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12
GAS GENERATION
generators gas pull is unanticipated.
Recent efforts to address these reliabil-
ity concerns have focused on harmoniz-
ing the natural gas and electricity mar-
kets. Here the tendency is to view these
energy products as essentially identical,
to be traded and scheduled in the same
way, the argument being that elimination
of inconsistencies will increase efficiency
and maximize utilization of existing in-
frastructure to help increase reliability.
But these energy products are not iden-
tical, and this approach overlooks their
significant differences.
Electricity moves at the speed of light,
but flows along the path of least resis-
tance. By comparison, natural gas moves
along the pipeline at no more than 30
mph, but can be directed based on the lo-
cation and amount of compression along
the pipeline. Electric generation can be
sited locally or remotely based on system
needs; natural gas is produced where it
is found geologically and transported to
market. As a result, different economic
and regulatory structures have been de-
veloped for the two industries that reflect
these fundamental physical differences.
Although it is sometimes enticing to see
the parallels in the industries in an effort
to bring them together to work more ef-
ficiently, the physical differences must be
respected.
Rather than trying to force the natu-
ral gas and electricity markets into some
form of common market, policy makers
should instead focus on the infrastructure
needed to help ensure reliability for both
natural gas and electricity customers.
A number of recent proposals to better
harmonize the natural gas and electric-
ity markets from better communica-
tions between electric transmission and
T
he use of natural gas-generated
electricity has grown substan-
tially in recent years, and con-
tinued growth is projected, especially
given expectations around natural gas
price stability and the potential shutter-
ing of coal-fired generation due to envi-
ronmental restrictions. But while natural
gas utilities meet the needs of the electric-
ity generation industry, they must simul-
taneously continue to provide reliable
services for residential, commercial and
industrial customers who use natural
gas directly for heating, end-use appli-
ances, as feedstock in manufacturing, etc.
These uses need not be in competition
with one another given that our nations
abundant natural gas resources can sup-
port growing demand across numerous
economic sectors. The key to serving all
of these needs is adequate investment
in the natural gas infrastructure used to
bring the countrys abundant supplies to
market. Market structures and cost recov-
ery mechanisms must be put into place to
help ensure that natural gas pipeline and
storage facilities are built quickly enough
to keep pace with the growing demand
for natural gas from all sectors.
For a number of years, energy policy
makers have been grappling with the
implications of the increased demand
for natural gas that power generation
creates. The inability of gas-fired gen-
erators to obtain natural gas deliveries
when needed can threaten the reliabil-
ity of electric systems. Similarly, when a
large gas-fired generator is dispatched to
serve electric needs, the pull on the gas
system can be sufficiently large to cause
changes in pipeline pressures and reduce
the gas delivery systems ability to meet
other consumer needs, especially when a
interstate pipeline operators to changes
in the natural gas nomination schedule
will have little success in improving reli-
ability if the natural gas infrastructure is
inadequate to keep up with the growing
demands of the system. For example, in a
recent effort to examine the gas nomina-
tion schedule, electric interests have ar-
gued for more opportunities for gas-fired
generators to nominate gas service to be
able to respond to intraday variations in
electric demand. However, additional
nomination opportunities will have little
impact if the pipeline is already fully uti-
lized. In this instance, improved reliabil-
ity could only come from additional in-
frastructure, whether in the form of new
pipeline or storage capacity.
Natural gas utilities use a variety of
assets to reliably meet the needs of their
customers. These assets include such
things as diverse holdings of pipeline
transportation and storage capacity, pipe-
line no-notice service, and on-system
storage facilities. Utilities continue to
invest in the infrastructure necessary for
reliability. This is due in part to the fact
that utilities, as regulated entities, are pro-
vided the opportunity to recover the costs
of these assets through various approved
cost recovery mechanisms. Energy policy
makers should more closely examine the
market structures that would support
similar investment in gas infrastructure.
They should keep in mind that this infra-
structure is critical to maintaining elec-
tric reliability, and they should introduce
policy that will allow for cost recovery,
thereby ensuring that such facilities can
be financed and built. Unless a robust
investment climate is created to build gas
infrastructure, efforts to harmonize both
markets will continue to fall short.
Need Reliability?
Focus on Infrastructure,
Not Harmony
BY ANDREW SOTO, VICE PRESIDENT, REGULATORY AFFAIRS, AMERICAN GAS ASSOCIATION
1410pe_12 12 10/13/14 11:34 AM
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14
VIEW ON RENEWABLES
permitting and siting process are
critical to achieving gigawatt-scale
offshore wind deployment in the
next decade. Although great strides
have been made to reduce the permit-
ting schedule from the 12 years it took
for Cape Wind to between 2-4 years to-
day, further enhancements by the multi-
tude of federal permitting and regulatory
agencies are needed.
7. Current organizational structures
in the U.S. may make it more difficult
to attain the offshore wind value
found in the study. This is because these
value levels rely on a regional or broader
perspective. Areas such as the Southeast
U.S. that do not have RTOs may find it
difficult to sufficiently socialize and jus-
tify the costs compared to the benefits.
However, working from a regional per-
spective may be more straightforward in
areas that have an ISO or RTO (e.g., ISO-
New England or PJM), but even here each
state and utility involved must be willing
to consider and share in the broader per-
spective, costs, and benefits.
8. Research and development
promise to help reduce initial capital
investment. One of the major market
barriers to offshore wind is the high capi-
tal costs compared to other forms of en-
ergy production. However, research and
development can help lower these costs.
It is my hope that the study findings
will be of great interest to executives,
decision makers and policy makers
throughout the power industry. We hope
this study supports the national conver-
sation and provides valuable insight for
decision makers on laying the ground-
work for offshore wind to become part of
the U.S. energy portfolio.
