87245 - Winston & Strawn

MATS 2015: Are Your Units Ready?
Outage Management for Power Plants
July 15, 2014
Stephanie Sebor
• Emission Limits
• Monitoring and Testing Requirements
• Startup and Shutdown Work Practice
• Tune-up Work Practice Standards
• Electronic Reporting
• Compliance Extensions
• MATS Litigation
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MATS Emission Limits
• MATS sets emission limits for three categories of pollutants:
– Hg
• All EGUs must comply with the Hg emission limit.
– Acid gases (HCl or SO2)
• Default: HCl
• May comply with SO2 emission limit if equipped with a wet or dry
FGD or DSI and an SO2 CEMS.
– Non-Hg HAP metals
• Filterable PM,
• Total non-Hg HAP metals, or
• Individual non-Hg HAP metals
• MATS emission limits must be met at all times, except during
periods of startup and shutdown, during which work practice
standards apply.
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MATS Emission Limits
Non-Mercury Metallic HAP
Existing NonLignite Units
Filterable PM
0.30 lb/MWh
Lignite Units
0.30 lb/MWh
New Units
(Revised Limits)
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0.090 lb/MWh
Total HAP
Acid Gas HAP
HAP Metals
0. 50
See Table
2 to
See Table
1 to
1.5 lb/MWh
1.5 lb/MWh
1.2 lb/TBtu
0.013 lb/GWh
4.0 lb/TBtu
0.040 lb/GWh
0.0030 lb/GWh
1.0 lb/MWh
0.040 lb/GWh
Monitoring and Testing Requirements
• Depending on the pollutant or surrogate selected,
compliance may be demonstrated using either a CMS or
stack testing
– Hg – Use either Hg CEMS or Hg sorbent trap
– SO2 – Must use SO2 CEMS
– HCl, PM and non-Hg HAP metals – Use either CEMS or
quarterly stack testing
• All continuous monitoring systems must be operated during
startup and shutdown.
• Each quarterly stack test must be completed within 80 to
100 calendar days after the previous test
– Can skip stack testing in quarters during which less than 168
boiler operating hours occur, but at least one test must be
conducted per calendar year.
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Should I elect to demonstrate compliance using CEMS?
• EPA assumed that “EGUs should be considered to be
operating normally at all times electricity is generated.”
• Variable emissions that occur after startup ends but before
an EGU has reached a stable operating load will be counted
by CEMS and sorbent trap monitoring systems.
– Sorbent trap monitoring systems cannot differentiate between
startup/shutdown emissions and normal operation.
• Default diluent capping
– Without diluent cap values at low CO2 or high O2
concentrations, emission rates calculated using EPA’s Ffactor methodology will be inaccurately high, approaching
– MATS currently allows default diluent caps to be used to
calculate Hg emission rates, but not for other pollutants.
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Startup and Shutdown Work Practice Standards
• EGUs must comply with work practice standards, rather than
the MATS emission limits, during startup and shutdown.
• Startup ends when any of the steam from the boiler is used
to generate electricity for sale over the grid or for any other
purpose (including onsite use).
– Under the current definition, startup ends at 1 MW.
• Shutdown begins either when none of the steam from the
boiler is used to generate electricity for sale over the grid or
for any other purpose (including onsite use), or at the point of
no fuel being fired in the boiler, whichever is earlier.
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Operation of Air Pollution Control Devices
• Once a unit converts to firing coal during startup, all
applicable control technologies must be engaged, except
dry scrubber and SCR, which may be started “appropriately
to comply with relevant standards applicable during normal
– SNCRs, WFGDs, ESPs, and limestone injection systems in
CFBs must be engaged upon firing coal, regardless of
temperature restrictions or manufacturers’ specifications.
• EGUs must operate all applicable control technologies while
firing coal during shutdown.
– No exception for SCRs, DFGDs, or any other air pollution
control devices.
© 2014 Winston & Strawn
Reconsideration of the SUSD Work Practice Standards
• EPA announced reconsideration of the startup and
shutdown work practice standards on November 16,
– Proposed to allow SNCRs and limestone injection at
CFBs to be engaged “as expeditiously as possible” after
an EGU begins firing coal during startup.
• Still no exception for ESPs.
– Proposed to no longer require engagement of SCR, dry
scrubber, SNCR, and limestone injection at CFBs while
firing coal during shutdown.
• EPA did not finalize these changes when it finalized the
new source MATS reconsideration.
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Reconsideration of the SUSD Work Practice Standards
• EPA re-opened the public comment on the startup and
shutdown work practice standards reconsideration on
June 25, 2013.
