Monthly Archives: August 2016

USEPA Issues Final Rule On Formaldehyde Emission Standards For Composite Wood Products

On July 27, 2016, the USEPA released a prepublication version of its final rule on Formaldehyde Emission Standards for Composite Wood Products. This is important as the USEPA has classified formaldehyde as a probable human carcinogen and many buildings looking to meet green standards take care to minimize indoor formaldehyde emissions. The authority for the rule comes from the TSCA. The USEPA’s rule relies heavily on the formaldehyde emissions rules set by the California Air Resources Board (CARB). The federal standards are identical to those set by CARB.

Formaldehyde emission standards
Hardwood plywood (with a veneer core or composite core) = 0.05 ppm
Particleboard = 0.09 ppm
Medium-density fireboard (MDF) = 0.11 ppm
Thin MDF = 0.13 ppm

When it goes into effect, this rule will affect manufacturers, importers, distributors, and retailers of products containing composite wood as listed above.
The USEPA’s final rule goes into effect one year after its publication in the Federal Register. At that point, fabricators, importers, distributors, and retailers of finished goods containing composite wood must begin to comply with new recordkeeping and labeling requirements. The final rule contains detailed requirements for recordkeeping, labeling, and testing of both composite wood and products containing composite wood.

Record-keeping and labeling. Fabricators, importers, distributors, and retailers of composite wood or products containing it will be required to “take reasonable precautions” to ensure their products comply with the emissions standards, defined as preparing or obtaining appropriate documentation, such as bills of lading or invoices, from suppliers of composite wood products that includes a written statement that the products are either compliant with the emissions standards or were produced prior to the rule taking effect. Companies must retain this documentation for at least 3 years.

In addition, importers must provide records (within 30 days of a request by the USEPA) identifying either the composite wood panel producer and date the composite wood products were produced or the supplier of the composite wood products (if different than the producer), component parts, or finished goods and the date of purchase.

Manufacturers of subject products must label each bundle containing finished goods with manufacturer’s name, date produced, and a statement that the material complies with the emission standard. Importers, distributors, and retailers must keep the label on each bundle and make information available to potential customers if requested.

Importer Certification. 2 years after final rule publication, importers will be required to certify that imported composite wood or products containing it comply with the standard.

Testing requirements. Beginning 7 years after publication of the final rule in the Federal Register, manufacturers of laminated products will be required to comply with third-party testing and certification requirements that apply to manufacturers of hardwood plywood panels. “Laminated products” are defined to include only those products with a wood or woody grass veneer, so testing requirements will not apply to synthetic laminates such as plastic or vinyl. The rule does contain certain exemptions for certain laminated products and for use of ultra-low emitting formaldehyde (“ULEF”) resins.

CCES can provide you with technical assistance to help you assess compliance with this and other environmental rules, and to perform a green building analysis. Contact us today at 914-584-6720 or at karell@CCESworld.com.

White House Issues Final Guidance On Climate Change Analyses in NEPA Reviews

On August 1, 2016, the White House Council on Environmental Quality (CEQ) released final guidance on how federal agencies should consider the direct and indirect impacts of climate change, including from greenhouse gas (GHG) emissions, in environmental reviews conducted under the National Environmental Policy Act (NEPA). See https://www.whitehouse.gov/sites/whitehouse.gov/files/documents/nepa_final_ghg_guidance.pdf. This final guidance is not part of rulemaking and, therefore, is not binding regulation. However, some courts consider CEQ guidance when evaluating NEPA reviews. The guidance is effective immediately, and encourages agencies to use it for all new proposed agency actions for which NEPA review is required.

The final guidance confirms the importance of climate change and its effects and GHG emissions fall under NEPA’s perview. In performing such a review of a proposed project, it is fair to evaluate its GHG emissions and the potential effects of physical climate change impacts. The guidance does not give exact criteria that must be followed in terms of GHG emissions and climate change (a change from the draft guidance), but gives each federal agency the flexibility to use its preferred experts and methods to assess impacts and options. For example, the guidance does not contain a threshold level of GHG emissions that would require review or action, but allows the individual agencies to make that determination.

