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Getting Started with CHP - Screening and Permitting

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Kind: captions
Language: en

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>> Lissa: Hello and welcome to the getting started
with CHP webinar. I'm Lissa McCracken with
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KPPC and will be serving as the facilitator.
KPPC is a non-profit technical assistance
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resource center based at the University of
Louisville J. B. Speed School of Engineering.
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Today's webinar is designed to help answer
questions about getting started with CHP and
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focuses on two specific areas, the screening
process used to determine if your facility
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is a good candidate for CHP and steps to determine
any air permitting requirements.
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Today's webinar is being sponsored by the
Kentucky CHP partnership, which in addition
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to KPPC is comprised of the Kentucky Department
for Energy Development and Independence, the
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Kentucky Association of Manufacturers and
the U.S. Department of Energy Southeast CHP
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Technical Assistance Partnership. This Kentucky
partnership is designed to promote CHP technologies
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throughout the Commonwealth.
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Now let's get started with the first presentation
for Cheryl Eakle. Cheryl is a sustainability
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engineer at KPPC and will be discussing the
CHP screening process.
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>> Cheryl: Thank you Lissa. As Lissa said,
I am an engineer here at KPPC and this webinar
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is actually a follow up to a couple of workshops
that we had in November when we talked about
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CHP and possibilities and how to get started.
We really briefly talked about screening at
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that workshop, but some people wanted to see
a little more detail, so we're going to go
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into a little more detail into the screening
here in just a few minutes.
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One of the things we probably need to do
is, for people who weren't at the workshop,
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just give you a real brief overview of
what CHP is. One of the key things is that
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CHP is energy that's created and
used near the user. It's made
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where it's going to be used. It generates
electrical and mechanical power, usually electrical
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power. It recovers waste heat for heating. It
can be used for cooling for an absorption
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cooler or for dehumidification. It can use
a variety of technologies and fuels. For instance,
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CHP can use reciprocating internal combustion
engines, steam turbines or combustion turbines
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as some of the technologies, and the fuels
could be anything from natural gas, landfill
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or other biogas, or even if it's a boiler,
it could be anything ... It could even be
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solid fuels like wood or coal.
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This is a typical conventional CHP. This is
what's called a topping cycle where you have
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your fuel come in to your engine or your
turbine that's turning the generator and the
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heat is going to a building or facility. In
this case, the heat is more
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of a byproduct. You recover that
and use it elsewhere in the facility.
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The next is what they call a bottoming cycle
where you're producing heat, that is, you're
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main purpose is producing heat. Now this shows
the heat going through a steam boiler, however,
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sometimes you can have the steam boiler
is direct fired.
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You're using the steam in your process,
but then at the same time you're also turning
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the turbine for electricity. You get a little
bit of both there.
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This is how we see the CHP projects developing.
We start out with a very high level screening
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process, and that's what we are going to be
going through here in just a few minutes.
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After that, we'll go into a feasibility analysis
which is a screening process but there is
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a lot more depth to that. We would probably
do a site visit and probably get a little
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more detail into the costing.
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The next thing will be an investment grade
analysis, and at this point, you might want
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to call a consultant. If you have engineering
resources and execute projects on your own,
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you might just want to have an individual
come in and be part of your team. If you don't
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have a lot of engineering resources, there
are companies that will do a turnkey installation.
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DEDI is developing a vendor list and that
should be on their site shortly posted. If
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you would like to see a list ahead of time,
you can contact one of us and we'll give you
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a draft. The last step obviously would be
procurement and starting and commissioning.
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This is the screening tool. Those of you that
have been at the workshop have seen this screen
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before. We're going to go into that a little
bit deeper. There are some things that we're
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going to start out with as far as information
to get started with the screening.
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Just to do this first high level screening,
we just have to have some basic information.
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One of the things we need to know is the base
load in kilowatts if known. If not known,
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we are going to take the annual electric use
of kilowatt hours and divide it by the annual
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hours of operation. That's going to get us
into the ballpark. The other thing we're going
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to use is the effective cost of electricity.
We're going to take your annual electric cost,
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divide it be your annual kilowatt hours. That
way it accounts for not only your kilowatt
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hour usage but also your demand use and all
the other miscellaneous charges like your
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fuel cost adjustment and maybe taxes and customer
charges that get put into the utility bill.
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Another thing that might be of interest to
people that might not want to do their whole
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facility. They might want to do just a part
of their facility. For instance, if you had
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a chemical plant and you are running a distillation
column or a spray dryer constantly, those
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are very good candidates for CHP power. Batch
reactors?
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Not so much so.
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If you've got a large facility and maybe just
part of the facility is running batch type
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processes and another type is running continuous,
you might want to split that up and say, okay,
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this is the part that we're going to consider
for CHP, and we can look at that possibility
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too.
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The next consideration will be thermal and
you need year round thermal demand to make
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CHP a good fit. If you're a large commercial
building and you're using heat in the winter
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time and you can use an absorption chiller
to provide your air conditioning, that's a
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good application. In an industrial setting,
if your main heat load is just building heat,
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that's probably not a good fit. You need to
route that year round thermal demand. Just
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like on the electric, we're going to use the
base load if known. If not, we're going to
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do the same thing. We're going to take the
annual thermal load in million BTUs, divide
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it by the annual hours of operation.
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Let's get started looking at our example here.
Okay. This company that contacted us, they
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are making automotive components, small parts
for automotive components, and they called
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to see if they would be a good fit for CHP.
