Cost for implementation of the BIF rules

The Boiler and Industrial Furnace Regulations (BIF) imposed an enormous cost and regulatory burden upon industries and commercial facilities which chose to continue the practice of extracting energy from waste-derived fuel. This paper looks at the cost of implementation of these regulations. The cost associated with implementation includes both direct and indirect costs. The direct costs encompass the following list. (1) Interim status permit compliance, encompassing precertification and development of other interim status documents. (2) Compliance testing. (3) Part B permit activities and implementation of Trial Burn Plan. (4) Installation of hardware and process control equipment to comply with regulations. (a) Continuous emission monitors for CO, total hydrocarbons and oxygen. (b) Process controller systems with automatic cutoffs for the nine automatic cutoff parameters. (5) Instrumentation of flow rate controllers. (6) Increased secondary containment and spill prevention requirements. Indirect costs have been shown to be a very significant part of the increase in compliance with the BIF Regulations. Additional personnel is required to maintain the instrumentation and cutoff system, including skilled instrumentation and computer hardward/software personnel