May 05, 2016
By:
Walter G. Wright
Category:
Arkansas Environmental, Energy, and Water Law
Arkansas Environmental, Energy, and Water Law
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Jesslyn Hale of Trinity Consultants undertook a presentation at the April 12th Arkansas Environmental Federation Air Seminar titled Major Source Boiler MACT: 2016 Action Items (“Presentation”).
Ms. Hale’s Presentation addressed a number of issues associated with the Clean Air NESHAP Act Major Source Boiler Maximum Available Control Technology (“MACT”) requirements.
The Presentation addressed:
- Boiler MACT Recent Timeline
- Initial Compliance Test
- Notification of Compliance Status
- Compliance Report
- Records
The Records portions of her Presentation provided suggestions in terms of documents that should be maintained including those associated with the boiler process heater.
“Common Pitfalls” were identified which included:
- Forgot to complete Energy Assessment or Tuneup for Gas 1 Boiler
- Forgot about the 60 day notification for performance test
- No operating parameter strategy/planning before day of performance test
- Don’t have all required records during ADEQ inspection
- Don’t have Startup Shutdown Plan if applying definition (2) of “startup” in §63.7575.
Click here to download a copy of the Presentation.
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