BACT Issues – A Technical
Perspective
Presented to:
American Public Power Association
APPA New Generation Meeting: Anticipating New Permitting
Issues,
IGCC Technology Options, Atmospheric Modeling,
and Anticipating the Public’s Reaction
Presented by:
Jennifer Sharp Seinfeld, P.E.
Principal
Zephyr Environmental Corporation
© 2004 Zephyr Environmental Corporation
June 28, 2006
Outline of Presentation
•References for developing BACT
analysis
• Overall BACT considerations
•Pollutant-specific
issues/precedents for PC boilers
•Mercury
© 2004 Zephyr Environmental Corporation
Finding Information
• The good news…
– A lot of useful relevant information is
on the web
• The bad news…
– A lot of useful relevant information is
on the web!
© 2004 Zephyr Environmental Corporation
Identifying Relevant Projects
• RBLC Clearinghouse
http://cfpub.epa.gov/rblc/cfm/basicsearch.cfm
• National Coal-fired Utility Projects spreadsheet (updated
10/05) – verify accuracy
(http://www.epa.gov/ttncatc1/products.html#misc)
• DOE Summary of Coal-fired projects (03/06)
( http://www.netl.doe.gov/coal/refshelf/ncp.pdf
• Clean Air Task Force - New Coal Plant Opposition Draft
and Final Permits
(http://www.catf.us/projects/power_sector/new_coal_plant_opposition/permits.php)
• Networking
• Summaries contained in recently submitted permit
applications
© 2004 Zephyr Environmental Corporation
References for Emission Limits
and BACT Discussions
• RBLC Clearinghouse
• Other permits (final, draft proposed)
• Permit applications, related documents,
hearing transcripts, written comments and
other correspondence
• Test/CEMS data from existing units
• Acid Rain database for historical SO2
emissions
http://www.epa.gov/airmarkets/emissions/prelimarp/index.html
• EPA dockets
(http://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/)
• State and regional databases
© 2004 Zephyr Environmental Corporation
Important BACT Considerations
• Type of unit
• Fuel type, sulfur content
• Averaging times, different limits for
different averaging times
• Cost-effectiveness analyses
• Startup, shutdown, malfunction emissions
• Method of demonstrating ongoing
compliance
–CEMS
–Test methods
© 2004 Zephyr Environmental Corporation
“Tuning” Periods/Feasibility
Studies
• The ‘middle ground’ in negotiations
• Pros:
– Progress toward permit issuance and start of
project
– Flexibility in not having to be in compliance
with a challenging limit immediately
• Cons:
–Review/regulatory scrutiny continues
© 2004 Zephyr Environmental Corporation
Planned PC Boiler Installations
Plant/Location
Description (size, fuel)
Status
800 MW; PRB coal
Application filed 6/06
Duke Energy
Cliffside Steam Station (# 5 and 6), NC
2 800 MW units;N. Appalachian
and eastern bituminous coal
Application submitted 5/06
Nets out of PSD for SO2 and HF
TXU - Big Brown (#3), Monticello (#4),
Martin Lake (#4), TX
3 800 MW units; PRB coal
Application submitted 4/06
800 MW, PRB and other
Permit issued 5/06
2 800 MW units; lignite
Application submitted 1/05; contested hearing
ended 6/06
750 MW, PRB coal
Netted out of Fed PSD for NOx and SO2
Permit issued 12/05; construction started!
850 MW, subbituminous coal
Permit issued 1/06
Construction to start in late '06; targeted to go
into service '10
275 MW, subbituminous
Permit issued 12/04. Funding approved 6/06!
116 MW, PRB
Permit issued 1/06 construction began 03/06.
