GHG BACT Determinations

GHG BACT DeterminationsGHG BACT Determinations

Top‐down BACT ProcessTop down BACT Process

1 Identify all available control options1. Identify all available control options

2. Eliminate technically infeasible options

3. Rank options by their effectiveness

4. Evaluate economic, energy and . a uate eco o c, e e gy a denvironmental impacts

5 Select BACT and create permit limits5. Select BACT and create permit limits

BACT in More Detail: Top Down Step 1BACT in More Detail: Top Down Step 1Step 1: Identify All Available Controls• Technologies and methods to consider:

I h tl l itti / ti /d i– Inherently lower emitting processes/practices/designs– Add‐on controls– Combinations of inherently lower emitting processes/practices and designs and add‐on controlsand designs and add on controls

– Methods/controls applied to similar source categories that may be available through technology transfer

• Need not consider options that would fundamentally redefine the nature of the source.

– “Redefining the source” is a question of degree and within the discretion of the permitting authority.Assessment begins with consideration of the fundamental– Assessment begins with consideration of the fundamental business purpose of the project, as described in the permit application

– Example: baseload vs. peak unit; simple cycle vs. combined cycle

BACT in More Detail: Top‐Down Step 1BACT in More Detail: Top Down Step 1

Step 1: Identify All Available Controls (cont’d)Consideration of sources of energy in a BACT review:

• Consideration of a cleaner version of the primary fuel i id d d fi i h iis not considered redefining the source in most cases.

G t f d f l i t id d• Greater use of a secondary fuel is not considered redefining the source in many instances.

• Consideration of a new alternative fuel or energy• Consideration of a new alternative fuel or energy source may be redefining the source and beyond the scope of a BACT review.scope of a BACT review.

BACT in More Detail: Top Down Step 1 (cont’d)BACT in More Detail: Top Down Step 1 (cont d)

GHG Considerations – Energy Efficiency

• In the near term, options to improve energy efficiency will be the key control technologies for

b ti l t d GHGcombustion related GHGs.

• Often energy efficiency is improved through many actions with small impacts In that context it may beactions with small impacts. In that context, it may be impractical to evaluate them individually.

• Opportunities to use energy more efficiently and• Opportunities to use energy more efficiently, and thereby reduce emissions of GHGs, are appropriate considerations in a BACT review for a new facility.y


GHG Considerations – Benchmarking Efficiency

• Data on the energy use/efficiency of similar new units can be used to “benchmark” overall energy ffi iefficiency.

• Benchmarking data can be used to demonstrate the relative energy efficiency of a facility process or unitrelative energy efficiency of a facility, process or unit.

• The comparison can show whether a unit is a best performer and whether additional reductions may beperformer and whether additional reductions may be achievable.


GHG Considerations (cont’d)• When and how to consider CCS?

– Expect CCS to be considered in Step 1 for larger sources of CO : power plants cement plants hydrogen plantCO2: power plants, cement plants, hydrogen plant, ammonia plant, ethanol plant, ethylene oxide production and iron and steel manufacturing, etc.

• Is the use of biofuels a GHG control strategy?***

– There is no consideration of offsite impacts in Step 1

– Often the CO2 emission rates of biofuels are similar to the fossil alternatives.

GHG Technology ResourcesGHG Technology Resources

• EPA GHG Technology White Papers – ElectricEPA GHG Technology White Papers Electric Generating Units, Boilers, Pulp and Paper, Cement, Iron and Steel, Refineries, Nitric Acid Plants http://www.epa.gov/nsr/ghgpermitting.html

• EPA GHG Mitigation Strategies Database – currently covers Cement and Electric Generating Units h // / / h h lhttp://www.epa.gov/nsr/ghgpermitting.html

GHG Technology Resources (cont’d)GHG Technology Resources (cont d)

• ENERGY STAR Guidelines for Energy ManagementENERGY STAR Guidelines for Energy Management– www.energystar.gov/guidelines

• ENERGY STAR Industrial Sector Energy Guidesgy– www.energystar.gov/epis

• EPA’s Climate Leaders Protocols– http://www.epa.gov/stateply/index.html

• EPA’s Lean and Energy Toolkit– www.epa.gov/lean/toolkit/LeanEnergyToolkit.pdf


• EPA’s Voluntary Partnerships for GHG Reductions:EPA s Voluntary Partnerships for GHG Reductions:– Landfill Methane Outreach Program http://www.epa.gov/lmop/

– Coalbed Methane Outreach Program http://www.epa.gov/cmop/index.html

Natural Gas STAR Program– Natural Gas STAR Program http://www.epa.gov/gasstar/index.html

