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Recommendations for Potential Actions By MassDEP For Winter 2005/06 With Respect to Electricity Generation

Recommendations for Potential Actions By MassDEP For Winter 2005/06 With Respect to Electricity Generation. Don DiCristofaro Blue Sky Environmental LLC. NECA. Northeast Energy and Commerce Association Recommendations Compiled From NECA Environmental Committee

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Recommendations for Potential Actions By MassDEP For Winter 2005/06 With Respect to Electricity Generation

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  1. Recommendations for Potential Actions By MassDEP For Winter 2005/06 With Respect to Electricity Generation Don DiCristofaro Blue Sky Environmental LLC

  2. NECA • Northeast Energy and Commerce Association • Recommendations Compiled From NECA Environmental Committee • 8 Proactive and Last Resort Recommendations • No Single Regulatory Decision Works For All Sources

  3. Clarify “Unavailable” • Many Dual-Fueled Units Permitted to Burn Oil for Specified Number of Hours Regardless of Availability of Natural Gas • Some Air Permits Only Allow Oil Combustion When Gas Is “Unavailable”

  4. Oil Procurement Flexibility • Many Units Require Use of 0.05% S Oil • In Winter, Distillate Oil (0.3% S) Is More Readily Available • Allow Generators To Only Meet Annual Sulfur Limits • Waive Short Term and Sulfur Fuel Specs During Winter

  5. Maximize Use of Oil-Fired Resources • Allow Use of Higher S Fuel Under OP 21 • Allows More Transportation Grade Fuel Available for Other Uses • Allows More Natural Gas Available

  6. Ammonia Feed on Natural Gas-Fired Units • Intermittent Burning of Oil on Gas-Fired Units Causes Back End Fouling • Under OP-21 Conditions, Allow Ammonia Feed Systems To Be Discontinued • Facility Still Subject to Maintaining Annual NOx Increases < 25 tpy

  7. Short-Term Opacity Exemption • Some Facilities Using Fuel Selection, Co-Firing With Gas, or Fuel Blending to Meet Opacity Limits • Under OP-21, Suspend Short-Term Opacity Limits

  8. Relief From Carbon Emissions • CO2 Limitations Effective 1/06 For Six Facilities • Significant Disincentive to Operate At Higher Capacity Factors • Either (1) Defer Implementation Until 4/06 or (2) Not Count Incremental Carbon Emissions

  9. Exempt Hours of Emergency Operation • Emergency Generators Restricted to 300 Hours Per Rolling 12 Months • Roadblock to Demand Response Participation • Exempt Hours of Operation During OP-21

  10. Create BACT Certainty • Best Available Control Technology (BACT) • Provide More Certainty In BACT Determinations for New Sources • Stimulate Proposals For Additional Resources

  11. Summary • No Single Regulatory Decision Works For All Sources • Need Different Approaches for Different Types of Units • Consider Both Proactive and Last Resort Steps

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