Questions for EPA on “Waste Energy Recovery Registry”

Proposed Rule Preamble:

Is the survey completion mandatory or voluntary?  You should be clear to
the public that survey completion is voluntary.

Self-certification – EISA statute calls for self-certification, yet
EPA seems to be foregoing that.  Please explain.

pg 11 – “On an annual basis, these projects will prevent the
emission of more than 10.93 MMTCO2.” 

- Can you please provide a citation for this?

pg 14 "WEST calculates the potential recoverable waste energy from each
source using embedded algorithms based on the criteria proposed in this
rule, using data provided by the site owner or operator."

-Should EPA include these algorithms in the rule package, so that the
industry can review and comment?

 

Pg 19 "EPA is proposing that the Survey be completed by owners or
operators of affected sources anytime following release of WEST.  The
Agency expects WEST to be released within 90 days of the final rule
being published in the Federal Register"

-Should EPA release WEST with the proposal so that the industry can
review the tool and comment on its ease of use?

 

Pg 19. "Following the release of WEST, affected sites and sources can
submit the Survey reporting information to the Agency at any time."

-Why are there no deadlines here?  Is this strictly voluntary?

 

Pg 20 "As such, the Agency is not proposing to create an option for
self-certification.  EPA invites comment on this approach"

-Based on previous statement, it sounds like EPA is relying on
self-certification (as opposed to 3rd party verifier), along with EPA
review.  Clarify what the certification process will be.

 

pg 20 "The Registry update will be accomplished through an updated
Survey issued by the Agency every three years. The Agency is proposing a
three-year schedule based on a number of factors, including the time
necessary to develop waste energy projects following the release of the
first edition of the Registry and a desire to limit the frequency with
which respondents are directed to complete and return a Survey to EPA. 
Based on experience of the EPA CHPP, a typical CHP project development
cycle is three to five years and it is reasonable to assume that other
waste energy projects have a similar development cycle"

-Why is the 3 year schedule necessary rather than a 5yr?  Will each new
survey require a new rulemaking and ICR?  Is 3 years reasonable? 

pg 21 "EPA considered alternatives to the proposed data collection
approach.  EPA considered utilizing the National Emissions Inventory
(NEI) for the source specific information necessary for the Survey and
Registry, but determined that NEI did not provide the type of
information necessary for four primary reasons: NEI does not include
data for waste gas streams or pressure drops so would not provide data
for all types of waste energy, as described in Section A(1) of this
preamble; NEI does not contain complete data sets; NEI contains data
anomalies; and NEI data is not consistent across the states as to what
specific information is included.  EPA is requesting comment on the
proposed data collection approach."

-Why wasn't NEI revised with these additional data elements (waste gas
and pressure drop)?  The industry should have more experience with NEI,
and substantial investments have been made in NEI to update data-sharing
capabilities.

 

pg 27, 28.  Clarify what data elements the industry needs to input,
and which estimates (GHG reduction potential, criteria pollutant, etc)
are determined through calculations by EPA.  

 

pg 32 "The algorithms embedded in WEST will estimate total installed
costs, incremental O&M costs, electricity generated, and incremental
fuel use and cost for each potential waste energy recovery project at a
responding site.  Each of these estimates will be based on rules of
thumb for sizing, efficiency, and costs that are specific to each of the
potential waste energy recovery categories (e.g., waste heat recovery,
waste gas recovery, pressure drop recovery, CHP). "

-Are these emissions factors and rules of thumb clearly laid out in the
TSP?  

ICR:

Question 11 for the WEST Survey (p. 7 of the ICR) asks for information
on the electric distribution utility serving site.  Can you explain why
this information is necessary? 

