The American Public Power Association recently filed comments in response to the Environmental Protection Agency’s (EPA) proposal to repeal specific amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units (EGUs) rule.
The rule is commonly referred to as the Mercury and Air Toxic Standards (MATS).
APPA’s comments generally express support for the proposal, which would effectively revert to the 2012 MATS Rule.
Industry continues to see consistent reductions in mercury (Hg) emissions, and as such, APPA finds that more stringent standards would impose additional costs without meaningful environmental benefits.
APPA said it supports the repeal of the filterable particulate matter (fPM) standard for coal and oil-fired power plants, which EPA revised from 0.030 to 0.010 pounds per million British thermal units (lb/MMBtu).
APPA also supports EPA's proposal to repeal the requirement to use particulate matter continuous emissions monitoring system (PM CEMS) as the only compliance demonstration for fPM emission standards for coal-and oil-fired EGUs.
In addition, APPA said it:
• Supports changes to the PM CEMS monitoring provisions to promote flexibility and accuracy;
• Supports allowing public power utilities to choose quarterly stack testing (QST), the low-emitting EGU (LEE) program, particulate matter continuous parametric monitoring system (PM CPMS), and PM CEMS to demonstrate compliance with the fPM standard; and
• Recommends EPA eliminate the new minimum volume and mass per run requirements for fPM compliance testing at coal plants.
