Boiler MACT Energy Assessments

Gene Taylor, P.E., C.M., Principal Consultant

Iowa Office

April 3, 2014

Energy Assessment Who & What˃ Who is required to conduct EA?

HAP major with existing boiler or process heater of any size & fuel that is not limited use (FEACF<10%)

HAP minor with existing coal, biomass, oil boiler >10 MMBtu/hr. that is not limited use (FEACF<10%)

Exempts facilities operating under ISO 50001 compatible EnMS, or post January 2008 EA, that includes affected units

˃ What is required? Scope & duration determined by firing capacity

♦ Site Visit (8-24 hrs., not to exceed 160 hrs.) Performed by Qualified Energy Assessor No report submittal but submit NOCS by due date Not required to implement any ECMs identified

˃ When is it required? Major sources (§63.7510(e)):

♦ Assessment and report due by:♦ Compliance date – January 31, 2016

Area sources (§63.11196(a)(3)):♦ Assessment and report due by:♦ Compliance date – March 21, 2014

˃ Submit certification of completion in Notice of Compliance Status (NOCS) NOCS due:

♦ 60 days after performance test for Major Sources♦ 60 days after perfor. test for Area Sources, if no

perfor. test required 120 days after compliance date (7/19/2014)

Energy Assessment - When

˃ Someone who has demonstrated capabilities to evaluate energy savings opportunities for steam generation and major energy using systems, including, but not limited to: Boiler combustion management Boiler thermal energy recovery, including

♦ Conventional feed water economizer, ♦ Conventional combustion air preheater, and ♦ Condensing economizer.

Boiler blowdown thermal energy recovery Primary energy resource selection, including

♦ Fuel (primary energy source) switching, and♦ Applied steam energy versus direct-fired energy versus

electricity Insulation issues Steam trap and steam leak management Condensate recovery Steam end-use management

Qualified Energy Assessor

Energy Assessment – QEA How˃ Visual inspection & testing of the

Boiler/heater system (comb., DA, economizers, blowdown, etc.)

Steam distribution system (piping, steam traps, insulation) Condensate return system (piping, insulation) End use systems (insulation, leaks, direct injection,

efficiency)˃ Evaluation of operating characteristics of

boiler/heater systems, energy use systems, O & M procedures, and unusual operating constraints

˃ Review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage

Energy Assessment – QEA Report˃ Comprehensive report detailing:

List of major energy conservation measures (ECMs) that are within the facility’s control

List of the energy savings potential of the ECMs identified ♦ How many Btu’s am I going to save?♦ How much $$ are those Btu’s worth?

Cost of specific improvements, benefits, and the simple payback for recouping those investments

Efficiency Credits Option˃ Option for meeting BMACT emission

limits in lieu of installing controls˃ Only for existing units at major sources˃ Take credit for equivalent emissions

reduction from implementing ECMs identified in EA to comply with emission limits

˃ Must elect to comply with output-based emission limits