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Key Compliance Dates for Boilers Approaching

The compliance dates are approaching for the rule applying to minor HAP sources that operate boilers – referred to as the Boiler Area Source NESHAP, 40 CFR 63 Subpart.

– September 17, 2011 for Initial Notification
– March 21, 2012 for work practices
– March 21, 2014 for energy assessments
– September 17, 2014 for initial emissions testing (if subject to an emissions standard)

The dates above are for existing boilers (constructed on or before June 4, 2010). New boilers (constructed after June 4, 2010) must comply upon startup and meet a shorter testing schedule.

Emissions Standards and Work Practices:
New biomass and oil-fired boilers and new and existing coal-fired boilers with a heat input capacity of 10 MMBtu/hr or greater are subject to emission limits and initial and triennial stack testing. New and existing coal, biomass, and oil-fired boilers are subject to biennial tune-ups to minimize carbon monoxide emissions. Facilities with existing boilers of 10 MMBtu/hr or greater burning coal, biomass, or oil must conduct a one-time energy assessment. Boilers equipped with air pollution control devices are also subject to operating limits.

Facilities with Fuel Oil Backup Need to Choose a Category:
Boilers that are gas-fired (natural gas and/or propane) are exempt from the Area Source NESHAP; no initial notification or other requirements apply. The rule allows boilers equipped with backup fuel oil to retain gas-fired status as long as the fuel oil is burned only for curtailment, supply emergencies, and periodic testing. Burning liquid fuels due to availability or cost considerations would void the exemption.

Boilers changing from gas-fired to oil-fired would become classified as a new oil-fired boiler, subject to emission limits, stack testing, tune-ups, and the energy assessment. Boilers classified as oil-fired as of the initial notification date may be considered an existing source, not subject to an emission limit, only required to conduct tune-ups and possibly an energy assessment. Facilities with the capability of electively burning fuel oil should consider how they want to be categorized prior to the September 17, 2011 initial notification due date.

Facilities that determine not to electively burn fuel oil (i.e., only burning fuel oil for curtailment, emergencies, or testing), should retain adequate records demonstrating their exemption status.

The effectiveness of the rule applying to major HAP sources, the Boiler MACT, continues to be postponed until the EPA reconsideration process is complete. However, the Boiler Area Source NESHAP remains effective.

For More Information:
The rule is available here:  http://www.epa.gov/ttn/atw/boiler/boilerpg.html

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