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Update on GHG Permitting in Region V

Discussion on GHG permitting in Ohio EPA. Topics include pollutants covered, GHG BACT, permits issued, GHG BACT permits, useful links.

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Update on GHG Permitting in Region V

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  1. Michael Hopkins Assistant Chief, Permitting Ohio EPA 614-644-3611 Update on GHG Permitting in Region V

  2. Discussion Topics U.S. EPA Slides… 2 • Pollutants Covered • Applicability • GHG BACT • Example GHG BACT Analysis • GHG Permits Issued in Region 5 • GHG BACT Permits for Wolverine Power and WE Energies-Rothschild • Useful Links

  3. What are Green House Gasses? 3 • Regulated pollutant is GHG • Combination of 6 individual greenhouse gases • Carbon dioxide (CO2) • Methane (CH4) • Nitrous oxide (N2O) • Hydrofluorocarbons (HFCs) • Perfluorocarbons (PCFs) • Sulfur hexafluoride (SF6)

  4. Applicability 4 • GHGs now regulated air pollutant • GHGs permitting since January 1, 2011 • Applicability thresholds based on CO2 equivalent (CO2e) • CO2e = sum of the mass emissions of each individual GHG adjusted for its global warming potential (GWP) • GWPs can be found in table A-1 of the GHG Mandatory Reporting Rule.

  5. Applicability 5 • GHG applicability based on mass emissions and CO2e emissions. • Current GHG permitting thresholds: • New facility: PTE of 100,000 tpy • Modifications at existing facilities: 75,000 tpy

  6. GHG BACT 6 Normal 5-step “top down” BACT process No less stringent than NSPS Currently focus on BACT options - improving energy efficiency

  7. GHG BACT General Requirements 7 • Need to go thru a GHG BACT analysis to consider: • Lower-emitting processes/designs • Add-on controls, • Carbon capture and sequestration (CCS) • Energy efficiency measures • New facility: look at entire facility • Modification: look at the modified emissions unit

  8. BACT Modeling and Monitoring 8 • No ambient modeling (no NAAQS or increments) • Applicants do not need to gather monitoring data to assess ambient air quality for GHGs.

  9. GHG BACT Issues 9 • Carbon capture and sequestration (CCS) • Evaluate large GHG emitting sources • Costs will likely rule out CCS for now (Step 4 of BACT process) • IGCC should be considered for coal-fired power plants.

  10. GHG BACT Issues 10 • Consider clean fuels, but not if fundamentally redefines source. • Can get a GHG PAL using actual emissions under 40 CFR 52.21(aa) but only a mass basis not a CO2e basis. The significance level of zero on a mass basis, not 75,000 tpy.

  11. GHG BACT Fuels & Limits 11 • Cleaner version of the primary fuel not redefining the source (e.g. cleaner coal types) • Can evaluate the trade-offs associated with decreasing one pollutant versus increasing another • Need numerical emissions limit such as: • pounds of CO2e per megawatt hour • pounds of CO2e per pound of steam produced • tons per 12-month rolling limit of CO2e

  12. GHG BACT Enforceability 12 • Ensure practical enforceability, adequate compliance monitoring to measure emissions or efficiency over time • (e.g., CO2 CEMS or use of fuel factors to calculate GHG emissions). • Consideration of non-CO2 constituents – methane and N2O for combustion sources: • Assure compliance with total CO2e GHG BACT emission limit for all greenhouse gases emitted

  13. GHG BACT Support 13 • Must justify BACT decision in the permit record. • Provide adequate explanation for rejecting control options • The permit record should explain • why a chosen approach is more energy efficient than other options • explain what good combustion practices are being used for the emission unit

  14. GHG BACT Biomass 14 • 3-year biomass Deferral Rule – Feds say must get it SIP approved • Ohio EPA not so sure • Prior to SIP approval can use the Interim Biomass CO2 Guidance document for biomass burning only • Helps decide if burning biofuels for energy is GHG BACT • Provides a framework for analyzing the environmental, energy and economic benefits of biomass in BACT Step 4. • Source would still be major for GHGs and go through BACT • See: http://www.epa.gov/nsr/ghgdocs/bioenergyguidance.pdf

  15. Example GHG BACT Analysis 15 • Pulverized-coal-fired power plant: • Consider lower-emitting processes: • Integrated Gasification Combined Cycle • Natural gas fired combustion turbine • Combined cycle (more energy efficient – recaptures waste heat) • Simple cycle • Circulating fluidized bed (CFB) • Pulverized coal • Ultra-supercritical • Supercritical • Critical

