• RMB ACE Rule and Combustion Turbine Startup/Certification Training Webinars (3/13/20)
    In the wake of EPRI CEMUG cancellation and various travel restrictions due to COVID-19 concerns, RMB will be offering two training workshops on May 11 and 12, 2020 as webinars.

    ACE Rule Training Workshop.  Finalized last year, the ACE Rule establishes CO2 performance standards based on potential heat rate improvements that can be made at each individual source.  While a federal rule, the ACE Rule requires states to submit implementation plans that detail how each source will comply.  However, EPA has provided states with very little guidance on how to establish the source specific limits required under the rule.  State personnel, who must develop these plans by July 8, 2022, will generally not have the expertise needed to develop the standards.  Therefore, utilities will need to take a pro-active approach and work with their states to ensure that the standards accurately reflect the unique operating characteristics of their units.  Utilities will need to identify which candidate technologies and O&M practices apply and the potential improvement for each source.  The performance standard must then be translated into a numerical emission limit.  This is a critical step since one must consider issues such as the appropriate baseline period and averaging techniques, as well as how to address different load conditions, startup/shutdown hours, missing data substitution, bias adjustment factors, etc.  The emission limit must also reflect the inherent variability both in the emission measurements and the process, which is an especially important consideration since the CO2 reductions associated with the potential heat rate improvements will generally be less than the inherent uncertainty of the emission measurements.  Once the standards are in place, CEMS bias and uncertainties will become more critical as sources strive to show on-going compliance.  The half-day workshop will discuss the ACE Rule requirements and related issues to help you meet the new challenges.  The training topics will include:

    • Overview of ACE Rule Requirements
    • Evaluating Candidate Technologies and O&M
    • Emission Limit Calculation Options
    • State Agency Information Requests
  • Addressing Dispatch Considerations
  • Potential ACE Compliance Alternatives
  • Reducing CEMS Bias and Uncertainty
  • Heat Rate Measurement Techniques

  Click here for more information or to register for RMB’s ACE Rule Training Workshop.

  • Combustion Turbine Startup/Certification Training Workshop.  Whether to address new base-load demand or for cycling or peaking needs, utilities are often turning to    combustion turbines.  Addressing permitting and emission monitoring requirements is an important part of commissioning these new sources.  Permit limits, emission  controls, and monitoring requirements can vary depending on the location and type of turbine while ultra-low NOX limits and managing ammonia slip can present            monitoring challenges.  CEMS certification, initial compliance tests and the associated reporting requirements all must be met within the regulatory deadlines even in      situations where the transition of ownership may make ensuring compliance difficult.  Whether you are in the process of installing a new turbine, considering adding      new generation or simply want to be better informed, this half-day workshop is intended to help you navigate the process and understand the requirements.  Topics will include:


    • Project Preparation Recommendations
    • Important Project Deadlines
    • Notification Requirements
    • Monitoring, Recordkeeping, and Reporting Requirements

  • Regulatory Concerns
  • Compliance Testing Requirements

  • Equipment and DAHS Recommendations
  • CEMS Certification and RATA Testing Requirements and Issues
  Click here for more information or to register for RMB’s Combustion Turbine Startup/Certification Training Workshop.

  • RMB Spring 2020 CEMS Training Course CANCELLED!! (3/12/20)

    Like many of you, we have been tracking updates regarding coronavirus (COVID-19) cases across the country as well as recent recommendations and efforts in many states to slow the spread of the virus.  Many companies are instituting common sense-based travel restrictions, and we have seen numerous meeting or large-scale events being cancelled or postponed.  As a result and in response to health and safety concerns, RMB regretfully is CANCELLING the CEMS Training Program that was scheduled for March 24-26, 2020. We apologize for the late notice and this disruption to your plans.  We assure you, RMB did not come to this decision lightly. 

    RMB plans to host the CEMS Training Program again this fall and next spring. While details with the hotel still need to be addressed, the fall training program is TENTATIVELY scheduled September 22-24, 2020.  As soon as RMB confirms this set of dates, we will post an update.

  • 2020 EPRI CEMUG Conference CANCELLED!! (3/10/20)
    In case anyone missed yesterday's announcement, EPRI has decided to cancel this year's CEMUG conference (scheduled for May 13-14 in Indianapolis) amid concerns associated with COVID-19.   It is unclear at this time whether or not other user group meetings slated for CEMUG week will still be held, cancelled or rescheduled.

