Calculating cogeneration unit emissions and compliance with GHG

performance standard per ESSB 6001

By: Alan R. Newman, PE

Policy questions to be considered by the advisory committee.

1. Should a facility that proposes or wishes to use the cogeneration opportunity to
demonstrate compliance with the performance standard be required to qualify as a
cogeneration facility under 18 CFR 292 first?
2. What should be the heat rate used to convert Btu of useful thermal energy to equivalent
MW of electrical energy? Why is this the preferred or best rate?
3. What are the units of the performance standard? The law says lb of GHG/MWh. Is the
lb GHG expressed as CO2 equivalent pounds, as carbon equivalent pounds, or the simple
total of the mass emissions of each GHG emitted?

Definitions
“Steam host” means the operation or entity that makes use of the useful thermal energy supplied
by cogenerator.

First the process in words:

Determine the useful annual thermal energy used by the ‘steam host’ and convert this annual
quantity of thermal energy used to an equivalent annual average MWh. The annual total energy
used is converted to the hourly annual average energy used by using the actual hours of operation
in cogeneration mode and the total useful thermal energy used.
Determine the annual electrical production sold and convert to an annual average MWh based on
the annual total electricity sold and the total actual hours of operation.
For a cogeneration facility, the total MWh is the sum of the annual average MWh of electricity
sold plus ½ the annual average MWh of useful thermal energy.
Determine the annual emissions of CO2, N2O, CH4, etc emitted. Convert all GHGs to CO2
equivalent using the warming potential of each chemical.
Convert the annual total CO2 equivalent emissions to an hourly rate using the annual total hours
that electricity is generated.
Determine emissions in the units of the performance standard by dividing the annual average
hourly CO2 equivalent emissions by the annual average hourly electrical production.

Procedure in formulas
1. Calculate useful energy used

Btuused = Btusupplied – Btureturned

Where
Btuused = actual heat energy used by the ‘steam host’ plus any transmission losses,
Btu/year
Btusupplied = total heat energy sent to the steam host for use, Btu/year
Btureturned = heat energy returned by the steam host as unused or unusable , Btu/year

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2. Convert the Btuused energy to MW electrical equivalent.

MWcogen = Btuused / Heat rate

Where
Heat rate = 3.413 MMBtu/MW (value based on considerations discussed elsewhere)

3. Calculate net MW produced for sale

MWcogen
MWN = MWG − MWP +
2

Where
MWN = Net electrical power produced (power sold plus equivalent from cogeneration),
in MW/year
MWG = Gross electrical production, nameplate rating of generator(s), in MW/year
MWP = Parasitic load on the generation system i.e. operation of pumps, motors, emission
control equipment, etc., in MW/year

4. Calculate GHG emissions

In this example we assume that the total GHG emissions are the total CO2 equivalent using
warming potential as the method to convert from pollutant mass to CO2 equivelance.

a. First the direct GHG emissions resulting from combustion

Ed = CO2 + N2O (KN2O) + CH4(KCH4)

Where
Ed = tons per year of GHG expressed as CO2 equivalent emitted from combustion
N2O = tons per year of N2O expressed as CO2 equivalent emitted from combustion
CH4 = tons per year of CH4 expressed as CO2 equivalent emitted from combustion
KN2O = N2O to CO2 equivalency conversion factor
KCH4 = CH4 to CO2 equivalency conversion factor

b. Second the indirect GHG emissions resulting from operations of support systems, switchyards
and transformers

Ei = HFC(KHFC) + PFC(KPFC) + SF6(KSF6)

Where
Ei = tons per year of GHG expressed as CO2 equivalent emitted from combustion
HFC = tons per year of HFC expressed as CO2 equivalent emitted from combustion
PFC = tons per year of PFC expressed as CO2 equivalent emitted from combustion
SF6 = tons per year of SF6 expressed as CO2 equivalent emitted from combustion
KHFC = HFC to CO2 equivalency conversion factor
KPFC = PFC to CO2 equivalency conversion factor

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 KSF6 = SF6 to CO2 equivalency conversion factor

5. Calculate emissions of GHG in units of the performance standard

⎛ 2000lb ⎞
lbGHG ⎜ ( E d + Ei ) ⎟
=⎜ ton ⎟ Operatinghours
MWh ⎜ MWN ⎟ year
⎜ ⎟
⎝ ⎠
Where
Operating hours per year = the actual number of hours the generation facility operated
and produced useful heat energy that was used.

