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Energy Matters

NOTE:  If you are looking for Santee Cooper's CCR Rule Compliance Data and Information page please click here.

Today's energy industry is in the midst of rapid change. 

Some of that change is bringing about positive developments for Santee Cooper and our customers; other developments unfortunately herald the potential for rapid cost increases and uncertainty about future generation availability and economic competitiveness.

Through Energy Matters, we highlight these areas of change for our customers and other stakeholders. Knowledge is power, and by informing you we hope to equip you with the tools you need to prepare for change and address any potential concerns that change may hold for you. We welcome your feedback.

Generation and Regulations

Santee Cooper generates electricity from a variety of fuels, including coal, natural gas, nuclear, hydro and renewable energy sources. The U.S. Environmental Protection Agency has significantly toughened the regulatory climate for fossil-fueled generation, in particular coal-fired units, so much so that Santee Cooper has retired four units at our two oldest generating stations. We are building new nuclear generation, which will increase our capacity, and our customers are better served if we retire these older units than spend the money needed to keep them in compliance.

Clean Power Plan

In June 2014, the Environmental Protection Agency (EPA) released the Clean Power Plan, which seeks to regulate emissions of carbon dioxide (CO2) from fossil fuel utility boilers and gas turbines. The agency is reviewing comments, and a final rule is expected by late summer or early fall 2015.

The rule aims to cut CO2 emissions nationwide by 30 percent, and the target EPA assigned South Carolina is 772 pounds of CO2 per megawatt hour (MWh). Currently, the state emissions rate is 1,587 pounds of CO2 per MWh. That’s a difference of 815 pounds of CO2 per MWh, the largest in the country. If it stands, it would represent a 51 percent reduction in CO2 emissions.

As is, the Clean Power Plan could increase the average South Carolina residential customer’s bill by 12-22 percent and the average South Carolina commercial customer’s bill by 16-28 percent, depending on the rate of economic growth between now and 2030.

We have several areas of concern with the Clean Power Plan. The biggest is the way EPA treats nuclear under construction.

When we announced our license application in 2008 to add two units to the V.C. Summer Nuclear Station, we cited emissions reduction as a chief reason for building new nuclear power. Electricity customers across the state are already paying for this $10 billion nuclear project.

South Carolina is one of three states building new nuclear. All three states face harsh target emissions goals. In assigning us a 51 percent reduction, EPA is essentially assuming the units are built, rather than under construction. The agency has then assigned us a steeper emissions target.

EPA is treating renewable projects currently under construction differently, letting states count emission impacts from these projects by setting a more reasonable goal. This amounts to inequitable treatment for different zero-emitting resources.

Other concerns stem from the fact that the EPA's state-level emissions targets vary widely and, in our case, are based on flawed assumptions about what is achievable in South Carolina. Renewable resources are very limited in South Carolina, and Santee Cooper has already tapped into the more cost-effective ones, such as biomass.

About 36 percent of the state’s electricity sales are to industrial customers. They are already operating at peak efficiency, which makes it very difficult for South Carolina to reach the energy efficiency increases assumed in the goal EPA handed us.

Other building blocks EPA has suggested are also impractical for South Carolina. We have limited natural gas resources, for instance.

Santee Cooper is working with other utilities to change the way EPA is treating nuclear under construction. We still have to increase renewables, energy efficiency, and consider other initiatives to reduce emissions, but getting proper credit for the nuclear units will significantly reduce the cost burden to customers across the state.

Many of the steps EPA suggests states take to reach the emission targets are steps Santee Cooper and our in-state peers have already taken.

Specifically, Santee Cooper:

  • Is running our fossil plants at maximum efficiency
  • Has increased our use of natural gas generation
  • Closed four older coal-fired units, about 10 percent of our generation
  • In partnership with SCE&G, we are building a $10 billion nuclear power expansion that will bring 2,200 MWs of reliable, emissions-free electricity to the state’s grid. Nuclear power is the only baseload resource that is emissions-free.
  • We have significantly expanded our renewable generating portfolio, with about 130 MW online or under contract today. We provide electricity to customers from landfill methane gas, woody biomass, solar power, wind energy and more.
  • We have rebates and other incentives for customers to make their homes and businesses energy efficient, with an ambitious 2020 goal we are on target to meet.

Santee Cooper will cut our CO2 emissions 44 percent by 2029 (over 2005 levels) with these initiatives and our existing renewable and energy efficiency plans. We have already cut CO2 emissions 23 percent since 2005.

Disposal of Coal Combustion Residuals from Electric Utilities

In December 2014, the Environmental Protection Agency (EPA) issued its final rule regulating coal combustion residuals (CCRs) from coal-fired power plants. It was published in the Federal Register in April 2015.

The rule finalizes national regulations to provide a comprehensive set of requirements for the safe disposal of CCRs — commonly known as fly ash, bottom ash, and scrubber byproducts such as gypsum — from coal-fired power plants.

The rule also establishes technical requirements for CCR landfills and surface impoundments under subtitle D of the Resource Conservation and Recovery Act (RCRA), the nation's primary law for regulating solid waste.

Under RCRA subtitle D, CCRs are defined as a non-hazardous waste, thereby giving EPA authority to set performance standards for waste management facilities with enforcement by states who adopt their own CCR management programs. Additionally, the rule sets out recordkeeping and reporting requirements.

Excavation and removal of the ash from existing ponds is not mandatory, but all ponds no longer receiving CCRs must begin closure within 30 days from its last receipt of CCRs. Groundwater monitoring and corrective action, as necessary, is required for all CCR ponds and landfills governed by the rule. Ponds at retired generating stations are exempt from the rule.