They are making small automotive parts and
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they are operating 24X7. They used 8400 annual
hours of operation as their baseline. They
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knew that their average demand was 6 megawatts
or their base demand. What we could have done
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if they hadn't had that, we could have done
the same thing where we talked about before.
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We would take their kilowatt hours and divide
by the operating hours and then divide by
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1000 to get for the kilowatts to megawatts.
You can see we get like ...You have to divide
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by 1000. You get about 6.7 megawatts.
That's a good approximation, that's a good
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approximation, even if you don't have your
base demand. They didn't know their average
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steam demand and that's their annual demand.
The current fuel costs were $5.79 per MMBTU.
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They have two or three gas-fired boilers and
they were using natural gas for that, so their
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CHP would be the same cost. Their effective
electric cost is 7.7 cents per kilowatt hour,
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and that is, like I said, the total cost for
their electric divided by their annual kilowatt
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hour use.
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Consider electric price avoided, this is typically
not 100%, and that's not your total electric
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price. That takes into account things that
are going to be on your bill whether you reduce
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your use or not. You usually have a customer
charge or basic service charge. You might
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have a facilities use fee. Anything that is
not tied to how much or how fast you use electricity
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is not going to change because you reduce
your use.
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For that reason, you want to see how much
that is of your electric bill
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and then take that factor into account
when you're talking about how much you're
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going to be saving.
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These people had existing boilers, so we're
going to be looking at this for a steam turbine
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only. I'm going to say that it's very reliable,
98%. Typically these turbines are very reliable,
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and their boiler efficiency is 80%. Now this
tool, which was given to use by the DOE has
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a lookup table in it, and what it will do
is actually looking at the demand and the
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electric demand and the steam demand. It will
match up for the thermal demand and give them
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power to heat ratio, and then it will calculate
what the CHP size should be. In this case, because
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they have a small steam load, they are only
going to be using about 200 kilowatts. This
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is going to be a small unit.
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The next couple of cells are that actually
they are more appropriate to a topping cycle,
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but the tool will also look at
the lookup table and give you the steam turbine
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cost. It's about a penny per kilowatt hour,
and that's typical for a lot of CHPs that
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operating and maintenance costs. In other
words, your fuel and maintenance costs.
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If you look down here, we can look at our
generated electricity, which is about 3% of
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their total, okay. You can see that the boiler
steam, the demand is about the same. It might
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be using just a little bit more fuel. The
next section is for standby charges, and this
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is empty at this time because the utility
that for this facility is do not have standard
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standby charges. This is something that would
have to be ... They'll have to contact the
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utility would have to be worked out with them.
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If you look here, you can see that they are
going to use just a little bit more fuel,
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natural gas. If you look at the savings from
the electric even with the additional natural
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gas and O&M charges, you're still saving about
$60,000 a year generating part of the electricity.
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You have the annual operating savings. Total
installed cost per kilowatt hour, this is
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a national average. This takes into account
equipment and installation charges across
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the country.
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Now things in Kentucky might be ... Are probably
going to be different. Certainly the labor
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charges are going to be different in Kentucky
than what they would be in Chicago. We're
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looking at a 5.3 year payback. If we can get
those charges down to say $1000 per kilowatt
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hour, now it's a 3.6 or 3.5 year payback,
so it's much better.
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Again, this screening is a very, very high
level. If you want to be able to looking into
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the possibilities of getting some better numbers
or some more definite numbers, a lot of times
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we can work this down and get it in for ... It
looks like it's a more favorable project.
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After those 3.6 years, they would be generating
... They would be paying 3.5 cents per kilowatt
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hour for every kilowatt hour that they generated,
and that's versus 7.7 for what they are buying.
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That would be probably a bigger difference
even then because electricity rates do tend
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to rise.
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That again is the cost to generate. One of
the things that we talked about ... Let me
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go back here just a minute. This box here
with standby rates, we mentioned standby rates,
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but we didn't really talk about them. The
standby rate is a rate or it's a charge that
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a utility usually charges just to have standby
power. In this case, if they wanted to say
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... They wanted a contract for 200 kilowatts
of standby power, the utility might charge
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them a fee per kilowatt. Actually it
is done a number of ways. Some utilities will
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charge a monthly fee per kilowatt. Some
utilities will just allow the increase to
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affect the ratchet. Others will have just
an administrative charge or it might be a
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combination of these.
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There is a utility in Kentucky which has a
CHP facility in their territory. They do not
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charge them a monthly fee, but they do ... The
charge does affect the ratchet. If the CHP
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goes down, then that facility starts pulling
a lot of power from the grid and they just
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set their demand for the next 11 months.
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If your utility does not have a standard charge
posted in the tariff, then you probably need
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to talk with them and see what kind of arrangements
you can work out. Obviously depending on how
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much you're going to be generating, it's going
... They are probably to handle a little bit
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differently. A small generator is probably
going to be different than someone who is
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doing 18 megawatts. There are things you can
do to minimize your standby charges. You can
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only contract for essential operations, so
instead of the full amount, if you're going
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to be generating 2 megawatts electricity,
maybe you only want a contract one or you
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want to contract for a certain part. You can
design your system to shed loads for CHP outage.
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There is a company that we work with that
the first part of their operation is continuous
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and so they power their boiler house and their
continuous operations off of CHP.
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Then they also have an assembly pack and ship
operation. When they are having trouble with
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the CHP, they close down the assembly part.
Then they switch to grid power for their CHP
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until they get the problem resolved. Then
they go back on and put the some of the people
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back on the grid.
