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EPA Issues Final EGU MACT and NSPS Rules (12/22/11)

On Wednesday, EPA released the final National Emission Standards for Hazardous Air Pollutants (NESHAP) from Coal- and Oil-fired Electric Utility Steam Generating Units (a.k.a. “EGU MACT”) and final revisions to the New Source Performance Standards (NSPS) in Subpart Da (as well as some similar changes in Subparts D, Db and DC). The Administrator signed the final Utility MACT Rule and NSPS changes late last week. EPA was subject to a Consent Decree that originally required the standards to be finalized by November 16, 2011. Shortly before the deadline, EPA was granted a one-month extension (December 16, 2011) based on a motion filed by the Department of Justice on behalf of EPA.

The Utility MACT rule affects all coal-fired, coke and oil-fired boilers that generated greater than 25 MW and will impose significant emission reduction requirements and compliance costs for many units. Unlike the Industrial Boiler MACT Rule that affects similar non-Utility sources but which is still being evaluated under “reconsideration,” EPA is treating the Utility MACT Rule as a final rule. Compliance will be required within 60 days of publication in the Federal Register for new units and within three years (and 60 days) after publication for existing units.

  • Elimination of Total PM Standard . One of the most significant changes in the final rule is that EPA has dropped total PM as a surrogate for non-mercury metallic hazardous air pollutants (HAPS) in favor of a filterable PM limit. The filterable PM limit for existing coal-fired sources is 0.03 lb/mmBtu. For new units, however, the filterable PM limit is a very stringent 0.007 lb/MWh. The Agency also added a filterable PM option for oil fired-sources.

  • Reduced Stack Test Frequency. The frequency of stack testing under some compliance options has been reduced from monthly or bi-monthly to quarterly.

  • PM CEMS Options. PM CEMS can be used to demonstrate compliance, but the Agency has added provisions to allow sources treat particulate monitors as continuous parameter monitoring systems (CPMS) rather than CEMS. However, by treating the output as indirect indicator, sources would be subject to more frequent stack testing and could forgo significant compliance margin since the option still requires sources to stay below whatever value happened to be measured during the most recent compliance test.

  • Emission Limit Changes. EPA states that it considered many of the comments that it received and corrected various problems in the way that it calculated the proposed emission limit. Nonetheless, while some of the final limits did vary somewhat from the proposed limits, many remain the same or are similar to the originally proposed limits. The new unit limits, in particular, still pose achievability (and measurability) concerns.

  • Operating Parameter Monitoring. EPA has eliminated all of the operating parameter monitoring and fuel monitoring requirements with the exception of PM CMPS and some options for oil-fired sources. The Agency also indicates it is applying work practice standards in lieu of requiring compliance the limits during startup and shutdown periods. However, the Agency’s definition of startup and shutdown are rigid and not consistent with the industry’s practice. EPA defines that startup to ends whenever the unit generates any electricity. Likewise, shutdown only ends when no electricity is produced (or there is no heat input). All control equipment must be operated any time when the unit operates with the exception of only dry scrubbers and SCR where some concession is given to “normal operation” (i.e., operating temperature issues). The rule explicitly states that only natural gas or distillate oil may be fired during startup and shutdown periods.  

  • New Coal Subcategory Definitions and New Limited Use Subcategory . EPA replaced the coal subcategories in the proposed rule that were based on coal heating value with two similar subcategories based on coal rank. EPA included a new subcategory for limited use liquid oil-fired units with an annual capacity factor less than 8%. These units will be subject to a work practice standard consisting of a periodic boiler tune-up.

Copies of the proposed and rulemaking can be found in our FTP library.

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Last Revised: February 16, 2016