  • CT MACT RTR Published in Federal Register (3/09/20)
    In today's Federal Register, dated March 9, 2020 (Volume 85, No. 46 - 23 total pages), EPA has published the final version of the CT MACT RTR.  The final rule includes requirements to address periods of SU/SD and adds some electronic reporting requirements. However, it does NOT finalize the proposed removal of the administrative stay of the effectiveness of the standards for new CTs, since EPA has indicated that they need more time to review and respond to comments regarding the lifting of the stay.  A copy of the final rule can found in our FTP library.

 
  • ACE Rule and Combustion Turbine Startup/Certification Training Workshops (2/25/20)
    RMB will be offering two training workshops on May 12, 2020 prior the EPRI CEMS User Group Meeting in Indianapolis. Register to join us for one or both training opportunities:

    ACE Rule Training Workshop.  Finalized last year, the ACE Rule establishes CO2 performance standards based on potential heat rate improvements that can be made at each individual source.  While a federal rule, the ACE Rule requires states to submit implementation plans that detail how each source will comply.  However, EPA has provided states with very little guidance on how to establish the source specific limits required under the rule.  State personnel, who must develop these plans by July 8, 2022, will generally not have the expertise needed to develop the standards.  Therefore, utilities will need to take a pro-active approach and work with their states to ensure that the standards accurately reflect the unique operating characteristics of their units.  Utilities will need to identify which candidate technologies and O&M practices apply and the potential improvement for each source.  The performance standard must then be translated into a numerical emission limit.  This is a critical step since one must consider issues such as the appropriate baseline period and averaging techniques, as well as how to address different load conditions, startup/shutdown hours, missing data substitution, bias adjustment factors, etc.  The emission limit must also reflect the inherent variability both in the emission measurements and the process, which is an especially important consideration since the CO2 reductions associated with the potential heat rate improvements will generally be less than the inherent uncertainty of the emission measurements.  Once the standards are in place, CEMS bias and uncertainties will become more critical as sources strive to show on-going compliance.  The half-day workshop will discuss the ACE Rule requirements and related issues to help you meet the new challenges.  The training topics will include:

    • Overview of ACE Rule Requirements
    • Evaluating Candidate Technologies and O&M
    • Emission Limit Calculation Options
    • State Agency Information Requests
  • Addressing Dispatch Considerations
  • Potential ACE Compliance Alternatives
  • Reducing CEMS Bias and Uncertainty
  • Heat Rate Measurement Techniques

  Click here for more information or to register for RMB’s ACE Rule Training Workshop. 

   Combustion Turbine Startup/Certification Training Workshop.  Whether to address new base-load demand or for cycling or peaking needs, utilities are often turning to         combustion turbines.  Addressing permitting and emission monitoring requirements is an important part of commissioning these new sources.  Permit limits, emission       controls, and monitoring requirements can vary depending on the location and type of turbine while ultra-low NOX limits and managing ammonia slip can present               monitoring challenges.  CEMS certification, initial compliance tests and the associated reporting requirements all must be met within the regulatory deadlines even in           situations where the transition of ownership may make ensuring compliance difficult.  Whether you are in the process of installing a new turbine, considering adding           new generation or simply want to be better informed, this half-day workshop is intended to help you navigate the process and understand the requirements.  Topics will     include:   


    • Project Preparation Recommendations
    • Important Project Deadlines
    • Notification Requirements
    • Monitoring, Recordkeeping, and Reporting Requirements

  • Regulatory Concerns
  • Compliance Testing Requirements

  • Equipment and DAHS Recommendations
  • CEMS Certification and RATA Testing Requirements and Issues

  Click here for more information or to register for RMB’s Combustion Turbine Startup/Certification Training Workshop.


  • EPA Finalizes CT MACT RTR (2/20/20)
    On January 31, 2020, EPA signed a final rule titled, “National Emission Standards for Hazardous Air Pollutants: Stationary Combustion Turbines Residual Risk and Technology Review.”  This rule finalizes EPA’s residual risk and technology review (RTR) conducted for the Stationary Combustion Turbines source category regulated under national emission standards for hazardous air pollutants (NESHAP).  Note: the final rule has yet to be published in the Federal Register. Once posted, RMB will post a notice.

