{"id":6927,"date":"2012-11-01T00:00:00","date_gmt":"2012-11-01T00:00:00","guid":{"rendered":"https:\/\/insulation.org\/io\/articles\/understanding-the-boiler-mact-regulation-for-area-and-major-sources\/"},"modified":"2017-06-09T20:25:15","modified_gmt":"2017-06-09T20:25:15","slug":"understanding-the-boiler-mact-regulation-for-area-and-major-sources","status":"publish","type":"articles","link":"https:\/\/insulation.org\/io\/articles\/understanding-the-boiler-mact-regulation-for-area-and-major-sources\/","title":{"rendered":"Understanding the Boiler MACT Regulation for Area and Major Sources"},"content":{"rendered":"

Rarely is it that a specific environmental regulation
\nbecomes so high profile as the recent Industrial Boiler Maximum Achievable
\nControl Technology (Boiler MACT) regulation, which has been the subject of
\nmyriad bills that have come before the U.S. Congress. The Boiler MACT has been
\ncited as a clear division point between the two major political parties in the
\nUnited States, with the ultimate fate of facilities to be determined within
\nmonths after the election in November 2012. The political back and forth has
\nled to a limbo status for the major source regulation?with “major source”
\ndefined by the U.S. Environmental Protection Agency (EPA) as “a stationary
\nsource or group of stationary sources that emit or have the potential to emit
\n10 tons per year or more of a hazardous air pollutant [HAP] or 25 tons per year
\nor more of a combination of hazardous air pollutants.” This regulation will be
\ncritical for those in the insulation trade: insulation is critical for
\nindustrial boilers and process heaters as it is employed for the reduction of
\nheat loss and the increase of boiler efficiency; and it is one method of
\nreducing emissions outlined in the Boiler MACT regulation, potentially lowering
\nfuel costs and usage by enhancing the boilers’ steam system insulation.<\/span><\/p>\n

The many recent changes to the Boiler MACT standards have
\nleft industries confused and unsure of the reporting, testing, monitoring, and
\nfurther compliance measures that must be taken to operate within the standards.
\nIn 2011 and 2012, the EPA released extensive revisions to the National Emission
\nStandards for Hazardous Air Pollutants (NESHAPs). The standards are divided
\nbetween 40 CFR Part 63 Subpart JJJJJJ for affected “area sources”?defined as
\n“any stationary source that is not a major source” ?and 40 CFR Part 63 Subpart
\nDDDDD for major sources, as defined by the respective air permits of the
\nfacilities. Of the units affected by the regulation, the most rigorous emission
\nlimits are assigned to those boilers and process heaters employing coal,
\ndistillates, and biomass as fuels.<\/span><\/p>\n

The regulations have had a bumpy recent history. A version of
\nthe Boiler MACT standards was released in April 2010 and received over 4,800
\ncomments from businesses and communities, some of which led to a change in
\nproposed subcategories and emission limits. In turn, the EPA published the
\nregulation into the Federal Register on March 21, 2011. The current final form
\nof the standard under Subpart JJJJJJ (with proposed amendments) was published
\nto the Federal Register on May 18, 2011. On March 13, 2012, the EPA issued a No
\nAction Assurance Letter for area sources. The EPA determined that further
\npublic review was required for Subpart DDDDD and in May 2011, under the
\nauthority of the Administrative Procedure Act, announced a delay of effective
\ndates of standards for major sources. On January 9, 2012, the U.S. District
\nCourt for the District of Columbia, in Sierra Club versus Jackson, vacated the
\nEPA’s administrative stay of the Boiler MACT, thus making the March 2011 major
\nsource standard effective. On February 7, 2012, the EPA issued a No Action
\nAssurance Letter for major sources. Currently, the EPA proposes to issue the
\nfinal rule before the compliance dates for existing sources.<\/span><\/p>\n

The current Boiler MACT standards divide facilities’ boilers
\ninto subcategories defined by boiler type, capacity, and fuel type. Based on
\nthis information, a source must meet emission limits, work practice standards
\n(including tune-ups and energy assessments), and operating limits, and\/or
\ndemonstrate initial\/regular compliance. Whether the facility is considered to
\nbe new or existing also will determine if it is subject to the varying work
\npractice standards and requirements. Sources also are considered new if they
\nswitch from one fuel to another (primary or secondary) that is applicable under
\nthe regulation. Below are some critical facts regarding the current Boiler MACT
\nstandards, how they may apply, and what impact they could have for your
\nfacility.<\/span><\/p>\n

