OTC-SESARM NOx Analysis

1. Region 4 Air Directors Meeting October 2013 Charleston, SC OTC-SESARM NOx Analysis

2. Overview • Southeast EGUs have significantly reduced NOx and emissions over the last 10-12 years • Current Southeast NOx emission rate is lower than the current Northeast NOx emission rate, on an annual, ozone season and HED day basis • Some validity to Northeast claim that some sources have reduced their level of control in the past few years, but in both the NE and SE • Air flow on Ozone exceedence days in the North-east is generally not from the Southeast

5. High Electric Demand Days • Northeast has identified Ozone exceedences associated with peak high electric demand days (peak HEDD) • Chris Salmi of NJ shared a comparison of peak HEDD emissions to an annual average day and a ozone season average day for PA power plants • NJ identified an increase in emissions on peak electric demand days • Not surprising since peak day emissions are expected to be higher than average day emissions

7. What is an HED Day? • Northeast identified the highest PJM electric demand day as a peak HEDD • Identified one day per year • 8/22/2003, 8/20/2004, 7/27/2005, 8/2/2006, 8/8/2007, 6/10/2008, 8/10/2009, 7/6/2010, 7/22/2011, 7/18/2012 • WV identified the 15 highest electric generating days (top 10%) during the Ozone Season for each individual state as an HED Day • HED Days vary by state and by year, with significant overlap

9. Data is on a State level, includes EGUs and nonEGUs reporting to CAMD For the last 3 years SESARM states have had a lower emission rate than OTC states, on an annual, Ozone season, HEDD and the PJM peak demand day basis

10. Daily Data Caveats • CAMD data • All Programs • Includes EGUs and Non-EGUs • Includes all fuels • coal, oil, natural gas and other • Daily Data aggregated to the State level • All of Virginia included in SESARM • NOx Rate Calculated • OTC total NOx (lbs)/OTC total Heat Input (MMBtu) • SESARM total NOx (lbs)/SESARM total Heat Input (MMBTU)

15. Unit Level Data • Byeong Kim of GA analyzed CAMD data on an annual and Ozone season basis • Unit level data • Can look at EGU or non EGU • Can look at specific fuels • Coal, gas, oil or other

16. EGUS only, All fuels

17. Anomalous looking data, may be the result of substituted data in CAMD EGUs only, All fuels

18. EGUs controls on HED Days • Tom McNevin of NJ identified EGUs reducing their NOx control during the ozone season over the past few years • NJ shared an analysis of NOx emission rates of EGUs in PA equipped with SCR • Blue vertical lines mark the start of the 3 cap-and-trade programs • Acid Rain Program, NOx SIP Call, CAIR

19. Acid Rain Program CAIR NOx SIP Call

20. Facility Level NOx Rates • Comparison of NOx rates for coal-fired facilities equipped with SCR by state • 2002 - 2012 • As allowance prices have dropped ozone season NOx emission rates have increased for some sources • This is occurring at facilities in both the OTC and SESARM

21. Ozone Season Allowance Market Prices Data Source: http://www.eia.gov/todayinenergy/detail.cfm?id=4830

22. Harrison and Pleasants are required to operate SCR year round, but do not have a specific emission rate limit, they are required to hold allowances

27. 2012 PJM Peak Day

28. CT DE MD MA NY CT MA NJ NY CT DE DC MD NJ NY PA CT MA MD Look more closely at this time period CT NJ MD NJ NY PA MD CT CT RI MA PA CT CT Derecho PJM Peak

29. Focus on this event Derecho

30. Ozone Exceedences in CT, DE, MA, MD, NJ and NY

31. Between 6/17 and 6/21, SESARM had a 37% increase in NOx emissions Over the same period the OTC had a 162% increase in NOx emissions

32. Where Does the Wind Come From on High Electric Demand Days/High Ozone Days? The Backward Trajectory Connection:

33. 4 pm 6 pm DE 90 ppb 10-005-1002 We gratefully acknowledge the NOAA Air Resources Laboratory (ARL) for the provision of the HYSPLIT transport and dispersion model and/or READY website (http://www.ready.noaa.gov) used in this presentation.

34. 4 pm 6 pm MD 99 ppb 24-003-0014 We gratefully acknowledge the NOAA Air Resources Laboratory (ARL) for the provision of the HYSPLIT transport and dispersion model and/or READY website (http://www.ready.noaa.gov) used in this presentation.

35. 4 pm 6 pm NJ 97 ppb 34-007-1001 We gratefully acknowledge the NOAA Air Resources Laboratory (ARL) for the provision of the HYSPLIT transport and dispersion model and/or READY website (http://www.ready.noaa.gov) used in this presentation.

36. 4 pm 6 pm MA 100 ppb 25-007-0001 We gratefully acknowledge the NOAA Air Resources Laboratory (ARL) for the provision of the HYSPLIT transport and dispersion model and/or READY website (http://www.ready.noaa.gov) used in this presentation.

37. Summary • Southeast has had significant reductions in NOx emissions, and NOx emission rate • NOx emission rates are lower in the Southeast than the Northeast, on an annual, ozone season and daily basis • Southeast, and Northeast, can achieve additional reductions by ensuring controls are utilized • Air flow on Ozone exceedence days in the NE is not from the SE

38. Just Lucky? More Trajectories… New Corvette PP/RE – Propane Powered/Redneck Edition

39. 4 pm 6 pm NJ: 111 ppb 34-017-0006 PJM Peak Day 7/06/2010 – Ozone exceedances: MD, NJ & NY

40. 6 pm 4 pm NY: 114 ppb 36-103-0002 PJM Peak Day 7/22/2011 – Ozone exceedances: CT, MA, MD & NY

41. 6 pm 4 pm CT: 91 ppb 09-011-0124 PJM Peak Day 7/18/2012 – Ozone exceedances: CT only

42. 6 pm 4 pm CT: 98 ppb 09-007-0007 NOT PJM Peak Day 7/17/2011 – Ozone exceedances: CT, MA, & MD

43. 6 pm 4 pm MD: 95 ppb 24-025-1001 NOT PJM Peak Day 7/17/2011 – Ozone exceedances: CT, MA, & MD

44. We gratefully acknowledge the NOAA Air Resources Laboratory (ARL) for the provision of the HYSPLIT transport and dispersion model and/or READY website (http://www.ready.noaa.gov) used in this presentation.