Notice of Opportunity To Comment on a Methodology for Allocating Greenhouse Gas Emissions to a Combined Heat and Power Configuration Under the Renewable Fuels Program, and the Application of this Methodology to a Proposed Plant by Dakota Spirit AgEnergy in Spiritwood, ND, 55834-55837 [2012-22347]
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55834
Federal Register / Vol. 77, No. 176 / Tuesday, September 11, 2012 / Notices
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[FR Doc. 2012–22344 Filed 9–10–12; 8:45 am]
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ENVIRONMENTAL PROTECTION
AGENCY
[EPA–HQ–OAR–2012–0636; FRL–9725–7]
Notice of Opportunity To Comment on
a Methodology for Allocating
Greenhouse Gas Emissions to a
Combined Heat and Power
Configuration Under the Renewable
Fuels Program, and the Application of
this Methodology to a Proposed Plant
by Dakota Spirit AgEnergy in
Spiritwood, ND
Environmental Protection
Agency (EPA).
ACTION: Notice.
AGENCY:
EPA is evaluating a petition
by Dakota Spirit AgEnergy for approval
of a fuel pathway for its corn ethanol
plant under the Renewable Fuels
Standard (RFS) program. The corn
ethanol plant would import process
steam from a combined heat and power
(CHP) system located at an offsite
facility. EPA is inviting comment on the
application of a certain methodology for
allocating greenhouse gas (GHG)
emissions for the steam and on the
feasibility and appropriateness of using
this allocation methodology for other
similar CHP configurations under the
RFS program.
DATES: Comments must be received on
or before October 11, 2012.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–HQ–
OAR–2012–0636, by one of the
following methods:
• www.regulations.gov: Follow the
on-line instructions for submitting
comments.
• Email: a-and-r-docket@epa.gov,
Attention Air and Radiation Docket ID
EPA–HQ–OAR–2011–0542.
• Mail: Air and Radiation Docket,
Docket No. EPA–HQ–OAR–2012–0636,
Environmental Protection Agency,
Mailcode: 6406J, 1200 Pennsylvania
Ave. NW., Washington, DC 20460.
• Hand Delivery: EPA Docket Center,
EPA/DC, EPA West, Room 3334, 1301
Constitution Ave. NW., Washington, DC
20460, Attention Air and Radiation
Docket, ID No. EPA–HQ–OAR–2011–
0542. Such deliveries are only accepted
during the Docket’s normal hours of
operation, and special arrangements
should be made for deliveries of boxed
information.
Instructions: Direct your comments to
Docket ID No. EPA–HQ–OAR–2012–
0636. EPA’s policy is that all comments
received will be included in the public
docket without change and may be
made available online at
www.regulations.gov, including any
SUMMARY:
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Federal Register / Vol. 77, No. 176 / Tuesday, September 11, 2012 / Notices
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email address: ghanta.venu@epa.gov.
SUPPLEMENTARY INFORMATION:
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Introduction
Background on CHP
As part of changes to the Renewable
Fuel Standard (RFS) program adopted in
a rule published on March 26, 2010,1
EPA specified the types of renewable
fuels eligible to participate in the RFS
program through approved fuel
pathways. Table 1 to 40 CFR 80.1426(f)
of the RFS regulations lists three critical
components of an approved fuel
pathway: (1) Fuel type; (2) feedstock;
and (3) production process. Each
specific combination of the three
components, or fuel pathway, is
assigned a renewable fuel category for
use of the fuel in the RFS program. EPA
may also independently approve
additional fuel pathways not currently
listed in Table 1 for participation in the
RFS program, or a third party may
petition for EPA to evaluate a new fuel
pathway in accordance with § 80.1416.
Pursuant to 40 CFR 80.1416, EPA
received a petition from Dakota Spirit
AgEnergy (‘‘Dakota’’) on October 15,
2011, requesting that EPA evaluate a
new fuel pathway’s lifecycle GHG
reduction and provide a determination
of the renewable fuel category for which
the new pathway may be eligible.
Dakota is proposing to build a dry-mill
corn ethanol plant in Spiritwood, North
Dakota, with a nameplate production
capacity of 65 million gallons of ethanol
per year. Dakota’s proposed process is
unlike those used in pathways modeled
for the 2010 RFS rule in that they plan
to meet their process steam needs by
importing steam from the adjacent
Spiritwood Station coal-fired power
plant, which would operate in a
combined heat and power (CHP) mode.
