In a recent government meeting, representatives from the Texas Chemistry Council (TCC) and Vistra Luminant Generating Company voiced significant concerns regarding proposed changes to boiler regulations under the Texas Administrative Code. The discussions centered around the implications of new language in section 65.13, which addresses boiler reinstallation requirements.

TCC's general counsel highlighted the importance of clarity in the proposed rules, emphasizing that ambiguity in terms such as \"disconnection,\" \"reconnection,\" \"disassembly,\" and \"reassembly\" could lead to unintended consequences. The council represents 67 member companies responsible for nearly 500,000 jobs in Texas and significant exports, making regulatory certainty crucial for their operations. They urged the board to reconsider the proposed language to prevent potential misinterpretations that could complicate maintenance activities.

Tony Harden, representing Vistra Luminant, echoed these concerns, warning that the proposed changes could create uncertainty and impair electric reliability by delaying the return of boilers to service after maintenance. He argued that the introduction of undefined terms could lead to unnecessary requirements for installation reports and inspections for boilers that have not been relocated or significantly altered. Harden called for either the outright rejection of the changes or a referral to a subcommittee for further discussion among industry stakeholders.

Both representatives stressed the need for a clear understanding of the intent behind the proposed rules and the potential risks they pose to operational efficiency and safety in the state's energy sector. The board's consideration of these comments will be crucial in determining the future of boiler regulations in Texas.