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Another thing you can do is you can use production
shutdowns for maintenance when you have to
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maintain your CHP. Like any other piece of
equipment, it's just got to have ... It has
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some maintenance from time to time.
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This slide shows different scenarios that
happen as far as shutdown of the CHP. The
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white line is the total line of the total
use, the electric for this facility. Yellow
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is the CHP generated electricity. As you can
see for the most part, these people are making
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more electricity than they are buying. This
would be a forced outage or an unplanned outage
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and this would be a planned outage. This forced
outage ... Unplanned outage, this is something
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no one wants to see. You don't want to see
it. Utility people don't want to see that.
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If you can do your maintenance here where
the plant is shut down or plant is operating
00:16:03.630 --> 00:16:10.630
at a lesser rate, then you can get around
those standby fees. Really right there, they
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are not buying nearly as much electric as
they would use when they are running. This
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is a planned outage and some utilities will
work with you on that if you've got a planned
00:16:23.900 --> 00:16:30.900
outage coming. TVA for example has a low monthly
rate. Then they have a small rate that they
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charge for people like for user backup charges.
Here if it's the planned outage, they would
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charge $1.09 I think it is for each kilowatt
use per week. If it's an unplanned outage,
00:16:45.130 --> 00:16:50.480
they'll charge $2.78. Again, you'd have to
work with the utility, see what kind of arrangements
00:16:50.480 --> 00:16:51.380
can be made.
00:16:51.380 --> 00:16:58.380
I'll just kind of wrap up. CHP is very efficient.
You can get probably 30-40% better efficiency
00:17:00.260 --> 00:17:07.260
using CHP versus using separate generations.
KPPC can do a high level screening for you.
00:17:07.670 --> 00:17:11.839
We'd need your base loads, your effective
cost and then maybe look at the standby cost
00:17:11.839 --> 00:17:16.740
that's going to depend on your electric provider.
We can also do a more in-depth feasibility
00:17:16.740 --> 00:17:22.480
analysis. If this overall high level screening
looks good, we'd be glad to come in and look
00:17:22.480 --> 00:17:28.870
at your facility and look at a feasibility
analysis would be. There is also like no cost.
00:17:28.870 --> 00:17:32.520
Does anybody have any questions?
00:17:32.520 --> 00:17:39.400
>> Lissa: Okay, thank you Cheryl. As a reminder,
please submit any questions you have at any
00:17:39.400 --> 00:17:45.860
time during the webinar. We do have a couple
of questions already. First one is will the
00:17:45.860 --> 00:17:47.940
Spreadsheet be available on the web?
00:17:47.940 --> 00:17:54.010
>> Cheryl: No, DOE has asked us not to share
this or to publish it, but do keep in mind
00:17:54.010 --> 00:17:59.640
that if you do call us and give us that basic
information there will be no charge. We'll
00:17:59.640 --> 00:18:01.210
be glad to run the numbers for you.
00:18:01.210 --> 00:18:05.540
>> Lissa: It's also I think important to include
the fact that it's confidential.
00:18:05.540 --> 00:18:07.050
>> Cheryl: Yes, it is.
00:18:07.050 --> 00:18:11.340
>> Lissa: Would you be able to meet with my
energy team to discuss what is needed for
00:18:11.340 --> 00:18:15.310
a CHP screening and how it might help my facility?
00:18:15.310 --> 00:18:19.650
>> Cheryl: Yeah, we'd be glad to meet with
you or conduct a teleconference. If you give
00:18:19.650 --> 00:18:24.690
us a call, we can talk about that. Actually,
there are some more questions ... Another
00:18:24.690 --> 00:18:30.040
questionnaire that goes along with this. We
like to do that interactively instead of just
00:18:30.040 --> 00:18:33.870
having people put ... Give us a call. We'll
be glad to meet with you or do a teleconference,
00:18:33.870 --> 00:18:38.260
or whatever it would need to be to make sure
we get that understanding going.
00:18:38.260 --> 00:18:44.509
>> Lissa: Another question. Does LG&E have
a penalty fee for gas if you go to CHP?
00:18:44.509 --> 00:18:51.400
>> Cheryl: A penalty fee? Not that I'm aware
of. I'm not real sure what they mean by a
00:18:51.400 --> 00:18:56.790
penalty fee. You might use a little more gas
if you're doing CHP, but I don't think there
00:18:56.790 --> 00:19:03.790
is a fee for that. Now they do have standby
charges on the electric side, but there again,
00:19:05.610 --> 00:19:09.400
it's down to what your facility is going to
be and if you really need standby charges
00:19:09.400 --> 00:19:12.700
and how much standby power you need.
00:19:12.700 --> 00:19:19.700
>> Lissa: Okay. At this point, we're going
to move on to the next presentation and we'll
00:19:20.559 --> 00:19:26.610
hear from Sree Kesaraju. Sree is an engineering
consultant for the Kentucky Division for Air
00:19:26.610 --> 00:19:33.610
Quality. He'll be presenting on air quality
permitting requirements for CHP's process.
00:19:34.010 --> 00:19:41.010
>> >> Sreenivas: All right. Now it's time
to figure out how to get an air permit. Air
00:19:44.730 --> 00:19:51.610
quality permit is a document which will have
the regulatory requirements application to
00:19:51.610 --> 00:19:58.610
all the emission units at the plant or the
facility. The permit in Kentucky
is a document which actually gives you permission
00:20:08.340 --> 00:20:15.100
to construct and operate. The permit will
identify which emission units you have and
00:20:15.100 --> 00:20:20.559
it will establish the emission limit and the
operating limit you have to meet. It will
00:20:20.559 --> 00:20:27.559
outline the procedures including testing,
record keeping, monitoring and reporting requirements.
