The PJM deactivation analysis that planned retirements of three FirstEnergy nuclear facilities in Ohio — the 896 MW Davis Besse plant, the 1,247 MW Perry plant and the 1,811 MW Beaver Creek facility do not present a reliability threat in the short term is wrong. The PJM conclusion does not include compliance with Environmental Protection Agency Criteria Pollutants, particularly ozone attainment requirements.
The emissions free nuclear plants offset the nitrogen (NOx) loads from coal plants that contribute to the formation of smog. Because wind and solar do not have the capability to replace baseload electrical power, natural gas will be the replacement fuel of choice. Thus NOx from natural gas generation will contribute to the non attainment status for ozone, which reduces reliability if the PJM expects states to comply with the Clean Air Act.
PJM is also relying on speculative new transmission projects to provide reliability. Such a dice throw is unreasonable. Approval of proposed transmission projects are meeting significant resistance and are not getting approvals all over the country. PJM says it can retain reliability through projects already planned in its Regional Transmission Expansion Plan. Again, such planning does not account for PJM states being in none compliance of the Clean Air Act for ozone. Ignoring health effects is not a good reliability plan. Another speculative conclusion by PJM is that, even with the retirements, they expect to have sufficient generation and transmission capacity to withstand two concurrent asset outages — a so-called "n-1-1" event. "They expect?" This should be a surety, not an expectation. It is anything but sure.
The reliability analysis is too narrow and does not give credit for the unique attributes of theirnuclear plants, particularly the emission-free nature of this type of generation. The PJM reliability study ignores the value that these units offer the grid in terms of fuel diversity and zero-carbon and nitrogen emissions generation.
PJM's new fuel security initiative, which seeks to identify and reward generators with secure fuel supplies, such as onsite stockpiles or dual fuel capabilities is flawed. "Onsite stockpiles?" Do they expect these facilities to stockpile wind and solar? Onsite? That is not going to happen. Natural gas, fuel oil and coal are left. All nitrogen generators. The PJM should not be promoting any strategy that adds one more pound of NOx or particulate matter (PM) to the ambient air.
If FirstEnregy does not receive emergency support, the Davis Besse plant will retire at the end of May 2020, while the Perry plant and one unit of Beaver Island would come offline at the end of May 2021. The final unit at Beaver is scheduled to close in October 2021. (Utility Dive, 4/30/2018)