Climate Scientists in the CDT
New editorial in the Centre Daily Times by Richard Alley and Michael Mann: Solid science benefits our overall knowledge. Still right on the climate science, still wrong on the energy economics. (Details on the relationship between fossil fuel supply, demand, capex, prices and economic growth v. contraction. “…What we are seeing now is a cutback in what companies consider “economically extractable oil…”)
Matt Dahlhausen on Emissions Impact of West Campus Steam Plant Retrofit & Next Activist Steps
[This is a rebuttal to the January 19 post that presented preliminary rough calculations of maximum potential additional emissions for the WCSP project. Some of the information was originally exchanged in a mid-December email thread, although that occurred before the DEP issued the permit on Jan. 13]
After the gas pipeline was re-routed, focus turned to the permits for the WCSP coal-to-gas retrofit. Most significant among these are the air quality permits. The impetus for the retrofit is to meet Maximum Achievable Control Technology (MACT) regulations, which sets emissions limits of hazardous air pollutants (HAP) per unit of energy from a fuel. Another regulation that can come into play is New Source Review (NSR). Several other posts have talked about PSU’s options for MACT compliance, and the positioning of the retrofit to avoid NSR, rather than to choose a more optimal solution for air quality, cost, and greenhouse gas emission mitigation.
Several community members have stated concern of criteria pollutant emissions and CO2 going up as a result of the project. However, because of the significant reduction in emission intensity of greenhouse gas emissions and criteria pollutants from switching from coal to natural gas, it is very unlikely that air quality or emissions will increase.
Greenhouse Gas Analysis
The primary one is CO2. The boilers are permitted at a maximum fuel rate for a set number of hours per year. However, the boilers are not going to run for this long, and at such a maximum rate. An example calculation from the maximum permitted emissions in the January 19 post:
Maximum permitted gas volume per hour times fuel energy content times plant efficiency = energy used per hour.
- Unit of fuel volume = standard cubic foot (scf).
- Unit of fuel energy content = British thermal unit (btu)
- Unit of fuel flow rate = pounds per hour (pph)
Four boilers at WSCP
- 2 times (198,000 scf/hr)
- 2 times (49,000 scf/hr)
One boiler at ESCP
- 1 times 27,450 scf/hr
- 0.62145 * 10^6 scf per hr
Converted to btu per hour (conversion factor of 1,027 btu/scf) and multiplied by plant efficiency factor of 0.8:
- 511 * 10^6 btu per hour
Compare this to the system peak steam in an hour this winter on a – 9 degree F night (as reported by Steam Services Superintendent Paul Moser):
- 412,000 pph times 1,290 btu per pound
- 531.48 * 10^6 btu/hr
So the system peak (531.48) matches the peak output of some, but not all boilers for one hour (511).
The permit allows much higher emissions than what each boiler actually emits. This allows Penn State energy system operators to run any one boiler for the permit amount (between 2,000-6,500 hours per year), which gives them flexibility if one goes down for prolonged maintenance.
Also, these emissions calculations don’t count the emissions reductions from onsite combustion that offsets electric purchases from the coal-heavy grid.
Greenhouse Gas Conclusion:
Onsite (and likely global) GHG emissions will go down with the WCSP gas plant retrofit. They could have reduced global emissions a lot more through onsite Combined Heat and Power, but they are not pursuing that at WSCP at this time to avoid New Source Review.
It’s unfortunate that such a small aspect of the project is typically the only legitimate area for legal disagreement on the project.
Ideally, local people would have the authority to approve or modify major local projects to achieve local goals for things like energy efficiency, downtown space allocation, student safety, etc.
But that’s not the case: state preemption has long since done away with meaningful local democracy. (More info.)
Even within the narrow frame of air quality regulation, however, the West Campus Steam Plant retrofit will cause emissions for all pollutants to go down significantly (substantially decreasing mercury, SOx, and particulates), at both a regional and local level.
The possible exceptions are maybe CO or NOx local to the plant if the plant is used to do substantial power production. To exceed those threshholds, plant operators would have to burn 2-2.5 times the amount of energy they currently produce to match emissions that they have now for these pollutants using coal.