T
hree years ago, the U.S. Depart-
ment of Energy (DOE) funded
an investigative research team to
conduct a national study on the feasibil-
ity for offshore wind integration into the
U.S. grid. In particular, the technical and
economic viability was studied as one
possible input for the DOE to produce
a roadmap to gigawatt levels of offshore
wind energy, based on the DOEs 20 Per-
cent Wind Energy by 2030 report. This
Offshore Wind initiative would help to
assess the ability to interconnect 54 GW
of deployed offshore wind generating ca-
pacity by 2030.
The DOE-funded study, known as
the National Offshore Wind Energy
Grid Interconnection Study (NOWE-
GIS) was ABB-led and overseen by
experts from ABB, AWS Truepower,
Duke Energy, the DOEs National Re-
newable Energy Laboratory (NREL),
and the University of Pittsburgh Swan-
son School of Engineering.
The team sought to determine the
expected staging of offshore wind de-
velopment in each of the U.S. coastal
regions, develop expected wind gen-
eration production profiles, assess
the applicability of integration study
methods to offshore wind production,
assess a variety of offshore wind col-
lection and delivery technologies, and
consider various regulatory issues.
Three years later, the results are in,
and the prospects are encouraging. The
NOWEGIS team determined eight key
results and observations:
1. The U.S. has sufficient offshore
wind energy resources to con-
sider having at least 54 GW of off-
shore wind. However, the resource
assessmentwhich considered exclusion
zones as a result of military use, commer-
cial shipping lanes, and environmental
concernsindicates that a significantly
larger amount of offshore wind could, in
theory, be utilized.
2. The methods used for evaluat-
ing the integration of land-based
wind energy are also appropriate
for studying offshore wind energy.
The methods currently used for evalu-
ating system impacts of onshore wind
power plants apply directly to studying
offshore wind, and the same types of
data are required.
3. Appropriate technologies exist
for interconnecting large amounts of
wind energy to the U.S. grid. Multiple
technologies designed for both alternat-
ing current (AC) and direct current (DC)
exist that can be used to collect wind-gen-
erated electricity and deliver it to the on-
shore grid efficiently and cost-effectively.
4. At a regional or national level,
offshore wind energy may provide
significant value. NOWEGIS estimated
that the 54 GW of offshore wind would
provide a national reduction of electricity
production costs of $7.68 billion annu-
ally, resulting in an approximate value of
offshore wind at $41/MWh.
5. State policies that recognize the
energy, environmental, and eco-
nomic benefits of offshore wind are
critical to encouraging investment in
offshore wind. State policies can encour-
age offshore wind deployment by creat-
ing demand through renewable portfo-
lio standards (RPS) that establish policy
mechanisms based on the needs of the
state.
6. Reductions in the federal
Offshore Wind Study Offers
Encouraging Prospects
for U.S. Coastlines
BY JOHN DANIEL (ABB), LEAD INVESTIGATOR, NATIONAL OFFSHORE WIND ENERGY GRID INTERCONNECTION STUDY
1410pe_14 14 10/13/14 11:34 AM
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16
ENERGY MATTERS
regulation is just as tricky. A modifcation
is defned as a physical or operational
change to an existing source that in-
creases the sources maximum achievable
hourly rate of air pollutant emissions. So,
if in physically modifying a combustion
turbine in order to increase its heat rate,
you also increase the hourly emission rate
of GHG and NOx, you can change an ex-
isting unit into a modifed unit, which, in
the case of combustion turbines, is then
subject to the same limits as a new unit.
Presto! What was old is new again.
Building block 1 makes it possible to
increase hourly emissions on existing
combined cycle units modifying them
enough that they become subject to the
limits for new units. Building block 2 en-
courages utilities to increase run time so
that tpy increases occur, subjecting plants
to NSR permitting and retroft of add-on
BACT control devices.
The end results of these three rules
is to 1) encourage construction of new
combined-cycle combustion turbines,
internal combustion engines (which are
typically under the MW threshold and
therefore not subject to the rules) and
new renewables, 2) create a regulatory
pathway that turns all existing combined-
cycle units into modifed units subject to
the new unit limits, and 3) discourages
construction of non-peaking simple-cy-
cle combustion turbines and 4) forbid
construction of new coal-fred boilers
without CCS. All of these will signif-
cantly increase costs to ratepayers. And,
remember, enforcement can come at the
request of any public interest group, not
just the EPA.
EPA wants to have its cake and eat it
too. But then, of course, they are the of-
fcial baker!
E
PA wants to use commonsense
to reduce greenhouse gas (GHG)
emissions by shifting electricity
generation to more effcient, less pollut-
ing power plants. In theory, writing reg-
ulations with commonsense is a noble
idea; in reality, EPA has created a recipe
for a no-win scenario for utilities.
EPAs proposed GHG rules split power
plants into three categories: new sources,
existing sources, and modifed sources.
Each group has its own new regulation
and its own diffculties.
New power plants are limited to a gross
energy output-based CO
2
emission limit
expressed in pounds per megawatt-hour
(lb/MWh). The limits can normally be
met for new combined-cycle turbines but
are problematic for non-peaking simple-
cycle turbines and impossible for coal-
fred boilers without Carbon Capture
and Sequestration (CCS). Essentially,
new coal-fred boilers without CCS are
outlawed by this rule and simple-cycle
turbines are limited to less than 2,920
hours per year of operation.
Existing power plants have been given
individual lb/MWh limits by state. In
developing each states limit, EPA estab-
lished four building blocks: 1) heat
rate improvements, 2) dispatch changes
among affected electric generating units
(EGUs), 3) using an expanded amount of
less carbon-intensive generating capacity,
and 4) demand-side energy effciency.
Building blocks 1 and 2 can cause New
Source Review (NSR) permitting prob-
lems for individual EGUs. On one hand,
EPA suggests heat rates can be improved
by specifc best practices and equipment
upgrades, including upgrades to boilers,
steam turbines, and control systems. On
the other hand, EPA has a long history of
enforcement actions against power plants
that make non-routine modifcations to
coal-fred boilers and turbines, despite
the fact that routine is not defned in
the NSR regulations. EPAs success is mea-
sured at over $19.4 billion in control ret-
rofts, penalties, and environmental miti-
gation at almost 100 plants since 1999.
