Kristine Gilbert

Background:

The US Environmental Protection Agency (EPA) published new boiler rules on March 21, 2011, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Sources: Industrial, Commercial, and Institutional Boilers (also known as Area Source Boiler MACT) found at 40 CFR Part 63 Subpart JJJJJJ.

On March 21, 2011, EPA also published a rule affecting boilers at major sources (the Major Source Boiler MACT) and amendments to the Commercial, Industrial, Solid Waste Incinerators rule affecting boilers that burn any solid waste. On May 18, 2011, EPA stayed the Major Source Boiler MACT and Solid Waste Incinerator rule amendments. The Area Source Boiler rule is still in effect.

Which boilers are affected?

Boilers that burn coal, oil, biomass (example: wood), or other solid and liquid non‐waste materials AND are located at area source commercial (as in  laundries, apartments and hotels)’  institutional (as in schools, churches, medical centers, municipal buildings), or industrial (as in manufacturing, refining, processing, mining) facilities. In addition, 63.11194(d) also states that a boiler is a new affected source, if the fuel source was changed from natural gas to solid fossil fuel, biomass, or liquid fuel after June 4, 2010.

The following units are NOT subject to the Area Source Boiler rule:

• Any gas-fired boiler. If your boiler burns gaseous fuels (e.g., natural gas, process gas, landfill gas, coal-derived gas, refinery gas, hydrogen, or biogas) not combined with any solid fuels, or if your unit burns liquid fuel only during periods of gas curtailment, gas supply emergencies, or periodic testing it is a gas-fired boiler.*
• Hot water heaters with a capacity of no more than 120 U.S. gallons and pressures not exceeding 160 pound-force per square inch gauge (psig), and all controls necessary not to exceed a temperature of 210°F (90°C)
• Waste heat boilers, also known as heat recovery steam generators (these boilers recover traditionally unused energy and convert it to usable heat)
• Boilers that are used as control devices for other NESHAP standards, where at least 50 percent of the heat input to the boiler is provided by the NESHAP regulated gas stream
• Research and development boilers
• Boilers subject to other NESHAP standards, Section 129 standards, or hazardous waste boilers.

What is an area source?

An area source is any source that is not a major source. A major source is a facility that emits, or has the potential to emit (in the absence of controls), at least 10 tons per year (TPY) of individual hazardous air pollutants (HAP) or 25 TPY of combined HAP.

When do you have to submit  Initial Notification (§63.9(b)(2))?

Existing sources: No later than September 17, 2011.  (To be consider an “existing source” your facility must have commenced construction or reconstruction of the boiler on or before June 4, 2010.)

New sources: No later than September 17, 2011, or within 120 days after start-up of a new source, whichever is later. (To be considered  “new source”  your facility must have commenced construction or reconstruction of the boiler after June 4, 2010 and you meet the applicability criteria at the time you commence construction.)

For additional  information, visit the EPA   boiler page:  http://www.epa.gov/ttn/atw/boiler/boilerpg.html

* It is important to note that periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year in order to maintain your status as a gas-fired boiler. if at any time the boiler burns fuel outside of the period of natural gas curtailment OR for greater than 48 hours per year, the boiler will then be considered a NEW fuel oil burner and subject to the requirement of PM testing every 3 years.

Press Release:  New Employee

For immediate release

Contact Kristine Gilbert, 610-559-8776

July 22, 2011, Easton, PA-

Avogadro Environmental is proud to announce and welcome Ed Burgher as the company’s Business Development Manager.  Ed’s primary focus will be on developing and maintaining business opportunities with existing and new customers.

