Public Stakeholder Conference Call 2013 Integrated Resource Plan. Organizations Participating. Conference Call Highlights

Transcription

1 Public Stakeholder Conference Call 2013 Integrated Resource Plan Call Date: December 6, 2012 Meeting Time: 2:00 pm 3:00 pm (Pacific) / 3:00 pm 4:00 pm (Mountain) Organizations Participating The list of individual meeting attendees is provided as Appendix A. Alpern Myers Stuart LLC Citizens' Utility Board of Oregon (CUB) Energy Strategies, LLC (For UAE) Industrial Customers of Northwest Utilities (ICNU) MidAmerican Energy Holdings Company (MEHC) Northwest Pipeline GP NW Energy Coalition (NWEC) Oregon Public Utility Commission (OPUC) PacifiCorp Salt Lake Community Action Program Utah Clean Energy (UCE) Utah Division of Public Utilities (DPU) Utah Office Of Consumer Services (OCS) Utah Public Service Commission (UT-PSC) Wyoming Public Service Commission Conference Call Highlights The purpose of this IRP public stakeholder conference call was to brief participants on recent and forthcoming actions by the U.S. Environmental Protection Agency (EPA) pertaining to the regional haze program, and to discuss the impacts of the EPA actions on the IRP portfolio modeling framework and the 2013 IRP schedule. The purpose of this IRP public stakeholder conference call was to brief participants on recent and forthcoming actions by the U.S. Environmental Protection Agency (EPA) pertaining to the regional haze program, and to discuss the impacts of the EPA actions on the IRP portfolio modeling framework and the 2013 IRP schedule. 1. PacifiCorp told participants that the EPA recently issued its final rule on the Arizona regional haze State Implementation Plan (SIP), which was published in the Federal Register. The EPA promulgated a Federal Implementation Plan (FIP) for Arizona that included revised emission rates and compliance schedules for implementation of Best Available Retrofit Technology (BART) on several electric generating units (EGUs) in the state. This final EPA action impacts Cholla Unit 4, wholly owned by PacifiCorp, by requiring installation of selective catalytic reduction (SCR) equipment by The 2017 SCR installation schedule for Cholla Unit 4 was originally included in the assumptions for the IRP Stringent Regional Haze scenario, but will now be redefined as part of the IRP Base Regional Haze scenario. This redefinition requires an update to unit-specific model inputs and re-running of the System Optimizer capacity expansion model IRP December 6, 2012, Public Stakeholder Conference Call 1

2 2. PacifiCorp also told participants that the EPA is under a consent decree deadline to issue its final rule on the Wyoming regional haze SIP on December 14, The ruling impacts the environmental control equipment retrofit requirements and compliance schedules for the following eight coal units: Dave Johnston 1-3, Jim Bridger 1-4, and Wyodak. Once the EPA s final action on the Wyoming regional haze SIP is made available, the Company will need to review and assess its implications on unit-specific model inputs and specification of portfolio cases. As with Cholla Unit 4, stringent regional haze assumptions for certain Wyoming coal units may be redefined as base regional haze assumptions, requiring modified coal unit inputs and new model runs. PacifiCorp noted that the precise date that the Wyoming final rule is made available to the public is not certain. 3. The 2013 IRP filing date is March 31, However, the Company indicated that it plans to postpone further IRP portfolio modeling until EPA s final action on the Wyoming regional haze SIP is issued and evaluated. Consequently, the Company intends to request a one-time 2013 IRP filing date extension to account for the modeling delay. PacifiCorp believes that it is in the public interest to request an IRP filing extension rather than meet the March 31, 2013 deadline with modeling results that will almost immediately thereafter be based on obsolete environmental compliance information. 4. A participant asked if the Company would ask for a filing extension to May PacifiCorp responded that the requested extension date would depend on the outcome of the Wyoming FIP analysis. The Company will schedule another stakeholder conference call to discuss the Wyoming FIP analysis and specifics on a filing extension request. 5. PacifiCorp summarized the main differences between the original SIP and EPA s final FIP for Arizona and the proposed FIP/SIP approval for Wyoming. In response to a request for more details, the Company prepared two tables provided in this report as Appendix A. The first table compares the Wyoming SIP and EPA s proposed FIP published in the Federal Register on June 4, 2012, while the second compares the Arizona SIP proposal to the proposed FIP published in the Federal Register July 31, 2012 and Final FIP, published in the Federal Register December 5, A participant questioned why the Company cannot proceed with the portfolio modeling given a limited set of outcomes for the EPA s proposed Wyoming FIP; i.e., the FIP will go one way or another regarding SCR implementation, and this is already captured with the base versus stringent regional haze scenarios. PacifiCorp responded that the Company is not sure what direction the EPA will take, nor can it accurately guess what the rule outcome will be, particularly with respect to the timing of SCRs for the Jim Bridger units. 7. A participant requested capacity assumptions for replacement gas conversion resource options in the IRP modeling. PacifiCorp agreed to provide public stakeholders with this information IRP December 6, 2012, Public Stakeholder Conference Call 2

