Boiler MACT Compliance: Meeting National Emissions Standards for Hazardous Air Pollutants
The EPA Finalizes its Adjustments to Clean Air Act Standards
Earlier this year the EPA finalized its adjustments to the Clean Air Act standards and issued a rule imposing stricter emissions limits on industrial and commercial boilers, process heaters for boilers, and certain solid waste incinerators. This rule, known as Boiler MACT (Maximum Achievable Control Technology), was written in an effort to reduce hazardous air pollutants (HAPs) and to protect the stratospheric ozone layer.
Boilers use a variety of fuels, including coal, oil, natural gas and biomass, and are used to power heavy machinery and provide heat for industrial processes. The burning of fossil fuels (e.g. gas, coal, oil, etc.) introduces carbon dioxide into the atmosphere, which has been linked to poor air quality, the overall rise in average temperature (climate change), health concerns, and increased incidents of unpredictable and sometimes devastating weather events. As part of the effort to reduce HAPs, the EPA has mandated one-time energy assessments for all existing major source boilers and area source boilers (oil, biomass and coal-fired) with a heat input capacity of 10 MMBtu/hr or greater.
Commercial and Industrial Owners May Need to Comply With Boiler MACT
Boiler MACT incorporates changes for both area source boilers (40 CFR 63, subpart JJJJJJ) and for major source boilers (40 CFR 63, subpart DDDDD). A major source is a facility that emits greater than 10 tons per year of a single hazardous air pollutant (HAPs) or greater than a total of 25 tons per year of HAPs. An area source is a facility that emits less than 10 tons per year of a single HAP or a total of 25 tons per year of HAPs. Boilers at refineries, chemical plants, and other industrial facilities are typically large sources of air toxic emissions and are often major source boilers. Whereas, boilers located at universities, hospitals, hotels and commercial buildings are typically area source boilers, emitting less hazardous air pollutants.
The adjusted standards require only the largest and highest-emitting units to add pollution controls or take steps to reduce air pollution. However, owners of commercial or industrial properties with existing boilers with a heat input capacity of 10 MMBtu/hr or greater will need to have their boilers evaluated through a formal energy assessment. The energy assessments need to be conducted by a qualified energy assessor and includes an audit of the boiler system (ie. boiler components, combustion air systems, fuel systems, etc.) and any systems using energy produced by affected boilers (ie. process heating, compressed air systems, hot water systems, etc.). The EPA predicts that this legislation will affect an estimated 180,000 existing area source boilers, as well as approximately 6,800 new boilers over the initial 3-year period.
Scope of Boiler MACT Energy Assessments
According to the new EPA guidelines, assessments must be performed by a qualified energy assessor by March 21, 2014 for area source boilers and by January 31, 2016 for major source boiler systems. Assessments will verify whether affected boilers meet Clean Air Act limits for HAPs, and will serve as a vehicle by which organizations can identify retrofits and upgrades critical for compliance. Assessments will entail, but are not limited in scope to, the following:
- Inspection of the boiler system;
- Evaluation of system specifications;
- Evaluation of operating and maintenance characteristics/procedures;
- Inventory of major energy-consuming system components;
- Review of architectural and engineering plans;
- Review of annual fuel usage;
- Determination of major energy conservation measures and associated savings potential;
- Production of a comprehensive report detailing the recommended energy efficiency improvements.
Keep in mind that the MACT Compliance does not apply to all boilers. See links below to learn more, or contact SourceOne to understand whether Boiler MACT applies to you.
With more than thirteen years of experience in the energy industry, Shaun Selha, LEED AP, DCEP, is the Director of Energy Systems at SourceOne, a nationally recognized energy management consulting firm and a subsidiary of Veolia Energy North America. Mr. Selha manages and oversees the Energy Systems and Energy Efficiency Groups at SourceOne and is responsible for a wide range of projects, including renewable energy, electrical/mechanical engineering design, testing and commissioning for new and modified critical power systems, and energy assessments. Mr. Selha is a LEED Accredited Professional, a Data Center Energy Practitioner, and he holds an MBA from New York University and a Master of Science and Bachelor of Science degree in Mechanical Engineering from Boston University.
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