Implementation Plan - Technical Assistance for

Small and Mid-size Commercial, Industrial and Institutional Solid Fuel Burning Devices

October 6, 2011

DEQ will implement outreach activities and technical assistance efforts to aid owners and operators of affected solid fuel burning devices in meeting applicable air quality and associated emissions requirements upon adoption of the proposed permanent rule amendments for small and mid-size solid fuel burning devices. Anticipated efforts can be categorized by the headings identified below.

Communication

•  Post-card size inserts explaining the proposed permanent DEQ boiler rules were included in the EPA mailing distributed to boilers affected by the NESHAP rules

•  Informational materials will be developed and disseminated to affected parties with information on the following:

◦  Who’s affected by the rule changes

◦  What they are required to do under the new rules

◦  When they are required to take required actions

•  Updates on developments of federal rules pertaining to solid fuel boilers subject to Federal NESHAP area source rules

•  Update the enforcement guidance so we know how to respond to a complaint (CarrieAnn Capp to coordinate with OCE Leah Koss/Jenny Root and George Davis)

◦  Goal: pathway for regions to deal with complaints

▪  Convey to permitting Staff at Inspector’s Forum - tentatively scheduled for May 9-10, 2012. This activity is included in the 2011-12 AQ operating plan.

Outreach

Outreach efforts to inform owners and operators of affected solid fuel burning devices will be implemented primarily through DEQ’s Small Business Assistance program. Headquarters staff will also be available by phone to assist affected parties with the online registration process and to help answer general questions.

Coordination

DEQ has partnered with EPA to provide informational materials specific to the proposed rulemaking to affected parties. EPA Region 10 sent letters to owners and operators of boilers that are affected by the recent changes to the Areas Source NESHAP rules in August of 2011. Included with this mailing were post-card size inserts from Oregon DEQ notifying recipients of the proposed Oregon permanent rulemaking affecting small-scale and mid-size commercial, industrial and institutional solid fuel burning devices. DEQ intends to work with EPA to help identify boilers in Oregon affected by the rule and to provide owners and operators further guidance in meeting the requirements of the proposed rule changes.

Infrastructure/Database Development

DEQ plans to create a simple, web-based construction notice and self-registration form that can be completed electronically by boiler owners and operators. DEQ Headquarters - Air Quality staff is working with DEQ’s Business Services Division to develop a web-based registration system for use by owners and operators of commercial, industrial and institutional solid fuel burning devices with maximum heat output capacities at or below 10 MMBtu/hr. Boiler owners and operators would not be charged a registration fee, and could self-certify their boiler complies with the applicable emissions standards. DEQ will evaluate the effectiveness of this tool, and may apply it to other source categories that currently must provide construction notice using paper forms.