Important Considerations for Permitting of Emission Control Systems - Lessons Learned and Recommendations

摘要

The U.S. Environmental Protection Agency (EPA) has recently proposed and promulgated many new air quality regulations that affect electric generating units (EGUs). Air pollution control (APC) systems have already been installed on many EGUs nationally to meet federal and state regulations, such as the Maryland Healthy Air Act - the State's multi-pollutant regulation targeting coal-fired EGUs; APC systems will be installed on other EGUs in the near future. Operational issues associated with retrofitting existing units with new APC systems could affect compliance with emission standards. Even for new generating units, including gas turbines, there are important operational considerations, especially regarding emissions during startup and shutdown, that not only influence how air permits are structured, but how compliance strategies are developed. This paper examines the operational issues associated with APC systems and the impacts these issues have on developing air permits, especially for limits during periods of startup and shutdown, and developing approaches for compliance.