675 MW, PRB coal
Permit issued 8/05; scheduled to begin
operation in 2010
750 MW, subbituminous coal
Permit issued 7/05; netted out of PSD for SO2
was under appeal, 6/06 District Court issued
order upholding PSD permit
NRG, Limestone #3, TX
Sandy Creek Energy Station, TX
TXU, Oak Grove (#1, #2), TX
CPS of San Antonio, JK Spruce, TX
Great Plains Energy, Kansas City P&L,
Iatan (#2), MO
City Utilities of Springfield Southwest,
MO
Rocky Mount Power, Hardin
Generating Station, MT
Big Cajun 2 (#4), LA
Xcel Energy Comanche Station (#3),
CO
© 2004 Zephyr Environmental Corporation
Planned PC Boiler Installations
(continued)
Plant/Location
Newmont Nevada Energy, TS plant, NV
Peabody Energy Corp Prairie State
Generating Station, IL
Omaha Public Power Nebraska City
Station, NE
Longview Power, WV
Hastings Utilities, Whelan Energy
Center #2, NE
Wisconsin Public Service, Weston
Plant, WI
Intermountain Power Service Corp, UT
Plum Point Energy, AR
© 2004 Zephyr Environmental Corporation
Description (size, fuel)
Status
200 MW, PRB coal
Permit issued 5/05
Under construction; proposed online
date 6/08
2 750 MW, bituminous (can also
use Illinois No. 5/6 coal)
Permit issued 4/05
Construction not started as of 6/06
660 MW, PRB coal
Permit issued 3/05
Construction started 10/05; expected
online May '09
600 MW, bituminous
Permit issued 3/04
Final settlement on air permit appeal
7/04
220 MW, PRB coal
Permit issued 3/04
Construction started summer '05;
anticipated online '09
500 MW, PRB coal
Approval granted 10/04; appealed but permit
upheld; permit finalized 2/06
Construction started 11/04; anticipated
online in '08
~900 MW, PRB coal
Permit issued 10/04 (appeal denied due to
standing); construction scheduled to
begin spring, 2007
800 MW, PRB coal
Permit issued 8/03
Construction began 4/06; commercial
operation targeted for '10
Planned PC Boiler Installations
(continued)
Plant/Location
MidAmerican Energy (#4),Council
Bluffs, IA
Bull Mountain Roundup, MT
Thoroughbred, KY
Louisville G&E, Trimble Station, KY
Wisconsin Energy Elm Road, WI (Oak
Creek)
Peabody Mustang Energy, NM
Santee Cooper (#3 & 4), SC
© 2004 Zephyr Environmental Corporation
Description (size, fuel)
790 MW, PRB coal
Status
Permit issued 6/03 construction started
September 2003; plans to be in service
summer '07
2 390 MW, subbituminous
Permit issued '03; extension issued
11/05 to 12/06 with more stringent
controls; no construction yet
2 750 MW, bituminous
Permit issued 10/02;
Permit revised 12/02 and 2/05;
challenged by Sierra Club 12/05, permit
remanded for BACT analysis
750 MW, eastern bituminous
draft permit 7/05; (nets out of PSD for NOx and
SO2)
Approved 3/06; plans to begin
construction 7/06
2 615 MW, bituminous
Permit issued 1/04; construction began 7/05;
proposed in service: first unit in 2009;
second in 2010
300 MW, Clean Coal Initiative
grant from DOE
2 660 MW, Bituminous
10/04 received DOE grant from DOE.
5/06 news article says project on hold. .
Permit issued 2/04; construction underway.
