# EPA Regulation: 

# Utility MACT Proposal

Jennifer Macedonia March 24, 2011

# What is Utility MACT?
 

# 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 2

# Why did EPA propose MACT?
3



## 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 

### out by court in 2008 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

# What is required?
 

# 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 4

HCl : Hydrogen Chloride

# MACT Flexibility
 

# 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  

# 4 th 

# compliance year, if needed for controls subcategories 5

# Health Based Emission Limits
 

# 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 6

# MACT Costs and Benefits

Costs Health

Benefits

Benefits are primarily from co- benefit particle reductions

Source: EPA projected costs and benefits 7

# 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

# MACT Emission Reductions
9 

# Hg • 78% reduction of mercury HCl • 91% reduction of acid gas 

# PM • 30% reduction of particulate matter SO 2 

# • 55% reduction of sulfur dioxide CO 2 

# • 3% reduction of carbon dioxide

EPA projected % reduction from affected units, compared to their baseline reference case

# 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.”

# MACT Retirement Projections
 

# 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 NOX

### , and GHGs  

## Some studies include baseline retirements projected regardless of EPA regulation 11

# What Replaces Retired Coal?
 

# 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  

# 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) 12

MACT: Maximum Achievable Control Technology GW: Gigawatts

# Retirements vs. Retrofits
Retirements

Control Installations 13Wet scrubber DSI Baghouse ACI SCR Ash Cooling Tower Alternate Water Relative Capital Cost $/kW 

### Retrofit Capital Costs

300 MW

500 MW 700 MW 

# Pollution Control Technologies

Pollutant/Issue Control Technologies Acid Gases + Sulfur Dioxide (SO 2) Wet or dry scrubber or Dry Sorbent Injection (DSI) + Particulate Controls Metallic toxics/Particulate Matter (PM) Baghouse/Fabric Filter or ESP Mercury Activated Carbon Injection (ACI) + Particulate Controls or wet scrubber + SCR NOX Selective Catalytic Reduction (SCR) or SNCR, low- NO x burners, etc Coal ash Dry ash handling + ash pond/pit liners, etc Cooling Water Intake Screens, barrier nets, low velocity caps, etc or Cooling Tower 14

*

* Dry scrubber cost 10 - 15% lessWet scrubber DSI Baghouse ACI SCR Ash Cooling Tower Alternate Water Relative Capital Cost 

### Retrofit Capital Costs

300 MW

500 MW 700 MW 

# Relative Costs of Control

MACT Controls or 15

Pollutant/Issue Control Technologies

Acid Gases + Sulfur Dioxide (SO 2) Wet or dry scrubber or Dry Sorbent Injection (DSI) + Particulate Controls Metallic toxics/Particulate Matter (PM) Baghouse/Fabric Filter or ESP Mercury Activated Carbon Injection (ACI) + Particulate Controls or wet scrubber + SCR NOX Selective Catalytic Reduction (SCR) or SNCR, low- NOx burners, etc Coal ash Dry ash handling + ash pond/pit liners, etc Cooling Water Intake Screens, barrier nets, low velocity caps, etc or Cooling Tower

# Compliance with Acid Gas Limits

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 time 1 DSI 65 12 months Dry FGD 24 24 months Wet FGD 4 36 months Existing Scrubbers Retrofits regardless of MACT Add Wet Scrubber Add Dry Scrubber Add DSI 

### Acid Gases

* EPA Projected Retrofits for Acid



### Gases 16

1 Institute of Clean Air Companies, Letter to Senator Carper, November 3, 2010

# Annual Control Costs

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 17

# Other Rules For Power Sector
 

# Air  

# Transport Rule: SO 2 

# and NOX 

# caps  

# Transport Rule II: tighter caps  

# GHG NSPS  

# Water  

# Cooling Water Intake 316(b)  

# Waste  

# Coal Ash – Coal Combustion Residuals 18

# Power Sector EPA Rules

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 19

# Also Proposed: Revised NSPS
20 

# Revised new source emission limits

• New Source Performance Standards (NSPS) 

# • For conventional pollutants: PM, SO 2

# , NOX 

# Responds to past litigation

• EPA sued on 2006 NSPS amendments • 2009 voluntary remand

# www.BipartisanPolicy.org 21

Jennifer Macedonia 

## jmacedonia@bipartisanpolicy.org