AB AMERICAN BOILER MANUFACTURERS ASSOCIATION 1500 WILSON BOULEVARD, ARLINGTON, VIRGINIA 22209 MA SUITE 317 AM BUILDING 703/522-7298 Revised July 17, 1975 COMMENTS OF THE AMERICAN BOILER MANUFACTURERS ASSOCIATION FOR THE SENATE COMMITTEE ON PUBLIC WORKS ON S.1777 THE PROPOSED NATIONAL PETROLEUM AND NATURAL GAS CONSERVATION AND COAL SUBSTITUTION ACT OF 1975 June 30, 1975 I. Introduction The American Boiler Manufacturers Association is a national manufacturing trade association whose 78 members market, design, fabricate and erect steam generators (boilers), fuel burning equipment and air pollution control systems for the public utility, industrial, marine and heavy commercial markets. Founded in 1888, the Association is now located in Arlington, Virginia. ABMA active member companies manufacture most of the commercial and industrial boilers, all of the fossil fuel-fired utility boilers and a significant portion of the nuclear steam supply systems used in the United States. ABMA boilers are manufactured in sixty plants in twenty-five states, employing approximately thirty thousand persons in manufacturing. A list of the members of ABMA is given in Appendix I. The 1974 sales of steam generating equipment and fuel burning systems by member companies were well over one billion dollars. Steam generating equipment is used in the generation of electricity and in the chemical, petroleum refining, pulp and paper, food, transportation, primary metals, wood, textile and rubber industries, among others. In addition it is used to heat large commercial and institutional buildings, e. g. hospitals, schools, universities, housing developments, apartments and office buildings, including the federal buildings in Washington and federal and military installations across the nation. There is scarcely an American industry, commercial firm or institutional user that does not rely on steam generating equipment for one or more of its basic functions. The expressed purpose of S.1777 is to effect an orderly replacement of oil and natural gas with coal as boiler fuel to the maximum extent practicable. ABMA subscribes to this principle of prudent utilization of our country's natural resources and the reduction of waste in materials and manpower by placing all elements of our economy in proper perspective and priority. All electric utility and industrial installations which contain fossil fuel-fired boilers that singly or in combination are by design capable of being fired at a heat rate of fifty million Btu or greater are covered by the provisions of the bill. It should be recognized that this 50 million Btu lower limit includes many more boilers than would normally be included by the designation "major industrial installations". Many of the boiler units covered by this specification are designed to burn gas and oil only, and for reasons described later, it is not practicable to convert them to coal firing. Therefore, replacement of the units is the only alternative. While conversion costs for units where this is practicable will be very large, the replacement of boilers where conversion is not practicable will impose an even greater burden on the resources of those affected. Therefore, the costs to achieve the stated objectives of this bill may be prohibitive and even publicly unacceptable. Specific problems which should be considered and solved before the purposes of the bill can be fulfilled are somewhat different for industrial installations than for electric power plants. These will be discussed below. 55-305 75 pt. 3 II Major Industrial Installations Senate bill S.1777 pertains to major industrial installations in addition to electric utility power plants. Per section 105 of the proposed bill the term "major industrial installation" means an installation other than a power plant that contains fossil fuel boilers, burners or other combustors of fuel that in combination are by design capable of being fired at a heat rate of 50 million Btu's per hour or greater and includes any person who owns, leases, operates, controls or supervises any such installation. As stated above the proposed legislation would apply to power plants of not only large industrial firms but also to small and medium industrial, commercial, institutional, hospital and any other installation which would have a combination heat input of 50 million Btu or greater. There are many such installations and most of these have multiple boiler units that add to the proposed heat rate input level. Examples of such "non-utility" category power plants include, in part, common installations such as: Many of the above installations not only have "on-line" boiler units, but also "standby" units or multiple boiler units of smaller size for capacity load flexibility. Many primary industries utilize a substantial amount of reported energy consumption for uses other than in boilers. These applications would include process heaters, heat treating furnaces, driers, ovens and incineration systems, to name a few. Based on a 1971 National Science Foundation Study, almost 50 percent of gas and oil input for primary industrial applications is used for non-boiler applications as described above. In summary, while the term "large industrial" is used in the proposed bill, it should be understood that the proposed power plant size pertains to a wide range of industrial, institutional, commercial, hospital and educational facilities. Secondly, a substantial amount of energy consumption in primary industrial plants is for uses other than boilers. The markets served by ABMA member companies are as varied and diverse as American industry itself. The products are used in boiler units ranging from small package units to large field erected boiler systems. The factory assembled package units range in size from less than one million Btu per hour heat rate input size to over 300 million Btu per hour input. Above an input level of 300 million Btu per hour most boilers are field erected. Factory assembled package units have been installed by the thousands during the past 20 years and have been almost exclusively engineered and designed for non-coal firing. In fact well under ten percent of these units have the capability for coal-firing. The package units have Revised 7/17/75 |