Mercury and Air Toxics Standard for Power Plants. Marney Hoefer January 26, 2012

Transcription

1 Mercury and Air Toxics Standard for Power Plants Marney Hoefer January 26,

2 Overview Background on mercury air toxics rule Overview of the new standards to regulate mercury and air toxics for power plants Compliance dates and flexibility How the final rule differs from the proposed rule Interaction with Wisconsin s Mercury Rule (ch. NR 446) 2

3 How did we get here? 3 December 2000: EPA made a determination that it was appropriate and necessary to regulate EGUs under s. 112 of the CAA January 2004: EPA proposed section 112 standards for mercury emissions from coal-fired EGUs and nickel emissions from oil-fired EGUs. Also proposed in the alternative to remove EGUs from the section 112 list and regulate under section 111. March 2005: EPA issued a final revision of the appropriate and necessary finding for coal and oil-fired EGUs and removed such units from s. 112 list. EPA never finalized s. 112 standards for mercury or nickel but did finalize the regulation under s. 111 to reduce mercury emissions from coal-fired EGUs (Clean Air Mercury Rule). February 2008: The D.C. Circuit vacated both the 2005 action to remove EGUs from the s. 112 list and the section 111 rule to limit mercury emissions. As a result, EGUs remain a s. 112 listed source category. March 2011: EPA proposed section 112 air toxics standards for all coal- and oilfired EGUs that reflect the application of maximum achievable control technology (MACT). December 2011: EPA makes a finding that it is appropriate and necessary to regulate EGUs and finalized section 112 air toxic standards for coal and oil-fired EGUs

4 Federal Rule -- applicability Applies to EGUs larger than 25 MW that burn coal or oil for the purpose of generating electricity for sale and distribution through the national electric grid to the public Includes investor-owned units, as well as units owned by the Federal government, municipalities and cooperatives that provide electricity for commercial, industrial and residential uses. In Wisconsin, applies to approximately 15 sources (50 units) 4

5 Wisconsin Sources (as identified by EPA) Alma Blount Street Columbia Edgewater Elm Road Genoa John P. Madgett Manitowoc Nelson Dewey Pleasant Prairie Pulliam Rock River South Oak Creek Valley Weston 5

6 Federal Rule Summary For all existing and new coal-fired EGUs, the rule establishes numeric emission limits for Mercury (reducing emissions by approximately 90%) Particulate matter (as a surrogate for toxic non-mercury metals) Hydrochloric acid (as a surrogate for all toxic acid gases) For existing and new oil-fired EGUs, the rule established numeric emission limits for Particulate matter (as a surrogate for toxic metals) Hydrochloric acid Hydrofluoric acid 6

7 Emission Limits coal & solid fired Subcategory Filterable PM Hydrogen Chloride Existing coal fired unit* Mercury 0.3 lb/mwh 0.02 lb/mwh lb/gwh Existing IGCC 0.4 lb/mwh lb/mwh 0.03 lb/gwh Existing solid oil derived unit 0.09 lb/mwh 0.08 lb/mwh lb/ GWh New coal fired unit* lb/mwh lb/mwh lb/ GWh New IGCC 0.07 lb/ MWh** or 0.09 lb/mwh*** lb/ MWh lb/ GWh New solid oil derived 0.02 lb/ MWh lb/mwh lb/gwh 7 * Limits are for units that do not burn low rank virgin coal. ** Limit is for duct burners on syngas. *** Limit is for duct burners on natural gas.

8 Alternative Numeric Emission Standards The rule establishes alternative numeric emission standards for: Sulfur Dioxide (as alternate to HCl) Individual non-mercury metal air toxics (as an alternate to PM) Total non-mercury metal air toxics (as an alternate to PM) 8

9 Limits on Organic Air Toxics Instead of numeric limits, the standards set work practices to limit emissions of organic air toxics, including dioxin and furan, from existing and new coal and oil-fired power plants. The work practice standards require an annual performance test program for each unit including an inspection, adjustment, and/or maintenance and repairs to ensure optimal combustion. 9

