First Name | Coree |
---|---|
Last Name | Javernick |
Email Address | coreejavernick@ussposco.com |
Affiliation | |
Subject | UPI's Cap and Trade Comments |
Comment | USS-POSCO Industries (UPI) appreciates the opportunity to participate in the public process for California Air Resources Board Proposed California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation, including Compliance Offset Protocols. We have thoroughly reviewed Appendix B: Development of Product Benchmarks for Allowance Allocation and would like to address some concerns that we have. Our comments are summarized below. Comment #1 – The Proposed Benchmark for Cold Rolled and Annealed Steel Sheet Production Appendix B cites that “the ease of developing product-based benchmarks depends on the homogeneity of products within the benchmarked industrial sectors.” The Appendix then goes on to list only one benchmark for Cold Rolled and Annealed Steel Sheet (CRS) Production. However, there are two types of annealing processes that result in different steel properties, which, in turn, result in two different CRS products. Steel can be annealed using either a batch annealing (BA) process or a continuous annealing (CA) process, and “BA” or “CA” is typically part of the CRS product description. Batch annealing is a multi-day process where up to several dozen coils are stacked in a furnace, and heated until the correct properties are obtained. In a continuous annealing process, the steel is uncoiled and passes in loops through a furnace for several minutes heating a cross section of the strip for several minutes. Continuous annealed material has a fine grain structure and is more resilient than batch annealed material which has a coarse grain structure and excellent formability. It is not a product that is simply differentiated by technology. Each process creates a unique product and therefore, each process should have its own benchmark. Comment #2 – The Proposed Benchmark for Tin Steel Plate Production The benchmark for Tin Steel Plate Production is listed as 0.0197 on page 10 of the Appendix. UPI is the only company that produces this product, and through communication with Mihoyo Fuji of the Air Resources Board, we came to the conclusion that our emission intensity for this product to be 0.03536. The appendix states that the “staff selected a benchmark based on the “best-in-class” value (i.e., the emissions intensity of the most GHG-efficient California facility).” Since UPI is the only California facility that produces this product, the benchmark should reflect our current emission intensity levels. Comment #3 – The Proposed Benchmark for Pickled Steel Sheet Production UPI currently runs an Acid Processor (AP) in concurrence with our Pickle Line Tandem Cold Line (PLTCM) which produces Pickled Steel Sheet Product. The AP uses natural gas to regenerate hydrochloric acid which is then returned to the pickle line. Because UPI is the only facility that recycles and regenerates our spent acid, the natural gas used should not be counted against our emission intensity benchmark for our Pickled Steel Sheet Product. |
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Date and Time Comment Was Submitted | 2011-08-11 12:10:19 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.