The guidance calls for a quantitative analysis of potential GHG emissions from a proposed project if appropriate and reliable tools or methodologies are currently available. Stating that GHG emissions are “negligible” or expressions like this are discouraged. A quantitative analysis is also required in discussions of alternatives to a proposed action. However, the guidance does not require the decision maker to select the alternative with the lowest level of GHG emissions. A balanced environmental approach is preferred.

The guidance also calls for agencies to consider how climate change impacts, such as increasing sea level, drought, heavy precipitation, etc. could affect a proposed action. Given that certain aspects of projects, such as development in floodplains or on or near a coastline, could be vulnerable to climate change, agencies should either reject such projects or identify opportunities for adaptation to these effects.

CCES has the technical experts to help your firm perform a quantitative evaluation of GHG emissions and assess potential climate change impacts on a potential project. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Insulation: Another Way to Save Energy Costs

Pipe and building insulation are proven strategies to reduce energy usage and, therefore, costs. Don’t try this at home or at work, but imagine how hot a metal pipe in steam or hot water service is and then imagine the reduction in heat loss when it is properly insulated. That heat loss stays inside the pipe with the steam or hot water, making it more effective and necessitating less energy usage (fuel combustion) to produce that steam or hot water. Properly and completely insulating a bare surface in steam or hot water service can easily reduce heat losses by over 90% and therefore, reduce your need to produce steam or hot water significantly, saving you fuel costs, improving safety (workers not touching the hot pipes), and reducing emissions of greenhouse gases and of toxics that may impact your plant and neighbors.

To illustrate the cost-effectiveness of insulating pipes in steam or hot water service, see this example. A facility produces and pumps steam at 350°F from an oil-fired boiler operating at an average efficiency of 80%. Oil is purchased at $2.50 per gallon. The 4-inch steam header is insulated with 2 inches of fiberglass pipe insulation. The North American Insulation Manufacturers Association (NAIMA) has software to estimate the energy savings. Let us say that the insulation reduced heat loss from that bare pipe by 95%. Assuming the boiler is used only during the heating season, this can easily save the building $100-$150 per foot per year, for the avoided cost of oil not combusted to replace the lost heat. This figure can be much higher if the cost of oil rises or if the boiler is used for other purposes and is used all year. This also reduces greenhouse gas emissions significantly, too.

Savings can also occur for cold piping, too. Cold water – from electric chillers – transported through pipes can be insulated to save the use of these chillers, reducing electricity usage. While oil prices are relatively low these days, electricity prices are at all-time highs and projected to rise even more. Anything that can be done to reduce electric usage, will save you money.

August is the time of year many buildings – residences, offices, and industry – check their boilers and chillers to make sure they are maintained so they run reliably in the upcoming months. Part of your evaluation should be whether there are pipes that are uninsulated or with insulation that is cracking and damaged. Of course, look out for asbestos and, if present, make sure its removal is managed professionally and via the law. If you see such areas that are uninsulated, underinsulated, or insulated with damaged or cracked insulation, now is the time to re-insulate it properly. That extra time and cost for insulation will be paid for in savings this winter.

CCES has the experts to perform an energy audit of your building, and examine this and many other energy issues to help you save energy and other costs reliably and effectively. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Prioritizing Your LED Lighting Upgrade

Most people know now that switching to more efficient lighting, such as LEDs, is one of the most effective strategies for saving energy costs. Facility managers are increasingly turning to LED lights for energy efficiency.

However, “going to Home Depot and picking up LEDs” is not the best way to upgrade buildings. It may be a stretch to change all your lights to LEDs at once (lack of available capital for upfront cost, lack of incentives to make it economically feasible). You may have certain goals and constraints. Thus, what can you do to optimize gains from a lighting upgrade in your facility? How should you prioritize an upgrade?

