Legislative & Legislative & Regulatory Regulatory Clean Air Activities in Clean Air Activities in 20092009

David C. FoerterDavid C. FoerterExecutive DirectorExecutive DirectorInstitute of Clean Air Institute of Clean Air

CompaniesCompanies

September 24, 2009September 24, 2009

CEMTEK Users Group MeetingCEMTEK Users Group MeetingSanta Ana, CASanta Ana, CA

Presentation OverviewPresentation Overview

Who is ICACWho is ICAC Major Regulatory Drivers for PM, Major Regulatory Drivers for PM,

Ozone, visibility, NOx, SO2, GHGOzone, visibility, NOx, SO2, GHG Additional rulesAdditional rules

– PM in SCAQMDPM in SCAQMD– Stationary EnginesStationary Engines– CementCement– Industrial boilersIndustrial boilers

Wrap UpWrap Up

Who Is ICACWho Is ICAC

The National Association for Air Pollution Control The National Association for Air Pollution Control

Manufacturers and Service CompaniesManufacturers and Service Companies

Promote Better Understanding of Air Pollution Control Promote Better Understanding of Air Pollution Control

Industry, Suppliers, Technologies, and Industry Industry, Suppliers, Technologies, and Industry

CapabilitiesCapabilities

– Federal, State and Local Regulatory IssuesFederal, State and Local Regulatory Issues

– Industry Trade Groups & Other AssociationsIndustry Trade Groups & Other Associations

– Public-At-LargePublic-At-Large

Stationary Sources Primary FocusStationary Sources Primary Focus

– Electric Power and Industrial SectorsElectric Power and Industrial Sectors

Who Are MembersWho Are Members

Represent More Than 100 Leading Companies in APC Represent More Than 100 Leading Companies in APC

Industry Industry

– $100 million dollar-plus projects down to $1000 retrofits$100 million dollar-plus projects down to $1000 retrofits

Members Include: (Full and Associates)Members Include: (Full and Associates)

– Architectural & Engineering FirmsArchitectural & Engineering Firms

– Original Equipment Manufacturers and Full System SuppliersOriginal Equipment Manufacturers and Full System Suppliers

– Emissions Measurement VendorsEmissions Measurement Vendors

– Component Suppliers and AQ Control ConsultantsComponent Suppliers and AQ Control Consultants

Structural SteelStructural Steel

CatalystCatalyst

Reagents (Ammonia, Lime, Activated Carbon, etc.)Reagents (Ammonia, Lime, Activated Carbon, etc.)

ICAC Member Company ICAC Member Company MarketsMarkets

Electric Power SectorElectric Power Sector

Pulp & PaperPulp & Paper

Petroleum RefineryPetroleum Refinery

Plywood Plywood

BakeriesBakeries

RestaurantsRestaurants

Residential Wood Residential Wood

BurningBurning

Chemical Process

Industry

Metals Processing

Asphalt Production

Plastic Products

Surface Coating

Cement Manufacturing

Incineration

Clean Air RegulationsClean Air Regulations

Federal LegislationFederal Legislation– Clean Air Act 1970; 1977 and 1990 Clean Air Act 1970; 1977 and 1990

AmendmentsAmendments– New Source Performance Standards New Source Performance Standards

(SO(SO22, NO, NOxx, and PM), Acid Rain Program, , and PM), Acid Rain Program, New Source Review (NSR), NESHAPS, New Source Review (NSR), NESHAPS, BART, NOx SIP Call, CAIR, CAMRBART, NOx SIP Call, CAIR, CAMR

– Set AQ Standards (PM, Pb, O3, CO, NOx, Set AQ Standards (PM, Pb, O3, CO, NOx, SO2)SO2)

State Regulations & NAAQS Attainment State Regulations & NAAQS Attainment Demonstrations – transport SIP call, 126 Demonstrations – transport SIP call, 126 actionsactions(O(O3 3 -1&8 hr, CO, PM-1&8 hr, CO, PM2.5 2.5 ,MACT Programs),MACT Programs)

Clean Air Act Clean Air Act Amendments 1977 – Amendments 1977 – keeps on giving…..keeps on giving…..

