Environmental Retrofits: Costs and Supply Chain Constraints Presented at MISO Annual Stakeholders Meeting Indiana Presented by Metin Celebi The Brattle Group June 20, 2012 Copyright 2012 The Brattle Group, Inc. www.brattle.com Antitrust/Competition Commercial Damages Environmental Litigation and Regulation Forensic Economics Intellectual Property International Arbitration International Trade Product Liability Regulatory Finance and Accounting Risk Management Securities Tax Utility Regulatory Policy and Ratemaking Valuation Electric Power Financial Institutions Natural Gas Petroleum Pharmaceuticals, Medical Devices, and Biotechnology Telecommunications and Media Transportation
Agenda Emerging EPA regulations Description of the MISO coal fleet Description of environmental retrofit equipment Projected retrofits and retirements Supply-chain constraints for projected retrofits and new generation 2
Emerging EPA Regulations Regulation Status Pollutant Targeted CSAPR Final rule, delayed with court ruling NO x, SO 2 MATS Final HAPs (mercury, acid gases, PM) Compliance Options SCR/SNCR, FGD/DSI, fuel switch, allowance purchases Expected Date of Compliance 2012(?) and 2014 ACI, baghouse, FGD/DSI 2015/2016 316(b) Proposed, revisions likely Cooling water Impingement: Mesh screens; Entrainment: Case-by-case, may include cooling towers 2018 Combustion byproducts (ash) Proposed Ash, control equipment waste Bottom ash dewatering, dry fly ash silos, etc. 2015 Revised Ozone Standard Potential revision in 2013 NO x SCR/SNCR (and allowance purchases under CSAPR)??? 3
U.S. Coal Fleet Coal-fired capacity (316 GW) represents about 1/3 rd of the total generation capacity Majority of coal capacity (237 GW) is owned by regulated companies (IOUs, munis/coops, etc.), and the rest (79 GW) owned by merchant companies Majority (93%) of the coal capacity lacks at least one major piece of equipment (scrubber, SCR and baghouse) to control air emissions 4
Projected Retrofits and Retirements in MISO to Comply with MATS Retrofits: Out of the 71 GW coal fleet, 49-63 GW will likely need to install at least one control GW 80 70 60 50 40 No Need for Controls Need One or More Controls Retirements: Up to 19 GW by 2016, though likely in 3-13 GW range New Gen: Up to 26 GW needed by 2016, likely in 5-14 GW range 30 20 10 Retirements 0 Gas CC Scenario 1 Scenario 2 Scenario 3 Scenario 4 Existing New Existing New Existing New Existing New Coal Fleet Builds Coal Fleet Builds Coal Fleet Builds Coal Fleet Builds No Need for Control 8 7 7 3 Need 1 or More Control 63 61 52 49 Retirement 1 3 12 19 Total 71 71 71 71 Renewable - Wind 2 2 2 2 Coal 2 2 2 2 Gas - CT 0 0 7 17 Gas - CC 0 0 2 5 Other 0 0 0 0 Total 5 5 14 26 Wind Coal Gas CT 5
Required Controls for MISO Coal Fleet 49-63 GW of coal capacity is likely to require at least one control retrofit to comply with MATS. 70 63 57 60 49 26 24 17 41 30 22 50 40 30 17 15 7 1 Range of All Four Scenarios 20 17 11 11 10 7 Required Control Retrofits (GW) 1 2 1 5 2 0 Baghouse Dry FGD Wet FGD DSI ACI ESP SNCR SCR Any Control 1 Control 2 Controls 3 Controls 4 Controls 6
Description of Key Control Equipment Targeted Pollutant Technology Primary Co-benefit Decreasing capital cost Wet/Dry FGD SO 2, acid gases Mercury, particulates SCR NOx Mercury Baghouse Particulates Mercury SNCR NOx DSI SO 2, acid gases Mercury, NOx ACI Mercury 7
Capital Costs of Major Control Equipment Capital costs are significantly more expensive for smaller units. Retrofit costs for major equipment such as wet scrubber and SCR are comparable to cost of a new gas CC at about $1000/kW. CAPITAL COST OF CONTROL EQUIPMENT (2011 $/kw) Unit Size (MW) Equipment 50 200 600 Wet Scrubber 904 734 513 Dry Scrubber 774 628 448 DSI 42 39 39 SCR 273 234 188 SNCR 51 51 51 Baghouse 504 387 219 ACI 29 27 19 Source: EPA IPM 4.10 Basecase assumptions and EEI 2011 Study 8
