PUBLIC

HEARING ON DMES PROPOSED

GAS PLANTS
Advices and Suggestions
December 23, 2015

Mahdi Ahmadi
Denton Resident
PhD in Philosophy (University of North Texas)
Master student in Mechanical and Energy Engineering (University of North Texas)

DFW ozone non-attainment history

Due to geographical and
meteorological factors,
Denton has been always
the worst city in the DFW
area in terms of ozone
pollution.
Emerging sources of VOC
and NOX (shale gas,
population, traffic) making
it more difficult to achieve
ozone attainment.
http://www.epa.gov/oaqps001/greenbk/anayo_tx.html

Denton Conundrum
2 years of studying DFW ozone problem at UNT
Statistical analysis
Photochemical simulation

Denton Conundrum
2 years of studying DFW ozone problem at UNT
Statistical analysis
Photochemical simulation
Three large sources of NOX/VOC

Results Scenario B.2

100% NOx reduction from the coal-fired EGUs

Results Scenario B.2

100% NOx reduction from the coal-fired EGUs

Results Scenario B
100% NOx reduction from the coal-fired EGUs

Change in Relative Response Factor (using the 10 highest days) and projected design value

CAMS
Ft. Worth Northwest-C13
Keller-C17
Frisco - C31
Midlothian OFW - C52
Denton Airport South - C56
Arlington - C61
Dallas North - C63
Rockwall - C69
Grapevine - C70
Kaufman - C71
Granbury - C73
Eagle Mt. Lake - C75
Parker County - C76
Cleburne Airport - C77
Midlothian Tower - C94
Dallas Hinton St. - C401
Dallas Exec. Airport - C402
Greenville - C1006
Pilot Point - C1032

2006 DV B (ppb)
89.33
91.00
87.67
77.00
93.33
83.33
85.00
77.67
90.67
74.67
83.00
93.33
87.67
85.00
80.50
81.67
85.00
75.00
81.00

UNT Projection

Scenario B

FY18 RRF FY18 DV F Scenario RRF Scenario DV F

0.8209
0.8169
0.8266
0.8255
0.8127
0.8260
0.8365
0.8436
0.8196
0.8522
0.8146
0.8061
0.8250
0.8187
0.8246
0.8294
0.8322
0.8335
0.8140

73.3
74.3
72.5
63.6
75.8
68.8
71.1
65.5
74.3
63.6
67.6
75.2
72.3
69.6
66.4
67.7
70.7
62.5
65.9

0.8120
0.8072
0.8177
0.8114
0.8029
0.8163
0.8278
0.8327
0.8111
0.8298
0.8021
0.8002
0.8180
0.7996
0.8089
0.8190
0.8223
0.8199
0.8069

72.5
73.5
71.7
62.5
74.9
68.0
70.4
64.7
73.5
62.0
66.6
74.7
71.7
68.0
65.1
66.9
69.9
61.5
65.4

Advices and Suggestions

DO NOT install a new major source of NOX or VOC (such as a gas EGU)
in the city limits of Denton
Ozone problem
Also, it probably is not the best long-term investment due to the OM costs

Although natural gas EGUs are typically cleaner than coal-fired plant,
but in this case it is not just the matter of volume of emission, it is
also a matter of where the new source of emission is located (whose
air is getting better due to the proposed natural gas EGU?)
Do EPA BenMap analysis to see how the benefits are distributed

Advices and Suggestions

If the city decided to install new EGU, there should be an immediately
effective plan to SHUT DOWN the Gibbon Creek plant
Divesting the city share in the plant will not reduce its pollution

The location of the proposed EGU should be chosen carefully with full
consideration of the downwind effects
New air quality monitoring stations/plans are necessary to quantify
the real impacts of the proposed EGU after installation

Advices and Suggestions

In all steps of decision making about the proposed EGU:
Use as much as scientific expertise you can (UNT and TWU are valuable
sources at your disposal)
BUT also involve non-expert citizens in ALL steps alongside the experts,
particularly before a decision is conceived.