Public
Missouri
• The Missouri Department of Natural Resources (MDNR) is the
lead agency
• MDNR has an established group working on ACE
Implementation
• Prepared/submitted two information requests to affected
units
• Held stakeholder and public meetings
• Establish unit-specific emission limitation by the end of
2020
Kansas
• The Kansas Department of Health and Environment (KDHE) is the
lead agency
• KDHE has several individuals assigned to ACE compliance
• Held stakeholder and public meetings
• The affected units have hired a third party consultant for ACE
implementation
• Establish unit-specific emission limitation by the end of
2020
16
What are the States doing locally?ACE Compliance
Implementation
Information Request for Missouri Designated Facilities under the
Affordable Clean Energy (ACE) Rule Heat Rate Improvement (HRI)
Analysis
Please review the following information request. An optional
spreadsheet has been provided for facilities to provide the
information requested with regards to the facility baseline and
future plan sections below. The spreadsheet should not be used to
provide the information requested in the upgrade studies
section.
Facility Baselines:
Facilities should provide information about each individual
electric generating unit at their facility that meets the
applicability criteria for a designated facility as found in the
ACE rule at 40 CFR 60.5775a (hereafter referred to as “affected
units”).
A. Current Heat Rate Technology and Practices a. Discussion of
current technology/work practices for each affected unit with
comparisons to the BSER candidate technologies/work practices
listed in section III.E.2.d. of the ACE Rule (starting at 84 FR
32538). The response should provide the date when the technology or
work practice was first installed, upgraded, and/or or implemented.
The response should also provide the capital cost incurred for
installing or upgrading any currently installed technology, and a
discussion about the remaining useful life and/or replacement
schedule for the technology. The response should also provide the
ongoing operating maintenance costs for any current technologies or
work practices for each unit.
i. Neural Networks/Intelligent Sootblowers 1. Neural Networks 2.
Intelligent Sootblowers
ii. Boiler Feed Pumps iii. Air Heater and Duct Leakage Control
iv. Variable Frequency Drives (VFDs)
1. VFDs on Induced Draft Fans 2. VFDs on Boiler Feed Pumps
v. Blade Path Upgrade (Steam Turbine) vi. Redesign/Replace
Economizer
vii. HRI Techniques – Best Operating and Maintenance (O&M)
Practices 1. Adopt HRI Training for O&M Staff 2. Perform Onsite
Appraisals to Identify Areas for Improved Heat Rate
Performance 3. Improved Steam Surface Condenser Cleaning
For items B and C below, facilities should provide this
information for the calendar years 2014-2018 for each affected unit
at the facility. For facilities that measure, record, and/or report
this information using different methods than those listed below,
the facility may provide multiple sets of this
Information Request for Missouri Designated Facilities under the
Affordable Clean Energy (ACE) Rule Heat Rate Improvement (HRI)
Analysis
Please review the following information request. An optional
spreadsheet has been provided for facilities to provide the
information requested with regards to the facility baseline and
future plan sections below. The spreadsheet should not be used to
provide the information requested in the upgrade studies
section.
Facility Baselines:
Facilities should provide information about each individual
electric generating unit at their facility that meets the
applicability criteria for a designated facility as found in the
ACE rule at 40 CFR 60.5775a (hereafter referred to as “affected
units”).
A. Current Heat Rate Technology and Practices
a. Discussion of current technology/work practices for each
affected unit with comparisons to the BSER candidate
technologies/work practices listed in section III.E.2.d. of the ACE
Rule (starting at 84 FR 32538).