EPA Established New Source Review (NSR)EPA Established New Source Review (NSR)– New Plants and Major Additions to Existing PlantsNew Plants and Major Additions to Existing Plants– Command and Control ProgramsCommand and Control Programs– Designed to Retire Old Units with New Cleaner Designed to Retire Old Units with New Cleaner

UnitsUnits– EPA Rewrite (2003) of NSR Tied-Up in CourtsEPA Rewrite (2003) of NSR Tied-Up in Courts– ~ 66% of utility boilers are 20-40 years old~ 66% of utility boilers are 20-40 years old

New Source Performance Standards New Source Performance Standards (NSPS)(NSPS)– Reasonably Available Control Technologies (RACT)Reasonably Available Control Technologies (RACT)– Best Achievable Control Technology (BACT)Best Achievable Control Technology (BACT)– Lowest Achievable Emissions Rate (LAER)Lowest Achievable Emissions Rate (LAER)

U.S. U.S. Legislative/Regulatory Legislative/Regulatory DriversDrivers

U.S. EPA Regulations Being U.S. EPA Regulations Being ImplementedImplemented– Clean Air Visibility Rule (CAVR) – SOClean Air Visibility Rule (CAVR) – SO22

and NOand NOxx

– Enforcement Cases/NSR – SOEnforcement Cases/NSR – SO22, NO, NOxx, , PM)PM)

– Ozone and PM2.5 NAAQSOzone and PM2.5 NAAQS U.S. EPA Rules Recently Remanded by U.S. EPA Rules Recently Remanded by

CourtCourt– Clean Air Mercury Rule (CAMR)/Utility Clean Air Mercury Rule (CAMR)/Utility

MACT; propose 2010 MACT; propose 2010 – Clean Air Interstate Rule (CAIR); Clean Air Interstate Rule (CAIR);

propose 2010propose 2010 Anticipated Greenhouse Gas Anticipated Greenhouse Gas

RequirementsRequirements– U.S. EPA Climate Change U.S. EPA Climate Change

Requirements/RegulationRequirements/Regulation– 111111thth Congress Climate Change Congress Climate Change

LegislationsLegislations Waxman-MarkeyWaxman-Markey Clean Air Planning Act Clean Air Planning Act

Acid Rain ProgramAcid Rain Program

All 50 States AffectedAll 50 States Affected Fossil-fuel fired power Fossil-fuel fired power

plants > 25 MWplants > 25 MW SOSO22 Cap-n-Trade Cap-n-Trade

ProgramProgram– Phase 1: 1995, 445 Phase 1: 1995, 445

coal-fired unitscoal-fired units– Phase 2: 2000, > 2000 Phase 2: 2000, > 2000

coal-, oil-, gas-fired coal-, oil-, gas-fired units, 10 million ton cap units, 10 million ton cap

– Phase 3: 2008, 8.95 Phase 3: 2008, 8.95 million ton capmillion ton cap

NOx Annual Emissions NOx Annual Emissions Rate ProgramRate Program– Averaging PlansAveraging Plans– Alternative Emission Alternative Emission

LimitsLimits

Clean Air Visibility RuleClean Air Visibility Rule Purpose of RulePurpose of Rule

– Guidelines for States to Guidelines for States to Help Meet Visibility GoalsHelp Meet Visibility Goals

– Achieve Natural Achieve Natural Background Visibility by Background Visibility by 20642064

TimingTiming– June 2005 - Rule Finalized June 2005 - Rule Finalized – December 2007 - State December 2007 - State

SIPs dueSIPs due– December 2013 – December 2013 –

Compliance is 3 Years Compliance is 3 Years after EPA Approves State after EPA Approves State SIPs SIPs

Sources Affected by RuleSources Affected by Rule– 26 Different Source 26 Different Source

CategoriesCategories– Built between 1962 - 1977Built between 1962 - 1977– Units > 250 MW at Plants Units > 250 MW at Plants

with >750 MW Capacitywith >750 MW Capacity– ~ 500 BART Eligible Units~ 500 BART Eligible Units