 Ed complements the consulting and measurements teams at Avogadro bringing more than 25 years of diversified experience in the environmental regulatory compliance and environmental measurements industry.  He has held positions in the sales, marketing, development and management of products and services used in the environmental measurements industry. Ed also has many years of experience as an industrial compliance manager and as an environmental consultant helping clients address their air quality measurement needs.  Ed’s body of work includes managing the development, marketing and sales of products used for measuring black carbon and particulate matter in ambient air and source emissions atmospheres and providing training programs for operations, maintenance and calibration of instrumentation used in the measurement of aerosols, particulate matter and black carbon.  He experience includes hands-on development, implementation and management of continuous emission monitoring programs for rotary kiln and fixed hearth hazardous waste incinerators and hazardous waste tank treatment processes.  His expertise also includes directing hazardous waste treatment, mining and construction aggregates facility air and air-related hazardous waste permitting and compliance programs.  Working for clients in the petrochemicals, chemicals, glass, paper and power generation industries, Ed has performed hundreds of performance and system audits of ambient air and meteorological monitoring programs. 

 Ed holds a B.A. in Chemistry from Western Connecticut State University and an A.A.S. in Natural Resources Conservation, Dutchess Community College.  He is a member of Air and Waste Management Association, The American Association for Aerosol Research and The Source Evaluation Society. 

 “I am delighted and honored to join a strong, positive team dedicated to making Avogadro “The Best Choice” for assisting customers in meeting the significant challenges posed by today’s complex environmental regulatory requirements.

 George Wagner, President of Avogadro Environmental states, “We are very excited to welcome Ed to our team at Avogadro.  His years of direct, hands-on experience in many phases of the environmental measurements business will further propel us to our goal to be the services provider that unfailing delivers at and above our customers expectations.”

 ___________________________________________________________________________________________

 Avogadro Environmental is a full-service Environmental, Health and Safety consulting and testing firm, headquartered in Easton, Pennsylvania.  Our fields of expertise include Air Monitoring & Testing, technical support services for Continuous Emission Monitoring Systems and Continuous Opacity Monitoring Systems as well as professional consulting services for compliance management issues.  Avogadro’s staff of professionals is dedicated to provide accurate scientific data to enable the preservation of our environment and natural resources and identify the most cost effective and innovative solutions to meet our customers needs.

For more information of Avogadro Environmental’s services, please visit our website www.avogadro.net

Kristine Gilbert

Avogadro Environmental is proud to announce the launch of our newly redesigned website.

The new website offers many new features including navigational enhancements, increased interactivity, and overhauled content. We have also worked hard to improve the aesthetics of the website.

Social networking is becoming the standard for staying connected online. Avogadro is dedicated to keeping up with these trends.  Please follow us on Linkedin.

Several additional features include:

• Quick and easy navigation to each of Avogadro’s divisions.
• Client access portal to download reports…no more clogging up email servers!
• Interesting news and blog articles (updated frequently…be sure to visit often!)
• Quick access to our CEMS Parts department  and CEMS Emergency Services 24/7 toll free hotline.
• New quote and information request interface.
• Navigation via easy to use drop down menus or site search box.
• Interesting news and blog articles updated frequently…be sure to visit often!
• Download or sign up for our informative newsletter, The Avogadro Advisor.

The launch of our new website is not the finish line for us; we continually improve the programs and services that we provide our clients and visitors.  We want you to see why our clients say we are the Best Choice!

Effective March 2012, new and existing boilers under 10 MMBtu/HR at major sources are required to conduct boiler tuning every other year.  Many owner/operators already have tuning arranged as a periodic maintenance item, especially with the rising costs of fuels.  Maintain those records as compliance records going forward.  Other work practices include conducting start up and shut down in accordance with manufacturer’s guidelines or other documented procedures.  Many owner/operators have copies of manufacturer’s O&M manuals, but haven’t looked at them in years.  Get it out, dust it off, or download another copy off the Internet.  Review it with your operational staff and document any regular deviations.  These will become an inspect item in the future should you get visited by USEPA and/or state agencies implementing this rule.

Until now, many boiler owner/operators have not closely followed manufacturer’s guidelines in O&M Manuals, often for good reason.  Equally so, tuning information never makes it into the environmental folder in the file cabinet.  Times are changing.  Your work practices for boilers new and old are now subject to more scrutiny and inquiry by people who likely won’t know much about your equipment.   What are your plans?  Give us some feedback!