The National Association of Manufacturers and ten other trade associations today filed a reconsideration petition on the Boiler MACT suite of rules, urging the Environmental Protection Agency (EPA) to “get it right” on the rules affecting the largest emitting boilers (MACT), smaller emitting boilers (GACT) and the solid waste incinerator (CISWI) portions of the regulation.* The petition highlights specific problems with the achievability of the rule that are still of major concern to manufacturers. If unresolved, these damaging provisions will hurt manufacturers’ competitiveness causing additional job loss in today’s tough economy.
Specifically, these issues include:
- the establishment of dioxin/furan emission limits that relied on a small amount of data that are largely below detection limits;
- the achievability of many of the new source limits, the solid fuel particulate matter, CO, and dioxin/furan new source limits; and
- improperly revised definitions which could reclassify boilers – already subject to MACT standards – as solid waste incineration units.
In addition to this reconsideration petition, the NAM and other manufacturing groups also submitted a Petition for Administrative Stay on April 27 which urges the EPA to stop the rule from taking effect while the reconsideration process continues. The stay, if granted, would provide manufacturers with the certainty they need to make business decisions pending the final outcome of the reconsideration of the rule.
* MACT – Maximum Achievable Control Technology
GACT – Generally Achievable Control Technology
CISWI – Commerical / Industrial Solid Waste Incinerators