My Head is Spinning Just Thinking about Boiler MACT Compliance Testing

Do you operate a multi-fuel boiler subject to Major Source Boiler MACT?  Have you given any thought to what your compliance testing will look like?  The January 31, 2016 compliance date is quickly approaching.  Facilities must complete their initial compliance demonstration for emission limits and establish operating limits by July 29, 2016.  The compliance options and considerations when conducting compliance testing start to add up pretty quickly.  It’s important to start planning and strategizing now.  You have to consider…

• I need to collect fuel samples during the test.  Can I collect my fuel samples in a manner consistent with the procedures outlined in Boiler MACT?  Do I have conveyance limitations such as safe access or causing an interruption to the fuel feed and tripping out the boiler?
• What is my worst case fuel firing scenario for a given pollutant?  It may be that fuel mix A is the maximum input loading for one (1) pollutant but fuel mix B is the maximum input loading for another pollutant.
• Will my operating load change depending on what pollutant I am testing for?
• Can I achieve my maximum rated operating load on my worst case fuel?  Do I need to consider adding an additional fuel so as not to limit my operating load on the boiler?
• Can I accurately measure the fuel firing rates during the test?  Is the process repeatable for future tracking requirements?
• What limitations, either permit limitations or physical restrictions, do I have when firing specific fuels?  I can’t forget about short-term permit limits!  I don’t want to conduct testing at a high coal firing rate and then blow past my SO₂ emissions limit.
• Has my coal pile been sitting and exposed to the weather for the last year?  That can have an impact on the testing results.  The last thing I want is to get a new shipment of coal, only to find out that now I have a different fuel composition that results in a compliance issue.
• What operating limitations will I be establishing when I conduct my initial performance testing?  Can I live with the operating load and minimum O₂ levels I am setting?
• Have I conducted engineering testing prior to the compliance test to know whether I will be able to live with the operating parameters that I will be setting?

As you can see, the list of things to consider and keep track of gets pretty complicated rather quickly if you have a multi-fuel boiler.  It is extremely important to have a well-thought out approach to your compliance testing.  At ALL4, we have assisted a number of clients with developing site-specific compliance testing plans, along with the separate, but closely related fuel monitoring plans and parametric monitoring plans, that carefully consider each of the questions above.  This has provided our clients with peace of mind, knowing that they are not backing themselves into a corner for compliance purposes.  The most important thing for facilities trying to comply with Boiler MACT to do is conduct some preliminary engineering testing.  Take your compliance testing plan for a “test drive.”  We are here to help you strategize and develop a compliance testing approach that works for your needs.  Check out our other Boiler MACT resources for additional ways that we can assist with your Boiler MACT compliance, or contact me with any questions.