ob regulation chp

8/14/2019 OB Regulation CHP

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Output-Based Regulation:

Best Practices for RegulatorsNational CHP Turbine Technology and Regulatory ForumMarch 6, 2003

Joel BluesteinEnergy and Environmental Analysis, Inc.

Prepared under contract for EPA


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Best Practices for Regulators


Best Practices for Regulators

Project of EPAs CHP Partnership

Purpose: Support air regulators seeking

to encourage energy efficiency as acontrol strategy.

Products:

White paper: Nuts and bolts -- What, whyand how

Outreach and support to air regulators


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What is Output-Based Regulation?What is Output-Based Regulation?

Regulation that relates emissions to the

productive output of a device or

process.

Unit of emissions/unit of output

lb emission/MWh

Can be applied for any process

Our focus is the power/large boiler sector


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Measurement in Air RegulationsMeasurement in Air Regulations

Historically based on industry

practice.

Some regulations have always beenoutput-based:

Engines - g/bhp-hr

Industrial processes - lb emission/ton of

product

Cars - g/mi


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Power Generation and Boiler Regulation

Have Not Been Output-Based

Power Generation and Boiler Regulation

Have Not Been Output-Based

Boilers - lb/MMBtuin

Turbines - ppm

Eliminate energy efficiency as a control

option.

Output-based version is:

lb/MWhout

lb/MMBtuout


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Evolution of Air Quality RegulationEvolution of Air Quality Regulation

Initial focus was add-on/end of pipe controls to reduceexisting pollution.

Great progress has been made on air quality.

Pollution prevention (P2) is an additional tool to

enable further, cost-effective progress. Improving efficiency in any process is P2 at its best.

Output-based regulations promote efficiency.


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Efficiency as a

Pollution Control Measure

Efficiency as a

Pollution Control Measure

Reduces all emissions, including non-

regulated and greenhouse gases.

Its always on. No start-up, shut-down or

malfunction interruptions.

Provides additional options for emission

reduction.

Makes emission reduction more cost-

effective.


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Design Flexibility BenefitsDesign Flexibility Benefits

Plant

efficiency

(percent)

Control device

efficiency

(percent)

Emission

limit

lb/MWh

34 60 1.3

40 50 1.3

Incorporating efficiency allows

alternatives to add-on pollution control.


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Efficiency Effect on ppm EmissionsEfficiency Effect on ppm Emissions

0.00

0.25

0.50

0.75

1.00

1.25

1.50

0 5 10 15 20 25 30

ppm NOx

lbNOx/MWh

15% Eff20% Eff

25% Eff

30% Eff

50% Eff


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Conventional Rate LimitsConventional Rate Limits

Output-based regulation allows and

encourages efficiency to be used as

a control option. Combustion efficiency

Reduced parasitic loads

Generator efficiency

Links emissions to productive output.


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Benefits of Output-Based RegulationBenefits of Output-Based Regulation

Emissions 0.09 lb/MMBtu

Emissions 0.12 lb/MMBtu

300 MW

300 MW

2.1 million MWh/yr

Plant

2

Plant

1

2.1 million MWh/yr


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Fuel Use 21 MM MMBtu/yr

Fuel Use 13.7 MM MMBtu/yr

34% Efficiency

53% Efficiency

300 MW

300 MW

2.1 million MWh/yr

Plant

2

Plant

1

2.1 million MWh/yr



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0.09 lb/MMBtu

21 million MMBtu/yr

0.12 lb/MMBtu

13.7 million MMBtu/yr

34% Efficiency

53% Efficiency

300 MW

300 MW

2.1 million MWh/yr

Plant

2

Plant

1

2.1 million MWh/yr

945 Tons/year0.9 lb/MWh

787 Tons/year

0.7 lb/MWh


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Example: CHPExample: CHP

Combined Heat and Power is thegeneration of electricity and heatsequentially from the same heat input.

Electricity primarily used on-site, butsome can be sold back to grid. Gridcan serve as back-up or swing provider.

Thermal energy used forheating/cooling or process applications.


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Typical CHP SystemsTypical CHP Systems

Gas Turbine or Engine/Heat Recovery Unit:Steam Boiler/Steam Turbine:


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Advantages of CHPAdvantages of CHP

CHP is more efficientthan separate generation ofelectricity and heat.

Higher efficiency translates to lower cost.

