Twinkle Tose Power and Light generates electricity in the St. Bradley area of the state. They have two closely located generating complexes; their main plant at Dalboy Station and a smaller plant called Poolside. The metropolitan area where the plants are located is considered non-attainment for ozone, PM 10 emissions, sulfur dioxide, and nitrous oxides. Twinkle Tose has problems with VAR support in the industrial area of the city and growth in the suburbs has pushed their generating capacity to where they can no longer meet even routine summer and winter peaks with their own generating capacity.

1. Mc-Andrew suggests that Twinkle Tose should build unit #4 at Dalboy Station. The original plan for the station called for four 500 megawatt PC units, so there is easily enough space to support such a layout. Because Twinkle Tose burns high sulfur Illinois coal (4.5 lb/MBTU) the new 500 megawatt unit would equipped with scrubbers and low Nox burners (0.71 lb/MBTU Nox). Mc-Andrew points out that not only would the plant provide the needed VAR support for the industrial area, but it would also cover the summer and winter peaks. It would also provide Twinkle Tose with a more politically correct image because it would be their first scrubbed unit and would show that they were trying to be environmentally responsible stewards. Mc-Andrew also points out that load on Dalboy and Poolside has grown 40% since the base years for calculating sulfur credits under the Clean Air Act and the company now spends considerable money each year on the purchase of sulfur credits. If Twinkle Tose puts in a scrubbed unit, Mc-Andrew points out that their average SO2 emissions per million BTU of fuel fired will fall. This will reduce their needs to buy sulfur credits from their present expenditures and save the company money in this way since this will bring their emissions down from the current 4.5 lbs/MBTU.

1. Would Twinkle Tose likely be able to get a permit to build Dalboy unit #4 as proposed? Why do you believe they either could or could not get the permit?
2. Are there any emissions control technologies that can be added to this PC plant that are missing from Mc-Andrew’s proposal and if the technology was added, would it likely change whether they could get the permit?
3. What three year time period is used to determine how many SO2 credits Twinkle Tose is receiving?
4. If Twinkle Tose could get the permit to build Dalboy unit #4, is Mc-Andrew correct that the company would spend less on sulfur credits each year because of lowering the average lbs/MBTU of SO2 emitted? Why or why not – give an explanation.

1. Chasen does not like Mc-Andrew’s plan. He points out that coal plants are under considerable scrutiny. He says that the new State implementation plan will regulate mercury emissions and that the area will most likely be considered non-attainment with respect to Mercury under title I of the CAA as soon as the state plan comes out in two years. For this reason Chasen says the State will never allow a coal plant to be built there because of title I mercury emissions in a non-attainment area. Instead Chasen says that Twinkle Tose should build 500 megawatts of gas peaking capacity. Chasen points out that the real problem for the company is not meeting winter and summer peak demand and that this can be done more cost effectively with a lower cost set of gas peaking turbines. Further because natural gas is clean burning it will not add any sulfur credit costs, and will not release particulate matter. Because natural gas fuel does not contain nitrogen Chasen adds that no nitrous oxides will be produced by gas turbines. For these reasons Chasen says he can get a permit to build a gas peaking plant in a non-attainment area while Mc-Andrew will never get a permit to build a coal plant.

1. Is Chasen right that the State will block a coal plant permit because the area will be classified as Title I non-attainment for mercury in two years? Why or why not – explain.
2. If the natural gas to be burned by the plant really were pure methane (CH4), is Chasen correct in claiming that gas turbines will produce no sulfur or nitrous oxide emissions? Why or why not – explain.
3. Will Chasen be able to get a permit for the gas peaking plant as proposed? Why or why not? – What barrier to granting the permit will have to be overcome? Explain.

1. Robber is the manager at the Poolside plant and he wants improvements at his plant, not Dalboy. Robber complains that his plant has been treated like the obsolete step-child for decades. Robber has two 35 megawatt stoker boilers. The beasts flood the air with particulate matter, and produce 2.5 lbs/MBTU of nitrous oxides and 5.3 lbs/MBTU of sulfur dioxide (they use stoker coal from a different mine than Dalboy). Robber proposes to replace the two obsolete stoker boilers with two 150 megawatt Fluidized Bed Combustion units and 270 megawatts of gas peaking turbines. Robber points out that this alternative will give as much new generation as any of the other plans and will give a better balance between the need for baseload and VAR support and the need to meet summer and winter peaks. Robber points out that FBC is an approved best available control technology so it will easily meet any new source performance standards with its 95% SO2 control and 0.4 lb/MBTU nitrous oxide emissions. His natural gas peaking turbines will only produce 0.12 lbs/MBTU of Nox. Robber says that putting money into his old power station will lower emissions over-all and will therefore meet any title I requirements for construction in a non-attainment area.

1. Although exact figures would require use of capacity factor assumptions, is it possible that Robber can lower emissions from his plant by adding capacity? Explain why or why not.
2. Will Robber likely be able to get a permit for his plan? Why or Why not? Explain.

1. With all this Title I business going on at the power plant, Toe Boy, the manager of the near by rock quarry, is glad the Clean Air Act does not effect his operations.

1. Which titles of the Clean Air Act will likely impact which parts of Toe Boy’s quarry operation?

1. Air-Rick is the manager of the Dalboy Station. The offices at the Dalboy Station are relatively old and are cooled in the summer by window air conditioning units. On a hot July day Air-Rick’s window air conditioner breaks down. Air-Rick calls in his secretary, Amy, who is a bit of a handi-woman and asks her to fix his air conditioner. Amy checks the air conditioner out and says that the freon has all leaked out of the unit. Air-Rick knows that there is a supply of old freon containers in the basement so he orders Amy to go get a freon container and recharge the unit for him with a fresh charge of freon. While she is recharging the unit, the local EPA inspector, Meany Paul, stops by Air-Ricks office to announce that he is making a surprise inspection at the plant.

1. Could Air-Rick be in any trouble under the Clean Air Act for what is going on in his office? Which if any titles of the Clean Air Act might apply and how would they apply?
2. What kinds of Actions could Meany Paul take against Air-Rick if he finds a violation in the little office repair job going on? Explain which title of the Clean Air Act if any would provide the right to the action?

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