August 2013

Maybe many of you loved science fiction as a child (or even now as an adult). Research in new energy technologies is showing some results that one may expect to see in a page-turner. What is interesting is that these ideas are not necessarily energy saving, but energy optimizing; they enable the user to use energy only when needed and turn off when not. Here is a summary of some recent new technologies. Please do not take this blog article as an endorsement of any technology, product, or company. Do your own research to determine if any is right and at an affordable price for your situation.

LED Wallpaper, by Lynn Hoffman, AIA, LEED-AP, Lynn Hoffman Design, LLC

Wallpaper has been having a renaissance over the past few years. During a recent furniture Fair, I visited the Meystyle exhibitor booth and was quite impressed with the company’s wallpapers, which are embedded with LED lights and luxury Swarovski crystals. Their designs are digitally printed on high quality wallpapers, with the LED lights and crystals completely embedded into the material and intricately hand-applied. LED wallpapers offer innovative options to illuminate rooms and deliver great impact to spaces. The soft, little, mysterious lights hardly reveal where the twinkle of illumination is coming from, can replace standard light bulbs of ceiling fixtures or floor lamps, and use 90% less electricity. One big advantage of using LED wallpaper is it can be hung in more or fewer strips and lengths allowing various creative options. LED wallpaper is a way of bringing green energy to interiors and offering an alternative to wall art.
Copyright (c) 2013 Lynn Hoffman Design LLC All rights reserved.

Control and Integration of LED Lighting

Advanced Control Technologies (ACT) has a new product called “controlLED” tubes to provide building operators a way to control building lighting in a dynamic way. A simple connection to a signal conditioner attached to one of the controlLED tube fixtures provides control over multiple fixtures, allowing control of hundreds of different fixtures. These lights can coordinate with a Building Automation System (BAS) or allow for local ON/OFF or dimming. This flexibility allows the operator to specifically schedule individual LED light usage, such as turning on certain ones in certain areas during a given time period as needed. Local override is available when needed.

Smart Window Technology

Heliotrope, in conjunction with Lawrence Berkeley National Laboratory, has developed a new window glass coating that leverages an electrochromic (EC) effect to allow control of light and heat transmission independently and dynamically. Windows with Heliotrope EC coatings can switch reversibly between transparency, heat blocking, and heat and light blocking controlled by low voltage using minimal power. Heliotrope is working with glass manufacturers to evaluate its potential for commercial and residential buildings.

CCES has the technical experts to help you assess and incorporate energy-optimizing and energy-saving technologies, whether conventional or “outside the box”.

Several major locales are attempting to reduce greenhouse gas (GHG) emissions, not by mandating emission reductions, but by changing building codes instead. While building codes used to focus on safety (assurance that the building will not fall down or cause any other type of debacle or injury), some are being expanded to cover energy usage, based on the thinking that buildings draw upon infrastructure to bring electricity and fuel to the building, so it is reasonable to minimize usage. Since most GHG emissions derive from energy usage, this can help achieve an alternative goal, as well.

The California Energy Commission recently adopted new energy efficiency standards for residential and commercial buildings (http://www.energy.ca.gov/title24/2013standards/rulemaking/). The rule will go into effect Jan. 1, 2014 affecting new buildings and major alterations and additions to existing buildings in California, making them among the most energy efficient in the nation. They estimate that Californians will save 25% on energy for homes and 30% for commercial buildings, avoiding the need to build six large power plants, saving people several billion dollars in the form of lower electricity and natural gas bills, and reducing emissions of several million tons of CO2.

The Commission felt that building code modification was the best approach because it is at the construction stage is when more efficient insulation, windows, and HVAC equipment can be designed and installed, rather than after construction.

