Kristine Gilbert

Background:

The US Environmental Protection Agency (EPA) published new boiler rules on March 21, 2011, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Sources: Industrial, Commercial, and Institutional Boilers (also known as Area Source Boiler MACT) found at 40 CFR Part 63 Subpart JJJJJJ.

On March 21, 2011, EPA also published a rule affecting boilers at major sources (the Major Source Boiler MACT) and amendments to the Commercial, Industrial, Solid Waste Incinerators rule affecting boilers that burn any solid waste. On May 18, 2011, EPA stayed the Major Source Boiler MACT and Solid Waste Incinerator rule amendments. The Area Source Boiler rule is still in effect.

Which boilers are affected?

Boilers that burn coal, oil, biomass (example: wood), or other solid and liquid non‐waste materials AND are located at area source commercial (as in  laundries, apartments and hotels)’  institutional (as in schools, churches, medical centers, municipal buildings), or industrial (as in manufacturing, refining, processing, mining) facilities. In addition, 63.11194(d) also states that a boiler is a new affected source, if the fuel source was changed from natural gas to solid fossil fuel, biomass, or liquid fuel after June 4, 2010.

The following units are NOT subject to the Area Source Boiler rule:

• Any gas-fired boiler. If your boiler burns gaseous fuels (e.g., natural gas, process gas, landfill gas, coal-derived gas, refinery gas, hydrogen, or biogas) not combined with any solid fuels, or if your unit burns liquid fuel only during periods of gas curtailment, gas supply emergencies, or periodic testing it is a gas-fired boiler.*
• Hot water heaters with a capacity of no more than 120 U.S. gallons and pressures not exceeding 160 pound-force per square inch gauge (psig), and all controls necessary not to exceed a temperature of 210°F (90°C)
• Waste heat boilers, also known as heat recovery steam generators (these boilers recover traditionally unused energy and convert it to usable heat)
• Boilers that are used as control devices for other NESHAP standards, where at least 50 percent of the heat input to the boiler is provided by the NESHAP regulated gas stream
• Research and development boilers
• Boilers subject to other NESHAP standards, Section 129 standards, or hazardous waste boilers.

What is an area source?

An area source is any source that is not a major source. A major source is a facility that emits, or has the potential to emit (in the absence of controls), at least 10 tons per year (TPY) of individual hazardous air pollutants (HAP) or 25 TPY of combined HAP.

When do you have to submit  Initial Notification (§63.9(b)(2))?

Existing sources: No later than September 17, 2011.  (To be consider an “existing source” your facility must have commenced construction or reconstruction of the boiler on or before June 4, 2010.)

New sources: No later than September 17, 2011, or within 120 days after start-up of a new source, whichever is later. (To be considered  “new source”  your facility must have commenced construction or reconstruction of the boiler after June 4, 2010 and you meet the applicability criteria at the time you commence construction.)

For additional  information, visit the EPA   boiler page:  http://www.epa.gov/ttn/atw/boiler/boilerpg.html

* It is important to note that periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year in order to maintain your status as a gas-fired boiler. if at any time the boiler burns fuel outside of the period of natural gas curtailment OR for greater than 48 hours per year, the boiler will then be considered a NEW fuel oil burner and subject to the requirement of PM testing every 3 years.

Kristine Gilbert

Last week the U.S. EPA instituted the use of a new tool to allow 28 industrial sectors to submit their 2010 greenhouse gas (GHG) pollution data electronically.

The Electronic Greenhouse Gas Reporting Tool (e-GGRT) is web-based system EPA has developed to support reporting under the Greenhouse Gas Reporting Program (GHGRP).  The data collected with e-GGRT will provide important information publicly about the nation’s largest stationary sources of greenhouse gas pollution. Industries and businesses can also utilize this data in an effort to decrease carbon pollution, increase efficiency and save money.

EPA expects to receive 2010 GHG data from approximately 7,000 large industrial GHG emitters and suppliers, including power plants, petroleum refineries and landfills.

EPA’s GHG Reporting Program, launched in October 2009, requires the reporting of GHG data from large emission sources across a range of industry sectors. Suppliers of products that would emit GHGs if released, combusted, or oxidized are also required to report GHG data. Under this program, covered entities are required to submit GHG data to EPA annually and the first round of data will be submitted electronically by September 30, 2011. EPA plans to publish non-confidential GHG data collected through the GHGRP by the end of 2011.