00:20:28.690 --> 00:20:35.690
We have seen in the earlier presentation how
a CHP setup looks like and how this typical
00:20:36.010 --> 00:20:41.130
setup, we will be later talking about a case
study.
00:20:41.130 --> 00:20:48.130
We'll quickly go through some abbreviations
which will be used in this presentation. First
00:20:49.150 --> 00:20:54.550
is potential to emit. Potential to emit is
the maximum amount of a pollutant that source
00:20:54.550 --> 00:21:00.510
is physically capable of emitting or legally
allowed in the permit, whichever is less.
00:21:00.510 --> 00:21:07.510
A HAP is hazardous air pollutant. A RAP is
a regulated air pollutant. A AR is a applicable
00:21:07.800 --> 00:21:14.420
requirement. MOC is a method of compliance,
which will include monitoring, record keeping
00:21:14.420 --> 00:21:21.420
and reporting requirements. NSPS is new source
performance standards. NESHAP is a national
00:21:22.350 --> 00:21:29.350
emission standard for hazardous air pollutants,
also known as MACT standards.
00:21:35.450 --> 00:21:42.450
When do you need a permit? A permit is needed
when you construct and operate the new source.
00:21:43.030 --> 00:21:49.809
When you're planning to build a source, you
need a permit before you start construction.
00:21:49.809 --> 00:21:56.809
In Kentucky and almost everywhere, typically
you have permitting for major sources and
00:21:57.600 --> 00:22:04.600
minor sources. Major sources are permitted
under Title V operating ... Permitting program
00:22:04.770 --> 00:22:11.309
and in Kentucky, you have only one permitting
program for construction and operating. A
00:22:11.309 --> 00:22:18.309
lot of states have separate programs for construction
and operating. We have major source permitting
00:22:18.370 --> 00:22:25.370
and we have what's called as synthetic minor
or conditional major, which is permits which
00:22:25.450 --> 00:22:32.050
the sources take to avoid the major source
permitting. Other types of permits required
00:22:32.050 --> 00:22:37.429
when you need a permit is when you modify
an existing source or you renew your permit
00:22:37.429 --> 00:22:42.200
after a certain period of time five years
for a major source.
00:22:42.200 --> 00:22:49.200
At what levels of emission thresholds do you
need a permit in Kentucky? If you have less
00:22:50.360 --> 00:22:57.360
than 2 tons per year of a hazardous air pollutant,
then you do not need a permit in Kentucky.
00:22:58.920 --> 00:23:04.640
If you have less than 5 tons per year of combined
hazardous air pollutants, you do not need
00:23:04.640 --> 00:23:11.640
a permit, and less than 10 tons of regulated
air pollutant. However, if you have a NSPS
00:23:11.720 --> 00:23:18.340
or NESHAP applicable, irrespective of what
your emissions are and if they are below these
00:23:18.340 --> 00:23:22.470
thresholds, you still at least need to be
registered in Kentucky.
00:23:22.470 --> 00:23:29.470
When do you need a registration in Kentucky?
If you have more than 2 tons per year, but
00:23:30.000 --> 00:23:34.990
less than 10 tons per year of a hazardous
air pollutant and if you have more than 5
00:23:34.990 --> 00:23:40.920
tons, but less than 25 tons of hazardous air
pollutants, more than 10 tons but less than
00:23:40.920 --> 00:23:47.920
25 tons per year of a regulated air pollutant
that is subject to an applicable regulation
00:23:49.030 --> 00:23:54.570
and does not have method of compliance. Of
if you have a NSPS or NESHAP applicable as
00:23:54.570 --> 00:23:59.770
we just talked about.
00:23:59.770 --> 00:24:06.510
A state origin permit is required once you
are above 25 tons of a regulated air pollutant,
00:24:06.510 --> 00:24:13.510
but less than 100 tons of regulated air pollutant,
and less than 10 and 25 of a single and 25
00:24:13.700 --> 00:24:20.700
of combined hazardous air pollutants is when
you are required to have a state origin permit.
00:24:21.760 --> 00:24:27.270
A Title V permit is required if you have more
than 10 tons per year of HAP and 25 tons per
00:24:27.270 --> 00:24:34.270
year of combined HAPs or more than 100 tons
per year of regulated air pollutant. Regulated
00:24:34.660 --> 00:24:41.260
air pollutant does not include hazardous air
pollutants. Even though hazardous air pollutants
00:24:41.260 --> 00:24:48.010
are regulated air pollutants, for quantification
for the purpose of permitting, we do not include
00:24:48.010 --> 00:24:54.710
hazardous air pollutants in the regulated
air pollutant quantification. The source potential
00:24:54.710 --> 00:25:01.710
to emit is not limited below these thresholds
by permit or prohibitory rule. If it is limited,
00:25:03.580 --> 00:25:10.580
then you basically can get a different classification
of a permit.
00:25:12.190 --> 00:25:17.600
Now we understand a little bit about Kentucky
air permitting. This is going to be a case
00:25:17.600 --> 00:25:24.600
study where we are going to quickly go through
the project description, a case study.
