Air Quality on Air Quality on High Electric High Electric Demand DaysDemand Days

&&What We Can Do What We Can Do

About ItAbout ItChris Salmi, NJDEP

February 6, 2007

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•• Emissions Emissions from Electric from Electric Generating Units (EGUs) areGenerating Units (EGUs) arehigher on high electric demandhigher on high electric demanddaysdays

•• This results inThis results in poorer air qualitypoorer air quality

•• Flexibility and innovation can result inFlexibility and innovation can result insuccessful programssuccessful programs to address thisto address thisissueissue

Three Points!Three Points!

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NONOxx Emissions Versus Peak Electricity Demand in New EnglandEmissions Versus Peak Electricity Demand in New Englandon Ozone and Nonon Ozone and Non--Ozone Ozone ExceedanceExceedance DaysDays

(June 1(June 1-- September 15, 2002)September 15, 2002)

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NONOxx Emissions Versus Peak Electricity Demand in NJ/Downstate NYEmissions Versus Peak Electricity Demand in NJ/Downstate NYon Ozone and Nonon Ozone and Non--Ozone Ozone ExceedanceExceedance DaysDays

(June 1 (June 1 -- September 15, 2002)September 15, 2002)

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The Mix of Generating The Mix of Generating Units varies Units varies

by day and regionby day and region

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Not all units run every dayNot all units run every day

CT Electric Generating Utility Average Percent Operating TimeCT Electric Generating Utility Average Percent Operating Time20022002--2005 Ozone Seasons2005 Ozone Seasons

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0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Martins Creek Williamsport Hamilton WilliamsGeneration Co

(Hazleton)

Trigen Energy- Schuykill

Trigen Energy- Schuykill

Martins Creek Sunbury ArmstrongPow er Station

ScrubgrassGenerating

Plant

Keystone

Ope

ratin

g Ti

me

(%)

PA Electric Generating Utility Average Percent Operating TimePA Electric Generating Utility Average Percent Operating Time20022002--2005 Ozone Seasons2005 Ozone Seasons

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Electric Generating Units Do Not Run on All Days

Daily NODaily NOxx Emissions from EGUs in New EnglandEmissions from EGUs in New England(June 1 (June 1 -- September 15, 2002)September 15, 2002)

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Non-Ozone Exceedance Day Ozone Exceedance Day

Daily NODaily NOxx Emissions from EGUs in NJ/NY CityEmissions from EGUs in NJ/NY City(June 1 (June 1 -- September 15, 2002)September 15, 2002)

Average Daily NOx Emissions = 286.5 TPD

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NO

xEm

issi

on fr

om N

ew E

ngla

nd E

GU

s (to

ns)

Fuel Types Comprising the Daily NOFuel Types Comprising the Daily NOxx EmissionsEmissionssorted by NOsorted by NOxx Mass from New England EGUsMass from New England EGUs

June 1 June 1 -- September 15, 2005September 15, 2005

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NO

xEm

issi

on fr

om N

j/NY

EGU

s (to

ns)

Fuel Types Comprising the Daily NOFuel Types Comprising the Daily NOxx EmissionsEmissionssorted by NOsorted by NOxx Mass from NY City and NJ EGUsMass from NY City and NJ EGUs

June 1 June 1 -- September 15, 2005September 15, 2005

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EGU Emission Reductions EGU Emission Reductions on High Electric Demand on High Electric Demand Days appears to lead to Days appears to lead to

improved air qualityimproved air quality

Preliminary Modeling from Early 2006 – Does not reflect the strategy under consideration

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Existing Attainment Modeling Does Not Capture the Increased

Emissions

Daily NODaily NOxx Emissions from EGUs in NJ/downstate NYEmissions from EGUs in NJ/downstate NYJune 1June 1--September 15, 2002September 15, 2002

The actual daily and hourly temporal changes in emissions is not incorporated in the modeling

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Modeling Daily NOModeling Daily NOxx EmissionsEmissions

37 36 3431

25 24

3337

71

47

54

69

37 353632

0

20

40

60

80

100

6-Aug 7-Aug 8-Aug 9-Aug 10-Aug 11-Aug 12-Aug 13-Aug

NO

X E

mis

sions

(Ton

s)

State Specific

Unit SpecificHudson County, NJ

NO

xE

mis

sion

s (to

ns)

The daily emissions can vary greatly

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Modeling Impact of High Electric Modeling Impact of High Electric Demand Day UnitsDemand Day Units

•• Looked at units operating on high electric Looked at units operating on high electric demand days, 2002demand days, 2002--5 ozone seasons5 ozone seasons–– NJ & MD : units whose average operating time is ~ < 20%NJ & MD : units whose average operating time is ~ < 20%–– CT: units whose average operating time is ~ < 50%CT: units whose average operating time is ~ < 50%

•• MA: six highest residual oilMA: six highest residual oil--fired load following fired load following unitsunits

•• NY: units as defined at 6NYCRR, Part 200, NY: units as defined at 6NYCRR, Part 200, Subpart 227Subpart 227--22

•• Other states: units whose annual contribution Other states: units whose annual contribution <2% and maximum hourly contribution >1%<2% and maximum hourly contribution >1%

Preliminary Modeling from Early 2006 – Does not reflect the strategy under consideration

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High Electric Demand Day UnitsHigh Electric Demand Day Units

State Facilities UnitsCT 12 56DE 1 4MA 6 37MD 5 16ME 2 4NJ 20 119NY 11 97PA 11 51

Total 68 384

Facilities with High Electric Demand Day Units

Preliminary Modeling from Early 2006 – Does not reflect the strategy under consideration

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Maximum Ozone Reductions Maximum Ozone Reductions (ppb)(ppb) from from High Electric Demand Day UnitsHigh Electric Demand Day Units

