Major Source Boiler MACT Report Due January 31, 2017

So it’s time to complete your first Boiler MACT compliance report. What exactly does that mean?  It means that’s just one more thing for you to do in January! (Hint: we can help, contact me.)  The report must be submitted via U.S. EPA’s Compliance and Emissions Data Reporting Interface (CEDRI) located on U.S. EPA Central Data Exchange (CDX) platform.  CEDRI is a web-based application used for the electronic reporting of various reports required by both Standards of Performance for New Stationary Sources (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPs), codified at 40 CFR Parts 60 and 63, respectively.  If you have not previously used CEDRI, you will need to make sure that you allow enough time to register.  U.S. EPA has provided a number of helpful tools to assist facilities with registering with CEDRI for the first time, including this video.

CEDRI learning curve aside, you will need to gather some data from the reporting period.  Whether you are submitting the compliance report under 40 CFR §§63.7550(c)(1), (2), (3), or (4) (more on these later), you’ll need to gather information on the source relating to emissions/operating limitations, operating time, and records of tune-ups and/or fuel analyses.  In addition, you may also need to gather information relating to deviations from limitations, malfunctions of the source, control device, or continuous monitoring system (CMS), and information relating to startup and shutdown periods.  Several examples of specific pieces of information required (depending on applicability) include:

• Type(s) and amount(s) of fuel used during the reporting period
• CMS downtime and reasons for downtime
• Corrective action performed on malfunctioning equipment
• Date, time, and description of each deviation
• Date and time of each startup/shutdown event and fuels fired during those times

Information such as fuel use, CMS downtime, and malfunctions must be submitted in a specific format, and U.S. EPA has developed Excel templates for this information to facilitate the reporting process.  Other types of information, such as tune-up records, and startup/shutdown details, do not have a prescribed format.  Once complete, the compliance report must be signed and submitted by a responsible official.

As promised, let’s discuss those four reporting provisions.  One or more out of four total possible reports must be submitted depending on your compliance method as follows:

• §63.7550(c)(1) – Tune-Ups
• §63.7550(c)(2) – Fuel Analysis
• §63.7550(c)(3) – Performance Testing
• §63.7550(c)(4) – Continuous Monitoring Systems

Each citation specifies what type of information is required for each report.

January is already a busy reporting month, so don’t wait to start compiling your data and developing your reports.  Contact me at kturney@all4inc.com or 610.933.5246 x143 or Lindsey Kroos at lkroos@all4inc.com or 610.933.5246 x122 to discuss your compliance methods and reporting obligations in more detail.