Determining Letter Grades
The methodology to distribute letter grades to individual EGUs builds from Maryland's 2017 ozone season analysis of control optimization at coal-fired EGUs with Selective Catalytic Reduction (SCR) and Selective Non-Catalytic Reduction (SNCR) controls across the eastern United States. MDE developed a grading system based on individual EGU performance rates.
Binning Methodology
MDE assessed SCR/SNCR control optimization for a specific year by comparing ozone season data for that year to a series of NO
x emission rates reflecting various levels of optimization for each unit. These optimized rates are derived from the unit's 2005-2016 ozone season data (adjusted if controls were installed after 2005), available in the
EPA's Air Market Programs Database. For initial screening, the lowest ozone season average NO
x emission rate was selected for each unit. If the unit installed an SCR or SNCR in 2005 or a later year, the data collection period was narrowed to the first ozone season in the year following the installation to 2016.
A deviation percentage was then calculated for each unit by dividing the current ozone season average emission rate by the identified best ozone season average emission rate. Units were then subdivided into three categories, or bins, based on the calculated percent deviation. Each of these bins represents a different level of optimization based on the unit's own previously demonstrated performance.
Table 1. Description of Three Bins for EGU Optimization Performance
1 |
<0% |
2017 NOx rate is less than past best rate. Equal or better performance compared to past |
2 |
0-100% |
2107 NOx rate is greater than past best rate but less than double. Slightly poorer performance compared to past |
3 |
>100% |
2017 NOx rate is more than double past best rate. Noticeably poorer performance compared to past |
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Grading Scale
While MDE's binning methodology allows comparison of a unit's control performance in a particular year to its own previously demonstrated capabilities, it does not allow comparison of units to each other. In order to assign a letter grade to each unit, MDE used the binning methodology in conjunction with performance rates for SCR and SNCR technologies to provide an indication of the unit's overall efforts to optimize controls. The following charts illustrate the methodologies used for grading EGU units. The methodologies are identical, but with different rate performance standards for SCR and SNCR units. Under this methodology, any SCR unit that achieved a 2017 rate less than 0.10 lb/mmBtu and any SNCR unit under 0.15 lb/mmBtu would receive a grade of A or A+ depending on their designated bin.
Grading Strategy for SCR Units
Grading Strategy for SNCR Units