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February Ain’t What It Used to Be – Major Source Boiler MACT Compliance is Upon Us

Posted: February 3rd, 2016

Authors: Nick L. 

February is exciting enough with Valentine’s Day, the Super Bowl, and particularly for 2016, those leap year birthdays! However, this February brought with it another exciting event – the Major Source Boiler MACT compliance date. Now that it has arrived, there are plans to prepare, testing to perform, and records and reports to develop. ALL4’s experience with Boiler MACT projects has resulted in a wealth of helpful hints, lessons learned, and things to watch out for during the course of preparing to demonstrate initial and ongoing compliance with this complicated rule.  Here is a select sample of these topics for you to consider.

  • First of all, are you aware of the November 2015 reconsideration and its changes to the rule?  If not, there are substantial changes to the rule that you need to know about. One such example affects the hybrid suspension grate boiler subcategory. Facilities are now required to demonstrate by monthly fuel analysis that the biomass fired by the boiler contains at least 40 % moisture on an annual heat input basis.
  • Does your facility have a long and winding fuel delivery system with multiple transfer points, and are you unsure how to select appropriate fuel sampling locations? Do you know how and when to collect the samples during your test?  Boiler MACT requires that samples be collected at a location that most accurately represents the fuel type.  Performance testing must be conducted under the worst-case pollutant loading levels for both chlorine and mercury.  Since this may come from an alternate fuel, facilities must make sure they have enough fuel on site to complete performance testing comprising at least three (3) 1-hour test runs at a minimum – the specified sample volumes in Boiler MACT often required test runs lasting more than one (1) hour.
  • Do you know how to conduct a performance evaluation on your continuous monitoring systems (CMS)?  Boiler MACT contains provisions for boilers to establish operating parameter limits during performance testing.  Ongoing compliance is demonstrated using quality assured data generated from CMS such as pH, steam flow, and scrubber flow rate meters.  The quality assurance activities conducted on these types of CMS is often not well defined and documented at facilities, which is now a Boiler MACT requirement.  Performance evaluations must be completed as part of performance tests and the results must be included in the submittal of test results to U.S. EPA.
  • If you will be conducting “engineering” testing prior to your initial performance test, but after the January 31, 2016 compliance date, do you understand the potential legal implications of non-passing test results? Even if you do not follow a U.S. EPA reference method [e.g., you do not collect the minimum sample volume, or you only perform one (1) or two (2) test runs instead of three (3)], you are generating creditable evidence related to your boiler’s emissions. You should consider getting legal counsel involved in such “engineering” test programs.
  • Do you know how you will define periods of “out of control” for your monitoring parameters? Data collected and used to demonstrate compliance with Boiler MACT have collection, reduction, and quality control requirements.  Poorly designed and implemented CMS and data handling systems can lead to invalid data and become a liability resulting in non-compliance.
  • If you have a multi-fuel boiler that can burn natural gas, do you have a handle on how you will comply with monitoring requirements when burning natural gas? Do you know what your options are?
  • Do you know what startup definition you will follow? Remember that first bullet? This is one of the twists in the reconsideration. Do you know how to establish your parameters for useful thermal energy as part of your startup and shutdown procedures? Are you able to meet the clean fuels requirements in the rule?

Not all of these topics will apply to each and every facility. However, there is a good chance that one or more of these topics will hit home. If you are struggling with one of these topics, or any other for that matter, reach out and contact Nick Leone (610-933-5246, extension 121; nleone@all4inc.com) with questions.  Chances are we’ve touched on your issue and we can work together on a sensible solution.


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