A great synopsis of the ruling that vacated the Cross State Air Polution Rule was given in today’s ASME Capitol Update newsletter – provided here in it’s entirety (other than the author’s email address, which I can provide to you on request):
FEDERAL APPEALS COURT VACATES EPA’S CROSS STATE AIR POLLUTION RULE
On August 21st, the U.S. Court of Appeals for the District of Columbia ruled in a 2-1 decision that the Environment Protection Agency (EPA) exceeded its authority in crafting the Cross State Air Pollution Rule (CSAPR). EPA had argued that CSAPR would lead to reductions of nitrogen oxide and sulfur dioxide emissions by more than 50 percent from 2005 levels by 2014. The rule’s challengers argued that the rule would place an undue strain on the country’s electric grid.
In its ruling, the Court found that “although the facts here are complicated, the legal principles that govern this case are straightforward: Absent a claim of constitutional authority (and there is none here), executive agencies may exercise only the authority conferred by statute, and agencies may not transgress statutory limits on that authority.”
“Here, EPA’s Transport Rule exceeds the agency’s statutory authority in two independent respects. First, the statutory text grants EPA authority to require upwind States to reduce only their own significant contributions to a downwind State’s nonattainment. But under the Transport Rule, upwind States may be required to reduce emissions by more than their own significant contributions to a downwind State’s nonattainment. EPA has used the good neighbor provision to impose massive emissions reduction requirements on upwind States without regard to the limits imposed by the statutory text. Whatever its merits, as a policy matter, the EPA’s Transport Rule violates the statute.”
“Second, the Clean Air Act affords States the initial opportunity to implement reductions required by EPA under the good neighbor provision. But here, when EPA quantified States’ good neighbor obligations, it did not allow the States the initial opportunity to implement the required reductions with respect to sources within their borders. Instead, EPA quantified States’ good neighbor obligations and simultaneously set forth EPA-designed Federal Implementation Plans, or FIPs, to implement those obligations at the State level. By doing so, EPA departed from its consistent prior approach to implementing the good neighbor provision and violated the Act.”
“For each of those two independent reasons, EPA’s Transport Rule violates federal law. Therefore, the Rule must be vacated.”
The rule was remanded to EPA to be rewritten.
The 104-page decision may be read at:
Paul Fakes covers public policy-related energy issues for ASME. He can be reached at email@example.com
It’s back to the drawing board for the EPA…
If any of you have experienced water hammer in your HRSG during load changes – you may benefit from the discussion on LinkedIn.
It’s been going on for a few weeks now, and there the discussion includes some good ideas on how to fix water hammer issues.
, Water Hammer
This month’s Electric Light & Power magazine has an interesting article on Energy Storage, starting on page 58. It’s actually an interview with Edwin Feo, the managing partner of USRG Renewable Finance.
One of the points they make, is that fast energy storage can be used for frequency regulation, to reduce the amount of ramping at power plants. I would be curious if anyone has made a study or has the data to support the heat rate impact their plant is seeing due to increased frequency and speed of ramps – such as those seen to balance wind generation.
This would make a great paper for the ASME Power Conference coming up in July 2012.
If you have another idea for a paper, please let me know. I’m the Paper Coordinator for Track 24 (Simple and Combined Cycles) and am actively looking for additional papers (and/or panel ideas) for our sessions. If your idea doesn’t fit Track 24, I can help you get in touch with the right Track Chair as well.
I was surprised to hear of the large power outage across the Southwest last night.
Power was out from Yuma, AZ to San Diego, CA and into parts of Mexico. Approximately 5 million people were in a blackout – which started right around 4pm, in the heat of the afternoon and the start of rush-hour traffic.
According to the news reports and statements from APS, the outage was triggered by a worker who was removing some monitoring equipment at a sub-station in Yuma – the equipment had apparently not been working correctly. It must have been behaving very badly for the utility to send out a worker to remove it during the peak time of a hot summer day. The worst case scenario expected by APS was for a blackout in Yuma, AZ. That the outage spread to San Diego and Mexico was unexpected, and will be the focus of their outage investigation.
Back in 2009, there were talks about upgrading the US Transmission grid. An example of one plan is found at NPR.org. In the picture from NPR, if you click the Proposed Lines “off”, you can see that the San Diego area has only one medium sized transmission line feeding it – coming directly from Yuma, AZ.
Most of the power is back on this morning, and airports are beginning to recover from the disruption. But, maybe it’s time to revisit the idea of upgrading the US transmission grid?
