Utility MACT-Impact and Compliance Strategy is Hot Topic Hour on September 9, 2010
EPA is required to issue a draft of proposed new regulations for air pollution emissions from electrical generating units (EGUs) based upon the Maximum Achievable Control Technology (MACT) provisions of the Clean Air Act Amendments by March 2011. The MACT process involves establishing emissions limitations on 187 listed Hazardous Air Pollutants (HAPS) based upon the best performing 12 percent of plants in each category of plant. The final regulations must be promulgated by November 2011 and then power plants will have 36 months to comply.
Based on what we have seen in the Cement MACT and recent draft MACT for industrial boilers, we would assume that most coal-fired power plants, even those with APC equipment installed, will not meet the new emission limits that will be effective in November 2014 and will need to add APC equipment. Because of the short time frame for compliance, power plant operators need to begin developing an integrated control strategy now based on worst case scenarios. This is a more difficult task for fleet operators that have plants with different equipment design and configurations and a variety of different coal types and characteristics. Developing a strategy to address the utility MACT is also more complex because in addition to HAPs, EPA is in the process of promulgating new regulations that will impact emissions standards for NOx and SO2 (Transport Rule), particulates and greenhouse gases.
It may be wise to focus on making decisions on fuel type (PRB, bituminous or gas) since this will affect decisions on large capital equipment such as scrubbers and fabric filters. Then the decisions on scrubbers and bag houses need to be made quickly because of the length of time need to design, specify, and construct these systems – typically 4 to 5 years. It has been estimated that this rule could create a need for 800 baghouse and 600 scrubber retrofits all of which need to be completed in the same 3 to 4 year time frame. This may well create a severe shortage of engineering and design personnel and materials required to construct the APC equipment necessary to bring a plant into compliance as well as construction/installation personnel. Operators of smaller or just one or a few plants may have a particular urgency because the APC equipment suppliers may well serve the larger customers (fleets and large plants) first.
The following speakers will address the issues related to the impact of the Utility MACT on power plant operators, the current status of the MACT rule making, the worst case scenario of emissions limits and required controls under the MACT, the key issues to be considered when developing a strategy to achieve compliance with the MACT, control technologies and equipment that can be utilized to achieve the expected emissions limits imposed by the MACT and various other strategies that an operator could adopt.
Robert Tang, President & CEO of CEFCO Global Clean Energy, LLC will describe an innovative cost-effective technology long recognized for compliance with Hazardous Waste Combustors (HWC) MACT standards for removal of acidic gases, mercury and trace metals, and fine particulate matter (even below 2.5 microns) from incineration of radioactive waste, in use for 25 years with the DOE Nuclear Regulatory Commission, is currently being considered and proposed as a comprehensive MACT solution for compliance in the Utility Power and Cement industries and also for CO2 Capture with a significantly lower 'parasitic load burden' or 'energy penalty'. The CEFCO (Clean Energy and Fuel Company) process is a major improvement in Air Quality Control System (AQCS) efficiency and CO2 capture levels compared to the currently available technologies. It integrates and enhances two proven and previously-patented technologies enabling the selective capture and removal of well over 99 percent of flue gas emissions and over 90 percent of CO2 with less than a total of 10 percent for parasitic load burden or energy penalty at capital and operating costs significantly below conventional AQCS technologies.
Robert (Bob) Fraser, QEP, a Senior Technical Director for Power Generation Services within AECOM Environment will discuss our experience to date with boiler MACT and explore whether or not it is a prequel to the utility MACT. Industrial boiler owners are in the process of evaluating compliance alternatives under EPA’s proposed boiler MACT Rules, scheduled to be issued final in December. Detailed review indicates that the proposed boiler MACT Rules are highly flawed, in that limits are proposed that have yet to be achieved simultaneously and continuously by any known boiler. In some cases, there is no known control technology that can be guaranteed to achieve compliance. USEPA appears to be following a similar (although likely even more stringent) path to develop MACT standards for utility boilers, and there is much that can be learned from ICI MACT.
Carrie Yonley, P.E., Vice President at Schreiber, Yonley & Associates will discuss new EPA combustion regulations and implications for the utility industry. EPA has now issued the first MACT standards for major combustion processes under the current EPA Administration, in addition to new proposed rules. This presentation addresses the MACT approach just finalized for the Portland cement NESHAP, in addition to the relation to the proposed CISWI and boiler rules. The purpose will be to explore the new rules in order to draw potential implications and parallels on similar regulations for the electric power generation industry.
Michael T. Rossler, Manager of Environmental Programs at the Edison Electric Institute will discuss the utility MACT. EPA is proceeding with the Utility MACT rulemaking for coal- and oil-based EGUs. The rule is to be proposed by March 16 and finalized on November 16. This rule will be unprecedented in its scope and range across a large sector of the U.S. economy. What will the MACT look like? What did the ICR data reveal? Can the industry comply with the rule in three years like the Clean Air Act mandates? Ultimately it will be one or two non-mercury HAPs that will determine the emission control fate of the coal- and oil-based power plant fleet.
Kenneth J. Snell, Environmental Consultant and Paul Farber, Environmental Specialist at Sargent & Lundy LLC Environmental Services Division will provide a brief summary of Sargent & Lundy's view of the Utility MACT (worst case) and potential compliance strategies.
To register for the "Hot Topic Hour" on September 9, 2010 at 10 a.m. CDT (Chicago time), click on: http://www.mcilvainecompany.com/brochures/FGDnetoppbroch/Default1.htm
Bob McIlvaine
President
847 784 0012 ext 112
rmcilvaine@mcilvainecompany.com