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September 2011 - Michigan Energy Forum - David Yanochko
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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. ...

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 September 2011 - Michigan Energy Forum - David Yanochko Presentation Transcript

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