Facility Boilers: Important Regulatory Deadlines Looming

National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Industrial, Commercial, and Institutional Boiler Owners (40 CFR Part 63 Subpart JJJJJJ)

On March 21, 2011, the U.S. Environmental Protection Agency (EPA) finalized the area source boiler generally available control technology (GACT) rule. This rule applies to certain industrial, commercial, and institutional boilers that are located at minor sources of hazardous air pollutants (HAPs) and affects boilers with heat input capacities greater than or equal to 10 MMBtu/hr. Natural gas boilers are exempt from this rule.

Existing facilities* subject to this rule are required to submit initial notifications established pursuant to the general provisions of 40 CFR Part 63, no later than September 17, 2011.

Mandatory Greenhouse Gas (GHG) Reporting Rule (40 CFR Part 98)

Owners and operators of facilities in certain source categories and those with more than 25,000 metric tons of carbon dioxide equivalent CO₂(e) emissions from fuel combustion are required to submit their initial GHG emission reports to U.S. EPA, no later than September 30, 2011. Reporting must be done with U.S. EPA’s reporting tool, e-GGRT.

*Existing as of May 20, 2011

HOW CAN O'BRIEN & GERE HELP?

Using its full-service capabilities, O’Brien & Gere can assist impacted facilities by evaluating GACT compliance options and designing and constructing the recommended technical solution. O’Brien & Gere’s compliance, permitting, and source testing experts can support the additional monitoring, record keeping, and reporting obligations applicable to affected sources. The Company’s certified energy managers can perform the required energy assessments and boiler tune-ups, offering clients the opportunity to move toward a sustainable energy platform.

If you need assistance in meeting these requirements or evaluating their applicability to your operations, please contact O’Brien & Gere for more information at info@obg.com.