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EPA proposes carbon limits for modified and reconstructed power plants

From the June 3, 2014 issue of Public Power Daily

Originally published June 3, 2014

By Jeannine Anderson
In addition to the proposed rule on existing fossil fuel-fired power plants (see story, this issue), the U.S. Environmental Protection Agency on June 2 released a proposed rule on modified and reconstructed units. The rule also falls under Section 111(b) of the Clean Air Act and, like the proposed rule for existing power plants, it, too, will have a 120-day comment period, starting on the day it is published in the Federal Register

The EPA said a modification is "any physical or operational change to an existing source that increases the source's maximum achievable hourly rate of air pollutant emissions."

A reconstructed source "is a unit that replaces components to such an extent that the capital cost of the new components exceeds 50 percent of the capital cost of an entirely new comparable facility."

"The proposed emission limits for modified or reconstructed sources are based on the performance of available and demonstrated technology," the EPA said in a fact sheet posted on its website. They "do not require implementation of carbon capture and storage (CCS) technology, nor are they based on that technology."

The agency is proposing separate numeric standards for different types of units.

For modified fossil fuel-fired electric steam generating units (utility boilers and integrated gasification combined-cycle, or IGCC units), the agency is proposing two alternative standards of performance. Under the first alternative, all modified units would be subject to a single standard of performance. In the second alternative, the agency is proposing that the specific form of the standard will depend on whether the source makes the modification before or after becoming subject to a Clean Air Act Section 111(d) state plan. This recognizes that actions taken to comply with a Section 111(d) state plan may result in improved performance at the source, the EPA said. In all cases, "the level of the proposed standards is based on a combination of best operating practices and equipment upgrades." 

For modified natural gas-fired stationary combustion turbines, the agency is proposing standards based on efficient natural gas combined-cycle technology. Those standards would apply whether or not a unit is subject to a Section 111(d) state plan.

For reconstructed fossil fuel-fired electric utility steam generating units (utility boilers and IGCC units) and for affected reconstructed natural gas-fired stationary combustion turbines, the EPA is proposing standards of performance "based on the most efficient generating technology that is applicable to each category of units." This standard would not be affected by the submittal of a state plan under Section 111(d) of the Clean Air Act.

The proposed rule is available on the EPA's website. The agency also posted a regulatory impact analysis it carried out on the proposal, as well as a fact sheet on the proposed rule for modified and reconstructed power plants. 


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Vice President, Integrated Media and Communications
Meena Dayak

Editorial Director
Robert Varela

Editor, Public Power Daily
Jeannine Anderson

Communications Assistant
Fallon W. Forbush

Manager, Integrated Media 
David L. Blaylock

Integrated Media Editor 
Laura D’Alessandro