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IICCAACC OOPPEERRAATTIIOONNSS SSPPOOTTLLIIGGHHTT 1st Quarter ICAC FY 2010, (July 1, 2009 – September 30, 2009)

The Operations Spotlight provides a brief summary of some of ICAC’s efforts to promote the understanding and capabilities of the air pollution control industry to regulators, potential members, customers, user groups, environmental groups, the media, universities, research organizations, and the public at large. GOVERNMENT AFFAIRS ICAC communicates with regulatory agency staff at the federal, state, and local levels on a regular basis concerning various air pollution control and measurement topics. Below are a few of the highlights from the most recent quarter:

• ICAC Members Briefed EPA on Emission Controls and Monitoring for Nitric Acid Plants- EPA is in the process of collecting information on the performance and cost of emission control and monitoring technologies to control NOx and N2O emissions from nitric acid plants. Information collected will be used as the agency develops a New Source Performance Standards (NSPS) for this sector. Environmentalists sued EPA to revise their 37 year old NOx emission limits for nitric acid plants and petitioned to include first-time controls on the GHG nitrous oxide (N2O), which is 310 times more potent than CO2 as a global warming gas. The new source performance standards (NSPS) for nitric acid plants were first established in 1971. The Clean Air Act requires EPA to review its NSPS every eight years for each source category; the standard was last reviewed in 1989. The current NSPS sets a NOx limit of 3.0 lb/ton (HNO3). EPA has several options to consider as it review the NSPS for nitric acid plants; 1) no change; 2) issue clarifying amendments; 3) change the emission limits or other rule requirements and ; 4) add emission limits for N2O. EPA expects to issue a proposed rule in November 2010 and a final rule in 2011. The nitric acid proposed rule may dovetail with the Mandatory GHG reporting rule as sources are expected to begin reporting in 2010 providing EPA will additional emissions data from this sector. Members briefing EPA on the primary, secondary and tertiary control technology available to reduce N2O emissions, SCR technology for NOx as well as the monitoring technologies that have been deployed. EPA has compiled a list of nitric acid facilities and has requested ICAC provide feedback on the listing with regarding to types of controls which may be installed at the plants and any emissions data for the facility. For more information please contact ICAC’s Doug Austin ([email protected]) or Carolyn Slaughter ([email protected])

• ICAC Opportunity to Supply Information to EPA on NOX Control Cost Manual - EPA’s Office of

Air Quality Planning and Standards (OAQPS) is updating its Control Cost Manual for NOx control technologies for fossil fuel fired power plants. Costs play an important role in setting many state and federal air pollution control regulations. The extent of this role varies with the type of regulation. The Control Cost Manual is designed to provide guidance to industry and regulatory authorities for the development of accurate and consistent costs (capital costs, operating and maintenance expenses, and other costs) for air pollution control equipment, and to establish a standardized and peer-reviewed costing methodology by which all air pollution control costing analyses can be performed. EPA will use the cost information collected as they develop the Clean Air Interstate Replacement Rule and the Utility Mercury MACT. Members have an opportunity to participate in this effort by supplying catalyst cost information for a typical/average honeycomb catalyst for coal fired EGUs. EPA is also interest in any catalyst cost differences for special features that minimize or maximize secondary pollutants such as SO3, Hg, etc. The information ICAC collects will be keep confidential and the information aggregated for EPA’s use. To participate in this effort please contact ICAC’s Carolyn Slaughter ([email protected]).


• ICAC Requests GHG Control Information from Members for Website and Advocacy in Washington – Both the executive and legislative branches of government are moving the ball forward on greenhouse gas (GHG) reduction requirements for U.S. industries. The emissions caps and affected industries are currently being debated in many forums and private meetings that will ultimately influence the outcome of these standards. ICAC would like inject information into this process concerning the status and capabilities of emissions control and monitoring for GHGs. ICAC is kicking off several initiatives to gather information and promote the common business interests of members through the following:

o ICAC GHG Control Website – Send your technical papers/conference presentations to Carolyn Slaughter ([email protected]) so that it can be posted here: www.icac.com/i4a/pages/index.cfm?pageid=3450

o ICAC Position Paper and Presentation – ICAC position paper discussing need for legislation, industrial and power sector control availability, job creation in APC industry, etc. Position paper outline is available at (URL)

o ICAC GHG Control Projects Database/List – Requesting members to submit short summaries of their GHG control projects (pilot tests, demonstration, and commercial installations) to be listed on ICAC website. Please use the following format:

Project Name: Project Location: Project developer or Owner: Other Project Participants: Technology Supplier: Type of Technology: Process or Chemical Trade Name: Project Size: (for example, enter as MWe or MWt or tons of CO2 collected per annum or

gas flow in NM3/hr) Source of GHG Emissions: Disposition of GHG Captured or Destroyed: Date Project Start-up or Projected Date of Start-up: Hours of Operation as of Posting: Process Description: Other Comments: Attach any Available Publications or Materials:

• ICAC Supports U.S. Dept. of Commerce Efforts to Highlight GHG Control Technologies at Copenhagen - The US Department of Commerce is collecting videos highlighting products, services, technology and/or R&D US industry has to offer to meet the challenges posed by climate change; especially solutions in renewable energy and energy efficiency that mitigate GHG emissions. Submissions should be 5-15 minutes in length and address GHG emission reductions from a solution-oriented point-of-view that is not necessarily biased to one product or service. Of special interest are any public/private partnerships which your company might be involved in. The US State Department is collecting videos for use at the US Presence Center at the COP15 negotiations in Copenhagen in December. The USG will need the rights to show the videos in public viewings at the COP15 and would like to retain those rights for follow-on activities and events. The US Commerce Department is looking for off-the-shelf materials. If your company has material and would like to make a submission please contact Carolyn Slaughter ([email protected]) as soon as possible. This is a unique opportunity for ICAC members to illustrate the capabilities of the U.S. air pollution control industry and its central role in the climate change issue.


