Dayton looks at issues for CSAPR and MATS compliance

Dayton Power and Light, a unit of AES Corp. (NYSE: AES), is pursuing various options, including the possible co-firing of biomass with coal, to reduce its CO2 emissions in the future, the company said in an updated environmental compliance plan filed April 13 at the Public Utilities Commission of Ohio.

Each of DP&L’s electric generating units (other than a solar facility) combusts fossil fuels and thus emits CO2. Currently, the DP&L share of CO2 emissions from these facilities is about 16 million tons per year. There are currently no Ohio or federal regulations requiring reductions in CO2 or other greenhouse gas emissions for existing sources. However, DP&L said it is closely following many aspects of this broad issue and is currently implementing certain programs and taking actions that will have positive effects on the amount of emissions relative to electric service requirements of customers.

DP&L engaged in test burns during 2009 and 2010 regarding the feasibility of co-firing coal-fired units with biomass. DP&L has since obtained from the Ohio Environmental Protection Agency air permits to install (PTIs) to transport, handle, store and combust clean cellulosic biomass at the Killen plant. DP&L has also obtained an air PTI authorizing the use of biodiesel fuel in oil-fired units at Killen.

DP&L said it continues to successfully operate a 1.1 MW solar array that became operational in March 2010.

DP&L has implemented extensive energy efficiency and demand response programs that will reduce the demand for electricity and should therefore over time, reduce the level of CO2 and other greenhouse gas emissions per customer served.

DP&L said that it is an active member of the Electric Power Research Institute (EPRI) and participates in river studies, renewable energy research and cost-effective approaches for reducing NOx, SO2 and mercury emissions.

The U.S. EPA has released the Utility Maximum Achievable Control Technology (MACT) rule, also known as the Mercury and Air Toxics Standards (MATS), for coal- and oil-fired electric generating units. The final rule had an effective date of April 16.

The final MACT/MATS standard regulates the emissions of mercury, certain non-mercury metallic toxic pollutants, acid gases, and organic air toxics including dioxin. DP&L has until April 16, 2015, to come into compliance with the new requirements, with the option to request an additional year, if required for construction. DP&L said it is reviewing the final regulations to determine the impact of the standards on existing plants. “We believe that the Stuart and Killen stations will be able to meet the final limits,” the utility reported. “The requirements imposed on Beckjord Unit 6 and Hutchings Station are very costly.”

In 2011, the U.S. EPA finalized a multi-state trading program called the Cross-State Air Pollution Rule (CSAPR) that lowered the “caps” on SO2 and NOx emissions in Ohio. In December of 2011, this new rule was stayed by a federal appeals court. The court has left in place in the meantime the older Clean Air Interstate Rule (CAIR), which is the SO2 and NOx trading program under which DP&L operates in 2012. Some observers predict that 2013 will be the first year of the CSAPR program. “DP&L is prepared to operate under either trading program,” the utility noted.

Fortunately, DP&L said it has invested heavily in modern air pollution control systems. The selective catalytic reduction (SCR) and flue gas desulfurization (FGD) systems at the Stuart and Killen stations are well suited for future NOx and SO2 obligations. DP&L anticipates that the FGD in conjunction with SCR operation will likely meet the mercury, toxic metals, and acid gas removal obligations found in the MATS rule without the installation of additional control technology.

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.