By Block Andrews, PE, Burns & McDonnell
Yet another environmental regulation has been proposed by the U.S. Environmental Protections Agency (EPA) this year. This one involves reducing ozone season nitrogen oxide (NOX) emissions from fossil fuel fired-power plants.
The intent is to modify Cross State Air Pollution Rule (CSAPR) ozone season allowances to help comply with the 2008 75 parts per billion (ppb) ozone limit. The rule as proposed applies to 23 eastern states and reduces NOX ozone season allowance allocations beginning in 2017.
The figure on this page is the percent NOX reductions required from the 2014 actual emissions to the proposed 2017 NOX ozone season allowances. As shown in this map, some states will require significant NOX emission reductions to meet the proposed emissions caps. Excess allowances from one state can be sold to another state. The state receiving allowances can continue to buy them, if available, so long as the actual state NOX ozone season total does not exceed the state’s assurance levels, which are 21 percent above the allocation level.
If a state exceeds their assurance levels, individual facilities that also exceeded their assurance levels will be facing penalties, including surrender of future allowances and violation of their Title V permit.
As utilities work through their planning process, a frequent question comes up: When have we done enough to meet environmental regulations at our fossil fuel fired-plants? Quite possibly, the answer is never.
Part of the issue involves how environmental statues are written. In the case of this most recent ozone issue, the Clean Air Act requires EPA to review the National Ambient Air Quality Standards (NAAQS) every five years. As is well known, EPA never loosens the NAAQS. It only goes in one direction- tightening the standard. Another second component is the barrage of court cases from environmental groups pushing for more stringent interpretations of the law. The final part of the issue is for EPA to require new controls on the primary emitting sources. In the case of ozone formation, NOx and volatile organic compounds are the primary culprits. Deciding which sources must be controlled and how much control will be required is the point where science, politics and law intersect and outcomes become unpredictable.
Despite the impressive reductions in multiple pollutants, fossil fuel sources are the target of political pressure to reduce environmental impacts or close. However, are utilities doing more than their fair share? In the case of ozone precursors, EPA determined in 2011 that 15,465,216 tons of NOX were emitted nationwide by all sources and 58,878,011 tons of VOCs were emitted nationwide by all sources. In 2011, electric utilities emitted 2.0 million tons of NOX and were down to 1.7 million in 2014. Electric utility VOC emissions were negligible. It seems like EPA is spending a lot of effort on electric utilities where they have only 2.2 percent of the total nationwide ozone precursor annual emissions. However, so long as there is significant political and legal pressure to get rid of fossil fueled power plants, standards will keep getting tougher to meet until EPA regulations get rid of most of our fossil fuel-fired power plants.