EPA Issues Final EGU MACT and NSPS
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
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)
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
Copies of the proposed and rulemaking can be found in
our FTP library.
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RMB Consulting &
February 16, 2016