EPA has not previously considered
the treatment of steam from an offsite
CHP plant in a lifecycle emissions
accounting analysis under the RFS
program. EPA is not aware of a previous
regulatory context where an allocation
approach has been applied to determine
the emissions associated with process
steam from an offsite facility. This
notice describes the methodology EPA
is considering to allocate emissions to
the imported steam Dakota plans to use
for biofuels production, as well as the
Agency’s rationale for selecting this
methodology in the context of the RFS
program and for the type of
configuration being considered. EPA
invites comment on the application of
the GHG allocation methodology and on
the feasibility and appropriateness of
using this allocation methodology for
other similar CHP configurations under
the RFS program.
CHP is an efficient, clean, and reliable
approach to generating power and
thermal energy from a single fuel
source. By installing a CHP system
designed to meet the thermal and
electrical base loads of a facility, CHP
can greatly increase the facility’s
operational efficiency and decrease
energy costs. CHP systems offer
considerable environmental benefits
when compared with purchased
electricity and onsite-generated heat. By
capturing and utilizing heat that would
otherwise be wasted from the
production of electricity, CHP systems
require less fuel than equivalent
separate heat and power systems to
produce the same amount of energy.
In the 2010 RFS rule, EPA evaluated
a corn ethanol biorefinery that utilized
an onsite CHP system as part of the
ethanol production process. The process
evaluated a CHP system installed at the
biorefinery which generated process
steam and electricity for use in the
process for producing ethanol. Dakota’s
proposed approach is different in that
they plan to import process steam from
the adjacent Spiritwood Station power
plant that will operate in CHP mode.
The Spiritwood power plant combusts
coal in a circulating fluidized-bed boiler
that will generate steam at high
temperature and pressure. This high
pressure steam will be sent through a
high-pressure steam turbine (HPST),
where energy will be extracted to
produce electricity. The steam will exit
the HPST at lower pressure and
temperature, at which point some of the
steam will be diverted to the Dakota
biorefinery plant to provide thermal
energy for the ethanol production
process. The remaining steam at
Spiritwood will be sent through a lowpressure steam turbine (LPST) to
produce additional electricity. The
extraction steam diverted for use at the
ethanol plant will result in a decrease in
the amount of power to be generated
from the power plant. Therefore,
although the amount of electricity
generated is reduced, the total fuel
consumed and the resulting GHG
emissions of the power plant remain
unchanged.
To determine the emissions
associated with the extracted steam, the
total emissions of the Spiritwood power
plant need to be allocated to the power
plant’s power production and to the
steam extracted for use at the
biorefinery. EPA analyzed the Dakota
CHP configuration and reviewed several
different allocation methods, including
1 75
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the GHG Protocol.2 EPA’s review
indicated that currently there is no one
recommended allocation method for
allocating emissions to the energy
outputs (electrical and thermal) from a
CHP system. EPA’s review also
indicated that the most appropriate
allocation methodology for a CHP
system will be dependent on the type of
CHP configuration in use, as well as the
primary use of the system’s electrical
and thermal outputs. Based on the plant
configuration presented in the Dakota
petition, EPA is considering using the
‘‘work potential’’ allocation approach to
allocate emissions.
Work Potential Allocation Approach
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EPA considers the work potential
allocation approach to be most
appropriate for CHP systems that use
heat to primarily produce mechanical
work or power, such as the case at the
Spiritwood plant where the primary use
for the steam is for power generation.3
The work potential approach allocates
emissions based on the useful energy 4
represented by electric power and heat.
For the configuration presented in the
Dakota petition, the method allocates
emissions to the extracted steam based
on the amount of electricity that the
steam would have produced had the
steam not been diverted for use at the
biorefinery.
The Spiritwood power plant is
designed for the primary function of
generating electricity. The total
emissions at the Spiritwood plant are
constant, whether steam is diverted or
not. When steam is diverted to the
Dakota biorefinery, the emissions
associated with the diverted steam and
the resulting loss in electricity
production is evaluated via the work
potential method. We can determine an
emission factor for the power plant
when it is just generating electricity and
not diverting steam to the Dakota
biorefinery (i.e., operating in a ‘‘power
only’’ mode). The GHG emissions
attributed to the extracted steam is
determined by estimating the amount of
power not generated by the power plant
because the steam was diverted from the
turbine, and applying the power plant’s
‘‘power only’’ emissions factor to that
value. The emission factor is unchanged
since the total emissions at the
2 Jointly convened by the World Business Council
for Sustainable Development (WBCSD) and the
World Resources Institute (WRI), Allocation of
emissions from a Combined Heat and Power Plant,
September 2006.