• ICAC Reappointed to U.S. Dept. of Commerce’s Environmental Technologies Advisory Committee – ICAC’s Executive Director received a letter from the Secretary of the U.S. Department of Commerce renewing the appointment to serve on the Environmental Technologies Trade Advisory Committee (ETTAC) as a representative of the Institute as well as the air pollution segment of the environmental industry sector. The ETTAC was created in 1994 to promote a close working- relationship between government and industry and to expand export growth in priority and emerging markets for environmental products and services. ETTAC is comprised of representatives from the private sector that work with the Department of Commerce in its pursuit of competitive trade objectives, policies, and programs for the environmental sector. ICAC has been represented on ETTAC for several years and reappointment has been pending in the new Obama administration. Serving on ETTAC has enhanced the visibility and influence of ICAC and resulted in continuing opportunities to inform federal agencies and stakeholders of our industry’s technologies, capabilities and concerns. For more on ETTAC go to the “Advisory Committee” link on http://web.ita.doc.gov.

• ICAC Host Emissions Measurement Division Conference Call - On Thursday, July 16th ICAC’s

Emissions Measurement division held a conference call to discuss ongoing division activities and ICAC staff provided a brief regulatory update on rules impacting the emissions monitoring community. The meeting’s action items are listed below:

o Workgroup Continues the Development of Ammonia Measurement Whitepaper o Develop briefing materials on measurement technology available for Nitric Acid

Plants o Briefing conference call on EPA’s Proposed rule on Emission Controls and

Monitoring for New Marine Vessels. For more information on the Emissions Measurement Division Activities, please go to: http://www.icac.com/i4a/pages/Index.cfm?pageID=3421 • ICAC Briefing on Emission Control and Monitoring Requirements for New Oceangoing Vessels-

ICAC Members received a briefing from EPA on their proposed rule for new marine vessels. On July 1, 2009, the U.S. EPA issued a proposed rulemaking for reducing emissions from large marine diesel engines that propel ocean-going vessels (Category 3 marine diesel engines, displacements at or above 30 liters/cylinder). This proposal mirrors the recent Tier 2 and Tier 3 emission standards that were added to the International Maritime Organization’s (IMO) MARPOL Annex VI regulations. The EPA proposal would cover vessels flagged or registered in the U.S. and includes a 2011 Tier 2 standard that relies on engine-based technologies to achieve a 15-25% reduction in NOx emissions relative to the existing EPA Tier 1 standards, and a 2016 Tier 3 standard that reduces NOx emissions by 80% relative to today’s Tier 1 standards through the use of emission control technologies such as SCR. The Tier 3 standards include standards for hydrocarbons and carbon monoxide but do not include a standard for particulate matter. Particulate matter emissions would be reduced through the use of lower sulfur marine diesel fuels that would be required if the U.S. and Canada receive IMO approval to designate their coastal waters as an Emission Control Area (ECA; this ECA petition has already been submitted to IMO). The EPA proposal also would forbid the production and sale of marine fuel oil above 1,000 ppm sulfur for use in the waters with a U.S. ECA and internal U.S. waters, and would allow for the production and sale of 1,000 ppm sulfur fuel for use in Category 3 marine engines. The proposed rule requires manufacturers to measure PM emissions along with NOX, HC, and CO during certification testing to report these results along with other test data. Continuous NOx monitoring would be required for Category 3 engines with on-off emission controls like an SCR.

ICAC WORKSHOPS AND TECHNICAL DIVISION ACTIVITIES


EPA estimates that the recent IMO emission changes in concert with this EPA proposal would reduce annual NOx emissions in the U.S. by about 1.2 million tons and PM emissions by about 143,000 tons by 2030. EPA is accepting comments on the proposal until September 28, 2009 and a final rule is expected by December, 17, 2009. Additional details on EPA’s large marine diesel engine emission proposal are available at: www.epa.gov/otaq/oceanvessels.htm.

• ICAC Meets with IEA Clean Coal Center on International Efforts to Address Global Mercury

Emissions- ICAC staff meet with Dr. Lesley Sloss, who is heading up efforts to develop mercury emission inventories from coal fired power plants in China, India, Russia and South Africa. In February 2009 the UN Environmental Programme’s (UNEP) Governing Council unanimously decided to launch negotiations on an international mercury treaty to address world wide mercury emissions. A global legally binding treaty on mercury is expect in 2013. IEA is working on behalf of the UNEP as a non-partisan organization to develop mercury emissions inventories, develop country level mercury reduction process level optimization plans which would be similar to MACT and or BACT requirements for coal plants and fund demonstration programs in the countries of interest. IEA has requested information regarding existing projects in the countries of interest that are utilizing a co-benefits approach to reduce conventional pollutants and mercury.

• ICAC Annual Forecast Report Gets Top Billing in Air Daily – The lead article in the August 3rd Air Daily, a newsletter for the air pollution control industry, provided positive PR for both ICAC and the pollution control market as a whole. The article’s opening sentence stated that “US utilities will spend nearly $6 billion on air pollution control and monitoring equipment by 2012, up from $4 billion in 2008, as projects are preserved in the recession to meet environmental requirements, the Institute of Clean Air Companies (ICAC) said in its annual forecast released today.” Referring to EPA Assistant Administrator Gina McCarthy’s testimony before a Senate hearing that SO2 and particulates control provides a 20-to-1 benefit-cost ratio, ICAC’s Executive Director Dave Foerter said “There is no place else to get that kind of return on investment” adding that “in terms of health care costs, this is preventive medicine.”

The Market Forecast analyzes market trends for stationary air pollution control equipment. The forecast summarizes the technological, regulatory, and general market influences driving the procurement of ESPs, fabric filters, NOx controls, VOC controls, FGD systems, CEMS, and utility reagent (ammonia, urea, lime, limestone, activated carbon) usage annually through 2010. The forecast was mailed July 2nd to the corporate representative at each regular member company. Associate members may purchase the full report for $950. For more information, please contact Carolyn Slaughter ([email protected]). Or go to http://www.icac.com/i4a/headlines/headlinedetails.cfm?id=35, to read the full press release.

