Impact of Ambient Air Rules for PM2.5 and Ozone is Hot Topic on Dec. 9th and
10th, 2010
NOTE: Because of the strong interest in this subject and the number of speakers,
we have split this Hot Topic Hour into two sessions. Persons that register for
the Hot Topic Hour will be able to attend both sessions.
A recent report by the North American Electric Reliability Corp. (NERC)
concluded that coming federal environmental regulations to improve water and air
quality could chop by nearly half the amount of projected reserve energy
available to the U.S. power grid by 2018. Nationwide, hundreds of coal-, oil-,
and gas-fired power plants, with a collective capacity of about 76,000 MW, could
be retired if the rules are implemented under the fastest proposed timeline. In
addition, major utilities have indicated that because of the costs for meeting
the expected regulations they may defer coal-fired power projects in the U.S.
and build gas-fired power plants should the price of gas remain stable.
With the Republicans now in control of the House, we can expect that action on
GHG regulations and the Clean Air Act will slow and that any forthcoming
legislation will be less onerous than previously anticipated. However, other
rules currently moving through the EPA process will continue basically as
originally proposed. EPA’s proposal to set the air-quality standard for ozone at
between 60 and 70 parts per billion, compared with 75 parts per billion
currently and the new 24-hour fine particle PM2.5 National Ambient Air Quality
Standards (NAAQS) of 35µg/m3 that became effective in December 2009 will have
serious consequences for coal-fired power plants.
In a Hot Topic Hour in April of this year, we heard six very knowledgeable
speakers address the problems and costs associated with these regulations. Colin
T. McCall, of All4, Inc., observed that the proposed health-based NAAQS are
extremely stringent and will make it increasingly difficult to obtain approval
for new facilities or for existing facility expansion and modernization
projects. Gale F. Hoffnagle, of TRC Environmental Corporation, stated that
photochemical modeling of PM2.5 is likely to be necessary to permit any new
construction due to the secondary particle creation of SO2 and NOx and that this
modeling will be exceedingly difficult. All agreed that most coal-fired power
plants will need to add baghouses and perhaps additional control equipment at
considerable expense.
Because of the strong interest in this subject, we will be conducting another
Hot Topic Hour on the “Impact of Ambient Air Rules for PM2.5 and Ozone on
Coal-fired Power Plants” on Thursday and Friday, December 9th and 10th, 2010.
The following speakers will discuss the impact of the coming regulations on
coal-fired power plants, their current experience with the measurement and
control of fine particulates and ozone precursors, and the various options
available to comply with the proposed regulations including fuel switching, with
a discussion of the advantages or disadvantages of the options for specific
plant configurations and operating conditions.
Speakers on Thursday, December 9th will be:
Robert (Bob) Paine, Technical Director of AECOM Environment, will discuss the
effect of tighter ambient standards for PM2.5 and ozone on permitting of new
sources. In addition, the effect of an expansion of nonattainment areas on
existing sources will be reviewed. Each nonattainment area and changes to the
State Implementation Plan requires considerable investment by stakeholders to
assure that their interests are protected when reviewing agencies are looking
for emission reductions to bring these areas into modeled attainment.
John Kinsman, Senior Director Environment at Edison Electric Institute. EPA is
actively engaged in setting new NAAQS for ozone, PM, SO2 and NO2. EPA activities
in standard setting and implementation will be overviewed, as well as the
impacts of the new standards on power generators.
Katherine (Kate) L. Vaccaro, Associate at Manko, Gold, Katcher & Fox LLP, an
Environmental Law Firm, will address the NAAQS for PM2.5 and ozone, focusing on
state-level implementation of the federal New Source Review (NSR) requirements
for PM2.5. In particular, she will discuss certain challenges faced by owners
and operators of fossil fuel-fired power plants and other industrial facilities
located in states seeking to institute PM2.5 NSR regulations that are more
stringent than the federal standards, evaluating both practical and economic
feasibility considerations. She will also discuss how these challenges affecting
the power production sector may be compounded by other air quality regulations
being developed by EPA, including the new proposed rule to reduce Interstate
Transport of Fine Particulate Matter and Ozone, which would impose stringent
emission limits for NOx and SO2 on affected electric generating units.
Speakers on Friday, December 10th will be:
Kevin Crosby, Technical Director of The Avogadro Group, LLC, will describe the
new PM2.5 stationary source sampling methods and discuss how the collection
technique varies from the ambient sampling methodology and how these new
sampling methodologies for PM2.5 might or might not improve the results for
stationary sources. Utilities and other types of source owners have shown great
interest on how the new sampling methodologies might impact their TSP/PM10/PM2.5
results, and how this compares to what the ambient samplers collect. The new
sampling method re-defines what is considered to be PM2.5. This will have an
impact on abatement equipment selection and will be a great fit for the
measurement of fine particulate sub-topic.
Sonja Sax, Environmental Health Scientist and Senior Associate at Gradient
Corporation, will provide an update of the new proposed PM and Ozone NAAQS. The
National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) are
currently undergoing regulatory review and the ozone NAAQS are being
reconsidered. The U.S. EPA is recommending lowering both the PM and the ozone
NAAQS despite considerable uncertainties associated with the underlying studies
used to support these efforts. Sonja will present an update of the review
process and uncertainties in the supporting evidence, and the possible
implications of lower PM and ozone standards for point sources such as
coal-fired power plants.
Colin McCall, Manager of the Ambient Group of All4, Inc. Within the past two (2)
years, the U.S. EPA has promulgated/proposed a 1-hour NO2 National Ambient Air
Quality Standard (NAAQS), a 1-hour SO2 NAAQS, and a revised 8-hour ozone NAAQS.
In addition, U.S. EPA has finalized new source review (NSR) regulations related
to the annual and 24-hour PM2.5 NAAQS. These new health-based NAAQS are
extremely stringent and will make it increasingly difficult to obtain approval
for new facilities or for existing facility expansion and modernization
projects. Now, more than ever, the NAAQS and the associated air dispersion
modeling requirements in both attainment and nonattainment areas will dictate
the viability of new projects and the way that new projects are designed.
Facilities may also be impacted by the new NAAQS levels even in the absence of a
new project. This presentation will provide an update on the new NAAQS levels
and their impact on power plants, including recommendations on how to plan for
the NAAQS implementation strategies that U.S. EPA has outlined over the last
several months for pollutants such as SO2.
To register for the "Hot Topic Hour" on December 9 and 10, 2010 at 10 a.m. CST
(Chicago time), click on: on: http://www.mcilvainecompany.com/brochures/hot_topic_hour_registration.htm
Bob McIlvaine
President
847 784 0012 ext 112
rmcilvaine@mcilvainecompany.com
www.mcilvainecompany.com