3 The GHG Protocol recommends the use of this
approach if the thermal output of the CHP system
is to be used for mechanical power
4 Useful energy is defined as the ability of heat
to perform work.
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Spiritwood plant are unchanged and
only a small portion of the steam energy
generated at the power plant is diverted
to the biorefinery. The process for
determining the steam GHG emission
factor using the work allocation
approach is summarized by the
following steps:
1. Calculate the GHG emission factor
for the Spiritwood power plant without
any steam extracted;
2. Determine the amount of electricity
that is not generated due to the
extraction of steam for the Dakota plant;
and
3. Apply the Spiritwood emissions
factor to the amount of electricity not
generated due to steam extraction and
calculate the associated emissions.
This following example illustrates
how the work potential method
allocates emissions based on useful
energy produced. In Dakota’s petition,
they presented an example where the
Spiritwood plant generates 92 MW of
electric power in power-only mode, but
only produces 82 MW of electric power
in CHP mode due to the steam
extraction. Thus, the steam extraction
displaces about 11% of the total power
production. Using the work potential
allocation method, the extracted steam
is allocated 11% of the total emissions
from the Spiritwood plant, whereas the
remaining 89% of emissions are
allocated to electricity production.
Other Allocation Approaches
EPA reviewed other allocation
approaches to assess their
appropriateness for allocating emissions
for the Dakota petition. The other two
most common methods to allocate
emissions from a CHP system are:
Efficiency Allocation Method—The
efficiency method allocates GHG
emissions based on the amount of fuel
used to produce each final energy
stream. Emissions are allocated based
on the efficiencies of thermal energy
and electricity production, and the
emission allocation will vary based on
how the electrical and thermal
efficiencies are defined. The actual
efficiencies of heat and power
production are often not clearly defined
for CHP systems, and assumed default
values are typically used.
Conversion or Energy Content
Method—This method allocates
emissions based on the relative amounts
of power and thermal energy output. It
makes no allowance for the relative
value of the outputs or the relative
efficiencies of generation and simply
allocates emissions based on the relative
energy content of each output.
The efficiency and energy content
allocation approaches are based on
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assumptions, either of the efficiencies
with which steam and electricity are
generated, or on the relative values of
energy outputs. As an example, the
emission allocation of the efficiency
method will vary based on how the
electrical and thermal efficiencies are
defined. Under these approaches, the
emissions allocated to the remaining
electricity generation (in terms of lbs/
MWh) at the Spiritwood plant in CHP
mode would be lower than the original
emissions factor for electricity generated
by Spiritwood operating in power-only
mode, indicating an over-allocation of
emissions to the extraction steam.
Since CHP system design and
operating characteristics vary so widely,
leading organizations in this field have
not developed a consensus on one
preferred allocation method. The
California Air Resources Board issued a
technical document as part of its
Climate Change Reporting
Requirements 5 that reviewed several
allocation methods but did not
recommend any one allocation method
in particular. The Climate Registry
(TCR),6 the former EPA Climate Leaders
program, and the GHG Protocol 7
recommend the efficiency method, and
that CHP facilities identify actual
thermal energy and electricity
production efficiencies. In the absence
of actual emissions, default efficiencies
of 35% for electricity (grid generation
efficiency) and 80% for steam (stand
alone boiler efficiency) are suggested.
Neither the default nor calculated
efficiencies appear representative of the
Spiritwood operations. However, as
stated above, the GHG Protocol 8 also
recommends the use of the work
potential method if the thermal output
of the CHP system is going to be used
for mechanical power.
The Western Climate Initiative
received various recommendations on
the treatment of combined heat and
power in its initial draft design
guidance for recording greenhouse gas
(‘‘GHG’’) emissions since it has
implications in both the industrial and
electricity sectors. The
5 Cogeneration: Proposed Approach for
Mandatory Greenhouse Gas Emissions Reporting.
California Air Resources Board: Climate Change
Reporting, Handout for ARB’s GHG Technical Team
Discussions, June 2007.
6 General Reporting Protocol, Version 1.1, The
Climate Registry, May 2008.
7 Jointly convened by the World Business Council
for Sustainable Development (WBCSD) and the
World Resources Institute (WRI), Allocation of
Emissions from a Combined Heat and Power Plant,
September 2006.
