Saturday, December 3, 2011

Proposed Changes To Emission Standards For Boilers & Incinerators.

The U.S. Environmental Protection Agency (EPA) is proposing additional changes to Clean Air Act standards for boilers and certain incinerators. The proposed reconsideration would achieve significant reductions in toxic air pollutants, while increasing the rule’s flexibility and addressing compliance concerns raised by industry and labor groups. The changes also cut the cost of implementation by nearly 50% from the original 2010 proposed rule.

More than 99 % of boilers in the US are either operate cleanly enough that they are not covered by these standards or will only need to conduct maintenance and tune-ups to comply. The current proposed rules focus on the less than 1% of boilers that emit the majority of pollution from this sector. For these high emitting boilers, typically operating at refineries, chemical plants and other industrial facilities, EPA is proposing more targeted emissions limits and provide industry with practical, cost-effective options to meet the standards – informed by data from these stakeholders. These limits are based on currently available technologies that are in use by sources across the country.

Some of the key changes EPA is proposing include:

Boilers at large sources of air toxics emissions: The major source proposal covers approximately 14,000 boilers (less than 1% of all boilers in the United States) located at large sources of air pollutants, including refineries, chemical plants, and other industrial facilities. EPA is proposing to create additional subcategories and revise emissions limits. EPA is also proposing to provide more flexible compliance options for meeting the particle pollution and carbon monoxide limits, replace numeric emissions limits with work practice standards for certain pollutants, allow more flexibility for units burning clean gases to qualify for work practice standards and reduce some monitoring requirements. EPA estimates that the cost of implementing these standards remains about $1.5 billion less than the April 2010 proposed standards.

Boilers located at small sources of air toxics emissions: The proposal also covers about 187,000 boilers located at small sources of air pollutants, including commercial buildings, universities, hospitals and hotels. However, due to how little these boilers emit, 98% of area source boilers would simply be required to perform maintenance and routine tune-ups to comply with these standards. Only 2% of area source boilers may need to take additional steps to comply with the rule. EPA is proposing to require initial compliance tune-ups after two years instead after the first year.

Solid waste incinerators and revisions to the list of non-hazardous secondary materials: There are 95 solid waste incinerators that burn waste at a commercial or an industrial facility, including cement manufacturing facilities. EPA is proposing to adjust emissions limits for waste-burning cement kilns and for energy recovery units.

EPA is also proposing revisions to its final rule which identified the types of non-hazardous secondary materials that can be burned in boilers or solid waste incinerators. EPA has proposed revisions to clarify what types of secondary materials are considered non-waste fuels. The proposed revisions also classify a number of secondary materials as non-wastes when used as a fuel and allow for a boiler or solid waste operator to request that EPA identify specific materials as a non-waste fuel.

EPA is accepting public comment on the proposed standards for 60 days following publication in the Federal Register. EPA intends to finalize the reconsideration by spring 2012.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

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