ILLINOIS POLLUTION CONTROL BOARD
In The Matter of:
)
Proposed New Clean Air Interstate Rule
)
)
NO. R06-26
(CAIR) S02, NOx Annual and NOx Ozone
)
(Rulemaking
-
Air)
Season Trading Programs, 35 Ill. Adm. Code
)
225. Subparts A, C, D and E
NOTICE OF FILING
TO:
See attached Service List
PLEASE TAKE NOTICE that on December 15,2006, I caused to be filed electronically
with the Office of the Clerk of the Pollution Control Board, on behalf of KINCAID
GENERATION, L.L.C., the attached DOMINION
NOx COMPLIANCE STRATEGY and
RESUME OF ANDY YAROS, as discussed during the testimony of Robert Asplund before the
Board on November 29,2006, copies of which are hereby served upon you.
BY: ISI
Xptlierine
M.
Raliia
Katherine M. Rahill
Bill S. Forcade
Katherine M. Rahill
JENNER
&
BLOCK LLP
Attorneys for Kincaid Generation, LLC
One IBM Plaza
Chicago, IL 6061 1
(3 12) 222-9350
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2006
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CERTIFICATE OF SERVICE
I, Katherine
M. Rahill, an attorney, hereby certify that I served copies of the foregoing
documents via first class mail upon the parties on the attached Service List this 15th day of
December,
2006.
BY:
ISI
Xptherine
M.
RghilT
Katherine M. Rahill
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2006
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SERVICE LIST:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph St., Suite 11-500
Chicago, IL 60601-32 18
John
Knittle
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 1 1-500
Chicago, Illinois 6060 1
John J. Kim
Rachel L. Doctors
Division of Legal Counsel
Illinois Environmental Protection Agency
102 1 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
William A. Murray
Special Assistant Corporation Counsel
Office of Public Utilities
800 East Monroe
Springfield, Illinois 62757
Kathleen C. Bassi
Sheldon A. Zabel
Stephen J. Bonebrake
Schiff
Hardin LLPP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
Matthew
Dunn, Chief
Division of Environmental Enforcement
Office of the Attorney General
188 West Randolph St.,
20th Floor
Chicago, IL 60601
Sasha
Reyes
Steven Murawski
Baker
&
McKenzie
One Prudential Plaza, Suite 3500
Chicago, IL 60601
David Rieser
James T.
Harrington
Jeremy R. Hojnicki
McGuire Woods LLP
77 West Wacker, Suite 4100
Chicago, Illinois 6060 1
Faith
E. Bugel
Environmental Law and Policy Center
35 East Wacker Drive, Suite 1300
Chicago, Illinois 6060 1
Keith I. Harley
Chicago Legal Clinic
205 West Monroe Street,
4th Floor
Chicago, Illinois 60606
S. David Farris
Manager, Environmental, Health and Safety
Office of Public Utilities, City of Springfield
201 East Lake Shore Drive
Springfield, Illinois 62757
Bruce Nilles
Sierra Club
122 W. Washington Ave., Suite 830
Madison, WI 53703
Daniel
McDevitt
Midwest Generation
440 S.
LaSalle Street
Suite 3500
Chicago, IL 60605
Virginia Yang, Deputy Legal Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, IL 62702- 127 1
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2006
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Dominion NO, Compliance Strategy
-
Andy Yaros
Dominion has predicated its
NOx compliance strategy on making the most economical
decisions on a Dominion System basis, under the
NOx SIP Call Cap
&
Trade regulations.
The strategy to date has focused on compliance in aggregate through reductions from
installed
NOx equipment, and trading among Dominion unit allocations, rather than
buying any additional
NOx allowances from the market.
The most economic means to effect this strategy relies primarily on installing high capital
cost SCRs on our largest units with the highest
NOx rates. Pre-SIP Call NOx rates were
generally a function of a combination of boiler-type, previous equipment such as
low-
NOx burners and over-fired air, and coal type. While SCR represents a huge capital
investment (approximately
$200/kw for most of our largest units) and large annual
operating costs (-$4,000,000 for a 550 MW unit), it is generally more cost-effective in
terms of cost per
NOx ton removed. It is also capable of removing 90% of NOx.
In executing Dominion's strategy, we have put SCRs on 12 of our largest coal units.
With SCRs removing 90% or more on our large units, Dominion is able to put less costly
controls on smaller units which do not remove nearly as high a percentage of
NOx.