Mercury Control Mercury Control Technology DriversTechnology Drivers

Clean Air Mercury Rule (CAMR)Clean Air Mercury Rule (CAMR)

– 38 ton cap in 2010 and 15 38 ton cap in 2010 and 15

ton cap in 2018ton cap in 2018

– Regulate EGU Hg emissions Regulate EGU Hg emissions

(Sec. 111)(Sec. 111)

Hg Emissions Control ApproachHg Emissions Control Approach

– Activated Carbon Injection Activated Carbon Injection

Systems Systems

– Co-benefit Control from SOCo-benefit Control from SO22, ,

NONOxx and PM Controls and PM Controls

LitigationLitigation

– CAMR vacated Feb 8, 2009 CAMR vacated Feb 8, 2009

State Mercury Regulations State Mercury Regulations – More than 20 states have More than 20 states have

proposed, finalized or proposed, finalized or implemented mercury implemented mercury limits or allocations more limits or allocations more stringent than CAMRstringent than CAMR

– State Model Rule State Model Rule ( NACAA)( NACAA)

Option IOption I– Phase I 80% Phase I 80% – Phase II 90-95 % Phase II 90-95 %

Option IIOption II– Co-benefit (SO2, Co-benefit (SO2,

NOx, PM and Hg) NOx, PM and Hg) by 2012by 2012

No tradingNo trading

– IL, MI, MN aggressive Hg IL, MI, MN aggressive Hg Emission reduction Emission reduction targets.targets.

Mercury plusMercury plus

February 8, 2008 - the D.C. Circuit vacated EPA's rule February 8, 2008 - the D.C. Circuit vacated EPA's rule removing power plants from the Clean Air Act list of removing power plants from the Clean Air Act list of sources of hazardous air pollutants. At the same time, sources of hazardous air pollutants. At the same time, the Court vacated the Clean Air Mercury Rule. the Court vacated the Clean Air Mercury Rule.

February 6, 2009 - DOJ, on behalf of EPA, asked the February 6, 2009 - DOJ, on behalf of EPA, asked the Supreme Court to dismiss EPA’s request that the Court Supreme Court to dismiss EPA’s request that the Court review the D.C. Circuit Court’s vacatur of the Clean Air review the D.C. Circuit Court’s vacatur of the Clean Air Mercury Rule (CAMR). Mercury Rule (CAMR).

EPA moving forward on a rule broader than coal-fired EPA moving forward on a rule broader than coal-fired power plants and beyond mercury; “informed” by the power plants and beyond mercury; “informed” by the courts.courts.

At least 25 states have mercury control regulations / At least 25 states have mercury control regulations / legislation.legislation.

United Nations addressing global fate of mercury.United Nations addressing global fate of mercury. Mercury CEMS sales for power plants peaked in 2008; a Mercury CEMS sales for power plants peaked in 2008; a

few being supplied to steel mills and foundries.few being supplied to steel mills and foundries.

GHG Control Technology GHG Control Technology DriversDrivers

U.S. EPA Advance Notice of Proposed U.S. EPA Advance Notice of Proposed Rulemaking for GHGRulemaking for GHG

Final (9/09) Mandatory Reporting of Final (9/09) Mandatory Reporting of Greenhouse Gases RuleGreenhouse Gases Rule

U.S. EPA Proposed Rule for Geological U.S. EPA Proposed Rule for Geological Sequestration of Carbon DioxideSequestration of Carbon Dioxide

Regional Greenhouse Gas Initiative Regional Greenhouse Gas Initiative Western Climate Initiative Western Climate Initiative Waxman-Markey Legislation Waxman-Markey Legislation