The enforcement case against Ohio
Edison is especially on point. During
the 1980s and 1990s, Ohio Edison de-
veloped a program to improve the heat
rate of the Samis Station units, including
replacements of furnace water wall tubes,
economizer tubes, superheater tubes,
reheater tubes, burners, coal pipes, pul-
verizers and low pressure turbine rotors.
Ohio Edison lost the argument that the
modifcations were routine maintenance
and was ruled to be in violation of the
NSR requirement to obtain a precon-
struction permit. Its worth noting that
emissions increased in terms of tons per
year but not pounds per hour. In other
words, the units were run for more hours
after the modifcation but at the same or
lower hourly rate.
EPA has a two-step test to determine
if a modifcation is subject to NSR: 1)
Is there a physical change or change in
method of operation and 2) is there a
resultant increase in emissions over the
ton per year thresholds. This rather nice-
ly parallels building blocks 1 and 2: 1)
make a physical change to increase heat
rate and 2) dispatch the affected unit for
more hours per year. Bingo! Youve just
triggered NSR permitting. And if your
combustion turbine doesnt already have
add-on control devices for NOx and CO,
then through the best available control
technology (BACT) process, it soon will.
Turning to modifed units, the new
Sticky Recipe:
The Clean Power Plan
BY ROBYNN ANDRACSEK, P.E., BURNS & MCDONNELL AND CONTRIBUTING EDITOR
1410pe_16 16 10/13/14 11:34 AM
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18
www.power-eng.com
BY DOUGLAS A. DIXON AND DAVID E. BAILEY, ELECTRIC POWER RESEARCH INSTITUTE
Available (BTA) options for both impinge-
ment and entrainment control. Those chal-
lenges will continue once BTA is determined
and those technologies must be installed,
properly operated and monitored. Part I of
this article briefly reviews the Rule and the
implementation challenges permit applicants
will have to meet. Part II of this article will
discuss the Technical Challenges.
CLEAN WATER ACT
316(B) RULE FOR
EXISTING FACILITIES
On Aug. 15, 2014 the U.S. Environmen-
tal Protection Agency (EPA) issued its final
regulation implementing this section of the
Act for existing plants with cooling water
intake structures (CWIS). The regulation is
effective on October 14, 2014. Plants in scope
of the rule include those that are capable of
withdrawing more than 2 million gallons
of water per day (MGD) design intake flow
(DIF) from waters of the U.S., have or re-
quire a National Pollution Control Discharge
Elimination System (NPDES) permit, and of
which 25 percent or more is used for cool-
ing. The EPA rule affects over 500 existing
power plants and an additional 500+ indus-
trial facilities (e.g., iron and steel, pulp and
paper, chemical manufacturing) that have
CWIS. The regulation is intended to reduce
the adverse environmental impact to fish and
shellfish that is considered in the rule to be
caused by CWIS impingement (entrapment
of organisms on intake screens) and entrain-
ment (passage of early life stages of organ-
isms through intake screens into the cooling
system). .
EPA COMPLIANCE
STANDARDS
All facilities withdrawing > 2 MGD DIF
are in scope for both impingement and en-
trainment compliance control; however, only
facilities withdrawing >125 MGD actual
intake flow (AIF) are required to complete
entrainment studies to determine entrain-
ment BTA. Entrainment study requirements
and BTA determination for facilities with-
drawing 125 MGD AIF are subject to the
discretion of Permit Directors [herein called
Directors]. Facilities required to do the
entrainment studies will determine entrain-
ment BTA compliance first, after which and
as soon as practical, the impingement com-
pliance will be determined. This provision
is a major change Irom the proposed Rule oI
2011 and eliminates the possibility that an
installed technology for impingement BTA
would have to be abandoned or replaced be-
cause entrainment studies required a differ-
ent control technology.
Species Protected for entrainment
compliance, all life stages (egg, larvae,
and juvenile) of fish and shellfish, subject
to Directors discretion, are in-scope for
protection. It does not include members
of the infraclass Cirripedia in the subphy-
lum Crustacea (barnacles), green mussels
(Perna viridis), or zebra mussels (Dreissena
polymorpha). The Director may determine
that all life stages of fish and shellfish
do not include other specified nuisance
species. Shellfish includes shrimp, lob-
ster, horseshoe and blue crab, and the
Editors note: This is the first of a
two-part series on the U.S. Environ-
mental Protection Agencys 316(b)
rule, which will affect more than 500
power plants in the U.S.
S
ection 316(b) of the Federal
Water Pollution Control Act
(aka Clean Water Act; here-
after the Act) of 1972 states:
Any standard established
pursuant to section 301 or section 306 of this
Act and applicable to a point source shall re-
quire that the location, design, construction,
and capacity of cooling water intake structures
reflect the best technology available for mini-
mizing adverse environmental impact.
Section 316(b) of the Act contains five
lines of text, 43 words, and 252 characters
yet it has figuratively yielded separate insti-
tutional libraries for related legal documents
and research results since the Act was passed
in 1973! These libraries are still a valu-
able resource because while provisions of
the regulation offer flexible compliance op-
tions for industry, many permit applicants
will be challenged technically, financially,
and by schedule as they strive to complete
the required biological, engineering and eco-
nomic studies to indentify Best Technology
316(b): A New
Technical and
Implementation
Challenge for
Power Plants
Authors:
Douglas A. Dixon is a Technical Execu-
tive and Program Manager of EPRIs Fish
Protection Research.
David E. Bailey is a Senior Technical
Leader managing EPRIs closed cycle
cooling retrofit research and 316(b)
compliance support.
