This document summarizes the timeline and details of proposed EPA regulations to limit greenhouse gas emissions from new electric generating units. Key points include:
- EPA proposed in 2012 to limit GHG emissions from new power plants to 1,000 lbs CO2/MWh, requiring carbon capture for non-natural gas plants. This received millions of public comments.
- In 2013, President Obama directed EPA to issue a new proposed rule by September 2013 and finalizes rules for new and existing power plants by 2015-2016.
- If finalized, the new source performance standard would define greenhouse gases as a regulated pollutant, significantly expanding emissions reporting and permitting requirements for industrial facilities.
The U.S. power generation fuel mix continues to shift, driven in part by low natural gas prices, state renewable mandates, tightening environmental regulations, and lower installed costs of some generation technologies such as solar. On June 18, 2014, the U.S. Environmental Protection Agency (EPA) issued its proposed Clean Power Plan (CPP), a proposed greenhouse gas emissions regulation scheme for existing plants, promulgated under section 111(d) of the Clean Air Act.
In this update, readers will see the latest legal developments and timelines under key EPA- proposed regulations, a brief overview of EPA’s Clean Power Plan and related state emissions reduction goals, and recent developments and open issues.
For more information, please visit www.scottmadden.com.
The application and suitability of existing and new valves at various function points throughout the power generation system is outlined and explained. The paper does a good job of reducing the complicated issue into a few pages of direct understandable explanation.
World Energy Situation and 21st Century Coal PowerJeffrey Phillips
An overview of the current power market in the US and the impact it may have on other parts of the world. This was first presented at a workshop held at the University of Tokyo in Japan on Feb 25, 2014
The Carbon Nexus - Boilers, Power Plants, and Strategic Energy ManagementVeritatis Advisors, Inc.
Lender, Insurers, manufacturers, regulators lack standardized methods to gauge the accuracy of predicted energy consumption thus financial savings from energy efficiency upgrades. This presentation captures the nexus of relevant issues in recently published case study and market experience. Author Don Macdonald of Veritatis Advisors, 2015
Currently, the quality of wind measure of a site is assessed using Wind Power Density (WPD). This paper proposes to use a more credible metric namely, one we call the Wind Power Potential (WPP). While the former only uses wind speed information, the latter exploits both wind speed and wind direction distributions, and yields more credible estimates. The new measure of quality of a wind resource, the Wind Power Potential Evaluation (WPPE) model, investigates the effect of wind velocity distribution on the optimal net power generation of a farm. Bivariate normal distribution is used to characterize the stochastic variation of wind conditions (speed and direction). The net power generation for a particular farm size and installed capacity are maximized for different distributions of wind speed and wind direction, using the Unrestricted Wind Farm Layout Optimization (UWFLO) methodology. A response surface is constructed, using the recently developed Reliability Based Hybrid Functions (RBHF), to represent the computed maximum power generation as a function of the parameters of the wind velocity (speed and direction) distribution. To this end, for any farm site, we can (i) estimate the parameters of wind velocity distribution using recorded wind data, and (ii) predict the max- imum power generation for a specified farm size and capacity, using the developed response surface. The WPPE model is validated through recorded wind data at four differing stations obtained from the North Dakota Agricultural Weather Network (NDAWN). The results illustrate the variation of wind conditions and, subsequently, its influence on the quality of a wind resource.
The U.S. power generation fuel mix continues to shift, driven in part by low natural gas prices, state renewable mandates, tightening environmental regulations, and lower installed costs of some generation technologies such as solar. On June 18, 2014, the U.S. Environmental Protection Agency (EPA) issued its proposed Clean Power Plan (CPP), a proposed greenhouse gas emissions regulation scheme for existing plants, promulgated under section 111(d) of the Clean Air Act.
In this update, readers will see the latest legal developments and timelines under key EPA- proposed regulations, a brief overview of EPA’s Clean Power Plan and related state emissions reduction goals, and recent developments and open issues.
For more information, please visit www.scottmadden.com.
