September 2011 - Michigan Energy Forum - David Yanochko


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Regulatory Drivers For CleanTech and Green Jobs: When people think of CleanTech, they usually think of wind turbines and solar panels, but there may be a burgeoning opportunity in energy efficiency. Many states, including Michigan, have adopted Renewable Portfolio Standards that requires utilities to generate a portion of their electricity from renewable sources. The U.S. Environmental Protection Agency recently promulgated a regulation (the GHG BACT) that will require utilities to reduce their carbon emissions, primarily through energy efficiency. However, several members of Congress are trying to cut back on GHG regulations arguing that these regulations are job killers. Come to the Michigan Energy Forum on September 8th to learn about the latest regulatory developments, what they have meant from green jobs in Michigan, and what the future might hold.

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September 2011 - Michigan Energy Forum - David Yanochko

  1. 1. Lessons Learned from a GHG BACT Analysis<br />by: David Yanochko, P.E.<br />
  2. 2. BACT Defined<br />An emission limitation<br />Based on the maximum degree of reduction that is achievable on a case-by-case basis <br />Taking into account energy, environmental, and economic impacts and other costs<br />Through application of production processes or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combination techniques for control of the pollutant<br />
  3. 3. EPA Guidance on GHG BACT<br />PSD and Title V Permitting Guidance for GHG’s<br />November 10, 2010<br />Analysis should follow normal “top down” BACT procedure<br />BACT should not redefine the source<br />Energy efficiency is an important part of production processes or available methods, systems, and techniques for control of a pollutant<br />Several simple, specific examples included<br />
  4. 4. EPA Guidance<br />What is a “top down” BACT analysis?<br />Identify all available control technologies<br />Include combinations of technologies<br />Eliminate technically infeasible options<br />Rank remaining control technologies<br />From most effective to least effective<br />Evaluate most effective controls and document results<br />Analyze in annualized $/ton of pollutant controlled<br />Select the BACT<br />
  5. 5. EPA Guidance<br />What is redefining the source?<br />This is the outside edge of inherently lower emitting processes/practices/designs that can be evaluated during the BACT analysis<br />It is defined by the record you create in your application and by legal precedent<br />Integrated Gasification Combined Cycle (IGCC) determined not to be a redefinition of a coal-fired power plant by the EPA EAB <br />To be defensible, all decisions must be linked to your site<br />
  6. 6. EPA Guidance<br />What is the appropriate role of energy efficiency?<br />During Step 1, in general, carbon capture and sequestration (CCS) and energy efficiency are only options.<br />The EPA recognizes that large scale CCS is not as yet technically feasible and will be eliminated in Step 2.<br />More efficient processes such as supercritical vs. subcritical steam cycles or combined cycle versus simple cycle turbines.<br />Biomass CO2 emissions are included in the analysis, but permitting authorities have discretion to consider their carbon neutrality as BACT. Recently the EPA has announced a plan to defer GHG permitting requirements from biomass sources for three years. <br />
  7. 7. Wolverine Application<br />Proposed 2-300 MW solid fuel-fired circulating fluidized bed (CFB) steam electric generating units in Rogers City, Michigan<br />Originally denied in May 2010 for lack of need<br />Denial overturned in January 2011 requiring additional regulatory requirements to be addressed including GHG BACT<br />
  8. 8. Wolverine GHG BACT Analysis<br />Challenges<br />No previous determinations posted on the EPA BACT/LAER clearinghouse.<br />Specific energy efficiency of system components would not be determined until the detailed design process - so no cost data could be presented for system component energy efficiency.<br />
  9. 9. Wolverine GHG BACT Analysis<br />Opportunities<br />MDEQ agreed we did not need to revisit in detail technologies which we had already shown to be technically and/or economically infeasible for other pollutants or would redefine the source due to our site selection:<br />IGCC<br />Combined cycle gas turbine<br />Pulverized coal (supercritical and ultra supercritical)<br />100% biomass<br />
  10. 10. Wolverine GHG BACT Analysis<br />Control Technologies Considered (Step 1)<br />CCS<br />Biomass fuel augmentation<br />Energy efficiency<br />Control Technologies Eliminated (Step 2)<br />None<br />Ranking (Step 3)<br />See Step 1<br />
  11. 11. Wolverine GHG BACT Analysis<br />Cost Analysis (Step 4)<br />CCS eliminated as too costly ($126/ton CO2 controlled)<br />Identify BACT<br />Biomass fuel augmentation (5%)<br />Energy efficiency<br />
  12. 12. Wolverine GHG BACT Analysis<br />Permit changes to address GHG BACT<br />Submit an Energy Efficiency Management Plan (EEMP) for all major equipment within 180 days of startup<br />All motors 100HP or greater must be variable speed<br />All APC devices operated at minimum pressure drop required for compliance<br />Thermal performance of all heat transfer components, including structure, designed for maximum energy efficiency<br />Optimize efficiency of fans, motors, and other components<br />
  13. 13. Wolverine GHG Analysis<br />Permit changes to address GHG BACT continued…<br />CO2e emissions from each CFB boiler are limited:<br />2.1 lb/kW-hr gross output (12-month rolling average)<br />6,024,107 tons per 12-mont rolling time period<br />Utilize a minimum of 5% biomass fuel on a heat input basis per year <br />
  14. 14.<br />