Final Mandatory Final Mandatory Reporting of Greenhouse Reporting of Greenhouse Gases RuleGases Rule EPA Finalized on Sept. 22, 2009.EPA Finalized on Sept. 22, 2009. Starts January 1, 2010; requires 10,000 facilities Starts January 1, 2010; requires 10,000 facilities

to collect GHG data. to collect GHG data. Covers approx. 85% of GHG emissions.Covers approx. 85% of GHG emissions. Includes facilities that emit 25,000 metric tons or Includes facilities that emit 25,000 metric tons or

more of CO2 equivalent per year.more of CO2 equivalent per year. First annual reports for calendar year 2010, will First annual reports for calendar year 2010, will

be submitted to EPA in 2011. Defined GH gasesbe submitted to EPA in 2011. Defined GH gases CO2, CH4, N2O, HFC, PFC, SF6CO2, CH4, N2O, HFC, PFC, SF6 Applies upstream and downstream Applies upstream and downstream

– Upstream: fossil fuel and chemical producers and Upstream: fossil fuel and chemical producers and importers importers

– Downstream: direct GHG emitters- large industrial Downstream: direct GHG emitters- large industrial facilitiesfacilities

SCAQMD PM ProposalSCAQMD PM Proposal

8/09 Proposed Performance and Maintenance 8/09 Proposed Performance and Maintenance Standards for PM Control DevicesStandards for PM Control Devices

Performance Rule 115 to reduce direct PM emissions from Performance Rule 115 to reduce direct PM emissions from various source categories venting by establishing various source categories venting by establishing performance (PM and opacity) standards, use of certified performance (PM and opacity) standards, use of certified filtration devices, monitoring equipment, mandatory filtration devices, monitoring equipment, mandatory operation and maintenance plans to maintain optimum operation and maintenance plans to maintain optimum efficiency. efficiency.

PR 1155 applies to more than 1,500 facilities with nearly PR 1155 applies to more than 1,500 facilities with nearly 5,000 currently active permits for PM control devices. The 5,000 currently active permits for PM control devices. The affected sources include:affected sources include:

aggregate and related operations, aggregate and related operations, cement and asphalt plants, cement and asphalt plants, food products, food products, metallurgical, metallurgical, pharmaceutical, pharmaceutical, textile and wood products, textile and wood products, chemical product manufacturing. chemical product manufacturing.

SCAQMD PM Proposal-SCAQMD PM Proposal-ControlsControls Most (74%) of permitted sources have baghouses and vent Most (74%) of permitted sources have baghouses and vent

bins; remaining (24 %) have cyclones, ESPs, and wet bins; remaining (24 %) have cyclones, ESPs, and wet scrubbers.scrubbers.

Baghouse performance standard outlet PM concentration limit Baghouse performance standard outlet PM concentration limit and a performance standard for new hood and ventilation and a performance standard for new hood and ventilation systems. systems. – PM emissions at the outlet of any Tier 2 (>500-7,500 sq ft) PM emissions at the outlet of any Tier 2 (>500-7,500 sq ft)

or Tier 3 (>7,500 sq ft) baghouse shall not exceed 0.01 or Tier 3 (>7,500 sq ft) baghouse shall not exceed 0.01 gr/dscf, immediately upon adoption of the rule. gr/dscf, immediately upon adoption of the rule.

– Baghouse upgrade – Effective January 1, 2012, an existing Baghouse upgrade – Effective January 1, 2012, an existing manual shaker shall be upgraded or replaced to, at a manual shaker shall be upgraded or replaced to, at a minimum, an automated shaker unit. An operator shall minimum, an automated shaker unit. An operator shall not install a manual shaker baghouse after adoption of the not install a manual shaker baghouse after adoption of the rule. rule.

– If the PM emission limit (0.01 gr/dscf) is exceeded, EPA’s If the PM emission limit (0.01 gr/dscf) is exceeded, EPA’s verified filtration products or other technologies or verified filtration products or other technologies or methods approved by the Executive Officer shall be used, methods approved by the Executive Officer shall be used, within three months, to meet the applicable requirements. within three months, to meet the applicable requirements.

