On December 28, 2005, EPA published minor revisions to the Industrial Boiler MACT (IB-MACT) Rule, resulting from reconsideration of portions of the Health-based Compliance Alternatives (HBC) for total selected metals (TSM) and hydrogen chloride (HCl). Among the more notable changes are (1) the use of a weighted average stack height to determine look-up table values for sources with multiple affected units and (2) HBC alternatives now apply to all sources with an HCl and/or TSM limit, not just solid-fuel fired units.
The fact that the HBC methodology remains virtually unchanged is good news for many sources that are unable to meet the HCl emissions standard using either of the primary compliance options, as HBC represents the only other alternative to meet the new standard without control equipment upgrades. Note that since the revisions did not change the requirement to assume the conversion of all fuel-based chlorine as Cl2, any coal-fired unit that plans on using the fuel-based HBC approach for HCl will likely have to use the emissions-based HBC approach instead of fuel sampling (i.e., conduct stack testing for HCl and Cl2). Sources must submit eligibility requests to use HBC by 9/13/06. These sources will need to conduct stack testing and/or fuel testing to demonstrate eligibility. RMB recommends that such testing be conducted no later than July 2006 to allow adequate time to prepare the eligibility request.
[Note to the Electric Utility Industry: Many utilities tend to overlook IB-MACT applicability for some of their older coal-fired boilers. RMB estimates that there may be as many as 150 existing boilers at electric utility plants that are affected by IB-MACT. RMB recommends that utilities verify whether or not they have any affected units and then conduct preliminary fuel sampling to determine compliance options.]
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