• ICAC Attends Ozone Transport Commission (OTC) Public Meeting – ICAC staff attended a meeting that the OTC held September 2-3 to present an update on various activities of its Modeling, Stationary and Area Source (SAS), and Mobile Source Committees. The OTC coordinates regional control strategies for eleven Northeast states plus the District of Columbia and the counties in northern Virginia for attainment of the ozone and PM2.5 National Ambient Air Quality Standards (NAAQS). The states rely on a mix of in-state, regional and national control strategies for reducing the precursors to ozone and PM2.5 formation and attaining the numerical standards (currently 35ug/l for 24-hour PM2.5, 15ug/l for annual PM2.5, and 0.075ppm for 8-hour ozone). The SAS Committee is evaluating regional control strategies for NOx reductions from boilers serving Electric Generating Units (EGUs), boilers in the ICI (Industrial / Commercial / Institutional) sector, HEDD (High Electric Demand Day) units, municipal

ICAC PARTICIPATTION IN OTHER STAKEHOLDER GROUPS


waste incinerators, and new small (<5 million Btu/hr heat input) gas boilers, process heaters, and water heaters. For VOC reductions, they are considering AIM (Architectural and Industrial Maintenance) coatings and paints, consumer products, solvent cleaning, Stage 1 and 2 for gas stations, large above-ground storage tanks, and auto refinishing control strategies. The Mobile Source Committee is evaluating national efforts on renewable fuel standards, the establishment of Emission Control Areas (ECAs) for oceangoing vessels, and improved aftermarket automobile catalysts for their impacts on NOx and VOC emissions. For more information go to: http://www.otcair.org/document.asp?fview=meeting.

• ICAC Releases its 2009 Air Pollution Control Equipment Market Forecast - The forecasts shows the overall U.S. market for air pollution control and monitoring technology is around $4 billion a year (constant 2008 dollars) and is expected to increase to almost $6 billion by 2012. The Market Forecast analyzes market trends for stationary air pollution control equipment. The forecast summarizes the technological, regulatory, and general market influences driving the procurement of ESPs, fabric filters, NOx controls, VOC controls, FGD systems, CEMS, and utility reagent (ammonia, urea, lime, limestone, activated carbon) usage annually through 2010. The forecast was mailed July 2nd to the corporate representative at each regular member company. Associate members may purchase the full report for $950. For more information, please contact David Foerter ([email protected]).

• ICAC Welcomes New Staff Member – ICAC welcomes its newest staff member, Doug Austin. Doug comes to us from the Ozone Transport Commission where he was a Program Manager for the past 4 ½ years. Doug was involved with a host of regional air quality topics affecting the Northeast states including State Implementation Plan (SIP) attainment planning, regional haze, multipollutant planning, photochemical modeling, High Electric Demand Day (HEDD), Industrial / Commercial / Institutional (ICI) boiler, and Clean Air Interstate Rule vacatur issues. Prior to the OTC, Doug was a SIP planner for 2 years in the Maryland Department of the Environment’s Air and Radiation Management Administration. Doug also has over a decade of technical sales and engineering experience with Betz Industrial selling boiler, cooling and wastewater treatment chemicals to both the industrial and utility sectors. Academically, Doug has a B.A. degree in Political Science from Denison University, a M.S. degree in Natural Resources Policy and Planning from Ohio State University, completed the graduate coursework in Environmental Engineering from the University of Cincinnati, and received a J.D. degree from Widener University of Law. Doug is available via email at [email protected] or via telephone at (202) 457-0911 ext 109.

• Uhde Corporation of America has been active in the North American market primarily servicing the

coke plant and coal gasification business, and only recently started to market the DeN2O technology in

MEMBERSHIP UPDATE

ICAC PRODUCTS & SERVICES

NEW STAFF MEMBER HIRE


North America based on the technology and experience from Uhde GmbH, Germany. Uhde Corp. of America’s office is at 1370 Washington Pike, Bridgeville, PA 15017. Uhde Corporate of America’s corporate representative to ICAC will be Dennis Lippmann, President (412/257-8277 or [email protected]) and the alternate representative will be Paul Nicks, VP of Business Development (713/302-3162 or [email protected] ). Uhde will initially participate in the NOx and Industrial Source Control Divisions and has already been participating, by invitation of Süd Chemie, in an ICAC initiative with states and EPA on controls for Nitric Acid manufacturing facilities. For more information, go to: http://www.uhde.eu/company/index.en.epl.


IICCAACC OOPPEERRAATTIIOONNSS SSPPOOTTLLIIGGHHTT 2nd Quarter ICAC FY 2010, (September 30, 2009- December 31, 2009)


• ICAC Participates in EPA Invitational Meetings on GHG Control Technology - ICAC’s Executive Director participated in several meetings this quarter hosted by U.S. EPA to work on the underpinnings of GHG regulations next spring on permit requirements for new and modified power and industrial sources.

The Greenhouse Mitigation Technologies Workshop meeting, brought together approximately 50 persons with knowledge of GHG control technologies for the power sector, to discuss information that could be compiled into a GHG Database being developed by U.S. EPA Office of Research and Development (EPA/ORD) with contractor support. ICAC members also participating in the meeting included Alstom, MHIA, and Sargent & Lundy. EPA will bring other industries, including cement, pulp and paper, steel, etc. together in similar forums to help design a database of GHG controls.

Mr. Foerter participated in a Climate Change Workgroup meeting that was formed under the Clean Air Act Advisory Committee (CAAAC) on which he serves. This workgroup provides input to EPA, through the CAAAC, on applying NSPS/BACT, consistent with the Clean Air Act, to GHG power and industrial sources. EPA anticipates regulating GHG emissions from stationary sources after it completed is rulemaking to regulate mobile source GHG’s in the spring of 2010 (precipitated by the MA v. EPA court decision) and to support EPA’s recently proposed PSD Tailoring Rule for GHG’s. The Tailoring Rule proposes to require permits for any source emitting over 25,000 tons of CO2-equivalent. The Workgroup, similar to the CAAAC, consists of a wide range of stakeholders; however, no stationary source control technology vendors are directly participating. The Workgroup has a 6-month charge to provide input to EPA with an interim report at the end of 2009. For more: http://www.epa.gov/air/caaac/climatechangewg.html

• ICAC Reappointed to U.S. Dept. of Commerce’s Environmental Technologies Advisory Committee – ICAC’s Executive Director received a letter from the Secretary of the U.S. Department of Commerce renewing the appointment to serve on the Environmental Technologies Trade Advisory Committee (ETTAC) as a representative of the Institute as well as the air pollution segment of the environmental industry sector. The ETTAC was created in 1994 to promote a close working- relationship between government and industry and to expand export growth in priority and emerging markets for environmental products and services. ETTAC is comprised of representatives from the private sector that work with the Department of Commerce in its pursuit of competitive trade objectives, policies, and programs for the environmental sector. ICAC has been represented on ETTAC for several years and reappointment has been pending in the new Obama administration. Serving on ETTAC has enhanced the visibility and influence of ICAC and resulted in continuing opportunities to inform federal agencies and stakeholders of our industry’s technologies, capabilities and concerns. For more on ETTAC go to the


“Advisory Committee” link on http://web.ita.doc.gov.

