·        Utility MACT  Pre Comment Webinar on June 9 Will be Free

·        Utility E Alert - May 27, 2011         Headlines                               

·        Status and Technology of Solar Power Generation

Utility MACT Pre Comment Webinar on June 9 will be free

Next week we are opening the hot topic to non-members as part of a collaborative initiative to review aspects of the Utility MACT rule (while there is still time to submit comments to EPA). You can join us at 10 a.m. Thursday, June 9 REGISTRATION:  http://www.mcilvainecompany.com/brochures/hot_topic_hour_registration.htm.

The one to two hour session will be unstructured other than the introduction of topics. We are relying on the participants to bring up their questions and also to provide some of the answers.

Debbie Fox joined the McIlvaine Company several years ago. She is an environmental attorney and engineer and has been reviewing all the analyses used by EPA to support the requirements. She has uncovered a number of inconsistencies she will share.  One has to do with the number of plants likely to be retired because of the rule.

Will Dry Sorbent Injection be the answer for HCl removal?

The analysis relies heavily on injection of dry sorbent for HCl removal. Can this technology meet the efficiency needs?  Conversely, will the SO₂ also be removed?  Some are arguing that injection can be tailored to remove the HCl and not take out all the SO₂ upon which EPA relies for the cost benefits. Is DSI a short-term solution only to be obsolesced by ambient PM_2.5, and SO₂ limits?

How many coal plants will be retired because of the rule?

EPA greatly underestimates the number of retirements, due to incorrect assumptions regarding the use of DSI and cost of upgrading existing FGD equipment.  A number of errors and inconsistencies throughout the rulemaking make EPA's projections even more questionable.  For example, in the Preamble and Regulatory Impact Analysis, EPA's says there will be 9.9 GW of retirements.  In a background document listing the retired units, there are 11,440 MW listed.  Of the 11,440 MW:

-- 6,212 MW (over half) are not in EPA's comprehensive database of coal-fired units (referred to as the NEEDs database).

-- 4 units totaling 224 MW were retired in the 1990's (Watts Bar in Tennessee) others may have been retired for some time as well.

-- 8 units are below 25 MW and wouldn't be subject to the rule anyway. 

With the recent nuclear disaster and revelations about high methane emissions from gas turbine units there is increased concern about loss of coal-fired electrical capacity.

What are the concerns about organics and CO?

In our February hot topic hour Robert (Bob) Fraser, QEP, Senior Technical Director for Power Generation Services at AECOM Environment,  expressed concerns  that an organics limits for both the Industrial and Utility MACT may be inversely rather than directly proportional to the CO. During start up and shut down there are high levels of CO and this could be a problem. It may be better to address dioxins and furans under work practice standards rather than limits.

Can particulate limits be achieved?

In our February Hot topic hour Ajay Kasarabada, an Air Permitting Manager in Black & Veatch Energy Division's Environmental Management Services Section, and Diane Fischer, Manager of Business Development for Air Quality Control Projects for Black & Veatch's Power Generation Services, focused on the key issues to be considered in developing a Utility MACT compliance strategy and the technologies that can be utilized to achieve compliance with the expected limits. There was concern about the ability to meet the particulate standards. There was also the advice to take into account the ramifications relative to other rules such as applicable renewable portfolio standards, the transport rule, regional haze, non-attainment and greenhouse gas regulations.

Can total particulate be accurately and consistently measured?

There are really two issues here. One is accuracy and another is consistency. Some present methods are consistent and reproducible but they may not be accurate because some SO₂ becomes absorbed and counted as condensable particulate.  Other methods may be more accurate but have not been standardized. So there is no ability to consistently report total particulate including condensibles.

Mass monitors will be required. In South Korea the switch to mass monitors resulted in big increases in reported emissions.  Will the same occur under this rule?  Mass monitors only measure discrete particulate. So we have two new challenges: a new way to measure discrete particles and the need to measure condensibles.  Are we ready to do this?

Can mercury be accurately and consistently measured?

We now have lots of mercury CEMS in operation. How reliable are they? Is there a difference between consistency and accuracy?  If one adds the error potential in the protocol gases, variations in the processes, instrument limitations, and the fact that particulate mercury is not measured, how accurate will be the reported emissions?

These are just a few of the many questions which can be discussed. We hope you will join us next week for this important session.