April '06 announcement to build another
600MW facility near Kingsburg SC
Planned PC Boiler Installations
(continued)
Plant/Location
Unisource Energy Tucson Electric, AZ
Black Hills Wygen 2, WY
Sand Sage Power, KS
Description (size, fuel)
Status
2 400 MW units
Permit issued 4/02; (netted out of PSD for SO2)
under construction; hopes to be online late
'06
500 MW, subbituminous
660 MW, PRB
Longleaf Energy Associates, GA
2 600 MW, PRB or Central
Appalachian bituminous
Cornbelt Energy, Prairie Energy Plant,
IL
91 MW ; partially funded by
DOE to test new coal
reburn system for lower
NOx emissions
© 2004 Zephyr Environmental Corporation
Permit issued 9/02
Construction began 8/05, expected finish
by early '08
Permit issued 10/02; revised 6/05
Permit 11/04
Permit issued 12/02
SO2 PC BACT Emission Rates
Plant/Location
Fuel
Emission Limit and Type of
Scrubber
Duke Energy
Cliffside Steam
Station (# 5 and
6), NC
N. Appalachian and
eastern
bituminous coal
TXU - Big Brown (#3),
Monticello (#4),
Martin Lake (#4),
TX
PRB subbituminous coal
Sandy Creek Energy
Station, TX
PRB and other coal
TXU, Oak Grove (#1,
#2), TX
Lignite
0.192 (30 day rolling)
wet scrubber
CPS of San Antonio, JK
Spruce, TX
PRB coal
0.10 (30 day rolling)
0.06 (12-month rolling)
wet scrubber
Great Plains Energy,
Kansas City P&L,
Iatan (#2), MO
Subbituminous coal
0.09 (30-day rolling)
wet scrubber
City Utilities of
Springfield
Southwest, MO
Subbituminous
© 2004 Zephyr Environmental Corporation
Unknown limits
wet scrubber
0.10 (12 month rolling)
dry scrubber
Comments
project nets out of PSD
for SO2; no SO2
limits included in
PSD application
Proposed limit in
application
0.10 (12 month rolling)
0.12 (30 day rolling)
dry scrubber
0.095 (30-day rolling)
dry scrubber
Originally limit was 0.12,
but was changed
to 0.095 during
BACT and
visibility
negotiations.
SO2 PC BACT Emission Rates
(continued)
Plant/Location
Rocky Mount Power,
Hardin
Generating
Station, MT
Big Cajun 2 (#4), LA
Xcel Energy
Comanche
Station (#3),
CO
Newmont Nevada
Energy, TS
plant, NV
Fuel
PRB
PRB coal
Emission Limit and Type of
Scrubber
Comments
0.12 during 18 month optimization
period; 0.11 (30-day rolling)
thereafter
dry scrubber
Provides for optimization
period
0.10 ( 30 day)
wet or dry scrubber
Subbituminous coal
0.10 (30 day rolling)
dry scrubber
PRB coal
if S content >0.45%,
0.09 (24-hour rolling)
95% (30-day rolling)
If S content <0.45%,
0.065 (24 hr rolling)
91% (30-day)
dry scrubber
Peabody Energy Corp
Prairie State
Generating
Station, IL
Bituminous
Omaha Public Power
Nebraska City
Station, NE
PRB coal
© 2004 Zephyr Environmental Corporation
0.182 (30-day rolling)
wet scrubber
98% control (12-month rolling),
effective 18 months after start-up
0.095 (30-day)
dry scrubber
Permit provides for
evaluating both
wet and dry
scrubbing
systems
Project netted out of
PSD for SO2; limit
not considered
BACT
Different requirements
depending on S
content; %
removal;
Not required to wash
mine-mouth coal,
but required to
wash IL No. 5&6
coal
SO2 PC BACT Emission Rates
(continued)
Plant/Location
Fuel
Emission Limit and Type of
Scrubber
0.12 (24-hr rolling)
0.095 (calendar year)
part of settlement agreement
wet scrubber
Longview Power, WV
