Facility Management: Top 5 Environmental Compliance Issues for Engineers and Managers

Is this how you would describe your week?

Coordinate and prepare for inspections – why do the Fire Marshal and your Manager both have to visit tomorrow?
Trouble-shoot why that one suite is always too cold.
Oversee a multitude of staff, contractors, and vendors.
Work late to assess flooding at one of your buildings and to calm a frustrated, displaced tenant.
Listen patiently as yet another person tells you about a light out on Floor 4.
Return to the office Saturday morning to catch up on emails and paperwork.

Based upon my experience providing air quality compliance support and managing multi-media environmental projects for commercial real estate companies, healthcare facilities, and others, the property management and building operations & maintenance fields are not for the faint of heart. Facility engineers and property managers, perhaps such as yourself, are required to multi-task daily, keeping everyone satisfied with limited resources. Your tasks also include a wide-range of environmental considerations, but the trick is to be aware of them early enough, instead of playing catch-up after a deadline has passed or equipment has been installed. No one wants an uncomfortable encounter with their supervisor or a regulator!

Here are the top five environmental compliance issues that I have seen impact facility engineers and property managers in various industries:

1. Air Quality – It’s more than mold.

Your facilities probably have at least one piece of fuel burning equipment, such as an emergency generator, hot water heater, or boiler. When it was installed, your contractors obtained permits such as building permits and pressure vessel permits – but how about an air quality construction permit from your state or local environmental agency? Many times the need to obtain an air permit is overlooked or the necessity is simply not realized prior to the installation of new equipment or replacement of an existing unit with a similar unit. All too often on a capital improvement project, preparation of the air permit application is an afterthought, which has the potential to cause construction delays or result in monetary penalties. As not all equipment requires an air permit and regulatory thresholds vary by state, projects should be reviewed case-by-case to evaluate permitting requirements, aggregation of new and existing sources, the potential need for control equipment, and applicable Federal requirements (even if permitting is not required). In most instances, there’s probably at least one requirement, such as recording the reason for operation for your generator. Early consideration of air permitting requirements is one critical aspect to a successful project and a hard-learned lesson by many facilities. But air regulations don’t stop there…requirements around asbestos and refrigerants are two more air compliance areas that can catch facilities by surprise. Stay tuned to future blogs for more details!

2. Oil storage tanks – Nothing below ground, I’m good to go.

Heaven forbid there is a pin-hole leak in that aboveground storage tank – you know, the one you’ve been meaning to deal with, but haven’t had the time or funds to relocate it away from the floor drain and/or obtain secondary containment. What about that smelly waste cooking grease container out behind the kitchen? Is your staff prepared to immediately address a spill and do they know who to call in the event of an incident? Often times the answer is “no” and this is one area in particular where the local, State, and Federal requirements can differ substantially for both your aboveground and underground oil storage tanks. And for the aboveground tanks, be aware that it’s not always the environmental regulators who handle the permitting, such as in the District of Columbia, where the Fire and Emergency Medical Services Department is in charge of registration of tanks. How about any tanks located on your property that are owned/operated by another company? Depending upon the situation, these other tanks may need to be included in the storage tank capacity assessment for the property, and together they may trigger the need for a Spill Prevention, Control and Countermeasures (SPCC) Plan. Based upon a variety of factors, oil storage tanks may need a state registration and/or operating permit, and don’t forget to look into your local fire code regulations– some localities require a flammable and combustible liquid storage permit, which your tank installer may have addressed, but this requirement has been overlooked on more than one project I’ve encountered.

3. Chemicals – Do they really matter?

As the owner/operator of an office building or hotel, you may think you don’t have much in the way of hazardous substances. What about your tenant(s)? The hazardous substances in the janitorial closet or the swimming pool likely won’t trigger any reporting requirements, but what about the diesel fuel for your generators and the chemicals in those lead-acid batteries? For healthcare facilities, if that doesn’t make you subject, perhaps one of the myriad of toxic chemicals stored might, so check with your materials management folk to ensure they know what you use. Some people may assume that the Emergency Planning and Community Right-to-Know Act (EPCRA) is only applicable to industrial facilities; however, any facility is subject if it is required under the Occupational Safety and Health Administration (OSHA) regulations to perform hazard communication for chemicals stored or used in the workplace and also exceeds specific regulatory thresholds that would trigger reporting.