8 Jointly convened by the World Business Council
for Sustainable Development (WBCSD) and the
World Resources Institute (WRI), Allocation of
emissions from a Combined Heat and Power Plant,
September 2006.
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Federal Register / Vol. 77, No. 176 / Tuesday, September 11, 2012 / Notices
recommendations varied based on the
type of CHP configuration. WCI in its
final 2008 recommendation 9 did not
advance one allocation method over
another, stating ‘‘adequate
quantification methods will be
established for emissions sources prior
to including them in the program’’. The
British Standards Institute (BSI)’s
Publicly Available Specification (PAS)
2050 10 recommends using an approach
based on the unit of useful energy
delivered. The specification
recommends ‘‘the allocation shall be
carried out in proportion to the amount
of useful energy delivered in each form,
multiplied by the intensity of GHG
emissions associated with each unit of
useful energy delivered as heat and
electricity.’’ This methodology
acknowledges that each CHP system
may have a different ratio of outputs of
thermal and electrical energy.
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Application of the Work Potential
Allocation Methodology to the Dakota
Plant
Under the RFS2 program, EPA is
considering use of the work potential
method for the configuration outlined in
the Dakota petition because the primary
purpose of the steam generated at
Spiritwood power plant before
extraction is to produce power. This
method allocates the emissions to
extracted steam based on the amount of
power displaced (i.e., the electricity not
generated).
A Memorandum to the Docket
explains in more detail how the work
potential methodology would be
applied to the plant configuration
proposed for the Dakota plant, resulting
in a specific GHG emission factor per
mmbtu of steam energy. This emissions
factor would be used in analyzing the
total GHG emissions per mmbtu of
ethanol produced by the Dakota facility,
as part of determining whether the
ethanol produced by the facility would
qualify under the lifecycle GHG
thresholds established in the RFS
program. For the configuration outlined
in the Dakota petition, EPA’s analysis
finds that the process steam has an
emission factor of 53,175 grams CO2-eq/
mmbtu steam.
9 The WCI Partner jurisdictions recognize the
importance of combined heat and power
(cogeneration) in the program scope and are
continuing to evaluate its implications for the
program design. Western Climate Initiative, Design
Recommendations for the WCI Regional Cap-andTrade Program. September 23, 2008, Corrected
March 13, 2009.
10 British Standards Institute (BSI), PAS 2050:
2011, Specification for the assessment of the life
cycle greenhouse gas emissions of goods and
services, Section 8.5, Emissions from energy
production using CHP.
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EPA invites comments on the
proposed application of the work
potential methodology to determine
emissions associated with imported
steam to the Dakota plant in the context
of lifecycle emissions accounting.
Furthermore, EPA invites comment on
applying the work potential approach to
other plants with similar CHP
configurations under the RFS program.
EPA also requests information on the
appropriateness of applying alternative
allocation approaches outlined in this
notice to the Dakota plant, as well as
any other approaches that could also be
used to allocate emissions to steam for
this specific CHP configuration under
the RFS program.
Open Session
Dated: August 31, 2012.
Margo Tsirigotis Oge,
Director, Office of Transportation and Air
Quality, Office of Air and Radiation.
Dated: September 6, 2012.
Dale L. Aultman,
Secretary, Farm Credit System Insurance
Corporation Board.
[FR Doc. 2012–22347 Filed 9–10–12; 8:45 am]
[FR Doc. 2012–22359 Filed 9–10–12; 8:45 am]
BILLING CODE 6560–50–P
BILLING CODE 6710–01–P
A. Approval of Minutes
• June 14, 2012 (Regular Meeting)
B. Business Reports
• FCSIC Quarterly Financial Reports
• Report on Insured and Other
Obligations
• Quarterly Report on Annual
Performance Plan
C. New Business
• Annual Performance Plan FY 2013–
2014
• Proposed 2013 and 2014 Budgets
• Insurance Fund Progress Review and
Setting of Premium Range Guidance
for 2013
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CORPORATION
FEDERAL COMMUNICATIONS
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Board Meeting
Information Collection Being Reviewed
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Farm Credit System Insurance
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ACTION: Regular meeting.
AGENCY:
Notice is hereby given of the
regular meeting of the Farm Credit
System Insurance Corporation Board
(Board).
DATE AND TIME: The meeting of the
Board will be held at the offices of the
Farm Credit Administration in McLean,
Virginia, on September 13, 2012, from
1:00 p.m. until such time as the Board
concludes its business.
FOR FURTHER INFORMATION CONTACT: Dale
L. Aultman, Secretary to the Farm
Credit System Insurance Corporation
Board, (703) 883–4009, TTY (703) 883–
4056.
