STATE OF WASHINGTON

DEPARTMENT OF ECOLOCY

PO Box 47600 . Olyntpia,WA 98504-7600 .360-407-6000

71 1 for 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 in Table

2 of Subpart JJJJJJ of part 63 , and Table 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 area source 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 onetime 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 due to

varying process needs. For instance, changes from the use of steam in a contact 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 five to ten year time frame might be appropriate.

Another issue we want to bring forth is one related to the length of the energy 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 at the facility, the rest of the time was spent setting up measurement

instrumentation for 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 a one-day assessment meets the rigor needed

in all instances.

Consider allowing the qualified assessors to make the determination of the appropriate length of

time needed on a case-by-case basis. It may be useful to reference well-known assessment

methodologies such as the "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