United States Environmental Protection Agency
https://www.epa.gov/caa-permitting/ej-air-permitting-principles-addressing-environmental-justice-concerns-ai
United States Environmental Protection Agency
https://www.epa.gov/caa-permitting/ej-air-permitting-principles-addressing-environmental-justice-concerns-ai
CIBO is joining with the Midwest Ozone Group (MOG) and other industrial sector trade coalitions to submit formal comments and to register detailed, constructive input on the proposed Regional Ozone Transport Rule. Put simply, we see major flaws and deep problems with this proposal. The larger goal with our response efforts is to be sure that the rulemaking record includes specifics on the flaws, both fundamental and technical – tied into the data, the assumptions, analyses and conclusions of the regulation, which pertain to industrial sources. Be assured that we will certainly share our final comments to you once submitted later this month. We appreciate the help and input on this effort from CIBO members!
Our formal comments address several critical policy concerns and technical issues where our members have deep expertise. The Rule, an ambitious proposal to expand and strengthen the CSAPR interstate emission program, would promulgate Federal Implementation Plan (FIP) requirements under the Clean Air Act for twenty-six identified states, including several Western states as well, tied to interstate transfer affecting the attainment of the 2015 Ozone NAAQS. As outlined by the EPA, the proposal is designed to ensure that states meet their “good neighbor” obligations under the CAA, which directs states to craft state implementation plans, or SIPs to mitigate their “significant contribution” to the problems of downwind states attaining and maintaining NAAQS. This proposed rule includes requirements for certain industrial source categories (non-EGUs) in twenty-three states , with unit – specific emissions limitations beginning in 2026, affecting existing and new units, to help attain interstate ozone reduction goals. EPA has asserted that it has taken this step directed at industrial unit sources based on its evaluation of air quality modeling information, annual emissions and potential controls. The Rule includes seven identified non-EGU source categories covered by the proposed FIP: boilers and other types of emission units in chemical manufacturing, pulp, paper and paperboard mills, iron and steel mills, gas pipelines, glass manufacturing, cement and concrete operations, and oil refining and coal products manufacturing. In addition, unlike the EGU’s, the affected industrial sector units within the 23-state region are not included in the EPA allowance trading program. Allowance trading for the EGUs is designed to enable more cost – effective NOx emission reductions, as well as compliance flexibility.
Until this point, EPA has regulated non-utility boilers under the CSAPR. The data contained in the docket for the proposed rule indicates that only limited emissions reductions can be achieved within the same cost-effectiveness ($/ton) applied to the EGUs. EPA also appears to have overestimated the reductions this proposed rule could achieve overall, while significantly underestimating the costs of compliance. Many industrial sectors, in fact, have experienced significant decreases in NOx emissions in recent years, as facilities have worked to lower energy costs, improve efficiencies, and reduce emissions. In addition, with the implementation of Boiler MACT standards and other NAAQS reductions, many industrial facilities have also indirectly achieved lower NOx reductions, including by way of fuel-switching. This proposed FIP comes as EPA has also acted recently to formally disapprove the Good Neighbor plans of many of the so-called upwind states. Industry sectors are urging EPA to re-orient and apply its regulatory aim to NOX sources geographically closer to downwind monitors. In their general public responses to the proposed rule, industrial sectors have also noted their support for some specific provisions recommended. For example, EPA has asked for submission of public comment on their recommendation to continue to exempt cogeneration units – those that already meet the Acid Rain Program exemption requirements. Past EPA analyses has given clear indications that little additional NOx reductions could be realized by including these units, among other reasons. CIBO will keep you updated on our efforts and further developments.
Feb 28, 2022 EPA – The proposed rule includes NOx emission standards for certain emissions units in identified large industries in 23 states, with an initial compliance date of 2026. On its list, EPA is proposing new emissions standards for certain new and existing emissions units, including: “High-emitting, large boilers in basic chemical manufacturing, petroleum and coal products manufacturing, and pulp, paper and paperboard mills.”
4th Annual CIBO FLAME AWARD
October 29, 2024
This award is annually presented to a CIBO member who best demonstrates the finest technical knowledge, a willingness and ability to educate our members, and an individual who maintains the highest standards and principles of CIBO as a champion of sustainable energy. This award also recognizes members who step up/volunteer their time and talents to the internal work CIBO does – in this case Officer and Treasurer!