ADDRESSES: Farm Credit System
Insurance Corporation, 1501 Farm
Credit Drive, McLean, Virginia 22102.
SUPPLEMENTARY INFORMATION: Parts of
this meeting of the Board will be open
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and parts will be closed to the public.
In order to increase the accessibility to
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SUMMARY:
Closed Session
• Confidential Report on Farm Credit
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AGENCY:
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SUMMARY:
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Agencies
[Federal Register Volume 77, Number 176 (Tuesday, September 11, 2012)]
[Notices]
[Pages 55834-55837]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-22347]
-----------------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
[EPA-HQ-OAR-2012-0636; FRL-9725-7]
Notice of Opportunity To Comment on a Methodology for Allocating
Greenhouse Gas Emissions to a Combined Heat and Power Configuration
Under the Renewable Fuels Program, and the Application of this
Methodology to a Proposed Plant by Dakota Spirit AgEnergy in
Spiritwood, ND
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: EPA is evaluating a petition by Dakota Spirit AgEnergy for
approval of a fuel pathway for its corn ethanol plant under the
Renewable Fuels Standard (RFS) program. The corn ethanol plant would
import process steam from a combined heat and power (CHP) system
located at an offsite facility. EPA is inviting comment on the
application of a certain methodology for allocating greenhouse gas
(GHG) emissions for the steam and on the feasibility and
appropriateness of using this allocation methodology for other similar
CHP configurations under the RFS program.
DATES: Comments must be received on or before October 11, 2012.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2012-0636, by one of the following methods:
www.regulations.gov: Follow the on-line instructions for
submitting comments.
Email: a-and-r-docket@epa.gov, Attention Air and Radiation
Docket ID EPA-HQ-OAR-2011-0542.
Mail: Air and Radiation Docket, Docket No. EPA-HQ-OAR-
2012-0636, Environmental Protection Agency, Mailcode: 6406J, 1200
Pennsylvania Ave. NW., Washington, DC 20460.
Hand Delivery: EPA Docket Center, EPA/DC, EPA West, Room
3334, 1301 Constitution Ave. NW., Washington, DC 20460, Attention Air
and Radiation Docket, ID No. EPA-HQ-OAR-2011-0542. Such deliveries are
only accepted during the Docket's normal hours of operation, and
special arrangements should be made for deliveries of boxed
information.
Instructions: Direct your comments to Docket ID No. EPA-HQ-OAR-
2012-0636. EPA's policy is that all comments received will be included
in the public docket without change and may be made available online at
www.regulations.gov, including any
[[Page 55835]]
personal information provided, unless the comment includes information
claimed to be Confidential Business Information (CBI) or other
information whose disclosure is restricted by statute. Do not submit
information that you consider to be CBI or otherwise protected through
www.regulations.gov or email. The www.regulations.gov Web site is an
``anonymous access'' system, which means EPA will not know your
identity or contact information unless you provide it in the body of
your comment. If you send an email comment directly to EPA without
going through www.regulations.gov your email address will be
automatically captured and included as part of the comment that is
placed in the public docket and made available on the Internet. If you
submit an electronic comment, EPA recommends that you include your name
and other contact information in the body of your comment and with any
disk or CD-ROM you submit. If EPA cannot read your comment due to
technical difficulties and cannot contact you for clarification, EPA
may not be able to consider your comment. Electronic files should avoid
the use of special characters, any form of encryption, and be free of
any defects or viruses. For additional information about EPA's public
docket visit the EPA Docket Center homepage at https://www.epa.gov/epahome/dockets.htm.
Docket: All documents in the docket are listed in the
www.regulations.gov index. Although listed in the index, some
information is not publicly available, e.g., CBI or other information
whose disclosure is restricted by statute. Certain other material, such
as copyrighted material, will be publicly available only in hard copy.
Publicly available docket materials are available either electronically
in www.regulations.gov or in hard copy at the Air and Radiation Docket
and Information Center, EPA/DC, EPA West, Room 3334, 1301 Constitution
Ave. NW., Washington, DC. The Public Reading Room is open from 8:30
a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The
telephone number for the Public Reading Room is (202) 566-1744, and the
telephone number for the Air Docket is (202) 566-1742.
FOR FURTHER INFORMATION CONTACT: Venu Ghanta, Office of Transportation
and Air Quality (MC6401A), Environmental Protection Agency, 1200
Pennsylvania Ave. NW., Washington, DC 20460; telephone number: (202)
564-1374; fax number: (202) 564-1686; email address:
ghanta.venu@epa.gov.
