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 10:00 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 PM2.5,
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
COAL WORLD
GAS / OIL - US
GAS / OIL - WORLD
CO2
NUCLEAR
BUSINESS
HOT TOPIC HOUR
For more information on the Utility Environmental
Upgrade Tracking System, click on:
http://www.mcilvainecompany.com/brochures/energy.html#42ei.
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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
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Company. All Rights Reserved
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