Coal Still Viable Despite Mercury Emissions Standard
The State Journal
9 April 2013
By Pam Kasey
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
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 more than six
times more strict, at 0.002 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
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 0.002 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
Still, it is 50 percent higher. Is that a difference that makes a
"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
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
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
"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
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 plants
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
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
"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
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
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
0.002 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 it," 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.