Many facilities have replaced their aging boiler systems with new high efficiency boilers. Why? There are several reasons:
1) Newer boilers are more energy efficient, reducing costs for heating & cooling buildings.
2) Because of the higher efficiency, a facility can reduce the number of units that they need to operate, which lowers the cost of new equipment installations.
3) Becoming a more sustainable facility by reducing their carbon footprint and lowering their potential emissions with equipment that has a greater combustion efficiency.
However, if you replaced the old clunker boilers, you must also consider what environmental air permits may be needed for the units you are considering purchasing. One of the highest and most frequent violations of New Jersey Air Pollution Codes is a failure to obtain an air permit to construct and certificate to operate installed equipment. In New Jersey, any combustion equipment with a heat input rating greater to or equal to 1 million BTUs, requires an air permit to construct and certificate to operate. However, you may have options as to what type of air permit would be required. There are two type of air permits in New Jersey; Preconstruction permits (PCPs) and General Permits (GPs).
A General Permit is a pre-approved permit and certificate which applies to specific significant source equipment. The registration for a General Permit satisfies the requirements of NJDEP air regulations for a permit to construct and certificate to operate. There are three different types of General Permits for boilers:
- Boilers each greater to or equal to 10 million BTUs/hr and less than 50 million BTUs/hr
- Boilers each greater than or equal to 5 million BTUs/hr but less than 10 million BTUs/hr
- Boilers Each less than 5 million BTUs/hr
Each of these general permits has specific facility requirements that must be complied with, such as monitoring and record keeping, fuel consumption and boiler operating hours per year, federal regulatory requirements (NSPS), notification requirements and stack height.
The fee for a five (5) year General Air permit is $ 885.00. That contrasts with a Preconstruction Air Permit (PCP) fee of $2,730.00 plus $ 640.00 for additional pieces of equipment for the same five (5) year approval period.
When would you need a PCP air permit? Here are some reasons.
- Boilers with a heat input rating of over 50 million BTUs/hr
- Boilers firing a non-commercial fuel
- Boilers with fuels with the potential to emit (PTE) Group 1 or 2 toxic air pollutants at a rate greater than 0.1 lbs/hr. The listing of these toxic air pollutants is listed in the NJDEP Air regulation NJAC 7:27-8
NOTE: All air permit applications (GPs and PCPs) must be applied for using the NJDEP Radius program and submitted electronically via NJDEP portal.
Now that your new air permits for your new Boiler equipment have been approved, You need to become familiar with the facility specific requirements that are included. Read your approved air permit/certificate very carefully and not just file it away. These facility requirements advise you of any monitoring, recording or recordkeeping requirements that must be completed. Another very frequent violation of an approved air permit is the failure to conduct Annual Combustion Adjustments (ACA) on the boiler.
These ACA tests include a measurement of the Nitrogen Oxides (NOx), Carbon Monoxide (CO) and Oxygen (O2) levels in the boiler exhaust prior to any maintenance (such as adjustment of boiler flame patterns) on the boiler and a final measurement of NOx, CO and O2 after any maintenance is completed.
Another frequent violation of air permits/certificates is the failure to electronically submit the ACA data to the NJDEP via their web portal.
These Boiler tests are to be conducted in the same month for each following year. The data is then uploaded to the NJDEP Online Portal and submitted after being certified by the person with direct knowledge of the ACA adjustment and the facility responsible official.
Once the ACA is submitted electronically it will be in the NJDEP database and you will have satisfied the ACA requirement for that year. You do need to keep a copy of the ACA data at your facility for a minimum of five (5) years. There may be other facility specific requirements listed in your air permit/certificate such as the notification of startup of the new boiler equipment to EPA Region 2 in accordance with federal NSPS standards, Amount of sulfur in fuels, hours of boiler operation, conduct an initial opacity or conduct stack emission tests. This is why it is imperative to become familiar with the facility specific requirements and what you need to comply with the boiler permit. Failure to not comply with any of the facility specific requirements would subject the facility to enforcement actions, which could include significant monetary penalties.
At enviroCOP we are here to help you with your permitting and compliance concerns, let us know if you have a compliance concern that needs our help! If you have any questions, contact us today at www.enviroCOP.com or by calling (609) 304-9662.