Environmental Permitting

Boiler NESHAP for Area Sources: Energy Assessments

What boilers are subject to an energy assessment?
Existing boilers (i.e., those constructed or reconstructed on or before June 4, 2010) firing oil, biomass, or coal with a heat input capacity of 10 MMBtu/hr or greater located at area source facilities must conduct a one-time energy assessment.

What does the energy assessment include?
The energy assessment must be conducted by a qualified energy assessor and must include:

  • A visual inspection of the boiler system;
  • An evaluation of operating characteristics of the applicable boiler systems, specifications of energy-using systems, operating and maintenance procedures, and unusual operating constraints;
  • An inventory of major energy-use systems consuming energy from the applicable boiler and that are under the control of the boiler owner or operator;
  • A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage;
  • A list of major energy conservation measures that are within the facility’s control;
  • A list of the energy savings potential of the energy conservation measures identified, and
  • A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments.

If your facility has an annual boiler heat input of…

Then the onsite technical hours of the energy assessment need not exceed…

And should include any on-site energy use systems that account for the following energy production from these boilers…

<0.3 trillion Btu/year (TBtu/yr)

8 hours

At least 50%

0.3 to 1 TBtu/yr

24 hours

At least 33%

>1 TBtu/yr

24 hours for first TBtu/yr, +8 hours for every additional TBtu/yr, not to exceed 160 hours

At least 20%


Who must conduct the energy assessment?
The energy assessment must be conducted by a qualified energy assessor with the knowledge and demonstrated capabilities to evaluate energy savings opportunities for steam generation and major energy using systems.  The qualified energy assessor may be a company employee or an outside specialist.

When must the energy assessment be completed?
The energy assessment must be completed by March 21, 2014.  An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the aforementioned energy assessment requirements is valid, and in such instances the qualification requirements for the energy assessor are waived. In addition, a facility that operates under an energy management program compatible with ISO 50001 that includes the applicable boilers also satisfies the energy assessment requirement.

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.

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