First Name | James |
---|---|
Last Name | Merriam |
Email Address | James_N_Merriam@praxair.com |
Affiliation | Praxair, Inc. |
Subject | AB32 -- GHG Emissions Compilation and Reporting |
Comment | Praxair Comment #1 : [Section 95103 -- Reporting Requirements] REQUESTED CHANGE -- Add a sentence to 95103(a), just above 95103(a)(1), stating : Hydrogen Plants using 95114(b)(2) to calculate CO2 emissions shall substitute "fuel and feedstock" wherever the word "fuel" is stated in 95103(a)(8) through (10). REASON FOR CHANGE -- Hydrogen Plant CO2 emissions can be determined by measuring all incoming carbon per 95114(b)(2). Therefore, sections 95103 (a)(8) through (10) concerning missing data, measurement accuracy, and interim data collection need to use "fuel and feedstock" as the parameter applicable to Hydrogen Plants, not just "fuel". Praxair Comment #2 : [Section 95114 -- Hydrogen Plants] REQUESTED CHANGE -- Add a sentence to 95114(a)(3) and also to 95114(a)(4) stating that the carbon contained in the Methane (CH4) calculation results for these sections shall be subtracted from the CO2 calculation result of 95114(b)(2). REASON FOR CHANGE -- As currently written, the carbon in the entering feedstock and fuel would be double-counted for the portion represented by the Methane calculations. [ This change does not greatly affect the facility's CO2 emissions computation, but needs to be made for overall correctness.] Praxair Comment #3 : [Appendix] REQUESTED CHANGE -- Revise Table 6 on Page A-9 of the Appendix to add entries for METHANE, HYDROGEN, and CARBON MONOXIDE. REASON FOR CHANGE -- Hydrogen Plant reformers combust Natural Gas, Methane, Hydrogen, and Carbon Monoxide. Table 6 entries for these fuels need to be included so that the Hydrogen Plant's CH4 and N2O combustion emissions can be calculated. COMMENTS -- Although the methane and nitrous oxide emission factors for combusting Methane are likely the same as for Natural Gas, 0.9 and 0.1, the table needs to state this. The methane emission factors for combusting Hydrogen and Carbon Monoxide also need to be listed. For those two fuels, the methane emission factor should be stated as ZERO because they contain no hydrocarbons, and an appropriate nitrous oxide factor is probably 0.1, similar to natural gas. [NOTE -- Hydrogen and Carbon Monoxide burn hotter than Natural Gas, and nitrous oxide emissions decrease as temperature increases, so their N2O factors in the table should be 0.1 or less.] |
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Date and Time Comment Was Submitted | 2008-06-04 08:11:57 |
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