The Environmental Protection Agency (EPA) has a number of proposed regulations; however, two in particular will present significant R&D opportunities for a number of utilities. With the addition of these two proposed rules, a number of electric generation facilities will be required to perform research to determine the best available technology (BAT) and/or combination of technologies to achieve the regulated requirements for both cooling water intake and mercury emission reductions.
Cooling Water Intake Structures – Clean Water Act §316(b):
The EPA has proposed standards under the Clean Water Act (CWA) to issue regulations to reduce injury and death of fish and other aquatic life caused by cooling water intake structures existing at power plants and factories. These facilities pull in large volumes of cooling water from lakes, rivers, estuaries or oceans to cool their machinery.
Many utilities are currently conducting fish and aquatic studies; conducting testing of various intake screens designs; and testing other alternatives in an effort to design the BAT for their plant’s specific site requirements. This testing of alternatives to determine the BAT are generally qualified research activities. Additionally, once a final design is identified, there is often a significant amount of applied research that is conducted to determine the appropriate method and design to retrofit an existing facility with new technologies or combination of technologies. Identifying these areas of spend can provide utilities with several million dollars of R&D benefit.
Controlling Power Plant Emissions – Clean Air Mercury Rule (CAMR):
The EPA is proposing standards to limit mercury, acid gases and other toxic pollution from power plants, keeping 91 percent of the mercury in coal from being released into the air. For all existing and new coal-fired Electric Generation Utilities (EGUs), the proposed standards would establish numerical emission limits for mercury, PM (a surrogate for toxic non-mercury metals), and HCl (a surrogate for toxic acid gases), and total metals (HCl and HF).
While there are a number of potential technology options available for use in reducing non-mercury pollutants – such as scrubbers, injection systems, and baghouses. Plants generally undergo significant amounts of applied research to determine how these technologies can be added to the existing generation plant process. Additionally, the control technologies for mercury control are in their infancy which will also require utilities to perform significant research to determine/develop an appropriate solution to meet the regulation requirements. At a minimum for each plant, the owner or operator must conduct performance tests to demonstrate compliance with all applicable emission limits.
New environmental regulation requirements will have a significant impact on utility R&D spending to develop and test technologies and combination of technologies to develop an appropriate design for each utility. The EPA recognizes the significance of site specific issues that drive technology selection and effectiveness and have therefore stipulated in its proposed regulations that each plant will be required to test and demonstrate its solution is capable of meeting the compliance requirements. In effect each plant will be required to perform its own, plant specific research.