The City of Chicago recently passed a new rule requiring large buildings to perform and post up results of a thorough energy audit – to be transparent in their energy use for prospective tenants to be able to review and use in their shopping for residences or offices. A building does not have to become more efficient, but will have results posted for the public to see. Chicago joins New York City, whose Local Law 87 requiring all buildings of 50,000 square feet or greater to perform a similar thorough energy audit plus retrocommissioning of their HVAC systems once every 10 years, and submit results certified by energy and retrocommissioning professionals the results. That law went into effect this year. Other municipalities are looking into copying these standards.
Buildings and companies have to abide by many environmental, safety and other rules. Now some of the biggest municipalities and states have expanded this to include mandatory energy rules: meeting energy efficiency standards or performing professional audits and retrocommissioning. Energy has become another area that the building or company must address in a thorough, professional manner to remain compliant.

CCES has the technical experts (licensed professional engineers and Certified Energy Managers and certified Retro-commissioning professionals) to perform the energy audits needed to comply with these and other similar energy standards. We can not only catalog where you stand, but develop smart strategies to raise the value of your property or company, and save you money.

Workplace Environments

Indoor air pollution is often more dangerous to human health than outdoor pollution. This is because bad air is trapped within the building, where more concentrated pollutant exposure is generally found than outdoors. Indoor air quality in the workplace affects the health, comfort, wellbeing and productivity of all building occupants. Many of us spend up to 90% of our time indoors during the day and much of that time is working in an office. Studies by USEPA and others confirm that indoor environments sometimes have levels of pollutants that are actually higher than levels found outside.

The sources of indoor pollutants can come from poorly designed buildings, a building’s ventilation system design, operation and maintenance, building materials, finishes, textiles, furnishings, consumer products, occupant activities, cleaning products and processes, dust, pesticide applications, and microbial contamination. People typically do not have control over their office indoor environments as they do in their homes.

The possible health impacts are cancer, sensory, respiratory irritation or infection, gastrointestinal irritation, neurotoxicity, hormone disruption, allergy, asthma attacks. A number of well-identified illnesses, such as Legionnaire’s disease, asthmas, humidifier fever, and hypersensitivity pneumonitis have been tracked to specific building problems. Most of these building-related illnesses can be treated, but some do require prolonged recovery time after leaving the building.

To improve the indoor air quality in your office, try the following:

 Work with building management to ensure that all parts of the building and your office space are receiving optimal service from the HVAC system.

 Make sure air supply vents and return grilles are not blocked by furniture or other potential sources (i.e, files, books, papers).

 Make sure office equipment, such as copiers, printers, and fax machines, are adequately vented.

 Place computers and other heat-producing equipment away from HVAC sensors.

 Avoid the use of common office products, such as solvents, adhesives, cleaners and pesticides that can give off pollutants and odors.

 Before renovating your office space work with the building management and contractors to identify the best ways of minimize exposure to pollutants.

 Purchase only building materials, finishes, furnishings, and cleaning products that emit low or no volatile organic compounds (VOCs).

 Work with your building management to make certain only necessary and appropriate pest control practices and non-chemical compounds are used.

 Comply with the office and building smoking policy.

 Dispose of garbage promptly and store food properly.

 Plan your next new, renovation or remodeling office project with a professional interior designer and/or architect, particularly one that is a LEED-certified professional. Even if the renovation will not meet LEED standards, a LEED-certified professional can recommend strategies to improve indoor air.

Home Environments

Indoor air pollution is a problem in your homes, too. Improving indoor air quality requires a systems approach. Here are some tips you can use at home.

The USEPA has responded to consumer demand for healthier homes by developing the comprehensive Indoor airPLUS label for new homes as a sister program to its Energy Star for Homes program.

To attain the Indoor airPLUS label, your builder must first qualify the sources of indoor air pollution by choosing the least hazardous products that are effective for the project. Using low or no-VOC paints to reduce harmful emissions as a sole effort in addressing Indoor Air Quality (IAQ) is not sufficient. In conjunction, the floor sheathing and carpet selections must be included. Specify only materials that minimize the risk of moisture damage and offer reduced levels of harmful chemical content.

Do not install a high quality, ultralow-VOC carpet over a low quality, potentially high-off-gassing pad. It is extremely important to ventilate a newly finished interior prior to occupancy, and to continue ventilating for at least several months afterwards.

