Diminishing Options For Pm10 Er Cs
Transcript of Diminishing Options For Pm10 Er Cs
Options Diminishing for Obtaining Emission Reduction Credits in
California
Electric Utilities Environmental Conference
January 27 – 30, 2002 Tucson, Arizona
by
Joel Reisman and John LaneGreystone
Environmental Consultants, Inc.
Focus on PM10 ERCs
Background Potential Sources Road Paving ERC Process
Quantity and Cost of ERCs Needed
Typical 520 MW Combined-cycle, natural gas-fired power plant
Varies; 50 – 150 tpy PM10 Emissions PM10 ERCs cost $5,000 to $20,000 per
ton Offset ratio depending on distance from
source – 1.0 to 2.0 Total Cost: $250,000 to $6,000,000
ERC Eligibility
RealPermanentQuantifiableSurplusEnforceableTimely
PM10 Ambient Air Quality Standards (μg/m3)
Period NAAQS CAAQS
24-hr 150 50
Annual
(Arithmetic Mean)
50 ---
Annual
(Geometric Mean)
--- 30
Federal/California PM10 Nonattainment Areas
Potential Sources of PM10 ERCs
Shutdown/replace or install controls on combustion sources
Install controls on material handling sources of dust
Agricultural activities (e.g., burning) Install controls on mobile sources Take enforceable permit limits (e.g., hours) Upgrade woodstoves Pave unpaved roads
Unpaved Road Emission Factor
Eext = k(s/12)a (W/3)b [(365-p)/365] [lb/VMT]
(Mdry/0.2)c
(Assumes vehicle speed > 15 mph)
Source: AP-42 Section 13.2.2 Unpaved Roads
Paved Road Emission Factor
E = k(sL/2)0.65 x (W/3)1.5 [lb/VMT]
Source: AP-42 Section 13.2.1 Paved Roads
Data Needs
Traffic, VMT Silt Content, sMean vehicle weight, WDefaults available for:
Moisture Content, Mdry
p, k, a, b, c Silt Loading, sL
Traffic Data
Traffic counter data preferred
If seasonal, use other data to support traffic data:Number of employeesAmount of product shippedStore receipts
ERC Process
Meet with Agency Prepare/submit application Agency Review ERC certificate issued to road owner Road owner must agree to maintain road Transfer certificate to project (prior
agreement) Surrender certificate to Agency prior to
construction
Potential Stumbling Blocks
BACM, RACT requirements Some Districts have seasonal offsetting
requirements Negative comments from CARB, EPA,
or intervenors New concern – PM2.5
SUMMARY
Tougher to find Banked PM10 ERCs
High CostMust be CreativeMust be able to Substantiate Eligibility
and QuantitiesAgencies/Regulations Must be
Agreeable