4. Hazardous waste – Do you know what you signed?

Did you see what happened to those pesticide containers left behind by the contractor? Those expired chemical products in your storage area – how will you get rid of them? Hazardous waste is another area that requires special attention as this type of waste is managed “cradle to grave” and there are many ways to misstep in this regulatory minefield. Proper notification, storage, reporting, labeling, training, inspections, and disposal requirements are all part of your potential waste management responsibilities. Knowing whether your facility is subject to the hazardous waste rules and if so, accurately determining your generator status, are the first steps since requirements vary based upon the determination. Chances are you generate used oil from maintenance operations, replace lamp bulbs and ballasts, and install new mercury-containing equipment (e.g., thermostats and switches). Did you know some of these used materials can be managed as universal waste and therefore wouldn’t count towards your hazardous waste generator status? For healthcare facilities, understanding proper segregation and disposal of hazardous waste versus medical waste, and what to do with specialty items such as expired pharmaceuticals, adds another level of complexity. Although other personnel probably take care of this, it’s important to understand how your department’s activities contribute. So before your staff throws out products, such as chlorinated cleaners, paints, and lab chemicals, determine if the products are categorized as hazardous waste and be sure to handle and dispose of them properly. Following the rules is a lot cheaper than breaking them, even if it wasn’t intentional.

5. Permits and plans – I was supposed to do what with them?

So, you have the necessary air permits, your oil storage tanks are in an SPCC plan if required, and you understand your hazardous materials and waste stream. Excellent! But there is still much to be done. Don’t just file those permits and plans away – make them easily accessible and require your staff to read them. These documents may dictate specific recordkeeping and reporting requirements, monthly and annual inspections, training, or performance testing, and don’t forget those Federal requirements. Regardless of the environmental media, maintaining a paper trail is the key to compliance. Records must be complete, accurate, readily available in the event of an inspection, and be retained as long as the permit, plan, or regulation requires (e.g., two years, five years, lifetime of equipment). Don’t get burned by automatic purging databases or personnel “walking off” with your hardcopies. If third parties are needed for testing or training, don’t be afraid to ask questions to make sure you receive good-quality results – after all, it’s your company that’s on the hook for compliance. There may be several reporting deadlines each year to track, which will differ among the sources you operate. Be aware of the less obvious ones, such as permit renewal deadlines and equipment notifications. Bottom line: whether it is an air or waste generator permit, or an SPCC Plan, it is the owner/operator’s responsibility to understand the legal obligations of its contents and to maintain and demonstrate continuous compliance.

Staying ahead of environmental regulations and their requirements is challenging when your full time job is beyond full time. Even with dedicated in-house environmental staff, there are many regulatory nuances and changes to track, especially if your property portfolio extends across state lines. While these five issues are just part of the environmental challenge faced by facility engineers and managers, they stand out because I’ve seen them happen time and again. How do you determine what you don’t know? How do you avoid the expense of environmental agency fines and blemishes to your public image?

Reach out to an environmental consultant and ask them to perform an assessment of your operations, your environmental requirements, and your records. Let them improve your recordkeeping, be your go-to for questions, loop them into capital projects, and have them communicate with regulators on your behalf. You have enough on your plate putting out fires (not literally, I hope), delivering long-term value to your tenants and investors, and maintaining assets to the highest standards. Through our in-house expertise and established partnerships, ALL4 can deliver the high-quality support you need and our team is very interested in talking with you.

What is your organization doing to address these five issues to create a responsible and sustainable facility? What sort of environmental challenges does your company or personnel face? Leave a comment below or connect via LinkedIn or Twitter.

Ga-ga Rocks!

ALL4 hosted one of its annual cornerstone events this past weekend – Crabfest 2015. Not only was this event held at a new venue this year, a local day camp facility located near our corporate office in Kimberton, PA, but it went down in ALL4 history as one of our highest attended events with 104 people present. While the day couldn’t have played out any better from a weather, venue, food, and friends vantage point there was one thing that stole the show for the day – Ga-ga ball! Ga-ga, which means ‘touch-touch’ in Hebrew, is a variant form of dodge ball and played with one ball. The game combines the skills of dodging, striking, running, and jumping, with the objective to be the last person standing. Players attempt to hit each other with the ball and are eliminated if the ball strikes them below the knees. The game can be played by a group competing as individual players, by groups divided into teams, or as a ‘one-on-one’ match. Rules, ball types, pit surfaces, and pit sizes can vary widely at different venues. While predominantly known as ‘Ga-ga’ this game can also be known as Israeli dodge ball, octo-ball, or panda ball.

