Frequently Asked Questions
Major Source Vs. Area Source
Step-by-Step Compliance Guide
Victory Energy Perspectives
Victory Energy Viewpoint - Boiler MACT
Compliance Best Practices
The following are the best practices that Victory Energy is noting as being employed as it relates to Boiler MACT Compliance. Many are viewing Boiler MACT as the impetus to look
at everything in and around their boiler room operations, not only from a compliance consideration but also from an operations effectiveness and efficiency perspective.
1. Understand the Fit and Implications against the Final December 2012 Boiler MACT Standards.
Much has changed over the course of getting to the final standards. Specific emission limits are more achievable and affordable. many commercial and industrial boilers were take out of the mix based on the fuel fired.
2. Going Beyond Just Boiler MACT Compliance. Reviewing All Boiler Room Strategies.
Many are using Boiler MACT as the motivation to review performance and operational methodologies of their boiler room strategies. It offers the opportunity
to think about all the boilers in operation in a broader sense. It's elevating the importance of boilers in the overall operations plan methodologies.
3. Seeking Out Subject Level Experts
Boiler MACT is a complicated subject complete with a significant amount of technical requirements. Companies are increasingly engaging with Boiler MACT subject level experts who can help them navigate the myriad of requirements, ensuring that they're compliant in 2014 for Area Source and 2016 for Major Source.
4. Using Trusted Boiler Manufacturers and Suppliers.
The most often referenced resources are the boiler manufacturers themselves. They design, manufacture and supply the boiler and boiler-related emission control and combustion equipment for compliance with the Boiler MACT rules. Victory Energy is well positioned to be a great resource of vast information on Boiler MACT.
5. Defining a Boiler MACT Strategic Approach and Timeline for Compliance and Beyond for the Operation.
2016 is still a long way off; However, the best operations are those that are proactively seizing on Boiler MACT to establish a strategic platform and timeline for not only achieving total compliance but also enhancing the efficiency and effectiveness of their boilers. They're going beyond mere compliance to viewing Boiler MACT as an opportunity to outline the budget and resource requirements for maximum operational efficiency.
6. Developing a Tight Boiler MACT Compliance Implementation Plan.
Boiler MACT is broad reaching with many different elements. The best entities are those that have a tight implementation plan in place that covers every nuance and consideration as it relates to ensuring compliance and avoiding fines.
Victory Energy Boiler MACT Compliance Tips
The following are helpful tips and insights from Victory Energy for implementing the optimum Boiler MACT compliance methodology and plan:
♦ Fully understand any and all of your Boiler MACT implications throughout your organization.
Factor in the most recent Boiler MACT standards that were issued.
♦ Create your own Boiler MACT methodology by developing a strategic document -
"How Boiler MACT Applies to Us" - that outlines specific actions.
♦ Develop a Boiler MACT expectations plan to determine what you ultimately want to come out
of achieving Boiler MACT compliance in 2012. Outline how Boiler MACT can be used to your
advantage to help improve the operation.
♦ Complete a tight timeline plan (complete with budget and resources) for
♦ Tap into external thought leaders for third party validation - most notably for EPA guidelines
♦ Use Victory Energy for support and counsel. We're experiencing and learning about many
diverse Boiler MACT compliance situations and applications. We're rapidly becoming subject
level experts. You can tap into this information base as well as our experience and expertise in
the manufacture and service of boilers and boiler-related equipment that will be an integral
element in Boiler MACT compliance requirements.