3 Appendix A: State vs. Federal Regional Haze Proposal Comparison Comparison of Wyoming Plan and U.S. EPA Proposal Facility Wyoming Submittal EPA Proposal 1 Naughton Unit 1 LNB with OFA with NO x emission limit of 0.26 lb/mmbtu Naughton Unit 2 Naughton Unit 3 Existing ESPs with 0.04 lb/mmbtu PM limit LNB with OFA with NO x emission limit of 0.26 lb/mmbtu Existing ESPs with 0.04 lb/mmbtu PM limit Install SCR and baghouse by 12/31/2014 with NO x limits of 0.07 lbs/mmbtu Baghouse for PM control with lb/mmbtu limit Dave Johnston Unit 3 LNB with OFA with emission limit of 0.28 lb/mmbtu Existing baghouse with PM limit of lb/mmbtu Dave Johnston Unit 4 LNB with advanced OFA with NO x emission limit of 0.15 lb/mmbtu Disapproved FIP proposed to find that LNB with OFA plus SNCR at an emission limit of 0.19 lb/mmbtu Jim Bridger Unit 1 Existing baghouse with PM limit of lb/mmbtu Install SCR or equivalent technology to achieve emission limit of 0.07 lb/mmbtu NO x by 12/31/2022 Disapproved 2 FIP proposed to install SCR within five years of SIP or FIP approval 1 EPA s proposed action is available electronically at: 2 Effectively, three alternatives were proposed by EPA regarding installation of SCR on the four Jim Bridger Units. The first alternative would require the installation of four SCR within five years after SIP or FIP approval allowing PacifiCorp to select the dates within the five year period when the four units install such controls. The second alternative would leave the SCR installations at Jim Bridger Units 3 and 4 in 2015 and 2016 while also requiring that SCR be installed at Units 1 and 2 within five years from SIP/FIP approval. The third alternative is contained in the Wyoming SIP and would require installation of SCR at Jim Bridger Units 3 and 4 in 2015 and 2016, and installing SCR at Units 1 and 2 in 2021 and IRP December 6, 2012, Public Stakeholder Conference Call 3

