Brought to you by Winston & Strawn LLP and Environmental Resources Management.

Transcription

1 The Future of Electric Generating Units Under the EPA s New NSR Rules, Cross-State Air Pollution Rules, and New Clean Air Act Regulations Brought to you by Winston & Strawn LLP and Environmental Resources Management.

2 Today s Speakers Jay Holloway Ken Weiss Liz Williamson Peter Belmonte George Holder 2

3 Ken Weiss, ERM Peter Belmonte, ERM 1:30 p.m. 2:45 p.m. (PST) 2:30 p.m. 3:45 p.m. (MST) 3:30 p.m. 4:45 p.m. (CST) 4:30 p.m. 5:45 p.m. (EST) 59

4 Replacement of an entire component (i.e., reheater or economizer) Ken Weiss, ERM 60

5 Replacement of an Entire Component Is it RMRR Frequency EPA typically thinks this turns on frequency at the site Nature and Extent EPA examines the need for temporary crews Purpose Is it life extension Cost EPA tends to emphasize absolute cost NSR Compliance Ramps Do an actual to actual calculation with your best information. Typically no projected increase that triggers NSR, provided demand is considered. Note EPA recent policy can be helpful Could it be RMRR sometimes for sure but document with a WEPCO analysis for the file Netting is not likely to be successful given the policy requiring actual to potential calculations at the contemporaneous emissions point 61

6 62 Turbine replacement or upgrade

7 Turbine Replacement Upgrade Is it a modification? Yes with respect to the site, but No with respect to the boiler NSR Issues The Good News BACT does apply as no emissions unit has been modified The Bad News An Air Quality Analysis is required including compliance with the short-term t NAAQS for SO 2 and NO 2 unless NSR can be avoided The NAAQS demonstration will require significant time 63

8 Sensitivity Results 200 MW EGU Boiler Stack height (ft) Simple Terrain SO2 Emission Rate (lb/mmbtu) No Background With FGD No FGD Background = 50% NAAQS With FGD No FGD Background = 75% NAAQS With FGD No FGD

9 Air pollution control equipment Pete Belmonte, ERM 65

10 Activated Carbon Injection (Hg) PM, PM 10, PM 2.5 Main Stack But ACI is all >10 microns! Are we sure? All? Do we know that it will not become finer in the boiler? If an ESP, lower resistivity? Quirkiness of stack testing? ti Any meaningful guarantee? Material Handling Pneumatic conveying Bin vent filters Roadway dust Incremental ash volume, non recyclable? 66

11 Fuel Switching to PRB Coal PM, PM 10, PM 2.5 Main Stack ~30% more solids loading to particulate t collector If an ESP, lower resistivity? Material Handling ~25% more coal Finer, more friable Unloading, stacking reclaiming conveyors, transfer towers, piles bulldozing, etc. Incremental ash volume Affect on Dispatch? 67

12 Dry Sorbent Injection (HCl/HF/SO 2 ) PM/PM 10 /PM 2.5 Main Stack But trona is all > 10 microns! Are we sure? All? Do we know that it will not become finer in the boiler? Quirkiness of stack testing? Any meaningful guarantee? Increase in CO 2 from calcination li i Material Handling Pneumatic conveying Bin vent filters Roadway dust Incremental ash volume Affect on Dispatch? 68

13 SCR (NO x ) PM/PM 10 /PM 2.5, H 2 SO 4, affect on heat rate Main Stack Oxidation of SO 2 to SO 3 Ammonia salts/blue Plume Quirkiness of PM 10 stack testing? Any meaningful guarantee? Increase in CO 2, SO 2, CO, VOC, PM, etc. to maintain present output (parasitic load) Ammonia in flyash Affect on dispatch? 69

14 SDA/FF (HCl/HF/SO 2 /PM 10 /PM 2.5 ) Main Stack Paper PM 10 /PM 2.5 increase? No condensables limit now No meaningful guarantee condensables Little data, quirkiness of stack testing Increase in CO 2 from calcination Increase in CO 2, SO 2, CO, VOC, PM, etc. to maintain output Material Handling Bulk delivery / pneumatic conveying Bin vent filters Roadway dust Incremental ash volume, disposal? Affect on dispatch? 70

15 Wet FGD (SO 2 /HCl/HF/Hg/PM 2.5 ) Main Stack Increase in CO 2 from calcination Wet stack, lower plume buoyancy Increase in CO 2, SO 2, CO, VOC, PM, etc. to maintain output Material Handling Bulk delivery/pneumatic conveying Bin vent filters Roadway dust Incremental ash volume, disposal? Affect on dispatch? 71

16 Thank you! Ken Weiss, ERM +1 (610) Peter Belmonte +1 (281)