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Industrial Boiler MACT Update (12/01/04)

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Industrial/Commercial/Institutional Boilers and Process Heaters, also known as the "Industrial Boiler MACT," was published on 9/13/04 in the Federal Register and became effective on 11/13/04. Existing sources must comply by 4/13/07 and new sources must comply with the new rule within six months of the effective date or six months after startup, whichever is later. The only existing boilers or process heaters that are affected are solid fuel-fired units with a heat input rating greater than 10 mmBtu/hr and "limited use," solid fuel-fired units that operate less than 10% of capacity.

The final rule contains a variety of compliance provisions for emissions of carbon monoxide (CO), hydrogen chloride (HCl), mercury (Hg) and "total selected metals" (TSM). Sources subject to a TSM standard may comply with an alternative particulate matter (PM) standard. Sources are able to comply with the emissions standards either based on stack emissions or fuel sampling. For sources that demonstrate compliance based on stack emissions, the rule also includes CAM-like monitoring requirements of the control device and prescriptive reporting and recordkeeping requirements.

The impact of the rule for existing sources will depend largely on whether the source is able to meet the new standards using the fuel-based compliance option. Sources that burn a relatively consistent fuel or fuel blend that can demonstrate compliance based on fuel analysis will likely find that the rule will have minimal impact. However, new sources and existing sources that are unable to demonstrate compliance based on fuel analysis will likely find the rule to be very costly to implement. RMB estimates that as many as half of all existing sources will be unable to demonstrate compliance using the fuel-based compliance option. These sources will have to conduct ongoing, expensive stack tests and meet prescriptive monitoring, reporting and record keeping requirements.

RMB recommends that sources start early in addressing the requirements of the new rule. The Industrial Boiler MACT is a complex rule that will require careful analysis of potential compliance options, performance testing, installation of new or upgrades to existing CEMS/COMS hardware, and development of new reporting and record keeping procedures. Some sources may also need to install control device(s) to meet the new limits. While the three year (four years for sources that need to install control devices) implementation schedule may seem like a long time, many sources will need most of this time to address the requirements of the rule. As a first step, RMB recommends that existing sources conduct an initial fuel "evaluation" to determine the applicability of the less cumbersome fuel-based compliance approach. This will essentially determine the impact of the rule and enable the source to plan for the more rigorous compliance requirements of the stack-emission based compliance option, if necessary.

CAM and the Industrial Boiler MACT. The Industrial Boiler MACT does not automatically exempt sources from the monitoring requirements of EPA’s Compliance Assurance Monitoring (CAM) Rule. CAM applicability will depend on the MACT compliance strategy for TSM and the manner in which the new PM limit is incorporated into the operating permit. It is quite possible that many sources will be affected by both rules for PM emissions. In this case, sources should consider the compliance strategy for both rules simultaneously. This may enable some sources to reduce the overall costs associated with monitoring plan development and implementation. Please contact Rob Barton at (919) 791-3129 or barton@rmb-consulting.com for more information.

A copy of the Industrial Boier MACT rule is available from our FTP Library.

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Last Revised: February 22, 2005