EPA Regulation: Utility MACT Proposal

Transcription

1 EPA Regulation: Utility MACT Proposal Jennifer Macedonia March 24, 2011

2 What is Utility MACT? 2 Proposed EPA regulation for public comment Controls power plant smokestack emissions New and existing facilities Coal & oil-fired Hazardous air pollutants (HAP)/air toxics: metals (e.g., mercury, arsenic, chromium, nickel) acid gases (e.g., hydrogen chloride (HCl)) organic air toxics (dioxin, furans) MACT= Maximum Achievable Control Technology

3 Why did EPA propose MACT? Clean Air Act required EPA study on power plant toxics determine if appropriate and necessary to regulate In 2000, EPA determined: yes Thus, Act requires MACT emission limits First EPA attempt (2005 CAMR) thrown out by court in 2008 Court disagreed w/epa delisting power sector from toxic provisions Court-ordered deadlines for Utility MACT Proposed Rule: March 16, 2011 Final Rule: November 16, 2011

4 What is required? 4 Strict command & control MACT emission limits Mercury, Particulate Matter (PM), HCl (acid gas) Work practice standards (good combustion) Dioxin/furans Some existing units comply w/current controls For some, required installations include: Activated Carbon Injection (ACI) Upgraded particulate controls Scrubber or Dry Sorbent Injection (DSI) Some units will retire rather than invest in controls HCl: Hydrogen Chloride

5 MACT Flexibility 5 Facility-wide averaging Could allow some units to exceed MACT limits Weaker limits for Existing units, compared to new Lignite, compared to other coal Pet coke, compared to oil subcategories Alternative emission standards (less monitoring) Exempt gas units that infrequently burn oil 4 th compliance year, if needed for controls

6 Health Based Emission Limits 6 Clean Air Act requires MACT for air toxics Limit at least as stringent as performance of top 12% EPA discretion for less stringent alternative Health Based Emission Limit CAA 112(d)(4) Must ensure margin of safety above health standard In past, EPA exempted other sectors from HCl MACT But EPA did not use health-based limit for utilities Power plants are largest human source of many toxics Lack of info on respiratory irritant cumulative impacts Environmental effects of acid gases Significant health co-benefits of MACT limit MACT: Maximum Achievable Control Technology HCl: Hydrogen Chloride

7 MACT Costs and Benefits 7 Costs Health Benefits Benefits are primarily from co-benefit particle reductions Source: EPA projected costs and benefits

8 Potential Impacts on Jobs 8 EPA finds that more jobs will be created in the air pollution control technology production field than may be lost as the result of compliance with these proposed rules Temporary gains during construction phase Long term impacts harder to discern

9 MACT Emission Reductions 9 Hg HCl PM SO 2 CO 2 78% reduction of mercury 91% reduction of acid gas 30% reduction of particulate matter 55% reduction of sulfur dioxide 3% reduction of carbon dioxide EPA projected % reduction from affected units, compared to their baseline reference case

10 Electric Reliability 10 With proper planning and coordination Retirements and retrofits should be manageable But poor planning and stacking up retrofits in the last year/maintenance season could lead to issues EPA: To the extent that isolated issues remain concerning the availability of electricity in some more remote parts of the country, we believe that EPA has the ability to work with companies making good faith efforts to comply with the standards so that consumers in those areas are not adversely affected.