• ICAC Hosted NOx and Integrated Technical Division Meeting at PowerGen International- during

this year’s PowerGen International Conference in Las Vegas, NV ICAC staff hosted the NOx Control and Integrated (SO2 & PM) Division Meetings. Below is list of each meetings action items; meeting summaries will be available in to next few weeks.

o NOx Control Division Update and solicit from member companies their SCR experience list. Solicit members to participate in technology workshop focused on industrial controls Hold conference call in Mid- January 2010 to continue developing SCR Whitepaper for

Industrial Applications o Integrated (SO2 &PM) Control Division

Update and solicit from member companies their FGD experience list. Develop supporting statement on the beneficial use of coal combustion residue (CCR)

• ICAC Holds Two Productive Division Meetings at Air Quality VII Conference – This October ICAC

held its mercury control and emissions measurement technical division meetings at the Air Quality VII conference in Arlington, VA. The following action items and highlights from both meetings are listed below.

o Mercury Control Division: Complete and Publish ACI Bid Specification and Evaluation Document Workgroup to Evaluate Mercury limits and timing in Senator Carper’s 3-P Bill Publish Current List of Commercial Mercury Bookings

o Emission Measurement Division: Complete final draft of Whitepaper: Ammonia Measurement for Combustion Sources by

December 2009 Workgroup to develop a whitepaper on Direct Measurement and Predictive Options for

Combustion Processes • ICAC Hosted Briefing Conference Call on Status of State Mercury Control and Measurement

Programs- ICAC members received a briefing on the status of state mercury control and measurement programs. The briefing highlighted preliminary results from an EPA funded study designed to evaluate the status of mercury control and measurement technology. Contractors working on the study include Northeast State of Coordinated Air Use Management (NESCAUM), Reaction Engineering International, and Energy & Environmental Strategies. The study will serve to inform EPA as it develops national emission standards for hazardous air pollutants for utility boilers. Recently EPA announced it will propose a rule by November 2010 to regulate utility air toxic emissions under its maximum achievable control technology standard. The final rule is expected no later than November 16, 2011 and there is a minimum 3 year implementation period. While there is no federal regulation in place to regulate HAPs emissions from power plants, there are approximately 19 states that have passed regulation or legislation requiring mercury emission reductions from power plants in the 2008-2010 timeframe. The state requirements have varying compliance deadlines and set emission reductions ranging from 85 to 95 percent. With regard to mercury monitoring state requirements also vary. Some states have chosen to adopt separate monitoring requirements while others are collecting base line emissions data.



The study’s preliminary results looked at the findings in a Government Accountability Office (GAO’s) October 2009 report, which acknowledged sorbent injection technology can achieve substantial mercury reductions in the 90 percent range while there are other configurations that are unable to meet that target based upon demonstration tests on lignite fired plants, high SO3 concentrations in flue-gas or plants with a hot-side ESPs. The EPA funded study will evaluate theses three areas to present a menu of technology options to assist the approx. ~34 percent of the coal plants with these configurations met a ~90 percent mercury limit.

The preliminary study also surveyed 14 states on the use of Hg CEMS and or Sorbent Traps. Based upon the survey 98 Hg CEMS and 17 Sorbent traps are operating in states with mercury requirements in place. However, the data from the monitoring equipment isn’t readily available to states under current regulatory regimes. For more information or to receive a copy of the presentation please go to: http://www.icac.com/files/members/Status_of_Mercury_Control_Measurement_Nov_19_2009.pdf .

• ICAC Supports U.S. Dept. of Commerce Efforts to Highlight GHG Control Technologies at

Copenhagen - The US Department of Commerce is collecting videos highlighting products, services, technology and/or R&D US industry has to offer to meet the challenges posed by climate change; especially solutions in renewable energy and energy efficiency that mitigate GHG emissions. Submissions should be 5-15 minutes in length and address GHG emission reductions from a solution-oriented point-of-view that is not necessarily biased to one product or service. Of special interest are any public/private partnerships which your company might be involved in. The US State Department is collecting videos for use at the US Presence Center at the COP15 negotiations in Copenhagen in December. The USG will need the rights to show the videos in public viewings at the COP15 and would like to retain those rights for follow-on activities and events. The US Commerce Department is looking for off-the-shelf materials. If your company has material and would like to make a submission please contact Carolyn Slaughter ([email protected]) as soon as possible. This is a unique opportunity for ICAC members to illustrate the capabilities of the U.S. air pollution control industry and its central role in the climate change issue.

• ICAC Co-Hosts Four Technology Presentations at the 2009 Chem Show- The Institute of Clean Air

Companies (ICAC) is an endorsing association of the 2009 Chem Show, which is the Chemical Process Industry’s biennial conference promising a comprehensive exhibition on a variety of topics from business solutions to engineering-oriented user seminars. The Institute of Clean Air Companies will be hosting a panel of emissions control technology presentations at the Chem Show on some of the latest technology developments that are designed to meet the growing challenge of reduced fiscal budgets and more stringent air emission limits.

• Strategies for Reducing Emission Control Operating Costs, Anguil Environmental • Flow Modeling for Chemical Processing, Kevin W. Linfield, Ph.D., P.E., Engineering

Manager; Airflow Science Corporation • Alternative Monitoring Systems for the Chemical Industry , Richard Hovan, Manager,

Environmental Solutions Pavilion Technologies • Complying with the PM2.5 Emissions Standard , Tom Anderson, National Sales Manager,

Midwesco Filter Resources

ICAC PARTICIPATTION IN OTHER STAKEHOLDER GROUPS


• ICAC Issues Carbon Capture Focus Paper – The focus paper outlines the air pollution control

industry’s perspective on how to expedite the commercialization of cost-effective carbon capture technologies. ICAC’s intent is to inform the policy debate on what will facilitate the commercial marketability of carbon capture technologies and processes for both new and existing coal-fired electric generating units, and greenhouse gas reductions from industrial process in the United States. A few key considerations should be kept in mind as the federal government moves forward in its considerations of GHG control requirements:

1) The threshold for commercial marketability of CC technologies is six to eight CC demonstration projects integrated with storage by 2015; 2) The Demonstration projects should treat 200-300 MW of flue gas capture at least 50% of the CO2 or at least 300,000 tons per year of CO2; 3) Conditions that facilitate and accelerate these demonstrations include financial incentives and regulatory certainty, availability of federal funding for first movers, targeted early and sustained distribution of funds for demonstration projects, attention to supply-side energy efficiency improvements of facilities, and federal attention on a framework on how to prepare existing facilities for CC retrofitting; 4) In addition, non-CO2 GHG industrial sources represent a near-term opportunity to retrofit existing sources using a wide range of commercially demonstrated technologies that do not rely on carbon capture and storage.