The application and suitability of existing and new valves at various function points throughout the power generation system is outlined and explained. The paper does a good job of reducing the complicated issue into a few pages of direct understandable explanation.
World Energy Situation and 21st Century Coal PowerJeffrey Phillips
An overview of the current power market in the US and the impact it may have on other parts of the world. This was first presented at a workshop held at the University of Tokyo in Japan on Feb 25, 2014
The Carbon Nexus - Boilers, Power Plants, and Strategic Energy ManagementVeritatis Advisors, Inc.
Lender, Insurers, manufacturers, regulators lack standardized methods to gauge the accuracy of predicted energy consumption thus financial savings from energy efficiency upgrades. This presentation captures the nexus of relevant issues in recently published case study and market experience. Author Don Macdonald of Veritatis Advisors, 2015
Currently, the quality of wind measure of a site is assessed using Wind Power Density (WPD). This paper proposes to use a more credible metric namely, one we call the Wind Power Potential (WPP). While the former only uses wind speed information, the latter exploits both wind speed and wind direction distributions, and yields more credible estimates. The new measure of quality of a wind resource, the Wind Power Potential Evaluation (WPPE) model, investigates the effect of wind velocity distribution on the optimal net power generation of a farm. Bivariate normal distribution is used to characterize the stochastic variation of wind conditions (speed and direction). The net power generation for a particular farm size and installed capacity are maximized for different distributions of wind speed and wind direction, using the Unrestricted Wind Farm Layout Optimization (UWFLO) methodology. A response surface is constructed, using the recently developed Reliability Based Hybrid Functions (RBHF), to represent the computed maximum power generation as a function of the parameters of the wind velocity (speed and direction) distribution. To this end, for any farm site, we can (i) estimate the parameters of wind velocity distribution using recorded wind data, and (ii) predict the max- imum power generation for a specified farm size and capacity, using the developed response surface. The WPPE model is validated through recorded wind data at four differing stations obtained from the North Dakota Agricultural Weather Network (NDAWN). The results illustrate the variation of wind conditions and, subsequently, its influence on the quality of a wind resource.
Technical background a potential new regulations for limiting greenhouse gas emissions (i.e. methane) from proposed new LNG export facilities in Nova Scotia--should those facilities get built.
Final Seasonal Assessment of Resource Adequacy for the ERCOT Region, Summer 2...EPIS Inc
ERCOTS's preliminary assessment of resource adequacy for the ERCOT region in Summer of 2015. This was originally posted on May 4, 2015 on www.ercot.com. A percentage and a section of text is quoted.
A consultation paper and request for feedback on a proposed new set of regulations limiting greenhouse gas emissions (i.e. methane) from proposed new LNG export facilities in Nova Scotia--should those facilities get built.
Addressing RE Intermittency and Operation Aspects of Generating Units in Long...IEA-ETSAP
Addressing RE Intermittency and Operation Aspects of Generating Units in Long-term System Planning of Indian Power Sector
Anjali Jain, Malaviya National Institute of Technology, India
Wind power forecasting an application of machineJawad Khan
The advancement in renewable energy sector being the focus of research these days, a novel neuro evolutionary technique is proposed for modeling wind power forecasters.
The work uses the robust technique of
Cartesian Genetic Programming to evolve ANN
for development of forecasting models.
These Models predicts power generation of a wind based power plant from a single hour up to a year - taking a big lead over other proposed models by reducing its MAPE to minimum values for a single day hourly prediction.
Results when compared with other models in the literature demonstrated that the proposed models are among the best estimators of wind based power generation plants proposed to date.
Industrial Sector in Jordan– Energy Use Current Status and Future OpportunitiesSamer Zawaydeh
Industrial Sector Energy Use Current Status and Future Opportunities in Jordan. This includes Electricity Tariffs, Opportunities for Electricity Saving, Stakeholders, Barriers for improvement, type of renewable energy and energy efficiency opportunities in the industrial sector.
Technical background a potential new regulations for limiting greenhouse gas emissions (i.e. methane) from proposed new LNG export facilities in Nova Scotia--should those facilities get built.
