The proposed Industrial Boiler MACT Rule, which is expected to significantly influence the pending utility boiler MACT rule, is a complex rule that includes a number of source categories and the various emission limits. The proposed rule is simply not well done and sets new, and troublesome precedents in a number of areas. For example, the proposed rule contains not only emission limits but associated work practice and operational restrictions that greatly limit boiler operational flexibility. The rule does not recognize compliance margin during the initial performance test. Even if the source is emitting well below the emission limit, the rule restricts future operation of the control devices to those conditions (or better) that exist at the time of the test. The recordkeeping and reporting requirements of the proposed industrial boiler MACT rule are also burdensome and costly and mandate a staggering amount of unnecessary data. A copy of the proposed Industrial Boiler MACT is available from our FTP Library.
RMB Consulting &