In order to realize the United States’ GHG emission reduction goals a near-term commitment to successfully demonstrating first mover projects, particularly before 2015 will generate huge dividends ensuring commercialization and technology acceptance. A continued long-term public and private investment in CC technology is vital to the success of stabilizing atmospheric CO2 concentrations.

To download ICAC’s Carbon Capture Focus Paper, go to: www.icac.com/ghg.

• ICAC is Updating Commercial Mercury Bookings List -ICAC is continuing to collect information

from members on their booking of mercury specific control technology. This effort has become increasingly more important now that the courts have vacated EPA's Clean Air Mercury Rule (CAMR) and EPA begins to develop a stringent mercury requirement for utilities. ICAC's list of projects is now up to over 100 commercial mercury control bookings. Typically ICAC has requested members’ updated information (i.e. plant size, APC technology, location, etc.) regarding any new mercury control projects they have booked. Plant names will remain confidential. If you have any information, corrections regarding any of your company’s projects please contact ICAC’s Carolyn Slaughter ([email protected]). Please visit http://www.icac.com/files/members/Hg_Commercial_Installations_Sept_09_public.xls , to review the draft October 2009 listing.

• ICAC Welcomes Holz Rubber Company as an Associate Member - Holz Rubber Company is a

leading manufacturer of non-metallic expansion joints, including spool, ducting, and high temperature composite joints installed in steam, gas, nuclear, etc. power plants. Applications include off-set flanges, corrosive media and high pressure situations. Holz Rubber has products it developed that withstand

MEMBERSHIP UPDATE



challenging wet and acidic conditions of FGD systems. Holz Rubber is headquartered at 1129 S Sacramento St., Lodi, CA 95240. Holz Rubber’s corporate representative to ICAC will be Ben Tannler, Director of Sales ([email protected] or 209/329-2822) and the corporate alternate will be Mark Ahonen, High Temp Ducting ([email protected]). Holz Rubber Company will initially participate in the Industrial Source, Integrated, and NOx Control divisions. For more information, go to: www.holzrubber.com.

1220 N. Fillmore St Suite 410 Arlington, VA 22201 703.812.4811 Fax 703. www.icac.com

IICCAACC OOPPEERRAATTIIOONNSS SSPPOOTTLLIIGGHHTT 3rd Quarter ICAC FY 2010, (January 1, 2010- March 31, 2010)


• ICAC Develops Emissions Control and Measurement Workshop for Midwest States-ICAC with State input developed a workshop to highlight the emission control and measurement technologies for industrial sources. ICAC has been working closely with Lake Michigan Air Directors Consortium (LADCO), a Midwest regional state planning organization to set up a workshop on March 24-25, 2010 focused on Innovative Industrial Source Control and Measurement Technologies. LADCO provides technical assessment for and assistance to its member states on issues related to air quality. LADCO’s major pollutants of concern are ozone, fine particles and regional haze and their precursors. The purpose of this workshop was to provide state/local and federal government agencies with the latest information on current and emerging emission control technologies for criteria and greenhouse gas (GHG) emissions. There were over 100 air quality officials in attendance. Workshop sessions addressed existing, commercially available controls, upgrading existing controls, and emerging control technologies for PM, NOx, and SOx; multi-pollutant emission reduction methods; activated carbon injection; emission measurement technologies; GHG control technologies; and state perspectives on technology and measurement issues in the permitting process. For more information about the meeting and to review final agenda go to: http://www.ladco.org/about/general/Emissions_Meeting/meeting.html

• EPA Roundtable Emissions Measurement Division: On March 2, 2010 ICAC co-hosted its annual

Emissions Measurement Roundtable Discussion with EPA in Research Triangle Park, NC. Emissions Measurement Roundtable discussion included the following topics; • EPA GHG Reporting Rule Implementation • Status of Procedure 3 Rule • Near Real Time Multi-Metals Ambient Fence Line Monitoring • Emissions Testing and EPA's Information Collection Requests • Method 202 Improvements • Large Area Source Ambient Monitoring • 2009-2010 Project Highlights • Updated on EPA Protocol Gas Verification Program The presentations from the roundtable are available on ICAC’s members’ only website at www.icac.com/emd.


• ICAC Held Two Division Meetings at EUEC- In conjunction with the EUEC conference in Phoenix,

AZ last week ICAC held its Mercury Control and Emissions Measurement Division meetings. See below for a list of action items from each meeting.

o Mercury Division Meeting Action Items Host conference call February 10, 2010 from 10-11 am ET to discuss drafting responses to

a NESCAUM questionnaire on the status and capabilities of mercury controls for certain plant configurations and fuel type (hot-side ESP, high SO3 and lignite). To participate on this call and receive discussion materials please email Carolyn Slaughter ([email protected])

Update Mercury Technology Fact Sheets. Go to: http://www.icac.com/i4a/pages/index.cfm?pageid=3347 to review fact sheets.

o Emissions Measurement Division Meeting Action Items

Complete Ammonia Measurement Whitepaper by April 2010 Develop a meeting agenda for the EPA Roundtable (March 2, 2010); ICAC is requesting

member input of the development of the agenda.

