EPA Fugitive Emissions Rule (12/7 CIBO Committee Presentation)

EPA has the fugitive emissions rule under reconsideration. The CAA does not really detail how to deal with fugitive emissions. The court case in 1979 did not really resolve the issue. That was followed by some unfortunate rule making and guidance under New Source Review that further confused the issue. New Source Review includes Non-Attainment New Source Review and Prevention of Significant Deterioration (PSD). EPA is proposing to eliminate the mid-2008 “Fugitive Emissions Rule” and eliminate a source of confusion. The rule was stayed in 2009 and remains stayed.

There was also another exclusion that was part of the original rule. The definition of a Major Source is not being changed. A listed source must include fugitive emissions in its potential to emit. There are 29 listed source categories. The problem is with “unlisted” sources. If not on the list, a source becomes major if the potential to emit is greater than 250 tons/yr. Title III, Section 302(j) mentions fugitive emissions. The list comes from Title I, Part C, Section 169. However, this portion does not mention fugitive emissions. Nor does it consider modifications. The court decision stated that EPA could not count fugitive emissions in a facility’s total emissions unless that facility went through rule making, particularly for modifications. A major modification is any physical change that would result in a significant emissions increase. Unfortunately, that definition came from the NSPS section of the CAA. That does not include fugitive emissions. Fugitive emissions have historically been excluded when dealing with unlisted source categories. In 2002, the PSD rule was modified to include fugitive emissions at unlisted source categories. This rule was amended in 2008 with some new clauses. These were stayed during the Obama administration and remain stayed today. Another part of the 2008 rule excludes fugitive emissions if such inclusion would be the only reason that a source would become a major source.

In October, the EPA proposed to rescind the 2008 rule and proposed to remove the exclusion further down in the CAA. The comment period ends Feb. 2023. In other words. EPA wants to include fugitive emissions for practically everything. The definition of fugitive emissions basically states that such emissions “could not reasonably be vented through a stack” (i.e. become a point source). Further, EPA states that the cost to control such emissions (not collect and subsequently vent) should not be a consideration. A coalition has been formed to comment to EPA.

Jay Hofmann, Trinity Consultants, Inc.

DOE – “GAIN” Initiative (Gateway for Accelerated Innovation in Nuclear)  (12/8 CIBO Committee Presentation)

The Gateway for Accelerated Innovation in Nuclear (GAIN) looks to drive innovation in the nuclear energy field. Developers can propose a work scope and the National Labs can execute that work scope to minimize the additional costs of building and troubleshooting new facilities.

There is nuclear technology information from a variety of prior government agencies that is often “lost” to the present. GAIN is looking to relocate that information and make it available. GAIN has a website. There is a coal to nuclear program. There is an industrial outreach program. Process heat applications as well as power are being considered. They are trying to find out what industry needs in these areas. Idaho National Labs is trying to establish an integrate energy system to consider all aspects of energy and then see where nuclear fits in. There is a lot of focus on hydrogen as an energy carrier.

The GAIN Voucher program started in 2016 and $26 million has been awarded to date. GAIN Vouchers are open to support multiple areas for advanced nuclear applications. End users can potentially make use of this resource. There is a 20% cost share requirement. The next cycle is due Jan. 31st. There are 4 cycles per year. Typically, these are one-year studies in the range of $100- $500 K. Summary results for each completed study are available on the website. There are two test beds for SMR projects. There are 6 SMR projects and 2 micro reactor projects that are on the timeline for the next 6 years.

Christopher Lohse, DOE Idaho Lab

New DOE – Office of Clean Energy Demonstrations (12/8 CIBO Committee Presentation)

The Office of Clean Energy Demonstrations (OCED) is charged with delivering clean energy demonstration projects in conjunction with industry. Some $25+ billion has been designated by Congress for the purposes of getting these demonstration projects built and ready for commercialization. While this is a lot of money, it is probably not enough to generate a substantial number of demonstration plants. One feature is to establish Centers of Excellence for project management of these programs. There is an engagement and outreach group that is looking to improve communications with industry.

OCED is firmly in the demonstration stage of RDD&D. They are to bridge the gap between development and deployment. Projects will be evaluated across EPC costs, business development, community benefits, safety, and environment benefits. Typical projects take around 10 years. Funding must be obligated by 2026.

Industrial Decarbonization is an incredibly complex problem. Energy efficiency, electrification, low carbon fuels, and CCS/CCUS. The legislation has identified energy intensive industries for priority consideration. The infrastructure bill has identified $6.3 billion for projects. For FY 2022 – 2025. However, the funds do not expire. Process heat, alternate feedstocks, and CCS are key cross cutting features across industries.

The Justice40 Initiative is intended to drive 40% of the benefits of these projects toward underserved communities. There is an OECD website and newsletter. The Office of Energy Efficiency and Renewable Energy and the Office of Manufacturing and Energy Supply Chains. The website is energy.gov/OCED.

Christina Walrond, USDOE

Update on Social Cost of Carbon (12/8 CIBO Committee Presentation)

The economic backdrop is currently an inflationary environment. Regulatory policy is often driven by economic environment. Wages are growing but not keeping pace with inflation. As a result, savings are down considerably as people are dipping into their savings to maintain living standards. Gasoline prices have come down, but are still higher than they were before the pandemic. Regulatory burdens just add to these burdens.