Final Seasonal Assessment of Resource Adequacy for the ERCOT Region, Summer 2...EPIS Inc
ERCOTS's preliminary assessment of resource adequacy for the ERCOT region in Summer of 2015. This was originally posted on May 4, 2015 on www.ercot.com. A percentage and a section of text is quoted.
A consultation paper and request for feedback on a proposed new set of regulations limiting greenhouse gas emissions (i.e. methane) from proposed new LNG export facilities in Nova Scotia--should those facilities get built.
Addressing RE Intermittency and Operation Aspects of Generating Units in Long...IEA-ETSAP
Addressing RE Intermittency and Operation Aspects of Generating Units in Long-term System Planning of Indian Power Sector
Anjali Jain, Malaviya National Institute of Technology, India
Wind power forecasting an application of machineJawad Khan
The advancement in renewable energy sector being the focus of research these days, a novel neuro evolutionary technique is proposed for modeling wind power forecasters.
The work uses the robust technique of
Cartesian Genetic Programming to evolve ANN
for development of forecasting models.
These Models predicts power generation of a wind based power plant from a single hour up to a year - taking a big lead over other proposed models by reducing its MAPE to minimum values for a single day hourly prediction.
Results when compared with other models in the literature demonstrated that the proposed models are among the best estimators of wind based power generation plants proposed to date.
Industrial Sector in Jordan– Energy Use Current Status and Future OpportunitiesSamer Zawaydeh
Industrial Sector Energy Use Current Status and Future Opportunities in Jordan. This includes Electricity Tariffs, Opportunities for Electricity Saving, Stakeholders, Barriers for improvement, type of renewable energy and energy efficiency opportunities in the industrial sector.
An update on regulatory options for emergency engines providing emergency demand response after the May 2, 2016 Vacatur from the U.S. Court of Appeals for the D.C. Circuit
ScottMadden recently joined industry leaders as a sponsor and presenter at Infocast’s 19th Annual Transmission Summit. Here, Todd Williams, partner and fossil practice co-leader at ScottMadden, reviewed the generation landscape and the impacts of the Clean Power Plan.
To learn more, please visit www.scottmadden.com.
Details regarding the 2012 U.S. EPA Air Regulatory Agenda: regulatory proposals regarding greenhouse gases, startup / shutdown / and malfunctions, hazardous air pollutants, new source performance standards, and ozone.
BlueScape Air Quality in 2015: What You Need to Know Webinar 2-10-15BlueScape
This webinar by James Westbrook at BlueScape describes air quality regulations and policies that will impact US businesses in 2015. Mr. Westbrook can be reached at 877-486-9257 for more information. For a video presentation go to http://youtu.be/Ot9B6lA_V0U.
Todd Williams, partner and fossil practice co-leader at ScottMadden, recently presented at the EnergyHub GenForum on the EPA’s CPP, one of the most significant environmental mandates in U.S. history. Here, he gave an overview of the requirements and impacts of the CPP. He also recapped events now unfolding in CPP litigation, politics, and legislation. Where are the battle lines drawn? Who is on what side? And, what are states doing to prepare their compliance plans?
For more information, please visit www.scottmadden.com.
In June 2010, EPA proposed a rule to regulate coal combustion residuals (“CCRs”) under the Resource Conservation and Recovery Act (RCRA). After a lengthy delay, the proposed rule, which set forth two options for the regulation of CCRs, is expected to be finalized by the end of this year.
This presentation describes the federal incentives under the Stimulus Bill for renewable energy, energy efficiency, carbon capture and storage, and alternative transportation fuels. There are significant incentives available for these and other related developing technologies and companies engaged in these projects.
Surviving And Prospering In A Carbon Constrained Economyscottdeatherage
How do companies survive and prosper in an emerging carbon constrained economy? This presentation describes the developing greenhouse gas regulatory program developing in the United States at the state and federal level. It then describes how companies can survive and prosper with the dramatic changes that are occuring that will restrict greenhouse gas emissions across the country.
