ENV-15-12 Boiler MACT/CISWI Implementation

Description:

With so many other federal and state regulatory issues (Refinery MACT I, MACT II, NSPS Ja, NSPS Db) applying to refineries and chemical plants, the 40 CFR, Part 63, Subpart DDDDD NESHAP known as the Industrial, Commercial & Institutional Boiler & Heater MACT has brought additional financial and resource burden on most affected facilities, especially with regard to the requirements for one-time energy assessments and periodic tune-ups. While the January 2016 compliance date is fast approaching, many facilities have misunderstood how the Subpart DDDDD Rule applies to their specific facility and to which combustion sources the Rule applies. Of particular note, there has been wide disparity amongst facilities as well as consultants as to whether “reformers” are subject (or not) to the Rule causing debate at EPA, state environmental agencies, as well as at facilities throughout every EPA Region. Additionally, while waste heat recovery boilers are specifically exempted from the Rule, it is common to find CO/waste heat boilers included in a facility’s applicability determination. Other interpretive discussion revolves around the EPA definition of an oxygen trim system. EPA’s guidance on this subject has not been consistently applied leaving facilities with a decision as to whether their combustion unit (typically a boiler) does or does not have a true oxygen trim system, which in turn determines whether the source is subject to tune-ups annually or every five years.