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CAIR and CAMR Applicability

CAIR and CAMR Applicability. EPA Region 7 Workshop Kansas City, Kansas August 16, 2007 Robert Miller. CAIR Applicability Criteria. A unit subject to CAIR must be a stationary boiler or combustion turbine that: Burns fossil fuel; and

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CAIR and CAMR Applicability

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  1. CAIR and CAMR Applicability EPA Region 7 Workshop Kansas City, Kansas August 16, 2007 Robert Miller

  2. CAIR Applicability Criteria • A unit subject to CAIR must be a stationary boiler or combustion turbine that: • Burns fossil fuel; and • Has served, on or after November 15, 1990, a generator that has greater than 25 MW nameplate capacity . . . • That produces electricity for sale

  3. A Few CAIRApplicability Nuances • If a unit burns any amount of fossil fuel at any time, that unit is fossil fuel-fired • A unit serves a generator if it is able to provide heat or steam to that generator. • Nameplate capacity: • What manufacturer says max. output is . . . • Of the generatoronly (not generator-turbine tandem)

  4. How Does CAIR Applicability Differ from Acid Rain Applicability? • No breaks in CAIR for simple combustion turbines that sold electricity before Nov 15, 1990 • No exemptions for QFs and IPPs that have qualifying power purchase commitments in CAIR • More difficult for cogeneration units to meet CAIR criteria for exemption than ARP

  5. CAIR Cogeneration Exemption • Certain cogeneration units aren’t subject to CAIR if they: • Meet the definition of cogeneration unit, and; • Don’t sell above a certain amount of electricity on an annual basis.

  6. Cogeneration Unit Definition • Heat must be used for two purposes: the production of electricity and at least one other industrial or commercial process • Some of the heat produced must be used sequentially (i.e., used twice)

  7. Cogeneration UnitDefinition, Cont’d. • Unlike ARP cogen applicability, CAIR cogen unit definition establishes minimum thresholds for • “Useful thermal energy” (for topping-cycle cogeneration units) • “Useful power” (for topping and bottoming-cycle cogeneration units)

  8. More CAIR Cogeneration • Electrical sales thresholds calculated using 1/3 of potential electrical output capacity or 219,000 MWe-hrs, whichever is greater, BUT . . . • CAIR electricity sales threshold is an annual threshold . . . NO 3 year rolling average for electrical sales like the Acid Rain Program has.

  9. More CAIR Applicability • Certain solid waste incineration units are exempt from CAIR requirements. • States in the NOx SIP call have the option of promulgating CAIR NOx Ozone Season applicability regs that capture same non-EGUs that would be subject to the NBTP.

  10. CAMR ApplicabilityCriteria (Look Familiar?) • A unit subject to CAMR must be a stationary boiler or combustion turbine that: • Burns coal or coal-derived fuel; and • Has served, on or after November 15, 1990, a generator that has greater than 25 MW nameplate capacity; and • That produces electricity for sale

  11. A Couple of CAMRApplicability Nuances • If a unit burns any amount of coal or coal-derived fuel at any time, that unit is coal-fired. • Coal-derived fuel is any solid, liquid or gaseous produced by “mechanical, thermal, or chemical” processing of coal.

  12. CAMR Applicability, Cont’d. • Same cogeneration applicability criteria in CAIR are used in CAMR as well • Same solid waste incineration unit applicability criteria in CAIR are used in CAMR as well

  13. Biomass Cogen Proposal • Rule proposed April 25, 2007 • Proposes to change CAIR and CAMR cogen applicability so that efficiency standard is only applied to fossil fuel-fired portion of a unit’s energy input

  14. Biomass CogenProposal, Cont’d. • Comment period ended June 11, 2007 • EPA hopes to finalize rule in the fall • Text of rule available at EPA’s website at www.epa.gov/cair/rule.html or www.epa.gov/camr/rule.htm

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