Questions for Potential Small Entity Representatives to help us estimate the impact s of potential new requirements the Agency is considering

Management Practices

Tune

- ups and boiler operator requirements :

1. Does your state or local authority require an annual or periodic tune

- up of the

boiler ?

2. If not, do you perform an annual or periodic tune

- up as part of routine maintenance, and what is your estimate of the cost to perform it? What percentage of the cost of performing routine maintenance is the annual tune

- up?

3. Does your state or local authority require any training or certification (licensing) of the boiler operator?

4. If so (a certified (licensed) boiler operator is required ), what is your estimate of the cost of either certifying the current boiler o perator or adding a certified (licensed) boiler operator ? What percentage of your facility’s or organization’s budget will this cost be?

Energy audit (assessment) :

1. Does your state or local electric power company offer any assistance, incentive, or

dis count in conducting an energy audit (assessment) for your facility?

2. If a requirement for implementation of the energy conservation measures identified by the energy audit is imposed, what rate

- of

- return (in percent terms, not payback period) would be the m inimum required for you to implement any identified energy conservation measures for your type of operation?

Good Combustion Practices:

1. Do you use a ny monitors, emissions parameters, or process parameters to monitor the operation of the boiler?

2. If you use monitors, what kind and how many? If monitors are used, are these monitors in place for environmental regulatory reasons? Insurance reasons? Are there other reasons, and if so, what are they?

Compliance Demonstration

1. Does your state requ ire any continuous monitoring of emissions or process

parameter (s) ? If so, what are the costs to the facility? W hat percentage of overall facility costs do these represent?

2. Does your state require any periodic testing or monitoring of emission s or proc ess parameter(s)? If so, what are the costs to the facility? What percentage of overall facility costs do these represent?3. Do your boilers have testing ports available for conducting compliance tests? If not, what do you estimate the costs to be of mo difying the stack for testing?

4. If your boilers were subject to emission limits, are there alternatives to monitoring

emissions or to stack testing that would be less costly to demonstrate compliance? How much less costly are these alternatives?

Permitti ng :

1. Are your boilers required to be permitted by the state or a local authority ? If so, what is the cost for permitting? If not, what would you estimate the burden to be in terms of costs and hours if the boilers are required to be permitted? What is the size of these costs compared to the costs of boiler operation and the facility as a

whole? If your boilers require permitting, are your permitting activities done by

in

- house staff or by outside contractors?

2. Are your boilers required to be ins pected for safety

, insurance or other reasons? If so, have often is this performed? What is the cost of these inspections? What is

the size of t hese costs compared to the cost of boiler operation and the facility as a

whole?

Compliance :

1. How do you kno w if your boilers are proper ly operated and maintained , and how do you ensure good combustion ?

2. How much burden (in terms of cost and hours) would it be for you to maintain a

file with daily operation and each inspection and maintenance conducted ?

3. If your b oiler was subject an emission limitation would you consider switching to a less polluting fuel and much additional burden (in terms of cost and hours)

would it add? What fuel would your facility switch to (or blends of fuels) , and

what benefits outside of reduced emissions could you r facility experience?

Capital Availability and Regulatory Impact :

1. A re your firm’s or organizations expenses for the activities listed above largely paid for out of equity, earnings, or debt?

2. Considered together, how much of your firm’s or organization’s revenues or budget are the costs of the activities listed above in percentage terms?