U.S.: It's All About the Fuel: New Emissions Standards for Boilers and Process Heaters
by Thomas R. Carey (Chicago), David A. Franchina (Charlotte), Ashley A. Peck (Seattle), and Christopher S. Walker (Charlotte)
On June 4, 2010, EPA published four proposed rules related to its regulation of emissions of hazardous air pollutants from new and existing industrial, commercial, and institutional boilers and process heaters and commercial and industrial solid waste incinerators ("CISWI") under the Clean Air Act.
Of the four rules, the rule clarifying which fuel types are not “solid waste” under the Resource Conservation and Recovery Act ("RCRA") may prove to have the greatest regulatory effect because it will dictate whether a particular combustion unit will be regulated as a boiler or under the more-stringent CISWI Rule.
Thus, the type of fuel used in a facility’s combustion units can have a large impact on a facility’s environmental compliance costs and should be considered in project, operation, and budget decision-making. This article provides an overview of the proposed rules and focuses specifically on facilities that combust two fuel types—natural gas and biomass.
