What is the Boiler NESHAP? Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) What is the Boiler NESHAP? National Emission Standards for Hazardous Air Pollutants (NESHAP) This rule applies to Industrial/Commercial/Institutional Boilers at HAP Area Sources (<10 TPY Single HAP; <25 TPY Total HAP). Affects New and Existing Boilers that combust Oil, Coal and Biofuels Does Not Apply to Natural Gas or Propane Does Not Apply to Distillate Oil if used only during curtailment or emergencies (48 hours of annual testing allowed too). Applies to Existing Boilers at all four U of M Campuses January 31, 2014

What are the Boiler NESHAP Requirements? Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) What are the Boiler NESHAP Requirements? Notifications Start-up/Shutdown Procedures (Hg and CO, Coal Only) Emission Limits (Hg and CO, Coal Only) Performance Testing (Hg and CO, Coal Only) Boiler Tune-Ups (Oil and Biomass Only) Continuous Compliance (CEMS or O2 Trim System) Energy Assessment (All Affected Boilers) Recordkeeping / Reporting / Annual Certification January 31, 2014

Which University Boilers are Affected? Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Which University Boilers are Affected? UM – Crookston: Coal-Fired Boiler (Propane Boiler not Affected) UM – Duluth: All Boilers UM – Morris: Biomass Boiler (Selected Curtailment-Only for gas/oil units) UM – Twin Cities: Southeast: CFB and Boiler # 4 (coal) St. Paul: Boilers #1, 2, 5 and 6 (Coal Boilers excluded if permit limits usage to less than 10 pecent annual capacity factor; Selected Curtailment-Only for gas/oil units) January 31, 2014

What are the Boiler NESHAP Deadlines? Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) What are the Boiler NESHAP Deadlines? Initial Notification All January 20, 2014 Start-Up/Shutdown Procedures Coal March 21, 2014 Emission Limits Coal March 21, 2014 Performance Testing Coal Notification of Intent to Test 60 days before test Testing September 17, 2014 Test Report 60 days after test CEMS or O2 Trim System Coal Site-Specific Monitoring Plan 60 days before test Initial Evaluation September 17, 2014 Boiler Tune-Ups Oil/Biomass March 21, 2014 Energy Assessment All March 21, 2014 Notification of Compliance All Multiple Dates (later) January 31, 2014

Start-Up/Shutdown Procedures Coal March 21, 2014 Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Start-Up/Shutdown Procedures Coal March 21, 2014 Affects UM – Crookston and UM – Twin Cities Must Minimize Startup/Shutdown Must Follow Manufacturer Procedures or Similar Emission Limits do not Apply during Startup/Shutdown January 31, 2014

Emission Limits Coal March 21, 2014 Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Emission Limits Coal March 21, 2014 Affects UM – Crookston and UM – Twin Cities Carbon Monoxide (CO) as Surrogate for Organic HAPs: 420 ppm @ 3% O2 ;30-day rolling average Mercury (Hg) 22 lb/trillion BTU @ 3% O2 Fuel Sampling: Calculate effective emission rate from boiler data Current Compliance Status UM – Crookston: Untested for CO, Emission Factors indicate Compliance Weekly Hg Data indicates Compliance @ < 50% of Emission Limit UM – Twin Cities: All units tested for CO, indicate Compliance One fuel sample indicates Compliance with HG Limit

Performance Testing Coal September 17, 2014 Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Performance Testing Coal September 17, 2014 Affects UM – Crookston and UM – Twin Cities Carbon Monoxide (CO) as Surrogate for Organic HAPs: 420 ppm @ 3% O2 ;30-day rolling average Representative Operating Load, Worst-Case Fuel 3 Test Runs Mercury (Hg) 22 lb/trillion BTU @ 3% O2 Fuel Sampling during Testing Minimum 3 Samples per Test Run, 3 Test Runs (see above) January 31, 2014

Continuous CO Compliance Coal O2 Monitoring System Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Continuous CO Compliance Coal O2 Monitoring System Affects UM – Crookston and UM – Twin Cities May Monitor Either CO or O2 Oxygen (O2) as Surrogate for CO: May use Oxygen Trim System instead of CEMs Must Maintain O2 Levels at or above Tested Level (30-day rolling average) 3 Test Runs Mercury (Hg) 22 lb/trillion BTU @ 3% O2 Fuel Sampling during Testing Minimum 3 Samples per Composite, 3 Composite Samples January 31, 2014

Continuous CO Compliance Coal O2 Monitoring System Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Continuous CO Compliance Coal O2 Monitoring System Affects UM – Crookston and UM – Twin Cities May Monitor Either CO or O2 Oxygen (O2) as Surrogate for CO: May use Oxygen Trim System instead of CEMs Must Maintain O2 Levels at or above Tested Level (30-day rolling average) Must Evaluate Oxygen Trim System at time of Performance Testing Site-Specific Monitoring Plan Required 60 days before test January 31, 2014

Continuous Hg Compliance Coal Fuel Sampling Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Continuous Hg Compliance Coal Fuel Sampling Affects UM – Crookston and UM – Twin Cities Mercury (Hg) If Initial Test indicates < 50% of Emission Limit, no further testing unless switching coals. If Initial Test indicates > 50% of Emission Limit, Quarterly testing January 31, 2014

Tune-Ups Distillate Oil/Biomass March 21, 2014 Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Tune-Ups Distillate Oil/Biomass March 21, 2014 Affects UM – Duluth and UM – Morris Other Campus Gas/Oil Units: Curtailment/Emergency Only are not Affected Follow Tune-Up Guides and Forms Provided by EPA Before/After Testing Includes CO Measurements but may use hand-held analyzer Current Compliance Status UM – Duluth: Conducted test in 2012 UM – Morris: Has not conducted test (operational?) January 31, 2014

Energy Assessment All Units March 21, 2014 Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Energy Assessment All Units March 21, 2014 Affects Regulated Units at ALL CAMPUSES Level of Effort based on Thermal Input Capacity: UMM / UMC UMD UMTC NO ON-SITE ENERGY USE SYSTEMS ACCOUNT FOR THE THRESHOLD. ONLY IN-PLANT! January 31, 2014

Recordkeeping / Reporting All Units Boiler NESHAP Requirements for ICI Boilers at Area Sources 40CFR63 Subpart JJJJJJ (6J) Recordkeeping / Reporting All Units Initial Notification of Applicability (COMPLETED) Notification of Compliance Status: Tune-Ups: July 19, 2014 Energy Assessment: July 19, 2014 Performance Test / Emission Limits: September 17, 2014 (180 days after 3/21/14) Annual Compliance Certification March 1 each year, submit if requested Submit by March 15 if deviations. Recordkeeping All required reports, test data, fuel consumption, CMS data, certifications, etc… January 31, 2014