For those in the new and aftermarket boiler/burner business, it is good news in the form of business opportunities knocking. In more-pragmatic-less-burdensome guise than originally anticipated, these rules should incentivize those who have failed over the years to voluntarily keep pace with boiler room emissions and efﬁciency advances in technology to make the types of energy-system modernizations that have proven unlikely to happen in the absence of mandates.
The not-so-good news for everyone affected is that in the process of EPA setting these “ﬁnal” rules, it has also provoked some ongoing uncertainty into the mix by introducing a “reconsideration process” during which certain key aspects of the ﬁnal rules will undergo over the next several weeks some additional public scrutiny, clariﬁcation, and reﬁnement that may, in fact, end up “changing” them in some important ways. In its own inimitable way, then, the Agency has produced both a desired marketplace certainty while, at the same time and through some unwanted regulatory legerdemain, only exacerbated the uncertainty it sought to preclude.
TEAMING AND TIMINGWith what is known, however, ABMA is nonetheless encouraging all those large and small entities potentially affected by these rules to begin work immediately with their chosen boiler and combustion equipment vendors to analyze their situations, and to begin as early as possible to ﬁnd integrated solutions that are not only achievable but cost-effective and realistic. This could include everything from simple boiler tune-ups to systemic upgrading and optimization, to system replacements depending on needs, existing boiler-room conditions, and available resources.
Boiler, combustion equipment, emissions controls and instrumentation manufacturers, and repair shops can help boiler users assess the extent to which they are subject to the new rules and what needs to be done to achieve compliance. They are the technical experts who have the experience to best interpret and apply these rules to individual situations. They have the resources necessary to build the teams to tackle the more complex jobs and to manage a process that should be beneﬁcial not only for safety, health, and the environment, but that can also contribute to a much healthier long-term bottom line for every affected business.
Any “reconsideration process” should not be seen as an excuse for continued inaction. It should be viewed by boiler users as an opportunity to take advantage of current raw-material and manufacturing-capacity stability, and to avoid any increased compliance costs that may come with time.
For a quick overview of the sum and substance of the new rules, see the news item on page 18. That said, you should certainly talk with your equipment and services vendors for further deﬁnitions and details.
Although on their face, these rules and parameters may appear less demanding than their original form, they are also replete with nuances that could make out-of-context compliance strategies problematic. All who are potentially affected need to seek counsel early from experts like those who are members of the American Boiler Manufacturers Association, expertise that will afford a boiler room of any size with acceptable, cost-effective, long-term solutions to Boiler MACT challenges. TB