While Crabfest guests initially walked around the hexagon shaped area on the grounds curious as to what this astroturfed based wooden structure was there for, guesses from the crowd began to take shape and ranged from a little tikes soccer field to a centralized time-out pit for the day campers. What picnic-goers came to enjoy was this was a Ga-ga ball pit and as the day progressed this became the place to be! The unique thing about this game is that there is no stereotypical player – sizes, ages, and abilities of participants ran the full gambit; however, there was one thing that participants, and observers alike, had in common…they were gaga over Ga-ga! This game held a captive audience the entire day and was not only the talk of the picnic, but was the talk of car rides home.

Move over horseshoes, swimming, and volleyball – picnics will never be the same now that ALL4 has the 4-1-1 on Ga-ga ball!

Proposed Revisions to the Guideline on Air Quality Models (Appendix W)

On July 14, 2015, the U.S. Environmental Protection Agency’s (U.S. EPA’s) Office of Air Quality Planning and Standards’ (OAQPS) Air Quality Modeling Group provided a pre-Federal Register (FR) publication of the proposed revisions to the Guideline on Air Quality Models (Appendix W to 40 CFR Part 51) (Guideline) on the U.S. EPA’s Support Center for Regulatory Atmospheric Modeling (SCRAM) website. In addition, a fact sheet summarizing the revisions made to the Guideline was also provided. As previously announced on SCRAM, the 11th Conference on Air Quality Models (Modeling Conference) is scheduled for August 12 and 13, 2015 at U.S. EPA’s Campus in Research Triangle Park, NC. The Modeling Conference will serve as a public hearing for the Guideline’s revisions, which I will be attending. Written comments will be accepted for 90 days after the final publication in the FR.

Below, I have outlined the revisions to the Guideline that have the biggest impacts on the regulated community. First, it should be noted that the revisions propose a one (1) year transition period during which time previous guidance contained in the 2005 version of the Guideline will be accepted. The Guideline is currently scheduled to be finalized in spring of 2016, allowing U.S. EPA time to address comments received during the 90-day comment period and Modeling Conference public hearing. The proposed revisions fall into the following two (2) categories:

1. Substantive changes to address enhancements to the formulation and applications of the AERMOD air dispersion modeling and the incorporation of a tiered demonstration approach to address the secondary chemical formation of ozone (O3) and fine particulate (PM2.5) associated with precursor emissions [nitrogen oxides (NOX) and sulfur dioxide (SO2) for PM2.5 and NOX and volatile organic compounds (VOC) for O3] from single sources.
2. Editorial changes to update and reorganize the Guideline.

Proposed AERMOD formulation updates include the incorporation of default settings options to mitigate over predictions in modeled concentrations related to low wind speeds (especially relevant to the 1-hour standards) and horizontal and capped release points. ADJ_U* is an option available in AERMOD’s meteorological preprocessor AERMET that allows the user to adjust the minimum friction velocity (u*). The minimum friction velocity is a critical value for calculating mixing height, initial horizontal and vertical dispersion. My own evaluation of ADJ_U* presented at the National Council for Air and Stream Improvement, Inc. (NCASI) Northern Regional Meeting in May 2015 indicated very favorable results in mitigating over predictions in modeled concentrations especially from low release and fugitive sources. Another proposed AERMOD option to assist in low wind speed over predictions is LOWWIND3. LOWWIND3 increases the minimum lateral turbulence intensity (sigma-v) and adjusts the dispersion coefficient to account for the effects of horizontal plume meander. Both LOWWIND3 and ADJ_U* are welcomed updates to AERMOD that will mitigate over predictions in low wind speed conditions. Another useful update to AERMOD’s default settings are the options that address plume rise for horizontal and capped stacks through the use of the POINTCAP and POINTHOR. Current conservative guidance is to assume no initial velocity associated with horizontal and capped stacks. The POINTCAP and POINTHOR options will also help to mitigate over predictions in modeled concentrations from capped and horizontal stack releases. When using these options the model performs the necessary adjustments to account for plume rise. For sources with rain caps the plume radius is adjusted to account for initial spread from the rain cap and for horizontal sources the initial horizontal momentum in the downwind direction of the wind is utilized.

