Monday, December 12, 2011

EPA Boiler Rules Create Significant Opportunity for Building Energy Assessments!

On Friday, December 2, 2011, the Environmental Protection Agency (EPA) released for public comment its rules for industrial boilers under the Clean Air Act. The rules require, among other things, that all buildings with oil-fired boilers equal to or greater than 10 million Btu/hr will need to conduct an energy assessment. Tens of thousands of buildings across the country will be impacted.

EPA divides all boilers in the country into one of two categories: “major sources” of toxic air pollutants (defined as emitting 10 tons or more per year of any single air toxic such as sulfur dioxide, nitrogen dioxide, mercury, lead, etc. or 25 tons per year or more of any combination of air toxics), and everything else (referred to as “area sources”). Approximately 187,000 boilers would be covered under the “area source” boiler rule, 98% of which would be required to implement work practice standards, including maintenance and tune-ups. The majority of area source boilers are located at commercial and institutional facilities, such as office building, retail establishments, hotels, medical centers, schools, universities, churches, municipal buildings, apartment buildings, warehouses, restaurants, nursing homes, etc.

If you own a boiler other than a gas-fired boiler, EPA’s boiler rule will impact you! The extent of the impact will depend on whether or not your boiler(s) has a heat input capacity less than, or equal to or greater than 10 million Btu/hr. From our "building energy performance assessment" viewpoint, facilities with oil-fired boilers having a heat input capacity equal to or greater than 10 million Btu/hr will be required to perform an energy assessment consisting of:

1. A visual inspection of the boiler system.
2. An evaluation of operating characteristics of the facility, specifications of
energy using systems, and operating and maintenance procedures.
3. Inventory of major systems consuming energy from the affected boiler(s).
4. A review of available architectural and engineering plans, facility operation
and maintenance procedures and logs, and fuel usage.
5. A list of major energy conservation measures (ECMs).
6. A list of the energy savings potential of the ECMs identified.
7. A comprehensive report detailing the ways to improve efficiency, the cost of
specific improvements, benefits, and the time frame for recouping those

The energy assessment would need to be completed no later than March 21, 2014.

How many area source oil-fired boilers would be impacted by this energy assessment requirement? I was astounded to find out that it would impact more than 26,000, located all across the country, but with the heaviest concentration, of course, in the Northeast and Mid-Atlantic. This is a huge number of buildings, and all will have to be assessed over the next two years!

The opportunity for energy professionals is significant. Moreover, the up-sell opportunity to conduct a full building energy audit is even more appealing. While an energy assessment as defined by EPA in the rule is not a full energy audit (since it only covers energy use systems that use the energy generated by the boiler), it would seem logical to me that a building owner would be remiss if he or she did not take advantage of this opportunity to include a full energy audit to identify all possible ECMs and their ROIs. In this way, a much more-informed decision could be made about any potential capital investment.

EPA is taking comment on the proposed rules for 60 days from the publication of the rule in the Federal Register this month, with the final rules to be published by April 2012.