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Pre-Compliance Planning: When to Begin

The following is taken from an artile we published in the Winter edition of The Steamlines, our corporate newsletter.  Climate change and compliance in California and other parts of the nation is a hot topic, and often times, companies are faced with tough decisions, with little information. Find out how Nationwide Boiler dealt with meeting compliance, through a proactive approach. In the long run, it was the right decision and today we continue to push the envelop in energy efficiency and ultra low emissions.

A recent shift away from coal and towards natural gas has been brewing in the United States. Many companies are taking advantage of the plunge in natural gas prices due to the introduction of horizontal drilling technology leading to the expansion of new reserves throughout the United States.

Business Week recently reported that several major utilities including Progress Energy, Tampa Electric and General Electric all have new strategies based on a shift to natural gas. Many of these strategies are combined with other renewable energy projects such as solar and wind power, helping to create a “balanced” strategy and utilizing all possible energy and efficiency instruments.

However, the Energy Information Administration suggests that natural gas prices will not stay low for long and that the fuel-switching trend will be short-lived. It may only be a matter of time when the laws of supply and demand take in effect, driving up fuel prices. If and when this happens, will these strategies change or will it be too late? Unlike the utilities above which have conducted major shifts in their business plans associated with predicted price savings, many other companies in varying sectors have decided to wait before committing to long-term strategies. This holds especially true on the topic of climate change. Many companies are taking the sidelines until climate change policies become final and are not making risky shifts to their business plans. Overall, when it comes to long-term environmental planning, when is it the right time?

From experience, long-term, pre-compliance planning paid off for Nationwide Boiler. As local air quality regulations in California rapidly decreased the limits for NOx emissions, Nationwide took action to research and develop strategies that would enable our rental boiler fleet to perform at the lowest NOx levels available. Ultimately, Nationwide chose a compliance strategy based on the best technology currently available, able to deliver the highest performance. Our CataStak Selective Catalytic Reduction (SCR) System was born through this discovery and today the CataStak SCR product line includes solutions for gas turbines, steam generators, watertube and firetube boilers, field-erected boilers and heaters.

Had Nationwide waited for final determinations made by air quality regulators, we would not have been able to provide a product offering for our customers by the time compliance was mandatory. In the long run, pre-compliance planning enabled us to better serve our customers with reliable, well proven solutions and in the process the company has grown, provided new jobs and Nationwide Boiler has expanded its operations to include a new strategic business unit. The new business unit, Nationwide Environmental Solutions, was specifically formed to help solve tough compliance issues and provide total plant solution that yields both emission reductions and increased energy efficiency.

Currently, both federal and state regulators are proposing aggressive strategies to combat climate change and promote energy reductions. In California, the Global Warming Solutions Act requires California to develop regulations that will reduce gas emissions to 1990 levels by 2020. Assembly Bill 32, targeting large generators of greenhouse gas, is currently in the drafting phase to support the act and it includes a cap-and-trade program that establishes a cap covering 85% of the state's GHG emissions. If passed, large industrial sources that process at or above 25,000 metric tons of CO2 equivalents will fall under these rules starting January 1, 2012. Similar situations are happening in TX, NY and other areas around the United States and the implications for businesses (as well as consumers) may be insurmountable. Increases in electricity, natural gas, transportation, product, and administrative costs are unknown, but likely.

Through our own experience we have learned that in terms of environmental planning it is vital that companies look and plan ahead in order to effectively manage risks, control costs, and to maintain competitiveness. The development of pre-compliance strategies based on best performance standards and efficiency upgrades should be of concern for every major facility in addition to the negotiation of long-term fuel and supply-chain contracts.

If you need assistance in developing a pre-compliance strategy, call Nationwide Boiler today. Our proactive approach to climate change was the right choice for us, and we are confident that it will also be the best choice for you.

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A Practical Approach to Easily Decrease NOx, Save Energy, & Improve Your Operations

Our latest case study, highlighting a major food processor is another example of how Nationwide Boiler can help achieve the best performance standards (BPS) for your boilers. We presented a E2Stak solution with a CataStak SCR system and an EconoStak economizer to a food processor in CA to achieve 5 ppm NOx and decease the plant's energy use, which resulted in the customer receiving a rebate check of almost $150,000. Not only did the we help the boilers achieve optimum performance, we also improved the operation and maintenance of the boiler. The plant manager's quote says it all: "This was the first year we could operate the boiler in automatic!"

If you are interested in decreasing your operating costs by saving energy and if you need to comply with tough emission standards, give Nationwide Boiler a call today at 800-227-1966. Our experience and expertise will provide you with additional options you may never have thought possible.

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Tips to Maintain Air Compliance

We recently came across an article in Pollution Engineering that highlights an important issue for all major facilities - air fines and how to avoid them. It is everyone's responsibility to ensure compliance and the best way to do so is by educating yourself and your team and by networking with others in the industry. Below highlights the main points from the article, but please visit the link above for a more detailed approached.

1.     Compliance is a team effort and the best preventive measure is to keep the entire team aware and fully briefed on where the facility stands in regards to compliance. With everyone in the know, compliance becomes a vested interest and a shared responsibility.

2.     A basic review of your facility's Title V permit, a federally enforceable document that provides parameters on plant emissions, is a good first start. A review of the basic allowable permissions contained in the permit will lead the way.

3.     Set a date for a frequent (yearly) review of the Title V permit. This will help flag inconsistencies and avoid further inspections and notices of violation (NOV).

4.     Get to know your local inspectors and do not hesitate to ask them for guidance. Ask them informative questions about what common violations they have seen lately and what others in the industry are doing to keep in good standing.

5.     Check out the following websites: The EPA's Acid Rain Inspectors Guide and the Clean Air Markets Division.

6.     To help keep abreast of changing regulations, join an association membership and attend industry events (conferences, seminars and tradeshows). Organizations such as the ABMA, CIBO and others update their members on a continual basis.

7.     Subscribe to the U.S. Environmental Protection Agency's Monthly Digest Bulletin. This e-magazine can be subscribed to by emailing usaepa@govdelivery.com. 

8.     Show pride in maintaining compliance and recognize and reward employees for their efforts in maintaining compliance.

9.     When evaluating vendors for stack testing, check their references, inquire about their experience in performing the tests needed to stay in compliance, and make sure that their work is conducted to the highest standards. Ask vendors if they are a Qualified Stack Test Individual, or QSTI.

10. Let your customers know about your compliance goals and your efforts to maintain "green" in your facility. Also promote this message to your stakeholders in the community.

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Regulatory Update - Final Mandatory Reporting of Greenhouse Gases Rule

Today the EPA published the final Mandatory Reporting of Greenhouse Gases rules in the Federal Register today.  The final rule is effective December 29, 2009, with reporting requirements in March 2011. Emissions of the six (6) major GHGs must be reported, including carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O), from combustion sources. Emissions of these GHGs are converted to carbon dioxide equivalents, CO2e, and must be reported in metric tons.

Does this apply to you?

The EPA set-up four broad categories in order to identify sources that must report under the program:

(1) Specifically designated facilities, including electric generating facilities.

(2) Facilities that emit more than 25,000 metric tons (MT) of CO2e per year in combined emissions from stationary fuel combustion units and sources in listed categories.

(3) Facilities that meet the following three conditions:

a. not identified in either of the other two categories;

b. aggregate design heat input from stationary fuel combustion units at the facility is greater than 30 MMBtu/hr; and,

c. the facility emits more than 25,000 MT CO2e per year.

Want to learn more? Click the link below for more information:

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html
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