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AB 32 Compliance Strategy

We recently came across the following column written by Allan Bedwell, URS Corporation’s California Practice Leader for Climate Change & Renewable Energy Services.  His article prepares food processors for the final implementation of AB 32, The Global Warming Solutions Act of 2006, aimed at reducing greenhouse gases.

AB 32 will certainly affect producers and processors, and, perhaps most importantly, will cause increases in the costs of energy inputs.  As a result, costs relating to electricity, steam, fuel and water will be affected.

Don’t wait until it’s too late! Start preparing for AB 32 now and establish an AB 32 strategy.  If you don’t know where to start, here’s where you can start:

This summer the California Air Resources Board (CARB) makes a series of AB 32 compliance and carbon allowance allocation decisions for food processors that will lock in facility carbon emission reduction targets for the next eight years. Before CARB locks in your facility carbon allowance allocations and launches carbon auctions, food processors should evaluate your options and chart a course forward to minimize your cost of compliance.

If you are wondering if you should buy carbon allowances during CARB’s upcoming auctions, the short answer is: Look before you leap. Before your company decides to buy or sell carbon allowances or offsets, determine what your facility compliance obligations will be during the next eight years and establish an AB 32 compliance strategy to guide your actions.

There are some key actions that food processors should do now to determine your compliance obligations and establish an AB 32 strategy. Actions to take now include:


  • Strategically evaluate the baseline emissions data you are supposed to supply CARB by July 1. The agency will consider baseline years prior than 2008 to 2010.

  • Estimate your carbon allowance allocations to determine if you are above or below CARB’s expected 90 percent allowance allocation.

  • Develop cost curves for AB 32 compliance. Cost curves identify least cost options for achieving compliance and will serve as a compass to guide your company’s decisions about the relative value of reducing emissions on site, purchasing carbon allowances or offsets, banking emissions, or taking a hybrid approach.

  • Calculate the net life cycle costs under different regulatory, allowance and offset cost scenarios. Net life cycle costs will guide your company’s effective comparison of emission management options.

  • Actively evaluate CARB’s "benchmarking" methodology for carbon allowance allocations to determine if it’s accurate for your operations and processes. Each percentage point of lost efficiency can cost some facilities millions of dollars over the next eight years. Now is the time to negotiate with CARB before your emissions baseline, benchmarks and allocations are locked in.

  • Before a product benchmark is established for food processors, determine its potential financial impacts to your facilities compared to the current allocation method.

  • Approach the full costs of cap-and-trade strategically. Your electricity, steam, fuel and water suppliers will be affected by AB 32, and your facility will likely see significant utility cost increases as a result. Price your suppliers' carbon liability and incorporate the "pass-through" costs into a net life cycle analysis of your options. It may have a significant bearing on the actions you take under different regulatory and carbon market scenarios.

Carefully evaluate the full range of life cycle costs and the relative values of on-site reduction compared to buying or selling allowances and offsets. A large part of your AB 32 cost will come from increased energy costs. Not only can process improvements reduce your emission costs, but they can also reduce your electricity and gas bills.

A successful AB 32 compliance strategy has the flexibility to manage changing regulatory, legal and market conditions. Evaluate all your options and timing before you buy or sell carbon allowances or offsets. Most importantly, use net life cycle costs to chart your strategy to maximize the effectiveness of your actions to save costs under AB 32.

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Touch Screen CataStak Ammonia Flow Control Skid Supplied to Major Northwest Hospital

Nationwide Boiler recently supplied a single ammonia flow control system, designed to supply three boilers as part of a low NOx CataStak SCR system.  It features a Honeywell touch screen operator interface with a 10” VGA LCD color display and is constructed in accordance with NEMA 4X.  A bottle rack, complete with digital scales, was also supplied and handles three standard 150# ammonia bottles.

The system is currently being installed and another successful start-up for Nationwide Boiler is predicted.