Note, the conversion from annual rates to hourly rates could be made separately for the
electricity sold, and the useful thermal energy produced, and the GHG emissions converted to
hourly rates based on annual operating hours for each operation. i.e. useful work may not be
used every hour it is available, conversely electricity may not be generated every hour either, but
useful thermal energy may be required by contract to be produced anyway.

Alternate calculation of the performance standard based on calculating annual average

hourly generation and emission rates.

Calculate the hourly average MW equivalent for useful thermal energy

MWC = MWcogen/ hourscogen

Where
MWcogen = the annual hourly average energy used in the form of useful thermal energy.
Hourscogen = the annual number of hours energy supplied or used as useful thermal energy
MWC = the annual total useful thermal energy used converted to MWh

Calculate the hourly average MWe produced

MWe = (MWG – MWP)/hoursgeneration

Where
MWe = net electricity produced for sale
hoursgeneration = the annual total hours electricity produced for sale

Total Net electricity produced

MWNh = MWe + MWC/2

Where
MWNh = the annual average hourly equivalent net generation for the cogeneration facility

Annual average GHG emission rate

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 GHG = (Ed + Ei)/hoursgeneration
Note this assumes that no useful thermal energy is produced except when electricity is being generated.

Where
GHG = the annual average GHG emissions in ton/hour

Calculate the performance standard

lb GHG/MWh = (GHG* 2000)/MWNh

Policy discussion
1. Should a facility that proposes or wishes to use the cogeneration opportunity to
demonstrate compliance with the performance standard be required to qualify as a
cogeneration facility under 18 CFR 292 first?

This is an entry point question. The law does not require that a facility wishing to use
cogeneration as part of its compliance with the performance standard to be a cogeneration unit.
The law only directs that these units have their emissions and electrical generation be determined
in a consistent manner with that regulation.

If only facilities that qualify as cogeneration under 18 CFR 292 can have emission rates
determined consistently with that rule’s criteria, then the number of qualifying sources will likely
be limited and relatively easily determined.
If the context is applied to a larger universe such as contemplated in RCW 80.70, then the
regulators must rely on representations by the companies that they now and into the future will
operate as cogeneration operations. This is easy in the case of operations that provide useful
thermal energy for their internal industrial uses and sell excess electrical production on the
market. Where the ‘steam host’ and the electrical generator components of the process are not
under common control or ownership, this reliance on representations by the source owner are
valid only as long as there is a valid contract between the parties. Thus do we need some sort of
guarantee that a cogeneration relationship will exist into the future?

2. What should be the heat rate used to convert Btu of useful thermal energy to equivalent
MW of electrical energy? Why is this the preferred or best rate?

The heat rate used to generate the performance standard could be used for this conversion;
similarly the heat rate for a new standalone natural gas boiler or natural gas combined cycle
combustion turbine could be used also.

The heat rate for a new combined cycle natural gas fired combustion turbine is on the order of
6800 -7200 Btu/kW, depending on make, model, site elevation, ambient temperatures, and

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HRSG configuration. Oil and pulverized coal based electrical generation typically have higher
to much higher heat rates.

Based on the use of only natural gas and the CO2 emission factor for natural gas contained in
WAC 173-407-050(1)(e) of 117.6 lb/MMBtu, the heat rate used for the performance standard in
the law is calculated to be 9353 Btu/kWh, much higher than a new combined cycle natural gas
unit.

