Connecticut Department of Energy and Environmental Protection

Transcription

1 Connecticut Department of Energy and Environmental Protection

2 Connecticut s 1-Hour Sulfur Dioxide (SO 2 ) NAAQS Analysis and Management Strategy April 24, 2013 R/S/L Modelers Work Shop Dallas, TX Sam Sampieri

3 SO 2 Standard & Public Health 1-Hour NAAQS of 75 ppb (196.5 µg/m 3 ) - effective August 23, 2010 Targets health effects of short-term exposures (<24 hrs) - narrowing of breathing airway and increased asthma symptoms NAAQS Compliance will reduce: - respiratory illness symptoms in at-risk groups (children, elderly, asthmatics) - emergency visits/hospital admissions - formation of PM 2.5, providing more respiratory/cardiovascular benefits

4 EPA s SO 2 NAAQS Timeline Infrastructure SIP, due June 2013 Modeling not required with submittal. EPA designates areas based on modeling, Dec 2017* EPA stakeholder process, May 2012 Identified need for flexibility (monitoring/modeling/mix). EPA designates areas with violating monitors, June 2013 Nonattainment area (NA) SIPs due Attainment by NA SIPs due Attainment by CT is seeking Attainment designation ASAP, based on modeling submitted March EPA designates rest of country, Dec 2020* 1-hr NAAQS effective August 23, 2010 New monitoring sites operational, Jan 2017* NA SIPs due Attainment by * EPA s preliminary schedule (subject to rulemaking)

5 Connecticut s SO 2 Management Strategy To achieve public health benefits as quickly and cost effectively as possible Existing air management framework does not address potential short term SO 2 exposure Examine existing commitments and identify opportunities where cost effective adjustments meet multiple goals

6 SO 2 Point Source Emission Reductions 36,918 Sulfur Dioxide Emissions (tons) 10,814 7,523 4,

7 Leveraging Existing Opportunities Existing Commitments CT Comprehensive Energy Strategy Regional Haze Requirements Low Sulfur Fuels (especially heating oil) Removing rate payer subsidies for old power plants CT 2008 SO 2 Inventory

8 Comprehensive Energy Plan Clean & Efficient Connecticut s Comprehensive Energy Plan

9 Regional Haze In the eastern U.S., sulfate remains the dominant contributor to the fine particle pollution that typically causes hazy conditions. Organic carbon (automobiles, solvents, natural vegetation) and to a lesser extent nitrate, elemental carbon (soot) and fine soil are other contributors. Changes in Light Extinction Downwind of Connecticut (comparison of to ) NESCAUM: Jan 2012 technical memo

10 CT s Revised Attainment Recommendation CT initially recommended unclassifiable (June 2011) - No modeling available to support compliant monitoring - EPA delay on designations provided time to model CT revised attainment recommendation based on both modeling and monitoring (March 2013) - Modeled facilities with => 100 tpy of actual SO 2 emissions - Updated monitoring analysis using latest data - Now recommending Attainment : justified by modeling & monitoring Modeling of maximum allowable shows areas of concern - NSR permit modeling requires allowable emissions - CT developing low-sulfur rule to provide for NAAQS maintenance and meet regional haze commitments

11 SO 2 Monitoring Network AERMOD hr SO 2 NAAQS = µg/m 3

12 Historical SO 2 1-Hour Design Values ( )

13 SO 2 1-Hour Modeling Analysis Modeled four major point sources with actual emissions of >=100 tons per year (tpy) threshold based on Draft Guidance (EPA, 2011) These sources are Electric Generating Units (EGUs) that contain Title V and New Source Review (NSR) Operating Permits with several trading orders and restrictions, including Connecticut s 0.33lbs/MMBtu residual oil rule. Sources are also subject to the Title IV Phase II Acid Rain Rule Three (3) facilities located on coastal plain from lower Fairfield County to central New Haven County with one facility located inland, along the Connecticut River Valley in Middletown, Ct. Three oil fired boilers currently burning #6 residual oil. One facility has one coal fired boiler.

