Our facility has a steam turbine that is supplied steam from two
boilers and from a Heat Recovery Steam Generator that is on the
exhaust of one of our gas turbine/generators. It does not make
sense to apply Section 95112 to the boilers and turbine/generators
because Section 95112 requires emissions to be distributed between
thermal energy production and electrical production. The thermal
energy production from the HRSG and boilers are used to generate
electricity. Could Section 95111 (a) (4) and the related
definitions for “cogeneration system” and “cogeneration facility”
be clarified so that they do not apply to our facility.
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