2012 AWMA – U.S. EPA Information Exchange

I attended the aforementioned event in Research Triangle Park on November 27^th and 28^th on behalf of ALL4. The predominant subject on the Information Exchange agenda was clearly greenhouse gas (GHG) emissions as seven (7) of the 24 information sessions were related to GHG emissions and associated regulations. Mercury related topics (including the mercury air toxics or “MATS” rule) came in second with four (4) information sessions.  Additional topics included NESHAPS (2 sessions), NSPS (2 sessions), NAAQS (1 session), monitoring/testing (2 sessions), CSAPR (1 session), and several sessions related to planning models that are used by U.S. EPA.  The subject matter presented was generally non-controversial primarily as a result of the fact that most of what was presented is already known.  Copies of presentation materials are not provided to attendees prior to or during the Information Exchange, though select presentations are typically provided within a few weeks of the event.  As a result, attendees come home with many pages of notes to wade through to ascertain any important points.  I have not been through my notes yet so please stay tuned for additional blog posts related to the above mentioned topics.  However, a couple of interesting items that came up are identified below.

One key point that was brought up during the MATS session was the ability of certain MATS affected facilities to utilize sulfur dioxide (SO₂) emissions monitoring as a surrogate for hydrogen chloride (HCl) monitoring, negating the need for an HCl continuous emissions monitoring system (CEMS) otherwise needed to comply with the HCl standard.  The presenters were questioned regarding analogous situations at other NESHAP affected sources (e.g. 40 CFR Part 63 Subpart LLL, Portland Cement MACT) and whether a similar approach could be utilized.  It was noted by the presenters that NESHAPs in general include provisions for affected facilities to propose alternative monitoring plans (AMP) and that situations analogous to the mentioned MATS SO₂/HCl situation would be reasonable to propose as an AMP. 

A second key point that was reiterated during discussions regarding the GHG “Tailoring” rule is that U.S. EPA considers carbon capture to be technically feasible, thus requiring it to be identified as such in many BACT analyses for GHG emissions.  U.S. EPA will be looking for robust discussion regarding the energy, environmental, and cost considerations associated with carbon capture to be included as part of the record for GHG BACT analyses.  This point was intriguing because during a subsequent session, the presenter indicated that carbon capture technology would likely not be commercially available until at least 2020.