Reporter registration is a necessary first step in meeting your GHG reporting obligations. The e-GGRT registration module is available at ghgreporting.epa.gov. All required to register are asked to have registration completed by August 1, 2011. But even if you have missed the deadline, EPA strongly encourages all reporters to register as soon as possible. Good faith efforts to register as soon as possible after the August 1st deadline will be taken into consideration.

For more information on the GHG Reporting Program: http://www.epa.gov/climatechange/emissions/ghgrulemaking.html

Press Release:  New Employee

For immediate release

Contact Kristine Gilbert, 610-559-8776

July 22, 2011, Easton, PA-

Avogadro Environmental is proud to announce and welcome Ed Burgher as the company’s Business Development Manager.  Ed’s primary focus will be on developing and maintaining business opportunities with existing and new customers.

 Ed complements the consulting and measurements teams at Avogadro bringing more than 25 years of diversified experience in the environmental regulatory compliance and environmental measurements industry.  He has held positions in the sales, marketing, development and management of products and services used in the environmental measurements industry. Ed also has many years of experience as an industrial compliance manager and as an environmental consultant helping clients address their air quality measurement needs.  Ed’s body of work includes managing the development, marketing and sales of products used for measuring black carbon and particulate matter in ambient air and source emissions atmospheres and providing training programs for operations, maintenance and calibration of instrumentation used in the measurement of aerosols, particulate matter and black carbon.  He experience includes hands-on development, implementation and management of continuous emission monitoring programs for rotary kiln and fixed hearth hazardous waste incinerators and hazardous waste tank treatment processes.  His expertise also includes directing hazardous waste treatment, mining and construction aggregates facility air and air-related hazardous waste permitting and compliance programs.  Working for clients in the petrochemicals, chemicals, glass, paper and power generation industries, Ed has performed hundreds of performance and system audits of ambient air and meteorological monitoring programs. 

 Ed holds a B.A. in Chemistry from Western Connecticut State University and an A.A.S. in Natural Resources Conservation, Dutchess Community College.  He is a member of Air and Waste Management Association, The American Association for Aerosol Research and The Source Evaluation Society. 

 “I am delighted and honored to join a strong, positive team dedicated to making Avogadro “The Best Choice” for assisting customers in meeting the significant challenges posed by today’s complex environmental regulatory requirements.

 George Wagner, President of Avogadro Environmental states, “We are very excited to welcome Ed to our team at Avogadro.  His years of direct, hands-on experience in many phases of the environmental measurements business will further propel us to our goal to be the services provider that unfailing delivers at and above our customers expectations.”

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 Avogadro Environmental is a full-service Environmental, Health and Safety consulting and testing firm, headquartered in Easton, Pennsylvania.  Our fields of expertise include Air Monitoring & Testing, technical support services for Continuous Emission Monitoring Systems and Continuous Opacity Monitoring Systems as well as professional consulting services for compliance management issues.  Avogadro’s staff of professionals is dedicated to provide accurate scientific data to enable the preservation of our environment and natural resources and identify the most cost effective and innovative solutions to meet our customers needs.

For more information of Avogadro Environmental’s services, please visit our website www.avogadro.net

Kristine Gilbert

On July 20th, a Bipartisan Senatorial group consisting of Susan Collins (R-ME), Ron Wyden (D-OR), Lamar Alexander (R-TN), Mary Landrieu (D-LA), Pat Toomey (R-PA), and Mark Pryor (D-AR) introduced a bill  (S.1392)  to delay ICI Boiler MACT.

Details of the bill:

• Give EPA 15 months from the bill’s date of enactment to re-propose and finalize the Boiler MACT regulations.
• Extend compliance deadlines from three years to at least five years (to allow facilities adequate time to comply with the new standards and install necessary equipment).
• Clarify that renewable and carbon-neutral materials remain classified as fuel and not solid waste.
• Direct EPA to ensure that the new rules are achievable by real-world boilers, process heaters, and incinerators, and impose the least burdensome regulator alternatives consistent with the President’s Executive Order.