00:25:25.780 --> 00:25:32.780
We have a campus, XYZ campus, which is a new
campus being planned and we are going to generate
00:25:33.130 --> 00:25:40.030
10 megawatts of energy and that's a need,
that's a base load which Cheryl just talked
00:25:40.030 --> 00:25:47.030
about requirement and they need 110,000 pounds
of steam. They found a natural gas turbine
00:25:47.830 --> 00:25:54.830
which can generate 8 megawatts of power and
it can generate 35,000 pounds of steam. The
00:25:56.490 --> 00:26:03.360
manufacturer has rated 80 million BTUs per
hour as the fuel input needed for the turbine.
00:26:03.360 --> 00:26:10.360
They decided to use this system, but they
have a 2 megawatt deficiency which they are
00:26:10.380 --> 00:26:17.380
going to get it from a grid. They decided
to use a duct burner, 40 million BTUs per
00:26:18.480 --> 00:26:24.140
hour natural gas backfiring before the HRSG,
which is called heat recovery steam generator
00:26:24.140 --> 00:26:31.140
which generates steam, and that will give
them additional 75,000 pounds of steam to
00:26:32.730 --> 00:26:38.900
cover their 110,000 pounds of steam.
00:26:38.900 --> 00:26:45.120
Air quality permit, so basically what are
those different things you need for getting
00:26:45.120 --> 00:26:49.940
an air quality permit in Kentucky Division
for Air Quality. The source needs the following
00:26:49.940 --> 00:26:56.940
data to submit an application to KDAQ. An
engineering design of affected units with
00:27:00.620 --> 00:27:07.620
information such as maximum design rate that
is used to calculate the air emissions and
00:27:08.000 --> 00:27:14.210
emission estimate for all regulated air pollutants
from each of the affected units within the
00:27:14.210 --> 00:27:20.200
source. Using the emission estimates, figure
out what kind of permit is needed and then
00:27:20.200 --> 00:27:24.710
what application forms and other documents
need to be submitted.
00:27:24.710 --> 00:27:31.710
First, maximum design rate. How do you calculate
the maximum design rate? In the presentation
00:27:36.660 --> 00:27:43.660
we just heard, we just talked about design
rate. You calculate the design rate with what
00:27:45.330 --> 00:27:50.630
is the base load requirements. and ...
00:27:50.630 --> 00:27:57.070
In this case study, we have a turbine and
a duct burner, which are the main pollutant
00:27:57.070 --> 00:28:04.070
generating units. In our case study, you need
80 million BTUs per hour of fuel for the turbine
00:28:05.919 --> 00:28:12.919
and the duct burner is going to be 40 million
BTUs per hour. This is a typical turbine setup,
00:28:14.870 --> 00:28:21.290
and you can see that there is an air intake
and then there is a turbine and the electric
00:28:21.290 --> 00:28:28.290
generator. How do you calculate the emissions?
Emissions have to be calculated for all the
00:28:30.960 --> 00:28:37.960
regulated air pollutants at an affected unit
within the source. An affected unit is a unit
00:28:39.549 --> 00:28:46.549
which generates pollution and the source is
a group of affected units. Emission estimate
00:28:47.549 --> 00:28:53.900
should be potential emissions for all these
emission units. Potential to emit means the
00:28:53.900 --> 00:28:59.220
maximum capacity of a stationary source to
emit air pollution under its physical and
00:28:59.220 --> 00:29:06.220
operational design. Potential to emit is calculated
when you multiply maximum hourly design rate
00:29:08.200 --> 00:29:15.200
times the emission factor times 8760 hours
per year which is 100% of the time available.
00:29:16.690 --> 00:29:23.690
For our case study, we have manufacturers'
data which provided the emission factors.
00:29:25.919 --> 00:29:32.919
We typically get emission factors which are
compiled by EPA on their website at epa.gov/ttn/chief/ap42
00:29:35.960 --> 00:29:42.960
and the division accepts those emission factors
as well. We are going to actually in a lot
00:29:52.710 --> 00:29:57.990
of cases, we get voluntarily limits taken
by the company to avoid major source requirement
00:29:57.990 --> 00:30:04.990
and to be a minor source, and that will fit
some people's permitting needs. For our case
00:30:05.880 --> 00:30:12.880
study, we will estimate emissions for two
different turbine configurations and based
00:30:13.340 --> 00:30:20.340
on two different emission guarantees. We are
going to estimate emissions for NOx, CO and
00:30:22.200 --> 00:30:27.929
VOC. There is also other emissions including
hazardous air pollutant emissions, VOC which
00:30:27.929 --> 00:30:33.370
is volatile organic compounds and greenhouse
gases. In our case example, we took these
00:30:33.370 --> 00:30:40.370
three pollutants and calculated emission potentials
and figured out permitting needs.
00:30:41.059 --> 00:30:48.059
Estimating emissions. For turbine 1, the emission
guarantees or the emission data given by the
00:30:50.030 --> 00:30:57.030
company which manufactures these turbines
is 0.06 pounds per million BTU for the turbine
00:30:58.830 --> 00:31:05.830
for NOx emissions, turbine 1 and 0.061 for
CO and .035 for VOC. For the turbine 2, you
00:31:10.669 --> 00:31:17.669
can see that the emissions potential or the
emission factors given is 0.1 pounds per million
00:31:17.669 --> 00:31:24.669
BTU, which is pretty close to double the amount
of NOx emissions, more close to 1.7 times
00:31:26.870 --> 00:31:33.870
the emissions. We figured that it will be
a little more cost effective if we use more
00:31:34.350 --> 00:31:41.350
pollutant but it's again case by case and
depends on what your situation is and what
00:31:42.120 --> 00:31:47.940
your permit you require and everything. The
area you're going to build these unit or the
00:31:47.940 --> 00:31:53.630
area you're going to do this. If area already
has bad air quality, you may be forced to
00:31:53.630 --> 00:31:58.850
get a cleaner engine.