Since Jan. 2021, this administration has issued 500 new regulations. That translates to over $200 million in additional paperwork burdens. The top 10 air rules drive about $400 billion/yr in regulatory costs. That is greater than the GDP for 31 different states. EPA’s spring regulatory agenda listed 70 new rules. EPA has proposed a revision to the Risk Management Program (CAA 112(r)(7)). This is a chemical accident prevention regulation. There are 140 regulated substances. There are currently 11,740 regulated facilities. These facilities must have a risk management plan to cover potential accidents. Accidents at these facilities have been reduced by more than 70% in the last 15 years. Over 97% of regulated facilities had no reportable accidents in the last 5 years. However, EPA is pushing for “no risks”. EPA is claiming EJ considerations need to be addressed in these plans.

The Obama administration had a proposal in 2017. The Trump administration rescinded the proposed rule. There have been a number of litigations. In the new rule, there is an inclusion of climate considerations. There are also requirements for power loss issues. This requirement states the need for backup power in order to maintain pollution control equipment in operation in the event of a power loss. Third party audits have also been added. Recommendations by such an audit need to be followed or some justification must be supported in the risk plan. Rail cars that are not unloaded within 25 hours can become part of the risk plan. The Chamber has recommended slowing down EPA and coordinating with OSHA.

The Social Cost of GHGs is an analytical tool that resulted from the government estimating the amount of GHGs being reduced from a particular policy. The courts ruled that the government should apply a cost to these claims so as to better understand the costs and benefits. The Obama administration put together a team to come up with an estimate. The Trump administration decided to eliminate world damage costs and only focus on US damage estimates. Also the Trump administration changed the discount rate that was used. As a result, the SCC dropped to something like $10/ton. The current administration is redoing the estimate and will be proposing a number closer to $250/ton. The Chamber will challenge this figure.

Chad Whiteman, US Chamber of Commerce

Decarbonizing Industrial Steam & Power with Chemical Looping and Oxygen Combustion Technologies

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

Congressional GOP Perspective and Plans for 2023

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.

  • Marty Hall, Citizens for Responsible Energy Solutions (CRES)

High Temperature Heat – New Technology Overview

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

DOE – Renewable Energy Guidance Report

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

University of Cincinnati Campus Energy Update

The University of Cincinnati campus covers nearly 8 million ft2. The campus is landlocked and in the middle of a built up urban area. It is subject to EJ considerations.

The Central Utility plant was constructed in 1993 to house the combined cycle plants, which allowed the shutdown of coal units. There are two gas turbines that feed HRSGs, which feed a steam turbine for power generation. There are 4 gas/oil fired boilers to provide steam, as well as backup diesel generators for summer use. The university has committed to 50% carbon reduction by 2035 and carbon neutrality by 2075. There is a climate action plan, but limited accountability in terms of reaching those goals. Implementing ideas to achieve these goals is a major challenge.

The combined cycle plant, installed in 2003, has generated renewable energy credits. An underground chilled water plant was installed in 2008. One of the peaking generators can use biodiesel. The two coal fired boilers were converted to wood pellets. However, problems with the feed systems and fuel supply led to the shutdown of these units. Chilled water systems are being upgraded with smart, multi compressor systems. Some green power is purchased from the utility. Wind power is the primary source. A real time data system is being installed to provide complete system data to identify potential opportunities for energy savings. A 1.5 Mw solar array is planned. Biodiesel blending is considered when oil firing (backup fuel) is needed. Hydrogen blending with natural gas is being considered for the gas turbines. Hydrogen supply is currently an issue. The PEMS system would have to be modified for such blends. Small modular nuclear reactors are being studied. The “nuclear battery” concept appears to be more attractive (shop assembled, 10 year life, plug and play). These units might be a long term solution.

– Sheri Bussard, University of Cincinnati

Cornell Campus Energy Update

The Cornell campus is pushing 15 million ft2 in upstate New York. The power plant supplies steam for heat, plus electric power and water services. Peak load is 35 Mw. Energy conservation activities improved overall efficiency which reduced carbon emissions. Two gas turbines with HRSGs provide cogeneration and allowed for the shutdown of the two coal boilers. Pressure from the student community, the state, the faculty, and eNGOs drove the elimination of the coal units.

The university adopted the Paris Accords. There are state regulations that will impact the university. Building codes may require renewable energy credits. The state is pushing for all buildings to be electric. The university has a Climate Action Plan which calls for carbon neutrality by 2035. Renewable energy use is only a part of the plan. One approach is earth source heat (like geothermal). The alternative is ground-sourced heat pumps. Nuclear power is another option. The last alternative is carbon credits. Solar PV and wind power can be deployed for electricity supply. Earth source heating involves drilling down about 10,000 ft to where the temperature can support heating water to 190 F. That hot water is brought to the surface for use as building heat. A test well has been drilled. Hot water has been verified. There were no seismic or fracture issues. The university promotes community involvement. Of course, this approach requires a shift from steam distribution to hot water distribution. Backup and emergency power and heat need to be evaluated. Energy conservation programs will continue. The university would like to be able to generate some carbon offsets.

 – Cheryl Ann Brown, Cornell University