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U.S. In particular, the Mirant Marsh L,anding Generating station in Contra Costa County, CA will be fitted with a hot SCR and is currently expected to complete construction in 2013.18 The deterinination of whether a particular CT project will require an SCR in order to receive an air peiinit will be determined based on the outcome of the new source review (“NSR’), as detei-rnined on a case-by-case basis for each plant. The NSR is overseen by a state regulatory agency in most cases and is guided by the current status in meeting the National Ambient Air Quality Standards (“NAAQS”). In locations that are in attainment of the NAAQS, the NSR is conducted under the Prevention of Significant Deterioration (“PSD”) rules that require units to install the Best Available Control Technology (“BACT”) in order to obtain approval. In locations that are designated as non-attainment of the NAAQS, the Non-Attainment NSR (“NNSR’) iule require units to apply the more stringent Lowest Achievable Emissions Rate (“LAER”) standard.” In locations that have previously been in non-attainment and are currently in “maintenance” of the NAAQS, the NSR will generally continue to impose a stringent control technology standard in order to maintain air quality pollutant levels. The attainment status for ozone, for which NOx is a precursor, is the most relevant for deteiinining whether an SCR will be required. Table 12 shows the current 8-hour ozone attainmentstatusbasedoncurrentNAAQS. TheEPAiscurrentlyintheprocessoftighteningits NAAQS for ozone with new standards to be ruled soon after the publication of this study that will likely bring more areas into nonattainment.20 Additional regulatory uncertainty regarding the need for an SCR is also introduced by the Cross-State Air Pollution Rule (“CSAPR”) finalized on July 6, 2011 that will require PJM states to revise their SIPS in order to help meet ozone NAAQS not only in their own states but also in specific downwind locations in other states.21 CONEArea 1 Eastern MAAC 2 Southwest MAAC 3 Rest ofRTO 4 Westein MAAC 5 Doiniiiion Soirrces a i d Notes EPA (201 I a). County Middlesex, N.J Charles County, MD Will, 1L Northainpton,PA Maintenance Faiiquier, VA Attaininent Table 12 8-Hour Ozone Attainment Status After considering the regulatory and technological factors described above, we believe the most likely outcome of a 7FA simple-cycle NSR for an online date of June 1, 2015 is that the project will be required to be fitted with an SCR if it is currently in a non-attainment or maintenance area for ozone, but that it will not need an SCR if it is in an attainment area. Table 13 contains a 18 l o The plant permit to construct contains details about the plant configuration and SCR, see BAAQMD (2010). Online date from Ventyx (2011). See EPA (2011b). See EPA (201 IC). See EPA (2011~1). 14 Ozone Attainment Status Non attainineiit Nonattainineiit NonattainmentPDF Image | THE APPLICATION OF KENTUCKY POWER
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