Utility MACT Proposal Jennifer Macedonia March 24, 2011 What is - - PowerPoint PPT Presentation
EPA Regulation: Utility MACT Proposal Jennifer Macedonia March 24, 2011 What is Utility MACT? 2 Proposed EPA regulation for public comment Controls power plant smokestack emissions New and existing facilities Coal &
Jennifer Macedonia March 24, 2011
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
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Court-ordered deadlines for Utility MACT
Proposed Rule: March 16, 2011 Final Rule: November 16, 2011
Thus, Act requires MACT emission limits
First EPA attempt (2005 CAMR) thrown
Court disagreed w/EPA “delisting” power sector from toxic provisions
1990 Clean Air Act required EPA study on power plant toxics
determine if “appropriate and necessary” to regulate In 2000, EPA determined: yes
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
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HCl: Hydrogen Chloride
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
Alternative emission standards (less monitoring) Exempt gas units that infrequently burn oil 4th compliance year, if needed for controls
subcategories
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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
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Benefits are primarily from co-benefit particle reductions
Source: EPA projected costs and benefits 7
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Temporary gains during construction phase Long term impacts harder to discern
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EPA projected % reduction from affected units, compared to their baseline reference case
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With proper planning and coordination Retirements and retrofits should be manageable But poor planning and stacking up retrofits in the last
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, NOX, 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 NOX, and GHGs
Some studies include baseline retirements projected
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Retired: small, inefficient generators that do not
Extra capacity in existing fleet to take up slack Capacity additions, regardless of MACT
25-36 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)
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MACT: Maximum Achievable Control Technology GW: Gigawatts
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Wet scrubber DSI Baghouse ACI SCR Ash Cooling Tower Alternate Water
Relative Capital Cost $/kW
Retrofit Capital Costs
300 MW 500 MW 700 MW
Pollutant/Issue Control Technologies Acid Gases + Sulfur Dioxide (SO2) Wet or dry scrubber
Metallic toxics/Particulate Matter (PM) Baghouse/Fabric Filter or ESP Mercury Activated Carbon Injection (ACI) + Particulate Controls
NOX Selective Catalytic Reduction (SCR)
Coal ash Dry ash handling + ash pond/pit liners, etc Cooling Water Intake Screens, barrier nets, low velocity caps, etc
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* Dry scrubber cost 10-15% less
Wet scrubber DSI Baghouse ACI SCR Ash Cooling Tower Alternate Water
Relative Capital Cost
Retrofit Capital Costs
300 MW 500 MW 700 MW
MACT Controls
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Pollutant/Issue Control Technologies Acid Gases + Sulfur Dioxide (SO2) Wet or dry scrubber
Metallic toxics/Particulate Matter (PM) Baghouse/Fabric Filter or ESP Mercury Activated Carbon Injection (ACI) + Particulate Controls
NOX Selective Catalytic Reduction (SCR)
Coal ash Dry ash handling + ash pond/pit liners, etc Cooling Water Intake Screens, barrier nets, low velocity caps, etc
Analysis based on EPA data files from MACT IPM runs
* Particulate control upgrades/retrofits also required with DSI and to comply with MACT PM limit MACT Retrofits GWs Design + construction time1 DSI 65 12 months Dry FGD 24 24 months Wet FGD 4 36 months
Existing Scrubbers Retrofits regardless
Add Wet Scrubber Add Dry Scrubber Add DSI
Acid Gases * EPA Projected Retrofits for Acid Gases
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1Institute of Clean Air Companies, Letter to Senator Carper, November 3, 2010
wet scrubber DSI Baghouse ACI
Relative Levelized Cost
Annualized Costs of Utility MACT Retrofits
300 MW 500 MW 700 MW
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
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Air
Transport Rule: SO2 and NOX caps Transport Rule II: tighter caps GHG NSPS
Water
Cooling Water Intake 316(b)
Waste
Coal Ash – Coal Combustion Residuals
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2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
AIR
Transport Rule Utility MACT Transport Rule II GHG NSPS
WATER
316(b) Intake WASTE Coal waste/ash Phase I Phase II Caps National Emission Standards pending final rule 5 yr phase-in, pending rule new units existing units: pending EPA/state rulemakings
Estimated Compliance Dates for Upcoming Regulations
pending revised NAAQS
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