1. 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

2. 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

3. 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

4. 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 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

5. 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

6. 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 3% O2 ;30-day rolling average
Mercury (Hg)
22 lb/trillion 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 < 50% of Emission Limit
UM – Twin Cities: All units tested for CO, indicate Compliance One fuel sample indicates Compliance with HG Limit

7. 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 3% O2 ;30-day rolling average
Representative Operating Load, Worst-Case Fuel
3 Test Runs
Mercury (Hg)
22 lb/trillion 3% O2
Fuel Sampling during Testing
Minimum 3 Samples per Test Run, 3 Test Runs (see above)
January 31, 2014

8. 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 3% O2
Fuel Sampling during Testing
Minimum 3 Samples per Composite, 3 Composite Samples
January 31, 2014

9. 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

10. 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

11. 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

12. 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

13. 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