Area
\nSource Requirements <\/span><\/b><\/p>\n

Area
\nsource requirements (40 CFR Part 63 Subpart JJJJJJ) affect facilities with the
\npotential to emit less than 10 tons per year (tpy) of any single HAP, and\/or
\nless than 25 tpy of combined HAPs. These regulations affect sources with
\nboilers defined as existing, new, or reconstructed.<\/span><\/p>\n

This rule covers boilers burning coal, oil, biomass, or
\nnon-waste materials, but not solid waste as fuels. This also includes natural
\ngas-fired boilers if they use fuel oil as a backup. All other propane or
\nnatural gas-fired boilers are exempt from the area source regulations. Also,
\ndepending on status and fuel type, there are emission limits for mercury,
\nparticulate matter (as a surrogate for non-mercury metals), and carbon monoxide
\n(as a surrogate for organic air toxics). <\/span><\/p>\n

Another aspect of this subpart critical for existing sources
\nis timing for compliance. All area sources considered subject to JJJJJJ were
\ninitially required to comply with emission limits or an energy assessment by
\nMarch 21, 2014, and work practice standards by March 21, 2012. A Notification
\nof Compliance to work practice standards (including a boiler tune-up) is due to
\nthe EPA by July 19, 2012. However, under the No Action Assurance Letter, the
\nEPA extended the compliance and notification dates for initial tune-ups after
\nseveral deliberations (and many companies already achieving the preliminary
\ncompliance date). Facilities have been granted a No Action Assurance by the
\nUSEPA. This does not require subject facilities to meet the originally-stated
\ncompliance deadline of March 21, 2012. It should be recognized that biennial
\ntune-ups must be conducted no more than 25 months after the previous tune-up.<\/span><\/p>\n

For new sources, compliance must be achieved upon commencement
\nof operations. This includes submittal (within 30 days after operation of
\nsubject equipment begins) of a Notification of Compliance Status to these
\nstandards. If you are required to conduct performance tests, you are obligated
\nto submit a Notification of Compliance to the EPA within 60 days of completing
\nthe performance test. Tables are included below to provide a basic overview of
\nwhat needs to be completed to meet the area source standard for boilers. <\/span><\/p>\n

Major Source
\nRequirements<\/span><\/b><\/p>\n

Major
\nsource requirements (40 CFR Part 63 Subpart DDDDD) affect facilities with the
\npotential to emit greater than or equal to 10 tpy of any single HAP, and\/or
\ngreater than or equal to 25 tpy of combined HAPs. This rule includes boilers
\nand process heaters burning natural gas, fuel oil, coal, biomass (e.g., wood),
\nrefinery gas, or other gas to produce steam. Unlike Subpart JJJJJJ, Subpart
\nDDDDD also includes natural gas\/propane\/clean fuel boilers. The requirements
\ncontain subcategories with very specific requirements. Of the roughly 14,000
\nmajor source boilers and process heaters in the United States, 88 percent are
\nrequired to conduct annual or biennial tune-ups; and 12 percent are required to
\nmeet emission standards if those standards are not already met. New and
\nexisting natural and refinery gas units are subject to tune-ups every 2 years,
\nregardless of operating rate. Other affected boilers are subject to limits on
\nemissions of mercury, dioxin, particulate matter, hydrogen chloride, and carbon
\nmonoxide, based on fuel type or combustion. Unfortunately, at the time of the
\ncompletion of this article, the final rule was not yet published. Therefore,
\nsome of this information may change and should be confirmed before proceeding.
\nNew proposals may see changes in the finalized version of the rule, to be
\npublished later in 2012 or early 2013. Much of the outcome of this regulation
\nis seen to be determined by the outcome of the November 2012 presidential and
\ncongressional elections.<\/span><\/p>\n