1410pe_REV_18 18 10/16/14 11:56 AM
19
www.power-eng.com
for brief periods during unusual
conditions)
t Option 4 have an existing (mini-
mum 800 feet offshore) velocity
cap with exclusion bars for marine
mammals and sea turtles
t Option 5 install modified travel-
ing water screens with a fish return
and optimize performance for non-
fragile species in a two-year biologi-
cal study
t Option 6 install an integrated sys-
tem of technologies, practices, and
operational measures that are op-
timized for non-fragile species in
a two-year study and demonstrate
biological performance is compara-
ble to that required in the following
Option 7, and
t Option 7 demonstrate that im-
pingement mortality is reduced to
no more than 24 percent annually
based on a minimum of monthly la-
tent mortality monitoring.
Entrapment (meaning the con-
dition where impingeable fish and
shellfish lack the means to escape
the cooling water intake - complete
definition at 125.92(j)) the EPA
dropped the 2011 proposed Rule require-
ment for special protection of entrapped
fish; however, a facility that entraps fish
must count the entrapped fish as im-
pingement mortality (i.e., during optimi-
zation studies for Compliance Options 5
and 6 and as part of monthly monitoring
of fish and shellfish survival to deter-
mine annual survival in Compliance Op-
tion 7.) Furthermore, when entrapment
of shellfish is a concern, Directors may es-
tablish additional requirements, such as
the seasonal deployment of barrier nets.
Waivers/Exemptions/Special Re-
quirements in addition to the impinge-
ment compliance options, compliance
requirements can be waived or modified
Side-by-side testing of different screens was funded by
EPRI and performed at Alden Research Laboratory in
Worcester, Mass. Photo Courtesy: EPRI
of the feasibility of a closed-cycle re-cir-
culating system (CCRS), fine mesh/nar-
row slot screens, and the use of grey, re-
claimed, and process water. Compliance
is determined by the permitting author-
ity on a case-by-case basis using best
professional judgment (BPJ) (see below
for mandatory and optional factors Di-
rectors must consider). The determina-
tion could range from the existing cool-
ing water intake structure (CWIS) being
deemed BTA to a requirement to retrofit
with a CCRS.
Impingement Mortality facilities
using > 2 MGD DIF have seven options
to achieve BTA for impingement mortal-
ity reduction:
t Option 1 operate a CCRS
t Option 2 demonstrate the maxi-
mum design through-screen veloci-
ty does not to exceed 0.5 feet per sec-
ond (fps) during minimum source
water levels and periods of maxi-
mum head loss across the screens
t Option 3 demonstrate through
daily monitoring that the actual
through-screen velocity is 0.5 fps
under all ambient conditions, in-
cluding during minimum source
water levels and periods of maxi-
mum head loss across the screens
(Permit Director may issue waivers
motil larval stages of mollusks (clams,
oysters, mussels, squid and octopus).
For impingement compliance, EPA has
developed a list of 14 fragile species that
can be excluded (e.g., gizzard shad, bay
anchovy, alewife, menhaden), subject to
Directors approval, from impingement
protection. These species were identified
based on their survival of less than 30
percent when collected on traveling water
screens. Additional species may be identi-
fied as fragile by demonstrating survival
rates of less than 30 percent on a site-
specific basis. Non-fragile species of fish
(survival > 30 percent) must be protected
as well as shellfish, marine mammals
and sea turtles. There are special provi-
sions for the protection of threatened and
endangered (T&E) species as discussed
below.
Entrainment Mortality Facilities
using >2 MGD DIF are also subject to re-
ducing entrainment mortality, however,
only facilities withdrawing >125 MGD
AIF must submit a Entrainment Char-
acterization Study, a Comprehensive
Technical Feasibility and Cost Evaluation
Study (to evaluate entrainment reduction
technologies), a Benefit Valuation Studay,
and a Non-water Quality and Other Envi-
ronmental Impacts Study. The technolo-
gy evaluation must include a assessment
1410pe_19 19 10/13/14 11:35 AM
www.power-eng.com
20
to insure their protection and address
the Services concern. As a result of the
changes, the Services modified their de-
termination to one of no jeopardy for
the EPA regulation action. As part of the
Source Water Baseline Biological Char-
acterization Study, applicants must now
provide information
on all T&E species po-
tentially affected by
impingement and en-
trainment, existing in-
cidental take permits
and any information
used to obtain the
permit(s). Directors
are also required to
submit all permit ap-
plication material to
the FWS (and NMFS
if anadromous species are involved) who
then have 60 days to provide recommen-
dations to insure T&E species protection.
Permit Directors may also require addi-
tional control measures, monitoring re-
quirements, and reporting requirements
that are designed to minimize incidental
take, reduce or remove more than minor
detrimental effects to Federally-listed
species and designated critical habitat, or
avoid jeopardizing Federally-listed spe-
cies or destroying or adversely modifying
designated critical habitat (e.g., spawning
and nursery areas or prey base).
INFORMATION
REQUIREMENTS
The rule contains extensive informa-
tion submittal requirements outlined
within 122.21(r)(2) through (12) (see
table for details).
EPA dropped the requirement for a
peer review of the Entrainment Char-
acterization Study Plan as the EPA
believed it would be reviewed when
review of the latter (122.21(r)(10-12)
documents is conducted. However,
by the Permit Director if the applicant
can demonstrate (1) impingement is de
minimis, (2) if the capacity utilization
rate is less than 8 percent averaged over
a 24-month contiguous period, and (3) if
the intake is located on a manmade lake
or reservoir and the fishery is managed
(but does not include any Federal T&E
species or their critical habitat). Relative
to the latter waiver for fishery managed
water bodies, only the r studies (i.e.,
permit application study requirements
see below) can be waived; however, ap-
plicants are still required to comply with
the Rule. This latter waiver also applies to
the required r studies for entrainment.
There is also a special exemption for
nuclear facilities. If compliance with the
Rule conflicts with a safety requirement
established by the Nuclear Regulatory
Commission, the Department of En-
ergy or the Naval Nuclear Propulsion
Program, the Permit Director must make
a site-specific BTA determination that
would not result in a conflict with safety
requirements.