NONOxx = 0.1 lb/ = 0.1 lb/ mmBtummBtu Modeling EpisodeModeling Episode-- Aug 1Aug 1--15, 200215, 2002

Preliminary Modeling from Early 2006 – Does not reflect the strategy under consideration

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Existing Cap & Trade Program Existing Cap & Trade Program has been insufficient to has been insufficient to

address this issueaddress this issue

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BaseloadBaseload Getting CleanerGetting CleanerHEDD Emissions Remain HighHEDD Emissions Remain High

Baseload unitsare getting

cleaner

Delta getting larger--HEDD units have a more profound effect

43,166 78,821 61,038 133,761

8/7/2002 6/4/2005 ∆ 8/12/2002 7/26/2005992 441 1615

551 798 1349

Emissions (TPD)High Electric Demand Day

Typical Summer Day

PJM Generating Peak (MW)

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Daily NODaily NOxx EmissionsEmissionsfrom All Units* in OTR Statesfrom All Units* in OTR States

.17019,050,2971,619WednesdayAugust 4

.164Seasonal total:1,995,251,140 Daily average: 13,040,857

Seasonal total:163,833 Daily average: 1071

May 1 –Sept. 30

.17019,619,9271,668WednesdayJuly 27

1,588

1,677

NOx Emissions (tons)

.17218,501,509FridayAugust 12

.16919,811,372TuesdayJuly 26

Average Emissions

Rate (lbs/mmBtu)

Heat Input(mmBtu’s)

Date

• There are 1168 units in OTR states that report their hourly emissions to EPA as either part of the NOx Budget Program and/or Acid Rain Program

(2005)

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Daily NODaily NOxx Emissions from Emissions from Combustion Turbines* in OTRCombustion Turbines* in OTR

.2071,756,262182WednesdayAugust 4

.155Seasonal total: 94,718,950Daily average: 619,078

Seasonal total: 7,363Daily average: 48

May 1 –Sept. 30

.2412,155,401260WednesdayJuly 27

185

221

NOx Emissions (tons)

.2131,736,021FridayAugust 12

.2231,979,451TuesdayJuly 26

Average Emissions Rate

(lbs/mmBtu)

Heat Input(mmBtu’s)

Date

• There are 491 combustion turbines in OTR states that report their hourly emissions to EPA as either part of the NOx Budget Program and/or Acid Rain Program

(2005)

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Cannot Attain without Effectively Addressing Peak Days

• Demand for electricity is increasing and theincrease in the peak is growing faster than the base:

- PJM Interconnection: consumer peak demand for electricity willrise ~ 1.6% annually over the next decade.

- NE ISO: peak demand will rise ~2.4% annually. - NYISO: relies heavily on many, many combustion turbines to

maintain NYC grid.

• Meeting hot day peak electrical demand requires bringing on more units, which are not necessarilyclean. These same units appear insignificant in inventory.

• Attainment plans must address high demand day units.

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Developing a ProgramDeveloping a Programto Address This Issue to Address This Issue --

The HEDD Partnership PlanThe HEDD Partnership Plan

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OTC High Electric Demand Day Initiative

• Long Term – Clean Units• Short Term (2009) – Reductions to Aid

Attainment• Existing and New Small Units – Clean• Leverage Energy Markets and PUC

Actions

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Long Term

• Set Clean Performance Standards• Allow Implementation Flexibility

Through HEDD Partnership

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Short Term

• Provide Emission Reductions for 2009 Attainment

• Emission Reduction Responsibility Assigned to each State– Goal = ~25% Reduction in HEDD Unit Emissions

• State and Generator HEDD Partnership– Action Oriented– Flexible– Enforceable– Incorporate in the SIP

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Existing and New Small Units

• Scope:– Distributed Generation Units– Demand Response Units

• Benchmarked:– Permitting Rules– Control Levels– Definitions

• Action??

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Leverage Energy Markets and PUC Actions

• Efforts to Reduce Electrical Demand – Energy Efficiency Programs

• Efforts to Improve System Reliability• Efforts to Promote Fuel Diversity

– Renewable Energy Programs– Diversity Requirements

• Actions Include:– Real Time Metering Infrastructure

• Cost Considerations– Dynamic pricing for retail customers– Removal of electric distribution company disincentives -

decoupling• Broaden the focus on energy efficiency to include demand response

and make energy efficiency a resource that can compete for market share

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State - Generator HEDD Partnership

• Agreement• Emission Reduction Responsibility• Defined Actions on High Electric

Demand Days• Quantification Methods• Reporting Requirements• Incorporated into the SIP

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Flexibility & Certainty

• Flexibility– HEDD unit owners choose the most cost effective

path– Avoid “Command & Control” approach– Allows the use of conservation to minimize peaks

& minimize the commitment impact– If not double-counted, HEDD unit owners

responsibility can span state borders if directionally correct

– Allows time to comply, financial markets to respond, and continue to plan

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Flexibility & Certainty

• Certainty– State and the generator enter into a mutually

agreed upon plan using a formal agreement as the “contract” which gets submitted in the SIP

– Lays out what is expected of both parties

– Provides the certainty required to plan future actions

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State Reduction Responsibility

State

NOx

(Tons per Day)

% Reduction From HEDD

UnitsCT 11.7 -25%DE 6.3 -30%MA 6.1 -26%MD 23.9 -32%NJ 19.8 -28%NY 46.1 -26%PA 22.2 -32%

136.1 -28%The Reduction Responsibly likely to change as the list of HEDD units is finalized

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Workgroup Participants

• ConEd• Dominion• Exelon• Keyspan• NRG• PPL• PSEG• Reliant

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What’s in it for…

HEDD Unit Owners: Flexibility & Certainty

The State: Attainment