• ICAC Issues Carbon Capture Focus Paper – The focus paper outlines the air pollution control

industry’s perspective on how to expedite the commercialization of cost-effective carbon capture technologies. ICAC’s intent is to inform the policy debate on what will facilitate the commercial marketability of carbon capture technologies and processes for both new and existing coal-fired electric generating units, and greenhouse gas reductions from industrial process in the United States. A few key considerations should be kept in mind as the federal government moves forward in its considerations of GHG control requirements:

1) The threshold for commercial marketability of CC technologies is six to eight CC demonstration projects integrated with storage by 2015;

2) The Demonstration projects should treat 200-300 MW of flue gas capture at least 50% of the CO2 or at least 300,000 tons per year of CO2; 3) Conditions that facilitate and accelerate these demonstrations include financial incentives and regulatory certainty, availability of federal funding for first movers, targeted early and sustained distribution of funds for demonstration projects, attention to supply-side energy efficiency improvements of facilities, and federal attention on a framework on how to prepare existing facilities for CC retrofitting; 4) In addition, non-CO2 GHG industrial sources represent a near-term opportunity to retrofit existing sources using a wide range of commercially demonstrated technologies that do not rely on carbon capture and storage.

In order to realize the United States’ GHG emission reduction goals a near-term commitment to




successfully demonstrating first mover projects, particularly before 2015 will generate huge dividends ensuring commercialization and technology acceptance. A continued long-term public and private investment in CC technology is vital to the success of stabilizing atmospheric CO2 concentrations.

To download ICAC’s Carbon Capture Focus Paper, go to: www.icac.com/ghg.

• ICAC Releases Activated Carbon Injection System Bid Specification and Bid Evaluation Document- ICAC’s Mercury Control Technology Division developed the Bid Specification and Information Requirements and Bid Evaluation Form for Activated Carbon Injection Systems (HG-1) document to assist purchasers of activated carbon injection systems compile information necessary to procure meaningful bids from suppliers of activated carbon injection systems. The document includes bid specification information requirements, a bid evaluation and a sample bid specification. The document is available at no charge to ICAC members and government officials and for $ 30 to others. Please go to the member’s only website to download the PDF file: www.icac.com/Publications.

• ICAC is Updating Commercial Mercury Bookings List -ICAC is continuing to collect information

from members on their booking of mercury specific control technology. This effort has become increasingly more important now that the courts have vacated EPA's Clean Air Mercury Rule (CAMR) and EPA begins to develop a stringent mercury requirement for utilities. ICAC's list of projects is now up to over 100 commercial mercury control bookings. Typically ICAC has requested members’ updated information (i.e. plant size, APC technology, location, etc.) regarding any new mercury control projects they have booked. Plant names will remain confidential. If you have any information, corrections regarding any of your company’s projects please contact ICAC’s Carolyn Slaughter ([email protected]). Please visit http://www.icac.com/files/members/Hg_Commercial_Installations_Sept_09_public.xls , to review the draft October 2009 listing.

• ICAC Welcomes RLP Energy as a Regular Member. RLP Energy is a mercury capture and

monitoring company; offering several mercury control technologies. In recent years, RLP Energy has carried out several customized full-scale mercury control testing on electric utilities and anticipates near-term commercial sales driven by state and federal programs. RLP Energy operates out of Ottawa Canada, and its primary U.S. operations co-located at the EERC facility (undeer news) at 15 N 23 St., Grand Forks, North Dakota 58202. RLP Energy’s corporate representative to ICAC will be Rick Macpherson, CEO (701/330-3146 or [email protected]) and the alternate representative will be Patrick Glemaud, Corporate Attorney (701/330-3146 or [email protected]). RLP Energy will initially participate in the Mercury Control and the Emissions Measuring Divisions. RLP Energy regularly participates in the MegaSymposium and was referred to ICAC by Calgon Corporation. RLP Energy’s website is under construction

MEMBERSHIP UPDATE

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4th

Quarter ICAC FY 2010, (April 1, 2010- June 30, 2010)

The Operations Spotlight provides a brief summary of some of ICAC’s efforts to promote the understanding and capabilities of the air pollution control industry to regulators, potential members, customers, user groups, environmental groups, the media, universities, research organizations, and the public at large.

GOVERNMENT AFFAIRS

ICAC communicates with regulatory agency staff at the federal, state, and local levels on a regular basis concerning various air pollution control and measurement topics. Below are a few of the highlights from the most recent quarter:

• ICAC Attends EMA’s Environmental Markets Summit – ICAC staff attended Environmental Markets Association's Environmental Markets Summit: 14th Annual Spring Conference last week. The Environmental Markets Association (EMA) is the leading US-based environmental trade association for promoting market-based solutions as the key to combat environmental problems. Founded in 1996 by a group of emissions traders, EMA’s current membership includes brokers, traders, consultants, lawyers, academics, government agencies, affected industries (e.g., utilities, manufacturing; transportation, construction), and financial/investment companies centered on the following transactional markets: SO2, NOx, CO2, RECs, ERC Offsets.

Doug Austin, ICAC Government Affairs Manager, was on a panel that discussed the topic “Can Cap & Trade Exist Under the Clean Air Act?” However, the CAIR replacement rule was the original topic, so Doug took the opportunity to promote ICAC and the APC industry’s capability to meet the requirements in the upcoming tidal wave of air pollution regulations emanating from EPA. Doug also emphasized the entire suite of technologies to remove and measure pollutants on the assumption that the conference participants, primarily financial-types, have a limited view (SCR / FGD) of the many technologies available to stationary emission sources to reduce emissions of both criteria and hazardous air pollutants.

• ICAC Staff Attends Ozone Transport Commission Fall Meeting – On June 3rd, ICAC staff attended

the Ozone Transport Commission’s (OTC) Annual Meeting in Baltimore, MD. OTC, a multi-state organization created under the Clean Air Act (CAA), is responsible for advising EPA on air pollution transport issues and for developing and implementing regional solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic regions. State environmental commissioners and air quality chiefs from the 12 Northeast states and the District of Columbia, as well as EPA regional and headquarters staff attended the meeting. OTC typically uses the meeting to update the public and interested stakeholders on its development of regional control measures for reducing NOx and VOC emissions (the precursors to the formation of ground-level ozone) that the individual states have the discretion to implement or not, and to adopt statements, resolutions, and/or MOUs on their collective progress in attaining the health-based ozone National Ambient Air Quality Standard.

