Georgia Power, in a quarterly update filed Dec. 1, told the Georgia Public Service Commission that it has completed or largely completed a number of emissions retrofits and coal-to-gas conversions that the commission had approved as part of the Southern Co. (NYSE: SO) subsidiary’s 2013 Integrated Resource Plan (IRP).
These projects are being implemented under a federal Mercury and Air Toxics Standards (MATS) environmental compliance strategy at Plant Bowen Units 1-4, Plant Gaston Units 1-4, Plant Hammond Units 1-4, Plant McIntosh Unit 1, Plant Scherer Units 1-3, Plant Wansley Units 1 and 2, and Plant Yates Units 6 and 7. The projects are:
- Baghouses – Plant Bowen Units 3 and 4;
- Activated Carbon Injection (ACI) and Alkali Sorbent Injection (ALK) – Plant Bowen Units 1-4, Plant Hammond Units 1-4, Plant Wansley Units 1 and 2;
- ACI and Dry Sorbent Injection (DSI) – Plant McIntosh Unit 1;
- Bromide Systems – Plant Scherer Units 1-3; and
- Coal-to-gas switch – Plant Gaston Units 1-4, Plant Yates Units 6 and 7.
Additionally, the compliance strategy involves installation of the support facilities, landfill work, and equipment necessary to operate the control systems or comply with MATS. These systems include natural gas piping and other systems, emissions monitoring equipment, control systems, and auxiliary equipment.
A summary of work performed since the last quarterly report is:
- Plant Bowen Units 1 and 2 – The Units 1 and 2 ALK and ACI systems have been placed in service. The Units 1 and 2 precipitator work is complete. Mercury Re-emission Control (MRC) system foundations are underway.
- Plant Bowen Units 3 and 4 – Concrete foundations are being installed. Installation of duct support steel and duct sections for the Unit 4 baghouse tie-in is underway. Installation of baghouse dampers and other components continues on Unit 3. Baghouse piping and electrical work is underway. The Unit 3 ALK system is complete. Work continues on the Units 3 and 4 ACI systems and the Unit 4 ALK system.
- Plant Gaston Units 1-4 – Unit 4 is operational on gas or coal as of July 8, 2015. Gas conditioning station is complete. Units 1 and 2 are currently in their tie-in outages; Unit 3 outage began in October.
- Plant Hammond Units 1-4 – The Units 1-4 ACI and ALK systems have been placed in service. Precipitator work for Units 1-4 is complete. Work continues on the lining of the existing landfill cell.
- Plant McIntosh Unit 1 – Work on the ACI and DSI systems is complete. Precipitator refurbishment work is complete. Work on the new landfill continues.
- Plant Scherer Units 1-3 – Engineering studies continue for bromide injection.
- Plant Wansley Units 1 and 2 – The Units 1 and 2 ACI and ALK systems are in service. The Units 1 and 2 precipitator refurbishment is complete. MRC system foundations are underway.
- Plant Yates Units 6 and 7 – The switch to natural gas at both units is complete. Unit 7 was placed into commercial operation on natural gas on May 4, 2015, and Unit 6 was placed into commercial operation on natural gas on June 27, 2015.
In its Nov. 5 quarterly Form 10-Q filing with the SEC, Southern Co. said about unit retirements at Georgia Power, which weren’t covered in the update filed at the PSC: “To comply with the April 16, 2015 effective date of the MATS rule, Plant Branch Units 1, 3, and 4 (1,266 MWs), Plant Yates Units 1 through 5 (579 MWs), and Plant McManus Units 1 and 2 (122 MWs) were retired on April 15, 2015. In addition, operations were discontinued at Plant Mitchell Unit 3 (155 MWs) and its decertification will be requested in connection with the triennial Integrated Resource Plan in 2016. The switch to natural gas as the primary fuel is complete at Plant Yates Units 7 and 6 and the units were returned to service on May 4, 2015 and June 27, 2015, respectively. On October 13, 2015, Plant Kraft Units 1 through 4 (316 MWs) were retired.”
As far as the MATS rule itself, Georgia Power noted in the Dec. 1 update that on Sept. 24 of this year, a coalition of 21 states, the U.S. Environmental Protection Agency and other participants in MATS litigation submitted motions to the D.C. Circuit Court on how the court should proceed in light of the June 29 U.S. Supreme Court decision finding that EPA failed to appropriately consider costs when it regulated hazardous air pollutants from utilities under MATS. In their motion, EPA asked the court to leave the MATS rule in place as it considers costs, while the states and industry groups asked the court to vacate the rule, claiming that EPA’s failure to consider costs should make the rule invalid. Participants involved in the litigation filed responses to the motions on Nov. 4. In the meantime, the MATS rule is still in effect.
In response to that adverse U.S. Supreme Court decision from this past June, EPA published in the Dec. 1 Federal Register a proposed finding that takes into account costs to comply with MATS. With this notice, the EPA is soliciting comment on a proposed supplemental finding that consideration of cost does not alter the agency’s previous conclusion that it is appropriate and necessary to regulate coal- and oil-fired electric utility steam generating units under section 112 of the Clean Air Act.