Boiler MACT Case Study Success Stories
Posted: May 18th, 2015Author: All4 Staff
Since the promulgation of 40 CFR Part 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants (NESHAP) for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (Major Source Boiler MACT) and 40 CFR Part 63, Subpart JJJJJJ – NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources (Area Source Boiler MACT), ALL4 has been busy helping clients develop strategies for complying with these rules. Here are two (2) examples of projects we have been working on to help our clients:
- Re-designation of a facility from a major source of HAPs to an area source of HAPs – A large industrial client that is a major source of HAPs has several existing boilers, including units that burn biomass subject to the emission limits, operating limits, and work practice standard requirements of Major Source Boiler MACT. The facility was only a major source because emissions of single HAP are over 10 tons per year (tpy). Total HAP emissions were well below the 25 tpy major source threshold. ALL4 worked closely with the facility to investigate alternative raw material options in order to reduce the emissions of the problematic HAP to below 10 tpy. ALL4 then prepared and submitted an air permit application to the state agency requesting a federally enforceable limit restricting HAP emissions at the facility to less than 10 tpy of a single HAP and less than 25 tpy of combined HAPs. Because the federally enforceable limit will be in place before the effective date of Major Source Boiler MACT (January 31, 2016), the facility will be designated as an area source for Boiler MACT. As an area source, the existing solid fuel boilers will not be subject to emission limit and operating limit requirements, which will greatly reduce the compliance burden on the facility.
- Replacement of coal-fired boilers with gas-fired boilers – ALL4 has assisted several major source clients with the replacement of aging coal-fired boilers with gas-fired boilers. Bringing these coal-fired boilers into compliance with Major Source Boiler MACT would have been a costly endeavor. ALL4 worked with the clients on the selection of the new boilers as well as developing strategies for the timing that would be required to have the old boilers out of service and the new boilers in service before the effective date of Major Source Boiler MACT (January 31, 2016). In one (1) case, ALL4 assisted the client with procuring a one (1)-year extension of effective date, as allowed in the rule. ALL4 prepared and submitted permit applications for the new boilers allowing the companies not only to meet the Boiler MACT compliance date, but to complete these money-saving projects in the desired timeframes.
These two (2) case studies are just a few of the examples of how we have helped our clients to comply with these complex regulations. Our work continues, as we assist clients with notification requirements, compliance reporting, fuel sampling, plan development, and other aspects of these rules.