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Boiler MACT Compliance Options
EnMS photo

The Boiler MACT regulations for applicable Major and Area Sources (40 CFR 63, 6J and 5D) were most recently revised in January and February 2013. The final energy related provisions include a compliance requirement to either conduct an energy assessment or implement a system conforming to the requirements of an ISO 50001 Energy Management System (EnMS). While the advantage of an energy assessment is a single, quick option to meet the requirements of the regulation, it does not drive actions to continually reduce energy consumption, increase energy efficiencies, or improve operational processes. This is because the Boiler MACT energy assessment provision only requires identification of energy conservation measures, and encourages facilities, but does not required them to implement the measures. Conversely, the implementation of an EnMS provides a structured, organized, and focused approach to continually reducing energy use and consumption, identifying opportunities for improvement, acting on those opportunities, and managing all aspects of energy within the bounds of its system.


Why ISO 50001?

ISO 50001:2011 – Energy Management System or EnMS, is based on the management system model of continual improvement using the Plan, Do, Check, Act cycle, which is also used for other well-known standards such as ISO 9001, ISO 14001 or OHSAS 18001. This makes it easier for organizations to integrate energy management into their overall efforts to improve quality, environmental, or health and safety management. An EnMS provides a framework of requirements for organizations to:

  1. Develop a policy for more efficient use of energy
  2. Fix targets and objectives to meet the policy
  3. Use data to better understand and make decisions about energy use
  4. Measure the results
  5. Assess how well the system works (See Figure 1 - Energy Audit Process Flow Diagram)
  6. Continually improve energy management.1

EnMS Figure

Several early adopters are reporting significant benefits and energy cost savings from the implementation and operation of an EnMS.  Proponents estimate that the standard, which supports management strategies to increase energy efficiency, reduce costs and improve energy performance, can influence up to 60% of the world’s energy use. Bentley, Coca-Cola, Delta Electronics in China, Schneider Electric of France, the Dahanu Thermal Power Station in India, and LCD TV maker AU Optronics Corp of Taiwan, Province of China, are just some of the organizations that have reported benefits of using an EnMS.

The global energy management challenge cuts across borders and requires concerted efforts from all sectors.  The standards are developed with stakeholders from industry, government, and consumers.  They strive for consensus on practical technological solutions that can be implemented as broadly as possible. Information, communication, and education are essential instruments for promoting a culture of energy efficiency within a country or a company. An EnMS consists of seven major clauses: 

  1. General Requirements
  2. Management Responsibility
  3. Energy Policy
  4. Energy Planning
  5. Implementation and Operation
  6. Checking
  7. Management Review.

An EnMS can be used to manage virtually all variables affecting energy performance that can be monitored and influenced by the organization. ISO 50001 does not prescribe specific performance criteria with respect to energy, i.e. 10% savings.  The ISO 50001 standard for energy management systems has been designed to be used independently, but it can be aligned or integrated with other management systems. It is applicable to any organization, building, or manufacturing process that wishes to ensure its conformity to its stated energy policy and wishes to demonstrate this to others. Such conformity can be confirmed by means of self-evaluation and self-declaration of conformity or by certification of the energy management system by an external organization.

Management Standard Commonalities

The ISO 50001 standard closely mirrors other management systems standards, such as: quality (ISO 9001); environmental (ISO 14001); and health and safety (OHSAS 18001). Companies with an existing ISO 14001, OHSAS 18001, or ISO 9001 system will have a jump start on the implementation of an EnMS, as common elements are already in place and understood. Common elements (with an energy focus) are:

  • A defined and documented Scope and Boundary
  • A policy that requires continual improvement and compliance with legal and other requirements
  • A method to appoint a top management representative
  • Identification of Significant Energy Uses (SEUs), much like environmental aspects and impacts
  • Identification of applicable legal and other requirements and a process to evaluate compliance
  • Development of objectives, targets, and action plans (versus programs)
  • Identification of training needs, competency, training, and awareness
  • Methods to internally and externally communicate related corporate objectives and methods
  • Identification and control of documents and records
  • Operational Controls
  • Design and Procurement processes (ISO 9001 like, with additional requirements noted below)
  • Monitoring and measurement, with analysis of data for performance and calibration
  • Evaluation of compliance
  • A system to address Nonconformance, Corrective and Preventive Actions
  • Internal Audits
  • Management Review
ISO 50001 Unique Requirements

In addition to the common elements with other management system standards, an EnMS introduces some new requirements such as:

  • Top management has very specific, additional responsibilities related to the implementation of the EnMS, including long-term planning
  • The Management Representative must have  appropriate (related) skills and competence and report not only on the performance of the EnMS, but also on energy performance and must determine the criteria and methods to ensure the effectiveness of the EnMS
  • The policy must include additional commitments to:
    • Improvements in energy performance
    • Ensure availability of information and resources to achieve objectives and targets
    • Support the purchase of energy-efficient products and services
    • Design for energy performance
    • Regularly review and update as necessary
  • Conduct an Energy Review, including:
    • Analyze current energy sources and past and present energy use and consumption
    • Identify areas of SEU, such as facilities, equipment, systems, processes or personnel
    • Identify relevant energy variables affecting SEUs
    • Determine current energy performance related to SEUs
    • Estimate future energy use and consumption
    • Identify, prioritize, and record opportunities for improving energy performance
  • Establish an Energy Baseline and adjust as necessary, using information from the energy review
  • Identify Energy Performance Indicators appropriate for monitoring and measuring and compare to the Energy Baseline, as appropriate
  • Prepare Energy Action Plans that are documented and update at defined intervals, with a statement of the method by which an improvement in energy performance is verified and the method for verifying results
  • Identify Operational Controls and ensure performance of those operations and maintenance activities which are related to its SEUs, and operating and maintaining facilities, processes, systems and equipment, in accordance with operational criteria
  • Consider and record energy performance improvement opportunities and operational control in design processes that can affect SEU energy performance and incorporate into the specification, design, and procurement activities of the relevant project(s)
  • Inform suppliers that procurement decisions consider energy performance; implement criteria for assessing new equipment energy use, consumption and efficiency over the planned or expected operating lifetime; and develop energy purchasing specifications
  • Address actual and potential nonconformities by making corrections (in addition to corrective and preventive actions)

As noted, companies with an existing management system will find the additional requirements of an EnMS less daunting as they follow a rational methodology to determine:

  • When, where, how and who is involved in energy consumption
  • Opportunities to improve energy efficiency or performance
  • Predictions of future energy consumption
  • Control of the planning (design) and purchase of energy consuming equipment
  • Definition  and demonstration of how energy success is measured
  • Correction of potential nonconformance issues, without a paper trail of actions, as appropriate

Facilities without an existing management system should approach the EnMS as an opportunity to reduce overhead costs and improve energy performance, potentially improving profitability.  Success requires a diligent and honest evaluation of how each aspect applies to the facility. As the “Other Option” to compliance with the Boiler MACT Energy Assessment requirement, an EnMS offers a continuous improvement model that creates opportunities for incremental improvement over time and breakthrough improvements. 

Trinity Consultants can assist with either approach, performing an energy assessment for Boiler MACT compliance or implementing an EnMS including implementation, compliance review, internal auditing, and training.  For more information, contact Jerry Skaggs at (412) 522-7654 or