Author: admin_cams

The United States Environmental Protection Agency (EPA) has been busy. Since late August, the EPA published two final rules relating to coal combustion residuals (CCR), one final rule relating to wastewater discharge from coal-fired power plants with emission controls and proposed a significant rewrite to the Cross-State Air Pollution Rule (CSAPR).

These rules have significant implications for coal-fired power plants’ future operations, and the CSAPR update will affect all power plants in 12 states in the eastern United States. CAMS operates three coal-fired power plants – Gavin Station in Ohio and Conemaugh and Keystone Stations in Pennsylvania. A summary of each rule and its implications follows.

COAL COMBUSTION RESIDUALS PART A AND PART B

In response to the catastrophic TVA Kingston coal ash release in December 2008, EPA passed a series of en­hanced regulations to regulate the storage and dis­posal of coal combustion residuals (CCR) or coal ash. EPA published the Disposal of CCR rule in April 2015. This rule addresses groundwater protection from leaking contaminants, blowing of materials into the air as dust, and catastrophic failure of coal ash surface impoundments. There is also a requirement to post specific information about coal-fired power plant CCR programs on public websites. Under the CCR rule, the design of ponds used to store coal ash must meet particular groundwater protection standards or be removed from service and closed. Clay lined im­poundments were previously permissible if ground­water monitoring did not detect a release. However, a 2018 court decision requires all active ponds to meet the rule’s liner requirements. In 2019, EPA proposed “A Holistic Approach to Closure,” Parts A and B, which outlines requirements for maintaining, closing, and replacing “unlined” ponds.

Part A specifies timelines for the development of al­ternative pond capacity and the use of unlined ponds. Under Part A, unlined ponds may not receive any coal ash after April 11, 2021, unless they receive an exten­sion from EPA or the state agency. Extensions are available if a plant develops another method for stor­ing CCR material (i.e., installing new ponds, retrofit­ting liners to existing ponds, removing waste streams) or a plant commits to the permanent closure of the coal-fired units. In essence, almost every coal-fired power plant must have lined CCR ponds that meeting EPA standards between 04/21 and 10/23 or commit to the retirement of the coal-fired boilers. Extension applications are required to be filed by November 30, 2020. Gavin’s Part A demonstration was filed Octo­ber 19, 2020, and Conemaugh’s was filed the week of November 16. Keystone already has concrete-lined ponds that meet the requirements of the CCR Rule.

Part B offers a potential alternative for CCR ponds con­sidered “unlined” but provides an equivalent ground­water protection level. For such facilities, Part B de­fines a process through which a facility may make an “alternate liner demonstration,” which, if successful, would allow those ponds to continue to operate with­out modification. Conemaugh’s ash filter ponds are lined with engineered synthetic clay liners that offer groundwater protection equivalent to or better than the standards the EPA sets forth in the CCR rule. An application to proceed with an alternate liner demon­stration is due by November 30. Conemaugh’s appli­cation will be filed the week of November 16.

EFFLUENT LIMITATION GUIDELINES FOR POWER PLANT WASTEWATER

On October 13, 2020, EPA finalized the revised Effluent Limitation Guidelines (ELG) for Steam Electric Pow­er Plants Rule. This regulation affects power plants that discharge bottom ash (BA) transport water or wastewater from flue gas desulfurization (FGD). The ELG rules potentially affect Keystone, Conemaugh, and Gavin stations. The ELG rule requires BA and FGD wastewaters’ compliance as soon as possible, but no later than 12/31/2025. There is an alternate compliance option of ceasing the plants’ operation by 12/31/2028 and meeting more stringent FGD limits by 12/31/2028. The most significant limitations in the FGD rule relate to mercury, selenium, arsenic, and nitrate/nitrite dis­charge. Compliance with the BA rule may be accom­plished through the revision of a plant’s water bal­ance. All three stations are currently evaluating their compliance options.

CROSS-STATE AIR POLLUTION RULE REVISED UPDATE

The Cross-State Air Pollution Rule (CSAPR) requires power plants in 23 eastern states to reduce sulfur di­oxide (SO2) and nitrogen oxides (NOx) to improve air quality through a “cap and trade” program. There are three programs in CSAPR, for which allowances are accounted and traded independently – SO2, annual NOx, and Ozone Season (May-September) NOx. Every ton of NOx emitted during the summer from an af­fected plant requires the surrender of two allowances: an ozone season NOx allowance and an annual NOx allowance. The cost of these allowances impact pow­er plant operating economics.

On October 30, 2020, the EPA proposed a significant update to CSAPR, reducing the number of Ozone Sea­son NOx allowances available for power plants in 12 states by 55% beginning in 2021. The impacted states are Illinois, Indiana, Kentucky, Louisiana, Maryland, Michigan, New Jersey, New York, Ohio, Pennsylvania, Virginia, and West Virginia. These states will belong to a new trading group, with allowance trading re­stricted to the same group sources. This change is not expected to impact compliance for any of the plants CAMS operates. However, it will affect compliance costs. The restriction on the number of allowances available and the market size restriction are both ex­pected to impact allowance prices. These changes in allowance prices could have a discernible impact on coal-fired power plants’ cost of operation, in addition to the ELG and CCR rules noted above.

Please contact CAMS’ Environmental Services De­partment if you have questions about any of the above regulations or other EPA rulemaking

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By David Harsell

As part of an effort to keep pace with the ever-changing technology of the oil industry, the BLM issued new Federal Onshore Orders in Jan 2017. These new regulations affected numerous topics including administration, reporting, operations, site security, and oil and gas measurement on Federal leases. Many of the significant portions of these regulations included implementation dates that were being phased-in to allow the industry adequate time to comply with their requirements and the BLM to create the necessary procedures and software for proper administration.

Because of the complexity of Onshore Order 3173 Requirements for Site Security and Production Handling, the BLM placed a temporary hold on implementing certain aspects of this regulation so that it could be re-written to provide more clarity to the industry’s operators. The new re-written Onshore Order 3173 is planned to be released to the public in the next several weeks and will be posted for 60 days to allow operators to review the requirements and provide comments. The re-write should address common issues/concerns with flowback equipment, commingling, allocation meters, bypasses, and Facility Measurement Points (FMPs). The BLM highly recommends and encourages operators to read the proposed re-write and submit comments as available on the Federal Register website.

Applications for the assignment of FMPs are still on hold until several development stages are completed after the introduction of the AFMSS 2 WISx system which will replace the Well Information System (WIS). The introduction of WISx will not happen until mid-March and the FMP reporting module will not be available until late 2020.

CAMS in-house technical staff is familiar with the requirements of the new Federal Onshore Orders and has experience working with the BLM to resolve compliance problems. As your operations encounter issues with understanding or complying with these new regulations, you should consider contacting CAMS to conduct a survey of your overall compliance level or assist in addressing problems. CAMS can be reached by sending an email or calling 713-380-4719.

This article is written by David Harsell, a CAMS senior engineering advisor, with over 45 yrs of industry engineering, facilities and operating experience working with the BLM.