To put that in perspective, in Fiscal Year 2010-2011, Penn State purchased and used
- 1.85 * 10^6 MMBtu in coal
- 0.31 * 10^6 MMbtu in gas
- 0.95 * 10^6 MMbtu in grid-produced electricity
As a very rough first-order approximation, if all the purchased electricity had come from a Combustion Turbine/Heat Recovery Steam Generation combination, with 33% electric-conversion efficiency, Penn State could have burned
- 3.1 * 10^6 MMBtu of fossil fuels
and met all campus energy needs.
In other words:
(0.95/0.33) plus the difference needed to have (1.85 +0.31) leftover for steam heating.
Example Air Quality Comparison: Nitrogen Oxides
- 1.85 * 10^6 MMBtu * (0.42 lb NOx/MMbtu for coal)
- 0.31 * 10^6 MMBtu * (0.18 lb NOx/MMbtu for gas)
- 0.83*10^6 pounds of NOx emitted
In contrast, if Penn State produced everything from gas, including electricity:
- 3.1 * 10^6 MMBtu * (0.18 lb NOx/MMbtu for gas)
- 0.55 * 10^6 lb NOx
Looking at other hazardous air pollutants, coal produces 2,500 times more sulfur oxides than gas, 333 times more particulate matter, and 2.5 times more carbon monoxide than natural gas.  It makes sense to argue for low-NOx burners as part of the WSCP retrofit, which could cut NOx emissions to 1/3. Also, there may be a lone volatile organic compound species that happens to be present in much higher concentrations in gas.
It’s possible – but unlikely – that Penn State could increase these pollutant emissions over current levels if they generate a substantial portion of their electricity, especially when steam isn’t needed, sell it to the grid, continue load growth, and stop energy conservation efforts.
But overall, the air quality case against the WCSP retrofit is really weak and would have to focus on impacts hyper-local to the plant, which would be comically nitpicky given the major automotive emissions, especially from diesel-burning coal trucks, that drive by the plant every day. For those worried about air quality, a much more pressing concern is residential indoor air quality, especially in the older housing / rental units in State College. See  J. M. Logue, T. E. McKone, M. H. Sherman, B. C. Singer. “Hazard assessment of chemical air contaminants measured in residences.” Indoor Air 2011. 21:92-109.
Air Quality Conclusion:
The retrofit will reduce HAP emissions significantly. Coal truck traffic will be gone too. So there isn’t a strong air quality case against the WSCP, as far as DEP is concerned. The only feasible air quality impact would be a NSR trigger from NOx emissions on the maximum rated firing rates for the boilers if WCSP had substantial power production, which is why OPP/PSU choose to delay the Combined Heat & Power project.
The Penn State and community activist priority needs to be energy efficiency and advocacy of no-growth and de-growth policies, rather than trying to decide between moving the generation resource to a location other than downtown State College, or making the downtown plant the best it can be, which should come after cutting energy consumption. I think a combined cycle plant there could be an extremely useful asset in transition, so I do think making the plant the best it can be is a viable approach.
Maybe Penn State would ultimately benefit from moving the WCSP. But if air quality, safety and aesthetics are the only arguments against the WCSP staying downtown, then I don’t think they’re enough to justify the cost of a plant relocation or building of a new plant.
Best case scenario: the gas plant will retire to an emergency back-up role in a few decades.
Second-best case: Penn State will keep power and heat generation infrastructure closest to the point of use for the efficiency and maintenance benefits, which means downtown at WSCP, close to the end users.
I’m partial to a full Combined Heat and Power with combined cycle approach at WCSP, to let Penn State produce most of their own power to cut GHGs in half or more by 2017, but I could be convinced for the low-build approach if PSU put a major focus on energy efficiency and ground-source heat pump district system in the near term (within five years), such that a combined-cycle plant wouldn’t serve as an asset for load reduction.
Expressing these views, however, is somewhat a waste of time without Penn State having any energy master plan that prioritizes efficiency. In any case, I suggest activists abandon efforts regarding plant-specific GHG and HAP emissions, and instead focus on expanding local sovereignty, gaining public access to and decision-making participation on the Penn State Energy System Master Plan, and reshaping the Board of Trustees’ energy engagement.
David Stone on Emissions Impacts and Energy System Planning
(Dec. 14, 2013 Email Response to Matt’s points)
I don’t see any advantage to locating a CHP (or Combustion Turbine) for electric generation within the WCSP building itself. For one thing, to do that, PSU has to tear out the soon to be retrofitted boilers 6 and 8 after already having installed two new boilers (#1 and #2) at great expense.
