With so much talk of boilers and heaters since the 4 Rules were published in early 2013, most facilities are focused on developing an understanding and strategy to comply with the Maximum Achievable Control Technology (MACT) standards for Boilers (commonly referred to as Boiler MACT).
However, one of the 4 Rules is the Commercial and Industrial Solid Waste Incineration (CISWI) rule, and facilities may want to consider this rule as a compliance alternative to Boiler MACT. The CISWI rules are codified at 40 CFR Part 60, Subpart CCCC for new, modified, or reconstructed units (i.e., New Source Performance Standards) and Subpart DDDD for existing units (i.e., Emission Guidelines).
This concept of choosing to be regulated under the CISWI regulations may not be as far-fetched as one might think. In fact, from an emission limit, fuel flexibility, and timing perspective, a case can be made that some boilers could be better off regulated under CISWI rather than Boiler MACT. Let’s look at the following five (5) considerations when deciding whether to go down the CISWI path or the Boiler MACT path:
- Fuel flexibility
- Compliance schedule
- Compliance requirements
- Emission limits
- Public perception