MEMORANDUM

To: Carbon Power Plan for Existing Power Plants; Docket id: OAR-2013-0602

From: Region 5, EPA

Subject: 10/7/14, Conference Call Regarding Proposed Carbon Plan for Existing Power Plants

Summary: A conference call was held between EPA and attendees from Wisconsin on October 7, 2014 to discuss the proposed Carbon Power Plan for Existing Power Plants.  The following list of questions was submitted for discussion by the Wisconsin Department of Natural Resources. 

Attendees may have included: Breuer, Delanie - PSC; Detmer, Kenneth - PSC; Vedvik, Alexander - PSC; Neumeyer, Donald G - PSC; Bizot, David A - DNR; Dickens, Angela F - DNR; Adamantiades, Mikhail; Cain, Alexis; newman, erin

Questions emailed prior to the call are below: 

1) Are CO2 emissions from new NGCC counted against the emission limitation for existing EGUs?  We would like confirmation that the proposed rule does not create this intent or requirement in meeting either an emission rate or mass cap limit.

   This conclusion is based on discussion in the proposed rule preamble starting on pages 34876 and 34923 of the federal register.   EPA appears to be stating in these discussions that new NGCC can be used towards compliance, but emissions are not regulated or required to be included in any way under the proposed existing EGU limit.
   

2) How can new NGCC units be used towards compliance of the existing EGU requirement?  Has EPA considered what would be approvable in a state plan?  It seems there are several options that result in various levels of stringency:

   a) Allow new NGCCs to be built without emissions being included under the existing EGU requirement.  This seems to be what the rule preamble is describing as a direct outcome of the proposed rule structure. [We would like to confirm this]
   b) Allow new NGCC emissions and MWh to be included in calculating the emission rate for the existing EGU system. 
   c) Allow new NGCC emissions to be excluded from a mass cap.
   d) Allow emission reductions in excess of the new NGCC NSPS limit to count towards compliance with the existing EGU emission rate or mass cap limits.


3) Potential question on calculating mass caps.  Is 2012 renewable and nuclear MWh included in the calculation?  The proposed rule language appears to direct states to model the EGU system and apply the emission limitation to the grown MWh generated by the fossil fuel fleet (affected units).  However, Wisconsin believes that the 2012 MWh of renewable and nuclear energy that was used in determining the emission limit must also be included in the calculation.  Otherwise the result is to make the requirement more stringent under a mass cap.  

