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Comment 4 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 3rd Workshop.
First Name: Robert
Last Name: Freerks
Email Address: rfreerks@rentk.com
Affiliation: Rentech, Inc
Subject: Comments on NRDC Presentation to Advisory Panel 1 July 2011
Comment:
Rentech Comments on Presentations to CARB LCFS Advisory Board Presentations At the California Air Resources Board LCFS Advisory Panel Meeting held on 1 July 2011 in Sacramento, NRDC and Wood-McKenzie presented views on the impacts of CARB rulings on the use of High Carbon Intensity Crude Oil in California fuel meeting the LCFS. Rentech, Inc. is developing technology and products to help Federal and State governments meet Renewable Fuels Standards and Low Carbon Fuel Standards utilizing a combination of biomass and where appropriate, fossil resources. Rentech is committed to producing fuels with carbon intensity values below that of conventional fossil based fuels by using advanced engineering technology and appropriate resources in the most efficient manner. An example of this effort is the Rentech Rialto Renewable Energy Center. This project is being designed to produce 1200-1500 bbl/day of liquid hydrocarbon fuels that are direct replacements for conventional fuels and refinery products. Based on independent life cycle assessment data provided by Lifecycle Associates, fuels produced from the Rialto facility will have baseline carbon intensity of approximately 5% of conventional fuels; and using reasonable estimates of the alternative fates of the feedstocks used in this project, the CI of these fuels will be much less than that. Rentech is also developing a project in Ontario, Canada where unmerchantable wood and wood waste would be converted into fuels and power with a CI for the fuel being below zero, or greater than 100% reduction in CI compared to baseline fossil fuels. Rentech is also developing technology to produce fuels from fossil resources utilizing combined fossil and biomass gasification. The project located in Natchez, MS is designed from the start to be a low carbon emissions plant using Carbon Capture and Storage to reduce the GHG emissions from the production of fuels at that plant. CCS technology is 100% integrated into this plant design, and is in fact a requirement of the design. Therefore permanent storage of the captured CO2 is actually a profitable part of the plant economics and not just a means of disposal of a waste stream. Rentech is partnering with Denbury Resources to utilize CO2 from CTL for EOR which will produced an additional 2 bbl of crude per bbl of F-T products produced. This has benefits both for storage of CO2 and reduction of dependence on imported crude which often has higher environmental impact than domestic production. I mention this aspect of the Rentech CBTL plant design in response to a slide presented by NRDC at the 1 July CARB LCFS Advisory Panel meeting. Slide 2 of the NRDC presentation is shown below, Figure 1. In this slide, NRDC shows that Coal to Liquids projects have GHG emissions of 120% greater than those of conventional fossil based fuels. Although this is theoretically approximately correct (numbers vary from 80% to 130% greater than fossil fuels), it is a very different picture of the CTL industry as it would exist in the US. Based on current regulations and political realities, no CTL facility in the US would produce fuels with a CI greater than that of fossil fuels produced in 2005 based on Section 526 of the EISA of 2007. There simply would not be a market for fuels produced from CTL technology without CCS and without meeting the Section 526 requirement. Rentech’s advanced design for a CBTL plant produces fuels with a CI of 70 gCO2e/MJ, substantially below the CARB LCFS baseline for fossil derived diesel fuel of 94.71 gCO2e/MJ. The reduction in CI for CBTL fuels produced by a project such as Rentech’s Natchez facility can be put into context using CARB LCFS fuel production pathway data. Figure 1 Slide 2 from NRDC Preseentation to CARB LCFS Advisory Panel 1 July 2011 Figure 2 shows the CI of several conventional and alternative fuels as reported in CARB documents. Note that the CI for fuels from the Natchez CBTL plant is below that for Hydrogen, Ethanol, Biodiesel, and Electricity when used in EV’s. Based on our analysis and the view that no CBTL plant is being planned or permitted that would vent CO2 at the rate shown in the NRDC presentation, we submit that the NRDC value for GHG emissions from a CTL plant are extremely out of line with reality, or reality as it exists in North America for CTL plants. And we further submit that CBTL plants are much more realistic to build in the current regulatory environment and that the GHG emissions from these plants is much more representative of what CI value should be considered for coal derived fuels. As CTL as depicted by NRDC has the highest GHG emissions of any alternative fuel, and the volume production is 1/3 of the total shown in NRDC slide 3, we believe that the “Change in Carbon Intensity v. 2005 Baseline” shown in Slide 4 of the NRDC presentation is very inaccurate. Figure 2 Comparison of CI for fossil and alternative fuels per CARB LCFS vs Rentech Rialto Renewable Energy Center baseline CI. The ability of a CBTL facility to produce larger volume of fuels with reduced CI compared to biofuels can be illustrated as follows: • CBTL facility produces 10,000 bbl/day (153,000,000 gal/yr) of alternative fuel (partially biomass derived) • CI of CBTL fuel is 70 gCO2e/MJ • Comparison between CBTL and Biodiesel with CI of 88.9 gCO2e/MJ • Rentech CBTL plant produces equivalent GHG emissions as production of 42,530 bbl/day of biodiesel (651,900,000 gal/yr or over 50% of all biodiesel production) Thus economies of scale for using biomass with fossil resources results in net reduction of GHG emissions without competition for food and land resources, and also water resources needed to make such fuels as 1st generation biodiesel fuel. Rentech’s RenDiesel is a drop-in replacement for conventional diesel fuel, unlike many 1st and 2nd generation biofuels such as ethanol, biodiesel, and pyrolysis oil derived fuels. We find it interesting that NRDC would choose to use KiOR technology as representative of fuel input switching. To our knowledge, KiOR has not presented a LCA study on their process, nor has KiOR presented data on their fuel product. Pyrolysis oil is a highly toxic and corrosive product that will represent risks during transportation to refineries where it is proposed to be upgraded into finished fuel. This upgrading process will consume large quantities of hydrogen which most likely is produced from fossil fuels (mostly natural gas). PNNL estimated that partial upgrading of pyrolysis oil into liquid fuels consumes 5,000 SCF/bbl of pyrolysis oil (Ellott & Neuenschwander, PNNL, 1996). The level of hydroprocessing only reduced oxygen in the feedstock by 95-98%. Complete removal of oxygen is required to meet diesel fuel specifications. PNNL presented data at the Smallwood conference (May 13-15, 2008 in Madison, WI) showing that H2 consumption for complete upgrading of pyrolysis oil can consume up to 47,000 SCF/bbl of pyrolysis oil processed. Rentech presents data on its process and products openly. We welcome open presentation of data from other producers so that all aspects of fuels production from biomass, fossil, or a combination of these resources can be discussed, compared and evaluated for efficiency of biomass utilization and production of useful commercial fuels for the transportation sector. Only when all the data is made available can useful discussions about options for meeting the LCFS provisions be realized.
Attachment: www.arb.ca.gov/lists/lcfsadvisorypanel-ws/13-rentech_comments_on_presentations_to_carb_lcfs_advisory_board_presentations_jd.doc
Original File Name: Rentech comments on Presentations to CARB LCFS Advisory Board Presentations JD.doc
Date and Time Comment Was Submitted: 2011-07-22 14:42:42
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