RED takes EPA to the MACT on industrial efficiency

The Alliance for Industrial Efficiency recently submitted comments to the Environmental Protection Agency (EPA) on its “Boiler MACT,” a set of rules to reduce hazardous air pollutants from the nation’s industrial boilers. (MACT stands for the “maximum available control technology” standards that must be met by these boilers.) The Alliance views the rules as an important means to enhance industrial efficiency, especially through the use of waste heat recovery (WHR) and combined heat and power (CHP) projects.

Among the Alliance’s comments are:

• EPA should clarify that coal-fired facilities seeking to incorporate clean and efficient combined heat and power or waste heat recovery are eligible for a one-year compliance extension.
• EPA should modify the output-based alternative compliance mechanism to allow more facilities to benefit.
• EPA should clarify that facilities may simultaneously adopt the alternative output-based compliance standard and average emissions.
• EPA should preserve the energy assessment requirement, but make this requirement more robust by expanding the definition of cost-effective energy efficiency improvements.
• EPA should refine its engineering cost analysis to account for savings identified in the energy assessment.

The comments were submitted on behalf of the U.S. Clean Heat and Power Association, Avalon Consulting, Cummins Power Generation, DCO Energy, Enercon Engineering, Energenic, Mechanical Contractors Association of America, National Electrical Contractors Association, Ohio Business Council for a Clean Energy, Recycled Energy Development, Sheet Metal and Air Conditioning Contractors’ National Association, Texas CHP Initiative, The Association of Union Constructors, and Veolia Energy North America.

On a separate but related issue – this time on hazardous air pollutants from larger, utility-scale boilers – RED’s Melissa Mullarkey delivered testimony at an EPA hearing in Chicago. Among Melissa’s key points:

• The final Utility MACT rule should provide a benefit greater than 5 percent for CHP’s avoidance of transmission and distribution losses.
• EPA should clarify that facilities seeking to incorporate clean and efficient CHP are eligible for a one-year compliance extension.

Should the EPA adopt these suggestions, U.S. industry will become more productive and competitive, create jobs, as well as reduce pollution.