EPA s Utility Air Regulations New Jersey Clean Air Council

Transcription

1 EPA s Utility Air Regulations New Jersey Clean Air Council Eric B. Svenson, Jr. Vice President Policy and Environment, Health & Safety PSEG Services Corporation October 12,

2 Our Family of Companies Fast Facts Total assets (2010): $29.9 billion Total annual revenues (2010): $11.8 billion Employees: Approximately 10,000 Installed Generating Capacity ~ 16 GWs PSEG Power Leading independent power producer Diversified portfolio of power plants, including base load units, load following units and peaking units PSE&G One of the largest combined electric and gas companies in the United States New Jersey's oldest and largest publicly owned utility Customers in more than 300 urban, suburban and rural communities, including New Jersey's six largest cities PSEG Energy Holdings Leader in U.S. solar development Investor in innovative alternative energy projects/technologies, including compressed air energy storage 2

3 PSEG Power s Electric Generation Portfolio 3

4 PSEG Air Pollution Control Investments PSEG Power has invested more than $1.5 billion on coal emission controls over the past decade. More than 1,600 construction workers were on the Mercer and Hudson job sites at the peak of construction. 4

5 EPA s Electric Sector Regulatory Agenda Hazardous Air Pollutants Develop Utility MACT Pre-Compliance Period Compliance with Utility MACT Criteria Pollutants Develop Transport Rule Compliance with CSAPR ( Transport Rule ) Greenhouse Gases Develop GHG NSPS Compliance with GHG NSPS Notes Utility MACT = EPA is under a court-ordered deadline to complete the rule by November 16, Affected sources would need to comply by 2015 (with option under the CAA for additional time for the installation of controls). Transport Rule = EPA issued final rule on July 6, 2011 and technical correction Oct 6, Compliance begins January 1, 2012; the second phase of SO 2 reductions begins January 1, GHG NSPS = EPA is required by a settlement agreement to issue a final rule by May 26,

6 Cross-State Air Pollution Rule (CSAPR) Background The Transport Rule finalized by EPA in July 2011 regulates NOx and SO 2 emissions from power plants in the eastern U.S. Transport Rule: Proposed NOx and SO 2 Emissions Caps The rule is intended to help downwind states attain the 24 hour PM 2.5 standards established in 2006, the 1997 annual PM 2.5 standards, and the 1997 ground level ozone standard. EPA estimates that the proposed rule will yield $120 billion to $280 billion in annual health and welfare benefits in Four trading markets will be established as shown to the right. 6

7 CSAPR - SO vs. Implied 2012 Rates Implied 2012 Emission Rate (lb/mmbtu) Based on 2012 CSAPR allocation and reported actual heat input in Tennessee Michigan Nebraska Missouri Iowa Alabama Kentucky Illinois West Virginia Pennsylvania South Carolina Georgia North Carolina Wisconsin Virginia Minnesota Maryland Kansas Texas New York Indiana Ohio New Jersey Actual 2010 Emission Rate (lb/mmbtu) Source: MJ Bradley & Associates

8 CSAPR Annual NOx 2010 vs. Implied 2012 Rates 0.30 Implied 2012 Emission Rate (lb/mmbtu) Based on 2012 CSAPR allocation and reported actual heat input in Minnesota Iowa Kentucky Pennsylvania West Virginia Alabama Tennessee Ohio Virginia Michigan Georgia Missouri South Carolina North Carolina Wisconsin Maryland Texas New York New Jersey Illinois Indiana Kansas Nebraska Actual 2010 Emission Rate (lb/mmbtu) Source: MJ Bradley & Associates

9 CSAPR Ozone Season NOx 2010 vs. Implied 2012 Rates 0.30 Implied 2012 Emission Rate (lb/mmbtu) Based on 2012 CSAPR allocation and reported actual heat input in Florida Indiana Iowa Kentucky Pennsylvania West Virginia Arkansas Tennessee Ohio Alabama Missouri Georgia Virginia Wisconsin South Carolina North Carolina Maryland Mississippi Illinois Texas Louisiana New York New Jersey Michigan Oklahoma Kansas Actual 2010 Emission Rate (lb/mmbtu) Source: MJ Bradley & Associates