Next under the substantive changes revisions category is proposed model application updates. First, is the long-time coming revision to officially designate AERSCREEN as the preferred screening model, replacing SCREEN3. Based on this revision applicants in States that have air toxics modeling requirements should take note. Usually States rely upon screening models for air toxics modeling, therefore it is more likely that States will update their guidance to utilize AERSCREEN instead of SCREEN3 for air toxics modeling.

Two (2) other welcomed application updates are related to nitrogen dioxide (NO2) modeling. The first revision involves the replacement of the ambient ratio method (ARM) with the ARM2 method as the Tier 2 option. ARM2 applies a NO2/NOX ratio to modeled concentrations based on an evaluation of measured NO2/NOX ratios from U.S. EPA’s Air Quality System (AQS) record of air quality data. The second revision is the incorporation of the Tier 3 Ozone Limiting Method (OLM) and Plume Volume Molar Ratio Method (PVMRM) as default options in AERMOD. This means that the Tier 3 options will no longer be treated as an alternative model and, therefore, U.S. EPA Regional Office approval will no longer be necessary as part of regulatory modeling applications such as when conducting NO2 National Ambient Air Quality Standards (NAAQS) modeling.

The proposed revisions to the Guideline related to precursor impacts represent additional analyses that will have to be incorporated into air quality modeling evaluations in support of Prevention of Significant Deterioration (PSD) permitting requirements. The proposed revisions for addressing impacts of secondary formation of PM2.5 and O3 go back to a January 4, 2012, U.S. EPA-granted petition submitted on behalf of Sierra Club on July 28, 2010. This petition required U.S. EPA to initiate rulemaking for establishing air quality models to evaluate impacts of PM2.5 and O3 precursors to be used by all major sources applying for a PSD permit. The revisions to the Guideline are the first step in the initiated rulemaking.

The revisions lay out a two (2)-tiered demonstration approach for addressing single-source impacts of secondary formation of PM2.5 and O3.

1. Use of technically credible relationships between precursor emissions and a source’s impacts that may be published in peer-reviewed literature; developed from modeling that was previously conducted for an area by a source, a governmental Agency, or some other entity that is deemed sufficient; or generated by a peer-reviewed reduced form model.
2. Case-specific chemical transport models (e.g., photochemical grid models) to be determined in consultation with the U.S. EPA Regional Office. The suggested preferred photochemical grid models include:

a. Comprehensive Air Quality Model with Extensions (CAMx)
b. Community Multiscale Air Quality (CMAQ) model

These two (2) tiers are consistent with the second and third tiers laid out in US. EPA’s “Guidance for PM2.5 Permit Modeling”.  The revisions to the Guideline propose a separate rulemaking to establish new PM2.5 and O3 Significant Impact Levels (SIL) and to introduce a new demonstration tool for PM2.5 and O3 precursors referred to as Model Emissions Rates for Precursors (MERP). A MERP will represent a level of emissions of precursors that are not expected to contribute significantly to the concentrations of O3 or secondarily-formed PM2.5 and will have ambient impacts that will be less than the SIL and therefore will not cause or contribute to a violation of the PM2.5 or O3 NAAQS or PM2.5 PSD increments. The MERP demonstration tool will replace the first tier qualitative assessment outlined in U.S. EPA’s “Guidance for PM2.5 Permit Modeling.” A new guidance document outlining the MERP approach will be published on the docket once the Guideline rulemaking is published in the FR entitled “Guidance on the Use of Models for Assessing the Impacts from Single Sources on Secondarily Formed Pollutants Ozone and PM2.5.”

In other unexpected revisions, U.S. EPA is proposing to remove CALPUFF as the preferred long-range transport model citing “concerns about the management and maintenance of the model code given the frequent change in ownership of the model code since promulgation in the previous version of the Guideline.” The current need for long range transport modeling in PSD modeling evaluations is associated with assessing Class I PSD increments. In its place U.S. EPA outlined a screening approach to evaluate Class I PSD increments and recommends evaluating Class I SIL impacts at or about 50 kilometers with U.S. EPA preferred near-field models. CALPUFF may still be used as a screening approach if further analysis is required. However, if a multi-source Class I PSD increment analysis is required there will be no preferred model for distances beyond 50 kilometers and applicants will have to select an alternative model for determining Class I PSD increments impacts on a case-by-case basis with the reviewing authority. It should be noted that the proposed action to remove CALPUFF as the preferred long-range transport model does not affect its use under Federal Land Managers (FLMs) guidance regarding Air Quality Related Value (AQRV) analyses (i.e., visibility and deposition impacts) or Best Available Retrofit Technology (BART) regional haze implementation plans.