This award is called the CIBO FLAME AWARD. Fire consumes, warms, and illuminates, it is often the symbol of inspiration. The recipient of the CIBO Flame reflects this as the person who best represents our mission of ensuring reliable, sustainable, safe, and cost-effective energy to support a strong and globally competitive economy.
This year’s recipient is Mr. Paul Kempf. Paul currently is on the CIBO Executive Committee, including serving as an Officer in the Treasurer position. He has carried out this important work, overseeing CIBO’s finances, with great dedication and the highest standards of excellence. Over his many years as a CIBO member, representing the University of Notre Dame, Paul has provided great leadership and a strong commitment to CIBO and its mission.
Please join me in congratulating the 2024 CIBO Flame Award winner Mr. Paul Kempf.
Alex Stoddard
Executive Director
CIBO
2nd Annual CIBO FLAME AWARD
November 15, 2022
This award is annually presented to a CIBO member who best demonstrates the finest technical knowledge, a willingness and ability to educate our members, and an individual who maintains the highest standards and principles of CIBO as a champion of sustainable energy. This award also recognizes members who step up/volunteer their time and talents to the internal work CIBO does – in this case the Environmental Committee!
This award is called the CIBO FLAME AWARD. Fire consumes, warms, and illuminates, it is often the symbol of inspiration. The recipient of the CIBO Flame reflects this as the person who best represents our mission of ensuring reliable, sustainable, safe, and cost-effective energy to support a strong and globally competitive economy.
This year’s recipient is Mr. Bob Morrow. Bob has been a participating member of CIBO since 2007. He has had a long career with The Detroit Stoker Company. Bob serves as CIBO’s Environmental Committee Chairman. Bob’s technical acumen, enthusiasm in sharing his knowledge, and his exceptionally high standards make him the ideal recipient for our 2nd Annual CIBO FLAME AWARD.
Please join me in congratulating the 2022 CIBO FLAME AWARD winner Mr. Bob Morrow.
Alex Stoddard
Executive Director
CIBO
Green energy can be thought of as renewable power, energy storage, synthetic fuels (particularly sustainable aircraft fuels), and industrial steam/heat. The energy transition involves a number of technologies, but particularly carbon capture. The first question is whether sequestration is available. If not, renewable fuels and energy will be the primary path. If sequestration is available, carbon capture will likely be deployed. Renewable fuels include green hydrogen, biomass, biowaste, and renewable natural gas.
The EU does not allow growing a crop to convert to fuel. In the EU, there is a waste hierarchy which leads to energy recovery after reduce, reuse, and recycle. For a boiler, the most straight forward approach is to substitute hydrogen for natural gas. The DOE target is $1/Kg hydrogen. That translates to about $ 7/MMBTU. However, transportation and delivery of hydrogen is difficult. Delivered cost can be much higher. Some hydrogen will be made from grid power, but currently grid power is more carbon intensive than natural gas. Methanol may turn out to be a better solution for transportation fuels. Low cost solar or wind is usually “behind the fence”. However, they are still intermittent. Distribution is still a significant cost. To get “green steam”, an electric boiler driven by renewables could be applied. Intermittency is still a problem. Heat pumps can also be applied, but that doesn’t change the intermittency problem. Thermal storage can smooth out the problem. B&W is using sand as the storage medium. With carbon sequestration available, carbon capture technologies become applicable. There will likely be a capture business, a transportation business, and a sequestration business.