    In addition, the final rule includes requirements to address periods of startup, shutdown, and malfunction (SSM) and adds electronic reporting requirements.  EPA is finalizing its proposed determination that the risks from this source category due to emissions of air toxics are acceptable and that the existing NESHAP provides an ample margin of safety to protect public health.  EPA is also finalizing its proposed determination that the Agency identified no new cost-effective controls under the technology review that would achieve further emissions reductions from the source category.

    In a significant departure from the proposed RTR rule, EPA decided to not finalize the proposed removal of the administrative stay of the effectiveness of the standards for new combustion turbines.  In the preamble to the final rule, EPA explains that the Agency needs additional time to review and respond to comments regarding the lifting of the stay.  EPA believes the Agency is also justified in not lifting the stay in order to make a determination regarding the petition that was submitted in August 2019, which requests that EPA delist the Stationary Combustion Turbine source category pursuant to § 112(c)(9) of the Clean Air Act.  A copy of the signed final rule can found in our FTP library.

  • Update on EPA Power Sector Rules (1/23/19)
    EPA provided an update on the various rulemaking efforts affecting the electric utility industry at the recent AWMA Information Exchange held in Research Triangle Park, NC on December 3 and 4, 2019.  While the Agency provided little additional detail regarding the pending rules, it did provide a summary of the publicly available drafts and discussed the tentative schedule for some of these rulemaking activities.

 

Regulation

Status

Expected Date

Combustion Turbine MACT RTR

Final

by March 13, 2020 (possibly January 2020)

MATS e-Reporting Rule

Proposal

“First Quarter 2020” a

MATS RTR and Supplemental Cost Finding Rule

Final

"By 2020" b 

GHG NSPS for New EGUs

Final

March 2020

RICE MACT RTR

Proposal

End of 2020

Boiler MACT RTR

Proposal

End of 2020

MATS Technical Corrections

Proposal

First Quarter 2021

a Although possibly June 2020 based on EPA’s regulatory agenda and discussion with other Agency personnel

b Rulemaking package is currently at OMB and action is expected within the next few months

Finalization of the CT MACT RTR is perhaps one of the more significant of the pending rulemakings.  EPA concluded that risks are acceptable under the existing rule and that no new cost-effective controls are available, thus the standards will remain unchanged.  However, EPA’s proposed action would remove the current stay of the emissions standards for lean premix gas-fired turbines and diffusion flame gas-fired turbines, which has been in place since 2004.  While there was initially a three-year compliance window associated with the rule, that time period has expired.  Thus, any applicable turbine (installed or reconstructed at a major source after 1/14/2003) would be immediately be required to demonstrate compliance with the formaldehyde standard of 91 ppbd@15% O2.  EPA stated that they are aware of the impact of removing the remand on existing CTs and that they "see a need" for some additional time to demonstrate compliance.  It’s possible that the final rule will include a provision for extending the amount of time for compliance demonstration and possibly allow sources to file an extension if oxidation catalyst is required to meet the new limits.


The MATS Risk and Technology Review (RTR) and Supplemental Cost Finding Rule is another significant rulemaking package that is expected to be finalized soon.  Based on a SCOTUS decision, EPA revised the cost analysis for MATS to reflect HAPS only and found the costs were significantly reduced such that the rule no longer met "appropriate and necessary" requirement in Section 112.  Despite this revised conclusion, EPA is not proposing to repeal the MATS Rule, stating that the revised appropriate and necessary finding does not automatically delist EGUs from the Section 112(c) and EPA has elected not to formally pursue the delisting option available under Section 112(c)(9) although it did request comments on several issues related to that decision.  Included in the rulemaking package was the MATS RTR, which concluded that no changes to the emission standards were necessary.


  • States Begin ACE Plan Development (1/23/20)
    Some state agencies appear to be getting an early start on their ACE compliance plans, which must be completed by July 8, 2022.  RMB has recently received a few inquiries from electric utilities in various states (e.g. Missouri, Nebraska, and Arizona) regarding data requests from their respective state agencies for conducting unit-specific heat rate improvement analyses for each state's ACE plan development.  These requests focus on background information on the existing ACE candidate technologies and various operating data, including fuel usage, generation, CO2 emissions, and heat rate data, as well as future plans for the facility.

