Released October 22, 2014 | SUGAR LAND
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Researched by Industrial Info Resources (Sugar Land, Texas)--This is part two of Industrial Info's series looking at the regulatory picture for the U.S. Power Industry. We look at the effluent limitations guidelines (ELGs) being proposed by the U.S. Environmental Protection Agency (EPA).
History of ELG
The EPA last updated standards for ELGs for steam power electric generation plants, as required by the Clean Water Act (CWA), in 1982. The ELGs were originally set in 1974. The EPA states that it is required by section 304 of the CWA to periodically review all effluent guidelines to determine whether revisions are warranted. A new proposal, first released in 2013, updates those standards with data the EPA has gathered since the last revision.
The ELG set limits for releases into wastewater streams associated with flue gas desulfurization (FGD) and the by-products of fly ash, bottom ash, flue gas mercury control, and gasification of fuels like coal and petroleum coke. The materials in these releases include arsenic, mercury, lead, boron, cadmium, selenium, chromium, nickel, thallium, vanadium, zinc, nitrogen, chlorides, bromides, iron, copper and aluminum.
New ELG Proposal
The proposed rule would establish new or additional requirements for releases into wastewater streams associated with FGD and the by-products noted above. According to the EPA: "Fewer than half of coal-fired power plants are estimated to incur costs under any of the proposed standards, because most power plants already have the technology and procedures in place to meet the proposed pollution control standards. For example, over 80% of coal plants already have dry handling systems for fly ash that avoid wastewater discharge."
The new ELG amendment primarily impacts coal-fired power plants with a generating capacity greater than 50 megawatts, as well as integrated gasification combined cycle (IGCC) facilities. Under the proposed rule, FGD wastewater, IGCC wastewater and coal combustion residuals (CCR) impoundment/landfill leachate would no longer be defined as low-volume waste. In addition, the merging of wastewater streams prior to discharge for the purpose of dilution would not be permitted.
Further complicating the picture, the EPA is proposing multiple solutions to be implemented by power producers. Each of these solutions involves revisions under best available technology economically achievable (BAT), new source performance standards (NSPS), pretreatment standards for existing sources (PSES) and pretreatment standards for new sources (PSNS).
Power producers would have a choice of solutions that would vary in cost, according to the EPA, from $185 million and $954 million. These cost estimates have been questioned, however. The Electric Power Research Institute estimates that the actual cost for bottom ash handling, for example "is approximately two times higher than the estimate used in the proposed rule."
Final Rulemaking Almost One Year Away
The final rulemaking for revisions to the ELG related to the electricity generation sector is expected by September 30, 2015, but there have been multiple delays already, so this date is not certain. Implementation of the proposed ELG is planned for July 1, 2017, and the timeline calls for plant permits to be updated within five years of the implementation date, or by July 1, 2022.
The large volume of public comments that have been received in response to the proposed rule is part of the reason the EPA has extended its deadline to publish the final proposal. (It was supposed to be published in June of this year.) The EPA has acknowledged that existing power plants will need time to study available solutions, and thus the EPA expects plants to be compliant with the new limits by 2022.
The EPA also has admitted that there is a need for coordination between the Coal Combustion Residual (CCR) Rule and the ELG, because many of the treatment options or controls overlap. The primary overlap stems from the Resource Conservation and Recovery Act (RCRA). The EPA's current thinking on CCR disposal, based on data collected to support the new ELG rule, is that CCR should be regulated under RCRA Subtitle D as nonhazardous waste, rather than under RCRA Subtitle C as a hazardous waste. This is a significant difference in cost and complexity.
Final resolution of this new EPA initiative may be further delayed, since both the power industry and environmental groups are unhappy with the current proposal.
For additional information, see October 21, 2014, article - U.S. Power Industry's Regulatory Future, Part One: Clean Power Plan, Coal Combustion Residuals Stir Legal Fights.
Industrial Info Resources (IIR), with global headquarters in Sugar Land, Texas, three offices in North America and 10 international offices, is the leading provider of global market intelligence specializing in the industrial process, heavy manufacturing and energy markets. Industrial Info's quality-assurance philosophy, the Living Forward Reporting Principle, provides up-to-the-minute intelligence on what's happening now, while constantly keeping track of future opportunities.
