CAIR & MATS
2012 Southern Sectional
AWMA Annual Meeting
& Technical Conference
September 12, 2012
Chris Goodman, P.E.
Environmental Strategy
Southern Company Generating Facilities
Environmental Program at a Glance
• Through 2011, invested about $8.3 B in environmental controls

17 FGDs on 25 units

17 SCRs

4 baghouses with ACI
• Projected base capital environmental expenditures of about $1.5 B over the next 3
years; Projected to spend an estimated $1.8 B for MATS and $0.5 B for ash and water
compliance over the next 3 years
• Since 1990, emissions of sulfur dioxide
and nitrogen oxides are down over 70 percent,
while electricity generation has increased
by more than 30 percent to serve growing demand
Environmental Leadership
New Projects and Research Programs
Smart Grid: Integrated Distribution Management
System
Second Largest U.S. Solar
Cimarron Solar Facility
Water Research Center
Georgia Power Plant Bowen
U.S. first New Nuclear
Georgia Power Plant Vogtle
National Carbon Capture Center
Wilsonville, Alabama
Integrated Gasification Combined Cycle
Mississippi Power Plant Ratcliffe
Largest U.S. Biomass
Nacogdoches Generating Facility
Air Quality Science Center
SEARCH network; ARIES; mercury
Power Delivery and End-Use
Technology Lab
Mercury Research Center
Gulf Power Plant Crist
Start-to-finish 25-MW CCS
Alabama Power Plant Barry
Transport Rules (CAIR/CSAPR)
• CSAPR vacated and remanded to EPA August 21
(CAIR remains in place)
– Court held that EPA exceeded its CAA authority
• CAIR Phase II begins in 2015
– Tighter SO2 and NOx
allowance requirements
Mercury and Air Toxics Standards (MATS)
• Final rule issued by EPA on February
16, 2012
– Largely unchanged from proposed rule
– Some additional compliance flexibilities
based on comments
• Imposes stringent emission limits for
mercury, particulate matter, and acid gases
• Could force many retirements and large
capital expenditures across the industry
• Unreasonable compliance time of three
years(April 2015), with case-by-case 1-year
extensions
EPA New Regulatory Actions Timeline
Action
MATS
Criteria
Pollutants
(NO2, SO2,
Ozone, PM)
Coal
Combustion
Residuals
Water
316 (b)
Effluent Guidelines
Greenhouse
Gases
(GHGs)
(Reporting Rule,
Permitting,
Performance
Standards)
2011
Proposed
Rule
Comment
Period
2012
Final
Rule
New or Revised
Standards
2013
2014
2015
2016
MATS Rule Pre-compliance Period
for existing sources
NAAQS SIP Compliance
CAIR Phase II (until new CAIR RR)
CAIR Phase I (until new CAIR Replacement Rule)
Possible Compliance w/CAIR RR
Proposed and Final CAIR RR
EPA Developing Final
316(b) Rule
CCR Rule
Pre-compliance
Period
Final
Rule
Final
Rule
CCR Rule Compliance
316 (b) Rule Compliance
316 (b) Rule Pre-compliance Period
Developing New Effluent Guidelines Rule
Final
Rule
(within 8 years of Final Rule)
Effluent Guidelines
Pre-compliance Period
Effluent Guidelines Compliance
EPA GHG Reporting Rule Compliance
Best Available Control Technology for Modified/New Sources (PSD/NSR/BACT)
GHG Performance Standards
Inc. Existing Units
Final
Rule
2018
MATS Rule Compliance
for existing sources
Nonattainment Areas Designated and
State SIPs Developed
EPA
Developing
Final Rule
2017
Pre-compliance
Smaller Sources Included by EPA
Compliance with New GHG Rules
Emission Control Technologies for Coal-Fired Boilers
•CAIR/CSAPR
•PM-2.5 NAAQS
•8-Hour Ozone NAAQS
•Mercury (Cobenefit)
•Regional Haze (BART)
•NO2 NAAQS
• Utility MACT
Coal-Fired Boiler
NOx & Hg
Control
SCR
SNCR
NOX
Combustion
Controls
Air
Heater
Dust&Hg
Control
ESP
SO2 & Hg
(acid gases)
Control
Scrubber
CO2
Reduction
Flyash
Gypsum
Bottom
Ash
•316(a) Thermal
•316(b) Intake Structures
Groundwater
Monitoring/ Dry
Handling / Landfilling
/ Pond Closure
• CCR Rule
•Effluent Guidelines
•CAIR/CSAPR
•Regional Haze (BART)
•Mercury (Cobenefit)
•PM-2.5 NAAQS
•SO2 NAAQS
•Effluent Guidelines
Process Water
Cooling Tower/
Intake Screens
•GHG Regulation/Legislation
Scrubber
WasteWater
Physical/Chemical/
Biological
Treatment
Scrubber
WasteWater
Ultra Fine Filtration
New
Stack
Balance
NOx
SCRs
CC/CT
Customers
Baghouses
Nuclear
PM
Wind
IGCC
High Reliability
Low Prices
High Customer Satisfaction
New
Resources
Water
CCR
Hydro
Solar
Renewables
Ash
H20
Nuclear
Regulatory
Drivers
Natural Gas
Healthy
Capital
Spending
Constructive
Regulation
SOx
Hg
IGCC
Scrubbers
DSO
CO2
CCS
Biomass
Demand Side Options
Preliminary Assessment of Impacts
of EPA Rules – More to Come
Possible Outcome
Potential Impacts
• Install new controls on 13 GWs
- 65% of coal fleet.
• Estimated $13B - $ 18B
capital cost through 2020
• Retire 3 – 4 GWs of coal-fired
generation.
• Fuel switching of 3 -4 GWs,
primarily to natural gas
• Possible 10% - 20%
electricity price increases
over the next 10 years
Summary
•
Cumulative impacts of MATS, CSAPR/CAIR, 316(b), new
effluent guidelines, CCBs, NAAQS, GHGs and other
requirements must be considered when making decisions
•
Research, testing and planning are the keys to finding the least
cost, least regret, site specific solution
•
Continuous process and is complicated by uncertain future
environmental rules and national energy policies