Levelized Costs of Major Control Equipment Levelized all-in (capital, FOM, VOM) cost of major control equipment for a 200 MW coal unit could be as high as $50/MWh depending on capacity factor and type of equipment LEVELIZED COST OF CONTROL EQUIPMENT ($/MWh) (200 MW Unit, 15-Year Recovery with 15% Capital Charge Rate) Capacity Factor Equipment 30% 70% Wet Scrubber $ 50.80 $ 22.91 Dry Scrubber $ 43.57 $ 20.13 DSI $ 10.10 $ 8.15 SCR $ 15.40 $ 7.37 SNCR $ 4.38 $ 2.48 Baghouse $ 23.25 $ 9.98 ACI $ 2.88 $ 1.91 Current energy margins (excluding capacity revenues) already low for merchant coal plants due to low gas prices, low demand growth, and new renewables Current dispatch costs for an existing coal plant ~$20-35/MWh Low wholesale power prices in 2011 PJM West: ~$47/MWh Midwest (Illinois/Michigan): ~$33-35/MWh Southeast: ~$32-35/MWh 9
Typical Timelines for Retrofit Technologies ACI and DSI can be deployed in 1-1.5 years, while FGD and baghouse can take 3-5 years. 7 6 ACI 5 DSI 12 18 9 12 EPA URS ICAC Southern Co. Cichanowicz Range from All Studies 4 Baghouse 12 48 3 SCR 21 50 2 Dry FGD 21 36 1 Wet FGD 24 69 0 0 10 20 30 40 50 60 70 80 Projected Retrofit Length (Months) 10
Feasibility of MATS Compliance -- Timeline Unless the construction already started, meeting the 3-year deadline (April 2015) would be challenging for some controls. ACI and DSI projects are relatively short, so no time constraints expected. ACI DSI Baghouse 7 6 5 4 3-Year Compliance Window Assumed Project Start MATS Federal Register Publication Range of Potential Project Completion Dates Compliance Deadline w/o Extension Compliance Deadline w/ 1-y Extension 3 SCR 2 But, even a 1-year extension may not be enough for Wet FGD projects that have not yet started. Dry FGD 1 Wet FGD 0 Jan-2012 Jan-2013 Jan-2014 Jan-2015 Jan-2016 Jan-2017 Jan-2018 11
Outage Days to Install Retrofits Incremental outage days are as low as less than a week for ACI, DSI, SNCR and DSI, while baghouse installation requires more than three additional weeks. Outage Type Average Outage Length (days) Incremental Outage Time (days) Without Retrofit 30.4 n/a With Retrofit Wet FGD 50.5 20.1 Dry FGD 38.2 7.8 DSI 36.0 5.6 Baghouse 54.7 24.2 SCR 49.3 18.8 SNCR 31.8 1.3 ACI 36.4 6.0 12
Projected Outage Needs in MISO About 4 GW of additional outages needed during the last four outage seasons prior to the 1-year extension deadline. Total coal capacity on outage (12-14 GW) may create reliability concerns if coal retirements exceed 12 GW. 16 14 12 10 8 6 4 2 0 Scenario 1: 0 GW Retire Scenario 2: 3 GW Retire Scenario 3: 12 GW Retire Incremental Retrofit Outages Scenario 4: 19 GW Retire Typical Outages Spring 2012 Fall 2012 Spring 2013 Fall 2013 Spring 2014 Fall 2014 Spring 2015 Fall 2015 Spring 2012 Fall 2012 Spring 2013 Fall 2013 Spring 2014 Fall 2014 Spring 2015 Fall 2015 Spring 2012 Fall 2012 Spring 2013 Fall 2013 Spring 2014 Fall 2014 Spring 2015 Fall 2015 Spring 2012 Fall 2012 Spring 2013 Fall 2013 Spring 2014 Fall 2014 Spring 2015 Fall 2015 Average MISO Coal Outages in Season (GW) 13
Historical Retrofits in Midwest Few retrofits in the 1990s, then reached as high as 15 GW per year in 2009 More capital-intensive projects (SCR, FGDs) in 2007 relative to 2009 when ACI retrofits were the largest type. 16 14 12 10 8 6 4 2 0 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Retrofitted Capacity (GW) Hg SO X PM NO X ACI SNCR SCR ESP Baghouse DSI Dry FGD Wet FGD Historical Deployment of Environmental Controls (Retrofit Only in MISO) Control Online Year 14
Historical Retrofits in U.S. Similar to Midwest, few retrofits in the 1990s nationwide, then reached as high as 70 GW per year in 2009 Large fraction (~20 GW) of the retrofits in 2009 from FGDs, while SCR was the dominant retrofit type in early 2000s. 0 80 70 60 50 40 30 20 10 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Retrofitted Capacity (GW) Hg SO X PM NO X ACI SNCR SCR ESP Baghouse DSI Dry FGD Wet FGD Historical Deployment of Environmental Controls (Retrofit Only in U.S.) Control Online Year 15
