Congratulations! You’ve made it through the first year of planning for compliance with the Major and Area Source Boiler MACT rules. That means there are two years left for major sources to come into compliance by January 31, 2016 (or January 31, 2017 for those who requested and received a one-year extension), and just shy of two months left for area sources to come into compliance by March 21, 2014.
Many major sources and area sources alike will need to conduct an initial tune-up and a one-time energy assessment by the applicable compliance date. Many tune-ups may be conducted in-house, but energy assessments must be conducted by a “qualified energy assessor.” While U.S. EPA has provided some examples of “qualified energy assessors” and some guidelines for the amount of time and cost they envision to be associated with these energy assessments, many in the regulated community are left scratching their heads about what to do and what resources are available to complete the required assessments.
Choosing an approach to satisfy the energy assessment required by the applicable Boiler MACT rule can be compared to going to a used car lot to buy a car – there are lots of options and you have to decide what is right for you! Are you looking for a certain type of car? Do you have a budget that you want to stay within? Do you open the doors, test the power windows and lock features, and have it pass the “eye test” or do you take it to a mechanic that you trust and have them give it the thorough inspection inside and out?
In the energy assessment world, you have similar choices. Do you just check the energy assessment box complete, or do you have an assessment completed that will potentially provide a financial return to your company? Do you use a local “boiler guy” or a national company? What is your definition of a qualified energy assessor?