SCAQMD PM Proposal-SCAQMD PM Proposal-MonitoringMonitoringThe monitoring requirements: The monitoring requirements: five-minute visible emissions observation five-minute visible emissions observation

once a week using EPA Method 22 and once a week using EPA Method 22 and continuous baghouse performance continuous baghouse performance monitoring using a bag leak detection monitoring using a bag leak detection system (BLDS) for Tier 3 units. system (BLDS) for Tier 3 units.

A continuous opacity monitoring system A continuous opacity monitoring system (COMS) installed at an existing Tier 3 (COMS) installed at an existing Tier 3 baghouse will changed to a BLDS, no later baghouse will changed to a BLDS, no later than January 1, 2015 or after the end of than January 1, 2015 or after the end of the useful life of a COMS, whichever the useful life of a COMS, whichever occurs sooner.occurs sooner.

NESHAP for Existing NESHAP for Existing Stationary EnginesStationary Engines

Stationary engine population (2008)Stationary engine population (2008) Gas-fired engines – 320,000Gas-fired engines – 320,000 Diesel engines – 1,100,000Diesel engines – 1,100,000 Over 80% of stationary diesel engines are Over 80% of stationary diesel engines are

used in emergency power applicationsused in emergency power applications Non-Emergency ApplicationsNon-Emergency Applications

– Power generationPower generation– Oil and gas transmission (e.g., pipeline compression Oil and gas transmission (e.g., pipeline compression

and transport)and transport)– Agricultural (e.g., irrigation pumps, electricity Agricultural (e.g., irrigation pumps, electricity

generation, etc.)generation, etc.)– Other –pumps, welders, etc.Other –pumps, welders, etc.

NESHAP for Existing NESHAP for Existing Stationary EnginesStationary Engines

Stationary engines are contributors of:Stationary engines are contributors of:– NOx, VOC, HAP, CO, CO2, PM2.5(including NOx, VOC, HAP, CO, CO2, PM2.5(including

carbon black)carbon black)– Diesel PM2.5emissions from stationary Diesel PM2.5emissions from stationary

engines are less than 10% of total diesel engines are less than 10% of total diesel PM2.5mobile inventoryPM2.5mobile inventory

Exhaust after treatment controls for non-Exhaust after treatment controls for non-emergency enginesemergency engines– Diesel > 300 HP at major or area sourceDiesel > 300 HP at major or area source– 2-and 4-stroke lean burn gas-fired2-and 4-stroke lean burn gas-fired

250-500 HP at major source250-500 HP at major source ≥≥250 HP at area source250 HP at area source

– 4-stroke rich burn gas-fired4-stroke rich burn gas-fired– 50-500 HP at major source50-500 HP at major source– ≥≥50 HP at area source50 HP at area source

NESHAP for Existing NESHAP for Existing Stationary EnginesStationary Engines

Limits are based on:Limits are based on:– Oxidation catalyst for diesel and 2-and 4-stroke Oxidation catalyst for diesel and 2-and 4-stroke

lean burn gas-firedlean burn gas-fired Up to 90% reduction for HAP, CO, and Up to 90% reduction for HAP, CO, and

VOC; 25-30% reduction for PM2.5VOC; 25-30% reduction for PM2.5– Non-selective catalytic reduction for 4-stroke rich Non-selective catalytic reduction for 4-stroke rich

burn gas-firedburn gas-fired Up to 90% reduction for HAP, CO and NOxUp to 90% reduction for HAP, CO and NOx

– Although most emission reductions target non-Although most emission reductions target non-emergency engines, limits are set for both emergency engines, limits are set for both emergency and non-emergency engines located emergency and non-emergency engines located at major sources (per Brick MACT court decision)at major sources (per Brick MACT court decision)

Compliance Compliance RequirementsRequirements Performance testingPerformance testing

– Initial test only for:Initial test only for: non-emergency engines 100-500 HP at major sourcenon-emergency engines 100-500 HP at major source area sources subject to numerical standards (versus area sources subject to numerical standards (versus

management practices)management practices)– Initial test plus subsequent test every 3 years or Initial test plus subsequent test every 3 years or