Bituminous
Hastings Utilities,
Whelan Energy
Center #2, NE
PRB coal
0.12 (30-day), 1.1 (3-hr rolling)
dry scrubber
Wisconsin Public
Service,
Weston Plant,
WI
PRB coal
0.10 (30-day rolling)
0.09 (12-month rolling)
dry scrubber
Intermountain Power
Service Corp,
UT
PRB coal
0.09 (30-day)
wet scrubber
Plum Point Energy,
AR
PRB coal
0.16
dry scrubber
MidAmerican Energy
(#4),Council
Bluffs, IA
PRB coal
0.10 (30 day rolling)
dry scrubber
Bull Mountain
Roundup, MT
Subbituminous
© 2004 Zephyr Environmental Corporation
0.12
dry scrubber
Comments
WVDEP stated that the
0.095 was not
considered BACT
Limits include SSM
emissions; also
mass limits on 3hr rolling
averages
Does not include SSM
emissions
SO2 PC BACT Emission Rates
(continued)
Plant/Location
Fuel
Emission Limit and Type of
Scrubber
Thoroughbred, KY
Bituminous
0.167
wet scrubber, wet ESP
Wisconsin Energy Elm
Road, WI (Oak
Creek)
Bituminous
0.15
dry scrubber
Santee Cooper (#3 &
4), SC
Bituminous
Black Hills Wygen 2,
WY
Subbituminous
0.10 (30-day)
dry scrubber
Sand Sage Power, KS
Subbituminous
0.12 (30-day)
dry scrubber
Longleaf Energy
Associates, GA
PRB, subbituminous or
central Appalachian
bituminous
0.12 (30-day)
dry scrubber
Cornbelt Energy,
Prairie Energy
Plant, IL
© 2004 Zephyr Environmental Corporation
0.13 (annual average)
wet scrubber
0.15
wet scrubber
Comments
BACT being reevaluated
PSD avoidance limits
SO2 BACT Issues
• The basics:
– Some type of flue gas desulfurization system
(FGD);
– SO2 CEMS
• For BACT analysis in application, typically
expressed in units of lb/MMBtu
• Common to have multiple emission limits for
different averaging times
– Short-term 1 or 3 hrs and/or 24 hrs
– Long-term – 30-day and/or annual
• Coal washing sometimes raised as an issue
• Control efficiency as a permit limit
© 2004 Zephyr Environmental Corporation
SO2 BACT Issues – Wet vs.
Dry Scrubber
• Mix of wet and dry scrubbers in recent
permits; majority are dry scrubbers
• In general, wet scrubbers are more
efficient, but dry scrubbers can still
obtain approval
• Cost-effectiveness arguments
necessary?
• Some with tuning periods
© 2004 Zephyr Environmental Corporation
BACT Arguments for Dry
Scrubbers
•
•
•
•
•
Infrastructure
Maintenance considerations
Power and water requirements
Market for wet scrubber byproducts
Generally, higher ground level
concentrations with wet scrubber
• Better control of sulfuric acid mist, fine
particulates, many HAP emissions
from wet scrubber (?)
© 2004 Zephyr Environmental Corporation
Limits for Dry Scrubbers
• Limits for dry are often contested, and have
been ratcheted downward
– Argument: unrealistic to base SO2 emissions on
continuous use of highest sulfur fuel
– Use of acid rain data base for typical sulfur content
– Examples of recent dry scrubber limits:
• City Utilities of Springfield – 0.12 to 0.095 lb/MMBtu
(30 day rolling average)
• Omaha Public Power Nebraska Cities – 0.10 to
0.095 lb/MMBtu (based on EPA comments)
• WI Public Service, Weston 4 – 0.09 lb/MMBtu (12month average) (based on Sierra Club comments)
• Newmont Nevada Energy – 0.09 lb/MMBtu, if fuel S
content >0.45%; 0.065 lb/MMBtu, if fuel S content
<0.45% S
© 2004 Zephyr Environmental Corporation