Another interesting proposed revision is related to the proposed use of prognostic meteorological data in limited situations. Specifically, U.S. EPA states in the revisions to the Guideline that the use of prognostic meteorological data may be used “where there is no representative National Weather Service (NWS) station, and it is prohibitive or not feasible to collect adequately representative site-specific data.” In these situations the Mesoscale Model Interface (MMIF) prognostic meteorological data processing tool would be used to develop an AERMOD meteorological dataset using the three (3) most recent years of prognostic data. Unfortunately, I doubt that the cost associated with an on-site meteorological monitoring program qualifies as “prohibitive or not feasible.”

The proposed revisions to the Guideline represent the first changes since AERMOD replaced ISC as the preferred near-field model in the 2005 amendments and represents a significant rework. Most of the revisions reflect changes necessary as a result of 2010 1-hour NO2 and sulfur dioxide (SO2) NAAQS and incorporate guidance contained in U.S. EPA memorandums released since this time period. In addition, how applicants account for impacts from PM2.5 precursors continues to evolve and for the first time addressing impacts from O3 will work its way into air quality modeling evaluations. This will be the first time that information contained in the guidance memorandums will be available to the public for comments so I encourage all those affected by air quality modeling requirements to take this opportunity to supply comment. I will be attending the public hearing as part of the 11th Conference on Air Quality Models on August 12 and 13, 2015 so look for another update from me on the information I learn.

Finalized PC MACT Amendments and Performance Specification 18

On July 1, 2015, the U.S. Environmental Protection Agency (U.S. EPA) finalized the proposed amendments to 40 CFR Part 63, Subpart LLL – National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the Portland Cement Manufacturing Industry, which establishes Maximum Achievable Control Technology (MACT) standards for affected sources, and is commonly referred to as “PC MACT.” The major revisions to PC MACT include:

• Clarifications on the definitions of rolling average, run average, and operating day.
• Allows an additional month of flexibility for the due date of the annual performance test.
• Restores the prior emissions limits (as Table 2 to PC MACT) that apply until the September 9, 2015 compliance date.
• Includes corrections to Equation 8 regarding kilns with an alkali bypass and/or an inline coal mill with a separate stack.
• Provides a scaling alternative for sources that have a wet scrubber, tray tower, or dry scrubber relative to the hydrogen chloride (HCl) compliance demonstration.
• Adds a temperature parameter to the kiln startup and shutdown requirements and clarifies that the requirement presented in 40 CFR §63.1346(g)(3) is related to devices that control emissions of hazardous air pollutants (HAP).
• Clarifies language related to span values for HCl and Hg continuous emissions monitoring systems (CEMS).
• Makes technical corrections related to inadvertent typographical errors.

Another new document released this month by U.S. EPA is the promulgated performance specification (PS-18) and quality assurance (QA) requirements (Procedure 6) for HCl CEMS. This is important for facilities who are using an HCl CEMS to demonstrate compliance with the emission limits in PC MACT, as well as for other purposes. PS-18 establishes requirements for initial acceptance, including instrument accuracy and stability assessments for HCl CEMS used for compliance determination at stationary sources. Procedure 6 specifies the minimum QA requirements necessary for the control and assessment of the quality of CEMS data submitted to U.S. EPA for compliance purposes. PS-18 will not only be a useful tool in demonstrating compliance with operating and maintenance requirements for HCl CEMS, but will also serve as a resource in providing procedures and guidance when developing required PC MACT plans for facilities, like site-specific monitoring plans. Click the link to find out how ALL4 can help!