8,760 hours for:8,760 hours for: non-emergency engines >500 HP (major or area non-emergency engines >500 HP (major or area

source)source)– No test requirements for emergency enginesNo test requirements for emergency engines

Monitoring requirements for large enginesMonitoring requirements for large engines Ultra-low sulfur diesel fuel for non-Ultra-low sulfur diesel fuel for non-

emergency CI > 300 HPemergency CI > 300 HP

Portland Cement - NSPSPortland Cement - NSPS

June ’08 proposed NSPS June ’08 proposed NSPS – reduce the PM emission limit for kilns from 0.3 reduce the PM emission limit for kilns from 0.3

lb/ton of dry feed to 0.086 lb/ton of clinkerlb/ton of dry feed to 0.086 lb/ton of clinker– set limit on NOX emissions from kilns of 1.50 set limit on NOX emissions from kilns of 1.50

lb/ton of clinker.lb/ton of clinker.– set limit on SO2 emissions from kilns of 1.33 set limit on SO2 emissions from kilns of 1.33

lb/ton of clinker, or demonstrate a reduction in lb/ton of clinker, or demonstrate a reduction in SO2 emissions from the kiln of at least 90 SO2 emissions from the kiln of at least 90 percent.percent.

– add new monitoring options of a bag leak add new monitoring options of a bag leak detector or PM CEMS for kilns and clinker detector or PM CEMS for kilns and clinker coolers to demonstrate compliance with the PM coolers to demonstrate compliance with the PM limits in lieu of the requirement for continuous limits in lieu of the requirement for continuous opacity monitoring systems (COMS).opacity monitoring systems (COMS).

Portland Cement -Portland Cement -NESHAPNESHAP

May ’09 proposed NESHAP/MACT for cement kilns or cement May ’09 proposed NESHAP/MACT for cement kilns or cement kilns/in-line raw mills; coolers and dryers kilns/in-line raw mills; coolers and dryers – Proposed performance specifications for mercury CEMS, and Proposed performance specifications for mercury CEMS, and

updating recordkeeping and testing requirements. PS-12A and updating recordkeeping and testing requirements. PS-12A and PS12-B.PS12-B.

– Mercury - emissions limit of 43 lb/million tons clinker for existing Mercury - emissions limit of 43 lb/million tons clinker for existing sources and 14 lb/MM tons clinker for new sources. 30 day rolling sources and 14 lb/MM tons clinker for new sources. 30 day rolling average.average.

– THC THC - - emissions limit of 7 parts per million by volume (ppmv) for emissions limit of 7 parts per million by volume (ppmv) for existing sources and 6 ppmv for new sources (measured dry and existing sources and 6 ppmv for new sources (measured dry and corrected to 7 percent oxygen). 30 rolling day average. PS-8A.corrected to 7 percent oxygen). 30 rolling day average. PS-8A.

– PM - an emissions limit of 0.085 pounds per ton (lb/ton) clinker PM - an emissions limit of 0.085 pounds per ton (lb/ton) clinker for existing sources and 0.080 lb/tons clinker for new sources. PM for existing sources and 0.080 lb/tons clinker for new sources. PM CEMS/PS-11. Remove opacity requirements in lieu of PM CEMS/PS-11. Remove opacity requirements in lieu of PM measurement.measurement.

– Hydrochloric Acid -Hydrochloric Acid - emissions limit of 2 ppmv for existing sources emissions limit of 2 ppmv for existing sources and 0.1 ppmv for new sources, required to use a CEMS/PS-15.and 0.1 ppmv for new sources, required to use a CEMS/PS-15.