Use of waste or byproduct fuel, where available,

further reduces cost.

On-site electric generation avoids distribution costs,

a significant component of grid electricity price.

Increased reliability and power qualitycan also add

significant value.


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Environmental Benefits of CHP (NOX)Environmental Benefits of CHP (NOX)


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Central Power vs

On-Site CHP Emissions

Central Power vs

On-Site CHP Emissions

0

5

10

15

20

25

30

35

40

45

Boiler+Grid Boiler+Non-CHP DG

(25 ppm)

CHP (25 ppm) CHP (15 ppm)

TonsNOx/yr

Electricity

Boiler

Grid = 1.5 lb NOx/MWh

Boiler=0.10 lb NOx/MMBtu


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Multipollutant CHP BenefitsMultipollutant CHP Benefits

38.7

76.3

31.7

27.3

17.3

0.1

22.5

0.00

10

20

30

40

50

60

70

80

90

NOx Tons SOx Tons CO2 1,000 tons Hg lbs*100

Emissions

Boiler+Grid Gas CHP


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Development of LimitsDevelopment of Limits

In the near term, we start with input-based limits and convert units to output

format.

Ideally, limits will be based on output-based measurements.

Output-based limits allow for uniform and

direct comparisons.


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Input to Output ConversionInput to Output Conversion

Power generation - lb/MMBtu, ppm or

g/bhp-hr to lb/MWh.

Industrial boilers - lb/MMBtuinput tolb/MMBtuoutput.

Requires unit conversions and

efficiency factor.


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Net vs Gross OutputNet vs Gross Output

Net output deducts internal loads and

losses.

Use of net is closer to policy goal of

recognizing overall efficiency.

Calculation of net can be complicated

for large power plants.

Tradeoff must be made between policy

goal and complexity.


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Compliance MeasurementCompliance Measurement

Emission measurement is the same

regardless of rule format.

Output measurement may require newprocedures but there are no

fundamental barriers.

Output is often measured as part of

plant business (selling the product).


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Output MeasurementOutput Measurement

Electricity output is easily measured andoften measured for commercial purposes.

Thermal output of large boilers is often

measured for plant operation purposes.

CHP facilities often measure thermal output

for sales purposes.

The technology is available.


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Thermal Output ApproachThermal Output Approach

Set basic standard in lb/MWh.

For CHP system, compliance is calculated

as:

emissions/(MWhe + MWhth) Some regulations allow only partial

thermal credit.

Impact is primarily a function of systemdesign (P/H).


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Displaced Emission ApproachDisplaced Emission Approach

Set basic standard in lb/MWh. For CHP system, compliance is calculated

as:

(emissions - avoided emissions)/MWhe Avoided emissions are the emissions that

would have been created by a boiler

providing the same thermal output. Reflects actual environmental benefits.


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NSPS ImplementationNSPS Implementation

lb/MWh measure to encompass totalplant efficiency.

Gross output to simplify measurement.

Limit initially based on conversion ofinput-based data. Final value based on

measured output-based data.

CHP credit based on 50 percent thermalcredit.


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Impacts of Output-Based NSPSImpacts of Output-Based NSPS

Important indicator of EPA support for output-based regulation.

Addressed many basic questions regarding

output-based regulation, compliance

measurement, treatment of CHP.

Few if any new affected boilers built yet but

the value for supporting other regulations has

been great.

C St d N ti l M d lC St d N ti l M d l


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Case Study - National Model

Emissions Rule for DG

Case Study - National Model

Emissions Rule for DG

An output-based national model rule

has been developed under DOE

funding through a stakeholder processfacilitated by the Regulatory Assistance

Project.

Draft rule available at:http://www.raponline.org


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Who Has DoneWho Has Done


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Who Has Done

Output-Based Regulation?

Who Has Done

Output-Based Regulation?

Conventional rate limits

Distributed generation

Allowance allocation Multipollutant programs

Generation performance standards


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Conventional Rate LimitsConventional Rate Limits

EPA NSPS for utility boilers - uniform

output-based limit with credit for CHP

Ozone Transport Commission Model

NOx Rule - sets NOx limits for

combustion turbines in lb/MWh


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Generation Performance StandardGeneration Performance Standard

Derives from Massachusetts

restructuring language.

Requires retail sellers to meet output-

based portfolio emission standards

including out of state generation.

Connecticut and New Jersey have

considered similar requirements.


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