Despite an unprecedented level of concern by industry over the Environmental Protection Agency’s (EPA) new emission standards for boilers (i.e., the so-called Boiler MACT rule), there may be a “sustainable” silver lining as a result of this rule. According to Kathleen Hogan, the Department of Energy (DOE) Deputy Assistant Secretary for Energy Efficiency, DOE is organizing to “reach out to every location that is likely to have a boiler affected by the boiler MACT rule and walk them through their investment options to be compliant.” DOE’s outreach will focus on the benefits of combined heat and power systems (CHP), which Hogan touted as the best investment option for many affected facilities. See “DOE Poised to Help Facilities Comply With Boiler MACT Rule, Official Says,” BNA Daily Environment Reporter, 27 DEN A-1 (February 10, 2012).
CHP is considered sustainable because it uses a single fuel source to generate power and thermal energy rather than separate fuel sources. Thus, for each ton of fuel consumed, it is more efficient than many alternatives since the waste heat is put to productive uses. By eliminating the second fuel source (e.g., to generate heat), CHP can reduce emissions of criteria pollutants, air toxics, and greenhouse gas emissions. The recent low natural gas prices provide another economic incentive to use CHP. According to DOE, increased CHP usage may add an additional 40 gigawatts of energy by 2020. For manufacturers and other entities interested in exploring CHP options, it is worth noting that CHP projects do not necessarily require direct ownership or direct capital investment by the host/energy user. There are third-party CHP providers who are willing and able to design, construct, own, and operate a CHP for the benefit of the host or energy user. The host typically must agree to purchase all of the electric power and steam and any chilled water produced by the CHP; the parties must agree upon the prices for these services and all the related service parameters.
DOE has long encouraged CHP and has approximately 24 CHP pilot projects currently highlighted on its web page. EPA’s Office of Water is even touting its Kendal power plant “partnership for sustainable solutions” CHP project. EPA negotiated a water discharge permit which allows a 256 MW power plant to, among other things, generate valuable steam from a previously wasted thermal discharge as well as improve air and water quality in lieu of more expensive end of pipe water cooling alternatives (See “NRC Report on Sustainability and the EPA: What does it mean for Water?” Discussion Guide for Stakeholder Consultations” (January 18, 2012). For more details, see EPA’s press release on the Kendall discharge permit. While such flexibility and use of incentives should be encouraged, as with most government programs, the devil will be in the details.