Strengthening the Mercury and Air Toxics Standards (MATS) for Coal-fired Power Plants Final revisions to the Residual Risk and Technology Review (RTR) of the MATS Rule (40 CFR Part 63, Subpart UUUUU) include significantly more stringent emissions standards and enhanced monitoring requirements for coal- and oil-fired EGUs. The filterable particulate matter (fPM) emissions standard used as a surrogate for non- mercury metal Hazardous Air Pollutant (HAP) was lowered 70% to 0.010 lb/MMBtu for coal-fired EGUs, and all coal- or oil-fired EGUs using the surrogate option must now use PM continuous emissions monitoring systems (CEMS) in lieu of stack testing to demonstrate compliance. Individual non-mercury metal HAP standards were also lowered proportionally to the new fPM standard, and the mercury emission standard applicable to lignite-fired EGUs was lowered to 1.2 lb/TBtu. Other changes include the removal of the fPM low-emitting EGU program and the removal of the 2nd definition of “startup.” EPA noted that PM CEMS are already in use by more than 100 affected coal-fired EGUs, or 1/3 of the existing fleet. However, with a compliance date of July 6, 2027, operators should consider the challenges associated with procuring, installing, and commissioning PM CEMS for the remaining 200 sources, particularly the 33 EGUs projected to also require control system upgrades to achieve compliance with the revised fPM standard. PM CEMS are far more complex than traditional gaseous pollutant CEMS (e.g., NOx), and there is a limited supply of qualified vendors that can support such projects. Note that the Title V permitting authority may grant up to a 1-year compliance extension, on a case-by-case basis, if such additional time is necessary for the installation of controls. Industry Implications In summary, these final rules will have significant impact on both existing and new EGUs such as: f When and how does an existing coal-fired facility convert to NG to avoid the most stringent requirements, especially for those that will be operational beyond January 1, 2039 and must implement CCS f Incentive for new Stationary Combustion Turbines to limit the capacity factor to avoid CCS required for baseload units f Practical challenges to implementation of CCS including the siting and EJ concerns for new pipelines f Costs associated with the more stringent MATS for coal-fired units In addition, availability of reliable power supply will be a key factor when selecting a site for new industries, including data centers and mining projects where the demand for power is expected to increase. In addition, the new GHG emission standards play a key role in selection of the units (e.g., turbines vs engines, small turbines
vs large turbines, new units vs existing units) as well as the dispatch of these units and agreements with the local grid operators. These rules may result in more self-generating projects to avoid implications associated with selling power to the grid. There are significant number of litigations both from the state agencies and industrial groups. Trinity will be monitoring the development and challenges to these rules.
Stay tuned for a free webinar offering on this topic ( trinityconsultants.com/training ).
If you need assistance with understanding the implications of these changes for your facilities, we can help! Trinity’s 50 years of multimedia experience in the Electric Utility sector translates to a deep understanding of the industry’s emission sources and business practices. If you’d like to discuss these rules, please consider reaching out to our team of experts for assistance at +1.800.229.6655.
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