14 EPA/DEEP Modeling Guidance/Clarification Memos EPA s Appendix W of 40 CFR Part 51 (EPA, 2005) Guideline On Air Quality Modeling Ambient Impact Analysis Guideline (DEEP, 2009) Applicability of Appendix W Modeling Guidance for the 1-hour SO 2 National Ambient Air Quality Standard (Aug. 23, 2010) Guidance Concerning the Implementation of the 1-hour SO 2 NAAQS for the Prevention of Significant Deterioration (PSD) Program (Aug. 23, 2010) Additional Clarification Regarding Application of Appendix W Modeling Guidance for the 1-hour NO 2 NAAQS (March 1, 2011) Area Designations for the 2010 Revised Primary Sulfur Dioxide NAAQS (March 24, 2011) Draft Guidance for 1-Hour SO 2 NAAQS SIP Submissions for the 2010 Revised Primary Sulfur Dioxide NAAQS (September 22, 2011)

15 Four 100 TPY EGU Sources Modeled PSEG, Bridgeport Harbor Station: One Coal Fired Boiler PSEG, New Haven Harbor Station: One Oil Fired Boiler NRG, Norwalk Power, LLC: Two Oil Fired Boilers Middletown Power, LLC: Three Oil Fired Boilers Modeled five years ( ) of actual hourly SO 2 emissions extracted from the Continuous Emissions Monitoring (CEM) data extracted from CAMD. Bridgeport Harbor Unit 3 Coal Stack - variable flow rates were calculated based on hourly load data; rest of sites used fixed permitted flow rate data for now Two ASOS sites were processed: Bridgeport /Sikorski Airport Surface Data in Stratford with Brookhaven Upper Air Data for the coastal sources. Bradley International Airport surface data in Windsor Locks with Albany Upper Air Data for Middletown Power, LLC. We did not model any neighboring states large SO 2 sources!

16 Location of Sources Modeled

17 Connecticut s Predicted 1-Hour SO 2 Modeled Design Concentration

18 Connecticut s Predicted 1-Hour SO 2 Modeled Design Concentration

19 NRG- Middletown Power, LLC Middletown Station Total of 953 MW electrical output Three steam electric generating boilers (Units 2, 3 & 4) Five combustion turbines natural gas/ultra low sulfur oil Several on-site ancillary units- FT4A-8 Turbine, Aux Boiler, Ger Units 2-4 boilers fire No. 6 oil; CEM hourly emissions modeled. All other sources modeled with permitted allowable emissions Sources subject to trading and consent orders to comply with CAIR NOx emission limits.

20 NRG- Middletown Power, LLC Middletown Station Three steam electric generating boilers (Units 2, 3 & 4) Units 2 & 3 Stack Height: 266 feet Unit No. 4 Stack Height: 498 feet

21 NRG-Middletown Power, LLC

22 NRG-Middletown Power, LLC

23 Middletown Power, LLC

24 PSEG Power Connecticut, LLC New Haven Harbor Station Older Electric Generating Unit EU1 4,286 MMBtu/hr boiler No. 6 Oil at 0.5% sulfur EU MMBtu/hr boiler No.2 Distillate Oil EU3 40 gal/hr diesel (distillate) fuel emergency generator, not modeled EU4 1.8 MMBtu/hr diesel fire pump engine not modeled New Turbines Operational Since 2011 EU30 50 MW GE LM6000PC combustion turbine natural gas/ultra-low sulfur fuel EU31 50 MW GE LM6000PC combustion turbine EU32 50 MW GE LM6000PC combustion turbine EU MW Cummins QSK50-G4-NR2 black start generator Trading and consent orders subject to CAIR to limit NOx emissions Modeled hourly emissions from EU1; all other sources emissions and stack data were modeled from latest permit and registration documents

