The compliance date for the Boiler MACT is January 31, 2016, but facilities should be preparing now. Facilities that are subject to emissions limits (solid fuel and liquid fuel boilers) are likely well under way in their compliance plans, including emissions and fuels testing and monitoring equipment installation. But, facilities that only burn natural gas (with or without fuel oil for curtailment and testing) should also be preparing. Much of the work to comply with the Boiler MACT will need to be completed in 2015; therefore, facilities may need to make budgetary plans this year to include:
- Determine if elective fuel oil firing is a possibility in the future – natural gas costs may rise making fuel oil more attractive. If facilities want this option, engineering stack testing and fuel testing should be conducted to assess compliance.
- Identify a “qualified energy assessor” and obtain a quote for the one-time energy assessment.
- Locate a contractor and obtain a quote to perform boiler and process heater tune-ups.
- Re-check your process heater list to make sure you have not missed any subject units, ask “How is this process heated? Indirect or direct-fired?”.
The Boiler MACT has been remanded back to EPA to address reconsideration of several aspects of the rule. However, the rule has not been vacated, and there is no current indication that the compliance date will be changed (but that is a possibility).
Questions? Contact your EPS consultant.