11 MACT Retirement Projections 11 EPA: MACT retires <1% national capacity (10 GW) On top of 27 GW expected to retire regardless Includes Transport Rule in baseline but not future rules for ash, cooling water, NO X, or GHGs Other studies Assume all units install most expensive technologies EPA allows lower cost alternative technologies to comply Include worst case estimates of other rules Ash disposal, cooling water, future NO X, and GHGs Some studies include baseline retirements projected regardless of EPA regulation

12 What Replaces Retired Coal? 12 Retired: small, inefficient generators that do not operate near full capacity Extra capacity in existing fleet to take up slack Capacity additions, regardless of MACT GW renewables (mostly wind) 1-3 GW gas As a result of MACT, EPA projects: 83 MW of new renewables built by 2015 No new gas, nuclear, coal (incremental) MACT: Maximum Achievable Control Technology GW: Gigawatts

13 Retirements vs. Retrofits 13 Retirements Control Installations

14 Relative Capital Cost $/kw Pollution Control Technologies 14 Retrofit Capital Costs 300 MW 500 MW 700 MW * Wet scrubber DSI Baghouse ACI SCR Ash Cooling Tower Alternate Water * Dry scrubber cost 10-15% less Pollutant/Issue Acid Gases + Sulfur Dioxide (SO 2 ) Metallic toxics/particulate Matter (PM) Mercury NO X Coal ash Cooling Water Intake Control Technologies Wet or dry scrubber or Dry Sorbent Injection (DSI) + Particulate Controls Baghouse/Fabric Filter or ESP Activated Carbon Injection (ACI) + Particulate Controls or wet scrubber + SCR Selective Catalytic Reduction (SCR) or SNCR, low-no x burners, etc Dry ash handling + ash pond/pit liners, etc Screens, barrier nets, low velocity caps, etc

15 Relative Capital Cost Relative Costs of Control 15 Retrofit Capital Costs 300 MW 500 MW 700 MW or Wet scrubber DSI Baghouse ACI SCR Ash Cooling Tower Alternate Water MACT Controls Pollutant/Issue Acid Gases + Sulfur Dioxide (SO 2 ) Metallic toxics/particulate Matter (PM) Mercury NO X Coal ash Cooling Water Intake Control Technologies Wet or dry scrubber or Dry Sorbent Injection (DSI) + Particulate Controls Baghouse/Fabric Filter or ESP Activated Carbon Injection (ACI) + Particulate Controls or wet scrubber + SCR Selective Catalytic Reduction (SCR) or SNCR, low-no x burners, etc Dry ash handling + ash pond/pit liners, etc Screens, barrier nets, low velocity caps, etc or Cooling Tower

16 Compliance with Acid Gas Limits 16 MACT Retrofits GWs Design + construction time 1 DSI months Dry FGD months Wet FGD 4 36 months Add Dry Scrubber EPA Projected Acid Retrofits Gases for Acid Gases Add DSI * Retrofits regardless of MACT Existing Scrubbers Add Wet Scrubber * Particulate control upgrades/retrofits also required with DSI and to comply with MACT PM limit 1 Institute of Clean Air Companies, Letter to Senator Carper, November 3, 2010 Analysis based on EPA data files from MACT IPM runs

17 Relative Levelized Cost Annual Control Costs 17 Annualized Costs of Utility MACT Retrofits 300 MW 500 MW 700 MW wet scrubber DSI Baghouse ACI Scrubber investment much higher than DSI But on-going cost of DSI brings annual cost closer to scrubber DSI best suited for certain fuels & smaller, less frequently run units

18 Other Rules For Power Sector 18 Air Transport Rule: SO 2 and NO X caps Transport Rule II: tighter caps GHG NSPS Water Cooling Water Intake 316(b) Waste Coal Ash Coal Combustion Residuals

19 Power Sector EPA Rules 19 Estimated Compliance Dates for Upcoming Regulations AIR Transport Rule Utility MACT Transport Rule II GHG NSPS WATER 316(b) Intake WASTE Coal waste/ash Phase I new units Phase II Caps National Emission Standards pending revised NAAQS existing units: pending EPA/state rulemakings 5 yr phase-in, pending rule pending final rule

20 Also Proposed: Revised NSPS 20 Revised new source emission limits New Source Performance Standards (NSPS) For conventional pollutants: PM, SO 2, NO X Responds to past litigation EPA sued on 2006 NSPS amendments 2009 voluntary remand

21 21 Jennifer Macedonia