10 CSAPR NJ is extremely tight relative to rule s Assurance provision Source: MJ Bradley & Associates

11 CSAPR - Oct 6 th Technical Correction No changes proposed to the core elements of the program. The changes reflect new technical information brought to EPA by stakeholders after the final CSAPR was published. For example, correcting information regarding: Assumptions regarding level of control installed; or Utilization of generation for other than load dispatch (running for voltage control or supply to other RTOs) The proposal revises budgets in Florida, Louisiana, Michigan, Mississippi, Nebraska, New Jersey, New York, Texas, and Wisconsin and new unit set asides in Arkansas and Texas. NJ state budget increased as follows: For 2012: SO 2 of 2,096 tons, annual NOx of 420 tons, and ozone-season NOx of 592 tons; and, For 2014: annual NOx of 112 tons, and ozone-season NOx of 195 tons. Unit level allocations in Alabama, Indiana, Kansas, Kentucky, Ohio and Tennessee adjusted to reflect utility consent decrees. Assurance provision of rule to be delayed by 2 years to

12 Utility MACT Rule Proposed April 2011, to be finalized November 2011 The Utility MACT Rule proposes to regulate mercury, acid gases and other hazardous air pollutants from coal- and oil-fired power plants throughout the U.S. The rule proposes (1) PM, (2) hydrogen chloride, and (3) mercury emissions limits for coal-fired power plants. EPA has proposed achievable standards well within the capability of existing pollution control technology: Nearly 60 percent of all coal-fired boilers that submitted stack test data to EPA are currently achieving the Utility Toxics Rule's proposed mercury emissions standard (101 units). About 70 percent of all coal-fired boilers that submitted stack test data to EPA are currently achieving the proposed standards for PM. Close to 120 units report emissions below the proposed PM standard (out of 172). About 70 percent of all coal-fired boilers that submitted stack test data to EPA are currently achieving the proposed standards for HCl. Close to 160 units report emissions below the proposed HCl standard (out of 217). Section 112 of the CAA requires affected sources to achieve compliance within 3 years of issuing the final rule, with the potential for a case-by-case, 12-month extension to install controls. Clean Energy Group companies and PSEG have supported coal MACT standards. We have also raised some technical concerns with the proposed rule: frequency of stack testing standards for oil-fired power plants (there should be #2 oil and #6 oil standards). 12

13 Technology Options for MACT Compliance MACT Pollutants Cobenefits Primary Pollutant Control Co-benefit Reductions Particulate Matter Mercury Hydrogen Chloride Sulfur Dioxide Nitrogen Oxides PM Hg HCl SO 2 NOx Activated Carbon Injection (ACI) Control Technologies Wet Scrubber Dry Scrubber SCR SNCR PM Controls (Fabric Filters & ESPs) Dry Sorbent Injection (DSI) Note: DSI has emerged as a potential control option for smaller, subbituminous coal-fired generating units seeking to control SO 2 and acid gas emissions. EPA s regulatory impact analysis of the Toxics Rule projects substantial installation of DSIs by the smaller uncontrolled units to achieve compliance. 13

14 Profile of Existing U.S. Coal-fired Fleet Installed Capacity (GW) Extensive Controls High Level of Controls Some Controls Minimal Controls 120 GW (268 units) 38% of U.S. Coal Capacity 71 GW (194 units) 22% of U.S. Coal Capacity 63 GW 4 GW 33 GW <1 GW GW 1 95 GW 2 75 GW <1 GW Total U.S. Coal-fired Capacity: 320 GW GW 5 GW 33 GW (141 units) 10% of U.S. Coal Capacity 96 GW (487 units) 30% of U.S. Coal Capacity 1 Capacity with the capability to burn subbituminous coal rank. These units may be able to use DSI, a low-cost alternative relative to scrubbers, as a compliance option. 2 Capacity with the highest risk of retirement 0 11 GW ACI Scrubber SCR/SNCR ESP/Baghouse Scrubber SCR/SNCR ESP/Baghouse Scrubber SCR/SNCR Scrubber ESP/Baghouse Scrubber SCR/SNCR ESP/Baghouse SCR/SNCR ESP/Baghouse No Controls Source: MJ Bradley & Associates 120 GW 71 GW 1 94 GW 2 35 GW 14