4 Comparison of Wyoming Plan and U.S. EPA Proposal Facility Wyoming Submittal EPA Proposal 1 Jim Bridger Unit 2 Jim Bridger Unit 3 Jim Bridger Unit 4 Wyodak Install SCR or equivalent technology to achieve emission limit of 0.07 lb/mmbtu NO x by 12/31/2021 Install SCR or other NO x control systems to achieve an emission limit or otherwise reduce NO x emissions to achieve 0.07 lb/mmbtu NO x emissions rate by 12/31/2015 (part of long term strategy) Install SCR or other NO x control systems to achieve an emission limit or otherwise reduce NO x emissions to achieve 0.07 lb/mmbtu NO x emissions rate by 12/31/2016 (part of long term strategy) Existing baghouse with PM limit of lb/mmbtu Disapproved (see footnote 2) FIP proposed to install SCR within five years of SIP or FIP approval EPA disagreed that SCR is part of long term strategy but approved compliance schedule and emission limit of 0.07 lb/mmbtu. For further discussion, see footnote 2. EPA disagreed that SCR is part of long term strategy but approved compliance schedule and emission limit of 0.07 lb/mmbtu. For further discussion, see footnote 2. LNB/OFA with NO x limit of 0.23 lb/mmbtu Dave Johnston Unit 1 No additional controls necessary during initial planning period Disapproved LNB with OFA plus SNCR at an emission limit of 0.18 lb/mmbtu no later than five years after EPA finalizes the FIP Disapproved LNB with OFA and emission limit of 0.20 lb/mmbtu in FIP to be installed as expeditiously as possible but no later than 7/31/ IRP December 6, 2012, Public Stakeholder Conference Call 4

5 Comparison of Wyoming Plan and U.S. EPA Proposal Facility Wyoming Submittal EPA Proposal 1 Dave Johnston Unit 2 No additional controls necessary during initial planning period Disapproved LNB with OFA and emission limit of 0.20 lb/mmbtu in FIP to be installed as expeditiously as possible but no later than 7/31/2018 Comparison of Arizona State Implementation Plan and U.S. EPA Proposed and Final Federal Implementation Plans Unit Arizona Proposed Plan EPA Proposed Plan 3 EPA Final Plan 4 Cholla Unit 4 LNB with OFA at emissions rate of SCR with emissions rate of lb/mmbtu lb/mmbtu SO 2 and PM emissions at 0.15 lb/mmbtu SO 2 and PM with emissions rate of 0.15 lb/mmbtu SCR with emissions rate of lb/mmbtu averaged over Cholla Units 2, 3 and 4 within five years of final rule SO 2 with removal efficiency of 95% by July 3, 2013 PM with emissions rate of 0.15 lb/mmbtu by July 3, 2013 LNB/OFA Low NO x burners and over-fire air are combustion controls to reduce nitrogen oxides emissions with emission reductions in excess of 30%. These controls are typically installed as an initial emissions reduction project due to relatively low capital cost. SNCR Selective non-catalytic reduction is post combustion nitrogen oxides control that injects ammonia into the flue gas stream to reduce emissions. SNCR is a less expensive control compared to SCR, but with lower control efficiencies (incremental reductions of approximately 25-30%). SNCR is typically installed as a secondary emissions reduction project to complement LNB/OFA installation; limited in application by ultimate emission rate requirements IRP December 6, 2012, Public Stakeholder Conference Call 5

6 Appendix B: Meeting Attendance List, Individuals Company Alpern Myers Stuart LLC Citizens' Utility Board of Oregon (CUB) Energy Strategies, LLC (For UAE) Industrial Customers of Northwest Utilities (ICNU) MidAmerican Energy Holdings Company (MEHC) Northwest Pipeline GP NW Energy Coalition (NWEC) Oregon Public Utility Commission (OPUC) PacifiCorp Salt Lake Community Action Program Utah Clean Energy (UCE) Utah Division of Public Utilities (DPU) Utah Office Of Consumer Services (OCS) Utah Public Service Commission (UT-PSC) Wyoming Public Service Commission Name Hickey, Lisa Feighner, Gordon Hendrickson, Don Sanger, Irion Woollums, Cathy Hagins, Teresa Gerlitz, Wendy Heutte, Fred Ordonez, Jorge Schue, Steve Kusters, Stacey Liljenwall, Michael Teply, Chad Warnken, Pete Weston, Ted Wolf, Betsy Hayes, Sophie Liu, Sam Zenger, Joni Vastag, Bela Dalton, Jamie Revelt, Carol Bohanan, Michelle 2013 IRP December 6, 2012, Public Stakeholder Conference Call 6