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The EPA recently changed the regulations controlling air emissions from certain types of boilers located at "area sources" with the Boiler Area Source Rule (40 CFR Part 63 Subpart JJJJJJ). An area source is any source that is not a major source. A major source is a facility that emits (or has the potential to emit) at least 10 tons per year of individual Hazardous Air Pollutants (HAP) or 25 tons per year of combined HAP. The deadlines for Area Source compliance are in effect now, however, as of 5/2011, the deadlines for Major Source compliance are delayed until determined by EPA. Most schools will fall under the area source designation, and will need to consider/complete the following steps in order to comply:

Step 1. Determine whether your boiler is covered by the Boiler Area Source Rule

Affected boilers burn coal, oil, biomass, or other solid and liquid non-waste materials AND are located at area source Institutional, Commercial, or Industrial (ICI) facilities. Examples:

  • Oil, coal, & biomass fueled boilers less than 10 MMBtu/hr.....are covered by this rule.
  • Oil, coal & biomass fueled boilers greater than or equal to 10 MMBtu/hr.....are covered by this rule.
  • Gas-fired (all types) boilers.....are NOT covered by this rule
  • Gas-fired (all types) boilers that have an oil tank back-up.....are NOT covered by this rule....."a gas-fired boiler that periodically fires liquid fuels during gas curtailment and supply emergencies or for periodic (not to exceed 48 hours) testing is still considered a gas-fired boiler".

Step 2. If covered, submit a required "Initial Notification" by September 17, 2011

Below is an Initial Notification form that you may use. We were just recently made aware of this requirement and the deadline has passed, however, you should submit your Notification form as soon as possible!

Step 3. If covered, comply with the rule Emission Requirements

These requirements vary depending upon your boiler fuel type, construction date and size. The chart on page 2 of the attachment: Boiler NESHAPS EPA Rule Summary will provide you with a summary of the requirements (I can also assist with helping you to determine which requirements you will need to comply with).

Step 4. If covered, comply with rule Compliance Dates

A few key dates:

  • For Existing Sources - perform Tune-Up by 3/21/12; complete Emission Limits -and- Energy Assessment by 3/21/14.
  • For New Sources - Tune Up/meet Emission Limits by 5/20/11 or upon start up, whichever is later.

Step 5. If covered, comply with rule Report Requirements

These reports will be kept on file and only submitted to EPA upon request:

Boilers NOT subject to Emission Limits - prepare a Compliance Certification Report by March 1st of every 2nd year.

Boilers subject to Emission Limits - prepare a Compliance Certification Report by March 1st of each year. (if your boiler had any deviations from an emission limits or operating parameter, then prepare and submit the annual report by March 15th)

Step 6: If covered, comply with rule Records Requirements

Some of the requirements for recordkeeping:

  • Record the types and amount of fuel used each month.
  • Record that you have conducted start-ups and shut-downs according to the manufacturer's recommended procedures.
  • Maintain records of all required notifications and reports, with supporting documentation.
  • Maintain records that demonstrate compliance with emission limits, operating limits, tune-ups, and the energy assessment.

For additional information, click here.

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