The first article I read today was about large scale solar, and the issues around finding enough land. Stepping through a few more items in my inbox, I see this: “A Solar Re-Skin at [The Redskin's] FedEx Field”
(a month old, but still making the rounds in various newsletters)
I did the economic analysis for residential solar panels a few years ago for a friend who lived in Arizona. At that time – before massive federal incentives – you could break even on installing solar panels on a new house. For a new house, the added capital costs were expected to be approximately $300/month over a 30 year mortgage to cover a $300/month electric bill. So to me, it seems like a no-brainer for new developments to include solar panels by default.
Retrofits like the one being done at the Redskin’s stadium may cost more, but with current incentive programs it can still make economic sense for the owners, and from an image standpoint it’s great marketing.
And if you’re into job creation, the incentive programs for small-scale solar could put a lot of people to work. Here in Washington state, there are additional incentives for solar installations – but the equipment must all be manufactured within the state to get the maximum payback rates. The policy with the incentives was put together as a jobs bill, not an energy bill.
With all the current incentives for solar power, I think it might be worth looking to see if we can find a little bit of room.
The 2012 ASME Power Conference has been announced, and we’re looking for engineers to participate.
I was lucky enough to be elected as the Combined Cycle Commitee Paper Coordinator for 2012, so if you have any ideas for papers, presentations or panel sessions; I’d love to hear about them!
You can post ideas here as a comment to this post, or send me a private message directly. Even if your idea does not involve combined cycle equipment, I can point you to the right coordinator to get in touch with.
The 2012 ASME Power Conference will be held in Anaheim, CA July 30-August 3, 2012. The location is sure to have many options for side trips and vacations along the way.
The conference will also be co-located with the 20th International Conference on Nuclear Engineering (ICONE), which should bring a lot of interesting key note speakers and presentations, as well.
For more information on the conference, visit ASME’s Website.
Abstracts for papers are due by November 21, 2011, so there is still time to put your thoughts together. More information on the publication schedule is also available at the conference website.
Hope to see you all in Anaheim next year!
I’ve added forum capabilities to the blog – check out the categories by clicking on “The Forum at T2E3″ in the page list at the upper-right of this page, or visit the following link:
The Forum at T2E3
If you have ideas for new categories or have any trouble posting a question or comment, please let me know with a comment to this post, or send me an email.
Thanks for your participation!
Power Technology reported today that Japan has collected enough wood waste from the rubble of the March 11, 2011 earthquake to fuel 5 new power plants.
Japan to Construct Combustion Power Plants – Power Technology.
Based on some gross assumptions, the 5 million tons of wood waste they’ve collected will fuel five 10 MW power plants for 12-15 years.
Assumptions include: the wood waste has an average heating value of 6,800 Btu/lb (20% moisture), net plant heat rate is 14,000 Btu/kWh and plant capapcity factors will be better than 80%.
I will be presenting a seminar on how to calculate key performance indicators for combined cycle power plants at this year’s ASME Power Conference.
For more information on the conference – including how to register for the workshop, see ASME’s website.
Looking forward to seeing many of you next month!
As reported by Combined Cycle Journal, presentations at this year’s spring CTOTF gathering included an outline of the new NFPA 56; regulations on safe handling of natural gas piping systems – including preparation for repairs, venting and purging.
From the article, regarding the new “Provisional Standard for the Commissioning and Maintenance of Fuel Gas Piping Systems”:
“NFPA 56 provides minimum safety requirements for the commissioning and maintenance of fuel gas piping—from the point of delivery to the equipment shutoff valve—found in power plants and industrial and commercial facilities. Activities impacted include the cleaning of new or repaired piping systems, placing piping systems into service, and removing piping from service. The term “system” applies to all system components—including valves, regulators, and other appurtenances—and any segment of the system that can be isolated from it.”
The standard, which is expected to be released later this year will require new operating procedures and inspections for most facilities. To learn more about NFPA 56 from the CTOTF presentation, visit www.ctotf.org- there should be an item on the left-hand navigation bar for “NFPA 56″. The link opens a PDF of the presentation made by John Puskar of CEC Combustion Services Group. A full copy of the NFPA 56 draft is included at the end of the presentation for industry review (note, this is not the official release version – that is not expected to be available until later this year).
Natural gas is a powerful commodity. Please be safe.
Thank you again to CCJ for another timely and important article.