-------------------

Here are the Headlines for the May 27, 2011 - Utility E Alert

UTILITY E-ALERT

#1026 - May 27, 2011

Table of Contents

COAL - US

• EPA Admits Making Math Error in MACT Proposal
• Wyandotte Plans to Reduce Emissions by Adding $10 Million Baghouse
• Navajo Coal-fired Power Plant focus of Congressional Hearings
• Duke to shut Two Units at Gallagher, Buy Share of Vermillion
• Opposition to SWEPCO Hempstead County Power Project must appeal to Arkansas PSC

COAL WORLD

• ITOCHU is Awarded CFB Power Plant Project in Tufanbeyli, Turkey
• Advisers for Dubai Coal-fired Power Station Selected
• SRM Energy Receives Environment Clearance Approval for 1980 MW Power Project
• Victoria EPA, (Australia) Approves 300 MW IGCC Power Plant
• Adaro Energy, Itochu and Electric Power Development to Build 2x1000 MW Power Plant in Central Java, Indonesia
• Adani Group plans 1320 MW Power Project in Bihar, India
• European Court says Permits for Three Coal-fired Power Projects in the Netherlands are in Order

GAS / OIL - US

• California Commission Approves Construction of Two Gas-fired Power Plants
• SDG&E Proposes Adding 450 MW of Local Peaking Power

GAS / OIL - WORLD

• MHI to Supply Combined Cycle Equipment to POSCO Pohang Works in South Korea
• Sweco to Supervise the Rehabilitation of Three CHP Plants in Moscow
• STX Wins Diesel-fired Power Plant Deal in Iraq
• EGAT to Expand Three Gas-fired Power Plants
• 1500 MW Hassyan Power and Desalination Project in Dubai out for Bids

CO₂

• SCS Energy Agrees to Take Over California Hydrogen/CCS Project
• Italian Council Halts Enel's CCS Project at Porto Tolle
• Doosan Power Awards Control Contract for Ferrybridge CCS Project to Emerson 
• MBD Energy Installs Algae System to Capture CO₂ in Australia
• Texas House Asks Congress to Keep USEPA from Regulating Greenhouse Gases in the State

NUCLEAR

• Swiss to Phase out Nuclear Power
• China could build Nuclear Power Plant in East Africa

BUSINESS

• Siemens Gas-fired Turbine reaches 60 Percent Efficiency
• GE Says New Gas Turbine Works in Conjunction with Wind, Solar Generation Gear
• B&W to build Boilers in India
• Exelon/Constellation to sell Brandon Shores, HA Wagner and CP Crane
• Unconventional Fuels Market for Filtration and Flow is $3.4 Billion
• 10 Largest Air Quality Challenges for Power Plant Operators

HOT TOPIC HOUR

• Status and Technology of Solar Power Generation
• "Valves for Power Plant Steam and Water Applications" is Hot Topic on June 2, 2011
• June 9 will be a Collaborative Session on Utility MACT Problems
• Upcoming Hot Topic Hours

For more information on the Utility Environmental Upgrade Tracking System, click on: http://www.mcilvainecompany.com/brochures/energy.html#42ei.

--------------------

Status and Technology of Solar Power Generation

"Status and Technology of Solar Power Generation" was the subject of the Hot Topic Hour held on May 26, 2011.  Five speakers provided a balanced overview of the subject.

Bart Krishnamoorthy of the Solar Electric Power Association opened the session by explaining efficiency and cost of the different types of PV. While thin film solar is less expensive than conventional solar cells it also less efficient.

He divided the PV market applications into three segments; residential, commercial and utility scale. Residential systems are generally less than 10 kW, commercial installations range from 10 kW to 2 MW and utility scale installations are larger than 5 MW.

In 2010 utilities installed 782 MW-ac of solar power. 705 MW of that was PV. This brought the total installed amount of solar energy to 2128 MW-ac of that 1,627 MW was PV. While Pacific Gas & Electric Co. installed the most MWs in 2009 Southern California Edison has the most total MWs installed. Florida Power & Light installed the largest project in 2010 with the Martin Solar Center at 75 MW.

Krishnamoorthy says there were three stages of market development. The first being customer owned, net metered projects. The second being industry driven, net metered projects. The third was utility driven projects at utility scale and utility value.