25 PSEG Power Connecticut, LLC New Haven Harbor Station Electric Generating Unit EU1 4,286 MMBtu/hr boiler No. 6 Oil at 0.5% sulfur Modeled hourly emissions extracted from CAMD Data Base for EU1 Stack Height 389 feet

26 PSEG Power Connecticut, LLC New Haven Harbor Station

27 PSEG Power, New Haven Harbor

28 NRG- Norwalk Power, LLC Norwalk Harbor Station Units 1 & 2 #6 Oil Fired Boilers Unit 3 17 MW No2. Oil/Gas Turbine Hourly emissions extracted from the CAMD Data Base for Units 1 & 2 Source is subject to trading and consent orders to evaluate opacity data and PM emissions, respectively. Subject to CAIR - Severe Non-attainment for Ozone in Fairfield County

29 NRG- Norwalk Power, LLC Norwalk Harbor Station Units 1 & 2 #6 Oil Fired Boilers Stack Height 350 feet

30 NRG Norwalk Power

31 NRG-Norwalk Power Units 1 & 2

32 PSEG Power Connecticut, LLC -Bridgeport Harbor Station Electric Generating Unit in operation since 1957 Three major-emitting fuel Burning Units Unit # 2 - No. 6 oil-fired Unit # 3 - Coal Fired and No. 6 Oil Unit # 4 - FT4 Turbine Jet Fuel Aviation fuel <300 hrs/yr Hourly emissions & flow rates calculated from the CAMD Data Base for Unit # 3 Annual Emissions have dropped significantly during the last five (5) years from >2000TPY in 2007 to 500 TPY in 2011 Slow economy and increased natural gas supply during the last several years = decline in coal emissions.

33 PSEG Power Connecticut, LLC -Bridgeport Harbor Station Unit # 3 - Coal Fired and No. 6 Oil Hourly emissions & flow rates calculated from the CAMD Data Base for Unit # 3 Stack Height 498 feet Base Elevation 2.44 meters Also modeled the Permitted Fixed Exit Velocity 38.8 meters

34 PSEG Power Connecticut-Bridgeport Harbor Station

35 PSEG Power Connecticut-Bridgeport Harbor Station

36 Location of the BDR ASOS to Bridgeport Harbor 5 KM

37 Bridgeport Harbor 4 th High Average SO 2 Concentration-Urban Mode

38 Bridgeport Harbor 4 th High Average SO 2 Concentration-Rural Mode

39 Bridgeport Harbor 4 th High Average SO 2 Concentration-Rural Mode

40 Bridgeport Harbor 4 th High Average AERMOD SO 2 Design Concentration

41 Bridgeport Harbor 4 th High By Year AERMOD Version , With Background Season /Hour/Day PSEG 5K Version With Background Season /Hour/Day PSEG5K Year Hourly Background Data Matched with Met Data TH PSEG50M

42 AERMOD Predicted 1-Hour Design SO 2 Concentrations Sources th High Average 1-hour SO 2 Concentrations (µg/m 3 ) Electric Generating Units With Background Without Background 1-Hour SO2 NAAQS µg/m 3 Urban/Rural PSEG New Haven Urban PSEG Bridgeport Urban PSEG Bridgeport Rural NRG Norwalk Power Urban NRG Middletown Power Rural

43 1-Hour SO 2 Modeling Results GOOD NEWS!: All facilities show predicted compliance with the new 1- hour SO 2 NAAQS of 75PPB (196µg/m 3 ), including background. Two (2) versions of AERMOD were modeled (12060 & 12345) and minor differences between the version were discovered and confirm the discussion in the Model Change Bulletin (MCB # 3)update to AERMET (dated 12345) AERMOD modeling results are likely to be affected to some degree by this AERMET bug fix in most cases. Both versions of AERMOD and AERMET show modeled attainment of the 1-Hour SO2 NAAQS More importantly modeling major sources in a city on the coastline is very sensitive to the Urban/Rural option, where land use analysis could be rural while the population makes it Urban.

44 Questions For more information on CT s SO 2 Planning Efforts, visit: Questions??