On August 5-6, 2013, EPA issued letters and a court filing indicating that it will reconsider certain portions of the Boiler MACT and the Boiler Area Source NESHAP. EPA received numerous requests to reconsider these rules and has agreed to grant reconsideration.
For the Boiler MACT, EPA has identified these issues for reconsideration:
- Definitions of startup and shutdown periods and the work practices that apply during such periods;
- Revised CO limits based on a minimum CO level of 130 ppm; and
- The use of continuous parameter monitoring systems (CPMS), including the consequences of exceeding the operating parameter.
For the Boiler Area Source NESHAP, EPA has identified these issues for reconsideration:
- Definition of startup and shutdown periods;
- Alternative PM limit for new oil-fired boilers burning low-sulfur oil;
- Establishing a limited-use boiler subcategory with its own set of limits;
- Eliminating further PM stack testing for boilers demonstrating emissions less than half the respective limit;
- Eliminating fuel sampling for coal-fired boilers that demonstrate initial compliance with the mercury standard using fuel analysis.
In addition to the issues listed above, EPA has indicated that it intends to clarify several requirements in the rules.
EPA’s letters and court filing are available:
Contact your EPS consultant for more information.