Two speakers from Burns and McDonnell gave the second presentation. Matthew Brinkman explained the RPS standards enacted by various states are driving utilities toward solar energy. Regulatory uncertainty is another driver.

Brinkman said that more PV projects are being installed than solar thermal projects because the financing is better understood for this type of project. Scalability is another reason PV is more popular than CSP. Solar thermal projects require the entire steam cycle therefore 50 MW is the smallest system that makes economic sense.

Peter Johnston continued the presentation by comparing the project attributes of PV and solar thermal. He did this by using a traffic light system with red, yellow and green lights. PV was a definite winner in this chart in areas of land use, brown fields, water use and cost. Five or 6 acres/MW are required for PV and 7 or 8 acres/MW are required for solar thermal. Costs for PV were given as $3-4/watt for PV and $4-5/watt per solar thermal. The next traffic light chart compared the operational attributes of the two systems. In this area solar thermal was the clear winner in the areas of cloud ride-through and despatchability.

Recent loan guarantees have spurred the development of solar thermal plants. The opening of federal lands by the Bureau of Land Management has also been a driver. Another area of interest is the combination of solar thermal plants with fossil fired plants.

Paula Mints of Navigant Solar Services described the dramatic growth of the solar industry with a compound annual growth of 65 percent between 2005 and 2010 but pointed out that before 2004 no one made money in the industry. At the present time margins are difficult and competition is fierce. Eighty-nine percent of the present market is in Germany. Since the market for all solar technologies into the grid connected application is incentive driven this means that 97 percent of the market is vulnerable.

Mints stressed the main advantage of PV over CPV and CSP is that it's cheap. Prices have fallen dramatically since 1989. In the CSP area lots of GWs are announced but she predicted approximately 60 percent will not come to pass because of cost and interference from outside parties. In the CPV area announcements total approximately 2 GWp. Her accelerated forecast for 2011 through 2015 for CPV was for 1 GWp_. Her conservative forecast for CPV was for 530 MWp_.

Mints concluded by saying, "Let's not count our megawatts before they are connected to the grid because we will have to get used to lower or perhaps no incentives in just a few years."

Joseph Bessler gave a very detailed explanation of the California Solar Utility Market. On April 12, 2011 Governor Brown signed legislation requiring all Investor owned Utilities (IOU) to procure renewable energy in the amount of thirty-three percent of retail sales by 2020.

In California there are two types of solar utilities - Investor Owned regulated by the California Public Utilities Commission (CPUC) and Public Owned (aka Municipals) with publically elected boards not regulated by the CPUC. Investor Owned Utilities have two types of programs one where the project is owned by the utility and RFOs (Request for Offer) where the utility just buys the power. With standard RFO Projects the term is 20 years, a third party is paid the bid price, the energy price is determined by the bid, all bids must be approved by the CPUC and the utility does not have to accept the project. Large scale projects are a separate procurement process.

John King of Combined Power Cooperative provided a perfect end for the session by describing areas for improvement in solar systems. First he also stressed the idea that many of the projects under development will never be build. He reinforced this point by explaining that if all the announced projects were built they would consume about 1.2 percent of total US steel production per year just for CSP in California for the next nine years. For comparison he said US steel consumption for cars is 11 percent.

King provided a capital cost breakdown for CSP plants. The two most expensive items are Solar Field and Thermal Energy Storage. The cost components of the solar field are the reflector system and the receiver system. Polymer reflectors are under development and he said suppliers to watch in this area are Reflectech and 3M. Users of polymer reflectors are CoolEarth and Helioviz AG.  In the area of receiver systems SunDrop is working on the direct conversion of biomass to biogas, Arizona State University is studying nanofluids and air was suggested as a working fluid. Interesting things to watch in the area of thermal storage is SandShifter, a cheap and widely available medium. Concrete storage was also suggested. DOE is funding a lot of work in this area.

King concluded with the reminder that water is always an issue especially since the areas with the greatest amount of sunlight tend to be the ones with the least amount of water.

Further details may be found at:

http://www.mcilvainecompany.com/brochures/Renewable_Energy_Brochure/renewable_energy_WM_brochure.htm

--------------------

You can register for our free McIlvaine Newsletters at: http://www.mcilvainecompany.com/brochures/Free_Newsletter_Registration_Form.htm

Bob McIlvaine
President
847 784 0012 ext 112

rmcilvaine@mcilvainecompany.com