Lynn Hoffman, IIDA, NCIDQ, RID, LEED®-AP ID+C has over 20 years of experience producing commercial, hospitality, and luxury residential environments. Lynn is the Founder of Lynn Hoffman Design, LLC, a full-service green and sustainable interior and universal design firm dedicated to elevating eco-conscious design to new levels of luxury and sophistication and that great interiors are inherently sustainable and healthy. Lynn Hoffman Design provides innovative, customized design solutions that meet the highest standards of efficiency, quality, and elegance. Website: www.lynnhoffmandesign.com

April 2013

The Regional Greenhouse Gas Initiative (RGGI), the U.S.’s first carbon cap and trade program, is expected to be modified later this year, a sign of changes to come and gives lessons to those who may design future cap and trade rules. RGGI affects large power plants in 9 Northeast states (NJ withdrew last year), mandating that each state’s plants reach its early 2000’s baseline when the rule began in 2009 (with flexibility: as emissions may be averaged over 3 year periods), then decrease gradually to 10% below baseline by 2019. Affected facilities must buy allowances from their states for all emissions, limited to the quantity of the baseline. However, due to a number of factors, including Recession-related decrease in electricity demand, GHG emissions declined right away and demand for allowances was very low, causing them to be sold at the floor price. In fact, now GHG emissions from the affected power plants have decreased by 40% from the baseline, well below the 2019 goal already. States thinking there would be a cash bonanza from sales were disappointed, a non-ideal market (for them).

The RGGI organization issued a model rule change in February 2013 to “correct” (http://www.rggi.org/docs/PressReleases/PR130207_ModelRule.pdf) the situation. The rule requires a more stringent GHG emission decline, which is expected to stimulate the price for allowances and strategies for compliance. The change would lower the overall cap to 91 million (short) tons beginning in 2014 (about 45% below the original baseline), with an additional reduction of as much as 33% from that cap by 2020.

The model rule change contains necessary actions should the cost of allowances exceed certain triggers. But instead of expanding the definition of offsets as the original rule states, the proposed change allows states to sell additional allowances, called cost containment allowances (CCAs). The original RGGI rule allows an affected facility to average allowances over 3 year periods; one can wait to purchase allowances for all 3 years at the end of the third year, for example. The draft change states that one must obtain at least 50% of the necessary allowances each year. The draft change raises the minimum (“floor”) price of an allowance in 2014 to $2.00/ton, rising 2.5% per year.

The draft model rule change must be reviewed and passed by each RGGI state by its own legislative process individually. Changes are aimed to be finalized later this year. Each state may make additional changes outside of these major ones. New York, for example, proposes to maintain its renewable energy set-aside at 700,000 tons, and potentially expand it. The comment period closes in New York on May 6, 2013. For further information, see: http://www.rggi.org/design/program_review.

CCES can help you keep up with changing environmental, energy, and climate change regulations, including determining the impacts of cap & trade and other types of regulations on your operations. Profit while complying with new rules. Call us today.

This blog has put out monthly articles on simple, inexpensive ways for companies and buildings to save energy. These are good tips and have proven successful in the “real world.” However, these tips focus on individual pieces of equipment (HVAC, lights, etc.) or practices, and therefore, while cost effective, may not be the “home run” of energy savings that a company wants. A report by the American Council for an Energy Efficient Economy looks at energy efficiency differently, taking the larger view. Their report, “A Defining Framework for Intelligent Efficiency” (http://aceee.org/research-report/e125), concludes that as a nation we can reduce energy consumption by 22% and save billions of dollars per year in energy costs by implementing “intelligent efficiency.” For some individual companies and buildings, the percent cost savings can be much greater.

The report discusses system efficiency opportunities to produce and distribute energy that can result in significant savings. The report discusses how major improvements in IT (information technology), such as the Internet, sensors, and communicating readings between equipment, can result in properly using and distributing energy cost-effectively.

