Most States Complying with First Phase of Cross-State SO2 Targets

Power plants are now grappling with early-stage compliance for new U.S. Environmental Protection Agency (EPA) rules affecting air, water and coal ash, and vigilance is vital, speakers said during a Wednesday COAL-GEN session in Las Vegas.

“I look at the end game. At some point, environmental groups are going to come after you,” said Block Andrews of Burns & McDonnell.

Andrews also quoted from the EPA Coal Combustion Residue (CCR) rule, which might hold true for many rules. “The plant should immediately begin evaluating how it intends to comply with the rules.”

Most states affected by the Cross-State Air Pollution Rule (CSAPR) should be able to comply with the first stage of SO2 standards for 2015, said Carl Weilert with CVW Consultants LLC.

Without turning to emissions trading, some affected states could have a tougher time complying with the 2017 SO2 standards under Cross-State.

Texas was about the only state not on track to easily meet the 2015 SO2 mandate for Cross-State. “They were really blindsided by the Cross-State rule,” said Weilert. Texas officials didn’t know until very late in the process that the rule would affect them.

Cross-State was drafted to replace the Clean Air Interstate Rule (CAIR), which was designed to enforce the “good neighbor” provision of the Clean Air Act, Weilert said. It regulates SO2 and NOx from fossil units in upwind states. Weilert’s study analyzed only SO2.

All 23 states must meet the first phase of the SO2 compliance target at the end of 2015, Weilert said. He noted that both Cross-State and its predecessor rule underwent several years of legal uncertainty. It wasn’t until 2014 that the U.S. Supreme Court said EPA was on solid ground in issuance of Cross-State rule. “There is no more chance that this rule might be thrown out,” but it might be modified, Weilert said.

During the years of legal challenges, many SO2 scrubbers were installed at coal plants in the affected states. Between 2008 and 2011, there was also a big jump in the use of natural gas for power generation. This reduced SO2 emissions, Weilert said.

Many Plants Will Use Screens to Prevent Fish Intake

In addition to air emissions, many fossil and non-fossil power plants are looking to comply with the EPA’s 316(b) regulation to prevent intake fish kills.

A “good percentage of plants” will go with option five [mesh water screens] to comply with the rule, said Hydrolox Manager Roman Carter.

“Your plant has to do a two-year entrainment study” to discover what species of fish might currently be drawn into the plant’s equipment, he continued.

“The reason you have an intake screen to begin with is to protect your plantfrom debris,” Carter said. Companies don’t want a lot of dead fish going into their plant intake.

Diver inspections, chain failures and crashes, and rebuilds are compliance-related financial impacts from 316(b), he said.

Many Coal Ash Ponds Are Expected to Close

The recently issued final EPA Coal Combustion Residue (CCR) rule and the Effluent Limit Guidelines (ELG) rules are related, Andrews said. “Basically, a lot of ponds are going to close.”

Post-closure plans for coal ash ponds are due in October 2016, and ELG compliance is required as soon as November 2018, Andrews said. States can enact more stringent coal residue rules than the EPA.

Alternative closure schedules for ash ponds require a lot. “This is a pretty hard lift, particularly from a legal perspective,” said attorney Jay Holloway. Plants could see dramatic increase in costs, especially if they must start “trucking ash down the road,” he said.

Cemtek Environmental’s Gary Cacciatore discussed monitoring equipment for coal-fired plants where hydrogen chloride (HCl) has to be measured.

HCl is a surrogate for all the toxic acid gases at most of the coal- and oil-fired plants that will have to meet Mercury Air Toxics Standards (MATS).

A lot of coals have high-chlorine content. This can cause corrosion, boiler tube leaks and other problems, Cacciatore said.

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