15 New Jersey Coal Plants are Well Positioned to Comply New Jersey coal fired power plants are well controlled with scrubbers, baghouses, and activated carbon injection (ACI) for mercury control. Virtually all coal units in the state are already meeting EPA s proposed standards for mercury, HCl, and PM. Plant Name Unit MW Scrubber On-line Year NOx Controls PM Controls Mercury Controls Compliance Status (based on information submitted to EPA as part of ICR) Mercury HCl PM Hudson SCR Baghouse ACI * * * Mercer SCR Baghouse ACI * * Mercer SCR Baghouse ACI * * Logan SCR Baghouse BL England** SNCR Baghouse ACI No Data No Data BL England** SNCR ESP No Data No Data No Data Carneys Point SCR Baghouse Carneys Point SCR Baghouse *Based on information from plant owners indicating that they would be able to comply with the proposed standards without the need for any additional controls. **The BL England coal units are subject to an Administrative Consent Order with the NJ DEP requiring NOx and SO 2 controls, and R C Cape May Holdings, LLC, the owner of the facility, has been investigating possible repowering options at the site. 15

16 Coal Capacity in PJM Interconnection Coal-fired Capacity in PJM Interconnection (~67 GW*) No Controls 13 GW (68 units) 20% Extensive Controls 7 GW (39 units) 11% Controls Capacity (MW) No. of Units % of total PJM Capacity Scrubber, SCR/SNCR, Baghouse, ACI 2, % Scrubber, SCR/SNCR, Baghouse 4, % Scrubber, SCR/SNCR 28, % Scrubber, Baghouse 1, % Scrubber 6, % SCR/SNCR, Baghouse % SCR/SNCR 6, % SCR/SNCR, ACI % Baghouse % ACI % No Controls 13, % Total Coal fired Capacity in PJM 66, Source: EPA NEEDS 4.10, EIA Some Controls 10 GW (39 units) 15% PJM Service Territory Moderate Controls 36 GW (97 units) 55% * greater than 25 MW in size Source: MJ Bradley & Associates Source: PJM 16

17 Northeast and PJM Coal Plant Retirements Some studies provide a breakdown for the PJM region. Estimates are in the range of 5-24 GW. PJM reported a reduction in committed coal capacity in 2014/2015 equal to 6.9 GW, and suggested that the decrease is likely related to some coal capacity reflecting the costs of environmental retrofits in their offer prices. Despite the decline, the market secured resources sufficient to maintain a 20 percent reserve margin for the region. Study by Release Date Estimated Coal Capacity Retirements in PJM and/or MISO CERA March GW (Northeast, incl. most of PJM) Bernstein Research March 2011 <9 GW (PJM West) <1.5 GW (PJM East) FBR Capital December GW The Brattle Group December GW (PJM only) NERC October GW (RFC) Credit Suisse September GW (PJM only) 17

18 US Coal Retirement Projections Retirement projections vary widely among studies primarily because of differences in assumptions 60 Utility Toxics Rule Proposed: Mar 16, Retired Capacity (GW) Natural gas price and outlook 2.Control technologies available, especially DSI 3.Flexibility in EPA rules 4.Capital cost of control technologies 5.Scope of regulations considered NERC 44 Brattle Group EEI Bernstein Research 10 EPA 29 CERA 36 5 EIA Median Median NERA Bipartisan Policy Center 35 Citi Date Released Oct 2010 Dec 2010 Jan 2011 Mar 2011 Mar 2011 Apr 2011 Apr 2011 May 2011 Jun 2011 Jul 2011 Regulations Considered Baseline Exclusions Air, Water, Ash 13 GW of announced retirements (may include noncoal units) Air, Water 6 GW of retirements Air, Water, Ash 22 GW of retirements Air 12 GW projected to retire due to unit age Air (Toxics Only) 13 GW of retirements Air, Water Figure indicated above is the assumed total Air 9 GW of retirements Air 5 GW of retirements Air, Water, Ash GW of retirements Air, Water, Ash Figure indicated above is the assumed total Source: MJ Bradley & Associates 18