SUPPLEMENTARY INFORMATION:
Introduction
As part of changes to the Renewable Fuel Standard (RFS) program
adopted in a rule published on March 26, 2010,\1\ EPA specified the
types of renewable fuels eligible to participate in the RFS program
through approved fuel pathways. Table 1 to 40 CFR 80.1426(f) of the RFS
regulations lists three critical components of an approved fuel
pathway: (1) Fuel type; (2) feedstock; and (3) production process. Each
specific combination of the three components, or fuel pathway, is
assigned a renewable fuel category for use of the fuel in the RFS
program. EPA may also independently approve additional fuel pathways
not currently listed in Table 1 for participation in the RFS program,
or a third party may petition for EPA to evaluate a new fuel pathway in
accordance with Sec. 80.1416.
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\1\ 75 FR 14670.
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Pursuant to 40 CFR 80.1416, EPA received a petition from Dakota
Spirit AgEnergy (``Dakota'') on October 15, 2011, requesting that EPA
evaluate a new fuel pathway's lifecycle GHG reduction and provide a
determination of the renewable fuel category for which the new pathway
may be eligible. Dakota is proposing to build a dry-mill corn ethanol
plant in Spiritwood, North Dakota, with a nameplate production capacity
of 65 million gallons of ethanol per year. Dakota's proposed process is
unlike those used in pathways modeled for the 2010 RFS rule in that
they plan to meet their process steam needs by importing steam from the
adjacent Spiritwood Station coal-fired power plant, which would operate
in a combined heat and power (CHP) mode.
EPA has not previously considered the treatment of steam from an
offsite CHP plant in a lifecycle emissions accounting analysis under
the RFS program. EPA is not aware of a previous regulatory context
where an allocation approach has been applied to determine the
emissions associated with process steam from an offsite facility. This
notice describes the methodology EPA is considering to allocate
emissions to the imported steam Dakota plans to use for biofuels
production, as well as the Agency's rationale for selecting this
methodology in the context of the RFS program and for the type of
configuration being considered. EPA invites comment on the application
of the GHG allocation methodology and on the feasibility and
appropriateness of using this allocation methodology for other similar
CHP configurations under the RFS program.
Background on CHP
CHP is an efficient, clean, and reliable approach to generating
power and thermal energy from a single fuel source. By installing a CHP
system designed to meet the thermal and electrical base loads of a
facility, CHP can greatly increase the facility's operational
efficiency and decrease energy costs. CHP systems offer considerable
environmental benefits when compared with purchased electricity and
onsite-generated heat. By capturing and utilizing heat that would
otherwise be wasted from the production of electricity, CHP systems
require less fuel than equivalent separate heat and power systems to
produce the same amount of energy.
In the 2010 RFS rule, EPA evaluated a corn ethanol biorefinery that
utilized an onsite CHP system as part of the ethanol production
process. The process evaluated a CHP system installed at the
biorefinery which generated process steam and electricity for use in
the process for producing ethanol. Dakota's proposed approach is
different in that they plan to import process steam from the adjacent
Spiritwood Station power plant that will operate in CHP mode.
The Spiritwood power plant combusts coal in a circulating
fluidized-bed boiler that will generate steam at high temperature and
pressure. This high pressure steam will be sent through a high-pressure
steam turbine (HPST), where energy will be extracted to produce
electricity. The steam will exit the HPST at lower pressure and
temperature, at which point some of the steam will be diverted to the
Dakota biorefinery plant to provide thermal energy for the ethanol
production process. The remaining steam at Spiritwood will be sent
through a low-pressure steam turbine (LPST) to produce additional
electricity. The extraction steam diverted for use at the ethanol plant
will result in a decrease in the amount of power to be generated from
the power plant. Therefore, although the amount of electricity
generated is reduced, the total fuel consumed and the resulting GHG
emissions of the power plant remain unchanged.
To determine the emissions associated with the extracted steam, the
total emissions of the Spiritwood power plant need to be allocated to
the power plant's power production and to the steam extracted for use
at the biorefinery. EPA analyzed the Dakota CHP configuration and
reviewed several different allocation methods, including
[[Page 55836]]
the GHG Protocol.\2\ EPA's review indicated that currently there is no
one recommended allocation method for allocating emissions to the
energy outputs (electrical and thermal) from a CHP system. EPA's review
also indicated that the most appropriate allocation methodology for a
CHP system will be dependent on the type of CHP configuration in use,
as well as the primary use of the system's electrical and thermal
outputs. Based on the plant configuration presented in the Dakota
petition, EPA is considering using the ``work potential'' allocation
approach to allocate emissions.