– Voluntary Aluminum Industrial Partnership y phttp://www.epa.gov/highgwp/aluminum‐pfc/index.html

– CHP Partnership Program

// /http://www.epa.gov/chp


• SF Emission Reduction Partnership for the Magnesium IndustryIndustry

– http://www.epa.gov/highgwp/magnesium‐sf6/index.html

• PFC Reduction/Climate Partnership for the SemiconductorPFC Reduction/Climate Partnership for the Semiconductor Industry– http://www.epa.gov/highgwp/semiconductor‐pfc/index.html

R t f th I t T k F C b C t d• Report of the Interagency Task Force on Carbon Capture and Storage– http://www.epa.gov/climatechange/policy/ccs_task_force.html

• As permitting authorities gain experience with GHG BACT determinations, more useful information on GHG permitting decisions will present itself in the EPA’s RACT/BACT/LAER Clearinghouse (RBLC) ‐‐ http://cfpub.epa.gov/rblc/

GHG Benchmarking ResourcesGHG Benchmarking Resources

• The following information sources may be helpful when e o o g o at o sou ces ay be e p u eincluding benchmarking as part of a BACT analysis. – EPA Energy Star Industrial Energy Management Information Center:http://www.energystar.gov/index.cfm?c=industry.bus_industry_info_center

–DOE Industrial Technologies Program:http://www1.eere.energy.gov/industry/

– Lawrence Berkeley National Laboratory Industrial Energy– Lawrence Berkeley National Laboratory Industrial Energy Analysis Program: http://industrial‐energy.lbl.gov/

– European Union Energy Efficiency Benchmarks:http://ec.europa.eu/environment/climat/emission/benchmarking_en.htm

GHG Benchmarking Resources (cont’d)GHG Benchmarking Resources (cont d)

• The following information sources may be helpfulThe following information sources may be helpful when including benchmarking as part of a BACT analysis:

– IPCC Four Assessment Report ‐ Climate Change 2007:http://www.ipcc.ch/publications_and_data/ar4/wg3/en/ch7.html

– ISO TC 207 Standards on Environmental and GreenhouseISO TC 207 Standards on Environmental and Greenhouse Gas Management and Related Activities:http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_tc_browse.htm?commid=54808wse.htm?commid 54808

BACT in More Detail: Top Down Step 2BACT in More Detail: Top Down Step 2

Step 2: Eliminate Technically Infeasible OptionsCriteria for eliminating a technology:• Not technically feasible (i.e., not demonstrated in practice

successfully)successfully)

• Demonstrated in practice relates to the same type and size of facility or one that has similar processes or emissions stream (for an add‐on control)

• Technology is infeasible if it cannot be reasonably installed and operated on the sourceand operated on the source

• Should not be eliminated simply because one cannot get a commercial guarantee from a vendor.g


GHG considerations – Feasibility of CO2 Sequestration

• Must consider all three aspects: capture, transport and storage

• Site specific considerations include space for equipment, rights of ways for pipelines, access to an appropriate geological reservoir or other storageappropriate geological reservoir or other storage option


Step 3: Ranking of Controls

• Remaining available, feasible control technologies (and combinations of technologies) are ranked in d f ll t l ff ti f thorder of overall control effectiveness for the

pollutant under review.

• Ranking options include:• Ranking options include:– Percent pollutant removed

– Emissions rate (input‐ or output‐based)Emissions rate (input or output based)

– Emissions reduction over time


Step 3: Ranking of Controls

• GHG measures of performance– If plantwide measures to reduce GHGs are considered, alternati e meas res of o erall net emissions impact maalternative measures of overall net emissions impact may be more useful:

• Expected emission rate in units such as TPY, lbs/hour, p , / ,lbs/unit of input or output, etc.

• Expected emissions reduction could be expressed in itsame units

• Must consider combinations of controls but not every possible permutationevery possible permutation


Step 4: Economic, Energy and Environmental ImpactsH t i t ff tiHow to examine cost effectiveness:

• Dollars per ton of emissions eliminated (in CO2e)

• Average cost effectiveness and incremental cost effectivenessAverage cost effectiveness and incremental cost effectiveness

• Steady state case– Operating cost plus annualizing initial investment

– Annual emissions reduction at full capacity

• Lifetime analysis for projectThis makes sense when costs and emissions reductions are not steady– This makes sense when costs and emissions reductions are not steady (e.g., landfills)

– Determine lifetime emissions reductions and costs


• Cost effectiveness criteria– As with other pollutants, acceptable cost levels for GHG will evolve through permitting experience

