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Presented by: Michelle Golden, Principal Environmental Engineer
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Prairie State Energy Campus, IL, USA
38°16'18"N | 89°40'34"W
Communicating Environmental Regulations: It's Good Business
Michelle Golden, Principal
Environmental Engineer
October 25, 2013
CIVIL GOVERNMENT SERVICESMINING & METALSOIL, GAS & CHEMICALS POWER
Overview
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The US has been and continues to be in a very active period of environmental regulatory change, particularly with respect to energy production.
These regulatory changes impact the short and long-term business strategies of power companies.
Today’s presentation is designed to give you brief highlights of regulations affecting the Power Industry, touch on why this matters to Bechtel Power Corporation and offer tips regarding effective communication of complex topics such as these to business managers.
Regulations Affecting the Power Sector
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1/30/20124
5/25/115
Possible Timeline for Environmental Regulatory Requirements for the Utility Industry
Regulations Affecting the Power Sector
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Air: Transport (CSAPR/CAIR) Ambient Air Quality Standards (NAAQS) Mercury and Air Toxics (MATS) a.k.a. Utility MACT MACT for Industrial Boilers
Climate Greenhouse Gas New Source Performance Standards,
Water: Cooling Water Intakes (Section 316(b)) Steam Electric Effluent Guideline (ELG)
Waste Coal Combustion Residuals (CCR)
Air – Uncertainty is the Status Quo
In 2013, EPA will focus on implementing and defending the suite of air regulations promulgated over last 4 years.
Rule Final
CSAPR July 2011 Vacated – Aug 2012US Supreme Court Review underway
MATS April 2012 Appealed, briefings through spring
MATS – New EGU Reconsideration
March 2013 Timing critical due to GHG NSPS
NAAQS – PM 2.5 Jan 2013 May drive transport rule requirements.
NAAQS – Ozone Feb 2014
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Air Transport : Litigation = Uncertainty
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Clean Air Interstate Rule (CAIR)
– Final regulations published March 2005– Challenged and remanded without vacature July 2008
Cross State Air Pollution Rule (CSAPR)
– Transport Rule to replace CAIR, final July 2011 – Numerous petitions for review and request for stay filed (Consolidated case: EME Homer
City v. EPA)– Court ordered stay 12/29/11, CAIR remains in effect.– CSAPR Vacated August 2012 – Decision 2-1 – EPA requested re-hearing by full panel of 9 judges, re-hearing denied January 24, 2013– EPA petitioned US Supreme Court , granted petition June 2013
What does this mean for the Power industry?
– Ongoing uncertainty – Uncoordinated Air Quality Control System (AQCS) planning/design/schedule
Climate: Greenhouse Gas Regulation
Mandatory Reporting Rules (MRR) – Sept 2009
Endangerment Finding – December 2009
Mobile Source Rule – April 2010
Tailoring Rule – May 2010
GHG Permitting (PSD/BACT & Title V) Guidance – Nov. 2010
Carbon Capture Sequestration Underground Injection Rule – Dec 2010
New Source Performance Standards for Power Plants
– New plants regulations re-proposed September 2013, final rule projected to be published June 2014
– Existing plants proposed rule projected for June 2014
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EPA moving ahead with regulations multiple fronts:
Water Regulations
Steam Electric Power Generating proposed Effluent Limitation Guidelines (ELG)
•Last updated 1982, EPA proposed rule issued June 2013
•Existing ELG retained but standards added for waste streams from AQCS
•Environmental groups pushing EPA to require zero liquid discharge (ZLD); cited by EPA as available technology.
•Final Rule projected May 2014
What are the implications for the Power industry?
•New water treatment facility requirements
•Additional considerations for AQCS retrofits
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Water Regulations
Cooling Water Intake (316(b)) Regulations
Phase I – Final 2001 (new intakes)
Phase II/III addresses existing power plants, other types of facilities.
•Rule proposed March 2011
•Settlement agreement required final rule by July 2013;
•However EPA obtained approval of an extension that requires final rule publication by November 2013
States have been addressing in NPDES renewals
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Waste: Coal Ash
Coal Combustion Residuals (CCR)
Reconsideration driven by TVA impoundment failure (Kingston, TN Dec 2008)
EPA proposed rule (June 2010) sought comments on two approaches
Subtitle C Hazardous Waste Subtitle D Solid Waste
EPA not projecting when this will be finalized, studying impacts of beneficial use
Bills have been floated in Congress to mandate regulation by the States and ban EPA from regulating coal ash.
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Strategic Implications for Power Companies
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Power Industry Challenges
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Proper planning means that utilities and merchant power companies cannot plan for one rule at a time but rather take a comprehensive view to:
Minimize economic impacts to shareholders and consumers
Continue environmental improvements
Maintain system reliability
Maintain fuel diversity options
Obtain access to capital and/or cost recovery
Negotiate myriad political landscapes
Complex, intertwined regulations in place or pending present barriers to new generating units (particularly coal-fired and possibly gas-fired) and require decisions to be made to retrofit or retire existing units.
Communicating Complex Messages to Business Leaders
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Getting the Message Out
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Costs associated with these regulations affect customer decisions to retrofit/retire/replace existing generation.
Senior Management awareness is critical for meeting customer needs and strategic planning.
Challenges:
•Honing the message
•Securing the audience
•Delivering the message effectively
Getting the Message Out
Refining the Message:
– Assess what you think business leaders need to know and why– Prepare your “elevator speech”
Getting the opportunity:
– Target the managers who have the most to gain from the message– Be prepared to be flexible about your delivery
Effective presentation:
– Limit the technical details to those that matter to the mission / business– Make your best effort to assess impact / benefit – Be prepared to get into details if necessary– Be confident!
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