These units are typically not large enough or may not run at a high enough capacity factor
to provide the economies of scale which would economically warrant addition of an
expensive SCR. However, with SCRs on the large Dominion units, and other lower cost
equipment (SNCR or advanced over-fired air) on most of the smaller, older units,
Dominion is able to comply company-wide, with the SIP Call, and CAIR in the future.
We will over-comply on the SCR units and use those units' excess allowances to
supplement other units which have
NOx emissions in excess of their SIP allocations. If
we lose substantial allowances from our large units with SCRs, the economics of the
strategy do not work. Dominion would then be forced to invest in more controls which
tend to have a much higher cost per
NOx ton removed, or to rely on buying allowances in
the marketplace.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2006
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Andrew F. Yaros
5220 Huntmaster Dr.
-
Midlothian VA 23 1 12
Tel(804) 273-2600
-
Cell (804) 314-5725
Andy-Yaros@dom.com
Versatile and innovative manager with expertise in P&L/general management, operations, supply management and engineering.
Pivotal in startup of profit centers in new and varied areas now delivering $100+ million annual earnings.
Results-oriented leader
and decision-maker with track record of delivering growth by building high performance teams.
Pioneered buyout strategy of above market contract energy suppliers, still adding
$20M incremental new earnings each year.
Managed new power plant to unprecedented levels of operational success and improved profitability for Company.
Fostered leadership development, ten direct reports achieved top station leadership levels in past six years.
$50M of excess environmental credits created and selling for earnings in 2005.
Strategist
with solid combination of business and technical acumen.
Develop strategic plan for $1 billion capital program to meet new draft environmental requirements.
Arbitraged
gaslelectricity prices for gas sales and to reduce avoided cost payments to non-utility generators.
Drove nuclear fuel costs to lowest in country by shifting to foreign sources, non-OEM sources, and redesigned fuel products.
Innovative change catalyst
with ability to create common vision.
$100M net revenue added last five years by allowance sales and replaced with future vintages with postponed expense hit.
Maximized gas supply value by selling instead of using at gas deregulation onset. Gas trading now major company profit
center.
Initiated coal sales to industrials to capture margin and utilize available state tax credits. Now
$1 OM annual earnings.
MBA,
University of Richmond
MS,
Nuclear Engineering, University of Cincinnati
BS,
Mathematics & Physics, Centre College of Kentucky
Professional Experience
Dominion Resources (Virginia Power), Richmond, VA
Manager
-
Environmental Systems
(Fossil & Hydro), '02-present
Spearheaded startup and operation of new environmental equipment early to capture pollution credits worth
$20M.
Key team member in EPAIDominion settlement agreement to facilitate breakthrough of two-year stalemate in negotiations.
Troubleshooting pollution equipment at newly acquired plant. Extended outage interval from 30-45days to
150day peak
season.
Added tens of millions
$ EBlT annually with pollution allowance sales and arbitraging credit vintage years.
Station Manager
- Clover Power Station, Clover VA, '98-'02
Focused on transitioning new leadership. All ten inherited leadership team members eventually promoted to top station
leadership at other business unit stations.
Achieved operations excellence at large, new station. lncreased capacity factor each year. Several
250+ consecutive day
runs.
Captured Virginia Manufacturing Association top environmental stewardship award for large industrial facility category for
2000.
Director
-
Fossil Fuels Operations,
'92-'97
Led re-engineering team that streamlined fuel department and implemented new data management system.
Originated selling natural gas supplies to industrials and arbitraging gaslelectric market differentials. Ultimately provided the
genesis of gas trading group that is now large gas trading profit center.
Launched program to provide fuel services for large electric customers to increase revenues and customer satisfaction.
Instrumental in NUG re-engineering project (Vision 2000) which changed corporate position on successful buyout strategy.
Director
-
Nuclear Fuel Procurement,
'85-'91
Focused on developing competitive non-OEM sources for materials
& services, including fuel leak testing and in-core
poisons.
Industry forerunner maximizing volume of uranium and fuel services from foreign entities and spot markets to reduce costs.
lncreased fuel economic value by aggressively pursuing upgraded fuel products.
Established low-level radioactive waste management group of multiple industries to proactively address disposal at state
level.
Supervisor
-
Fuel Economics,
'82-85
Aggressively marketed new supply requirements to increase competitiveness of coal vendor base to reduce costs.
Optimized buying for fuel supply for converted coal units to system level to reduce costs and improve market leverage.
Previously employed by U.S. Treasury Dept and Girard Manufacturing Co (PA).
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 15, 2006
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