– Given the large amounts of GHGs we expect the cost per– Given the large amounts of GHGs, we expect the cost per ton criteria will be lower than for other pollutants

• Other economic considerations that are relevant– Cost of control relative to cost of project

– Impact on product cost and local job losses

Cost Effectiveness Example: New Natural Gas Fired BoilerNew Natural Gas Fired Boiler

Emissions

Assumptions Size of Nat Gas Boiler 250 MMBTU/hrAnnual Operating Emissions

Analysis:Hours 8760 HoursCO2 emission factor 53.02 kg/MMBTUCH4 emission factor 0.001 kg/MMBTUN2O emission factor 0.0001 kg/MMBTUGWP CH4 21CWP N2O 310 Annual Fuel Use 2,190,000 MMBTU CO2 emissions 116 113 800 KGCO2 emissions 116,113,800 KGCH4 emissions 2,190 KG N2O emissions 219 KG CO2 emissions 128,015.46 Tons CH4 i i 2 41 TCH4 emissions 2.41 TonsN2O emissions 0.24 Tons CO2 emissions 128,015.46 tons CO2e CH4 emissions 50.70 tons CO2e N2O emissions 74.85 tons CO2e

TOTAL 128,141.02 tons CO2e

Cost Effectiveness Example: l i d il ( ’d)New Natural Gas Fired Boiler (cont’d)

Measure Efficiency Capital Annualized Operating Annual CO e C/EMeasure Efficiency Benefit (Fuel

Savings)

Capital Cost

Annualized Capital Cost

Operating Fuel

Savings and Maint.

Costs

Annual Cost or Savings

CO2e Emissions Reduction

C/E$/ton

Oxygen Trim 1% $100K $16.3K ‐78.8K+$25K

‐$37.5K 1,281 NA

Economizer 5% $1,000K $163K ‐$395K ‐$157K 6,405 NA,+$75K

,

Blowdown Heat

Recovery

0.3% $400K $67.2K ‐$23.6K+$50K

+$93.6K 384.3 $243/ton

Recovery


• Energy impacts: Both the energy use and its economic implication are addressed. Direct energy impacts (e.g., cost of p gy p ( g ,fuel) as well as indirect energy impacts (e.g., fuel scarcity). Purchased electricity is addressed at this point.

• Other environmental impacts: – Solid and hazardous waste generation, wastewater discharges, visibility impacts, demand on local water resources or emissions of unregulated pollutants.

– Both onsite and offsite impacts considered.• Historically, the economic impact has been the most common

basis for putting aside the most effective control as not being p g gBACT. Energy and environmental collateral impacts have been rarely a factor in the BACT decision process.


• GHG Issues– Impacts of CCS on energy use and related emissions

– Weighing of possible trade‐offs of criteria pollutants and GHGsGHGs

– Biofuel offsite impacts ‐ treatment of emissions for BACT purposes is still under review by EPA

• Permitting authority has discretion in the determining the weight given to the particular impacts under consideration.

• Consideration and rationale must be documented.


Step 5: Selecting BACT

• Determining BACT: – Should be the most effective control option not eliminated in Step 4in Step 4

• Permit ConditionsEmissions limit– Emissions limit

– Equipment specifications

– Work practicesWork practices

– Monitoring, recordkeeping and reporting


• GHG Considerations– Output based limits can be a useful means of capturing the impact of a multitude of energy efficiency measures

– Longer averaging periods may be appropriate for GHGs– Longer averaging periods may be appropriate for GHGs and are useful in dealing with variations related to load, malfunctions and start‐up and shutdown.

– Design requirements and work practices may be needed to create practical enforceable conditions for individual efficiency measures.efficiency measures.

Recap of EPA Perspective on Technology IssuesRecap of EPA Perspective on Technology Issues

• Energy Efficiency– Measures that reduce onsite energy use: Should be Considered in Step 1

– Measures that reduce offsite energy use: Should be– Measures that reduce offsite energy use: Should be Considered in Step 4

• Biofuels***– Onsite GHG emissions: Relevant in Step 1

– Offsite GHG emissions impacts: Relevant in Step 4

– Other environmental impacts: Relevant in Step 4

Recap of EPA Perspective on Technology Issues (cont’d)p p gy ( )

• Carbon Capture and Storage (CCS) – May be considered an add‐on control

– Three key components: • TransportTransport,

• Capture and

• Storage (sequestration)

– Technical feasibility: Relevant to Step 2

– Cost: Relevant to Step 4

Other impacts on energy use and environment: Relevant– Other impacts on energy use and environment: Relevant to Step 4

Documents

GHG BACT Determinations