“Review of the Utility MACT Rule Status and Comments” was the Hot Topic on October 4, 2011 

Three speakers addressed compliance strategies for the proposed rule, the current status of the rule and the process used to develop the proposed emission limits. EPA must finalize the Utility MACT rule by November 16 - just a few weeks from now - according to the terms of a settlement agreement.  All indications are that EPA will meet that deadline. The speakers speculated on what the final rule might look like based on their review of comments submitted and conversations with EPA representatives.  In particular, their sense was that EPA may:

§  Move away from the “Franken-plant” approach to setting emission limits, which could result in the relaxation of limits for one or more pollutants

§  Move away from Total Particulate Matter (PM) limits due to the difficulty of measuring total PM, and focus more on just filterable PM

§  Make changes which will require fewer fabric filter installations than would have been required under the proposed rule

Carl V. Weilert, Principal Process Engineer at Burns & McDonnell, discussed “The Good, the Bad and the Ugly” aspects of the proposed rule. On the positive side, he noted that the proposed rule allows for averaging among multiple units at a facility. On the negative side, he discussed why the test methods and processes for measuring total particulate matter were unreliable and questioned EPA’s assumption that dry sorbent injection (DSI) could be used to achieve compliance with the HCl limits. He also pointed out that the MACT limits for new units were too low and could effectively block any new fossil fuel-fired projects.

Brian Higgins, Vice-President for Technology at Nalco Mobotec, Inc., discussed compliance strategies for the proposed rule. In particular, he noted the difficulty of using particulate matter CEMS (which measure only filterable PM) to demonstrate compliance with a total particulate matter standard. He also discussed issues associated with the ash from DSI systems used to achieve compliance with the HCl limit.

Kasi Dubbs, Managing Consultant at Trinity Consultants, summarized the methods and processes used by EPA to set emission limits for the Utility MACT rule. Her presentation was particularly effective in showing the impact of EPA’s “Franken-plant” approach to setting the MACT floor. For example, of the top 20 performing units for PM, only one unit was also on the list of top 20 performing units for total suspended metals. Similarly, of the top 20 units for SO₂, only one unit was also on the list of the top 20 units for HCl. She also identified other issues associated with EPA’s method for defining the “top performing 12 percent” of units in establishing the MACT floor.

The Bios and Abstracts are linked below.
BIOS, PHOTOS, ABSTRACTS - October 4, 2011.htm