ENVIRON Utility MACT Regulatory Summary
- 1. Regulatory Summary: Proposed Mercury and Air Toxics Standards On March 16, 2011, USEPA announced proposed Mercury and Air Toxics Standards (MATS) for power plants, which establish Maximum Achievable Control Technology (MACT) emission standards for hazardous air pollutants (HAPs) from approximately 1,340 electric utility steam generating units (EGUs) located at about 525 power plants. Under MATS, USEPA expects to achieve a 78% reduction in mercury and a 91% reduction in acid emissions from power plants. This rule replaces the court-vacated Clean Air Mercury Rule (CAMR), which had previously attempted to address mercury reductions from power plants through a cap-and-trade program. WHO IS SUBJECT TO THIS RULE? Different emission standards are provided for existing and new (i.e., construction commenced after May 3, 2011) sources. The The proposed MATS (a.k.a. Utility MACT) apply to approximately emission limits are 30-boiler operating-day averages including 1,200 coal- and 150 oil -fired EGUs with a capacity of 25 periods of start-up, shut-down, and malfunction (SSM). EPA allows megawatts or greater. USEPA has proposed several subcategories facility-wide averaging of emissions from existing units within the of affected sources under MATS, for which differing requirements same category. will apply: Affected sources must develop a site-specific performance test plan • Coal-fired EGUs designed for coal ≥ 8,300 Btu/lb and conduct performance testing to establish site-specific operating • Coal-fired EGUs designed for coal < 8,300 Btu/lb limits and to demonstrate initial compliance no later than 180 days after the compliance date. • Oil-fired EGUs designed to burn liquid oil • Oil-fired EGUs designed to burn solid oil-derived fuel CONTINUOUS COMPLIANCE MONITORING REQUIREMENTS • IGCC units combusting either gasified coal or gasified solid Sources must operate the continuous monitoring system at all times oil-derived fuel the affected EGU is operating, except for periods of malfunctions or out-of-control periods. Natural gas power plants are not affected by this rule. • Continuous emission monitoring system (CEMS) required for EMISSION LIMIT STANDARDS AND PERFORMANCE TESTING numeric emission limits (Hg, HCl or SO2, and PM) For each of the subcategories described above, the proposed rule • Emissions testing, parameter monitoring, and fuel analyses provides the option of meeting either heat input-based or gross allowed for metals and acid gases; sorbant traps allowed for energy output-based standards for the following HAPs: Hg • Mercury (Hg) • Thirty day averaging period to accommodates process Hydrogen chloride (HCl) – an alternate SO2 limit may be used variability and, coupled with CEMS, facilitates compliance • if some form of flue gas desulfurization system is installed WORK PRACTICE STANDARDS • Non-Hg metals – compliance can be demonstrated through For both existing and new EGU, you must conduct annual emission limits on particulate matter (PM), total non-Hg metals, performance tests of the EGU. The initial compliance requirement is or ten individual metal HAPs to conduct a tune-up of your EGU.
- 2. Regulatory Summary: Proposed Mercury and Air Toxics Standards RECORDKEEPING REQUIREMENTS ENVIRON’S EXPERIENCE AND SERVICES The following records must be maintained for at least five years Throughout its history, ENVIRON has provided services to the and on-site for two years: power industry. From siting to closure, projects have spanned the needs of power generation companies, ranging from: • Copies of all notifications and reports submitted to regulatory authorities Business Development and Expansion • Due Diligence Evaluations • Records of performance stack tests, fuel analyses, or other • Environmental Planning compliance demonstrations and performance evaluations • Site Development • Monitoring and operational data Regulatory Approvals and Litigation Support • Fuel usage and type • Facility Permitting and Compliance • Natural Resources Surveys • Occurrence and duration of each SSM and actions taken • Litigation Support during malfunction Operational and EHS Performance Enhancement WHAT ARE THE KEY COMPLIANCE DATES? • Environmental Compliance (including CSAPR, Utility MACT, MATS was announced on March 16, 2011 and published in 316(b), Coal Ash Rule, GHG) the Federal Register on May 3, 2011 (76 FR 24976-25147). • Sustainability and Governance Comment period ended on July 15, 2011. In accordance with • EHS and Carbon Management Systems a Consent Decree, final rule must be signed by November 16, Site Closure and Decommissioning 2011. • Site Characterization Compliance for existing EGUs is required no later than three • Closure Strategy and Management years after date of publication of final rule in FR, with option for • Site Redevelopment one year extension. FOR MORE INFORMATION, PLEASE CONTACT: REFERENCES Alan Kao, Principal Alan Shimada, Principal Rule home page – +1.978.449.0324 +1.973.286.4263 http://www.epa.gov/airquality/powerplanttoxics/ akao@environcorp.com ashimada@environcorp.com www.environcorp.com