• ICAC Staff Attends EPA Public Hearing on Emissions Standards for Boilers and Process Heaters

and Commercial / Industrial Solid Waste Incinerators- On June 15th EPA held its first public hear on the suite of four proposed rules to regulate hazardous air pollutants from boilers, process heaters and waste incinerators. The proposals were published in the June 4, 2010 Federal Register. As expected industry outlined their general concerns with the major source IB MACT rule, namely requesting EPA Administrator to use her discretion and set a health based emission limit for HCl under Clean Air Act section 112(d)(4). The National Association of Clean Air Agencies (NACAA) testified congratulated


EPA on issuing the long over due proposed rule and cautioned the agency to not bow to pressure form industry on setting a health based standard. The second issue raised concerned the reasonableness of the emission limits proposed. Industry representative testified that EPA’s variability analysis selected only the top 1% and not the top 12% of best performing emission sources and that the air pollution control supplier community is unable to guarantee the currently proposed dioxin/furan and HCl limits for existing boilers. NACAA, also commented on EPA’s variability analysis stating EPA applies a statistical test that requires 99 % confidence that a standard has been exceeded before a violation is established. EPA also appears to calculate this factor on the basis of variability of individual test runs, even though the applicable standard requires averaging three individual test runs to reduce the variability that would be present in individual runs. In other rules EPA has used a 90 % confidence factor, applied to the average of three runs to calculate variability. The general result of requiring a higher confidence level is that the standard is higher than it otherwise would have been. A third issue raised by the Council for Industrial Boiler Owners (CIBO) challenging EPA to identify existing boilers that have demonstrated the ability to achieve all the proposed existing and new source emission limits simultaneously. CIBO and other industry representatives supported EPA’s proposed use of work practice standards for Gas 1 sources and requests the agency to consider its use for all sources using Gas 2 fuels. The fourth issues raised in testimony given by a small local utility, requested EPA consider subcategorizing EGUs with generating capacity of less than 25 MWs and harmonize their compliance with the Utility MACT or exempt them from the Utility MACT. During this hearing EPA also heard numerous requests to extend the comment period beyond August 3rd as the rule and supporting material require additional time for review and analysis given the complexity of the rule packages. The paper industry had a strong representation at the Washington, DC hearing citing concerns that EPA's proposed strict air toxics standard for boilers, will impose costly controls on biomass that will deter investment in biomass -- something that industry officials argue is at odds with the Obama administration's support for biomass as a renewable energy resource. The comment period for the rule ends August 3, 2010 and ICAC staff have been holding calls of our members to better understand the rule and to prepare comment. To participate in this process, please contact Doug Austin ([email protected]) or Carolyn Slaughter ([email protected]).

• ICAC Active in Supporting States’ Request for Multipollutant Controls from EGUs – In recent weeks, ICAC staff and members have been asked to provide technical support to State organizations in their appeal for NOx controls needed sooner and at more stringent levels than currently in Senator Carper’s bill (S.2995), and the bill’s legislative mercury MACT backstop. The Carper bill, S.2995, has been introduced in February 2010 as bipartisan 3-Pollutant legislation for control of NOx, SO2, and mercury. When introduced, the bill had 14 Senators from both sides of the aisle supporting the amendment to the Clean Air Act. States, particularly those in the northeast, contend that the NOx control requirements in Zone 1 (States east of the Mississippi River) of S.2995 are inadequate in addressing pollutant transport and as a backdrop for attaining increasingly stringent ozone standards. The States contend that the bill needs to provide greater certainty in their meeting health-based standards, as well as providing industry with greater certainty about control requirements. States involved in briefing Senate staffers have strongly supported the mercury provisions in S.2995 and its reliance requirements that would come from an EPA Mercury MACT process. ICAC’s role in these briefings has been to explain the breadth of technologies available, and provide information on our industry’s ability to install controls contemplated by the bill, the States’ proposal, and within the context of other major APC programs. The Carper Bill was the subject of a March 4, 2010 hearing by the Sen. Carper chaired Subcommittee on Air Quality and Nuclear Safety (under the Senate Environment and Public Works Committee). For more on S.2995, go to: S.2995 Carper 3-P Bill.


• EPA Briefing on Industrial Boiler and Major and Area Source Proposed Rule- ICAC hosted a conference

call briefing with EPA staff to discuss the proposed boiler MACT Rule. Approximately 50 member companies participated on the call. Most major source boilers and process heaters covered by the proposed major source rule are located at industrial facilities, and EPA estimates that there are approximately 13,555 boilers and process heaters at major sources in the United States. EPA has identified 11 different subcategories of boilers and process heaters based on the design of the various types of units, and the proposed rule would include specific requirements for each subcategory. The proposal would establish emission limits for: mercury, dioxin, particulate matter (PM) (as a surrogate for non-mercury metals), hydrogen chloride (HCl) (as a surrogate for acid gases), and carbon monoxide (CO) (as a surrogate for non-dioxin organic air toxics). EPA estimates that implementation of the rulemaking, as proposed, would reduce nationwide emissions from major source boilers and process heaters by: 15,000 pounds per year of mercury; 3,200 tpy of non-mercury metals; 37,000 tpy of HCl; 50,000 tpy of PM; 340,000 tpy of SO2; 722 grams per year of dioxin; and 1,800 tpy of volatile organic compounds. EPA estimates the total national capital cost for the final rule to be approximately $9.5 billion in the year 2013, with a total national annual cost of $2.9 billion in the year 2013. The annual cost, which considers fuel savings, includes control device operation and maintenance as well as monitoring, recordkeeping, reporting, and performance testing. In 2013, this rule will protect public health by avoiding: 1,900 to 4,800 premature deaths; 1,300 cases of chronic bronchitis; 3,000 nonfatal heart attacks; 3,200 hospital and emergency room visits; 3,000 cases of acute bronchitis; 250,000 days when people miss work; 33,000 cases of aggravated asthma; and 1,500,000 acute respiratory symptoms. The value of the benefits ranges from $17 billion to $41 billion in 2013.

