Document QJN5n8Y5QVgNJ5Vynp0yoG6aR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1 5 POST OFFICE SQUARE, SUITE 100 BOSTON, MASSACHUSETTS 02109-3912 Clean Air Act Inspection Report Drafted: September 3, 2021 Finalized: September 14, 2021 EPA Inspectors: Davianna Vasconcelos, Environmental Engineer, Air Compliance Section /DMV/ Darren Fortescue, Environmental Engineer, Air Compliance Section Hannah Patel, Physical Scientist, Air Compliance Section EPA Reviewer: Christine Sansevero, Chief, Air Compliance Section /CMS/ Date of Inspection: August 31, 2021 Facility Name: Boston Properties, Inc. d/b/a Boston Properties ICISAir ID#: MA0000002511901864 Facility Location: 800 Boylston Street, Boston, MA 02199-8103 Mailing Address: 800 Boylston Street, Suite 1900, Boston, MA 02199-8103 Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Inspection Attendees: Name Davianna Vasconcelos Darren Fortescue Hannah Patel Joe Bertoni Tracy Nicholson Title Environmental Engineer CAA Inspector Physical Scientist Regional Engineer Organization EPA Region 1 EPA Region 1 EPA Region 1 Boston Properties Boston Properties Page 1 of 5 Boston Properties Boston, MA Dennis Carrafiello Scott Durkin Facility/Purpose Description: History C&W Services C&W Services The facility, commonly known as the Prudential Center, is located at 800 Boylston Street, Boston and is owned by Boston Properties, Inc. d/b/a Boston Properties ("Boston Properties"). The facility was formally owned by Prudential and was sold to Boston Properties in 1997. Purpose The Prudential Center houses over 60 stores and restaurants, over 4,000 parking spaces, and at least 19 floors of office space. Boston Properties maintains its headquarters and a regional within the Prudential Center. Generators Boston Properties owns and operates five generators at the facility, these generators are described in Table 1. Table 1: Generators located at the facility. Generator Use Manufac- Model Name turer Tower 1 Emergency Caterpillar 3512 Tower 2 Emergency Caterpillar 3512 Retail Emergency Caterpillar 3512 Serial No. 24Z07131 24Z07123 24Z04247 Type CI CI CI Capacity (HP) 1818 1818 1818 Manufacture Date Hour Meter Reading 595 608 446 Parking Emergency Caterpillar 3412 81Z18652 CI 749 Garage Fire Pump Fire Pump Caterpillar NTA- 56973 CI 400 855-F 546 233.5 Number of Employees and Working Hours: Boston Properties employs over 100 employees. The facility is open to clients 24 hours per day, 365 days per year and open to the public from 6 a.m. to 8 p.m. on business days. Potentially Applicable Clean Air Act Requirements: 40 CFR Part 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines ("Subpart 4I") Page 2 of 5 Boston Properties Boston, MA 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines ("Subpart 4J") 40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines ("Subpart 4Z"). Previous Enforcement Actions: A "Detailed Facility Report" from EPA's Enforcement and Compliance History Online database indicates that there have been no informal or formal enforcement actions taken against Boston Properties in the past five years. Opening Conference: Entry On August 31, 2021, at 9:05 am, EPA Region 1 representatives Davianna Vasconcelos, Darren Fortescue, and Hannah Patel arrived at the facility, located at 800 Boylston Street, Boston, Massachusetts. EPA representatives met Joe Bertoni, Tracey Nicholson, Dennis Carrafiello, and Scott Durkin in the hall in front of the tower entrance. Mr. Fortescue presented his credentials and Ms. Vasconcelos initiated an opening conference. Opening Conference Mr. Bertoni said the generators located at the facility do not participate in a demand-response program by either providing power back onto the grid or allowing the facility to operate as an island power location. Mr. Bertoni said that the facility does participate in a demand-response energy curtailment program that, when requested, uses activities such as turning off lights and adjusting the building temperature to lower the facility's power demand. Mr. Bertoni said the generators are only used to provide emergency stand-by power for common area lighting and elevators where necessary for safety and the building is not equipped to operate at full capacity in an emergency. Mr. Bertoni said that source registrations for the generators had been submitted to the Massachusetts Department of Environmental Protection. Mr. Bertoni said that the generators had previously been enrolled in a demand-response program; however, he said they had stopped participating in the program approximately 15 years ago. Mr. Bertoni said that the generators use ultra-low sulfur diesel fuel, and the generators all have non-resettable hour meters. Page 3 of 5 Boston Properties Boston, MA Mr. Carrafiello said preventative maintenance is routinely performed on the generators and a computerized tracking system is used to keep records of the maintenance performed. Mr. Carrafiello said that the computerized tracking system is also used to log when generators are operated. Ms. Nicholson said that, upon request, specific generator information could be supplied by email after the inspection. Facility Tour: Mr. Bertoni, Mr. Carrafiello, and Mr. Durkin led Ms. Vasconcelos, Mr. Fortescue, and Ms. Patel on a tour of the facility. During the tour, Mr. Fortescue took pictures of each of the generator nameplates. All photographs are in the inspection file. The group proceeded to a room containing a generator that Mr. Bertoni said was the emergency generator for the retail space. EPA representatives documented, from the nameplate, that the generator was a Caterpillar; Model No.: 3512; Serial No.: 24Z04247; Capacity: 1818 HP (1356 kW). EPA representatives documented that the generator's non-resettable hour meter read 446 hours. The group proceeded to a second room containing two generators that Mr. Bertoni said were the emergency generators for the office space located in the tower. EPA representatives documented, from the nameplate, that the first generator was a Caterpillar; Model No.: 3512; Serial No.: 24Z07131; Capacity: 1818 HP (1356 kW). EPA representatives documented that the first generator's non-resettable hour meter read 595 hours. EPA representatives documented, from the nameplate, that the second generator was a Caterpillar; Model No.: 3512; Serial No.: 24Z07123; Capacity: 1818 HP (1356 kW). EPA representatives documented that the second generator's non-resettable hour meter read 608 hours. The group proceeded to a third room, that Mr. Bertoni said contained a fire pump. EPA representatives documented, from the nameplate, that the generator for the fire pump was a Cummins; Model No.: NTA-855-F; Serial No.: 56973; Engine No.: 11407445; Capacity: 400 HP. EPA representatives documented that the fire pump generator's non-resettable hour meter read 233.5 hours. The group proceeded to a fourth room containing a generator, that Mr. Bertoni said was the emergency generator for the parking garage. EPA representatives documented, from the nameplate, that the generator was a Caterpillar; Model No.: 3412; Serial No.: 81Z18652; Capacity: 749 HP (558.5 kW). EPA representatives documented that the generator's nonresettable hour meter read 546 hours. Page 4 of 5 Boston Properties Boston, MA Closing Conference: Ms. Vasconcelos, Mr. Fortescue, Ms. Patel, and Mr. Bertoni attended the closing conference. The EPA representatives thanked the Boston Properties representatives for their time. The EPA representatives explained that generators can be subject to various regulations including Subpart 4I, Subpart 4J and Subpart 4Z. The specific regulations that a generator may be subject to, depends on a variety of factors including the type of facility at which the generator is located and the generator's fuel type, capacity, and data of manufacture. Mr. Fortescue recommended that Boston Properties review the potentially applicable regulations. Ms. Vasconcelos said she would send a follow-up email detailing the information Boston Properties had agreed to provide, which included the following: The registered legal name for Boston Properties; Manufacture dates of the generators; and Official titles for attendees of the Opening Conference. EPA representatives left the facility at 10:15 am. Page 5 of 5 Boston Properties Boston, MA