  16. Example GHG BACT Analysis 16 • Look at ways to maximize efficiency of the boiler and other equipment • Ensure good combustion practices for the boiler • Develop an Energy Efficiency Management Plan • Develop an output-based CO2e emissions limit, i.e. in lb/Mw-hr

  17. GHG Permits Issued in Region 5 17 • WE Energies-Rothschild, Wisconsin (biomass combined heat & power boiler at an existing paper mill) • US Steel-Keetac, Minnesota (re-activation of a taconite facility) • Hoosier Energy, Indiana (installing 8 coal bed methane-fired RICE engines) • Wolverine Power, Michigan (600 MW power plant firing coal and biomass – two CFB boilers)

  18. GHG Permits Issued in Region 5 18 • Wolverine-Sumpter, Michigan (modifying a simple-cycle turbine into a combined-cycle) • University of Wisconsin-Charter Street Heating Plant (installing four gas-fired boilers) – permit not final yet • Taylorville IGCC in Illinois (IGCC power plant) – out for public comment • Indiana Gasification (coal-to-liquid facility) - not yet out for public comment

  19. Examples of GHG BACT permits issued in Region 5 19 • WE Energies-Rothschild: biomass-fired CFB boiler with a 1,830 lb/mW-hr GHG emission limit • Wolverine Power: coal/biomass-fired CFB boiler with a 2.1 lb/kW-hr GHG emission limit • Approximately 15 other permits issued nationally.

  20. Wolverine Power 20 • Issued final on June 29, 2011 • New 600 MW power plant (two CFB boilers to burn coal, pet coke, and biomass) • Permitted to emit up to 2.1 lb/kW-hr GHGs, and 6,024,107 tpy of GHGs • The 2.1 lb/kW-hr limit is an output-based emission limit based on energy efficiency

  21. Wolverine Power Considerations 21 • Burning natural gas in a gas turbine • gas supply not available, • flexibility to burn various fuels is vital. • IGCC (cost prohibitive) • 100% biomass combustion and biomass gasification • Fuel source not an available • Pulverized coal • Limited flexibility to burn various fuels including biomass

  22. Wolverine Power Considerations 22 • Carbon capture and sequestration: cost prohibitive • Energy efficiency measures considered/chosen: • Variable speed motors over 100 hp • Good combustion/efficient practices for the boilers and other fuel burning equipment • Development of an Energy Efficiency Management Plan (for the entire facility) • Decided on energy efficiency measures and burning 5% biomass - due to utility’s energy portfolio standard

  23. WE Energies-Rothschild 23 • Permit was issued final on March 28, 2011 • New 50 MW biomass-fueled CFB combined heat and power boiler at an existing paper mill. Will provide steam to the paper mill as well as generate electricity. • Permitted to emit up to a 1,830 lb/mW-hr GHGs • The 1,830 lb/mW-hr limit is an output-based emission limit based on energy efficiency

  24. WE Energies-Rothschild Considerations 24 • Natural gas in a combustion turbine • Needed to burn biomass because the Renewable Portfolio Standard • Carbon capture and sequestration • not technically available for similar CFB boilers • no nearby sites to sequester CO2

  25. WE Energies-Rothschild Considerations 25 • Energy efficiency measures considered/chosen: • Use of combined heat and power to maximize efficiency • Good combustion/efficient practices for the boilers and other fuel burning equipment • Decided on an energy efficient combined heat and power boiler, good combustion practices, and burning biomass - due to utility’s energy portfolio standard

  26. What do the Feds look for? 26 • Numerical emission limit for GHG BACT that accounts for all GHGs emitted from the facility (e.g., usually CO2, methane and nitrous oxide). • Output-based GHG BACT limit, if applicable • pounds of total CO2e per megawatt hour • pounds of total CO2e per pound of steam produced • and a tons of total CO2e per year on a 12-month or 365-day rolling average. • Adequate monitoring, recordkeeping and reporting • Monitoring has been either CO2 CEMS or the use of fuel factors to calculate emissions of all GHGs emitted at the facility.

  27. Wrap up 27 • EPA GHG Permitting Web Site: http://www.epa.gov/nsr/ghgpermitting.html • EPA’s GHG Tailoring Rule: http://www.epa.gov/nsr/actions.html#may10 • EPA’s Biomass CO2 Guidance document: http://www.epa.gov/nsr/ghgdocs/bioenergyguidance.pdf • Biogenic CO2 DeferralRule: http://www.epa.gov/nsr/actions.html#jul11 • Questions?

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