According to  Senator Collins, “The EPA performs vital functions in helping to protect the public health by ensuring that the air we breathe is clean and the water we drink is safe. We need, however, to make sure that as the EPA issues new regulations, it does not create so many roadblocks to economic growth that it discourages private investment, which is the key to maintaining and creating jobs,” said Senator Collins. “At a time when manufacturers are struggling to retain jobs, it is essential that this rule not jeopardize thousands of jobs in manufacturing, particularly in the forest products industry, by imposing billions of dollars of new costs. Our legislation provides common sense solutions to the challenges the EPA is facing in attempting to implement these complicated rules, which if written without proper data, analysis, and consideration, would cost the industry billions of dollars and potentially thousands of jobs.”

This legislation is supported by the American Forest and Paper Association, National Association of Manufacturing, U.S. Chamber of Commerce, National Federation of Independent Business, Business Roundtable, Biomass Power Association, and approximately 25 other national associations.

To see the full release from Senator Collins, click here

To see a copy of the support letter, click here

To see legislative details, click here

Kristine Gilbert

Avogadro Environmental is proud to announce the launch of our newly redesigned website.

The new website offers many new features including navigational enhancements, increased interactivity, and overhauled content. We have also worked hard to improve the aesthetics of the website.

Social networking is becoming the standard for staying connected online. Avogadro is dedicated to keeping up with these trends.  Please follow us on Linkedin.

Several additional features include:

• Quick and easy navigation to each of Avogadro’s divisions.
• Client access portal to download reports…no more clogging up email servers!
• Interesting news and blog articles (updated frequently…be sure to visit often!)
• Quick access to our CEMS Parts department  and CEMS Emergency Services 24/7 toll free hotline.
• New quote and information request interface.
• Navigation via easy to use drop down menus or site search box.
• Interesting news and blog articles updated frequently…be sure to visit often!
• Download or sign up for our informative newsletter, The Avogadro Advisor.

The launch of our new website is not the finish line for us; we continually improve the programs and services that we provide our clients and visitors.  We want you to see why our clients say we are the Best Choice!

The Institute of Professional Environmental Practice (IPEP) has awarded Heidi Ann Fleming certification as a Qualified Environmental Professional (QEP).  Ms. Fleming is a Project Manager for Avogadro Environmental Corporation.  Achievement of the QEP certification is considered to be an accomplishment of the highest order, signifying strong professional and ethical standards in the arena of environmental management.  The award comes after rigorous scrutiny of experience and qualifications, and satisfactory completion of the oral/written examination.  As a QEP, Ms. Fleming is required to participate in continuing education and to maintain high ethical standards. 

The QEP certification is the first and only multi-media, multi-disciplinary, board-certified credential of its kind that requires environmental professionals to consider the overall environmental picture, and to have the skills and knowledge to resolve real world problems.  Through the QEP certification, environmental professionals demonstrate the breadth and depth of their knowledge and experience.  It is distinguished from other certifications by its cross-disciplinary nature.   The QEP is international in scope and has received accreditation by the Council of Engineering and Scientific Specialty Boards (CESB). 

As a newly certified QEP, Ms. Fleming will join the ranks of certified environmental professionals throughout the world.  The Institute of Professional environmental Practice awards approximately 50 certifications annually.  for further information on the QEP, contact the IPEP office at 412-396-1703 in Pittsburgh, PA.

By Heidi Fleming

Avogadro regularly attends meetings of NJDEP’s Industrial Stakeholders Group (ISG).  This group focuses on Air Quality Permitting within the State of New Jersey and is composed largely of DEP air quality permitting and air quality enforcement staff as well as representatives of regulated industries.  At the February 4^th NJDEP ISG Meeting, Mr. John Preczewski of the Air Quality Permitting Program distributed a draft memo regarding Permitting Repair and Maintenance Activities for review and comment. 

The memo contains potential clarifications on whether equipment used to conduct repair and maintenance activities should fall under the same air requirements as equipment used to conduct construction activities.  This means that if the repair and/or maintenance equipment will be situated at one location for less than 12 months, it does not require an air permit.  If the equipment is to remain onsite for more than one year, however, then it will require permitting.  This only applies to equipment that is brought onsite in order to conduct the repair or maintenance, and does not become part of the production process. 

The memo lists 15 equipment scenarios and whether they are required to obtain a permit.  Some specific examples include:

During stack testing activities, Avogadro’s field crew may need to set up where power is not readily available.  In this case, small portable diesel generators can be the best choice to provide power.  This temporary equipment does not need to be permitted.

