The Wait Is Over; The New Boiler MACT Is Here
April 29, 2010 was a busy day for U.S. EPA and marked the culmination of months and years of background effort and planning related to air toxic emissions from boilers. U.S. EPA has released pre-publication versions of four (4) proposed rules on their website that, when finalized, will impact thousands of facilities. The proposed rules are all interrelated and will affect boilers and process heaters of almost every size throughout the country. Of the four proposed rules, two rules are intended to reduce emissions of toxic air pollutants from boilers and process heaters located at major sources of hazardous air pollutant (HAP) emissions (Boiler MACT rule), as well as area sources of HAP emissions (Area Source Boiler MACT/GACT rule). In the third rule, U.S. EPA has proposed to reduce toxic air pollutants from Commercial and Industrial Solid Waste Incinerators (CISWI).
The fourth proposed rule redefines the term 'solid waste.' This definition will potentially reclassify certain units currently considered to be boilers as CISWI units if the units burn a fuel that meets the proposed new definition of a solid waste. Each of the proposed rules can be viewed at: http://www.epa.gov/airquality/combustion/actions.html.
ALL4 recognizes that these proposed new rules will affect almost all of the regulated community and we have assembled an internal RegTech team of experts to analyze the impact that each of these rulemakings will have on boilers, process heaters, and CISWI everywhere. Due to the major implications that all 1,048 pages of the proposed rules could have on thousands of facilities, we are taking a 'slow and steady wins the race' approach. Our team strategy is to thoroughly review each of the proposed rules.
- Gain a clear understanding of their interrelationships.
- Determine the potential implications for the various industrial, commercial, and other types of entities impacted.
- Plan a course of action to support the regulated community with respect to the pending new regulations. That support will likely range from assisting with comment development on the proposals, to strategizing compliance approaches and alternatives, to assisting clients with specific facility plans and permit applications.
With a deadline for comment submittal of only 45 days after publication in the Federal Register, we recognize the importance of a timely and complete evaluation. We will keep you informed of our progress as we work through the details so be sure to stay tuned for more in-depth updates over the coming weeks in ALL4's 4 The Record and 4 The Record Extra.
If you are looking for additional clarification on specific areas of the proposed rules or if you have questions about how the proposed rules will affect your industry or your company, please do not hesitate to contact ALL4's John Egan at 610.933.5246 x14 (firstname.lastname@example.org). www.all4inc.com