On June 4, 2010 National Emission Standards for Hazardous Air Pollutants for Major Sources; Industrial, Commercial, and Institutional Boilers and Process Heaters – Proposed Rule [Major Source Boiler/Process Heater MACT - Vol. 75, No. 107 page 32006) and National Emission Standards for Area Sources: Industrial, Commercial and Institutional Boilers – Proposed Rule [Area Source Boiler MACT - Vol. 75, No. 107 page 31896] were published in the Federal Register. One feature of both proposed rules is the requirement that facilities conduct an energy assessment to identify cost-effective energy conservation measures.
US EPA identifies the energy assessments as a beyond-the-floor standard for existing sources. The energy assessment will be required for all boilers at major sources and boilers greater than 10 million Btu per hour for affected area sources. In the preamble to the Major Source MACT, US EPA indicates that boilers and/or process heaters are required to conduct this energy assessment, but the proposed language of the rule applies to boilers only.
The Department of Energy has conducted energy assessments at selected manufacturing facilities and reports that facilities can reduce fuel/energy use by 10 to 15 percent by using best practices to increase their energy efficiency. The most common best practice is simply tuning the boiler to the manufacturer’s specification.
The procedures for an energy assessment are:
a. Conduct a visual inspection of the boiler system.
b. Establish operating characteristics of the facility, energy system specifications, operating and maintenance procedures, and unusual operating constraints,
c. Identify major energy consuming systems,
d. Review available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage,
e. Identify a list of major energy conservation measures,
f. Determine the energy savings potential of the energy conservation measures identified, and
g. Prepare a comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments.
h. A facility energy management program developed according to the ENERGY STAR guideline for energy management.
The energy assessment report, along with a signed certification that the assessment is an accurate depiction of your facility must be submitted to US EPA.
US EPA is estimating that the energy assessment cost will range from $2500 to $55,000. The cost will depend on the size of the facility. US EPA estimates that 1,551 major source facilities will need to conduct the energy assessment. US EPA did not provide an estimated number of affected area source facilities. The estimated total cost of implementing the energy assessments is $25 million for major sources and $52 million for area sources. This is only the cost to conduct the energy assessment. The cost for implementing the suggestions is not included.
In the proposed rule, US EPA is defining a cost-effective energy conservation measure to be any measure that has a payback (return on investment) period of 2 years or less. The proposed language defines cost-effective energy conservation but does currently require the implementation of the recommended measures.
The energy assessment must be performed by qualified personnel. US EPA is defining qualified personnel a specialist in evaluating energy systems, such as those who have successfully completed the DOE Qualified Specialist program for all systems, Certified Energy Manager certified by the Association of Energy Engineers or the equivalent.
The Department of Energy qualified specialist program has five areas for certification: steam systems, fan systems, process heater systems, compressed air systems and pump systems. When looking at the qualified specialist website http://www1.eere.energy.gov/industry/bestpractices/qualified_specialists/, qualified specialists can be searched by name, company or location. There are currently 144 compressed air systems qualified specialists, 170 pump system qualified specialists, 102 process heater systems qualified specialists, 142 steam systems qualified specialists and 32 fan systems qualified specialists in the United States. Currently no individual is a qualified specialist in all 5 areas. There 5 individuals that are qualified specialists in 4 of the 5 programs. The majority of the individuals currently recognized as qualified specialists by DOE are university professors.
The Association of Energy Engineers (AEE) Certified Energy Manager (CEM) program is a certification program for energy engineers. A combination of education and energy experience is required to set for the examination. All CEM candidates must attend AEE’s preparatory CEM training seminars, and complete and pass a four-hour written open-book exam, proctored by an approved exam administrator. There are 17 AEE seminars, candidates must complete at a minimum of eleven, including three seminars that are required.
The preamble does not provide any information on how a facility would determine if another certification program is “equivalent” to the DOE or AEE programs.
US EPA is specifically requesting comment on the following elements of the energy assessment:
1. Whether estimates of the assessment costs are correct
2. Is there adequate access to certified assessors
3. Are there other organizations for certifying energy engineers
4. Are online tools adequate to inform the facility’s decision to make efficiency upgrades
5. Is the definition of “cost-effective” appropriate in this context since it refers to payback of energy saving investments without regard to the impact on HAP reduction
6. What rate of return should be used
7. Are there other guidelines for energy management beside ENERGY STAR’s that would be appropriate
Public comments must be received on or before July 19, 2010.
This article was excerpted from publically available information, and was authored by Joyce Gentry, Acacia Environmental Group LLC. For more information on the author see here.