GHG Best Performance Standards

San Joaquin Valley APCD

GHG Best Performance Standards

San Joaquin Valley APCDASHRAE Meeting

Daniel Barber, Ph.D.

Dennis Roberts, P.E.

November 3, 2011

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District Permitting Actions District Permitting Actions

•Per CEQA, projects subject to discretionary approval are subject to CEQA provisions

•District issuance of permits for projects subject to BACT is a discretionary approval

•Every permit application project undergoes a CEQA review (1,800 projects in 2010) to determine the appropriate level of environmental analysis

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District CEQA Review ProcessDistrict CEQA Review Process

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District CEQA RolesDistrict CEQA Roles

•District Lead Agency: Permit application project undergoes a CEQA review, including GHG significance determination (District CEQA GHG Policy)

•District Responsible Agency: District does not have statutory authority over GHG emissions. Therefore, District relies on Lead Agency’s GHG analysis

•District Commenting Agency: District does not have statutory authority over GHG emissions and relies on Lead Agency’s CEQA GHG analysis. Therefore, the District does not comment on Lead Agency’s GHG analysis (District CEQA GHG Guidance)

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SJV ApproachSJV Approach

Performance Based Approach

•Projects with GHG emission reductions consistent with the State’s legislative mandates would be determined to have a less than significant impact on global climate change•Goal is to meet AB32 GHG emissions reduction target•District Policy requires evaluation of GHG emission reductions achieved through implementation of BPS

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Baseline & Business As Usual (BAU)Baseline & Business As Usual (BAU)

• Baseline is a 3-year average GHG emission inventory for the 2002-2004 period

• BAU is a projection of the baseline emissions inventory reflecting anticipated growth by the year 2020

• ARB’s 29% reduction target is from BAU

• Projects occurring after the Baseline period may already have achieved GHG reductions

2002-2004 BASELINE

2020BAU

1990Emissions

29%

10%

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GHG Significance ThresholdGHG Significance Threshold

Performance Based Standards

• When the District is the Lead Agency for CEQA purposes, all projects with increase in GHG emissions would be subject to significance determination for GHG emissions impact.

• The District’s use of performance based standards is a method of determining significance of project specific GHG emissions using established specifications or project design elements:

Best Performance Standards (BPS)

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• BPS Stationary Source Projects – Best GHG controls that have been achieved on a

given type of source of GHG emissions (technology, energy efficiency, etc.)

– Achieved-in-Practice– Pre-quantified GHG emission reductions

• BPS Development Projects– At least 29% GHG emission reductions compared

to BAU (AB32 target)– Any combination of District approved measures– Achieved-In-Practice

Best Performance StandardsBest Performance Standards

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BPS – ImplementationBPS – ImplementationNo

NO Further Analysis

LESS THAN SIGNIFICANT SIGNIFICANT

Yes

No

Project EXEMPT

from CEQA

Yes

Yes

Yes

No

Project complies with an adopted statewide, regional, or

local plan for reduction or mitigation of GHG emissions

Complies with District Approved BPS for this type

of project

Project achieves 29% GHG Emission Reductions

compared to BAU(AB32 target)

GHG emissions Quantification

No

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BPS - ImplementationBPS - Implementation

• Projects Implementing BPS: Streamlined process

– GHG emission reductions pre-quantified– No additional quantification of GHG required – GHG impacts deemed less than significant

• Alternative to BPS: Project specific analysis

– Must quantify project specific GHG emissions– May demonstrate equivalency to approved BPS– May reduce or mitigate GHG emissions by 29%

compared to BAU to be deemed less than significant

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BPS – District ExperienceBPS – District Experience

• BPS– Streamlined process– 15 source categories addressed– Takes time up front, but expedites subsequent reviews– Transparent for ATC project applicant

• Projects specific determination– Alternative offered to applicant– Takes time at the project level

• Zero equivalency policy: Project emitting less than 230 ton-CO2e/yr

• Construction related GHG emissions: Amortized over project life

• Achieved real GHG emission reductions

Overall positive experience

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What is BPSWhat is BPSWhat is BPSWhat is BPS

• When BPS is proposed, GHG emissions are automatically deemed less than significant (note that if there is no emission increase such as Routine Replacement of boiler, consideration of BPS not required)

• Best GHG emission controls for a specific class and category of equipment (technology, energy efficiency, etc.)

• Achieved-in-Practice

• Pre-quantified GHG emission reductions (compared to the baseline, 2002-2004 period)

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

BPS Development Process• Identify Class and Category• Initial Public Process (public comments solicited)• BPS Determination• Issue Draft BPS (public comments solicited)• 30-day public comment period (public workshop meeting if

deemed necessary)• Issue final determination

To subscribe /participate/receive notifications:

Go to www.valleyair.org/Public Participation/Email Lists

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

BPS Established• New NG boiler w/ steam pressure > 75 psig• New NG boiler w/ steam pressure < 75 psig• New NG hot water boilers• Oilfield steam generators

Additional BPS Under Development:• Existing Boilers• Non-oilfield steam generators• Process heaters

See www.valleyair.org/CEQA/greenhouse gas/BPS

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

BPS for New Steam Boilers

• In practice, BPS applicability is usually restricted to new boilers (new service, non-replacement).

• Applicability to modified boilers has generally been restricted to units for which the original air pollution permits established a maximum firing rate which was less than the full potential and the facility now wants to increase.

• BPS are generally design standards rather than operational performance standards.

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

BPS for New Steam Boilers

GHG Reduction Measures Considered:• Reduce stack losses• Reduce efficiency losses associated with high

excess air operation• Reduce indirect GHG emission associated

with high excess air/FGR rates• Reduce energy losses associated with high

boiler blow down rates

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

Stack loss reduction measure for steam boilers:• Performance standard based on economizer with 20

oF approach to boiler feed water for units 20 MMBtu/hour and less

• Economizer approach of 50 oF to weighted cold water supply temperature for larger units over 20 MMBtu/hour where water supply < 150 oF

• Any proposed alternate design option approvable as long as it meets the same stack temperature specification and the recovered heat is used to offset fuel use which would have otherwise been required

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

Excess air reduction measure for steam boilers (>20 MMBtu & > 75 psig only):

• Install O2 trim system

• Design for 3% O2 during normal operation

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

Indirect emission reduction measure for steam boilers:

• Require VSD and high efficiency motors for combustion air/FGR fans

• Limit FGR to 10% (>20 MMBtu/hour & > 75 psig only)

• Unit designed for 3% O2 operation (>20 MMBtu/hour & > 75 psig only)

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

Blow down Loss reduction measure for steam boilers with continuous blow down exceeding 8% of steam production (>20 MMBtu/hour & > 75 psig only):

• Automatic blow down control system

• Flash steam recovery system

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BPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and HeatersBPS for Boilers and Heaters

BPS for new hot water boilers:

• 89% rated efficiency with return water temperature of 100 oF and 20 oF temperature rise

• 84% rated efficiency for low use or secondary boilers in hydronic systems

• VSD for combustion air fan• 2008 CA Energy Efficiency Standards

required where applicable

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Contact InformationContact Information

• Air District – Website: www.Valleyair.org– Phone: (559) 230-5800

• Daniel Barber, Supervising AQS

– E-Mail: Daniel.Barber@Valleyair.org– Phone: (559) 230-5840

• Dennis Roberts, Senior Air Quality Engineer

– E-Mail: Dennis.Roberts@Valleyair.org– Phone: (559) 230-5919