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\2\ Jointly convened by the World Business Council for
Sustainable Development (WBCSD) and the World Resources Institute
(WRI), Allocation of emissions from a Combined Heat and Power Plant,
September 2006.
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Work Potential Allocation Approach
EPA considers the work potential allocation approach to be most
appropriate for CHP systems that use heat to primarily produce
mechanical work or power, such as the case at the Spiritwood plant
where the primary use for the steam is for power generation.\3\ The
work potential approach allocates emissions based on the useful energy
\4\ represented by electric power and heat. For the configuration
presented in the Dakota petition, the method allocates emissions to the
extracted steam based on the amount of electricity that the steam would
have produced had the steam not been diverted for use at the
biorefinery.
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\3\ The GHG Protocol recommends the use of this approach if the
thermal output of the CHP system is to be used for mechanical power
\4\ Useful energy is defined as the ability of heat to perform
work.
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The Spiritwood power plant is designed for the primary function of
generating electricity. The total emissions at the Spiritwood plant are
constant, whether steam is diverted or not. When steam is diverted to
the Dakota biorefinery, the emissions associated with the diverted
steam and the resulting loss in electricity production is evaluated via
the work potential method. We can determine an emission factor for the
power plant when it is just generating electricity and not diverting
steam to the Dakota biorefinery (i.e., operating in a ``power only''
mode). The GHG emissions attributed to the extracted steam is
determined by estimating the amount of power not generated by the power
plant because the steam was diverted from the turbine, and applying the
power plant's ``power only'' emissions factor to that value. The
emission factor is unchanged since the total emissions at the
Spiritwood plant are unchanged and only a small portion of the steam
energy generated at the power plant is diverted to the biorefinery. The
process for determining the steam GHG emission factor using the work
allocation approach is summarized by the following steps:
1. Calculate the GHG emission factor for the Spiritwood power plant
without any steam extracted;
2. Determine the amount of electricity that is not generated due to
the extraction of steam for the Dakota plant; and
3. Apply the Spiritwood emissions factor to the amount of
electricity not generated due to steam extraction and calculate the
associated emissions.
This following example illustrates how the work potential method
allocates emissions based on useful energy produced. In Dakota's
petition, they presented an example where the Spiritwood plant
generates 92 MW of electric power in power-only mode, but only produces
82 MW of electric power in CHP mode due to the steam extraction. Thus,
the steam extraction displaces about 11% of the total power production.
Using the work potential allocation method, the extracted steam is
allocated 11% of the total emissions from the Spiritwood plant, whereas
the remaining 89% of emissions are allocated to electricity production.
Other Allocation Approaches
EPA reviewed other allocation approaches to assess their
appropriateness for allocating emissions for the Dakota petition. The
other two most common methods to allocate emissions from a CHP system
are:
Efficiency Allocation Method--The efficiency method allocates GHG
emissions based on the amount of fuel used to produce each final energy
stream. Emissions are allocated based on the efficiencies of thermal
energy and electricity production, and the emission allocation will
vary based on how the electrical and thermal efficiencies are defined.
The actual efficiencies of heat and power production are often not
clearly defined for CHP systems, and assumed default values are
typically used.
Conversion or Energy Content Method--This method allocates
emissions based on the relative amounts of power and thermal energy
output. It makes no allowance for the relative value of the outputs or
the relative efficiencies of generation and simply allocates emissions
based on the relative energy content of each output.
The efficiency and energy content allocation approaches are based
on assumptions, either of the efficiencies with which steam and
electricity are generated, or on the relative values of energy outputs.
As an example, the emission allocation of the efficiency method will
vary based on how the electrical and thermal efficiencies are defined.
Under these approaches, the emissions allocated to the remaining
electricity generation (in terms of lbs/MWh) at the Spiritwood plant in
CHP mode would be lower than the original emissions factor for
electricity generated by Spiritwood operating in power-only mode,
indicating an over-allocation of emissions to the extraction steam.
Since CHP system design and operating characteristics vary so
widely, leading organizations in this field have not developed a
consensus on one preferred allocation method. The California Air
Resources Board issued a technical document as part of its Climate
Change Reporting Requirements \5\ that reviewed several allocation
methods but did not recommend any one allocation method in particular.
