to add or change your facility’s pollution control equipment. The rule also requires the use of a Continuous Monitoring System (CMS) and Data Acquisition System (DAS). These systems could be expensive and complex.

Be aware that for the above, time is of the essence, even with a compliance deadline of January 31, 2016. The standard delivery time for these types of systems can be approximately 4 months. This does not include the time required for installation and start-up. These are not just systems that you can buy off the shelf, plug in, and you are in compliance. There is an optimization process to select the most economical and feasible CMS and DAS for your facility’s requirements. The compliance deadline is fast approaching. Contact CTI now.

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