NOx PC BACT Emission Rates
Plant/Location
Fuel
Duke Energy
Cliffside Steam Station
(# 5 and 6), NC
N. Appalachian and
eastern bituminous coal
Emission Limit
Comments
0.08 (30 day)
application mentions
consideration of burning
"high NOx" coal
TXU - Big Brown (#3),
Monticello (#4), Martin
Lake (#4), TX
PRB subbituminous coal
0.05 (12-month rolling)
Sandy Creek Energy
Station, TX
PRB and other coal
0.07 (30-day rolling)
0.05 (12-month rolling)
TXU, Oak Grove (#1,
#2), TX
Lignite
0.08 (30-day rolling)
Must specify 0.05 in
proposals; 2-year
demonstration period
0.069 (30 day rolling)
0.05 (12-month rolling)
Option for optimization
study for NOx, PM10,
Hg, H2SO4
CPS of San Antonio, JK
Spruce, TX
PRB coal
Great Plains Energy,
Kansas City P&L, Iatan
(#2), MO
Subbituminous coal
0.08 (30 day)
City Utilities of
Springfield Southwest,
MO
Subbituminous
0.08 (30-day)
Rocky Mount Power,
Hardin Generating
Station, MT
PRB
0.09 (30-day)
Big Cajun 2 (#4), LA
PRB coal
© 2004 Zephyr Environmental Corporation
0.07 (12 month)
Provides for
optimization period
NOx PC BACT Emission Rates
(continued)
Plant/Location
Xcel Energy Comanche
Station (#3), CO
Fuel
Subbituminous coal
Emission Limit
Comments
0.08 (30 day)
Project netted out of
PSD for NOx, but limit
considered comparable
to BACT; includes SSM,
except for cold start-ups
Newmont Nevada
Energy, TS plant, NV
PRB coal
0.067 (24-hr rolling)
Peabody Energy Corp
Prairie State Generating
Station, IL
Bituminous
0.07 (30-day rolling)
Omaha Public Power
Nebraska City Station,
NE
PRB coal
interim: 0.12 ; after 18 months, 0.07
Allows for optimization
period
0.08 (24-hr)
0.07 (30-day)
0.065 (annual)
WVDEP originally had
0.08 (24 hr rolling) as a
permit limit; has stated
that the 0.065/0.07
limits are not considered
BACT
PRB coal
0.08 (30-day); for first 18 months after
startup, 0.12 (30-day)
18 month demonstration
period
Wisconsin Public
Service, Weston Plant,
WI
PRB coal
0.07 (30-day rolling)
0.06 (12-month rolling)
Limits reduced after
appeal
Intermountain Power
Service Corp, UT
PRB coal
0.07 (30-day)
Longview Power, WV
Bituminous
Hastings Utilities,
Whelan Energy Center
#2, NE
© 2004 Zephyr Environmental Corporation
NOx PC BACT Emission Rates
(continued)
Plant/Location
Fuel
Plum Point Energy, AR
PRB coal
0.07 (30-day rolling)
MidAmerican Energy
(#4),Council Bluffs, IA
PRB coal
0.07 (30-day rolling)
Bull Mountain Roundup,
MT
Subbituminous
Thoroughbred, KY
Bituminous
Louisville G&E, Trimble
Station, KY
Eastern bituminous
Wisconsin Energy Elm
Road, WI (Oak Creek)
Bituminous
0.15
dry scrubber
Santee Cooper (#3 & 4),
SC
Bituminous
0.08 (annual)
Black Hills Wygen 2, WY
Subbituminous
0.07 (30-day)
Sand Sage Power, KS
Subbituminous
0.08 (30-day)
Longleaf Energy
Associates, GA
PRB subbituminous or
Central Appalachian
bituminous
0.07 (30-day)
Cornbelt Energy, Prairie
Energy Plant, IL
© 2004 Zephyr Environmental Corporation
Emission Limit
Comments
0.07 (24-hr)
0.08 (30-day)
Nets out of PSD review
for SO2
0.1
18-month tuning period
allows for 24-month
tuning period
NOx BACT Issues
• The basics:
– Controls: SCR + “combustion controls”
– CEMS
• Averaging time is critical
• Quantity of NOx generated depends on
type of coal(?)