Proposed Cement MACT Proposed Cement MACT Emission LimitsEmission Limits

Proposed Emissions LimitProposed Emissions Limitaa

Range of Range of Current Current

EmissionsEmissions Existing SourceExisting Source New SourceNew Source

HgHg12 to 3,300 12 to 3,300 lb/MM tons lb/MM tons clinker clinker

43 lb/MM tons 43 lb/MM tons clinker clinker (30 day average)(30 day average)

14 lb/MM tons 14 lb/MM tons feed feed (30 day (30 day average)average)

THCTHC(Surrogate for (Surrogate for Organic HAP)Organic HAP)

<1 to 173 <1 to 173 ppmvppmv

7 ppmv for all 7 ppmv for all kilnskilnsbb

(30 day average)(30 day average)

6 ppmv for all 6 ppmv for all kilnskilns

(30 day (30 day average)average)

PM PM (Surrogate for (Surrogate for nonmercury nonmercury metal HAP)metal HAP)

0.005 to 0.50 0.005 to 0.50 lb/ton clinkerlb/ton clinker

0.085 lb/ton 0.085 lb/ton clinkerclinker

0.080 lb/ton 0.080 lb/ton clinkerclinker

HClHCl <1 to 75 ppmv<1 to 75 ppmv 2 ppmv 2 ppmv 0.1 ppmv 0.1 ppmv a For Hg, THC, and PM these limits would apply to major and area sources. For HCl these limits only apply to major sources.

b We believe this value may be biased low due to lack of data.

Industrial BoilersIndustrial Boilers

Renewed focus on new and Renewed focus on new and existing boilers will generate existing boilers will generate demand for controls and CEMSdemand for controls and CEMS

Over 250 new boilers out Over 250 new boilers out through 2012; with steady through 2012; with steady growth of CEMS.growth of CEMS.

Over 500 existing boilers to be Over 500 existing boilers to be retrofit with CEMS 2010-2012.retrofit with CEMS 2010-2012.

Industrial Boiler MACT Industrial Boiler MACT Requirements Requirements EPA Promulgated Industrial Boiler EPA Promulgated Industrial Boiler

Maximum Achievable Control Technology Maximum Achievable Control Technology (MACT) Rule in 2004.(MACT) Rule in 2004.– The rule intended to control emissions of hazardous The rule intended to control emissions of hazardous

air pollutants (HAPs) from industrial, commercial, air pollutants (HAPs) from industrial, commercial, and institutional boilers and process heaters.and institutional boilers and process heaters.

– EPA anticipated ~58,000 existing sources to be EPA anticipated ~58,000 existing sources to be affected. (42,000 boilers and 15,000 process affected. (42,000 boilers and 15,000 process heaters)heaters)

Three Main SubcategoriesThree Main Subcategories– Solid fuel sourcesSolid fuel sources– Liquid fuel sourcesLiquid fuel sources– Gaseous fuel sourcesGaseous fuel sources

Industrial Boiler MACTIndustrial Boiler MACT

Additional RequirementsAdditional Requirements– Alternative compliance optionsAlternative compliance options– Emissions averaging for all large-Emissions averaging for all large-

solid fuel fired boilers located at one solid fuel fired boilers located at one site.site.

– Health based emissions limitsHealth based emissions limits– Three ways to verify compliance Three ways to verify compliance

alternative eligibility alternative eligibility

Existing Boiler Emission Existing Boiler Emission StandardsStandards

New Boiler Emission New Boiler Emission StandardsStandards

SubcategorSubcategoryy

Emission Standards (lb/MM Btu)Emission Standards (lb/MM Btu)

PM or PM or TSMTSM

HCLHCL MercuryMercury COCO

New Solid New Solid fuel unitsfuel units

0.0250.025.0003.0003

.02 .02 (20ppm(20ppm))

3.0 3.0 lb/TBtulb/TBtu

400 ppm 400 ppm @7% O2@7% O2

New liquid New liquid fuel unitsfuel units

.03.03 .0005.0005 400 ppm 400 ppm @ 3 %O2@ 3 %O2

Compliance OptionsCompliance Options

Conduct stack emission testsConduct stack emission tests Conduct fuel analysisConduct fuel analysis Emissions Averaging (large solid Emissions Averaging (large solid

fuel units only)fuel units only) Health based compliance Health based compliance

alternative for HCl and TSM.alternative for HCl and TSM.

Compliance MonitoringCompliance Monitoring

Compliance Monitoring Compliance Monitoring (cont.)(cont.)