• The Mercury Control Division hosted a conference call on May 12, 2010 to discuss updating the Mercury

Control Technology Fact Sheets developed in 2006. Members were invited to participate in a workgroup to begin updating the fact sheets and to collaborate in the development of additional fact sheets that address measurement and other technological developments in mercury control technology for coal fired power plants not addressed in the existing fact sheets. ICAC’s Mercury Control Division created four fact sheets on various technologies for mercury control at coal-fired power plants, below is a list of the current fact sheets. Please visit www.icac.com/mercuryfactsheets to review and download the draft fact sheets.

o MERCURY CONTROL WITH FABRIC FILTERS FROM COAL-FIRED BOILERS o SORBENT INJECTION TECHNOLOGY FOR CONTROL OF MERCURY EMISSIONS

FROM COAL-FIRED BOILERS o ENHANCING MERCURY CONTROL ON COAL-FIRED BOILERS WITH SCR,

OXIDATION CATALYST, AND FGD o PRE-COMBUSTION AND COMBUSTION TECHNOLOGY FOR CONTROL OF

MERCURY EMISSIONS FROM COAL-FIRED BOILERS • The Ammonia Measurement Whitepaper Workgroup held a conference call to discuss timing for

publishing ICAC’s Whitepaper on Ammonia Measurement Technologies for Fossil Fuel Fired Combustion Sources as well as to incorporate any remaining comments from the membership on the Whitepaper.



• ICAC 2010 Annual Meeting Wrap Up- The 2010 ICAC Annual Meeting marked our 50th and one of the best meetings yet! The highly successful format for the ICAC Annual Meeting once again was a winner! Meetings were closely coupled moving quickly from the meeting of the Board of Directors, to a plenary session for members with invited experts and followed with a full suite of technical Division meetings. Members and guests networked and united socially over food and receptions - special thanks to this year’s network sponsors ICL-IP and FuelTech. To help us better understand how our businesses fit in with the changing economy and regulations, this year members heard from and had an active exchanges with Dr. Denny Ellerman a retired MIT senior lecturer on cap and trade and its potential for application to GHG’s; Janet Giesselman, Dow Chemical General Manager for Oil & Gas and GHG solutions; Abe Breehey, Director of Legislative Affairs for the International Brotherhood of Boilermakers on labor availability and common interests with ICAC; Ryan Fair of Florida Power & Light on power industry preparing for air quality initiatives; Dr. Bob Wayland, EPA Group Leader on NESHAP/MACT rules and stationary source energy strategies; Bill Becker, the Executive Director for NACAA – the association of U.S. state and local air officials; John Holmes of AEMS on control considerations for cement production; and Henry Weber on how the ICAC APC Market Forecast is prepared annually and being prepared for its 29th issue release in July.

In a sophisticated round of Q&A, members took the opportunity to dialogue and delve deeper into the speakers’ areas of expertise. Equally as dynamic, the Division chairs and ICAC staffer Carolyn Slaughter led highly interactive member discussions in the different Division areas (Industrial Sources, Mercury, NOx, SO2, PM, GHG, and emissions measuring) on how to most effectively apply ICAC resources to best position itself as regulatory initiatives are being shaped. As was clear from the meeting, the APC markets are rebounding with substantial new control and measurement initiatives being released this year for both the power and industrial sectors. By the numbers, more than half of the ICAC member companies participated in this Annual Meeting, including 100 percent attendance by Officers and Directors, thirty spouses participated, nine guest speakers, and three companies that are considering membership. At the general membership meeting held on Friday, ICAC President Joe Langone and the Executive Director David Foerter, approved the 2011 slate of Officers and Directors, gave a heads up on letters being sent out on dues commitments needed for the 2011 budget, and presented special achievement awards to members Ken Greaves of CEMTEK Environmental, Dan Kietzer of SICK Maihak and James Staudt of Andover Technology Partners for their work with staff this past year that has made ICAC stronger. On behalf of the Board and members, staff presented Joe Langone with the Outstanding Achievement Award for his presidential leadership from 2008 through 2010. The conclusion of any Annual Meeting is not complete until members take to the greens, and a few to the courts, in competitive sports. This year, ICL-IP rewarded Jan Durham the winner of the ‘longest drive’ with a top-end driver. If you missed the 2010 meeting, plan for the 2011 Annual Meeting that starts on April 28 in Point Clear, Alabama (see website for more). Annual meetings are a unique opportunity for the APC community to come together face-to-face to work hard and benefit from the networking opportunities.

The presentations from ICAC’s 2010 Annual Meeting are posted as PDF files on the members’ only website. Please visit www.icac.com/annualmeeting to download the presentations, attendee list, and division meeting presentations.

2010 ANNUAL MEETING


• ICAC Welcomes Koch Knight as an Associate Member -Koch Knight LLC provides corrosion

solutions and heat exchange media serving various industries including the refining and petrochemical industries. Product offerings include heat transfer media for regenerative thermal oxidizers (RTOs) and other types of thermal oxidation systems, random and structured packing materials (ceramics, plastics, monolith honeycomb, etc.), ceramic and graphite tower internals, sumps, brick linings, mortars, acid-proof membranes, and overall design, installation, and service capabilities in corrosion systems. Koch Knight is located at 283 Summer Shade Drive in Somerset, Kentucky 42503. Koch Knight’s corporate representative to ICAC will be Paul Sims, Global Market Manager – Environmental (606/678-0801 or [email protected]) and the alternate representative will be Geza Zirczy, Business Development Manager – WFGD (330/488-1651 or [email protected]). Koch Knight LLC will initially participate in the Industrial Source and Integrated (PM/SO2) Control Divisions. Koch Knight’s Paul Sims attended the 2010 Annual Meeting in April. For more information, go to: http://www.kochknight.com/products.htm.

• ICAC Welcomes Met-Pro Corporation as a Regular Member- Met-Pro Corporation designs and

builds turnkey VOC and HAP destruction thermal and catalytic oxidation systems as well as servicing through its other divisions a wide range of industrial and municipal sector multimedia solutions, products and systems including systems for treatment of odors, corrosive fumes and air toxics. Met-Pro Corporation is located at Box 144, 160 Cassell Rd. in Harleysville, PA 19438. Met-Pro Corporation’s corporate representative to ICAC will be Thomas Edwards, Technical Director (215/723-6751 or [email protected]) and the alternate representative will be Paul Tetley, Executive Vice President (215/723-6751 or [email protected]). Met-Pro will initially participate in the Industrial Source Control Division. Met-Pro Corporation also is a member of the U.S. Dept. of Commerce’s Environmental Technology Trade Advisory Committee (ETTAC) with ICAC’s Executive Director. For more, go to: http://www.met-pro.com/index.htm.

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