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Greenhouse Gas Limits on New Electric Generating Units
1. Applying our technical expertise
to a more sustainable world…
While every effort has been made to ensure the accuracy of this information, SC&A is not
responsible for any errors or omissions. This information is not a substitute for professional
environmental consulting services. If legal services are required, consult with legal counsel.
Greenhouse Gas Limits on New Electric
Generating Facilities: First Strike
While every effort has been made to ensure the accuracy of this information, SC&A is not
responsible for any errors or omissions. This information is not a substitute for professional
environmental consulting services. If legal services are required, consult with legal counsel.
Andrew D. Shroads, QEP
Regional Director
P.O. Box 1276 • Westerville, OH 43086
) (614) 887-7227 • 8 ashroads @ scainc.com
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Power Plant Greenhouse Gas Timeline
Feb 27, 2006: 40 CFR 60, Subparts Da, Db, & Dc Amended
• “EPA has concluded that it does not presently have the
authority to set NSPS to regulate CO2”
• 11 states, 2 cities, and 3 environmental groups sued
Apr 2, 2007: Massachusetts v. EPA: EPA must determine
whether greenhouse gases (GHGs) are an air pollutant
Dec 7, 2009: Endangerment Finding establish GHGs as
air pollutants
Dec 30, 2010: EPA settles lawsuit by agreeing to issue a
proposed GHG electric generating unit (EGU) rule
by Jul 26, 2011 and a final rule by May 26, 2012
Apr 13, 2012: EPA proposes a new source performance
standard (NSPS) for GHGs from new fossil fuel-fired EGU
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Proposed EGU GHG Regulation
Applies to fossil fuel-fired EGUs >25 megawatt electric (MWe)
Emissions limit of 1,000 pounds of CO2 per megawatt-hour (lb
CO2/MWh), as a 12-operating month annual average
Emissions limit based on emissions analysis of natural gas
combined-cycle (NGCC) plants
For all other fossil fuels, proposal would require
carbon capture and storage (CCS) technology
• There are no currently operating commercial
grade CCS operations on any U.S. Power Plants
30-year averaging option for coal and petcoke CCS units
• 1,800 lbs. CO2/MWh for the first 10 years
• 600 lbs. CO2/MWh for the remaining 20 years
• Longest compliance demonstration period ever for EPA
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Proposed EGU GHG Regulation Follow-up
Proposed rule had 2,682,625 comments
“Most Comments for an EPA Proposed Rule”
• Final rule was expected on Apr 13, 2013
EPA received three notices of intent to sue for failing to issue
a final rule from 3 environmental groups, 10 states, 2
cities, and the Conservation Law Foundation
• 21 other states attorneys general asked EPA not to settle
• All three groups delayed filing a lawsuit, due to upcoming
Administration announcement on climate change
President Obama detailed his Climate Action Plan during a
speech on Jun 25, 2013
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I. Cutting Carbon Pollution
Deploying Clean Energy
• Cutting Carbon Pollution
from Power Plants
• Promoting Renewable Energy
• Clean Energy Innovation
21st Century Transportation
Cutting Waste Energy
Reducing Other GHG Emissions
Federal Initiatives (E.O. 13514)
The President’s Climate Action Plan
“I’m directing the Environmental Protection Agency to put an
end to the limitless dumping of carbon pollution from our
power plants and complete new pollution standards for both
new and existing power plants.” - President Obama, 6/25/2013 5
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EPA Response
EPA has submitted a new draft of the proposed EGU GHG rule
to the Office of Management and Budget (OMB)†
• Proposed rule is being reviewed by Federal agencies for
comment before being issued
What is in the proposed rule? Only EPA knows.
Best guesses:
• If continuing with one limit for all fuels,
a new proposed rule would not be necessary
• NGCC remains the lowest GHG emitter
• CCS remains the only likely option for fossil-fuel fired EGUs
• A new proposed rule could set a new applicability date
(e.g. June 12, 2006 expansion of the RICE NESHAP)
†“EPA sends climate rule to White House.” Politico. 1 July 2013.