• Continuous compliance based on monitoring Continuous compliance based on monitoring and maintaining operating limitsand maintaining operating limits

• MonitoringMonitoring• Opacity (COMS)- dry control systemsOpacity (COMS)- dry control systems• Fuel (monthly records)Fuel (monthly records)• Scrubber parametersScrubber parameters• CO (new units only)CO (new units only)

• CEMS for large units >100 million Btu hrCEMS for large units >100 million Btu hr• Annual CO test for other new unitsAnnual CO test for other new units• Exempt data from < 50 % load and Exempt data from < 50 % load and

based upon a 30 day average.based upon a 30 day average.

Petitions for Petitions for ReconsiderationReconsideration

– EPA Received three petitions for reconsiderationEPA Received three petitions for reconsideration Request clarification that rule allows for testing at the Request clarification that rule allows for testing at the

common stack rather than each stackcommon stack rather than each stack Lack of standards for all HAPs emitted on all subcategoriesLack of standards for all HAPs emitted on all subcategories Health based compliance alternativesHealth based compliance alternatives

– State stakeholders questioned EPA’s emission data for State stakeholders questioned EPA’s emission data for affected sources used to set MACT flooraffected sources used to set MACT floor

National Association for Clean Air Agencies (NACAA) issued National Association for Clean Air Agencies (NACAA) issued permit guidance documentpermit guidance document

EPA issued a new Information Collection Request (ICR)EPA issued a new Information Collection Request (ICR)– 350 sources expected to report emissions data by Sept 350 sources expected to report emissions data by Sept

2009.2009.– Court ordered EPA to re-propose rule by July 2009 and issue Court ordered EPA to re-propose rule by July 2009 and issue

final rule by July 2010.final rule by July 2010.

Compliance TestingCompliance Testing

Performance Test RequirementsPerformance Test Requirements– Common EPA test method for PM, TSM, HCl, Common EPA test method for PM, TSM, HCl,

mercury and CO limitsmercury and CO limits EPA Method 1,2, 3,4 and 19EPA Method 1,2, 3,4 and 19

– For PM EPA Methods 5 or 17For PM EPA Methods 5 or 17– For TSM EPA Methods 29For TSM EPA Methods 29– For HCl EPA Methods 26 or 26AFor HCl EPA Methods 26 or 26A– For Mercury Methods 29 or 101AFor Mercury Methods 29 or 101A

ASTM D6422-00 or PTC 19, Part 10ASTM D6422-00 or PTC 19, Part 10– For CO EPA Methods 10, 10A or 10BFor CO EPA Methods 10, 10A or 10B

ASTM D6422-00 (natural gas only)ASTM D6422-00 (natural gas only)

Proposed RulesProposed Rules

Methods to Measure Filterable and Methods to Measure Filterable and Condensable PM Emissions (methods Condensable PM Emissions (methods 201 & 202 mods.)201 & 202 mods.)

Standards of Performance for New Standards of Performance for New Sources: Test Method 2H – Sources: Test Method 2H – volumetric stack flow for Title IV/SIP volumetric stack flow for Title IV/SIP sourcessources

Refineries – proposed June ’08 NSPS Refineries – proposed June ’08 NSPS – PM, NOx, SO2, CO THC– PM, NOx, SO2, CO THC

Why Accurate Why Accurate MeasurementsMeasurements

CEMS require CEMS require daily calibrationdaily calibration

Without regular Without regular calibration the calibration the monitors may be monitors may be reporting reporting incorrectly which incorrectly which could be costly!could be costly!

Verify accurate Verify accurate readings due to readings due to drift for CEMS drift for CEMS and other gas and other gas analyzers.analyzers.

Thank YouThank YouDavid C. Foerter, Executive David C. Foerter, Executive

DirectorDirectordfoerter@icac.comdfoerter@icac.com

(202) 457-0911(202) 457-0911

Institute of Clean Air CompaniesInstitute of Clean Air Companies

1730 M Street, NW, Suite 2061730 M Street, NW, Suite 206Washington, DC 20036Washington, DC 20036www.icac.comwww.icac.com