Trinity Consultants

Preparing for Boiler MACT Compliance



This 1-day course is for industrial corporate and facility environmental personnel responsible for facilities with boiler or process heaters. The course covers regulatory requirements for industrial, commercial, and institutional boilers and process heaters located at area and major sources of HAP emissions, as well as the NSPS for commercial and industrial solid waste incineration units (CISWI). Includes case studies, group exercises, and discussion of lessons learned at existing facility Boiler MACT compliance analysis for new units already subject to the rules.

Course attendees learn about:

  • Boilers and process heaters subject to NESHAP Subpart DDDDD or NESHAP Subpart JJJJJJ
  • How to determine if material meets the definition of Non-Hazardous Secondary Materials (NHSM) and whether NHSM are classified as solid waste or fuel
  • Compliance options for units subject to emission limits regarding monitoring, testing, fuel analysis, and operational limitations
  • Work practice standard requirements including tune-ups and energy assessments

Course Topics

  • Background on HAP Regulation
  • Evolution of MACT, GACT, CISWI Rules
  • Applicability, Exclusions, Exemptions
  • Emissions Limits
  • Work Practice Standards
  • Testing and Monitoring Requirements
  • Fuel Analysis Requirements
  • Establishing Operational Limits
  • Malfunction Affirmative Defense
  • Monitoring, Recordkeeping, Reporting
  • SSM Requirements
  • Categorizing Waste Burned as a Fuel

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