• Types and age of lights currently used. To best prioritize a partial upgrade, focus your replacement on the lights that are older and less efficient, such as T-12 fluorescents, halogen bulbs, and incandescents. Replacement of certain bulbs, such as newer T-8 fluorescents with new ballasts, represent a smaller efficiency gain. Of course, it is preferable to replace them all with LEDs, but if that is not possible, then replace older and more inefficient lighting types first.

• Your current fixtures’ hours of operation and usage. It is best to install LEDs to replace less efficient lights where high intensity light is needed, such as security lights. Also, determine which of your lights are on the greatest number of hours per year. Only bulbs that are on use electricity, so if lights are used in a situation where they are rarely on, such as a storage room or an electrical room, these could be candidates to be replaced later compared to lights used often. Or to look at it another way, prioritize replacement with LEDs of bulbs normally used often, such as warehouses, parking garages, hallways, elevators and entrances. Of course, for lights with these functions, it is also good to consider occupancy controls which automatically dim or shut off the lights during idle periods.

• Maintenance issues. Prioritize replacement of lights with LEDs in places that are difficult to reach or require significant time. LEDs last considerably longer than most fluorescents and incandescents. Therefore, LEDs will also free up your maintenance staff to perform other duties. It will also reduce rental fees of cherry pickers and result in fewer trips up and down ladders, reducing the risk of a costly accident. Longer lasting LEDs mean fewer bulbs to keep in storage, freeing up some space there, too.

• Prioritize based on operating condition needs. Unlike most other lights, LEDs do not flicker, reducing eyestrain for office workers. A recent study estimated that properly-designed (less glare) lights resulted in the average office worker having one less “coffee” break per day, improving productivity. Therefore, switching to LEDs in an office setting could be a higher priority. LEDs can also be found in any color on the CCT scale (2,000 to 7,000 Kelvin). For areas where precise work by workers is critical, such as lab or work benches and offices, an LED with a high CCT rating (5,500-6,000K) may be best.

Of course, it is preferable to maximize energy cost reductions by replacing all your lights with appropriate LEDs. However, because many large buildings and entities have financial and other constraints it may be necessary to prioritize where one replaces older lights with LEDs. Proper research into the areas of the building that are lit and their function and current lighting status will be helpful in prioritizing properly.

CCES can help you design and implement a lighting upgrade to maximize your financial benefits and improve productivity. Contact us today at 914-584-6720 or at karell@ccesworld.com.

Resolution for 2017: Take Control of Energy – Your Most Controllable Operating Expense

It is August, and things may be slow in your office or company, as many people are taking well-deserved time off. But that also means that September – the start of school, fall is around the corner – which means everyone is back at work. For many companies, September is also the start of budgeting season. Departments and Operations envision and plan for projects in 2017, and request budget for them. I think energy efficiency should be on the top of your wish list for your company, as this is the lowest-hanging fruit for reducing operating costs and also provide other financial benefits. Of course, you need to communicate that energy efficiency provides great return for minimal risk to your Finance Dept in language they understand to get approval for initial upfront funding. Actual case studies demonstrate that smart energy efficiency projects help businesses be more competitive.

Briefly, here are some facts about energy efficiency to present to your bosses and CFO:

• Great financial returns. The rates of return for energy efficiency projects vary, of course, based on technology, the building, and design. But in many cases, they are superior to most financial investments, often over 25%/year. What bank or Wall St. investment pays that?

• Low risk, high reliability. New energy efficiency strategies are not experimental and are proven in the field. While some vendors offer better quality products than others, they will work, bring about energy reductions, and should be warrantied.

In financial investing, we are constantly faced with high risk to get high yields. Or if we are afraid of losing our investment, we sacrifice yield. With energy efficiency, we have low risk (reliable product) and get fine cost savings! See chart comparing energy efficiency with other financial investments found below:

http://www.roienergyservices.com/wp-content/uploads/2014/10/Risk-reward.png

• Long lasting savings. Energy efficiency results in continual savings for many years, actually growing in time with no additional effort, based on energy rates you pay, which will only go up in the future. If you saved $1,000 in one year from an energy efficiency project, that savings will be $1,050 the next year if rates increase 5%. And that is with no additional effort on your part!