Here are 2 such strategies cited in the report that can result in energy efficiency gains:

Manufacturing often uses intricate equipment with complex electricity and steam needs. Advanced sensors and controls can record real-time energy usage and operational information and feed it through the Internet to pinpoint changes in demand over time. Sensors and controls with the proper software can link to a company’s existing software to regulate energy usage, reducing waste and saving costs.

Real-time energy usage data in office buildings can also save money. Some office buildings already use systems that compute electricity usage between different offices and functions and communicate them to individuals at their desks or on a video monitor for all to see. The key is to give tenants real-time data to better understand the major energy consuming operations and to determine gains in energy efficiency by implementing different strategies. Such “what if” analyses can lead to cost savings.

While there will continue to be improvement in individual component efficiencies, the systems-based approach can result in major energy efficiency gains to result in measureable energy cost savings and reduce energy risk.

CCES can work with your engineering and IT staff to develop and help implement intelligent energy systems to help you understand your energy usage and improve efficiency. We can also recommend strategies to improve the efficiency and save you money for the individual components, as well.

March 26, 2013

The USEPA published a proposed rule on Feb. 22, 2013 modifying policy on startup, shutdown, and malfunction (SSM), and would require 36 states to modify their SSM rules in their State Implementation Plans (SIPs) (http://www.gpo.gov/fdsys/pkg/FR-2013-02-22/pdf/2013-03734.pdf). Many states specifically allow facilities to be exempt from some Clean Air Act requirements (mainly emission limits) during SSM events, due to a lack of specific policy and rulemaking by the USEPA. Many of these exemptions have been written into rules and facilities’ Title V Operating Permits. Therefore, by requiring these 36 states to revise their SIPs to remove the SSM exemptions, the USEPA would also require them to modify the pertinent Title V Permits, a large under-taking. Affected facilities would also need to institute procedural changes fairly soon.

This issue has been controversial for decades. It is known that emissions from equipment during startup, shutdown and maintenance may be greater than while operating “normally.” Because emission limits are sometimes promulgated based on health standards or on normal operating equipment there are some who feel that such exemptions should not be allowed. Others understand that it is hard to limit emissions during non-normal operations and that SSM conditions occur for short periods only. The USEPA has sided with the latter interpretation. However, environmental groups have challenged the USEPA’s SSM exemptions as violating air toxic (NESHAP) rules.

Many states in their SIPs have addressed the USEPA’s nod to allow SSM exemptions. For example, the Illinois SIP expressly allows state officials “to determine in the permitting process that the excess emissions during startup and malfunction will not be considered violations of the applicable emission limitations.” Michigan’s SIP allows “an affirmative defense to violations of applicable emission limitations during startup and shutdown events.” As many as 36 state SIPs follow one or both of these approaches.

What are facilities to do? Not knowing the final outcome of the USEPA proposed rule change, facilities should begin to prepare for a potential time when SSM exemptions are eliminated or removed as a potential defense for emission exceedances. Environmental managers need to work with combustion and operation engineers to determine what actions can be taken during SSM to minimize emissions. What changes in Standard Operating Procedures (SOPs) may be necessary to ensure that emission limits are met at all times? Also, environmental managers, in assessing what are potential SSM emissions, should determine the lowest reasonably attainable SSM emission rates, and work with agency officials to amend Air permits accordingly to allow such rates.

CCES has the experience to help you determine your SSM and other emissions from a variety of process and combustion sources and to devise cost-effective strategies, such as operational changes, to comply with applicable regulations and with your permit. Give us a call or send us an e-mail today.

The “Sequester”, the mandatory across-the-board spending cuts is causing havoc with federal government activities, including the US EPA and funding to state environmental compliance programs. While the Sequester is causing major personnel cuts, don’t think that you will have any license to not comply with applicable environmental rules and permits. The USEPA and states have developed a large network of cooperation when it comes to enforcement and can enforce rules with fewer personnel, such as by mandatory self-reporting. Because environmental violations can be a source of revenue to the USEPA and state agencies and funding is tight, environmental agencies will likely be more aggressive in enforcing what it believes is violations and will pursue these more doggedly (at least for the largest possible fine).

