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

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March 2011Page B-2Draft Analysis of Emissions from Power Plants and Other Large Combustion SourcesComment 1: Figures 1-1, 1-2, 7-1, 7-2, 8-1 and 8-2 – the color scheme used to distinguishbetween coal-fired units and wood-fired units is not discernableResponse: Color scheme changed to show wood using a green color scheme. There are very fewwood-fired units in the CAMD database, with little capacity and emissions.Comment 2: Figures 1-2, 1-6 and 1-10 - the text presented immediately above the figure denotesthat the ordinate (y-axis) is expressed in terms of “megawatt capacity” whereas the ordinatewithin the figure presents capacity in terms of heat input (MMBtu/hour). The text needs to bechanged to reflect the information presented in the figure.Response: Corrections made.Comment 3: Figures 1-3 and 1-4 – Presumably NOx and SO2 emissions, respectively, arepresented in units of tons. The mass units should be included in these figures.Response: Corrections made.Comment 4: Figure 1-8. Please provide the hierarchy of NOx control technologies assumed inthis analysis.Response: NOx controls in the CAMD database are reported directly by the industry. CAMDprovides a lookup table of valid NOx control devices(http://www.epa.gov/airmarkets/business/ecmps/docs/ECMPSLookup.pdf ). Sources canindicate that there are multiple control measures (combustion modifications or post-combustioncontrols) for each unit. Since there were about 75 unique combinations of NOx controls reportedin the CAMD database, it was necessary to aggregate these in some simplified manner forgraphical presentation. NOx controls were generally grouped according to the emissionreduction potentials identified in Table 1.1-2 of AP-42. The intent of this Figure 1.8 was to showthat there are a large number of uncontrolled units in the 50 % bin – the value should be80.0, not 8. Additionally, RRI presumes that the time periods selected for the data presented inthe first and second tables represent unusually cold and hot periods, respectively. If so, then thisshould be stated and supporting temperature data should also be presented.Response: Correction made and a discussion of temperatures associated with the February andAugust dates was added to the text.Comment 6: Question 6, table preceding Figure 6-1. How do these findings differ from thosepresented in Figure 2-2, which presents NOx emissions (percentages) for each of the three
Draft Analysis of Emissions from Power Plants and Other Large Combustion Sources March 2011Page B-3operating bins versus month? The percentages are similar on high ozone days as compared withthe month as a whole.Response: The table was modified to also show the monthly averages in addition to the dayspecificvalues.Comment 7a: Figures 9-1a through 9-1e, Figures 9-2a through 9-2e, Figures 9-3a through 9-3e,Figures 9-4a through 9-4e – These figures present time series plots of daily maximum ozoneseason concentration and hourly NOx emission rates for each of the three operating bins forselected high ozone events. RRI notes that high ozone concentrations are not necessarilycorrelated with high NOx emission rates, thus suggesting that there are other contributing factorsthat need to be considered. For example, it would be helpful to include ambient temperature andhumidity on these plots as these data are likely available with the ozone data.Response: Daily maximum temperature was added to each chart.Comment 7b: It should also be noted that MARAMA has recently reported that annual NOxemissions from on-road mobile sources are nearly four times greater than annual NOx emissionsfrom CAMD-reporting EGUs, so perhaps similar figures could also be generated if hourly onroadmobile source NOx emissions data are available.Response: Hourly on-road mobile source NOx emissions are not currently available pendingcompletion of MOVES modeling and review/approval by the States. The suggestion is noted andwill be considered at a later date.Comment 8: Figures 10-4 through 10-6 – Why were the data from Virginia excluded from thisparticular analysis? Although Virginia is not included within the MANE-VU states, the scope ofthe report was focused on the MANE-VU states plus Virginia. Additionally, the heat input datapresented in Figure 10-3 shows that the pattern of higher annual heat input in 2007 as comparedwith 2006 and 2008 was demonstrated in both the MANE-VU and VISTAS states.Response: Data for Virginia was added to Tables 10-1, 10-2 and 10-3 as well as Figures 10-4,10-5, and 10-6.Commenter: Roger Caiazza, Environmental Energy Alliance of New YorkComment: The MARAMA report should note that there are different reporting methodologiesand the reported emission values for the units in the “Units that operated less than 15 percent ofthe time (
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