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The President’s Memorandum to EPA
On Jun 25, 2013 President Obama wrote a memorandum to EPA
directing them to implement his Climate Action Plan with the
following directions:
Sep 20, 2013: Issue another proposed rule for GHGs from
new EGUs (and issue final rule in a “timely fashion”)
Jun 1, 2014: Issue proposed rule for GHGs from existing,
modified, and reconstructed EGUs
Jun 1, 2015: Issue final rule for existing, modified, and
reconstructed EGUs
Jun 30, 2016: States must submit state implementation plan
(SIP) for existing, modified, and reconstructed EGUs
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Next Steps
EPA will issue proposed rule limiting GHGs from new EGUs
EPA will issue final rule
• Lawsuits will be filed by environmental
groups, industry, and states
EPA will issue proposed rule limiting GHGs from
existing, modified, and reconstructed EGUs
EPA will issue final rule
• More lawsuits will be filed
EPA will use lessons learned from implementing mercury
standards and its 14-year new source review investigation
into coal-fired power plants to implement an EGU GHG NSPS.
“The coal-fired power plant industry is an EPA national
enforcement priority.” EPA Enforcement Website
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Unintended Consequences
The EGU NSPS will be the first federal air regulation providing
an emissions limit and/or control requirement for GHGs
This will have a profound affect on the Title V permit program
• The GHG Tailoring Rule only established a separate Title V
major source applicability threshold for GHGs
(Required to calculate facility-wide GHG potential-to-emit)
• The EGU NSPS would automatically reclassify GHGs as a
“regulated air pollutant,” used to define emissions units
(Required to calculate GHG for each emissions unit)
From 40 CFR 70.2 – Regulated Air Pollutant:
(3) Any pollutant that is subject to any standard
promulgated under section 111 of the Act ...
(enabling legislation for NSPS)
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GHGs as Regulated Air Pollutants
A Title V permit application must contain:
All emissions of regulated air pollutants
Details on each emissions unit (equipment that emits
regulated air pollutants), such as:
1. All emissions of a regulated air pollutant;
2. All emissions egress points (e.g. stacks);
3. Emissions rates;
4. Process rates, operating schedules, flow rates; and
5. Control equipment.
Listing of insignificant emissions units
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Title V Permit for GHG Emissions Unit
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Since there are no GHG limits
or control requirements for
anything other than
EGUs, there would be no
restrictions in the Title V
permit. A blank page would be
issued for an emissions unit
that only emitted GHGs and is
not regulated by the EGU
NSPS.
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Potential GHG Emissions Units
Many sources of GHG emissions are not in a Title V permit, as
GHGs are not considered a regulated air pollutant. After the EGU
NSPS is issued, some of the following sources of GHGs would be
considered emissions units:
Transformers (Sulfur Hexafluoride [SF6])
Electrical Equipment (Perfluorocarbons [PFC] or SF6)
Refrigeration Equipment (Hydrofluorocarbons [HFC])
Air Conditioning Equipment (HFC)
Fire Suppression Systems (HFC or PFC)
Industrial Wastewater Treatment (Methane [CH4])
Liquified Industrial Chemicals (Carbon Dioxide [CO2])
Geologic Sequestration of CO2 from CCS (CO2)
Industrial Waste Landfills (CH4)
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Some Questions to Ponder
When is an updated permit application required?
(Effective date of the EGU NSPS or permit renewal date)
How should GHG emissions be calculated?
(GHG leaks from air conditioning equipment)
How should GHG emissions be reported?
(By individual GHG or in carbon dioxide equivalents [CO2e])
Should insignificant emissions units that emit a significant
amount of GHG be reclassified as significant emissions units?
Does the state Title V application computer program allow for
GHG emissions to be included for emissions units?
Would EPA amend the Title V regulations so that insignificant
includes GHG emissions units not otherwise regulated?
(Reducing paperwork for the Title V permit “blank page”)
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Any Questions?
Andrew D. Shroads, QEP
Regional Director
P.O. Box 1276 • Westerville, OH 43086
) (614) 887-7227 • 8 ashroads @ scainc.com
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