Analysis of 2007 Emissions from Power Plants and Other ... - MARAMA

Draft Analysis of Emissions from Power Plants and Other Large Combustion Sources March 2011Page B-1APPENDIX BMARAMA Response to Comments(October 21, 2010)Analysis of Emissions from Power Plants and Other Large CombustionSources in the Northeast/Mid-Atlantic Region (September 15, 2010)Commenter: John Shimshock, RRI EnergyGeneral Comment: There are many other peaking-type electrical generating units (primarilycombustion turbines and diesel generators) that do not report their emissions to CAMD because(i) their nameplate capacity is less than 25 MWe or (ii) the electrical generating units do notsupply their electricity to the local electrical grid (i.e., distributed generating units). Neither ofthe aforementioned units is subject to emissions monitoring and reporting to CAMD per 40 CFR75 requirements. It is conceivable that NOx emissions from these units can be substantialbecause many of these units are not equipped with NOx emissions control devices. Although theanalyses provided in the draft MARAMA report is valuable, RRI suggests that the scope ofanalysis be expanded to include the non- CAMD reporting units in order to provide for a morecomprehensive examination of SO2 and NOx emissions from this source category. Please notethat the recently proposed Clean Air Transport Rule included a file provided by U.S. EPA thatpresented all known EGUs (excludes distributed generating units). Emissions data for the non-CAMD reporting EGUs and distributed generation units can be obtained from the applicablestate regulatory agency.Response: We recognize that there are other types of peaking units besides those that report theiremissions to CAMD. However, we elected to limit the analysis to the units reporting to CAMDbecause the hourly emissions for these units were readily available and we were interested inunderstanding how the emissions varied on an hourly basis during peak periods. On an annualbasis, the emissions from the nonCAMD EGUs are relatively small. We queried the MANE-VU+VA 2007 annual inventory for nonCAMD EGUs (i.e., source classification code of 1-01-xxx-xx or 2-01-xxx-xx that do not report to CAMD). For NOx, the annual emissions for CAMDreporting units were 431,331 tons, compared to only 14,677 tons for EGUs that do not reporthourly data to CAMD. That is not to say that the emissions from nonCAMD EGUs are notimportant during peak periods. We just don’t have sufficient data to include these units in theanalysis at this time. The comment, however, is valid and we added a “Data Caveats” section tothe Introduction to the report to address this issue.