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California Desert Air Working Group 2014 Conference Pala, California October 8 & 9, 2014. Meeting the Need for Reliable Electricity Post-SONGS. Mohsen Nazemi P.E . Deputy Executive Officer South Coast Air Quality Management District. What is South Coast Air Quality Management District?.

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Meeting the need for reliable electricity post songs

California Desert Air Working Group 2014 Conference

Pala, California

October 8 & 9, 2014

Meeting the Need for Reliable Electricity Post-SONGS

Mohsen Nazemi P.E.

Deputy Executive Officer

South Coast Air Quality Management District


What is south coast air quality management district

What is South Coast Air Quality Management District?

  • Local Air Pollution Control Agency in Southern California (All of Orange & Non-Desert Portions of LA, Riverside & San Bernardino Counties)

  • Population of 16.4 million (about half of State’s population)

  • Worst air quality in the nation (Ozone & PM 2.5)

  • Receives and Processes about 9,000 permit applications annually

  • Regulates over 27,000 stationary sources


Scaqmd s role responsibility in permitting power generation

SCAQMD’s Role/ Responsibility in Permitting Power Generation

  • Local Air Quality Permitting Agency

  • Primary Permitting Authority for

    Power Generation for less

    than 50 Megawatts (MW)

  • Co-Permitting Authority for thermal

    Power Generation projects of 50MW or greater

    • CEC has Primary Licensing and CEQA Lead Agency Authority/ Responsibility (AFC Process)

    • SCAQMD has Authority/ Responsibility to issue Federal Permits (Title V/ PSD Permits)

  • Small Distributed Generation – Exempt from Permits/ Must meet CARB Certification


San onofre nuclear generating stations songs shutdown

San Onofre Nuclear Generating Stations (SONGS) Shutdown

Since Jan. 2012, SCE has shutdown both SONGS Units 2 & 3 due to leaks in radioactive steam tubes

Total of 2,200 MW lost – Shortfalls in South Orange County & San Diego

SCE announced permanent shutdown of SONGS on June 7, 2013


Actions post songs shutdown

Actions Post SONGS Shutdown

  • Retirement of SONGS on June 7, 2013

  • Governor’s Office called upon energy agencies, utilities and others to develop a plan

    • Multi-agency review of options to assure reliability

    • Preliminary Reliability Plan for LA Basin and San Diego developed by multi-agency team was reviewed in September 2013 and updated in August 2014 at CEC workshops held at UCLA, as part of IEPR proceeding

  • CPUC and CAISO made policy decisions in March 2014 that partially implements the “Preliminary Reliability Plan”

  • SCAQMD is proposing to implement contingency measures


Cpuc s long term procurement plan ltpp

CPUC’s Long Term Procurement Plan (LTPP)

  • The LTPP authorizes new infrastructure to maintain system reliability

  • Looks forward 10 years to identify system and local needs

  • Considers alternative futures (renewable portfolio, demand and supply, and transmission scenarios)


Cpuc s 2012 ltpp

CPUC’s 2012 LTPP

  • Track 1 – D.13-02-015 authorized SCE to procure electrical capacity in the West LA Basin & Moorpark sub-areas to meet long term local capacity requirements

  • Track 4 – D.14-03-004 authorized additional procurement for SCE and SDG&E to meet local capacity needs as a result of the retirement of SONGS


Cpuc procurement authorization and requirements for sce

CPUC Procurement Authorization andRequirements for SCE*

* Source: CPUC Decision Authorizing Long Term Procurement to Replace Permanent Shutdown of San Onofre Nuclear Station – March 14, 2014


Cpuc procurement authorization and requirements for sdg e

CPUC Procurement Authorization and Requirements for SDG&E*

* Source: CPUC Decision Authorizing Long Term Procurement to Replace Permanent Shutdown of San Onofre Nuclear Station – March 14, 2014


Other requirements actions

Other Requirements / Actions

  • OTC policy was adopted by SWRCB in

    May 2010 with compliance dates linked

    to known replacement projects

  • January 2013, SONGS units shutdown

  • Summer 2012, HB Units 3-4 brought back

  • Summer 2013, HB Units 3-4 converted to synchronous condensers and ISO/utilities begin installation of reactive power equipment at selected substations