New Units at Existing Facilities
these units would need to comply with
the compliance standards in the EPA
New Facility Rule which was issued in
2001. This requires them to employ use
of CCRS or a technology that is equiva-
lent to closed-cycle cooling (achieves an
entrainment reduction within 90 percent
of that achieved by a CCRS).
THREATENED &
ENDANGERED
(T&E) SPECIES
PROTECTION
The EPA delayed re-
lease of the final Rule
for nearly a year un-
til the U.S. Fish and
Wildlife Service (FWS)
and the National Ma-
rine Fisheries Service
(NMFS) completed
their consultation and
Biological Opinion
(FWS/NMFS 2014). The Services initially
concluded, after review of the proposed
regulation, the draft final regulation,
EPAs biological evaluation, and other
available information, that the proposed
action would likely adversely affect T&E
species and designated critical habitat.
EPA, therefore, modified the final Rule
to include special information require-
ments and requirements for the Director
A cooling water intake structure at Alabama Powers
Plant Barry. EPRI is testing and optimizing the Hydrolox
molded polymer screen at this plant.
Photo Courtesy: EPRI
The EPA rule
affects over 500
existing power
plants and an
additional 500-plus
industrial facilities
that have cooling
water intake
structures.
1410pe_20 20 10/13/14 11:35 AM
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1410pe_21 21 10/13/14 11:35 AM
www.power-eng.com
22
interim measures for impingement and
entrainment control until a final BTA is
installed. The ultimate decision on en-
trainment BTA will be based on the Di-
rectors BPJ. In accomplishing this, the
Director has a number of mandatory
factors (125.98(f)(2)) that must be
considered, including:
1. Number and species of organisms
entrained, including federally
listed T&E species and designated
critical habitat
2. Impact of changes in particulate
emissions or other pollutants as-
sociated with entrainment tech-
nologies
3. Land availability as it relates to
technology feasibility
4. Remaining useful life of facility,
and
5. Quantified and qualitative social
benefits and costs of available
technologies when such informa-
tion is sufficient to make a deci-
sion.
The following factors are optional
for consideration and also weight-
ed at the discretion of the Director
(125.98(f)(3)):
1. Entrainment impacts on the wa-
terbody
2. Thermal discharge impacts
3. Credit for reductions in flow asso-
ciated with retirement of units oc-
curring within 10 preceding years
4. Impacts on reliability of energy in
immediate area
5. Impacts on water consumption, and
6. Availability of process water, grey
water, waste water, reclaimed wa-
ter, or other waters of appropriate
quality and quantity for reuse as
cooling water.
applicants should consider conducting
a peer-review of their entrainment data
collection plan as a prudent risk-man-
agement practice. Negative review(s) of
the latter three studies, particularly if it is
found that they are all based on a problem-
atic entrainment characterization study,
could set applicants compliance planning
back multiple years at significant costs.
STATE PERMIT DIRECTOR
REQUIREMENTS
The EPA Rule also provides consider-
able flexibility or discretionary author-
ity to Permit Directors. Directors may
add EPA-designated fragile species to the
non-fragile list and they can similarly in-
clude species not explicitly designated by
EPA as fragile species. They can require
additional protection for shellfish and
Bilfinger Technologies contributed its fine-mesh rotary
multi-disk pilot screen to EPRI for testing at the Alden
Lab. Photo courtesy: EPRI
Ovivo Inc. contributed a fine-mesh traveling band screen to
EPRI for testing at Alden Lab. Photo courtesy: EPRI
1410pe_22 22 10/13/14 11:35 AM
For info. http://powereng.hotims.com RS#11
1410pe_23 23 10/13/14 11:35 AM
Duct Burner 2
H.P. Superheater 4
H.P. Evaporator 5
H.P. Steam Drum 15
L.P. Vent Silencer 16
H.P. Vent Silencer 14
L.P. Steam Drum w/ Integral Deaerator 17
Distribution Grid 1
Observation Port 3
Injection Grid 7
S.C.R. 8
C.O. Catalyst 6
H.P. Economizer 10
L.P. Superheater 11
H.P. Evaporator 9
L.P. Evaporator 13
DA. Pre-Heater 12
Stack 18
H.P. Steam Outlet
L.P. Superheater Outlet
BEST SUITED
FOR GAS
TURBINES UP
TO 120MW.
F OL L OW A L E A D E R
Gas-Turbine HRSG
S
Information Requirements
>2 MGD
Design Intake Flow
>125 MGD
Actual Intake Flow
Peer
Review
Source waterbody physical data >125 MGD
Cooling water intake structure data Peer Review
Source water baseline biological characterization data,
including required T&D species info
x x
Cooling water system data x x
Chosen method(s) of compliance with impingement mortality standard x x
Entrainment performance studies x x
Operational status information x x
Entrainment Mortality Characterization Study based
on two years of entrainment sampling
x x
Comprehensive Technical Feasibility and Cost Evaluation Study x x x
Benefit Valuation Study x x
Non-water Quality and Other Environmental Impacts
Study of fish protection technologies evaluated
x x
316(b) Information Submittal Requirements
1410pe_24 24 10/13/14 11:35 AM
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This changes everyone
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1410pe_35 35 10/13/14 11:35 AM
EVOLVING PRACTICES IN GAS TURBINE O&M
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ENERGY STORAGE
Ontario for the Independent Electric-
ity System Operator (IESO) and has a
pipeline of contracted projects for large
building owners in New York City, as
well as for utilities in the Northeast U.S.
EOS
Eos Energy Storage develops and
manufactures AC and DC integrated
battery systems based on zinc hybrid
cathode technology. The company
is working with eight global utility
partners as part of its genesis
program in which new technologies
will be tested and deployed in pilot
installations. Partnering with Con
Edison, AEP and Enel among others,
Eos has agreements with utilities
whose combined global infrastructure
includes 350 MW of power, across 1.8
million miles of transmission and
distribution lines, and servicing 81
million customers.
