Sunday, January 30, 2011

How some environmental regulations increase pollution and carbon emissions.

Environmental regulations that establish the operating parameters for industrial operations are intended to minimize the impact to the environment by the emissions from the facility.  But it doesn't always work that way.  Yes, it may come as a shock that a Government program might actually not achieve its intended goal, but it can happen.

A particular case is regarding the operation of coal fired steam generation plants.  If a steam plant is coal-fired there is likely some verbiage in the air quality permit that the boiler must operate at some very high  temperature to control the NOx emission concentration to a certain ppm level.   That's well and good.  But suppose the plant doesn't need to generate a lot of steam on a particular day and the boiler could support the operation with a lower temperature setting.  That would reduce the amount of coal burned and tons of carbon emitted into the atmosphere.  Good thing right?

No, that would put the plant in violation on the NOx regulation.  To stay legal the plant has to run the boiler hotter than it needs to and make more steam than it needs to and then dump the heat somewhere (as in outside).  And that would be OK I suppose if the object was to minimize the amount of NOx emissions.

But here's the problem.  In order to reduce the concentration of NOx in the boiler exhaust, the plant has to burn more coal than it needs to, so it ends up emitting more mass of NOx.  The slight reduction in concentration that comes from running the boiler hotter does not compensate for the increased amount of coal that was burned to make the boiler run hotter.

It would make common sense if people enforcing these sort of regulations could have some leeway to use common sense and determine the optimal operating point of temperature based on the load to minimize the amount of coal burned and the total amount of NOx emitted.  Maybe Adam Smith's "invisible hand" concept could actually help reduce energy consumption and reduce the environmental impact from factories.

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