00:31:58.850 --> 00:32:05.850
In our case we have duct burners and the emission
factors are here given .065 pounds per million
00:32:06.809 --> 00:32:13.809
BTU for NOx and .04 pounds per million BTU
for CO and .05 pounds per million BTU for
00:32:16.789 --> 00:32:23.160
VOC. After using all these emission factors
given, we figured what are the emissions using
00:32:23.160 --> 00:32:30.160
the equation we just saw above in the above
couple of slides above. The emission potentials
00:32:30.850 --> 00:32:37.850
for NOx from turbine 1 is 21 tons and the
emission potential from turbine 2 for NOx
00:32:39.400 --> 00:32:46.400
is 35 tons. The duct burner is the same in
both cases. The total potential for NOx is
00:32:47.429 --> 00:32:54.429
46 tons in the turbine 2 and 32 tons in the
turbine 1. If you look at the numbers, the
00:32:57.150 --> 00:33:04.150
biggest difference in the emissions are CO
and NOx for the turbine 1 and turbine 2. The
00:33:05.020 --> 00:33:09.080
emissions then calculated are going to be
compared to the thresholds we looked in the
00:33:09.080 --> 00:33:16.080
tables above. Based on that information, we
have seen that if you have above 25 tons of
00:33:17.620 --> 00:33:24.240
a regulated air pollutant, but if you have
less than 100 tons per year, then you require
00:33:24.240 --> 00:33:27.039
state origin permit.
00:33:27.039 --> 00:33:30.840
Now what is the difference between require
state origin permit and a Title V permit?
00:33:30.840 --> 00:33:37.840
It's basically the emission fee and monitoring
and record keeping requirements and things
00:33:38.590 --> 00:33:44.270
like that. You may still need to pay emission
fee for a state origin permit if you have
00:33:44.270 --> 00:33:50.929
NSPS or NESHAP applicable.
00:33:50.929 --> 00:33:56.549
What kind of application forms do you need
and what are the other documents you need?
00:33:56.549 --> 00:34:02.299
Any construction activity emitting air pollution
needs a prior authorization in the state of
00:34:02.299 --> 00:34:09.299
Kentucky. What kind of permit is needed is
what we have seen and the application forms
00:34:12.190 --> 00:34:18.750
you need to submit will depend on what kind
of permit you're going to require. In this
00:34:18.750 --> 00:34:25.480
case, you are requiring state origin permit.
It will pretty much require all the forms
00:34:25.480 --> 00:34:28.869
which are on our website at www.air.ky.gov.
00:34:28.869 --> 00:34:35.869
The permitting forms listed are in a series
from DEP7007A form to DEP7007Y form. All these
00:34:47.040 --> 00:34:54.040
are permit-related forms and DEP7007A Form
is an administrative form. DEP7039A form is
00:34:57.540 --> 00:35:04.540
a registration application form. DEP7007 AI
form is an administrative form and the A form
00:35:09.500 --> 00:35:16.349
actually is I think I could have said administrative,
but it is not. It is a form for including
00:35:16.349 --> 00:35:21.650
information for indirect heat exchangers and
internal combustion engines. The AI form is
00:35:21.650 --> 00:35:27.840
an administrative information form where you
put various sources located and what kind
00:35:27.840 --> 00:35:34.840
of permit you require. It also will include
the signature of a responsible official.
00:35:36.570 --> 00:35:43.570
For this project, DEP7007A form is one of
the key forms to fill. All the forms are listed
00:35:47.599 --> 00:35:54.599
on our website, and if you go to www.air.ky.gov,
you have all the forms on our website under
00:35:57.099 --> 00:36:04.099
the Permitting tab. They are in the Word format
and they have instructions when required and
00:36:05.070 --> 00:36:10.500
they are mostly fillable documents.
00:36:10.500 --> 00:36:17.500
DEP7007A form lists what type of unit you
have, combustion unit you have and what's
00:36:22.430 --> 00:36:29.430
the date install or estimated ... The install
date and also what kind of unit you have.
00:36:29.430 --> 00:36:36.240
If you have a turbine or do you have a reciprocating
engine or do you have an indirect heat exchanger,
00:36:36.240 --> 00:36:43.240
and it will list the fuel input requirements
and the power output requirements. In our
00:36:43.340 --> 00:36:50.340
example, we have a combustion turbine and
we have actually duct burner particulates,
00:36:52.570 --> 00:36:59.140
only the combustion turbines input here. Natural
gas we have 80 million BTUs per hour, high
00:36:59.140 --> 00:37:06.140
heating value at 59 degrees Fahrenheit. That's
basically the manufacturer's design or manufacturer's
00:37:06.960 --> 00:37:13.960
data provided. It is based on these conditions,
the 59 degrees.
00:37:16.170 --> 00:37:21.670
The other important application forms, part
of Kentucky Division for Air Quality are DEP7007B
00:37:21.670 --> 00:37:28.670
form which will list all the applicable requirements.
What regulation is applicable and what standard
00:37:32.760 --> 00:37:39.760
applies and what is the method of determining
compliance. Also it will list all the monitoring
00:37:40.030 --> 00:37:46.260
requirements, record keeping requirements,
reporting and testing requirements.