The response should provide the date when the technology or work
practice was first installed, upgraded, and/or or implemented. The
response should also provide the capital cost incurred for
installing or upgrading any currently installed technology, and a
discussion about the remaining useful life and/or replacement
schedule for the technology. The response should also provide the
ongoing operating maintenance costs for any current technologies or
work practices for each unit.
i. Neural Networks/Intelligent Sootblowers
1. Neural Networks
2. Intelligent Sootblowers
ii. Boiler Feed Pumps
iii. Air Heater and Duct Leakage Control
iv. Variable Frequency Drives (VFDs)
1. VFDs on Induced Draft Fans
2. VFDs on Boiler Feed Pumps
v. Blade Path Upgrade (Steam Turbine)
vi. Redesign/Replace Economizer
vii. HRI Techniques – Best Operating and Maintenance (O&M)
Practices
1. Adopt HRI Training for O&M Staff
2. Perform Onsite Appraisals to Identify Areas for Improved Heat
Rate Performance
3. Improved Steam Surface Condenser Cleaning
For items B and C below, facilities should provide this
information for the calendar years 2014-2018 for each affected unit
at the facility. For facilities that measure, record, and/or report
this information using different methods than those listed below,
the facility may provide multiple sets of this information for each
affected unit based on the various methods used by the facility.
For each set of information provided, the facility should provide
an explanation of the method used to measure, record, and/or report
this information along with the purpose and/or requirement for
using such method. Similarly if the data set includes substituted
data for missing time periods, the facility may identify all the
substituted data in the submission.
B. CEMS Data
a. Hourly heat input (mmBTU) from 2014 – 2018
b. Hourly CO2 emissions (lbs) from 2014-2018
c. Hourly energy generation (MWh) both gross and net
C. Fuel input data
a. Monthly mass of coal input (tons) from 2014-2018
b. Monthly average heat content of coal used (mmBTU/ton) from
2014-2018
c. Monthly mass input of other fuel types (provide the unit of
measurement) from 2014-2018
d. Monthly average heat content of other fuel types (mmBTU/unit)
from 2014-2018
e. Monthly calculated CO2 emissions (tons)
f. Monthly energy generation (MWh) both gross and net
Upgrade Studies:
For each of the seven BSER technology categories in ACE, the
facility should provide the following analysis for each affected
unit at the facility. The facility should provide this information
and discuss the feasibility and impact of each technology upgrade,
even if the particular technology upgrade will have a negligible
heat rate improvement. If the current unit is already meeting the
BSER description in ACE for the current technology, and information
regarding the current technology or work practice has already been
provided in response to the facility baseline questions, no
additional study or information for that particular technology or
work practice is needed at this time.
The following information should be provided based on previously
performed engineering feasibility studies if such studies are
available. For previous studies, the facility should provide the
date the study was performed and the company that performed the
study. If such previous studies are not available, facilities may
defer to the charts in the federal ACE rule. Alternatively,
facilities may perform new feasibility studies if no previous study
is available and the facility does not wish to use the charts
provided in the ACE rule for any of the seven candidate technology.
For any previous or new study provided, the study should provide an
evaluation of the following factors assuming the current unit is
upgraded in order to meet the description for BSER described in the
ACE rule for each of the seven BSER technology categories. When
provided the anticipated heat rate improvement potential of a
project, the study should assume each upgrade is installed or
implemented independently of any other upgrades. The facility
should provide any calculations and engineering analysis needed to
justify the responses provided.
a. Feasibility
b. Detailed cost estimate of upgrading the current unit (capital
cost)
c. Detailed explanation of the ongoing operating and maintenance
costs associated with the upgrade
d. Anticipated percent improvement in heat rate
e. Anticipated degradation of the technology and the impact of
the anticipated degradation on heat rate for the unit
f. Anticipated useful life of the upgrade
Interactive Effects
If any of the technology upgrade options or work practice
improvements identified in the upgrade study would have interactive
effects that would impact the cumulative percent heat rate
improvement such that the improvement would not just be a sum of
the independent heat rate improvements, please provide a discussion
of these interactive effects. Please include along with this
discussion the appropriate calculations and reasoning for such
anticipated interactive effects.
Future Plans
Discuss future plans for the facility. Include the following,
and any other relevant information.
a. Projections and discussion of future electrical generation at
each unit, with particular regard to increases or decreases in
generation/utilization.
b. Planned upgrades which are not part of BSER as identified in
ACE which may have impact on either gross or net heat rate (e.g. if
a new emission control technology upgrade is planned that will draw
auxiliary load from the facility, thus affecting net heat
rate).
c. Plans to change fuel sources or ratios in the next 10 years
if such plans exist.
d. Plans to retire the facility in the next 10 years if such
plans exist.
