5.2. ERMUSR 08-09-2011 - Laserfiche WebLink

Home Browse Search

OPTIONS FOR ERMU Option I - No Change Under the NESHAP-RICE Regulations, as currently proposed, Elk River Municipal Utilities (ERMU) could continue its present operation until May 3, 2013. After that date, ERMU's diesels will be subject to the new regulations, which allow up to 100 hours/year far maintenance and readiness testing, but not for financial benefit, such as peak shaving, if part of an Emergency Demand Response (EDR) program. The current version of the regulations allow the non-complying unit to be designated as an Emergency Unit, to allow operating 15 hours per year, during defined emergency times, but the 15 hours must count towards the above mentioned 100 hours. The IAMU, MMUA, and CMMPA have filed comments tothe-Environmental Protection Agency (EPA) requesting that the Emergency Units be allowed to operate, beyond readiness testing, up to 100 hours per year, while allowing financial credits from the designated unit, for diesels subject to an EDR program. It is unknown what the EPA's response will be or how soon a decision will be made on this request. One industry observer speculated that the EPA might finalize on 60 hours within the next year, although at least one State (Delaware) is asking that this be reduced to 0 hours. If all of ERMU's diesels become Emergency Units, they could be run if there was an outage on the interconnection. However, under the proposed regulations, ERMU could not continue to receive capacity credits without emissions controls. If EPA revises the present regulations to requested levels of 100 hours, or even 60 hours, then ERMU could continue its present operation, without emissions controls, even it were in an EDR program. In order to become Emergency Units, the ERMU diesels would need to adopt certain maintenance features, discussed later in this Study. 11