Historical Retrofits + New Gen in Midwest Historical retrofits and new builds in MISO reached a max of 16 GW ( wet FGD equivalent ) in 2008, largely due to new wind plants Conversion to wet FGD equivalent capacity is done by using ratio of capital costs relative to wet FGD New Gen and Retrofits in Wet FGD Equivalent (MW) 18,000 16,000 14,000 12,000 10,000 8,000 6,000 4,000 2,000 0 Retrofits New Builds 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Capacity Online Year 2004 16.3 GW 2005 2006 2007 2008 2009 2010 2011 16
Historical Retrofits + New Gen in U.S. Historical max of 89 GW (wet FGD equivalent) in the U.S. for retrofits and new builds was in 2009 (with a close second in 2002) Large fraction of the historical activity from new builds, mostly from gas and wind plants since 2000 New Gen and Retrofits in Wet FGD Equivalent (MW) 100,000 90,000 80,000 70,000 60,000 50,000 40,000 30,000 20,000 10,000 0 Retrofits New Builds 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Capacity Online Year 2004 2005 89 GW 2006 2007 2008 2009 2010 2011 17
Historical vs. Projected Retrofits + New Gen in MISO In all four MISO scenarios, projected retrofits plus new gen to meet the 3-year MATS deadline substantially exceed the historical max of 16 GW. Retrofit and New Build Capacity in Midwest (Wet FGD Equivalent GW) 50 45 40 35 30 25 20 15 10 5 Scenario 1: 0 GW Retire Scenario 2: 3 GW Retire Scenario 3: 12 GW Retire Scenario 4: 19 GW Retire Retrofits New Builds 16.3 GW Historical Max 0 2012 2013 2014 2015 2012 2013 2014 2015 2012 2013 2014 2015 2012 2013 2014 2015 18
Historical vs. Projected Retrofits + New Gen in U.S. EPA s projection of retrofits plus new gen to comply with MATS is well below historical max of 89 GW. However, EEI s projections for the retrofit plus new gen is almost double the historical max. 200 180 Scenario 1: EPA Estimate Scenario 2: EEI Low Estimate Scenario 3: EEI High Estimate Retrofit and New Build Capacity in U.S. (Wet FGD Equivalent GW) 160 140 120 100 80 60 40 Retrofits 20 0 2012 2013 2014 2015 2012 2013 2014 2015 2012 2013 2014 2015 New Builds 89 GW Historical Max 19
Projected Demand for Boilermakers in U.S. MATS compliance could require as many as 40% of current boilermakers (7,590 out of 18,850) under the EEI s projected needs for retrofits and new gen, but only less than 15% under the EPA projections. 20
Conclusions Coal fleet in MISO is facing a substantial amount of retrofit installations (49-63 GW) to comply with EPA s MATS rule over the next 3-4 years Compliance planning is difficult due to other emerging regulations (CSAPR, 316(b), ash handling, CO 2 ) as well as uncertain future market conditions Unless the construction already started, meeting the 3-year deadline (April 2015) under MATS would be challenging for some controls such as baghouses and FGDs. 21
Conclusions (cont d) Incremental outages of 4 GW per season needed to tie-in retrofits in MISO, which may require extending the outage season to 9 months as well as a potential need for extending compliance deadline beyond 2016. To meet the 3-year MATS deadline, projected retrofits plus new gen in MISO substantially exceed the historical maximum of 16 GW (wet FGD equivalent) in 2008. Nationwide, MATS compliance could require 15-40% of the current boilermakers working on retrofits and new generation. 22
Presenter Dr. Metin Celebi Principal Phone:+1.617.864.7900 Email: Metin.Celebi@brattle.com Dr. Celebi provides expertise in electricity markets and analysis of environmental and climate policy. He has consulted primarily in the areas of electricity spot pricing and market design, and has experience in developing and analyzing climate policies, assessing generation market power, LMP modeling, and merger analysis. He holds a Ph.D. in Economics from Boston College and B.Sc. in Industrial Engineering from METU, Turkey. 23
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