If It is June, It Must Be a NCASI Boiler MACT Session

Each June, ALL4’s Atlanta, Georgia office participates in the National Council for Air and Stream Improvement’s (NCASI’s) Southern Regional Meeting. This annual rite of summer allows ALL4 to reconnect with our pulp and paper and wood products sector clients and regulatory contacts, make new connections, and have a lot of fun. We also take advantage of attending and presenting at the various workshops and technical sessions. As a member of ALL4’s 4 Rules initiative, the Boiler MACT technical session is a “can’t miss” session to learn about the latest regulatory rumblings and how mills are dealing with the challenges of this rule. The technical presentations in this year’s session focused on emissions and parametric monitoring, along with the management of data produced by these monitoring systems. These discussions were preceded by an update on the status of the proposed reconsideration rule, and the resulting uncertainty that is impacting mills across the country, particularly for those mills that have not received a one (1)-year extension to the compliance date of January 31, 2016. Some highlights of the discussions are provided below [with an acknowledgement to the presentation materials provided by NCASI and the American Forest & Paper Association (AF&PA) during the meeting]:

• The proposed reconsideration of the rule is not expected to be finalized until the end of the year or the first quarter of 2016. This timing is unfortunate because it will be after the deadline to file for an extension to the compliance date (i.e., by October 1, 2015). Why the delay? The Clean Power Plan has taken priority in the pecking order for regulatory action and this is diverting resources from promulgating the proposed reconsideration. The same issue is the reason for the delay in finalizing the proposed Non-Hazardous Secondary Materials changes from spring 2014, in which paper recycling residuals, construction and demolition wood, and creosote railroad ties would be classified as categorical non-waste fuels.
• Startup and shutdown: Not all boilers can burn the listed clean fuels in the current rule, particularly at those mills that have limited access to natural gas. The inclusion of dry biomass in the final reconsidered rule as a listed clean fuel for units with multi-clones would improve operational flexibility for many units.

• Particulate matter (PM) controls during startup: The current rule requires (with some exceptions) venting emissions to the main stack and engaging all applicable air pollution control devices when you start firing non-listed clean fuels. Excepted air pollution control devices must be started as expeditiously as possible. Electrostatic precipitators (ESPs) currently are not one (1) of the excepted air pollution control devices. It is critical for ESPs to be added to the list of excepted air pollution control devices in the final reconsidered rule due to concerns related to safety interlocks and to prevent fouling/damage to equipment.

• Opacity operating limit: Multi-fuel biomass boilers equipped with dry PM controls cannot meet the 10% opacity operating limit parameter over its operating conditions, particularly during times when the biomass is wet. Because PM limits for existing solid fuel boilers range from 0.02 – 0.44 lb/MMBtu, a single 10% opacity level is not necessarily appropriate as a monitoring parameter for all subcategories. During times when the opacity operating limit is exceeded, the PM emissions may be below the emissions limit. The situation gets further complicated because facilities can petition for an alternative operating limit using the procedures found in 40 CFR §63.8(f) (relating to use of an alternative monitoring method). According to NCASI, in recent discussions between U.S. EPA and an affected facility that submitted a request for an alternate opacity operating limit, U.S. EPA stated that they wanted the facility to instead follow the procedures in 40 CFR §63.7570(b)(2), which states that approval of alternative opacity emission limits in 40 CFR §63.7500(a) is done per 40 CFR §63.6(h)(9) (relating to compliance with opacity and visible emission standards). This is not an appropriate approach because 10% opacity is not an emission limit. U.S. EPA is effectively subjecting units to a more stringent PM standard than the established MACT floor as this process will not be feasible to complete prior to the compliance date. Facilities can adequately demonstrate to U.S. EPA through the 40 CFR §63.8(f) process that a higher opacity level can be appropriate for specific situations. To resolve this issue, U.S. EPA would need to delete 40 CFR §63.7570(b)(2) so it will be clear that a request for an alternate opacity operating parameter limit is accomplished under 40 CFR §63.8(f) per 40 CFR §63.7570(b)(4) and 40 CFR §63.7500(a)(2).

As the compliance date inches closer, the road to compliance seems to be getting more complicated. ALL4 continues to work with our clients to comply with Boiler MACT, and the insights we learn through our active participation in trade associations like NCASI continue to be invaluable as we all work through this compliance journey together. Although there is plenty of uncertainty, the January 31, 2016 compliance date remains firm, and facilities must continue pursuing their initial compliance obligations, including energy assessments, tune-ups, performance testing, fuel sampling, and developing the required compliance plans. Visit our Boiler MACT Resources page for more information, and contact me for additional guidance and takeaways from the NCASI Boiler MACT session.