A facility may need to bring in a crane and compressor to replace a burner in a boiler.  In this case, the burner replacement is a permitable activity and would need to be reviewed by DEP.  The crane and compressor needed to perform the repair, however, do not need permits.

A facility is cleaning out a reaction or mixing vessel for a new production load utilizing a compressor/pump.  In this case, both vessel cleaning and compressor/pumps would need permits, as they are part of the production process.

A temporary piece of process equipment or a control device is brought in so that a turnaround can take place on the existing equipment.  In this case, since a permitted piece of equipment or control device is being replaced, even though it may be of equal quality and/or for a short period, a permit is required.

Portable lighting powered by diesel engines can be brought onsite to be used during power failures and other out of the ordinary events such as spill cleanups.  In this case, if the activity is less than one year in length, no permit is required.  However, if the equipment is purchased, instead of rented, the generator for the lighting would be subject to permitting if it’s above subchapter 8 thresholds.                       

 NJDEP encourages interested parties to provide any additional scenarios so that the guidance can be clarified and intends to publish a final document by sometime in the spring of 2011.

If you would like to share any comments on this document with NJDEP, please email john.preczewski@dep.state.nj.us.  For more information regarding ISG, please go to http://www.nj.gov/dep/aqpp/isg.html.

Author: William Barnes, PE – Manager of Consulting Engineering, Avogadro Environmental Corporation

 Bill Barnes of Avogadro offered a presentation on the role of Energy Management Systems in managing business risk and environmental impacts at the Greater Lehigh Valley Chamber of Commerce (GLVCC) fourth annual environmental innovations conference.  The conference provided a showcase of locally grown technologies and integrating partners for energy conservation, management and source alternatives.  The Environmental and Energy Sub-Committee of the GLVCC (which Bill is a member of) combined efforts into a single annual event recognizing the convergence of environmental and energy efficiency initiatives.  Forward thinking companies and those looking to survive the economic challenges of this new decade explored sustainable solutions that can benefit the environment and community and lower your bottom line.

 With the recent enactment of the Greenhouse Gas Mandatory Reporting Rule (GHG MRR) by the USEPA, many industrial sources of air emissions of GHG are now required to report releases, primarily as a result of direct and indirect use of fossil fuels.  Even more, this opens the door to EPA promulgating regulations for the permitting of sources of GHG using existing Clean Air Act programs such as New Source Review (NSR).  As a means of establishing Maximum Achievable Control Technologies (MACT) for sources soon to be subject to permitting, it has been suggested that affected sources demonstrate means to achieve reductions in their energy intensity as a MACT demonstration.

Consider that over 180 institutional investors managing more than $13 trillion in assets have reached out to Congress to help create a stable environment for long term investing through a GHG cap and trade program.  Consider that the US Government has already committed $117 billion in stimulus funding to energy efficiency and GHG reduction technologies.

Sparked by the GHG MRR, SEC guidelines and expanded interest in Voluntary Disclosure programs, corporate America has now progressed into an effort of diligently and seriously accounting for and managing the material risk of your activities.  You say you don’t have significant GHG emissions.  What are the material risks of climate change on your operations?  Availability of natural resources, sustainability of your suppliers, changes to the business world and marketplace, and other factors still impact your ability to put product to market profitably and suddenly it’s your business.

This adds to the list of newly realized and much publicized corporate drivers for the reduction of energy use.  Before the GHG MRR, there were voluntary programs for GHG inventory reporting to raise visibility of energy use in manufacturing and power generating industries.  Carbon Footprint management has quickly been spotlighted as a must in the eyes of the investment community.  De-regulation in Pennsylvania and elsewhere over the past several years has resulted in steep increases in the cost of energy and ultimately the cost of doing business in America.  This all gets tied in to Sustainability Reporting for corporate America – protecting the economy, the environment and local communities in the course of business.  As a result, energy use and management has risen from the occasional spreadsheet report from facilities maintenance and engineering supervisors to being a core corporate. Key Performance Indicator (KPI), even establishing new roles like Energy Manager in many companies.