10 Averaging Averaging allowed only between individual existing units at a single stationary source Would only be permitted between individual units in the same subcategory in the Final EGU NESHAP (i.e., coal-fired EGUs) Would not be permitted between two or more different affected sources New affected sources would not be able to use averaging Required to submit an emission averaging plan Existing sources subject to EGU NSPS would be required to continue to meet the PM emission standard of that NSPS regardless of whether or not they are using emissions averaging 10

11 Start-up and Shut-down Rule sets work practice standards instead of numeric emission limits during periods of start-up and shut-down These standards require units to burn fuels such as natural gas or distillate oil during start-up and shut-down 11

12 Compliance Options The EPA anticipates that the following technologies, practices and compliance strategies can be used to comply with the new standards: Wet and dry scrubbers Dry sorbent injection systems Activated carbon injection systems Fabric filters Extended compliance option from state and enforcement discretion to help with implementation timelines 12

13 Compliance dates Without extensions, compliance with the new standard will be required by approximately April 2015 (depending on when the rule is published) States given discretion to extend compliance date by one year (likely to be broadly applied) Reliability critical unit determination (likely to be narrowly applied) Enforcement discretion Dec. 16, 2011 Giles Memo 13

14 Compliance Flexibility Facilities can use a longer averaging time for mercury 90 days instead of 30 days but if they choose this option, they will have to meet a tighter standard (1.0 lbs/tbtu) State ability to grant an additional year as needed for technology installation Pathway for reliability critical units to obtain a schedule with up to an additional year to achieve compliance Enforcement discretion 14

15 How does the final standard differ from the proposed standard? Using filterable PM as a surrogate for the metal toxics limit Monitoring and reporting requirements Provided an alternative compliance option for sources that plan to comply by averaging across multiple units Revised definitions of coal subcategories Added subcategories for non-continental oil-fired units and limited use oil-fired units (use work practice standards) 15

16 Filterable PM EPA had proposed an emission limit for total PM, which includes both filterable PM and condensable PM. The filterable PM limit was finalized instead of condensable. The EPA determined that this was appropriate because most of the metallic air toxics consist of filterable PM and the one that is not selenium is well controlled by the limit on acid gases. 16

17 Monitoring and recordkeeping EPA adjusted several monitoring and recordkeeping Final rule simplifies the procedures for demonstrating continuous compliance to two options: continuous monitoring or periodic quarterly testing Rule clarified that sources are only required to do testing for the form of the limit they choose to meet 17

18 Sustainability of MATS rule? Challenge of the appropriate and necessary finding which based the finding on the benefits from the reduction of particulate matter and that the benefits from reducing mercury were not quantified in such a way to justify a finding that regulation of mercury was necessary and appropriate Sen. Inhofe has indicated that he will file a petition under the Congressional Review Act to block the regulation Sen. Inhofe has also sought an Inspector General study into the EPA s scientific review procedure of its mercury risk assessment Questions about whether EPA failed to properly consult FERC on the impact of the rule on the energy supply 18

19 Summary of Wisconsin Rule Required the state s four major utilities (Alliant, Dairyland, We Energies and Wis. Public Service Corporation) to reduce their mercury emissions by 40 percent by 2010 Requires large (150 MW and greater) coal-fired power plants to reduce mercury using one of two approaches: Achieve a 90 percent reduction in mercury emissions by the year 2015 ( lbs/gwh) Reduce multiple pollutants, including NOx and SO2 and achieve 90 percent reduction in mercury emissions by 2021 Requires small (>25 MW and < 150 MW) coal-fired power plants to reduce their mercury emissions using best available control technology Allows for averaging across system units 19

20 Wisconsin Sources Majority of EGUs in Wisconsin have opted to comply with the 90% reduction by 2015, averaged across the utility s fleet Many facilities have opted to have their small units subject to the 90% reduction in order to be able to average across their fleets MG&E Blount has converted to natural gas and probably will not be subject to the rule We Energies opted for the multi-pollutant option with the 2021 compliance date for 90% reduction Some utilities have already stated publicly that they are set to comply with the limits 20

21 New Source Performance Standard Revision In addition to the standards for mercury and air toxics, the EPA revised the new source performance standards for fossil-fuel-fired EGUs. These revisions include numeric emission limits for PM, SO2 and NOx. 21

22 Questions? Marney Hoefer