The Boilers NESHAP Deadlines Are Fast Approaching
Updated: Aug 28
(Regulation: 40 CFR Part 63, Subpart DDDDD, Effective Date: September 13, 2004, Compliance Deadline: September 13, 2007)
Overview: The Boilers NESHAP requires maximum achievable control technology (MACT) for Industrial, Commercial, and Institutional Boilers and Process Heaters. The Boilers NESHAP affects a wide range of industries due to the varied applications of the machinery under regulation.
The regulation is applicable to major sources of hazardous air pollutants (HAPs), defined as having the potential to emit at least 10 tons per year of any HAP, or 25 tons per year of a combination of HAPs. Emissions from the entire facility, including non-boiler or process heater sources, count toward major source status.
Equipment that is subject to the regulations includes boilers that produce steam or hot water and process heaters that are used to transfer heat indirectly to a process material.
Boilers and process heaters are grouped by their size as well as the type of fuel used. Below is a table that briefly summarizes what is regulated.
*Constructed or reconstructed after January 13, 2003.
Modifications since final rule: Recent modifications (December 6, 2006 Federal Register notice) address issues raised related to emissions averaging, stack testing on boilers vented to a common stack and modify some definitions
What you need to be working on now: Affected sources must be in compliance with all requirements of the Boilers NESHAP by September 13, 2007, so there are only a few months left. You should be in the final stages of equipment selection, installation and start-up. There are specific compliance requirements for continuous emission monitoring systems, fuel selection, fuel analysis, and performance tests. Initial performance tests must be complete by March 2008. However, it is a good idea to complete some form of performance testing prior to the compliance date to ensure compliance.
In addition, you should be developing the compliance systems (startup, shutdown and malfunction (SSM) plans, monitoring, and recordkeeping) necessary to ensure equipment is operated and maintained per the regulation.
For further information or assistance on The Boiler NESHAP, please contact us. In addition, review the information on EPA’s web-site.