Sugar Mill Boiler Testing Policy

Policy Disclaimer: Nothing in this policy shall nullify any specific requirements of a permit issued by the Department. If the air permit contains more stringent testing requirements than this policy, the requirements of the permit shall supersede this policy.

• Alternative testing locations may be allowed for NOx and CO testing with approval from the Department. A description of the alternative testing location, including a diagram of the testing location, must be submitted with the test protocol and approved by the Department prior to testing.
• Testing shall be performed using EPA Method 7E for NOx, Method 10 for CO, and Method 5 for PM, unless other methods are approved by the Department prior to testing. EPA reference method analyzers shall be used for Method 7E and Method 10.

Boilers subject to NSPS: 

• Boilers subject to NSPS will perform NOx and CO testing with every permit renewal (every 5 years). If the NOx PTE is less than 40 tons/yr, boilers subject to NSPS Dc may not be required to test for NOx and CO. To determine whether testing is required, please refer to the specific requirements in the facility’s air permit.
• Boilers subject to NSPS will be allowed to have an approved maintenance and repair plan for all equipment that is part of the PM control. These boilers will be required to perform an initial test that shows compliance with the PM permit limit. Once the test shows compliance, the boiler will be maintained in that condition by following the maintenance and repair plan. The maintenance and repair plan will clearly outline what equipment will be inspected. Records of annual inspections and repairs must be kept onsite and made available to the Department for review. 

Boilers not subject to NSPS:

• If the NOx PTE is greater than 40 tons/yr, boilers not subject to NSPS will perform NOx and CO testing with every permit renewal (every 5 years).
• Boilers with PTE > 25tpy will not be required to test for PM if it can be shown that actual PM emissions are less than 25 tons/yr for the last 3 out of 5 years. Actual emissions shall be calculated in accordance with the application methodology for the most recent approved permit or with relevant stack test data.
• If actual PM emissions exceed 25 tons/yr and the boiler is not subject to NSPS, an approved maintenance and repair plan will be allowed instead of testing. The maintenance and repair plan will clearly outline what equipment will be inspected. Records of annual inspections and repairs must be kept onsite and made available to the Department for review.