Via The Daily Tribune:

This summer, the Environmental Protection Agency is due to issue final rules on its Clean Power Plan and carbon pollution standards for new, modified and reconstructed power plants.

The plan has sparked protests from AEP/SWEPCO and other utility companies from across the country, who contend that the EPA is operating in the dark proposing this plan.

“The investment of billions of dollars in these plants to meet other EPA requirements over the past decade would be prematurely lost,” SWEPCO reported to EPA in summary statements on the plan, and cited that the plan would result in “SWEPCO’s system reliability and $900 million investment in current retrofit projects at four plants (including the Welsh plant located in Cason, Titus County) to be prematurely lost.”

The EPA has cited carbon pollution from existing power plants as the single largest source of carbon pollution in the United States.

According to the EPA, power plants account for roughly one-third of all domestic greenhouse gas emissions in the U.S.

When the EPA proposed the Clean Power Plan last June, the statement was issued with the plan that, while there are limits in place for the level of arsenic, mercury, sulfur dioxide, nitrogen oxides and particle pollution that power plants can emit, there have been no national limits on carbon

pollution levels.

By 2030, according to the EPA plan, the Clean Power Plan’s compliance measures should result in a reduction of carbon emission from the power sector by 30 percent nationwide, below 2005 levels; cut particle pollution, nitrogen oxides and sulfur dioxide by more than 25 percent,  and shrink electricity bills roughly 8 percent by increasing energy efficiency and reducing demand in the electricity system.

By 2030, according to EPA, the measures will “avoid up to 6,600 premature deaths, up to 150,000 asthma attacks in children and up to 490,000 missed work or school days – providing up to $93 billion in climate and public health benefits.” 

The summer of 2016, EPA has set as the due date for states to submit compliance plans to EPA with extension requests. Next summer the EPA has stated the agency will be in a position to issue a final federal plan for meeting Clean Power Plan goals in areas that do not submit plans.

This coming July, EPA is scheduled to issue final rules on the Clean Power Plan for existing power plants and for new, modified and reconstructed power plants; and propose a federal plan for meeting the Clean Power Plan goals for public review and comment.

According to the EPA website, the Clean Air Act Section 111(d) of the Clean Power Plan for existing power plants was proposed by EPA June 2, 2014:  for reduction of carbon dioxide emissions from existing power plants with a goal of 30 percent reduced emissions by 2030.

By the time the agency’s extended comment period on this proposal ended, Dec. 1, 2014, EPA reports receiving more than 2 million public comments. 

American Electric Power and Southwestern Electric Power companies report they are participating fully in the federal and state processes to protect customers and reliability of the electric grid. 

But SWEPCO urged its stakeholders to ask EPA to “reconsider and modify its unrealistic assumptions; extend its schedule to allow a reasonable opportunity for compliance and allow flexibility for continued operation of base load generation as needed to support reliability.”

“SWEPCO, AEP and many other utilities across the U.S. have submitted thousands of pages of comments on 111(d).  Hopefully the EPA will be reasonable and relax the unrealistic deadlines to meet the plan as written now, which call for our Welsh and Pirkey plants to close by 2020,” AEP/SWEPCO spokesman Scott McCloud said.  

AEP submitted 400 pages of comments to the EPA on the plan, he said.

Some 5,200 Welsh Power Plant employees, contractors, retirees and customers sent comments to EPA by their comment deadline at years-end 2014, protesting the EPA demands on the plant, the timetable and financial investments required, according to McCloud.

The AEP/SWEPCO Welsh Power Plant, located in Cason, is a base loaded, coal-fueled power plant that generates 28 percent of SWEPCO’s capacity with a net value of $247 million for all three units, according to AEP/SWEPCO reports. 

The plant reportedly burns low-sulfur coal from Powder River Basin, Wyo., shipped by rail; reports 133 employees and an annual payroll of $9 million, annual property taxes of $4.147 million.