Phillipe Bouchard, vice president of
Business Development for Eos, said,
Our goal is not simply to compete
against other battery manufacturers,
but also to compete against other
incumbent solutions. This means,
for example, that batteries which are
used in peak load scenarios must not
only be competitive with other battery
technologies, but also with gas peak
turbines. Ultimately, our success is
measured by one key metric: can we
levelize the cost of energy? We want to
contextualize energy storage solutions
within the need to create true value on
the grid. Toward this end, we strive to
balance up-front capital with battery
longevity, safety, storage density and
efficiency.
Eos has been selective in its
partnerships to ensure that it can
needs at a forecasted peak-hour, -day,
and -year. However, when peak load
grows and demand outstrips supply,
these utilities must either upgrade the
grid itself or find another solution that
allows them to supplement existing
infrastructure and balance out these
pressures. Energy storage assets such
as battery banks and flywheels can
provide solutions to these problems,
thereby creating greater efficiencies
from existing infrastructure and
providing major cost savings when
accurately located and operated to solve
specific constraints. He also notes that
these solutions can be rapidly deployed
and create no on-site emissions or
noise impacts, thus providing low-
barrier options for utility planners and
building owners.
Convergent Energy + Power was re-
cently awarded 12 MWs of projects in
1410pe_36 36 10/13/14 11:35 AM
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COMPETITIVE, STRATEGIC, GLOBAL, GAS TURBINE SERVICE PROVIDER
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and automation technologies in
Chicago, and its PureWave SMS
technology outside Milwaukee in
Franklin, Wisconsin. Operating as
the brains that renders energy
storage deployable, PureWave SMS is
S&Cs power conditioning system that
converts stored energy into a voltage
and current that utilities can utilize.
Troy Miller, manager of Business De-
velopment and Product Management
for S&Cs Power Quality Products Di-
vision said, S&C is excited about the
future of the electrical grid and fore-
sees a coming transformation from
last centurys grid to a modern grid
in which utilities and their customers
will have to manage two-way power
flows and distributed generation be-
hind the meter. We are pioneering the
use of energy storage as an essential
part of that transformation.
demonstrate success across the full
spectrum of business and regulatory
models, including vertically-integrated
utilities, transmission and distribution
owners, independent power producers,
and customer-facing service providers.
By 2016, Eos plans to have tran-
sitioned from its AC Zenyth proto-
type to its full-production DC Au-
rora 1000/6000 battery. Enclosed in
a 40-foot ISO container, the battery
will provide a 1-MW, 6-MW-hr sys-
tem at a targeted price of $160/KW-hr.
The technology will utilize an aque-
ous zinc-based electrochemistry in a
sealed static-cell sub module design
and is projected to have a service life of
10,000 charge cycles.
S&C ELECTRIC COMPANY
S&C Electric Company holds grid-
scale battery technologies totaling 47
MW of commissioned power. Head-
quartered in Chicago, Illinois, the
century-old company has manufactur-
ing facilities across North America and
around the world.
S&C does not manufacture batter-
ies, but works with a variety of sup-
ply partners who provide five major
battery technologies to meet client
needs. These include: lithium ion, so-
dium sulfur, sodium nickel chloride,
advanced lead acid, and ultra-battery,
essentially an ultracapacitor combined
with lead acid technology.
The company has completed mul-
tiple energy storage projects includ-
ing a 6 MW facility for UK Power Net-
works designed to relieve transmission
congestion, and a 1 MW facility for BC
Hydro designed to improve grid reli-
ability.
S&C manufactures its switching
1410pe_37 37 10/13/14 11:35 AM
www.power-eng.com
38
Typical Generator Reactive Capability Curve 1
Side Ripple Spring
M
V
A
R
500
400
300
200
100
0
-100
-200
-300
-400
MW
A
B
C
D
0 100 200 300 400 500 600
MWe Uprate requires an increase in MVAR
to maintain the same power factor
Reactive Capability
Curve
Curve AB
Field Capability
Curve BC
Armature
Capability
Curve CD
Core End Capability
Core end stepping
Flange
Flux shield
Flux shunt
Outside space block
Core
Uprate
Stator
Uprate
Field
Uprate
Copper
Strands
Vertical
Separator
McCapal
Insulation
Bar Armor
Conforming Material
Side Ripple Spring
Filler
Top Ripple
Spring
Wedge Slide
Wedge Body
Core
Conforming
Material
Filler/RTD Filler
be transmitted to - and consumed at
- the load centers, while maintaining
stable power system voltages. Trans-
mission system operators and regula-
tors are increasingly emphasizing that
the generator must supply more VARs
and maintain rated power factor to ac-
company any increase in real power
output. Also, synchronous genera-
tors supply dynamic VARs, which are
important for voltage stability during
system transients such as transmission
line faults. An uprated generator can
address needs for both additional MW
and VARs. Additionally, a generator
uprate can be used to simply address a
need for increased VARs, where there
is a system VAR capacity concern in a
local grid. In this case, additional VAR
capacity can be achieved by upgrading
and uprating the generator without im-
pacting the turbine, boiler, or reactor.
A SYSTEM VIEW
The generator is actually a set of sub-
systems that should be considered in-
dividually to allow a new nameplate
with a higher rating to be placed on
the generator. The reactive capability
curve (RCC) is included in every gen-
erator instruction book and represents
a good means of picturing how the
various sub-systems interact to define
the generator capability (see Figure
1). Common sub-systems are listed
G
lobal demand for elec-
tricity supply contin-
ues to grow. Power
generation providers
constantly evaluate
capacity additions and the tradeoffs
between alternatives. Since Ameri-
can utilities are building a very small
number of new coal-fired and nuclear
plants, power generation providers
are turning to alternatives that can in-
crease both the reliability of existing
power generation equipment and pow-
er output. Upgrades exist for boilers,
reactors and turbines that increase the
shaft horsepower of the power train.
And, options to increase combustion
turbine output are being pursued ac-
tively. Other major equipment within
the power plant, including the genera-
tor, must also be considered as part of
any power plant uprate project.
