CAIR & MATS
2012 Southern SectionalAWMA Annual Meeting& Technical Conference
September 12, 2012
Chris Goodman, P.E.Environmental Strategy
Southern Company Generating Facilities
• 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 Program at a Glance
Environmental LeadershipNew Projects and Research Programs
National Carbon Capture CenterWilsonville, Alabama
Integrated Gasification Combined CycleMississippi Power Plant Ratcliffe
Second Largest U.S. SolarCimarron Solar Facility
Largest U.S. BiomassNacogdoches Generating Facility
Mercury Research CenterGulf Power Plant Crist
Start-to-finish 25-MW CCSAlabama Power Plant Barry
Water Research CenterGeorgia Power Plant Bowen
Power Delivery and End-Use Technology Lab
U.S. first New NuclearGeorgia Power Plant Vogtle
Smart Grid: Integrated Distribution Management System
Air Quality Science CenterSEARCH network; ARIES; mercury
• 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
Transport Rules (CAIR/CSAPR)
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
2011 2012 2013 2014 2015 2016 2017 2018
MATS
CriteriaPollutants
(NO2, SO2, Ozone, PM)
CoalCombustionResiduals
Water316 (b)
Effluent Guidelines
GreenhouseGases (GHGs)
(Reporting Rule,Permitting,
PerformanceStandards)
ProposedRule
CommentPeriod
Final Rule
MATS Rule Pre-compliance Period for existing sources
MATS Rule Compliance for existing sources
New or RevisedStandards
Nonattainment Areas Designated andState SIPs Developed
NAAQS SIP Compliance
CAIR Phase I (until new CAIR Replacement Rule)
Possible Compliance w/CAIR RR
Final Rule
EPADevelopingFinal Rule
CCR Rule Pre-compliance
PeriodCCR Rule Compliance
EPA Developing Final316(b) Rule
Developing New Effluent Guidelines Rule
Action
EPA GHG Reporting Rule Compliance
Best Available Control Technology for Modified/New Sources (PSD/NSR/BACT) Smaller Sources Included by EPA
GHG Performance StandardsInc. Existing Units Compliance with New GHG Rules Pre-compliance
Effluent Guidelines ComplianceFinal Rule
Final
Rule316 (b) Rule Compliance
(within 8 years of Final Rule)
Effluent Guidelines Pre-compliance Period
316 (b) Rule Pre-compliance Period
FinalRule
CAIR Phase II (until new CAIR RR)
Proposed and Final CAIR RR
EPA New Regulatory Actions Timeline
• CCR Rule• Effluent Guidelines
AirHeater
BottomAsh
FlyashGypsum
NOX
CombustionControls
Bag
ho
use
(H
g)
(Ac
tiv
ate
d C
arb
on
Inje
cti
on
)Coal-Fired Boiler NOx & Hg Control
SCR
SO2 & Hg(acid gases)
ControlScrubber
Dust&Hg Control
ESPSNCR
• CAIR/CSAPR• PM-2.5 NAAQS• 8-Hour Ozone NAAQS• Mercury (Cobenefit)• Regional Haze (BART)• NO2 NAAQS
• Utility MACT
• CAIR/CSAPR• Regional Haze (BART)• Mercury (Cobenefit)• PM-2.5 NAAQS• SO2 NAAQS
NewStack
CO2
Reduction
Groundwater Monitoring/ Dry
Handling / Landfilling / Pond
Closure
• 316(a) Thermal• 316(b) Intake Structures
• Effluent Guidelines
Scrubber WasteWater
Physical/Chemical/Biological Treatment
Scrubber WasteWater
Ultra Fine Filtration
• GHG Regulation/Legislation
Process Water
Cooling Tower/ Intake Screens
Emission Control Technologies for Coal-Fired Boilers
Scrubbers
CCRWater
SCRs
CC
/CT
Nu
cle
ar IG
CC
Re
ne
wa
ble
s D
SO
NOx
SOx
Hg
PM
Ash
H20
CO2
CCS
Natural GasIGCC
Nuclear
Solar
Wind
Biomass
Regulatory Drivers
New Resources
Balance
Baghouses
Constructive Regulation
Healthy Capital
Spending
High Reliability Low Prices
High Customer Satisfaction
Customers
Hydro
Demand Side Options
Preliminary Assessment of Impactsof EPA Rules – More to Come
Possible Outcome
• Install new controls on 13 GWs - 65% of coal fleet.
• Retire 3 – 4 GWs of coal-fired generation.
• Fuel switching of 3 -4 GWs, primarily to natural gas
Potential Impacts
• Estimated $13B - $ 18B capital cost through 2020
• 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