00:37:46.260 --> 00:37:53.260
This example here is not related to our case
study, but an example sheet where we list
00:37:55.760 --> 00:38:00.910
standards and compliance requirements for
a turbine.
00:38:00.910 --> 00:38:07.910
DEP7007N form is used to submit emissions
and stack related information. The pollutants
00:38:12.300 --> 00:38:18.109
are listed and the respective emission factors
and the basis for the emission factors, which
00:38:18.109 --> 00:38:24.650
could be vendor or manufacturer data and it
could be also an engineering estimate or an
00:38:24.650 --> 00:38:31.650
AP-42 data. We calculate what is the maximum
hourly emissions which are emitted and what
00:38:32.599 --> 00:38:38.760
is the annual emissions which are emitted
from all the affected facilities and also
00:38:38.760 --> 00:38:45.760
the total for the source. All this data is
used to calculate your permit needs and then
00:38:48.700 --> 00:38:54.730
submitted to State of Kentucky for their approval.
Any questions?
00:38:54.730 --> 00:39:01.640
>> Lissa: Okay, thanks Sree. Yes, we do have
a few questions here and please go ahead and
00:39:01.640 --> 00:39:07.880
submit any questions that might have at this
time as we start to wrap down the webinar.
00:39:07.880 --> 00:39:14.880
Our first question for Sree, does Kentucky
follow NSPS guidelines or are Kentucky standards
00:39:15.650 --> 00:39:16.740
more stringent?
00:39:16.740 --> 00:39:23.740
>> Sreenivas: Kentucky does follow NSPS standards.
We incorporate the NSPS requirements in our
00:39:24.280 --> 00:39:31.280
program and we implement NSPS requirements.
We also have state implementation plan and
00:39:33.690 --> 00:39:40.400
we have our own state regulations which could
be applicable. NSPS requirements do apply,
00:39:40.400 --> 00:39:47.349
and if they apply, we cannot be more stringent
or less stringent than the federal regulations.
00:39:47.349 --> 00:39:54.349
It will be incorporated by reference and they
will be implemented as they are in the federal
00:39:56.090 --> 00:39:57.090
regulations.
00:39:57.090 --> 00:40:03.710
>> Lissa: How long will the permit process
be for a simple 400 kilowatt CHP?
00:40:03.710 --> 00:40:10.710
>> Sreenivas: Assuming it's the right engine
for 400 kilowatts or it could be a micro turbine,
00:40:14.210 --> 00:40:20.510
as we have seen in our example which is a
8 megawatt unit and it's a state origin permit
00:40:20.510 --> 00:40:27.510
and it will be 120 days for that, for a 400
kilowatt, I am thinking that it will be a
00:40:27.770 --> 00:40:34.680
registered source permit and at the most 60
days is my assumption. You can get more information
00:40:34.680 --> 00:40:36.660
on www.air.ky.gov.
00:40:36.660 --> 00:40:43.660
>> Lissa: Is there someone at Air Quality
to call to answer questions about the permit
00:40:44.810 --> 00:40:45.280
process?
00:40:45.280 --> 00:40:52.280
Sreenivas: Yes. You can call at 502-564-3999
and ask for permitting, and there are several
00:40:56.190 --> 00:41:03.190
groups in the permit review branch which are
there to help the industry. In this case,
00:41:05.349 --> 00:41:12.349
the group which will help is combustion source
section, and they have expertise and specialty
00:41:14.430 --> 00:41:19.540
and they can help you through any questions
you may have.
00:41:19.540 --> 00:41:25.329
>> Lissa: What are the fees to register and
to obtain a permit?
00:41:25.329 --> 00:41:31.480
>> Sreenivas: In Kentucky, there is no application
fee for a permit.
00:41:31.480 --> 00:41:38.480
>> Lissa: What type of CHP emission limits
are typically regulated? NOx, CO, SO2, VOC,
00:41:39.630 --> 00:41:40.250
others?
00:41:40.250 --> 00:41:45.660
>> Sreenivas: Greenhouse gases and hazardous
air pollutants are also regulated.
00:41:45.660 --> 00:41:50.730
>> Lissa: What testing and record keeping
requirements are there?
00:41:50.730 --> 00:41:54.440
>> Sreenivas: Generally the testing requirements
will depend on what kind of standards you
00:41:54.440 --> 00:42:01.290
have, and in the case of turbines, it depends
on how big they are and what the applicability
00:42:01.290 --> 00:42:08.290
is, but turbines generally the standards which
apply are NOx requirements and CO requirements
00:42:09.510 --> 00:42:16.510
and VOC requirements. Generally, for them
you have testing requirements which apply
00:42:16.740 --> 00:42:23.339
and the record keeping requirement and you
will have to keep records of fuel used, and
00:42:23.339 --> 00:42:30.339
then you have to use the emissions data generated
by testing to calculate the emissions for
00:42:31.530 --> 00:42:37.369
an hour or for a different period of time
to show compliance with the standard. General
00:42:37.369 --> 00:42:43.349
record keeping includes fuel, monitoring and
calculating emissions.
00:42:43.349 --> 00:42:50.349
>> Lissa: Can a system be pre-approved so
that using an identical system would not require
00:42:50.380 --> 00:42:55.320
the 60 day waiting period for a permit?
