utility mats - compliance with the low emitting egu compliance option

www.all4inc.comKimberton, PA | 610.933.5246Columbus, GA | 706.221.7688

Utility MATS -Compliance with the Low Emitting EGU Compliance

Option

Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 117April 8, 2013

Presented by All4 Inc.

2 Your environmental compliance is clearly our business.

Low Emission Electrical Generating Unit (LEE)• Reduced Emission Testing• Minimal Monitoring Requirements

Emission Testing• Quarterly

Monitoring• CEMS• Parametric

Utility MATS Compliance Strategies

3 Your environmental compliance is clearly our business.

Hydrogen Chloride HCl• CEMS (SO2 Monitor)

Particulate Matter (PM)• LEE

Mercury (Hg)• LEE

Presentation Homework

4 Your environmental compliance is clearly our business.

Evaluate Various Emission Testing Firms• Negotiate Contracted Rates• Assess Resources

Personnel Trucks/Trailers/Equipment Location(s) Reporting

• Award Multiple Contracts• Start Testing Early

Emission Testing

5 Your environmental compliance is clearly our business.

U.S. EPA Reference Method 5 (Filterable) Initial Performance Test (LEE Qualification)

• 3-Run Emission Test Program ~90-min Sampling Time Each Onsite analysis

• Maximum Normal Operating Load Conditions 90 and 110% of unit design capacity

• Quarterly Testing for 3 Consecutive Years Unit operating quarter (> 168 hours) 80 to 100 calendar days after the previous performance test

Subsequent Performance Test (LEE Status) Every 36 calendar months

~$12,000 per Test Program

PM Testing

6 Your environmental compliance is clearly our business.

U.S. EPA Reference Method 30B Initial Performance Test (LEE Qualification)

• 30-day Performance Test • Facility’s 40 CFR 75 Monitoring Systems

Subsequent Performance Test (LEE Status)• Every 12 calendar months

~$44,000 per Test Program• Plant Personnel Training• Internet Access• Analysis (1 set of tubes per 5 days)

Hg Testing

7 Your environmental compliance is clearly our business.

0 5 10 15 20 25 30 35 40$0

$100,000

$200,000

$300,000

$400,000

$500,000

$600,000

$700,000

$800,000

Operating Quarter

LEE

Em

issio

n T

esti

ng

Co

st

LEE Status

Annual Hg Test-

ing

3-yr PM Testing

Annual Hg &

Quarterly PM Test-

ing

$117 K

$55 - 70 K

LEE Emission Testing Costs

8 Your environmental compliance is clearly our business.

Resume Quarterly PM Testing Monitoring Compliance Options

• PM CEMS• PM CPMS

Lose PM LEE Status

9 Your environmental compliance is clearly our business.

PM Compliance Option Cost Comparison

0 5 10 15 20 25 30 35 40$0

$200,000

$400,000

$600,000

$800,000

$1,000,000

PM CEMS PM CPMS Emission TestingQuarter

Op

era

tin

g C

ost $116

K

10 Your environmental compliance is clearly our business.

Resume Quarterly Hg Testing Install and certify Hg CEMS within 6 months

Lose Hg LEE Status

11 Your environmental compliance is clearly our business.

Hg Compliance Option Cost Comparison

0 5 10 15 20 25 30 35 40$0

$200,000

$400,000

$600,000

$800,000

$1,000,000

Hg CEMS Hg Sorbent TrapQuarter

Op

era

tin

g C

ost

www.all4inc.comKimberton, PA | 610.933.5246Columbus, GA | 706.221.7688

Questions ?

Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 117