A synchronous AC generator should
provide two key functions as part of
a power plant uprate. Of course, it
can serve as the conduit of the power
from the plant to the grid. Second,
the generator should supply reactive
power, otherwise known as VARs (volt
ampere reactive), to the power sys-
tem to allow the real power (MW) to
Power Plant
Uprates:
Dont Forget
the Generator
BY JEFF MUHA AND KIRK OBRIEN, GE POWER & WATER
Authors:
Jeff Muha, Generator Technical Leader,
GE Power & Water Power Generation
Products; Kirk OBrien, Generator Princi-
pal Engineer, GE Power & Water Power
Generation Services
UPRATES
1410pe_38 38 10/13/14 11:35 AM
2014 Diamond Power International, Inc. All rights reserved.
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For info. http://powereng.hotims.com RS# 452
For info. http://powereng.hotims.com RS# 454
Get a thorough mix with:
Pugmill Systems, Inc.
P.O. Box 60
Columbia, TN 38402 USA
Ph: 931-388-0626 Fax: 931-380-0319
www.pugmillsystems.com
For info. http://powereng.hotims.com RS# 451
The Institute of Electrical Engineering at EPFL invites applications
for a tenure track assistant professor in Electrical Engineering.
Recruitment to a tenured senior position may be considered in excep-
tional cases.
Applicants should demonstrate strong competences in the broad area
of electrical engineering. Areas of interest include, but are not limited
to, embedded computing and communication systems, radio-frequency
circuits and antennas, nano-circuits and devices, electrical sensors and
interfaces, displays, energy-efficient design and energy distribution
systems. The Institute welcomes applications from candidates in new
emerging areas that do not fit the above groups but that relate to Electri-
cal Engineering at large.
As a faculty member of the School of Engineering, the successful can-
didate is expected to initiate independent, creative research programs
and actively participate in undergraduate and graduate teaching.
Significant start-up resources and state-of-the-art research infra-
structure will be available. Salaries and benefits are internationally
competitive.
EPFL, with its main campus located in Lausanne, Switzerland, is a
dynamically growing and well-funded institution fostering excellence
and diversity. A technical university covering essentially the entire
palette of engineering and science, EPFL has a highly international
environment that is multi-lingual and multi-cultural, with English
often serving as a common interface.
Applications should include a cover letter with a statement of motiva-
tion, curriculum vitae, list of publications and patents, concise state-
ment of research and teaching interests, and the names and addresses
of at least five referees. Applications must be uploaded in PDF format
to: http://go.epfl.ch/iel-search
Formal evaluation of candidates will begin on December 1
st
, 2014.
Enquiries may be addressed to:
Prof. Pierre Vandergheynst
Search Committee Chair
E-mail: iel-search@epfl.ch
For additional information on EPFL, please consult the web sites:
www.epfl.ch, sti.epfl.ch and iel.epfl.ch.
EPFL is committed to increasing the diversity of its faculty, and
strongly encourages women to apply.
Faculty Position in Electrical Engineering
at the Ecole polytechnique fdrale de Lausanne (EPFL)
For info. http://powereng.hotims.com RS# 453
POWER PROFESSIONALS
Opportunities in Operations and Maintenance,
Project Engineering and Project Management.
Business and Project Development.
First-line Supervision to Executive Level Positions.
Employer pays fee. Send resumes to:
P.O. BOX 87875,
VANCOUVER, WA 98687-7875
email: dwood@staffing.net
(360) 260-0979 (360) 253-5292
www.powerindustrycareers.com
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WE ARE
BUYING!!!
ARE YOU SELLING?
VALVES
INSTRUMENTATION
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VISIT
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T. 978-815.6185 Fax. 603-814.1031
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LIMITORQUE OPERATORS WANTED
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847-541-5600 FAX: 847-541-1279
visit www.wabashpower.com
FOR SALE/RENT
POWER
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wabash
For info. http://powereng.hotims.com RS# 458
1319 Macklind Ave., St. Louis, MO 63110
Ph: (314) 781-6100 / Fax: (314) 781-9209
www.ampulverizer.com / E-Mail: sales@ampulverizer.com
Quality and Service Since 1908
Ring Granulators, Reversible Hammermills,
Double Roll Crushers, Frozen Coal Crackers
for crushing coal, limstone and slag.
For info. http://powereng.hotims.com RS# 457
For info. http://powereng.hotims.com RS# 459
ESI Boi l er Rent al s, LLC
RENTAL EQUIPMENT
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For info. http://powereng.hotims.com RS# 461
For info. http://powereng.hotims.com RS# 462
GEORGE H. BODMAN, INC.
Chemical cleaning advisory services for
boilers and balance of plant systems
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P.O. Box 5758 Office (281) 359-4006
Kingwood, TX 77325-5758 1-800-286-6069
email: blrclgdr@aol.com Fax (281) 359-4225
For info. http://powereng.hotims.com RS# 456
Burner Management
System Logic Review
Exothermic Engineering, LLC
Complete BMS Services
We are also experts at solving ancillary
problems with flame scanners, igniters
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Begin with a conference call
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Call Bill Smith:
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Our staff actively maintain seats on key
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H8 |nterna| Log|c Rev|ews and 0es|gn
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For info. http://powereng.hotims.com RS# 460
CONDENSER & HEAT EXCHANGER TOOLS
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e-mail: sales@johnrrobinsoninc.com
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1410pe_66 66 10/13/14 11:34 AM
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PRAIRIE STATE GENERATING COMPANY IS HIRING!
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provides low-cost electricity to 2.5 million families across 8 states.
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insulating Prairie State from the ups and downs of the coal marketplace
for the next several decades. Positions we are hiring for include:
EN0lNEER3 - E|eclr|ca|, C|er|ca|, Vec|ar|ca|, Re||ao|||ly, l&C
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enef|ts:
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Va|uab|e |ndustry exper|ence
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P30C |s equa| opporlur|ly erp|oyer.
Females and minorities are encouraged to apply.