    We believe that states will generally lack the information or expertise to develop meaningful ACE Rule emissions limits for each unit based on the specific.  Ultimately, sources will be required to provide their own assessment of heat rate improvement resulting from implementation of one or more of the candidate technologies specified in the rule and to evaluate of the baseline CO2 emissions rates and the uncertainty associated with that data as well as important details regarding averaging times and how those averages will be calculated--all critical given the lack of guidance from EPA regarding any of these issues.

    If you received an ACE Rule data request from your state agency please contact RMB, so we can track these activities and discuss any questions you may have about the rule.

  • EPA Proposes Latest Round of Test Method Revisions (12/13/19)
         In today's Federal Register, dated December 13, 2019 (Volume 84, No. 240 - 29 total pages), EPA has proposed yet another round of changes to various reference test           methods and CEMS performance specifications.  A copy of the proposed rule can found in our FTP library.


    • RMB's Spring 2020 CEMS Training Course - Registration Now Open!  (11/4/19)
      RMB's Spring 2020 CEMS Training Course has now been confirmed and registration is now open! The Spring course will be held March 24-26, 2020 in Raleigh, North Carolina.  For more details on RMB's Spring 2020 CEMS Training Course as well as registration information, click the following link: RMB Training.  For direct registration informaiton, click here: RMB CEMS Course Registration - Spring 2020



    • EGU MATS HCl Quarterly Testing News - Audit Sample Program (10/28/19)
      Earlier this summer, EPA posted a notice regarding a lack of providers for audit samples as part the audit sample program under 40 CFR Parts 60 and 63.  As a reminder, use of audit samples are required if the audit samples are "commercially available" from two or more independent accredited audit sample providers (AASP).  Since there are no longer two providers, the requirement to obtain these audit samples is no longer in effect until another indepedent AASP has audit samples for purchase.   What does this mean in practice for many is EGU MATS affected sources?  Those sources performing quarterly stack testing for HCl no longer need to acquire blind audit samples for quarterly performance tests (e.g sources using Reference Method 26A for HCl stack testing).  Finally, EPA has stated that they will post an update with the name(s) of the providers and audit sample(s) available for purhaase when there are two or more AASP.  Once that post occurs, the audit sample program will go back into effect 60 days after the post has been made.


        Follow this link for the actual notice: EPA Notice - Audit Sample Program


    • EPA Finalizes ACE Rule and Clean Power Plan Repeal  (7/8/19)
      In today's Federal Register, dated July 8, 2019 (Volume 84, No. 130 - 65 total pages), EPA has finalized the Affordable Clean Energy rule ("ACE Rule") and formally repealed the Clean Power Plan (CPP).  A copy of the final rule can found in our FTP library.



    • Update on EPA's Combustion Turbine NESHAP  (4/12/19)
      On April 12, 2019, EPA published in the Federal Register a proposed rule titled, “National Emission Standards for Hazardous Air Pollutants: Stationary Combustion Turbines Residual Risk and Technology Review.”  EPA initially issued its NESHAP rule for Stationary Combustion Turbines on March 5, 2004.  The rule applies to stationary combustion turbines located at major sources of hazardous air pollutants (HAP).  The NESHAP requires new or reconstructed stationary combustion turbines to meet a formaldehyde limit of 91 parts per billion by volume, dry basis at 15 percent oxygen.  However, EPA stayed the effectiveness of the rule on August 18, 2004.  A copy of the proposed rule can found in our FTP library

      Following a residual risk and technology review conducted pursuant to the Clean Air Act (CAA), EPA is proposing to determine that risks from the source category are acceptable and that no new cost-effective controls are available.  In the proposed rule, EPA is also:


      • Revising the requirements for periods of startup, shutdown and malfunction (SSM) to be consistent with recent court decisions;
      • Requiring electronic reporting of performance test results and compliance reports; and
      • Lifting the stay of the standards for new gas-fired stationary combustion turbines, which has been in effect since August 2004.           


    • EPA Proposes Reconsideration of Supplemental MATS Finding  (2/7/19)
      In today's Federal Register, dated February 7, 2019 (Volume 84, No. 26 - 35 total pages), EPA has proposed their reconsideration of supplemental finding and resisdual risk and technology review of the MATS rule.  At this time it's unclear what the ultimate outcome of this new finding would mean for the industry.  Comments are due by April 8, 2019.   There will also be a public hearing concering this proposed rule.  The time and location of the public hearing will be announced in a subsequent Federal Register notice.  A copy of the proposed rule can found in our FTP library.