Developing a Boiler NESHAP Compliance Strategy

The deadlines for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for industrial, commercial, and institutional boilers and process heaters at major sources (40 CFR 63, Subpart DDDDD) and boilers at area sources (40 CFR 63, Subpart JJJJJJ) loom ahead. Affected units at area sources of hazardous air pollutants (HAPs) must be in compliance by March 21, 2014 and units at major sources of HAPs must be in compliance by January 31, 2016.  Facilities with sources affected by these rules should develop compliance strategies and plans to achieve compliance prior to the rule compliance deadlines.Compliance photo

If a facility has units that are subject to the boiler NESHAP and has not started developing a strategy and plan for compliance with this regulation, the following steps may be helpful for developing a strategic plan for compliance with the rule requirements.

  1. Review and digest the regulations. Find resources that help explain the rule requirements such as the Table 1 summary of the rule requirements.
  2. Consider external resources needed to support the compliance process. If additional equipment is needed, contact control equipment or monitoring equipment vendors. Does the facility need consulting assistance to help evaluate rule requirements or outside assistance for the energy assessment? (for more details, see Developing an Energy Management Strategy) Can you utilize resources from government entities (e.g. Department of Energy)? Does the facility need to hire a stack testing company?
  3. Assess the applicability and coverage of the regulations.  Confirm the source classification for the facility (major source or area source of HAPs). Inventory the boilers that are onsite and determine their construction dates, fuels, control devices, and use profiles (limited, seasonal, or year-round). Document the specific rule provisions applicable to each unit.
  4. Assess the feasibility of complying without capital expenditures or changes.  For units with emission limits, compile existing data, including fuel analyses and past stack test data. Evaluate available compliance options, including any alternative monitoring options.  Assess the feasibility of the fuel sampling option and arrange to conduct test fuel sampling to see if your fuel conforms to the standards. Assess the feasibility of complying through a performance test and arrange any engineering studies, as needed, to assess whether fuels can comply   with the fuel analysis option and/or if the unit can comply with the emission limits.
  5. If changes are needed at the facility, begin a strategic assessment.  Identify the options available for compliance with each emission limitation, including changes to control equipment, monitoring options, boiler shutdown or replacement, fuel switching, and other alternatives. A different compliance method may be determined for each pollutant (i.e. stack testing for pollutant A, fuel analysis for pollutant B, CEMS for pollutant C). Conduct an economic analysis and a risk analysis for each option. Based on the analyses, select a compliance option, including control and monitoring options, for each pollutant.
  6. Develop a detailed action plan through the compliance date.  Ensure that all required steps to compliance are included and can be completed prior to the compliance date. This should include: 
    • Initial notification
    • Equipment procurement, construction, and operating schedules for monitoring equipment and/or control equipment
    • Air permitting for any changes (i.e. fuel switching, control equipment, etc.)
    • Execute verification pre-testing as needed
    • Develop monitoring plans (if required)
    • Schedule performance test and submit performance test notification
    • Conduct initial tune-up and energy assessments (if required
    • Once performance test and other initial compliance activities are completed, submit notification of compliance status
  7. Create systems to manage ongoing compliance obligations. Add tasks to the existing compliance management system or environmental management system to include all continuous compliance requirements. This includes planning and scheduling future fuel sampling and performance tests, developing monitoring equipment plans and scheduling maintenance activities, managing and documenting startup and shutdown, developing program to maintain compliance with malfunction obligations, scheduling future tune-ups, ensuring control device maintenance activities are planned and documented, and preparing annual compliance reports.

Compliance Table1