Once through cooling generating units

Once-Through-Cooling Generating Units

State Water Resources Control Board Policy

1 Huntington Beach Boilers 3 & 4 (450MW) shutdown Nov. 2012

2 El Segundo Boiler 3 (135MW) shutdown July 2013

3 Haynes Boilers 5&6 (573 MW) shutdown June 2013

4 Scattergood Boilers 3 (460 MW) shutdown Dec 2015


Scaqmd s major source thresholds offset requirements

SCAQMD’s Major Source Thresholds & Offset Requirements

*Emission Reduction Credits

**Reclaim Trading Credits


Meeting the need for reliable electricity post songs

PM10 ERC Supply & Cost2000 – 2014*

*Thru May 2014


Rule 1304 1 electrical generating facility fee for use of offset exemption

Rule 1304.1 - Electrical Generating Facility Fee For Use Of Offset Exemption

  • Rule 1304(a)(2) exempts electric utility boiler replacements from offsets, however SCAQMD still has to provide offsets from SCAQMD’s Internal Bank

  • Rule 1304.1 adopted on September 6, 2013 to require fees for use of this exemption & SCAQMD offsets

  • Governing Board directed staff to work with stakeholders to develop guidelines for use of funds

    • “. . .priority will be placed on the use of the funds to improve air quality consistent with the AQMP in the impacted, surrounding communities”


Rule 1304 1 overview

Rule 1304.1 Overview

  • Rule 1304.1 applicable to Repowering of electric utility boiler units at Existing power plants

  • Provides PM10, NOx, SOx and VOC Offsets to repowering projects for a fee

  • Current lack of PM10, SOx and NOx ERCs in the open market


Proposed guidelines for use of rule 1304 1 mitigation fees

Proposed Guidelines for Use of Rule 1304.1 Mitigation Fees

  • Impacted Surrounding Communities consistent with AQMP with Emphasis on:

    • Preferred Resources

      • Energy Efficiency

      • Demand Response

      • Energy Storage

      • Renewables

    • Meeting AQMP Reduction Needs

    • Near Zero- or Zero-Emission Vehicles & Charging Infrastructure


Proposed rule 1304 2 purpose

Proposed Rule 1304.2 Purpose

  • Implement the “Contingency Measure” in the Governor’s Multi-agency’s “Preliminary Reliability Plan”

  • Promote preferred resources

  • CPUC Loading Order

  • CARB AB32 Scoping Plan

  • SCAQMD Energy Policy

  • Facilitate grid reliability

  • Assist in implementation of attainment strategy


Proposed rule 1304 2 overview

Proposed Rule 1304.2Overview

  • Require a Fee for SOx/PM10 Offsets obtained from SCAQMD offset accounts for New Greenfield Electrical Generating Facility

  • Not mandatory to obtain offsets from SCAQMD accounts

  • Fee proceeds to be invested in air pollution improvement strategies consistent with the Air Quality Management Plan and/or local impacts


Use of proposed rule 1304 2 fees

Use of Proposed Rule 1304.2 Fees

  • Impacted Surrounding Communities, consistent with AQMP with Emphasis on:

    • Preferred Resources

      • Energy Efficiency

      • Demand Response

      • Energy Storage

      • Renewables

    • Low- or Zero-Emission Vehicles & Charging Infrastructure

  • Consistent with Proposed Rule 1304.1 Guidelines


Psd t v ghg tailoring rule

PSD/T-V GHG Tailoring Rule

PSD Permitting

  • New projects with emissions of

    >100,000 tpy of CO2e

  • Modifications at an existing Major

    source with increase of >75,000 tpy

    of CO2e

    Title V Permitting

  • All new and existing sources with PTE>100,000 tpy CO2e

  • Modifications at an existing Major source with increase of >75,000 tpy of CO2e


Ghg tailoring rule actions completed to date

GHG Tailoring Rule – Actions Completed to Date

  • Step 1

    • Established GHG applicability criteria for “anyway sources”

      • “Anyway sources” must address GHG emissions increases of 75,000 tons

        per year (tpy) CO2e or more

    • Went into effect on January 2, 2011

  • Step 2

    • Retains “anyway sources” applicability criteria and established GHG applicability criteria for large air emissions sources

      • PSD Permits for New facilities with GHG emissions of at least 100,000 tons per year (tpy) CO2e and existing facilities with at least 100,000 tpy CO2e making changes that would increase GHG emissions by at least 75,000 tpy CO2e

      • Title V Permits for New and existing sources with GHG emissions above 100,000 tpy CO2e

    • Went into effect on July 1, 2011


U s court of appeal s decision

U.S. Court of Appeal’s Decision

  • On June 26, 2012, The U.S. Court of Appeals for the D.C. Circuit ruled on cases for GHG Regulations

  • The Court of Appeals upheld four of EPA’s GHG rulemakings.