• Reduced O&M costs. Most technologies last longer than the ones replaced. This means less time for maintenance staff, for example, changing light bulbs. This frees them up for other, more important projects to benefit employees and customers (tenants). Fewer light bulb changes also means fewer trips up and down the ladder, reducing the risk of a costly accident. Longer lasting items mean fewer need to be procured in reserve and stored, freeing up space for other uses or allowing you to downsize the space you rent.

• Raise the desirability and value of your property. Perhaps I’ve saved the best for last. Studies have shown that buildings and offices that are energy efficient are ones that employees will work more productively in, which may be more valuable than the cost savings. Employees will be happier, too, reducing turnover and reducing HR and productivity costs of finding replacement workers and hoping he/she is as good as the one that left. With solid energy efficiency technologies to show, companies or families will have a greater desire to rent your property, raising rental income, or desire to buy your building, raising its resale value.

Bottom line: the right, smart energy efficiency projects will produce many financial benefits, more than compensating for the cost to implement them, and an overall positive cash flow.

I hope this primer will help you approach your bosses for some smart energy efficiency ideas and projects for 2017! CCES has the experts to help you design and implement energy efficiency projects to maximize the financial benefits and to ensure they are implemented properly and work well. We want you to succeed and get the benefits and credit! Contact us for an initial discussion at karell@ccesworld.com or at 914-584-6720.

USEPA Releases New Final Landfill Emissions Rules

August 2, 2016

On July 15, 2016, the USEPA released a new final amended rule limiting emissions of greenhouse gases (GHGs) and other compounds from both existing and newly-constructed municipal solid waste landfills. This is the first modification to the federal landfill emission rule in 20 years and, for the first time, addresses GHG emissions. There has been the realization lately that any approach to successfully reduce GHG emissions nationally mist include reduction of methane emissions, a major component of landfill gas, because it is 21 times more potent on a mass basis than the main GHG, CO2, which had been the focus of most GHG reduction strategies. Therefore, came this focus on amending the main federal municipal landfill air quality rule.

Newly-constructed or modified landfills after July 17, 2014 will have emission limits found in New Source Performance Standards (NSPS) or Sect. 111(b) of CAA. See https://www3.epa.gov/ttn/atw/landfill/landfills-nsps-2060-am08-final-signature.pdf For existing landfills built before this date, emission guidelines have been published to be implemented by each state in their specific plans. See https://www3.epa.gov/ttn/atw/landfill/landfills-eg-2060-as23-final-signature.pdf. The USEPA estimates that the new standards will cover over 1,100 new and existing landfills at a combined compliance cost of approximately $60 million by 2025.

The new standards apply to landfills that have design capacities of 2.5 million metric tons and 2.5 million cubic meters or more of waste, no change in the current rules promulgated in 1996. Under both the rule and the guidelines, facilities that meet the design thresholds and emit over 34 metric tons of non-methane organic compounds (NMOC) per year will be required to install a gas collection control system (GCCS), such as flares, an enclosed combustion system for energy generation, or gas treatment system for its sale or beneficial use. A landfill may be exempt from GCCS requirements even if it meets this applicability threshold if it can demonstrate that the surface NMOC concentration is below 500 ppm for consecutive quarters.

The rule and guidelines will take effect 60 days after publication in the Federal Register (which has not occurred yet as this article is posted). Any facility that exceed the design capacity and NMOC emissions thresholds will have 30 months to install GCCS. The USEPA estimated that > 100 newly-built or modified landfills will install GCCS by 2025.

Capturing landfill gas can be beneficial as it is combustible and can be useful in generating electricity, heat, or hot water. So while being mandated to capture landfill gas can be costly, it is a “free” source of energy that can be converted to useful energy to reduce your energy costs.

CCES can provide for you the technical portion of the advice to determine which federal and state air quality rules are applicable to you and the most cost-effective strategies to maintain compliance. Contact us today at 914-584-6720 or at karell@CCESworld.com.