Facilities subject to the National Emission Standard for Hazardous Air Pollutants (NESHAP) for industrial, commercial, and institutional boilers located at area sources (40 CFR 63, Subpart JJJJJJ) were required to prepare a one-time Energy Assessment (EA) for many existing oil and solid fuel fired units by March 21, 2014. The EA requirements included:
- A visual inspection of the boiler system
- An evaluation of operating characteristics of the affected boiler system, specifications of energy use systems, operating and maintenance procedures, and unusual operating constraints
- An inventory of major energy use systems consuming energy from affected boiler(s) and which are under control of the boiler owner or operator
- A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage
- A list of major energy conservation measures that are within the facility’s control
- A list of the energy savings potential of the energy conservation measures identified
- A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments
The major source rule in 40 CFR 63, Subpart DDDDD, commonly referred to as the Boiler MACT, contains similar EA requirements for existing boilers and process heaters that must be completed by January 31, 2016. While that might seem well into the future, sources should start preparing for their EAs as soon as possible to ensure smooth completion and receive maximum benefit from their EAs. After all, a comprehensive EA is designed to find cost-effective opportunities to reduce energy consumption in the form of achievable projects or process changes that have short payback periods. Recommended first steps include the following:
- Identify and assemble an EA team – the team should be comprised of qualified energy assessors, personnel who are knowledgeable on boiler/process heater operations, maintenance activities, regulatory requirements, and energy use systems
- Gather data needed to complete the EAs – this includes boiler/process heater design and operational data, energy use information, and energy conservation measures that have been evaluated and implemented or discarded
- Schedule the on-site portion of EA – the rule includes an expected time commitment for the onsite portion of the EA, which ranges from 8 hours to 160 hours based on the combined heat input capacity of the affected boilers/ process heaters
While most area sources required only 1-2 days of on-site assessment time, major sources will typically require multiple assessors to be on-site for multiple days (or even weeks) due to their size and complexity. Therefore, it is imperative to schedule the EAs far enough in advance to ensure sufficient time is allocated to gather required data, avoid internal scheduling conflicts (e.g., plant outages or turnarounds), and ensure the proper resources are available (e.g., qualified energy assessors, operators, maintenance staff).
Trinity assisted many area sources with the completion of their EAs and has several qualified energy assessors that can assist in the planning and execution of Boiler MACT EAs. Please contact Jose Orsini at (407) 982-2891 or firstname.lastname@example.org with any questions or for assistance with your EA.