Environmental Permitting

Boiler NESHAP for Area Sources: Are You Ready?

To whom does the boiler NESHAP for area source apply?
Area sources are commercial, institutional, or industrial facilities that emit or have the potential to emit less than 10 tons per year (tpy) of a single HAP, or less than 25 tpy of combined HAPs.  Area sources that may have boilers subject to the NESHAP could include laundries, apartments, hotels, schools, churches, medical centers, municipal buildings, manufacturing facilities, and other industrial operations.

What are the NESHAP requirements for area source boilers?
The NESHAP for area source boilers requires applicable boilers to comply with:

  • Emissions limits for particulate matter, mercury, and carbon monoxide based on the type and age of boiler, the heat input capacity, and the fuel type;  
  • Work practice or management practice standards, including boiler tune-ups and energy assessments, which again vary based on the type and age of boiler, the heat input capacity, and the fuel type; and
  • Operating limits based on the methods used to demonstrate compliance with the applicable emissions limits.

What are the important upcoming dates to know?
Sources subject to the standard should mark their calendars with the following dates:

  • January 20, 2014 or within 120 days after a new source (i.e., those constructed or reconstructed after June 4, 2010) becomes subject to the NESHAP: initial notification must be submitted to the appropriate regulatory agency.
  • March 21, 2014: existing boilers (i.e., those constructed or reconstructed on or before June 4, 2010) must be in compliance with emissions limits and work practice or management practice standards, including tune-ups and energy assessments
  • July 19, 2014: a notification of compliance status must be submitted to the appropriate regulatory, unless a stack test is required then the notice must be submitted within 60 days following the completion of the stack test.

In addition, any new boiler started up after May 20, 2011 is required to be in compliance upon startup.

Additional Resources:

Timothy P. Fagan is a Legal Editor for BLR’s environmental publications, focusing primarily on air quality related topics. Mr. Fagan has covered environmental developments with BLR since 2000. Before joining BLR, he spent 5 years in environmental consulting and was responsible for air quality permitting and compliance for a broad range of industries in both the private and public sector. He received a Bachelor of Science degree in chemical engineering from Villanova University and a Master’s degree in environmental engineering from the Pennsylvania State University.