• EPA’s analysis “could support defining the end of
startup at coal-fired EGUs as occurring at 25 percent of
nameplate capacity plus 3 hours or the start of
electricity generation plus 6 hours, whichever comes
– Some EGUs cannot meet the MATS emission limits at EPA’s
suggested end of startup, particularly CFBs, which have
longer startup times.
• Over a year later, EPA has not yet finalized the
proposed changes to the work practice standards.
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Reconsideration of the SUSD Work Practice Standards
• MATS does not address how the startup and shutdown
work practice standards should apply to EGUs venting to
a common stack.
– Commenters have suggested that the startup and
shutdown work practice standards apply to all units venting
to a common stack when any one of the units is starting up
or shutting down while any other unit is in operation.
© 2014 Winston & Strawn
Tune-Up Work Practice Standards
• Two parts to a MATS tune-up:
– Preventative maintenance work performed during outage
– Boiler tuning work performed while the unit is operating
• MATS does not specify how soon the boiler tuning must be
completed after the preventative maintenance work is completed.
– It may be preferable to allow time between when the unit comes out
of outage before conducting the boiler tuning work to allow the unit to
become seasoned and normalized after the outage.
• Keep this timing in mind when scheduling initial compliance tuneup before MATS initial compliance deadline.
• EPA drafted the tune-up work practice standards with PC units in
– The tune-up work practice standards contain a number of
requirements that do not apply to CFB units.
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Electronic Reporting
• MATS requires three types of reporting: semiannual compliance
reports, quarterly stack test reports, and quarterly CMS reports.
• The first semiannual compliance report will cover the period from
April 16, 2015 through December 31, 2015 and must be submitted
to EPA by January 31, 2016 using the Compliance and Emissions
Data Reporting Interface (“CEDRI”).
• Quarterly stack test results must be submitted to EPA within 60
days after the date of completing each performance test using
EPA’s Electronic Reporting Tool (“ERT”).
• Quarterly Hg CEMS and sorbent trap monitoring reports must be
submitted 30 days after each calendar quarter using EPA’s
Emissions Collection and Monitoring Plan System (“ECMPS”)
client tool.
• PM and SO2 CEMS data must be submitted to EPA 60 days
following the end of each calendar quarter using CEDRI.
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Electronic Reporting
• CEDRI does not appear to have any specific reporting format for
MATS reporting at this time.
• ECMPS does not yet support submission of Hg sorbent trap or
SO2 CEMS data.
– EPA is conducting beta testing of a MATS-friendly version of ECMPS
• Reporting stack test results, PM CEMS data, RCA/RRA data, and
RATA data will be cumbersome and time-consuming due to
limitations of the CEDRI and ERT systems.
• EPA is aware of these electronic reporting issues but has not yet
revised the rule to streamline electronic reporting.
© 2014 Winston & Strawn
MATS Compliance Extensions
• One year extensions from state permitting authorities are
available under § 112(i)(3)(B) where additional time is necessary
for installation of controls.
– EPA stated that these one-year extensions should be broadly
• EPA interprets installation of controls broadly
– Installation of onsite replacement power, such as a simple cycle gas
– Running a retiring unit for reliability reasons while related units are
installing pollution control upgrades
• EPA recently reported that less than ¼ of utilities have requested
compliance extensions.
– Approximately 80 extensions have been granted to date.
• Deadline to submit an extension request is December 17, 2014.
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MATS Compliance Extensions
• OECA memo outlines limited circumstances under which a oneyear extension for reliability purposes may be granted in an
administrative order:
– Where an EGU that otherwise would have been deactivated is
required to operate in noncompliance with the MATS for an
additional year, or
– Where an EGU has a delay in installation of controls due to factors
beyond the control of the owner/operator and is required to run for
reliability purposes, or needs to operate because another unit has
had such a delay.
• Timeline for obtaining an AO has already started.
• OECA cannot issue an AO until April 16, 2015.
• OECA memo is not legally enforceable and can be withdrawn at
any time.
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MATS Litigation
• D.C. Circuit upheld MATS on April 15, 2014
– Court upheld EPA’s “reasonable and necessary”
– Court upheld process by which EPA established Hg emission
– Court held that a separate subcategory was not required to
be established for circulating fluidized bed units.
– Court held that EPA was not required to set separate
standards for major sources and area sources of HAPs.
© 2014 Winston & Strawn
Stephanie Sebor
35 W. Wacker Drive
Chicago, IL 60601
(312) 558-7341
[email protected]
© 2014 Winston & Strawn

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