For capture, there is post combustion capture (amine scrubbing), oxygen firing, and fuel processing. Amine scrubbing is essentially commercial (although the largest unit is around 100 MW). Oxygen firing has been demonstrated. However, the boiler must be essentially leak proof. A package oxyfired boiler is already slightly pressurized, so leakage is not as much of a problem. Electric power can be generated to drive a small ASU as well as the CO2 compression station. The usual fuel can be used and the CO2 sequestered. Finally, B&W is developing a chemical looping system called BrightLoop. The system consists of three vessels. The lower vessel is a fluid bed with a solid particle that is an oxygen carrier. Air is introduced in which the particle absorbs oxygen. The depleted air exhausts. The particles are separated and sent to a moving bed. The particles transport to a higher vessel where fuel is introduced. The fuel takes the oxygen from the particle and produces a relatively pure stream of CO2. The CO2 can be sequestered. The system can also be operated to produce hydrogen. A pilot plant was built at the DOE/Southern Co test center combined with KBR on the gasification side. A 15 ton/day hydrogen plant is planned. The oxygen carrier is an iron oxide particle engineered to operate between two oxidation states of iron. There are other substances added to help control the oxygen uptake and oxygen pickup by the fuel.
– Brian Higgins, The Babcock and Wilcox Company
The Republican policy task force on climate in the US House prepares for a potential Republican majority following the November elections. The goal is to have a plan ready.
Major themes include energy and environment, energy independence, lower costs, faster permitting, cleaner, and American produced. The US is the most efficient producer in the world. A product produced in China generates three times the emissions as the same product produced in the US. The US has reduced more GHG emissions since 2005 than the next five reducers in the world. A similar analysis applies to natural gas that comes from Russia compared to US natural gas. If lower GHG emissions are desired, production in the US should be optimized. That also means removal of obstacles to US production. Permitting should be made easier. American resources should be unlocked to provide security at home as well as abroad. Reliance on China needs to be reduced. China controls 90% of rare earth minerals needed for renewable energy systems. Replacing OPEC with China is not the way to solve our energy problems. Yet opening a new mine in the US is nearly impossible. Innovation will be critical to reducing costs (and thus emissions). That also requires changes to the permitting system. This will be required across the board. We need to beat Russia and China. We need to make ourselves more competitive. Conservation technologies are also needed (for example in farming and forest management). Finally, a more resilient society is needed. Spending money on mitigation prior to a disaster will pay in reduced cost and resiliency going forward.
Off-peak power from renewables in SPP causes the wholesale price of electricity to go to zero or less (with incentives). In that area, the incentives drive the generation of power when it is not necessarily needed. However, this generation is intermittent. Effective and reliable storage of such energy in the form of heat can provide reliable heat for industrial use. The Antora process uses resistance heating of carbon blocks to drive up the temperature of the blocks. The blocks then radiate heat to the desired process. Carbon blocks are used because they can be heated to high temperatures in a stable manner. They are generally low in cost and highly scalable with an existing supply chain. The material has a high thermal conductivity and a high specific heat. The technology has been used in graphitization furnaces for many years. The use of radiation to move the heat allows large quantities of heat without circulating a fluid through the system. The system is modular. Shutters can be used to modulate the amount of energy being delivered to an industrial process. A pilot system is currently deployed at a site in California. The system is a 5 Mwhr storage system, intended as the foundation for a single module. Success of this system would allow industrial thermal heat to be supplied by renewable electric power.
– David Bierman, Antora Energy
There are a number changes going on with the Advanced Manufacturing Office. The AMO will split into two offices for assistance in October 2022: Industrial Efficiency and Decarbonization and Advanced Materials and Technologies. The Industrial Decarbonization Roadmap focuses on the 5 sectors that account for the majority of industrial GHG emissions (chemicals, iron and steel, refining, food & beverage, and cement). There is no silver bullet. Multiple solutions are needed, as well as process integration. A current funding opportunity announcement is out under a $104 million funding effort. Proposals are due in December. The AMO has a number of institutes and is now setting up a 7th institute on industrial electrification.
The DOE has a Better Climate Challenge that aspires to reduce GHG emissions by over 50% in 10 years. A renewable guidance document for industry includes a summary document and a detailed supplemental document. Energy efficiency underpins the major resource for these efforts. Reducing energy needs also reduces the requirements for the remaining equipment and processes (including renewables and storage). The CHP program will be expanded to include all types of onsite energy. There is also an Industrial Technology Validation program. Phase 3 of that program is coming soon. The Infrastructure Law has provisions for providing grants and aid to smaller businesses for GHG reductions. There is also a state manufacturing leadership program. There are several manufacturing related provisions in the Inflation Reduction Act.
– Anne Hampson, DOE