    • Upheld EPA’s Endangerment Finding and the Tailpipe Rule on the merits, and

    • Dismissed the petitions for review of the Triggering/Timing Rule and the Tailoring Rule on standing grounds


Ghg tailoring rule actions completed to date cont d

GHG Tailoring Rule – Actions Completed to Date (cont’d)

  • Step 3

    • Did not lower the applicability thresholds under Steps 1 and 2; these thresholds still apply

    • Establishes GHG PALs for GHG-only sources on a CO2e basis in addition to the already available mass-basis

    • Finalized in July 2012

  • June 23, 2014 Supreme Court split decision (5-4) struck down the PSD & Title V permit requirements for “GHG only sources”, but withheld BACT for GHG for “Anyway PSD Sources”


U s supreme court decision in utility air regulatory group vs epa

U.S. Supreme Court Decision in Utility Air Regulatory Group vs. EPA

  • On June 23, 2014 U.S. Supreme Court ruled in the case of UARG vs. EPA

  • To Sum Up: “We hold that EPA exceeded its statutory authority when it interpreted the CAA to require PSD and TV permitting for stationary sources based on their GHG emissions. Specifically, EPA may not treat GHG as a pollutant for purposes of defining a “major emitting facility” (or a “modification” thereof) in the PSD context or a “major source” in the TV context. To the extent its regulations purport to do so, they are invalid.”


U s supreme court decision in utility air regulatory group vs epa1

U.S. Supreme Court Decision in Utility Air Regulatory Group vs. EPA

  • To Sum Up (continued):

  • “EPA may, however, continue to treat GHG as a “pollutant subject to regulations under this chapter” for purposes of requiring BACT for “Anyway” sources.

  • The judgment of the Court of Appeals is affirmed in part and reversed in part.”

  • The “Anyway” sources account for about 83% of stationary sources GHG emissions,compared to only 3% for the “Non-Anyway” sources under Steps 2 & 3 of Tailoring Rule


Future actions tailoring rule step 4

Future Actions – Tailoring Rule – Step 4

  • 5-Year study will be used to support a “Step 4” rule that might phase-in GHG permitting for smaller sources

  • Determination to consideration same criteria used in Tailoring rule:

    • The time that permitting authorities need [or needed] to ramp up their resources, including developing permitting infrastructure as well as hiring and training staff

    • Sources’ abilities to meet the requirements of the PSD program and permitting authorities’ abilities to issue timely permits, including gaining experience with GHG permitting

    • Whether the EPA and the states could develop [or developed] streamlining measures

  • Rule is due on April 30, 2016, but may not be

    pursued due to the Supreme Court decision


Ghg tailoring rule implementation timeline

GHG Tailoring Rule Implementation Timeline

2011

2012

2013

2014

2015

2016

Step 1 Implementation

Step 2 Implementation

Step 3 Implementation

5-Year Study

Step 4 Phase-in Rule


Epa s new power plants ghg rule proposed rule 111 b

EPA’s New Power Plants GHG RULE Proposed Rule - 111(b)

  • EPA released proposed rule for GHG emissions from new electric generating units(EGUs) in Sept. 2013 

  • Applies to units built/operated after January 8, 2014 

  • CO2 limits based solely on fuel type and size 

  • For natural gas-fired units:

    • — 1,000 lbs CO2/MW-hr for EGUs > 850 MMBtu/hr

    • — 1,100 lbs CO2/MW-hr for EGUs <= 850 MMBtu/hr

    • — EGU with <33% capacity factor is exempt


Epa s existing power plants ghg rule proposed rule 111 d

EPA’s Existing Power Plants GHG RULE Proposed Rule - 111(d)

June 2, 2014 - EPA released proposed rule for GHG emissions from existing EGUs 

  • — Expected to reduce CO2 emissions 30% from 2005 levels by 2030 

  • — Limits carbon intensity of a state’s electrical grid as a whole 

  • — Credit given for demand-side energy efficiency programs and renewable energy programs


Proposed rule 111 d building blocks

Proposed Rule 111(d) Building Blocks

Four building blocks to set emissions target:

  •  Make existing coal-fired EGUs more efficient 

  • — Greater use of lower-emitting EGUs 

  • — Greater use of zero and low-emitting power sources 

  • — Increase demand-side energy efficiency 1.5% annually 

    States have flexibility to comply using any combination of measures


Proposed 111 d target

Proposed 111(d) Target

  • EPA proposed California’s emission baseline is

    698 lb CO2/MW-hr in 2012

  • California’s proposed target is:

    — 537 lb CO2/MW-hr by 2030

    CARB’s Preliminary analyses suggest that California will meet the targets through existing programs


Proposed rules 111 b 111 d schedule

Proposed Rules 111(b) & 111(d) Schedule

  • June 2015 - EPA to finalize 111(b) rule

  • June 2015 - EPA to finalize 111(d) rule

  • June 2016 - States to submit compliance plans

  • June 2018 - States may choose to submit multi-state plans 


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