|
|
In 1990, EPA released amendments to the Clean Air Act. In these amendments, EPA made provisions for acid rain, commonly known as Titile IV. Although the provisions affect only a small amount of the sources of acid rain gases, the improvements caused are expected to be significant. With the creation of Title IV, EPA implemented two new concepts. These concepts are:
1. Emissions Trading
2. National Emissions Cap
Basically, Title IV aims to reduce the total nationwide electric utility emissions of SO@ by 10 million tons per year by the year 200. This would be a 50 percent reduction from the emissions in 1980. Also, Title IV puts a cap on the electric utility SO2 emission level at the 10 million ton per year level. Therefore, at no time in the future can an increase in SO2 emissions occur.
In order to accomplish its goals, Title IV established a nationwide system of SO2 emission allowances. These allowances are expressed in terms of tons of SO2 emitted per year, and the basic allowance is emission of 1 ton per year of SO2. It is important to note that no source affected by Title IV can emit SO2 without holding an allowance for the emission. If a source does this, it may have to face judicial action. Also, if a source want to increase production and therefore increase emissions, it must obtain an emission allowance from another source that has reduced emissions. This is known as emissions trading
In addition to the SO2 reduction, Title IV calls for a 2 million ton reduction in NOx. This reduction will be accomplished through burner modifications and will be measured from the amount of NOx that would have been emitted in the year 200 if no modifications had been made. In terms of NOx emissions, Title IV does not require that industries install postcombustion controls for monitoring. Also, unlike the SO2 emission reduction program, there is no NOx emission allowance system or emission cap for NOx.
The above sources can be divided into four main groups:
1. PHASE I SOURCES : This category is composed of the 110 electric generating plants (about 261 individual units) that were in existence on 15 November 1990 (the day that the revisions to the Clean Air Act were signed). The large amounts of SO2 emitted by these sources were mostly due to the burning of high-sulfur coal. Since the burning of high-sulfur coal is primarily done in the eastern United States, all of these 100 sources were located east of the Mississippi River.
2. PHASE II SOURCES : This category of sources includes ALL electric utility steam electric generating units larger than 25 MWe. By "all", I mean that Phase II sources include new and old sources as well as Phase I sources larger than 25 MWe. Approximately 2200 individual units are affected by Phase II. Systems excluded fro Phase II were existing combined-cycle plants, small power production, or cogeneration facilities that fall under the Public Utility Regulatory Policies Act (PURPA). However, any post-1990 combined-cycle and cogeneration facilities ARE subject to Title IV.
3. NEW UNITS: This includes units whose operation began after the 199o ammendments to the Clean Air Act were enacted.
4. OPT-IN-SOURCES : This category of sources includes those sources that are not directly affected by Title IV, but choose to become affected so that they can sell their SO2 emission allowances to electric utilities. After all, Title IV states that all emitting sources will be given or must obtain emissions allowances. The allowances, which will be issued every year, must be held for ALL emissions (i.e. existing and new sources).
In 1980, the 110 sources that are categorized as Phase I emitted about 10 million tons per year of SO2. After meeting the Phase I limits, these sources will emit approximately 5 million tons total. The Phase I sources were required to meet the legislated limits no later than 1 January 1995, or they could file for an extension and additional allowances with the EPA. If the proper actions were not taken, Phase I sources were subject to severe penalties.
EPA developed the emission allowance for Phase I sources based on an SO2 emission rate of 2.5 pounds of SO2 per million Btu heat input (lb/mmBtu). Since the standard was not in terms of rate, but rather in terms of annual quantity, it was assumes that Phase I sources would meet it by any combination of the following:
If a Phase I source reduced emissions to below 1.2 lb/mmBtu before the deadline, that source was eligible to receive the amount of reduction time two in allowances to be used at other plants in order to meet the Phase I requirements. ALso, if an individual unit is retired, the allowances for than unit can be applied to another unit to ensure compliance with Phase I standards. Fianlly, if a source employs renewable energy technology (i.e. solar, wind, geothermal, etc), for a portion of its electricity generation, the EPA could issue bonus allowances to the utility.
The Phase II emission limit is 1.2 pounds of SO2 per million Btu heat input (lb/mmBtu). These sources have to be in compliance with regulations by 1 January 2000. If, in 1985, the unit emitted less than 1.2 lb/mmBtu, the allowances for that unit were set to the 1985 emission rate. Therefore, those units are not allowed to increase emission above the 1985 emission rate. If Phase II sources are not able to meet the emission limil=ts, they are able to acquire additional allowances.
The calculations for Phase II limits were based on a variety of things because individual units were given special allowances to account for unique operating conditions that may have been in existence in 1985. Some example of theses special conditions are using primarily natural gas in 1985 when the unit could have used oil, operating at an unusually low capacity in 1985, operating in smaller untility systems or lacations where there are low emission rates historically. The inclusion of these special conditions was aimed at benefitting states that have historically produced very low emissions due to good practices.
No New units can operate without first obtaining allowances. New sources that are owned and operated by an independent power producer (IPP) must also obtain allowances prior to operation. Title IV states that IPPs have the right to purchase emission allowances from the EPA at a price of $1500 a ton or through auction.
If a source is not directly affected by Title IV, but chooses to be affected by it, the emissions from that source become allowances, which can be transferred to another, already affected, source. The amount of the allowances depends on the actual or permitted (which ever is less) emission of the unit in 1985, based on the 1985 emission rate. If the allowable current emission rate (lb.mmBtu) at the time of application is less than the rate in 1985, the EPA will use the lower emission rate and apply it to 1985 operational data.
Any source that is exempt from Title IV cannot opt-in
The major advantage to opting-in to the program is selling emission allowances. The disadvantages of opting-in to the program are:
I. A Title IV source is automatically a Title V source. If the source was previously exempt from Title V, it may now have to obtain a Title V operating permit
II. Once a source makes the decision to opt-in to the program, emission allowances are set for that source and the source will not be able to increse emissions unless additional allowances are obtained.
As was already stated, all Title V sources must have a Title V national operating permit. For Phase I sources, the permit was available through EPS and had to be obtained by 1993. For Phase II sources, permits will be issued by local authorites at the expiration of the initial Phase I source permits (1998).
Title IV requires that sources sub,it a plan as to how it will achieve its emissions allowances as well as how compliance with teh allowances will be determined. Also, all Title IV sources have to install continuous monitoring equipment. For Phase I sources, the deadline was 1 January 1995. For all new sources, the deadline for installment is before the beginning of commercial operation. Finally, opt-in sources must have the proper equipment installed before they officially become a Title IV source.
If, in any given year, a Title IV source exceeds its emission allowance, the source must pay EPA $2000 per ton of emission that exceeds the allowance. Also, the source's allowances for the year following exccedance will be reduced by the amount of excess in the preceding year.
****For additional information about regulatory programs for sulfur and nitrogen oxide emissions, please refer to the following web pages: