STATE OF WASHINGTON 

### DEPARTMENT 

## OF ECOLOCY PO Box 47600 

### . Olyntpia,WA 98504-7600 .360-407-6000 71 1for Washin¡¡,ton Relay Service

## . Persons with a speech clisability can call 877-833-6341

I|v4ay 

## 17,20ll

Mr. Brian Shrager 

### Energy Strategies Group Sector Policies and Programs 

### Division D243-01 

### Office of

### Air Quality Planning and Standards 

### U. S. 

### Environmental Protection 

### Agency Research 

### Triangle Park,

### NC 27711 Dear 

### Mr. Shrager: The purpose 

### of this letter is to 

### petition you 

### to review the

### work practice standards published 

### inTable 2

### of Subpart JJJJJJ 

### of part 63

### , andTable 3

### of Subpart DDDDD of part 63

### , Work 

### Practíce Standards, Emission Reductíon Measures and Management 

### Practices. The rule 

### text and table specify that 

### "a one-tínte energy assessment performed 

### by a

### qualified energy assessor" must be completed 

### for boilers subject to the 

### requirements. This one-time energy assessment requirement applies to boilers that

### fall into both the 

### major and areasource categories. Energy assessments are undoubtedly valuable 

### to diagnose problems and 

### identify opportunities that can 

### result in reduced 

### pollutant emissions and energy 

### conservation. However, we believe that a one

### time energy assessment

### will not adequately address the needs over the

### lifetime of a

### boiler and the processes that 

### it serves. Operational changes that 

### affect energy usage can and do occur 

### often dueto 

### varying process 

### needs. For instance, changes 

### from the use

### of steam 

### in acontact 

### to a non-contact 

### application dictated by process changes may also mean that condensate return becomes 

### viable, whereas

### it was not 

### in the 

### past. Condensate return reduces 

### fuel usage, improves thermal 

### efficiency, and results 

### in lower pollutant loadings. Consider changing the one-time assessment requirement, 

### to one that must be conducted at regular intervals, perhaps every 

### five years, 

### in step

### with the

### Title V permitting procoss 

### for major sources. For area sources, a

### fivetotenyear 

### time frame 

### might be appropriate. 

### Another issue wewant to 

### bring 

### forth is one related 

### tothe length 

### of theenergy assessments. Small systems can require more than one day

### to 

### review. For instance, an assessment at a cereal 

### manufacturing

### facility using a 

### boiler less

### than 10 

### MMBtu/hr took more than

### two days and

### two 

### visits. A significant portion of the 

### time was spent understañding the 

### particulars of operation and process constraints atthe

### facility, the rest 

### of the

### time was spent setting up measurement 

### instrumentationfor various parameters, 

### collecting boiler water samples, 

### reviewing manufacturer's

### Mr. Brian Shrager

Ilúay 

## 17,20ll Page2
specification sheets,and observing 

### othei systems 

### including dryers and 

### chillers, and wastewater 

### collection and treatment systems. 

### V/e do not believe aone-day assessment meets the 

### rigor needed 

### in 

### all instances. Consider 

### allowing the 

### qualified assessors to makethe determination 

### of theappropriate length 

## of time needed on a case-by-case 

### basis. It may be useful 

### to reference 

### well-known assessment methodologies such asthe "Save Energy 

### Now" assessments conducted through the Department 

## of Energy 

### (http://wwwl.eere.energy.gov/industry/saveenergynodassessments.html).
Please contact Cristiana Figueroa at c.figueroa@wa.ecy.gov 

### or 

### (360) 407-6342,if you 

### would like to 

### follow up on

### this communication. Sincerely,

Hazardous Waste and 

### Toxics Reduction Southwest Regional 

### Office Ava Edmonson, Section Manager