Additional
\nCompliance Considerations<\/span><\/b><\/a><\/p>\n

For
\nall subject facilities, both major and area source, certain boilers also must
\ndemonstrate continuous compliance through stack testing, continuous monitoring,
\nrecordkeeping, and reporting. In addition, facilities must submit initial
\nnotification and a Notification of Compliance Status within several months
\n(exact numbers and dates will be solidified and included in finalized
\nstandards). For area sources, an Annual Compliance Certification report is due
\nby March 1 of each year. Recordkeeping requirements can include permits,
\ncontinuous monitoring data, deviation reports, fuel use, performance test,
\nenergy assessment reports, tune-up documentation, stack test data, and any
\nsite-specific monitoring plans.<\/span><\/p>\n

It is critical to check with your state regulatory agency
\nbefore rushing to comply with some of these area source regulations. For
\ninstance, in Indiana, a facility would not necessarily be subject to the
\nregulation if that facility has boilers that primarily run on natural gas, with
\nfuel oil as a backup fuel source. The exemption applies if you use fuel oil at
\nany time other than in a period of curtailment or during periodic testing (less
\nthan 48 hours within a 12-month period). A period of curtailment refers to any
\ntime when gas is cut off and it is beyond a facility’s control (e.g., during a
\nnatural disaster). If a facility in Indiana has an air permit and this is not
\nexplicitly stated in that permit, it may be wise to pursue a permit
\nmodification stating that fuel oil is a backup fuel used strictly during periods
\nof curtailment or during periodic testing. While this specific regulatory
\nnuance applies to Indiana, individual state regulatory agencies should be
\nconsulted to see if a similar detail may be applicable to your facility.<\/span><\/p>\n

A large point of concern for many facilities, both major and
\narea sources, is the prospect of completing an energy assessment by March 21,
\n2014. An on-site energy assessment consists of the following major points, to
\nbe conducted by a qualified energy assessment professional:<\/span><\/p>\n

 <\/span><\/p>\n

– A visual inspection of boiler or
\nprocess heater system<\/span><\/p>\n

– An evaluation of operating
\ncharacteristics of the facility, specifications of energy-using systems,
\noperation and maintenance (O&M) procedures, and any unusual operating
\nconstraints<\/span><\/p>\n

– Inventory of major on-site
\nenergy-consuming systems using energy generated by the subject boiler(s)<\/span><\/p>\n

– Review of architectural and
\nengineering plans, facility O&M procedures, logs, and fuel usage<\/span><\/p>\n

– Review of facility energy
\nmanagement practices and recommendations for improvement<\/span><\/p>\n

– List of major energy
\nconservation measures<\/span><\/p>\n

– List of energy savings potential<\/span><\/p>\n

– Report detailing ways to improve
\nefficiency, cost of specific improvements, benefits, and time frame for
\nrecouping investments<\/span><\/p>\n

 <\/span><\/p>\n

There are three primary types of energy assessment. For
\nfacilities that use less than 0.3 trillion Btu per year heat input, an 8-hour
\nassessment is required. Facilities using 0.3-1 trillion Btu per year heat input
\nrequire a 24-hour assessment. The boiler systems accounting for 33 percent or
\nmore of the affected boilers’ energy output will be evaluated to identify
\nenergy savings opportunities discovered through a 24-hour energy assessment. A
\n24-hour energy assessment is an energy assessment that spans 24 technical hours
\nof a boiler\/process heater in operation at a facility. Finally, for those
\nfacilities using over 1 trillion Btu per year heat input, a 24-hour assessment
\nis needed. The boiler systems accounting for 20 percent or more of the affected
\nboilers’ energy output will be evaluated to identify energy savings
\nopportunities discovered through a 24-hour energy assessment.<\/span><\/p>\n

There are many subtleties to these
\nregulations, and not everything is encompassed in this article. Also, there are
\nslight changes for these regulations on the horizon, including the number of
\nexemptions that exist for boilers at certain facilities. Clarifications and
\nadditional information will be provided in a future article in 2013.<\/span><\/p>\n

 <\/span><\/p>\n

\n
<\/a>Figure 1<\/b><\/div>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

Rarely is it that a specific environmental regulation becomes so high profile as the recent Industrial Boiler Maximum Achievable Control Technology (Boiler MACT) regulation, which has been the subject of myriad bills that have come before the U.S. Congress. 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