Products & Services
Catalytic Products International eNews - January 2012
Expert Insight: Boiler MACT Regulations
Richard Trzupek, Principal Consultant, Mostardi Platt Environmental
EPA continues to move forward with sweeping regulatory changes – sort of. The Agency published the latest, and presumably last, version of the Boiler MACT regulations the Federal Register on December 23, 2011.
This is a significant step, because publication in the Federal Register officially starts the clock on the required sixty day comment period. The comment period thus closes on February 21, 2012. EPA must then respond to all of these comments before it issues the final rule. Since there will surely be thousands of comments, it will take EPA a while to respond, meaning that the final rules will likely go into effect sometime in March or April, barring any other complications.
However, the appearance of such complications is far from unlikely. Legislative and judicial actions could delay implantation of the Boiler MACT rules in their current form. On the legislative front, the House version of the latest budget bill passed in December included language that would have delayed implementation of Boiler MACT. Ultimately, the compromise version of the Senate bill did not include pushing Boiler MACT back, but that doesn’t mean that legislative action is dead. Since the latest budget bill is a short term fix, it’s likely that Boiler MACT will again be the subject of discussions on the Hill.
There’s a good chance that judicial action could come into play as well. Large manufacturing organizations, like the Council of Industrial Boiler Owner s (CIBO) and the National Association of Manufacturers (NAM) are very much opposed to the Boiler MACT rules. Many industrial advocates believe that implementation of these rules will result in significant job losses in the United States. While that belief is not sufficient, in and of itself, to prompt judicial intervention, it is a strong motivator to seek such action. Industry groups are thus going every step of the rulemaking process and every provision of the rules to see what might serve as a basis for judicial action.
Judicial action recently came into play with regard to another rule: the Cross State Air Pollution Rule (CSAPR). On December 30, the United States Court of Appeals for the D.C. Circuit stayed implementation of CSAPR pending judicial review of the rule. This does not mean that CSAPR is dead, only that EPA cannot implement the rule until the court decides whether or not it should die.
The stay means that the Clean Air Interstate Rule (CAIR) goes back into effect. Affected sources have been living with CAIR for a while, so that’s not a big deal on the face of it, but there will be complications at the state level. Some states dismantled their CAIR programs in anticipation of CSAPR taking CAIR’s place in 2012. With CAIR dead, these states will either have to scramble to put CAIR back in place or leave state level CSAPR rules in place and assert that those rules meet CAIR requirements.
At its website, EPA says that it will do everything it can to make the transition back to CAIR as smooth as possible. This may be so, but this latest regulatory battle further emphasizes the degree of regulatory uncertainty that American businesses are dealing with as they try to plan for future capital expenditures.
WHAT IS BOILER MACT?
This really refers to two rules designed to regulate emissions of Hazardous Air Pollutants (HAPs) from boilers. There is the major source Boiler MACT which covers large boilers that emit more than 10 tons per year of a single HAP or 25 tons per year of all HAPs. Area source Boiler MACT covers boilers that do not emit that level of HAPs.
CSAPR vs CAIR
Both CSAPR and CAIR are trading programs that affect fossil fuel fired emissions units. Both programs focus on emissions of sulfur dioxide, nitrogen oxides and fine particulate matter. There are many subtle differences, but the biggest is in terms of scope. The two programs are focused on the eastern half of the country, but CSAPR covers more facilities in more states than CAIR does.
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According to The Progress News, the new Pennsylvania bill would:
According to the Denton Record-Chronicle, these new regulations in Texas would:
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