CataStak SCR Ammonia Flow Control Unit
 

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Customer in CA Takes Delivery of 75,000 lb/hr BPS Boiler

California, if considered a country, is among the top 20 emitters of CO2 worldwide. Current legislation addressing GHG include California Assembly Bill 32 (AB32), aimed at reducing existing GHG emissions to 1990 levels by 2020, and the California Environmental Quality Act’s (CEQA) Climate Change Action Plan that incorporates Best Performance Standards (BPS) measures into the review process to assist new boiler permit applicants (natural gas-fired units).  The policy relies on the use of BPS to assess GHG emissions on global climate change and standards are incorporated in the overall design and operation of the equipment, providing the most efficient performance measures with major reductions in GHG emissions.

Current BPS examples that provide maximum efficiency benefits include:

    • ? 20ºF Approach Temperature on the Economizer
    • ? 15% Excess Air with O2 Trim
    • ? 10% FGR
    • VFD on Fan
    • Heat Recovery on Blowdown if over 8%


Nationwide Boiler recently provided a BPS boiler solution to a CA pulp and paper customer governed by the San Joaquin Valley Air Pollution Control District (SVAPCD).  BPS equipment included a 75,000 pph boiler, CataStak™ SCR system, EconoStak economizer and auxiliary equipment. The system incorporates the latest boiler upgrades and once in operation, will perform well below current NOX standards.

This system is one of many BPS solutions supplied by Nationwide Boiler, and BPS boilers in operation include several prominent food processors located throughout CA.  Each company is committed to operate their boiler systems with the most technologically advanced equipment in the industry, doing their part in helping the environment and lowering overall GHG emissions, while running operations as efficiently as possible.

Nationwide Boiler BPS Boiler System Delivered

Nationwide Boiler BPS Boiler System

For additional information regarding BPS requirements, specific to the San Joaquin Valley, visit: http://www.valleyair.org/Programs/CCAP/bps/BPS_idx.htm#Boilers

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CataStak™ SCR – Best Option for System Upgrades

In February of this year, the Boiler MACT rule was published in the Federal Register, causing the Environmental Protection Agency (EPA) to propose new regulations calling for system upgrades on boilers and auxiliary equipment in many plants.  The costs associated with these upgrades can reach up to $35 billion according to the EPA, but because the costs will be specific to each individual plant, no one will know the real costs until the boiler equipment is evaluated to comply with new and future regulations.  Boiler operators are hesitant to spend the money due to the uncertainty of regulations, but eventually something will need to be done.

There are resources available, and the U.S. boiler and combustion equipment industry is readily able to meet the demand for these system upgrades. Randy Rawson, President of the American Boiler Manufacturer’s Association (ABMA), said, “We have the workforce resources to meet the needs of our customers, as long as our customers don’t push compliance go the last minute.”

The largest air districts in California have passed rules that require NOx compliance as low as 5 ppm by the year 2015.  Few burner manufacturers have been successful with developing new ultra low NOx (ULN) burner technology that easily and safely performs at 9 - 7 ppm NOx.  Many users that have tried ULN burners suffer the consequences of high FGR or excess air rates that compromise not only efficiency, but also the operational limits of boiler equipment, resulting in limited turndown capabilities, flame pulsations and unstable operation.

Today, selective catalytic reduction (SCR) technology has taken over as the best available control technology for complying with ultra low NOx emission requirements.  Nationwide Boiler, having invested in SCR technology for our rental fleet over the last ten years, has both the experience as an user and a supplier of the CataStak™ SCR system.   Our SCR systems have met or exceeded emission requirements for over one hundred boilers, steam generators and gas turbines installations.

The Nationwide Boiler CataStak™ SCR system is proven to decrease emissions, increase energy efficiency, reduce fan horsepower and provide greenhouse gas / carbon reductions. Typical users can save significant energy costs by reducing flue gas recirculation which substantially reduces fan horsepower (HP) and when compared with a typical 9 ppm burner, fan HP can be reduced by as much as half.

If you are concerned or have questions about how your facility is planning to comply with local air quality regulations, send am email to info@nationwideboiler.com and together we can come up with a solution that can perform as low as 2.5 ppm NOx and pass any current air regulation with the lowest carbon footprint.

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