Upcoming Area Source Boiler MACT Requirements for Existing Affected Sources

It hasn’t quite been a year since the final Area Source Boiler MACT rule was published in the Federal Register on February 1, 2013, but the deadline for submitting initial notifications for existing affected sources is just about here (i.e., January 20, 2014).  Soon thereafter, by March 21, 2014, certain existing affected sources must conduct an initial tune-up, one-time energy assessment, and comply with emission limitations.  In most cases, a Notification of Compliance Status (NOCS) must then be submitted by July 19, 2014.  Facilities that emit less than 10 tons per year of a single HAP and less than 25 tons per year of total HAPs are area sources of HAP and are potentially subject to the Area Source Boiler MACT. Facilities that emit 10 tons per year or more of a single HAP or 25 tons or more of total HAPs are major sources of HAP and are potentially subject to the Major Source Boiler MACT.

Initial Notification Requirements

What information is required for the initial notification?  Pursuant to 40 CFR §63.9(b)(2), initial notifications must include the following information:

• “The name and address of the owner or operator;
• The address (i.e., physical location) of the affected source;
• An identification of the relevant standard, or other requirement, that is the basis of the notification and the source’s compliance date;
• A brief description of the nature, size, design, and method of operation of the source and an identification of the types of emission points within the affected source subject to the relevant standard and types of hazardous air pollutants emitted; and
• A statement of whether the affected source is a major source or an area source.”

U.S. EPA has provided an initial notification template for area sources, which must be submitted to your U.S. EPA Regional Office, as well as your state agency if they have been delegated authority by U.S. EPA to implement the rule.

Tune-up Requirements

Owners and operators of existing coal-fired boilers with heat input capacities less than 10 MMBtu/hr and biomass- and oil-fired boilers of any size must conduct an initial tune-up of the boiler by March 21, 2014.  The frequency of subsequent tune-ups varies by fuel type and size.  Facilities should keep in mind that they do not have to submit the results of the tune-up to U.S. EPA, but records of the tune-up must be maintained.  U.S. EPA has provided facilities with a template tune-up recordkeeping form along with guidance on how to complete the tune-up. 

Energy Assessment Requirements

Owners and operators of existing coal-, biomass-, and oil-fired boilers greater than 10 MMBtu/hr must conduct a one-time energy assessment performed by a qualified energy assessor by March 21, 2014.  Stay tuned for an upcoming 4 The Record article with more details about the energy assessment requirements.

Emission Limitation Requirements

Owners and operators of existing coal-fired boilers greater than 10 MMBtu/hr must comply with emission limitations for mercury (Hg) and carbon monoxide (CO) by March 21, 2014.  Compliance must be demonstrated, through performance testing and/or fuel analysis, by September 17, 2014.

Notification of Compliance Status Requirements

By July 19, 2014, facilities must submit a Notification of Compliance Status (NOCS) indicating that an initial tune-up and energy assessment, as applicable, were conducted.  The NOCS must be submitted through the Compliance and Emissions Data Reporting Interface (CEDRI) on U.S. EPA’s Central Data Exchange.  Templates of the NOCS for initial tune-ups, one-time energy assessments, and emission limitations have been provided by U.S. EPA.

Still have questions about the upcoming requirements?  Check out our webinar, leave a comment below, or contact me at cdoyno@all4inc.com or 678.460.0324 x204.