Yes, all of this drives new business innovations.  New techniques and tools for conducting energy audits are all over the Internet now, and even utilities are being driven to push energy efficiency measures to their large corporate and industrial consumers as a solution pathway versus construction of new generating capacity.  LEED certification of new and retrofitted commercial, industrial and institutional building designs and construction have proven out a wide variety of new building materials, lighting systems, and rooftop gardens as effective means to lower the carbon footprint and energy intensity in high-rise offices, hospitals, factories, and even schools.

Organizations with environmental management systems (EMS) certified to international standards such as ISO 14001 are now demonstrating continual improvement and pollution prevention through energy related advancements and innovations.  As a certified EMS auditor, I’m seeing these projects more and more as the new measures of continual improvement, in large part because they get corporate attention.  In the 70’s and 80’s, the Total Quality Management (TQM) movement drove reduction in scraps and rejects through Quality Management Systems (QMS) through certified ISO 9001 systems.  Whereas in the past, materials reductions or toxicity reductions have dramatically reduced the release of harmful chemicals throughout industrial America, the new currency of improvement and efficiency is energy intensity –  the amount of energy needed to obtain and process raw materials into finished consumer goods.  This has the potential to affect every conceivable industry sector from cell phones to your dinner plate and everything else consumed in this consumer hungry world (don’t forget exploding marketplaces in India and China now).

The international systems community has evolved the ISO 50001 Energy Management Systems (EnMS) to provide a framework for management circles to demonstrate energy efficiency aimed at lowering energy intensity.

“ISO 50001 will promote a managed approach to energy efficiency programmes, including key performance indicators (KPIs) to track improvements from a baseline. I predict it will be the ‘new quality’ for this decade.” – Bill Schiel of Invensys – Microsoft Commentary, OnWindows.com, 7 July 2010

Corporate energy managers are now tasked with managing portfolios of energy consuming assets and operations.. With the emergence of smart grids, they are enabled to manage consumption in real time to take advantage of price differentials throughout the day to time consumption by energy intensive processes when capacity is available at lower cost. This encourages companies to produce goods and services with less energy overall and to lower costs of doing business at the same time.  Yet another industry is emerging providing analytical software that models when to take advantages of capacity and lower costs.

According to a recent ANSI press release, the soon to be released ISO 5001 standard (due in early 2011) provides:

• A framework for integrating energy efficiency into management practices;
• Making better use of existing energy-consuming assets;
• Benchmarking, measuring, documenting, and reporting energy intensity improvements and their
• projected impact on reductions in greenhouse gas (GHG) emissions;
• Transparency and communication on the management of energy resources;
• Energy management best practices and good energy management behaviors;
• Evaluating and prioritizing the implementation of new energy efficient technologies;
• A framework for promoting energy efficiency throughout the supply chain; and
• Energy management improvements in the context of GHG emission reduction projects.

Another front in the war on energy consumption is sourcing.  There are numerous non-carbon and lower carbon footprint opportunities emerging.  In the Lehigh Valley alone, Crayola and MARS Chocolate NA have pursued development of solar energy farms at corporate and manufacturing sites.  Wind energy has emerged as both distributed energy and feed-to-grid alternatives to Pennsylvania-based industries. 

In our business of environmental compliance management at Avogadro Environmental, we have been engaged in a number of activities over the past several years for local enterprises that are serious about changing their energy intensity and their carbon footprint for both stewardship and financial gains.  We have seen firsthand, the turn in direction towards these new innovations.  Distributed natural gas-fired engines providing combined heat and power (CHP) energy are taking advantage of readily available cheap natural gas as is the case at Warren Hospital in Phillipsburg, PA.  Even energy intensive industries like cement are exploring alternative fuel sourcing such as plastic-derived fuel and biogenic fuels such as waste paper and wood to replace coal in kilns.  We’ve been engaged in demonstrating their viability in the marketplace and lesser impact on the environment.  Yet other local companies such as NAGSCO offer recovered petroleum oil and vegetable-oil based biodiesel fuel.

For consultation on environmental management systems and energy management systems integration please contact Bill directly at bbarnes@avogadro.net.

By Tom Mattei

First A Bit of History

More than 10 years ago, USEPA published Methods 201A and 202. Method 201A (M201A) was designed to measure filterable particulate matter (PM) with an aerodynamic particle size of ≤10 microns (PM10). However, because condensable particulate matter (CPM) is less than 10 microns, it could not be measured by M201A. As a result, USEPA published Method 202 (M202) to measure condensable particulate matter (CPM). In one sample system, sampled stack gas first passes through M201A equipment before going through M202 equipment.  USEPA Method 5 or USEPA Method 17, which are both used to measure total filterable PM, may also be used with M202. M202 is not meant to be used by itself.