19 The Clean Energy Group PSEG is among a coalition of power companies that have been actively supporting EPA s efforts to develop effective air pollution regulations. The member companies serve electricity to more than 57 million people (20% of U.S. population) Power Generation Electric or Natural Gas Service The companies have over 170,000 megawatts of generating capacity throughout the U.S. 19

20 Reactions to the Utility Toxics Rule have been mixed, but many are framing the rule as an important opportunity to modernize the nation s electric power infrastructure. Optimism Concern Jim Rogers, President and CEO of Duke Energy, said: [T]he anticipation of more stringent environmental rules has long been part of our business plan We have really mitigated a lot of the risk and the cost associated with this program by the early steps that we took. May 3, 2011, Duke Energy 1st Quarter 2011 Earnings Call Benjamin G.S. Fowke, III, President and Chief Operating Officer of Xcel Energy, said: Our proactive steps to reduce emissions through the MERP project in Minnesota and our plans for the Clean Air-Clean Jobs Act in Colorado put us in good position to comply with these rules. April 28, 2011, Xcel Energy Inc. 1st Quarter 2011 Earnings Call Mauricio Gutierrez, Executive Vice President and Chief Operating Officer of NRG reports that: The proposed [Utility Toxics Rule] provides flexibility in that compliance can be achieved through facility averaging and company selected control technology [t]he key takeaway is that we do not expect at this time any additional environmental CapEx beyond what we have previously announced. May 5, 2011, NRG Thomas Fanning, President of Southern Company, said: In summarizing our position on the EPA MACT, we have 4 key concerns: First, no matter how you look at it, the timeline for this rule is unreasonable both for providing comments and for complying. Second, its accelerated 3-year timeline for compliance could put the reliability of the nation's electric generating system at risk. My third point is that the rushed timeline will also impact electricity affordability. My fourth and final point is that the industry needs a realistic compliance schedule, a schedule that is based on historical experience, a schedule that allows us to retrofit existing units and begin work on additional capacity at the same time. April 27, 2011, Southern Company 1 st Quarter 2011 Earnings Call Tom Voss, President and CEO of Ameren, said: These rules are expected to impose additional costs on our company and our customers and these additional costs could be substantial We are still evaluating the rules proposed by the EPA in March and their impact on each of our generating units. May 5, 2011, Ameren Corporation 1 st Quarter 2011 Earnings Call Energy 1st Quarter 2011 Earnings Call 20

21 Electric System Reliability and Jobs Companies can comply with CASPR and MACT w/o impact to grid reliability: Many coal plant operators have already installed pollution control systems. The results of PJM s most recent forward capacity auction demonstrate that the industry can meet future electricity demand while maintaining electric system reliability. Several independent reports conclude that electric system reliability can be maintained while transitioning to a cleaner energy future. A variety of tools are available to manage electricity system reliability. Mechanisms are in place to ensure that reliability standards are met and EPA has the authority to provide additional time for the installation of controls, if necessary. Utility MACT is expected to create jobs (1) ~ 28,000 to 158,000 by 2015 Note (1): Economic Policy Institute, June 2011 report, A Lifestaver, Not a Job Killer EPA s Proposed Air Toxics Rule is No Threat to Job Growth 21

22 GHG NSPS Source: MJ Bradley & Associates 22

23 GHG NSPS Can NSPS be a path for achieving meaningful reductions? Source: MJ Bradley & Associates 23

24 Thank you Eric B. Svenson, Jr. Vice President Policy and Environment, Health & Safety PSEG Services Corporation 24