In establishing its 1100 lb CO2 /MWh performance standard, the California Energy Commission
stated the following:

The CPUC {California Public Utility Commission} staff proposed 1,100 pounds carbon
dioxide per megawatt-hour as an Interim Emissions Performance Standard in its October
2, 2006 Final Workshop Report. The standard was selected from proposals ranging from
800 to 1,400 lbs CO2/MWhr, and the earlier Revised Staff Report’s recommendation of
1,000 lbs CO2/MWhr (0.46 metric tons CO2/MWhr)1. The CPUC staff proposed EPS’s
of 1,000 or 1,100 lbs CO2/MWhr (0.50 metric tons CO2/MWhr) appear to be a
compromise between the 800 lbs CO2/MWhr that the most efficient modern combustion
turbine combined cycle plant could achieve, and the 1,400 lbs CO2/MWhr that might
envelope the majority of natural gas burning technologies (e.g., steam cycle boiler,
simple cycle combustion turbine, reciprocating engine, and a range of combustion turbine
combined cycle units).

A proposed standard of 1,100, or 1,000, lbs CO2/MWhr is equivalent to a power plant

unit with an effective heat rate, in higher heating value (HHV)2, of3:

Typical Fuel CO2 Effective Heat Rate Effective Heat Rate

emission factor, @ an EPS of 1,000 @ an EPS of 1,100
(lbs CO2/mmBtu) lbs, (lbs CO2/MWh) lbs, (lbs CO2/MWh)
Natural Gas 116.4 8,590 Btu/kWhr 9,450 Btu/kWhr
Fuel Oils 158.0 6,330 Btu/kWhr 6,890 Btu/kWhr
Bituminous 204.0 4,900 Btu/kWhr 5,390 Btu/kWhr
Coal
Petroleum 222.9 4,490 Btu/kWhr 4,940 Btu/kWhr
Coke

The California Energy commission staff report quoted above questions if any coal based power
plant (any size or design) could meet the 1100 lb CO2/MWh performance standard. The Staff
paper also notes that none of the small or microturbines currently available could meet the
1
Conversion: pounds to metric tons, multiply by 0.454 x 103
2
Heating Value: traditionally, heat rates in the USA and of boiler units is specified in higher heating value, while
Europe and combustion turbines generally use lower heating value. For this discussion and more direct comparison,
the higher heating value is used unless otherwise stated.
Natural gas HHV = 1.11 x LHV
Bituminous coal HHV = approx. 1.05 x LHV
3
Collard, Gary, Implementation of SB 1368 Emission Performance Standard, Staff issue Identification Paper, No.
CEC-700-2006-011, November 2006

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standard, though the staff paper also questions whether there are any of these units providing
baseload electricity.

Similarly to the treatment of cogeneration emissions for CAMR, the California Energy
commission utilized in its rule the ;standard engineering conversion factor of 3.413
MMBtu/MWh (3413 Btu/kWh) for converting useful thermal energy used to a MWh equivalent.

Oregon Energy Office’s Energy Facility Siting Standards currently uses a standard of 5770 Btu
(HHV)/kWh for new baseload natural gas units (equivalent to 0.675 lb CO2/kWh). This
standard is 17 percent below heat rate of the most efficient base-load gas plant operating in the
US. The basic heat rate for a new baseload unit would be 6955 Btu (HHV)/kWh or 0.81 lb CO2
/kWh (810 lb/MWh). A recent project (the COB Energy Facility) located in Klamath County
Oregon utilizes a combined cycle combustion turbine with a heat rate of 6842 Btu (HHV) /kWh
which equates to a CO2 rate of 0.834 lb/kWh (834 lb CO2/MWh).

3. What are the units of the performance standard? The law says lb of GHG/MWh. Is the
lb GHG expressed as CO2 equivalent pounds, as carbon equivalent pounds, or the simple
total of the mass emissions of each GHG emitted?

The absolute number used to calculate the GHG emissions could be different whether it is just
CO2, whether it is the CO2 equivalent of the combustion gases or is the total mass of the
individual GHGs. The law is not clear on how to determine this. Reading the definition of
“average available greenhouse gases emissions output” and the language in Sections 5and 7
indicate that we could choose either the simple sum of the individual GHG emission rates or use
the warming potentials to convert to CO2 equivalents.

The California regulations which are purported to be the basis of the initial performance standard
in Washington law only limits the direct CO2 emissions resulting from the fuel combustion
process4.

4
See Chapter 11, Greenhousee Gases Emission Performance Standard, Article 1, §2902

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