What was revised?

The principle of Method 202 was to scrub CPM out of sampled stack gas by bubbling it through high purity water. The water would then be analyzed for CPM collected in it.  However, by bubbling sampled-gas through water, CPM was believed to be formed in the water from things in the stack gas other than just CPM.  Instead of just collecting CPM from the sampled-gas, additional artifact CPM would form in the water. Since there’s no way to distinguish between collected and formed CPM, the measured CPM would be biased high by any formed CPM.  Sulfur dioxide is the biggest possible contributor to formed CPM (by forming sulfuric acid) and was the real focus of the new method development.

To address this issue, USEPA published Other Test Method 028 (OTM-28). Late last year, USEPA promulgated this method as Method 202 and it replaced the existing version of the method. “New” M202 is substantially different from “old” M202. In old M202, the water also cooled the sampled-gas, which is needed to properly collect CPM. In new M202, a water-jacketed condenser system is used to cool the stack gas to the point where CPM will efficiently collect in the condenser system, on a filter and in moisture condensed from the stack gas. Most importantly, with new M202, no longer does sampled gas bubble through water. Thus, the opportunity for CPM to be formed in the sample is greatly reduced, which improves the accuracy of new M202 over old M202.  

What about Method 201A?

The principle of Method 201A was to separate PM10 from larger PM with a cyclone.  Once separated, filterable PM10 would collect on a filter. However, recent years have seen the advent of emissions standards for PM with an aerodynamic particle size of ≤2.5 microns (PM2.5). Some sources have limits for both PM10 and PM2.5.

To measure PM2.5, USEPA added a second cyclone to M201A to separate filterable 2.5 from larger PM. Sampled gas goes through the PM10 cyclone and then the PM2.5 cyclone. They dubbed the sample system Other Test Method 027 (OTM-27). At the same time Method 202 was revised, USEPA promulgated this method as M201A and it replaced the existing version of M201A.

“New” Method 201A provides two key measurements; filterable PM ≤10 microns, but >2.5 microns and filterable PM ≤2.5 microns. New M201A has provisions for using one cyclone or the other at one time. Thus, by choosing one cyclone or the other, measurements can be limited to just filterable PM10 or just filterable PM2.5.

How This Affects You

Revised Method 202 should provide higher quality condensable emission data, especially for sources which emit high concentrations of sulfur dioxide.

Revised Method 201A is really just the old version of the method, enhanced to include collection of PM2.5 along with PM10. However, M201A can’t be used at sample locations where water droplets are entrained in the stack gas. In this situation the most common approach is to measure total filterable PM by Method 5 or Method 17.

Since PM2.5 and/or PM10 measurements almost always include condensable PM, be sure revised Method 202 will also be used.

When seeking stack emission testing services, be sure revised Method 202 and revised Method 201A will be used.  Avogadro has experience with both the original and revised versions of both methods on a wide variety of emission sources.   If you need PM2.5 and/or PM10 emissions measured, and the sample location contains entrained water droplets, Avogadro can help you to understand the available emission sampling options To download a copy of the promulgated rule, go to the EPA’s website

Effective March 2012, new and existing boilers under 10 MMBtu/HR at major sources are required to conduct boiler tuning every other year.  Many owner/operators already have tuning arranged as a periodic maintenance item, especially with the rising costs of fuels.  Maintain those records as compliance records going forward.  Other work practices include conducting start up and shut down in accordance with manufacturer’s guidelines or other documented procedures.  Many owner/operators have copies of manufacturer’s O&M manuals, but haven’t looked at them in years.  Get it out, dust it off, or download another copy off the Internet.  Review it with your operational staff and document any regular deviations.  These will become an inspect item in the future should you get visited by USEPA and/or state agencies implementing this rule.

Until now, many boiler owner/operators have not closely followed manufacturer’s guidelines in O&M Manuals, often for good reason.  Equally so, tuning information never makes it into the environmental folder in the file cabinet.  Times are changing.  Your work practices for boilers new and old are now subject to more scrutiny and inquiry by people who likely won’t know much about your equipment.   What are your plans?  Give us some feedback!