AGA Comments on Major Source Boiler MACT Proposed Rule (Feb. 21, 2012)
On Feb. 21, 2012, AGA filed comments on EPA's proposed revisions to the hazardous air pollutant standards for industrial and commercial boilers and process heaters.
First, our comments strongly support EPA s proposal to apply a work practice standard (calling for regular tune-ups) for natural gas-fired boilers at major sources, rather than an emissions limit. This is appropriate, because EPA s data for natural gas-fired units show the overwhelming majority of emissions to be below the level that can be accurately quantified by the available test methods.
Second, we ask EPA to clarify whether residential-style appliances are exempt only when located in "dwellings" - e.g. on a college campus - or also when located in an office building or utility service center.
Third, we thank EPA for removing misleading comments about the availability of natural gas supply and for adding a definition of "curtailment" that excludes situations where a commercial or industrial customer chooses an interruptible contract in order to pay a lower rate for gas service.