“At Welsh, EPA’s Clean Power Plant and carbon pollution standard requirements will affect some 133 SWEPCO employees with layoffs, with additional employment effect to local contractors, and impact the $4.125 million in local taxes, including $2.6 million for Daingerfield-Lone Star ISD and $235,000 to Northeast Texas Community College; and $278,000 in Texas state taxes the plant currently pays,” McCloud said.

“To comply with the stringent new U.S. Environmental Protection Agency regulations, AEP/SWEPCO is investing $411 million to install additional environmental controls at Units 1 and 3 of the coal-fueled Welsh Power Plant,” according to McCloud.

“The generating capacity of each unit is 528 megawatts. Unit 2 is scheduled for retirement by April 2016,” he said.

McCloud listed AEP/SWEPCO’s primary concerns regarding the proposed carbon dioxide emissions reduction plan center on the EPA’s proposed demands as “being too high.” 

“The rule requires emissions rate reductions of 45 percent in Arkansas, 40 percent in Louisiana and 39 percent in Texas, much higher than EPA’s nationwide goal of 30 percent by 2030. The EPA’s analysis reveals a severe impact,” he said.

According to the impact summary statement AEP/SWEPCO submitted to the EPA, “SWEPCO is currently investing $900 million in environmental retrofit projects to comply with existing EPA regulations by 2015-2016. The projects are necessary to keep the lights on across SWEPCO’s system. EPA’s proposed rule places those protects and system reliability at risk.”

“Across the nation, EPAs aggressive compliance time line is projected to force the retirement of massive amounts of generation capacity in less than five years. The time line will not allow adequate time for the planning, siting, permitting and construction required for replacement generation and transmission,” according to the summary statement.

Ultimate increases in the price of electricity from the higher costs replacement generation and transmission needed to maintain reliability, were cited in the summary statement.

“EPA’s ‘building blocks’ are plagues with problems that set unrealistic targets for power plant operations, renewable energy expansion and customer energy-efficiency increases,” according to the statement.

The summary states the proposed rule “reaches far ‘outside the fence’ of power plant operations, seeking to control resource mix and electrical usage because carbon dioxide controls at the power plant level are not available.”

Included in the SWEPCO arguments are statements that the ramping up of customers’ energy efficiency levels 1.5 percent annually are unrealistic considering that the most cost-effective efficiency improvement –  lighting – is already occurring through newly-adopted federal lighting standards.

“EPA’s analysis predicts that 46,000 to 49,000 megawatts of coal-fueled generation will be shut down no later than 2020 as a result of this proposal – in addition to more than 60,000 that will already retire this decade. That means about one-third of all existing coal-fueled power plants, enough generation to power 60 million homes, would be gone in just five years. The EPA estimates that most of these combined retirements (about 110,000 megawatts) will occur by 2016,” SWEPCO has stated.

“For SWEPCO, EPA assumes that 2,200 megawatts of 24/7 base load generation (Pirkey and Welsh Units 1, 2 and 3) are shut down by 2020, and another 1,000 megawatts (Turk, Flint Creek and Dolet Hills) will run less because they will be dispatched according to EPA’s new priority for natural gas combined cycle plants,” SWEPCO reported to EPA.

“Closing this much generation in such a short time frame raises serious concerns about the ability to maintain reliability and meet peak demand, particularly in periods of extreme weather – across the nation and especially at SWEPCO,” the SWEPCO report summary to EPA states.

Another retrofit project underway at Welsh is driven by the EPA’s new Mercury and Air Toxics Standards rule, McCloud said. 

“Construction and modification efforts are well underway at Welsh to meet EPA compliance for MATS by April 2016,” he said.

That technology consists of activated carbon injection to reduce mercury emissions and pulse jet fabric filter (commonly called baghouse) to capture carbon and mercury, according to McCloud, and that project includes a new 531-foot-tall stack. 

See the article here.