Comment Log Display

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.]