The Climate Registry (TCR),\6\ the former EPA Climate Leaders program,
and the GHG Protocol \7\ recommend the efficiency method, and that CHP
facilities identify actual thermal energy and electricity production
efficiencies. In the absence of actual emissions, default efficiencies
of 35% for electricity (grid generation efficiency) and 80% for steam
(stand alone boiler efficiency) are suggested. Neither the default nor
calculated efficiencies appear representative of the Spiritwood
operations. However, as stated above, the GHG Protocol \8\ also
recommends the use of the work potential method if the thermal output
of the CHP system is going to be used for mechanical power.
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\5\ Cogeneration: Proposed Approach for Mandatory Greenhouse Gas
Emissions Reporting. California Air Resources Board: Climate Change
Reporting, Handout for ARB's GHG Technical Team Discussions, June
2007.
\6\ General Reporting Protocol, Version 1.1, The Climate
Registry, May 2008.
\7\ Jointly convened by the World Business Council for
Sustainable Development (WBCSD) and the World Resources Institute
(WRI), Allocation of Emissions from a Combined Heat and Power Plant,
September 2006.
\8\ Jointly convened by the World Business Council for
Sustainable Development (WBCSD) and the World Resources Institute
(WRI), Allocation of emissions from a Combined Heat and Power Plant,
September 2006.
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The Western Climate Initiative received various recommendations on
the treatment of combined heat and power in its initial draft design
guidance for recording greenhouse gas (``GHG'') emissions since it has
implications in both the industrial and electricity sectors. The
[[Page 55837]]
recommendations varied based on the type of CHP configuration. WCI in
its final 2008 recommendation \9\ did not advance one allocation method
over another, stating ``adequate quantification methods will be
established for emissions sources prior to including them in the
program''. The British Standards Institute (BSI)'s Publicly Available
Specification (PAS) 2050 \10\ recommends using an approach based on the
unit of useful energy delivered. The specification recommends ``the
allocation shall be carried out in proportion to the amount of useful
energy delivered in each form, multiplied by the intensity of GHG
emissions associated with each unit of useful energy delivered as heat
and electricity.'' This methodology acknowledges that each CHP system
may have a different ratio of outputs of thermal and electrical energy.
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\9\ The WCI Partner jurisdictions recognize the importance of
combined heat and power (cogeneration) in the program scope and are
continuing to evaluate its implications for the program design.
Western Climate Initiative, Design Recommendations for the WCI
Regional Cap-and-Trade Program. September 23, 2008, Corrected March
13, 2009.
\10\ British Standards Institute (BSI), PAS 2050: 2011,
Specification for the assessment of the life cycle greenhouse gas
emissions of goods and services, Section 8.5, Emissions from energy
production using CHP.
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Application of the Work Potential Allocation Methodology to the Dakota
Plant
Under the RFS2 program, EPA is considering use of the work
potential method for the configuration outlined in the Dakota petition
because the primary purpose of the steam generated at Spiritwood power
plant before extraction is to produce power. This method allocates the
emissions to extracted steam based on the amount of power displaced
(i.e., the electricity not generated).
A Memorandum to the Docket explains in more detail how the work
potential methodology would be applied to the plant configuration
proposed for the Dakota plant, resulting in a specific GHG emission
factor per mmbtu of steam energy. This emissions factor would be used
in analyzing the total GHG emissions per mmbtu of ethanol produced by
the Dakota facility, as part of determining whether the ethanol
produced by the facility would qualify under the lifecycle GHG
thresholds established in the RFS program. For the configuration
outlined in the Dakota petition, EPA's analysis finds that the process
steam has an emission factor of 53,175 grams CO2-eq/mmbtu steam.
EPA invites comments on the proposed application of the work
potential methodology to determine emissions associated with imported
steam to the Dakota plant in the context of lifecycle emissions
accounting. Furthermore, EPA invites comment on applying the work
potential approach to other plants with similar CHP configurations
under the RFS program. EPA also requests information on the
appropriateness of applying alternative allocation approaches outlined
in this notice to the Dakota plant, as well as any other approaches
that could also be used to allocate emissions to steam for this
specific CHP configuration under the RFS program.
Dated: August 31, 2012.
Margo Tsirigotis Oge,
Director, Office of Transportation and Air Quality, Office of Air and
Radiation.
[FR Doc. 2012-22347 Filed 9-10-12; 8:45 am]
BILLING CODE 6560-50-P