Are temporary boilers subject to the Boiler MACT? The National Emission Standards for Hazardous Air Pollutants: Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63 Subpart JJJJJJ) is commonly referred to at the “Boiler MACT” were finalized by US EPA in January 2013. For facilities with boilers and process heaters that are subject to the Boiler MACT, an initial notification must be submitted not later than January 14, 2014, and affected sources will need to be in compliance with the MACT requirements. Therefore, facilities need to determine what boilers and process heaters need to be included in their initial notification.
Temporary boilers have been exempted from regulation under the Boiler MACT. Temporary boilers are any gaseous or liquid fuel boiler that is designed to, and is capable of, being carried or moved from one location to another by means of, for example, wheels, skids, carrying handles, dollies, trailers, or platforms. A boiler is not a temporary boiler if any one of the following conditions exists:
- The equipment is attached to a foundation.
- The boiler or a replacement remains at a location within the facility and performs the same or similar function for more than 12 consecutive months, unless the appropriate regulatory authority grants an extension. Any temporary boiler that replaces a temporary boiler at a location and performs the same or similar function will be included in calculating the consecutive time period.
- The equipment is located at a seasonal facility and operates during the full annual operating period of the seasonal facility, remains at the facility for at least 2 years, and operates at that facility for at least 3 months each year.
- The equipment is moved from one location to another in an attempt to circumvent the residence time requirements of this definition.
Caltha LLP provides expert technical support to facilities to determine applicability of the Boiler MACT and other air regulations, and to develop a cost effective Boiler MACT Compliance Plan. Caltha also has certified Energy Auditors who meet the EPA qualification requirements for a Qualified Energy Assessor as defined under the Boiler MACT.