Santee Cooper supports declaring CCRs non-hazardous waste under subtitle D of the Resource Conservation and Recovery Act. We also support the development of a national standard for structural integrity of CCR impoundments.

Santee Cooper has a long track record of beneficially using coal combustion products (CCPs), conducting routine groundwater monitoring and inspecting impoundments. The existing groundwater and inspection programs will be modified to comply with the CCR rule. All landfills and ponds governed by the rule will be evaluated to ensure they meet the rule's technical criteria.

Santee Cooper in 2013 announced plans to beneficially use CCPs by excavating ponds at three of its generating stations — providing economic, environmental and customer benefits. Approximately 260,000 tons of ash from the Grainger and Jefferies stations were removed and beneficially reused in 2014. Our goal is to beneficially use several million tons of ash by the end of 2023. We also will continue to beneficially use the gypsum by providing it to the drywall, cement and/or agricultural industries.

Lastly, the required website is under development and will be published in Oct. 2015.

Distributed Generation

Distributed generation refers to solar panels and other electricity generating resources that are located in places besides utility generating stations. The primary source of distributed generation in South Carolina is rooftop solar panels installed by customers to provide some of their own electricity. Our customers can also sell any excess electricity they generate to Santee Cooper for credit on their customer bill.

Santee Cooper has a strong history promoting and providing renewable resources to our customers, and in fact we put the first solar power on the state electric grid, back in 2006. We also offered a Solar Home Initiative in 2008 to encourage and help finance solar panels for residential customers who wanted to install them at home.

Santee Cooper is developing a distributed generation rider that can be applied to any retail customer rate — residential, commercial or industrial. The rider recovers fixed costs (such as for generating stations, power lines and poles) from solar customers, who still need 24/7 access to our electric system to meet their needs when the sun isn’t shining and also to sell us back their excess power. These fixed costs make up two-thirds of a typical customer bill, and our priority in supporting rooftop solar programs is making sure those costs to serve solar customers are not shifted and borne by non-solar customers.

Learn more here.

Revisions to Effluent Guidelines for the Steam Electric Power

The Environmental Protection Agency (EPA) is proposing an amendment to the Steam Electric Power Generating effluent guidelines and standards, which govern the wastewater treatment requirements and the amount of constituents that can be discharged in steam power-plant wastewater. The proposed rule was published in the Federal Register in June 2013, and the final rule is expected in September 2015.

EPA is proposing four options that differ in the number of waste streams covered (such as fly-ash handling systems, treatment of air pollution control waste, and bottom ash), the size of the units controlled, and the stringency of the treatment controls imposed. Under the current proposal, new requirements for existing power plants would be phased in between 2017 and 2022.

The amendment would require the construction and operation of advanced wastewater treatment systems for flue gas desulfurization wastewater and possibly non-chemical metal cleaning waste.

Other requirements include:

  • Conversion to dry bottom ash handling
  • Collection and treatment of leachate from surface impoundments and landfills
  • Treatment of wastewater streams prior to their reuse, recycling, or mixing with different waste streams — which could also result in requiring further separation of wastewater streams and requiring additional intake water
  • Establishing additional best management practices requirements for surface impoundments
  • Use of "Sufficiently Sensitive" Methods for laboratory testing
  • Treatment of "Legacy Wastes"

The final rule is expected to require more controls of heavy metals removed by air-pollution controls, necessitating the construction of additional wastewater treatment systems to meet the new limitations.

Santee Cooper submitted detailed comments to EPA in Sept. 2013, and we're working with industry trade groups including the American Public Power Association and the Large Public Power Council to express our concerns.

Standards for Cooling Water Intake Structures

The Environmental Protection Agency (EPA) in Aug. 2014 published a rule under section 316(b) of the Clean Water Act to minimize the environmental impacts of power plant cooling water intake structures on aquatic life. The standards address the impingement and entrainment rates, and also provide guidance on acceptable technology EPA feels will meet the new restrictions.

The rule establishes new standards to reduce impingement mortality at all power and manufacturing facilities withdrawing more than 2 million gallons per day (MGD) and using at least 25 percent for cooling. This applies to our Cross, Winyah, Jefferies, and Rainey generating stations. There are additional requirements for any facility that withdraws more than 125 MGD, which could further affect the Jefferies station.

The rule also outlines additional reporting that will be required under the National Pollutant Discharge Elimination System (NPDES) wastewater and stormwater permit applications for all stations during their renewal periods.

The rule provides seven compliance options for impingement for existing facilities, including closed-cycle cooling systems. This means the Cross, Rainey and Winyah stations meet the technology standards for this portion of the rule.

Santee Cooper supports the final rule, and our intakes will be able to meet compliance.

We continue to gather information to prepare NPDES reports for Jefferies, Cross, Winyah, and Rainey stations. And we completed a 12-month baseline study for Cross Generating Station in partnership with the South Carolina Department of Natural Resources for future compliance reports. Discussions continue with the South Carolina Department of Health and Environmental Control on compliance options.

Clean Water Rule (Waters of the United States)

The Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers released their final version of the Clean Water Rule in May 2015. It will be effective 60 days after publication in the Federal Register.

The Clean Water Rule seeks to define and protect tributaries that impact the health of downstream waters, and also protects navigable waterways and their tributaries. The rule also seeks to protect waters that are next to rivers and lakes and their tributaries. It limits protection to ditches that are constructed out of streams or function like streams and can carry pollution downstream.

We continue to review the final rule, which was published on May 27, 2015. We have voiced our position to the EPA and worked with trade groups like American Public Power Association and the Large Public Power Council to further express our concerns.