For info. http://powereng.hotims.com RS# 467
For hundreds of years navigation was
based on two numbers; latitude and
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For info. http://powereng.hotims.com RS# 464
Training Professionals
Wanted
GP Strategies, a global leader in performance
improvement, is seeking qualified subject
matter experts to fill director level positions
to lead power plant operations and
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global energy customers.
Ideal candidate will have:
4-year engineering degree / B.S.
in related field of study
5+ years experience in coal-fired
power plants
Professional engineering
license preferred
If youre looking for a career with a dynamic,
fast-growing company with an excellent
reputation in the power generation industry,
contact Scott Peterson at GP Strategies
today: speterson@gpstrategies.com, or
+1.443.367.9626.
1410pe_67 67 10/13/14 11:34 AM
www.power-eng.com
68
INDEX
RS# COMPANY PG# SALES OFFICE RS# COMPANY PG#
1421 S. Sheridan Rd., Tulsa, OK 74112
Phone: 918-835-3161, Fax: 918-831-9834
e-mail: pe@pennwell.com
Sr. Vice President North
American Power Group
Richard Baker
Reprints
Foster Printing Servive
4295 Ohio Street
Michigan City, IN 46360
Phone: 866-879-9144
e-mail: pennwellreprint@fosterprinting.com
National Marketing
Consultant
Rick Huntzicker
Palladian Professional Park
3225 Shallowford Rd., Suite 800
Marietta, GA 30062
Phone: 770-578-2688, Fax: 770-578-2690
e-mail: rickh@pennwell.com
AL, AR, DC, FL, GA, KS, KY, LA, MD, MO,
MS, NC, SC, TN, TX, VA, WV
Regional Marketing Consultant
Dan Idoine
806 Park Village Drive
Louisville, OH 44641
Phone: 330-875-6581, Fax: 330-875-4462
e-mail: dani@pennwell.com
CT, DE, IL, IN, MA, ME, MI, NH, NJ, NY,
OH, PA, RI, VT, Quebec, New Brunswick,
Nova Scotia, Newfoundland, Ontario
Regional Marketing Consultant
Natasha Cole
1455 West Loop South, Suite 400
Houston, Texas 77027
Phone: 713.499.6311; Fax: 713.963.6284
e-mail: natashac@pennwell.com
AK, AZ,CA,CO,HI,IA,MN,MT,ND,NE,NM,NV,
OK,OR,SD,UT,WA,WI,WY,AB,BC,SK, Manitoba,
Northwest Territory, Yukon Territory
International Sales Mgr
Michelle Smith
The Water Tower
Gunpowder Mills
Powdermill Lane
Waltham Abbey, Essex EN9 1BN
United Kingdom
Phone: +44 1992 656 609, Fax: +44 1992 656 700
e-mail: michelles@pennwell.com
Africa, Asia, Central America, Europe,
Middle East, South America
European Sales
Asif Yusuf
The Water Tower
Gunpowder Mills
Powdermill Lane
Waltham Abbey, Essex EN9 1BN
United Kingdom
Phone: +44 1992 656 631, Fax: +44 1992 656 700
e-mail: asify@pennwell.com
Europe and Middle East
Classifieds/Literature Showcase
Account Executive
Jenna Hall
1421 S. Sheridan Rd.
Tulsa, OK 74112
Phone: 918-832-9249, Fax: 918-831-9834
email: jennah@pennwell.com
18 Allen-Sherman-Hoff 39
www.a-s-h.com
Brandenburg Industrial C4
Service Company
www.brandenburg.com
20 Busch LLC 42
www.buschusa.com
23 Chemetrics, Inc. 45
www.chemetrics.com
19 Circor Energy Products 41
www.circorenergy.com
22 Clearspan Fabric 45
Structures
www.clearspan.com
8 Corrpro 15
www.corrpro.com
25 Detroit Stoker Co 48
www.detriotstoker.com
11 Evoqua Water 23
Technology LLC
www.evoqua.com
3 Globalspec 5
www.engineering360.com
9 Hilliard Corporation 17
www.hillardcorp.com
10 Hydrolox 21
www.hydrolox.com
HYTORC Industrial 43
Bolting Systems
15 Invensys Systems 35
www.foxboro.com/foxboroevo
27 Magnetrol International 52
www.power-eng.com/webcasts
1 Martech Training Services C2
www.martechtrainingservices.com
4 MITSUBISHI HITACHI POWER 7
SYSTEMS AMERICA ENERGY
AND ENVIRONMENT, LTD
www.mhpowersystems.com
13 MITSUBISHI POWER 29
SYSTEMS AMERICAS, INC.
www.mhpowersystems.com
16 Mobil Industrial Lubricants 36
www.power-eng.com/webcasts
21 Mobil Industrial Lubricants 44
www.power-eng.com
5 Nuscale Power Inc 9
www.nuscalepower.com
7 Philadelphia Gear 13
Corporation
www.philagear.com/boring/pe
29 Power Generation Week 57
www.powergenerationweek.com
17 Power Systems Mfg LLC 37
www.psm.com
31 POWER-GEN International C3
www.power-gen.com
30 Projects of the Year 59
Awards Gala
www.power-gen.com
24 PW Power Systems 47
26 Structural Integrity 49
Associates
www.structint.com/power-eng
6 United Rentals Inc 11
www.unitedrentals.com/urcontrol
12 Victory Energy 24-25
Operations LLC
www.victoryenergy.com
14 Volvo Penta of 31
the Americas
www.volvopenta.com/industrial
28 Waste Management 53
www.power-eng.com/webcasts
2 Westinghouse Electric Co 3
www.westinghousenuclear.com
Advertisers and advertising agencies
assume liability for all contents (includ-
ing text representation and illustrations)
of advertisements printed, and also as-
sume responsibility for any claims aris-
ing therefrom made against the pub-
lisher. It is the advertisers or agencys
responsibility to obtain appropriate
releases on any items or individuals pic-
tured in the advertisement.
1410pe_68 68 10/13/14 11:36 AM