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Kenneth J. Snell, Environmental Consultant at Sargent & Lundy LLC Environmental Services Division, believes that EPA will divide sources into categories by fuel type as well as combustor type. He anticipated regulations could include (in descending order of likelihood). Mercury Acid gases (HCl and HF) Dioxins/furans Non-mercury trace metals Non-dioxin organic HAPs
Revision Date: 9/9/2010
Tags: 221112 - Fossil Fuel 化石燃料, Sargent & Lundy, MACT
Carrie Yonley, P.E., Vice President at Schreiber, Yonley & Associates, alerted participants to the fact that the Cement MACT was published on September 9 in the Federal Register. It is indicative as to the likely content of utility rules. The industry is also facing the CISWI final rule slated for December. If the kiln burns solid waste then it may be subject to this rule. For existing kilns the Cement MACT particulate limit will be 0.04lb/ton of clinker. This is 0.004 gr/dscf. This compares to the previous limit on new kilns which was 10 times higher. PM CEMs will be required to determine compliance. CEMs will also be needed for Hg and THC. An HCl CEMs will be needed only if a wet scrubber is not used. But the units will have to comply with an HCl limit of 3 ppm based on a 30 day rolling average and 7 day rolling average for startup and shutdown operations
Revision Date: 9/9/2010
Tags: 221112 - Fossil Fuel 化石燃料, Schreiber Yonley & Associates, MACT
Robert (Bob) Fraser, QEP, a Senior Technical Director for Power Generation Services within AECOM Environment, believes the proposed Boiler MACT is a prequel to the Utility MACT. Since the best utility units are better controlled than their industrial counterparts he expects a more stringent utility rule. If low CO levels are required because CO is a surrogate for organic HAPs then there may be a problem meeting NOx limits. Oxidation catalysts have not been proven for solid fuel applications with the possible exception of the Babcock regenerative catalyst for wood-fired boilers. Incinerators control dioxins using ACI, but with lower quantities of dioxinsit may be hard for the utility industry to achieve comparable percent efficiencies.
Revision Date: 9/9/2010
Tags: 221112 - Fossil Fuel 化石燃料, AECOM, MACT
Michael T. Rossler, Manager of Environmental Programs at the Edison Electric Institute, says the Utility MACT could cost the industry $200/billion/yr by 2015. He provided timelines. The rule will be proposed by March 16 and finalized by November 16, 2011. This will not replace mercury rules already issued by 20 States. The industrial boiler MACT as proposed offers a prelude. It proposes limits for mercury, dioxin, PM (as a surrogate for non-mercury metals, HCl (surrogate for acid gases) and CO (surrogate for non-dioxin organic toxics). Other rules on water, waste and carbon need to be coordinated with this rule in fairness to the industry.
Revision Date: 9/9/2010
Tags: 221112 - Fossil Fuel 化石燃料, Edison Electric Institute, MACT
Robert Tang, President & CEO of CEFCO Global Clean Energy, LLC, described a system using steam assisted nozzles for removal of metals and acid gases followed by another similar system to separate the CO2. Experience has been obtained on hazardous waste combustors. The company is looking for partners to apply this to the utility industry.
Revision Date: 9/9/2010
Tags: 221112 - Fossil Fuel 化石燃料, CEFCO Global Clean Energy, MACT