If you want to argue that those two new boilers should be two small CHPs instead, that’s another thing. But any CHPs would trigger increased DEP/EPA scrutiny, because their emissions would be higher given the 12-month a year operation. Noise is also a problem, given the WCSP’s high window design and thin walls.
To resign ourselves in any way to a WCSP gas combustion lock-in gives away the store with nothing to show for it. The less money spent there. the sooner the phase-out and the more urgent the need for demand reduction overall.
What else can we point to as a way for PSU to meet the MACT at this point though, given the regulatory constraints, except a quick retrofit of all five existing boilers to burn only gas?
Such a plan wouldn’t require a 1-year extension needed from DEP, so one less year of burning coal. The retrofitted boilers would even give PSU the turndown and n-1 backup capacity OPP says it needs.
There are all sorts of “mix and match” combinations here I suppose: one CHP instead of one new boiler, retrofit the rest etc. – and I would not rule anything out in negotiations – but PSU is not negotiating. Getting them to negotiate is the whole point of what we are trying to do.
If you want a CHP combustion turbine, you could just put it anywhere along the new pipeline route or at ECSP where the year round local emissions and noise aren’t a detriment to the downtown revitalization and neighborhood property values. Localized smaller CHP units might be preferable anyway, perhaps linked into the high pressure steam lines from ECSP to step down steam pressure for the legacy low pressure steam system. The CHP would also be better located for linking with geothermal if surrounded by open space.
Again, negotiations could be productive here. But nobody is talking to us, so confrontation and relentless legal, political, and direct action are in order.
I’ve always said that you could quickly meet MACT with the Option 1 “bridge to the bridge” retrofit and use the dollar savings ($10-15 million, perhaps much more – I need to quantify this once and for all but am staying conservative for now) to pay for a combustion turbine or ultra low NOx boiler elsewhere. Right away if you want.
But can’t we do better than that?
Even our best argument for a ultra low NOx solution as BAT can only work if we get DEP/EPA to “think outside the walls” of the WCSP proper. It is that “inside the box” location which prevents an ultra low NOx or post-combustion mitigation alternative, according to OPP itself.
I think you are wrong about the level of emissions of the WCSP with a CHP compared to downtown Borough traffic. This too could be quantified later.
The Borough can still zone against a new downtown Combustion Turbine for electric generation, and ratchet up air quality standards consistent with the Charter Bill of Rights. Art of the possible to some extent.
Much of the perceived high pressure pipeline risk is, of course, not accident-based but terrorism-based. Penn State is a prominent terrorist target for many reasons. Then too, if any similar gas infrastructure is attacked anywhere in the world, the Borough’s and Penn State’s reputation as a safe community will suffer accordingly. Property value is perception. The dollars involved though are real enough.
The student who will avoid coming to a college with a prime terrorist target at its center, or a despicable energy policy built around unrestrained fracking, is exactly the kind of student PSU should otherwise want to attract. What kind of educational community puts its high rise student housing next to its most dangerous and unhealthy facility? This is an environmental justice question as well – students being the lowest on the food chain around here.
Small Group of PSU Faculty Beginning to Engage on Operational Sustainability
I recently learned that a small group of Penn State faculty has been meeting quietly to discuss operational sustainability issues – energy production and consumption at the University Park campus. If you’re a faculty member interested in getting involved, contact Jon Brockopp.
Last weekend I forwarded them some documents related to the Fossil Free Penn State work done by community activists over the past year.
- 3.15.14 FFPS Email
- 12.7.13 FFPS Report – Public
- 12.14.13 FFPS Statement Draft
- 12.15.13 CDT Draft
- 12.16.13 Watt to Trustees
- 2.15.14 FFPS Regrouping Report
- 2.24.14 SSAC Email Thread
- 2.26.14 Rybacki Renewable Energy Plan – Final
One of the most interesting pieces of information I’ve come across in the past year is from this 2009 ESMP brainstorming document:
“End-Use Efficiency – Hutch Hutchinson stated that PSU might save 50% of building energy usage through end-use efficiency. Weatherization should be the first step implemented. Altering user patterns and providing feedback are also important. An energy fund could be created as a way for interested donors to support campus sustainability. Michael Kinsley mentioned that Harvard views energy efficiency as their best investment.”