A number of power companies and suppliers to the utility industry participated yesterday in the Hot Topic Hour (actually 2.5 hours) on the Cement MACT. There were five speakers. Keith provided great insights on how the rule was put together. For example the change in the HCl limit from a proposed 2 ppm for existing and 0.2 ppm for new to 3 ppm was caused by the inability to reliably measure at the lower levels. EPA took the lower detection limit of 0.1 and multiplied it by 30 to arrive at the MACT limit. So it was insightful information for the utilities and industrial boiler operators. Utilities have been worried that there could be a sub ppm HCl rule based on the lowest 12 percent (low chlorine, high calcium coals). So this precedent should be welcome news. There was one informative discussion with Keith on the problems of the 10 percent change in temperature. A participant pointed out that mathematically this was only possible on an absolute scale. Keith explained that the provision was in response to a very narrow comment for one of the cement plants talking about the 10 percent difference between 360°F and 400°F. Keith mentioned more important issues which will need to be resolved as we move forward. One has to do with timing of the compliance dates. Arron, Carrie, and David provided lots of expert insights on the details of the rule and implications for the operators and suppliers. The takeaways for the utility industry are that PM CEMs will be required. There could be advantages or disadvantages in the fact that plants may be categorized under Commercial and Industrial Solid Waste Incineration Units (CISWI) instead of Cement. There is very little potential of extensions in compliance dates. Tom explained the details on the CEFCO system which uses steam assisted nozzles and various process technologies to provide multi-pollution control. PASSWORD hth816 Click Here For Complete Webinar Recording Text
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