• Ammonia slip
– Approx 3 ppm, annual
– Higher short-term - ~10 ppm, hourly
• Several permits have optimization
studies
© 2004 Zephyr Environmental Corporation
PM/PM10 PC BACT Emission Rates
Plant/Location
Duke Energy
Cliffside Steam
Station (# 5 and 6),
NC
TXU - Big Brown
(#3), Monticello (#4),
Martin Lake (#4)
Sandy Creek Energy
Station
TXU Oak Grove (#1,
#2), TX
CPS of San Antonio,
JK Spruce, TX
Great Plains Energy,
Kansas City P&L,
Iatan (#2), MO
City Utilities of
Springfield
Southwest, MO
Fuel
N. Appalachian and
eastern bituminous coal
Emission Limit and Type of
Controls
0.015 (PM/PM10) for filterable only; no
limit proposed for condensible portion or
for PM2.5
PRB subbituminous coal
0.015 filterable
0.04 filterable + condensible
baghouse
PRB and other coal
0.015 filterable
0.04 filterable + condensible
baghouse
Lignite
0.015 filterable
0.04 filterable + condensible
baghouse
Comments
Application states that little
data is available from wet
ESPs; and does not propose
an emissions limit for PM2.5
or the condensible portion of
PM10
750 MW, PRB coal
0.015 (filterable)
0.022 (filterable + condensible
PM/PM10)
baghouse
Option for optimization study
for NOx, PM10, Hg, H2SO4
Subbituminous coal
0.015 filterable PM (3-hr rolling)
0.014 filterable PM10 (3-hr rolling)
0.0236 total PM10 (30-day rolling)
baghouse
Required to have CEMS for
PM
Subbituminous
© 2004 Zephyr Environmental Corporation
0.018 (3-hr)
baghouse
PM/PM10 PC BACT Emission Rates
(continued)
Plant/Location
Rocky Mount Power,
Hardin Generating
Station, MT
Big Cajun 2 (#4), LA
Xcel Energy
Comanche Station
(#3), CO
Newmont Nevada
Energy, TS plant, NV
Peabody Energy
Corp Prairie State
Generating Station,
IL
Omaha Public Power
Nebraska City
Station, NE
Longview Power,
WV
Fuel
PRB
PRB coal
Subbituminous coal
PRB coal
Bituminous
PRB coal
Bituminous
© 2004 Zephyr Environmental Corporation
Emission Limit and Type of
Controls
Comments
0.015 (filterable) during optimization
period
0.012 (filterable) post optimization
0.024 (filterable and condensible)
fabric filter
Provides for optimization
period
0.015
PM controls depend on which type of
scrubber
Appears to be only filterable;
Method 5 is included in
permit
0.013 (filterable PM)
0.012 filterable PM10
0.022 total PM
0.020 total PM10
baghouse
0.012 (24 hr rolling); filterable only
Total PM10 (filterable and
condensible) factors to be
established during stack test
0.015 filterable PM/PM10
0.035 total PM10
ESP, Wet ESP
Permit stipulates that total
PM/PM10 limit subject to
reduction based on stack test
data
0.018 filterable and condensible
PM/PM10
fabric filter
0.018 6 hr rolling (PM)
0.018 6 hr rolling (PM10, including
filterable and condensible)
wet scrubber
PM/PM10 PC BACT Emission Rates
(continued)
Plant/Location
Fuel
Emission Limit and Type of
Controls
Hastings Utilities,
Whelan
Energy
Center #2, NE
PRB coal
0.018, filterable and condensible
baghouse
Wisconsin Public
Service,
Weston Plant,
WI
PRB coal
0.02 PM10 (includes filterable and
condensible)
Intermountain Power
Service Corp,
UT
PRB coal
0.012 PM10
0.013 PM
baghouse
Plum Point Energy,
AR
PRB coal
0.018
baghouse
MidAmerican Energy
(#4),Council
Bluffs, IA
PRB coal
0.027 PM
0.025 PM10 (includes
condensibles)