History of ELG
The EPA last updated standards for ELGs for steam power electric generation plants, as required by the Clean Water Act (CWA), in 1982. The ELGs were originally set in 1974. The EPA states that it is required by section 304 of the CWA to periodically review all effluent guidelines to determine whether revisions are warranted. A new proposal, first released in 2013, updates those standards with data the EPA has gathered since the last revision.
The ELG set limits for releases into wastewater streams associated with flue gas desulfurization (FGD) and the by-products of fly ash, bottom ash, flue gas mercury control, and gasification of fuels like coal and petroleum coke. The materials in these releases include arsenic, mercury, lead, boron, cadmium, selenium, chromium, nickel, thallium, vanadium, zinc, nitrogen, chlorides, bromides, iron, copper and aluminum.
New ELG Proposal
The proposed rule would establish new or additional requirements for releases into wastewater streams associated with FGD and the by-products noted above. According to the EPA: "Fewer than half of coal-fired power plants are estimated to incur costs under any of the proposed standards, because most power plants already have the technology and procedures in place to meet the proposed pollution control standards. For example, over 80% of coal plants already have dry handling systems for fly ash that avoid wastewater discharge."
The new ELG amendment primarily impacts coal-fired power plants with a generating capacity greater than 50 megawatts, as well as integrated gasification combined cycle (IGCC) facilities. Under the proposed rule, FGD wastewater, IGCC wastewater and coal combustion residuals (CCR) impoundment/landfill leachate would no longer be defined as low-volume waste. In addition, the merging of wastewater streams prior to discharge for the purpose of dilution would not be permitted.
Further complicating the picture, the EPA is proposing multiple solutions to be implemented by power producers. Each of these solutions involves revisions under best available technology economically achievable (BAT), new source performance standards (NSPS), pretreatment standards for existing sources (PSES) and pretreatment standards for new sources (PSNS).
Power producers would have a choice of solutions that would vary in cost, according to the EPA, from $185 million and $954 million. These cost estimates have been questioned, however. The Electric Power Research Institute estimates that the actual cost for bottom ash handling, for example "is approximately two times higher than the estimate used in the proposed rule."
Final Rulemaking Almost One Year Away
The final rulemaking for revisions to the ELG related to the electricity generation sector is expected by September 30, 2015, but there have been multiple delays already, so this date is not certain. Implementation of the proposed ELG is planned for July 1, 2017, and the timeline calls for plant permits to be updated within five years of the implementation date, or by July 1, 2022.
The large volume of public comments that have been received in response to the proposed rule is part of the reason the EPA has extended its deadline to publish the final proposal. (It was supposed to be published in June of this year.) The EPA has acknowledged that existing power plants will need time to study available solutions, and thus the EPA expects plants to be compliant with the new limits by 2022.
The EPA also has admitted that there is a need for coordination between the Coal Combustion Residual (CCR) Rule and the ELG, because many of the treatment options or controls overlap. The primary overlap stems from the Resource Conservation and Recovery Act (RCRA). The EPA's current thinking on CCR disposal, based on data collected to support the new ELG rule, is that CCR should be regulated under RCRA Subtitle D as nonhazardous waste, rather than under RCRA Subtitle C as a hazardous waste. This is a significant difference in cost and complexity.
Final resolution of this new EPA initiative may be further delayed, since both the power industry and environmental groups are unhappy with the current proposal.
For additional information, see October 21, 2014, article - U.S. Power Industry's Regulatory Future, Part One: Clean Power Plan, Coal Combustion Residuals Stir Legal Fights.
Industrial Info Resources (IIR), with global headquarters in Sugar Land, Texas, three offices in North America and 10 international offices, is the leading provider of global market intelligence specializing in the industrial process, heavy manufacturing and energy markets. Industrial Info's quality-assurance philosophy, the Living Forward Reporting Principle, provides up-to-the-minute intelligence on what's happening now, while constantly keeping track of future opportunities.