A case in point is Pelican Oil of Louisiana which entered a plea bargain for Clean Air Act violations, including not properly operating control and monitoring equipment. Pelican had to pay $12 million in criminal penalties plus $2 million for community service that will go toward various environmental projects in Louisiana, saving the state from funding them. This is the largest ever criminal fine in Louisiana for Clean Air Act violations. The trend is for the USEPA, state environmental agencies, and federal and state prosecutors to share information to determine violations and press for the highest monetary fines possible. Even losing some personnel will not stop these trends.

And this does not stop at pure environmental violations. Last week Mr. Rodney Hailey of Clean Green Fuel, LLC was sentenced to 12.5 years in prison for selling $9 million in renewable fuel credits under false pretenses. Hailey was also ordered to pay restitution of about $42.2 million to over 20 companies and forfeit $9.1 million in proceeds from the fraud. Hailey had registered Clean Green Fuel under the USEPA’s Renewable Fuel Standard (RFS) program as a producer of bio-diesel fuel, a fuel derived from renewable resources. To encourage the production of renewable fuel, all oil companies that market petroleum in the U.S. are required to produce a given quantity of renewable fuel or to purchase credits, called renewable identification numbers (RINs) from producers of renewable fuels to satisfy their renewable fuel requirements. Hailey sold over 35 million RINs to brokers and oil companies, when in fact Clean Green Fuel had not produced nor was able to produce such fuel from renewable sources at all. While the USEPA led the prosecutorial effort, they were joined by state and county (Baltimore, MD) detectives and prosecutors to collect and provide the court evidence.

CCES has the experience to provide technical assistance for your environmental compliance efforts. We can assess your compliance program and provide technical advice to improve effectiveness or how to make it more cost-effective. Call us today.

On Jan. 14, 2013, the USEPA finalized revisions to MACT standards for reciprocating internal combustion engines, “RICE”. See: http://www.epa.gov/ttn/atw/rice/20130114amendments.pdf.
A controversy concerning the draft rule was whether facilities can use backup diesel generators during non-emergency, demand-response purposes without emission controls. According to the USEPA, there are over 1 million RICEs in the US, most of which used only for power in emergencies. Many are located in areas that may experience power shortages during the peak season. These, therefore, are seen as potential sources to provide a facility power during peak demand when there may be shortages or risk of one: greater operating flexibility for the facility and local power grid.

The vast majority of RICEs combust diesel oil, whose combustion by-products have been linked to asthma, lung cancer and, particularly, childhood respiratory problems. However, because many RICEs are located in sparsely populated areas (for example, for oil or gas production) or are used to power offshore vessels, some have argued that emission controls need not be as strict as for units commonly found in populated areas.

The USEPA had previously proposed to allow backup generators to run for up to 100 hours/year for demand-response purposes without being subject to emission limits. Both industry and environmental groups objected. In the final rule just announced, the USEPA provided these compromises:

• Emergency engines can operate for demand-response up to 100 hours/year

• More clearly defined the precise situations when backup generators may operate (what is an emergency)

• Backup generators must use ultra-low sulfur diesel fuel beginning in 2015.
Operators with subject RICE emergency engines must submit annual reports reporting the dates and lengths of times of operations to determine compliance.

While some groups are still dissatisfied and threaten to sue, a number of commentators believe that this represents reasonable public health protection and will survive in court.
The USEPA intends to modify the New Source Performance Standards (NSPS) for stationary compression-ignition and spark-ignition internal combustion engines (40 CFR Part 60, Subparts IIII and JJJJ, respectively) to ensure consistency with RICE MACT.

CCES has the experts and the experience to evaluate your engine generators for compliance with these and other federal and state air quality regulations, and advise you on technical options to comply and provide your operators with greater operating flexibility. Contact us today.

