C 6.1  | The Utility MACT Rule: An Industry Perspective

Michael  Rossler |  Manager, Environmental Programs, EEI

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 November 16. This rule will be unprecedented in its scope and range across a large sector of the US 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. Meanwhile, some groups and the international community have other plans

C 6.2  | Combustion MACT Standards Update

Carrie Yonley | Vice President, Schreiber, Yonley & Associates

EPA has now issued the first MACT standards for major combustion processes under the current EPA Administration, in addition to new proposed rules. The latest rules include significantly more stringent standards, incorporate startup/shutdown/malfunction emission standards, new CEMs/CMSs and significantly more challenges than previous NESHAP rules. In addition, other 2010 proposed rules include a different regulatory approach for combustion facilities using non-hazardous waste as an alternative fuel in the process. This presentation addresses the MACT approach finalized in the Portland Cement NESHAP (40 CFR 63, Subpart LLL), in addition to the relation to the proposed (final by January 2011) CISWI and Boiler rules. The purpose will be to explore these rules in order to draw potential implications and parallels for similar regulation of the electric power generation industry.

C 6.3  | HAP Insights from the Utility ICR Database

Sid Nelson Jr. | Director New Business Development, Albemarle Corporation

The U.S. EPA is to soon set the utility hazardous air pollutant (HAP) standards at the average performance limitations of the best performing 12% of boilers.  To determine these MACT emission limits, an Information Collection Request was issued requiring HAP emission measurements at about 350 utility boilers, costing an EPA-estimated $75 million.  Measurements included mercury and other heavy metals, HCl, PM, dioxins and other organic HAPs and possible surrogates.  This presentation will take a preliminary peek at the resulting database for a variety of HAPs.  Initial findings will be presented and interesting relationships will be described.

C6.4  | Projection of Final EPA Utility MACT Requirements…

Karl Wilber | General Manager, Tekran Instruments Corporation

…and Presentation of a Challenge for Design and Implementation of a Complete Emissions Monitoring Solution” EPA is finalizing their Information Collection Request (ICS), which will lead to finalization of the Utility Maximum Achievable Control Technology (MACT) guidelines for Hazardous Air Pollutants (HAPS) from coal-fired power plants. Projections from regulatory authorities and knowledgable consultants suggest that the Utility MACT rules will closely follow paths of the ICI and PC MACT regulations. This paper will provide updates on the specifics of the Utility MACT provisions, with focus on new CEMS requirements. Examples of reporting requirements for criteria pollutants and HAPS will be provided. The paper will also show the performance and experiences with real-time CEMS for Hg, HCI, THC and PM. Data from Coal-fired Electric Generating Units and Cement processes will be presented. Recent supplemental laboratory and research information on low-level accuracies of CEMS will be summarized. Traceability requirements for HgCEMS will be highlighted with the EPA/NIST. Analogous data on PM CEMS are anticipated. The use of low-level CEM system for performance monitoring and optimization of pollutant-specific abatement systems will be included. Economic considerations and examples of the latter will be included as well.

C 6.5  | Energy Efficiency as a Regulatory Requirement

Kristine Baranski | Project Engineer, Cardinal Engineering, Inc.

The U.S. Environmental Protection Agency (EPA) has proposed energy assessments as requirements in rulemakings such as 40 CFR 63 Subparts DDDDD and JJJJJ, or Boiler MACT, as well as 40 CFR 60 Subparts CCCC and DDDD, or New Source Performance Standards for Commercial and Industrial Solid Waste Incinerators (CISWI). EPA is also expected to issue technical guidance including energy efficiency as an approach to Best Available Control Technology (BACT) for greenhouse gases as related to Prevention of Significant Deterioration (PSD) permitting under the recently finalized Tailoring Rule. The Boiler MACT and CISWI regulations as well as the EPA technical guidance on greenhouse gas BACT are all anticipated to be finalized during 2010. This session will focus on energy efficiency from a regulatory standpoint. Requirements for facility-wide energy assessments for compliance with the Boiler MACT and CISWI rules will be addressed, including the assessment scope and the necessary technical qualifications for auditors. Additionally, an overview of greenhouse gas BACT guidance and relevant BACT determinations will be presented. Finally, any recent EPA rulemakings including energy efficiency requirements will be discussed.

C 7.1  | Strategies and Costs of Compliance with the Engine NESHAPS

William Stark | Senior Consultant, R. W. Beck, A Science Applications International Corporation Company

In 2010, the U.S. Environmental Protection Agency finalized new National Emission Standards for Hazardous Air Pollutants (NESHAPS) applicable to existing reciprocating engines. In most cases, the new rule will require emission controls be added to engines used in peaking service. The presentation will include a summary of rule requirements as applicable to engines in peaking service and will present strategies for compliance, including evaluation of engines, initial emissions testing, and evaluation of emission reduction requirements and control technology alternatives. Estimates of capital, operating, and maintenance costs expected to be incurred in order to achieve and maintain compliance will also be presented. The presentation will be largely based on work performed for several municipal agencies in conjunction with their individual members.