“Implementation of the MACT Rule” - Hot Topic Hour on February 9, 2012

On December 21, 2011, the U.S. EPA issued the final “Utility MACT” rule establishing mercury and air toxics standards for coal-and oil-fired electric generating units (EGUs) larger than 25 MW.  The final rule has not yet been published in the Federal Register, but is expected to be published by early March. All existing EGUs will have three years after publication to comply with the standards, although the rule allows states to grant specific units an additional year for equipment installation. Implementation was the focus of the Hot Topic Hour.

The speakers discussed a number of issues related to compliance with the final Utility MACT rule. 

William (Bill) Campbell, III, Vice President and Senior Program Manager at AECOM, discussed the available options for ensuring compliance with the particulate matter (PM) and acid gas standards.  The final rule contains only a filterable PM standard, whereas the proposed rule contained a total PM standard.  Bill said that since the final rule dropped the standard for condensables, facilities will be able to comply by upgrading precipitators rather than having to add a bag house.  Even so, he indicated that compliance will be costly - a Kentucky utility recently requested a 20% rate increase due to the cost of MACT compliance. 

Kevin Crosby, Technical Director at The Avogadro Group, LLC, discussed compliance testing requirements for the Utility MACT rule.  He reviewed stack tests and continuous monitoring (CEMS) options for demonstrating both initial compliance and continuous compliance under the new rule.  

Brian Higgins, Vice-President for Technology at Nalco Mobotec, Inc, discussed the relationship between the Utility MACT rule and the Cross-State Air Pollution Rule (CSAPR), especially given that CSAPR was stayed by a federal court in December. He indicated that the large reduction in HCl forecast under the Utility MACT rule will drive the installation of fabric filters or require significant ESP upgrades.

Patrick Doonan, with Siemens Environmental Systems and Service, explained that coal-fired power plants with wet FGDs installed should consider adding a wet ESP instead of a fabric filter to meet the Utility MACT standards as well as future PM_2.5 regulations. WESPs offer a compact option for retrofits, particularly where space is limited. Fabric filters create an increased pressure drop which may require a new fan.  Plus, operating and maintenance costs are higher for fabric filters because the bags require replacement and disposal.