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EPA ESPS for OUC Chip Merriam
Vice President - Legislative, Regulatory & Compliance July 8, 2015
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Emission Changes
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Possible Timeline for Environmental Regulatory Requirements for the Utility Industry
Ozone
PM2.5
'08 '09 '10 '11 '12 '13 '14 '15 '16 ‘20
Beginning CAIR Phase I Seasonal NOx Cap
HAPs MACT proposed
rule
Implement CSAPR Seasonal NOx
Begin CAIR
Phase I Annual
SO2 Cap
Beginning Cross State Air Pollution Rule & NOx Caps
Next PM-2.5 NAAQS Revision
Next Ozone NAAQS Revision
SO2 Primary NAAQS
SO2/NO2 Secondary
NAAQS
NO2 Primary NAAQS
SO2/NO2
New PM-2.5 NAAQS Designations
CAMR & Delisting Rule vacated
Hg/HAPS
Final EPA Nonattainment Designations
PM-2.5 SIPs due (‘06)
Proposed CAIR Replacement Rule Expected
HAPS MACT final rule expected
CAIR Vacated
HAPS MACT Compliance 3 yrs
after final rule
CAIR Remanded
CAIR/ CSAPR
Begin CAIR
Phase I Annual
NOx Cap
PM-2.5 SIPs due (‘97)
316(b) proposed rule expected
316(b) final rule expected
316(b) Compliance 3-4 yrs after final rule Effluent
Guidelines proposed rule
expected
Water
Effluent Guidelines Final rule expected Effluent Guidelines
Compliance 3-5 yrs after final rule Waters of The US final rule
Begin Compliance Requirements under
Final CCB Rule (ground water
monitoring, double monitors, closure,
dry ash conversion) Ash
Proposed Rule for CCBs Management
Final Rule for CCBs Mgmt
Final CAIR Replacement Rule Expected
Compliance with Cross State Air Pollution Rule
CO2
CO2 Regulation
Reconsidered Ozone NAAQS
Clean Power Plan
Revised Ozone NAAQS
-- adapted from Wegman (EPA 2003) Updated 2.15.10
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Of Course, It’s Easy
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Understanding Impacts
• Understanding Central Florida’s Customer Base
• OUC is customer-owned. There are no Stockholders
• Most Reliable Vertically Integrated Utility in the State of Florida
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• Zero stormwater discharge to waters of the United States
• 6% efficiencies already in place. Units come off-line according to EPA’s 2025 Policy Case
• Utilization of landfill gas displacing coal • Two pipelines into Florida • Proposed third pipeline to be constructed by
IOU • Hurricane season realities from the 2004-2006
Hurricane Season
Understanding Impacts (cont.)
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UNDERSTANDING IMPACTS (CONT.)
• Newest of Florida Coal Plants would be retired with stranded costs due to age and improvements to meet Section 112 requirements
• Florida is an island in regard to Transmission • No new Nuclear under construction • 20% Solar Capacity Factor • OUC has no authority to set rules outside our generation
abilities • FDEP will have to seek legislative ratification to set new
rules for Building Blocks 3 & 4 • Results in a 40-45% rate increase for OUC ratepayers
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Overall emission rate change 1,200 lbs CO2/MWh
740 lbs CO2/Mwh
Emission Formula
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2020 Cliff
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Suggestions
• Work with States to Extend the Coal Power Plant dura?on out to each plant’s capital life cycle
• Allow for real construc?on starts and limited labor pool for new construc?on. Possibly use date of plant construc?on to set a priority
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Coal-Burning Power Plant Countdown
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Questions?
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