On Dec. 14, 2012, the USEPA finalized an update to the national ambient air quality standard for fine particles (PM-2.5), setting it at 12 micrograms/cubic meter, more stringent than the previous one of 15 µg/m3. PM-2.5 (2.5 µm effective diameter) is particularly problematic in public health as it can bypass our natural defenses against larger PM (dust from fields), and penetrates deep into the lungs. Recent research has linked PM-2.5, derived from more recent sources, such as fuel combustion, to a wide variety of adverse health effects, such as asthma, acute bronchitis, heart attacks, and strokes, particularly among children and the elderly. Thousands of public health studies were used to set the new standard; almost 250,000 public comments were reviewed.
A criteria pollutant, PM-2.5 is measured in monitoring stations across the nation. A new assessment of the areas in or out of attainment with the new standard is shown below.

States with non-attainment areas will need to create and enforce new rules to reduce PM-2.5 emissions, many of which will regulate combustion from fuels, such as diesel, that cause high PM-2.5 emissions. Such areas must meet the new ambient air standard by 2020. The USEPA believes that meeting this standard by 2030 will prevent up to 40,000 premature deaths, 32,000 hospital admissions and 4.7 million days of work lost.

The USEPA also made a change concerning PM that relaxes a previous requirement. For New Source Review (NSR, including PSD), facilities are no longer required to measure condensible PM – gaseous emissions that form liquid or solid PM after release, such as sulfuric acid. The definition of PM in NSR (40 CFR Part 51) was changed to remove inclusion of condensible PM. Thus, it no longer needs to be measured in NSR.

CCES can help you assess your combustion profile and switch to lower emitting fuels, which are also cheaper than fuel oils currently. Marc Karell also offers a graduate level course online on Air Pollution at NY Medical College. See www.nymc.edu to learn more.

Climate change is affecting us now, as we see an increase in warming and extreme temperatures, as well as an increase in the frequency of more intense precipitation and droughts. There are many potential indirect, long-term effects, including water availability, which are critical for many industrial processes. The US Geological Survey (USGS) has recently published studies of the potential impacts on specific major US water supplies (see http://journals.ametsoc.org/page/Watershed and http://pubs.usgs.gov/circ/1316 through 1329, 1347, 5077). As EH&S and Sustainability Managers, you are also resource managers, and it is critical that you understand future impacts on water availability so you can plan for the increasing challenges of having water critical for your processes.

It should be understood that forecasting water availability is not an exact science. Accurately predicting future temperatures, precipitation trends, and changes to the hydraulic and geographic features of water basins in detail is impossible, but projections of general trends of a changing climate are currently being extensively modeled. A decrease in water availability is a particular problem for a facility if water must be shared with other interests, such as municipalities (drinking water), agricultural and recreation.

The USGS reports predict possible water resource availability changes for 14 major water basins across the US. Using climate, hydrologic, and other models, the report projects how water supplies may be impacted.

For example, the USGS models project that temperature increases due to climate change will cause increased melting of snowpacks that feed several basins, causing annual peak stream flows to occur earlier in the spring and to lessen in the long term. The unique soil, hydrologic, and geologic conditions of each basin can affect availability. USGS projections are site specific. Maine is projected to have an increase in water flows, while basins in the South, already impacted by droughts, may become dryer. Therefore, facilities may need to modify their water storage and delivery schedules to meet availability.

Are your facility’s operations dependent on water? Perhaps large quantities of water? What can you and your company do about it? Assuming you do not have the resources to simply move a plant to a region projected to increase its water availability over time, it is important to have a water conservation program, to cut down usage. Not only is this a cost issue (as water shortages will lead to increased costs), but even a quality and perhaps an existential issue. With reduced amounts of water available, can your plant still produce the same quality and quantity product? Can you improve water efficiency? Therefore, it is important to begin to capture baseline information, such as quantities of water used in different aspects of your operations and to determine which areas use the most and how you can cut back or reuse wastewater in those operations.

CCES can help you assess your water quantity and quality issues to provide you with advice on how to cope with a projected long-term decline in water availability or cope with short-term drought impacts. WeatherMark, LLC (www.weathermarkpro.com) are experts in reconstructing past weather conditions, provide weather & climate records, and conduct analyses & write reports. Contact us now.