SOCMA: Inconsistencies in Boiler MACT Proposal Create Uncertainties

In comments submitted Aug. 23, (pdf) to the U.S. Environmental Protection Agency, the Society of Chemical Manufacturers and Affiliates (SOCMA) voiced strong concerns regarding the agency’s proposed National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers.

SOCMA Vice President of Government Relations Bill Allmond issued the following statement:

“As proposed, EPA’s Boiler MACT proposal would impose significantly higher costs on industry than EPA anticipates and be extremely burdensome to an already battered manufacturing sector. While most SOCMA members are regulated as area sources of hazardous air pollutants, some member facilities are major sources and would be subject to this proposed rule. Feedback from many of them indicates that some of the proposed emission limits are unachievable.

"Gas-fired units predominate among our members’ boilers, and so we support EPA’s decision to establish work practice standards in lieu of emission limits for certain gas-fired boilers. Those standards should apply to all gas-fired boilers. Moreover, some SOCMA members have dual-fuel units that can burn gas or oil, and thus the differentiating point between oil and gas-fired units is of great importance. But the way the preamble describes gas-fired boilers is contradicted in several places by the proposed regulatory definitions of gas and oil-fired units. One of those definitions also conflicts with the comparable definition in the proposed Area Source Boiler rule.

“Until EPA clarifies these inconsistencies, there will be uncertainties regarding major portions of the proposal’s impact on SOCMA members," Allmond concluded.

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