00:42:55.320 --> 00:43:02.320
>> Sreenivas: We do not have a pre-approval
system, but in case a source has already permitted
00:43:03.930 --> 00:43:10.930
unit and come up with an identical unit, makes
the permitting process easy because we have
00:43:11.160 --> 00:43:16.920
already gone through the similar permitting,
so we would have all the data. Our approval
00:43:16.920 --> 00:43:21.550
process, the technical review process is going
to be cut down and even the permitting time
00:43:21.550 --> 00:43:25.680
is going to be cut down as have already have
documentation and the review process already
00:43:25.680 --> 00:43:30.150
done. That will cut down the time and we can
accomplish it much faster.
00:43:30.150 --> 00:43:37.150
>> Lissa: We have a couple of comments here.
One is adding that the CEMS operations and
00:43:37.550 --> 00:43:41.160
maintenance law is required. I guess that
falls back to the record keeping?
00:43:41.160 --> 00:43:47.740
>> Sreenivas: Right. It is required in case
NSPS or NESHAP are applicable and CO and NOx
00:43:47.740 --> 00:43:49.829
may require CEMS.
00:43:49.829 --> 00:43:56.829
>> Lissa: Another comment that the EPA BACT/LAER
is a great source for emission data for even
00:43:57.730 --> 00:44:02.050
small turbines of less than 10 megawatts and
IC engines.
00:44:02.050 --> 00:44:08.030
>> Sreenivas: There could be some information
on less than 10 megawatts in case if that
00:44:08.030 --> 00:44:15.030
is part of a major source because LAER and
BACT is only applicable to major source permitting,
00:44:15.849 --> 00:44:20.660
construction permitting. Smaller engines,
if they are by themselves, would not trigger
00:44:20.660 --> 00:44:27.210
those requirements. If that is part of a major
source, then definitely, you may be able to
00:44:27.210 --> 00:44:34.010
find some information. You can definitely
give us a call at Division for Air Quality
00:44:34.010 --> 00:44:36.710
if you have any questions.
00:44:36.710 --> 00:44:43.710
>> Lissa: Cheryl, we have another question
for you. The screening process and the feasibility
00:44:45.359 --> 00:44:52.359
analysis are no costs, are there any other
costs associated with KPPC's help for this
00:44:53.089 --> 00:44:54.290
CHP project?
00:44:54.290 --> 00:45:00.670
>> Cheryl: No. KPPC's services are confidential
and free. There would be no cost. Now when
00:45:00.670 --> 00:45:07.650
you get into doing the investment quality
estimate and that's probably when you probably
00:45:07.650 --> 00:45:11.880
need to talk with a consultant or someone
like that. Of course they would probably charge
00:45:11.880 --> 00:45:13.470
you.
00:45:13.470 --> 00:45:20.470
>> Lissa: Let's see. Another comment here.
Texas TCEQ, Commission for Environmental Quality,
00:45:24.030 --> 00:45:31.030
also has a very good database for a small
turbine and IC engines.
00:45:32.460 --> 00:45:34.089
>> Sreenivas: That is correct.
00:45:34.089 --> 00:45:35.809
>> Lissa: The Texas TCEQ.
00:45:35.809 --> 00:45:38.339
00:45:38.339 --> 00:45:43.380
>> Lissa: We have another question about will
the presentation be available? Yes, along
00:45:43.380 --> 00:45:50.380
with the recorded webinar, a PDF of the presentation
slides will also be made available on KPPC's
00:45:51.609 --> 00:45:58.609
website. Also the slide in front of you here
has a list of some of the resources and the
00:45:59.359 --> 00:46:05.680
website contact for those resources. Many
of these you have heard mentioned today. One
00:46:05.680 --> 00:46:12.520
good resource for everything CHP happening
in Kentucky in DEDI's website. They have information
00:46:12.520 --> 00:46:19.520
related to a CHP workgroup that has been pulled
together and there is meeting notes and information
00:46:21.119 --> 00:46:27.470
about different subcommittee meetings that
have been developed. Also, there is case study
00:46:27.470 --> 00:46:31.700
information and other resource information
available on that website. You will be able
00:46:31.700 --> 00:46:38.700
to get a link to the CHP webinar and the presentation
slides from that website as well.
00:46:39.570 --> 00:46:46.570
Okay, we have no further questions. Let's
move ahead to the next slide, and these are
00:46:46.880 --> 00:46:52.150
just a couple of other additional websites
that are referenced for energy efficiency
00:46:52.150 --> 00:46:52.750
information.
00:46:52.750 --> 00:46:59.750
Lastly, to wrap up, without any other questions,
we do want to thank you for attending today's
00:47:02.980 --> 00:47:08.589
webinar. We hope that this information has
helped, a little more specific information
00:47:08.589 --> 00:47:15.080
regarding the permitting and the screening
process. Once again, if you still have questions,
00:47:15.080 --> 00:47:21.890
please do not hesitate to contact KPPC or
the Division for Air Quality. As mentioned
00:47:21.890 --> 00:47:28.440
earlier, we will have the webinar recording
on KPPC's website. Also want to make a point
00:47:28.440 --> 00:47:34.300
to note that the CHP partnership is hosting
a site visit and demonstration at a Kentucky
00:47:34.300 --> 00:47:39.619
CHP facility in March. More details on that
will be coming soon. Lastly, please take the
00:47:39.619 --> 00:47:45.329
time to complete the webinar survey, which
will appear at the conclusion of the webinar.
00:47:45.329 --> 00:47:50.210
We'd appreciate your feedback on additional
CHP training topics that you'd find helpful.
00:47:50.210 --> 00:47:53.630
Thank you once again and have a good day.

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