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I have a boiler and an air permit, do I have to comply with the NESHAP 6J boiler MACT?

Whether you have to comply with the National Emission Standards for Hazardous Air Pollutants (NESHAP) 6J boiler Maximum Achievable Control Technology (MACT) depends on whether or not you are considered an area source and the size of your boiler. 

An area source is defined as a Hazardous Air Pollutant (HAP)-emitting stationary source that is not a major source. Most galvanizers are area sources. Major sources have Title V air permits or a significant minor permit. This rule applies to all existing and new industrial boilers, institutional boilers, and commercial boilers located at area sources.

 Boilers are defined as enclosed combustion devices having the primary purpose of recovering thermal energy in the form of steam or hot water. The industrial boiler source category includes boilers used in manufacturing, processing, mining, refining, or any other industry. Boilers that burn any liquid fuel and are not in either the biomass or coal subcategories are considered oil boilers. 

This final rule on boilers requires an energy assessment for all existing boilers with a heat input capacity of 10 MMBtu/h or greater and clarifies the definition of energy assessment with respect to the requirements of Table 3 of this final rule. This final rule requires if you own or operate an existing source subject to a work practice or management practice standard of a tune-up, you must comply with this final rule no later than March 21, 2012. If you own or operate an existing source subject to an emission limit or an energy assessment requirement, you must comply with this final rule no later than March 21, 2014. 

Based on the information available to the agency, the boilers subject to this area source rule use predominantly coal, oil, or biomass as a combustible material. The boilers subject to this rule may combust non-hazardous secondary materials that do not meet the definition of solid waste pursuant to the rule of subtitle D of Resource Conservation and Recovery Act (RCRA). A boiler located at an area source burning any secondary materials considered solid waste would be considered a solid waste incineration unit subject to regulation under CAA section129. 

Having the background information, now you can determine whether you must comply with NESHAP 6J Boiler MACT

  • Yes: If you are an area source AND your boiler is greater than 10 MMBtu/Hr AND uses >15% coal, biomass or liquid fuel you must comply with NESHAP 6J boiler MACT.
  •  No: If you are not an area source OR your boiler is smaller than 10 MMBtu/hr OR if your boiler burns natural gas, then you do not have to comply with NESHAP 6J boiler MACT.

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