As Appalachian coal production continues its drastic decline, West Virginia’s coal-producing counties are not only losing people as lifelong residents are forced to flee their homes in order to find work, but in many cases, they’re also relinquishing millions of dollars from their budgets.
UPDATED to correct original mercury emissions standard for new power plants
When the U.S. Environmental Protection Agency put out its first-ever standards for power plant emissions of mercury and other air toxics in December 2011, the utility industry cried foul.
The Mercury and Air Toxics Standards, or MATS, rule set a limit on emissions of mercury from existing coal-fired power plants at 0.013 pound/gigawatt-hour starting in 2015 — within reach as a co-benefit for plants that already had installed sulfur dioxide emissions controls; prohibitively expensive for smaller, older plants that hadn't.
And for new coal-fired plants, MATS set a limit far more strict, at 0.0002 pound/GWh.
Power producers immediately announced retirements of existing plants and attributed them in part to the mercury standards.
And for new plants, no current technology would allow plant operators even to measure mercury at that level, industry representatives argued in petitions for reconsideration. The agency had misunderstood or misused data it had collected on the mercury removal that the cleanest power plants can achieve, they wrote.
Power producers were joined by the coal industry in concerns about the fuel's future viability for making electricity.
Coal producer James Laurita said at an August 2012 energy forum in Morgantown that even the brand new Longview power plant, for which his operations supply coal and which was named the most efficient coal-fired plant in the U.S. fleet in its start-up year of 2011, would not be able to meet the MATS limit for new plants.
"No new plant would be able to meet the standard," said United Mine Workers of America lawyer Eugene Trisko more broadly at the same forum. "We're not in a position to even consider the inclusion of coal in a future national energy policy."
Fast forward to March 29, when the EPA issued an update based on another look at the data.
The mercury limit for existing plants was not part of the update and remains the same.
But the agency raised the limit for new coal-fired power plants from 0.0002 to 0.003 pound/GWh. That may seem a minuscule difference — and, in fact, the agency anticipates that meeting it will require the same technology at the same cost as the original standard.
But is it a difference that makes a difference?
"We think it does," said Leonard Levin, senior program manager for Air Toxics Health and Risk Assessment at the industry nonprofit Electric Power Research Institute.
What does the response so far of West Virginia's existing power generators to the MATS rule say for the continued viability of coal for power in the state? What does Longview's emissions say about the viability of coal for new plants?
Why regulate mercury
A quick reminder of the reason for all this.
Coal contains mercury. When coal is burned and the mercury is released into the air, it eventually falls to the earth, is washed into streams, may be taken in by fish and further may be eaten by humans, where it can impair brain development in fetuses and children.
The EPA has said the MATS rule will reduce mercury emissions by 90 percent from the baseline year of 2005 to the compliance year of 2015.
It estimated that compliance with the MATS rule as a whole — which covers more than mercury — would cost $9.6 billion a year and have benefits of at least $37 billion beginning in 2016.
Power plant operators that have installed scrubbers or other controls for sulfur dioxide are well positioned to meet the limit for mercury and other toxics.
It's hard to say just how well, because emissions data reported to the EPA's Toxics Release Inventory typically do not come from Continuous Emissions Monitors but are estimated based on formulas.
AEP's Amos, Mitchell and Mountaineer plants are scrubbed, as are FirstEnergy's Ft. Martin, Harrison and Pleasants plants and Dominion's Mount Storm — and the Toxics Release Inventory shows some of these plants meeting the 2015 mercury limit in 2011 and some not.
"In 2011 we did not have actual measurements so we used a very conservative emissions factor," wrote AEP subsidiary Appalachian Power spokesperson Jeri Matheney in an email when asked about Amos's emissions — "conservative" meaning erring on the high side. "When 2012 numbers come out, it will appear that our emissions at Amos will go down because we'll have actual measurements."
The company has said it would shut down its unscrubbed Kammer, Kanawha River and Sporn plants.
Appalachian Power's filings with the state Department of Environmental Protection are not yet complete as to whether the company will need to make changes to meet the MATS rule and whether it will need an available one-year extension, according to Renu Chakrabarty, air toxics coordinator for DEP's Division of Air Quality.
FirstEnergy has asked for and been granted the MATS one-year extension, Chakrabarty said, and so apparently expects that some kind of change may be needed. That can range from running a scrubber differently or changing a coal mix to installing specially designed activated carbon injection equipment.
The company already has powered down its unscrubbed Albright, Rivesville and Willow Island plants.
At Mt. Storm, reported emissions for 2011 were above the coming limit, but, again, were estimated, according to Dominion spokesperson Dan Genest. The company expects only to have to "do some things operationally in the way we run the scrubbers."
That leaves two plants, both relatively small: American Bituminous Power Partners' plant at Grant Town and the Morgantown Energy Associates plant in Morgantown.
These plants are not scrubbed, but the lime injection they use to control sulfur dioxide also helps with mercury, Chakrabarty said. ABPP has applied for the one-year extension, and MEA has not yet indicated what it will do.
Any major work to be done will have to be coordinated very carefully, Chakrabarty said.
"Equipment they put in place to met the new air toxics standards has to work with their existing control suite, so each individual facility has specific considerations that aren't generic," she said.
Beyond that, "they can't just take their plants down whenever they feel like it — they have to schedule outages with (regional grid operator PJM Interconnection) so we don't have brownouts and blackouts. And they're all going after that same pool of specialized workers to put in the types of controls they need — so it's a big logistical issue."
In any case, in West Virginia, it appears that the future viability of coal for power so far remains intact.
Longview as indicator for new plants
When Electric Light and Power magazine named the advanced supercritical pulverized coal-fired Longview the most efficient coal generator for 2011, the plant had only been running a short time.
"Efficient" doesn't necessarily translate to "clean," but it helps: Along with Longview's advanced pollution controls, it's a simple fact that less coal in per megawatt-hour produced means less pollution out.
So how did Longview do in its first full year of operation? That may be some indication of whether the updated mercury standard for new plants is a difference that makes a difference for coal's future.
For 2012, preliminary numbers show that Longview emitted about 15 pounds of mercury for 4,506 gigawatt-hours generated in 2012, according to Longview Power Vice President and General Manager Charles Huguenard.
That comes to about 0.00333 pound/GWh, well below the 2015 limit of 0.013 for existing plants and just a little over the 2015 limit of 0.003 for a new plant — but well over the previous standard of 0.0002 for a new plant.
The emissions controls are designed for full-on operation and don't work as well during start-up and shut-down, Huguenard said.
"If we were running 100 percent of the time around the clock without ever coming off-line, then we would meet (the updated standard for new plants)," he said.
Longview's experience is not proof, but it's an indication that new coal-fired plants could meet the standard.
A legal challenge to the MATS rule in the U.S. Court of Appeals for the D.C. circuit was suspended while the EPA reconsidered the standards, and is now moving forward.
Four power companies more heavily invested in gas and nuclear generation filed April 8 asking that the challenge be thrown out, saying coal-fired utilities that have dragged their feet on installing pollution controls have hurt electricity markets and it's time for a level playing field and regulatory certainty.