baghouse
Bull Mountain
Roundup, MT
Subbituminous
© 2004 Zephyr Environmental Corporation
0.015
baghouse
Comments
PM/PM10 PC BACT Emission Rates
(continued)
Plant/Location
Fuel
Emission Limit and Type of
Controls
0.018 PM (no condensibles)
wet scrubber, wet ESP
Thoroughbred, KY
Bituminous
Wisconsin Energy
Elm Road, WI
(Oak Creek)
Bituminous
0.018
wet ESP
Santee Cooper (#3 &
4), SC
Bituminous
0.015 (PM)
0.018 (PM10)
scrubber
Unisource Energy
Tucson
Electric, AZ
Type of coal
Black Hills Wygen 2,
WY
Subbituminous
0.012
fabric filter
Sand Sage Power,
KS
Subbituminous
0.015 Fabric filter
Longleaf Energy
Associates,
GA
PRB, subbituminous or
Central
Appalachian
bituminous
Cornbelt Energy,
Prairie Energy
Plant, IL
© 2004 Zephyr Environmental Corporation
0.015 PM
0.055 PM10
0.033
fabric filter
0.02 (3-hr block)
ESP
Comments
PM BACT Issues
• Basic controls:
– Dry FGD:
• Baghouse
– Wet FGD:
• ESP or baghouse for primary filterable
PM control
• In some cases, wet (or polishing) ESPs
downstream of the wet FGD are
proposed (e.g., Thoroughbred, Duke
Energy, Prairie Generating Station)
© 2004 Zephyr Environmental Corporation
PM BACT Issues
• Inconsistency in various permit limits
• Measurement method really defines
particulate matter
– Method 5 or 17– all sizes of PM, filterable
– Method 201A – PM10, filterable
– Method 202 –condensible or “fine PM”
• Method 202 may overstate PM10
emissions, due to ammonia and sulfate
compounds created in the sampling
system
© 2004 Zephyr Environmental Corporation
PM BACT Issues
• PM/PM10 compliance
demonstration
– PM CEMS
• Performance specifications, PS-11 for
PM CEMS
• Only measures filterable PM
– Typical requirements are periodic
tests for PM10 and operational
requirements for the PM control
device
© 2004 Zephyr Environmental Corporation
CO/VOC BACT
• Control technology - not an issue,
but even these limits keep going
down
• “Good combustion practices”;
trade-off with NOx control
• CO CEMS; some permits use CO
CEMS as a surrogate to estimate
VOC emissions
© 2004 Zephyr Environmental Corporation
Mercury
• Not subject to Federal PSD-BACT; no
more case-by-case analysis
• Subject to CAMR (70 FR 28606,
revised 71 FR 33388)
• CAMR highlights
–
–
–
–
New coal-fired units – NSPS, Subpart Da
New and existing units – cap and trade
Monitoring requirements
CEMS certified 90 operating days/180
calendar days after operation for new units
© 2004 Zephyr Environmental Corporation
Mercury
• Some states have more stringent
requirements and/or not opt-in to
national trading program
• Level of detail for application?
© 2004 Zephyr Environmental Corporation
Summary
• Build a good library of information and
continue to update it
• Careful review of permit application – it
will be scrutinized by many!
• Careful negotiations with vendors for
emission guarantees
• Consider:
–
–
–
–
SSM emissions
Averaging periods
Method of compliance
Optimization periods
© 2004 Zephyr Environmental Corporation
Contact Information
Jennifer Sharp Seinfeld, P.E.
Zephyr Environmental Corporation
10420 Little Patuxent Parkway, Suite 320
Columbia, Maryland 21044
410-312-7915
jseinfeld@zephyrenv.com
visit us at www.ZephyrEnv.com
And www.HazMatAcademy
© 2004 Zephyr Environmental Corporation