include 'common/uniqueness.php'; include 'common/EndLeft-BeginCenter.php'; ?>

This page collects and publishs ideas to help facilities impacted by the Cross State Air Pollution Rule.


Many companies must quickly do something to address the new Cross State Air Pollution Rule. For some this looks like a daunting task. Here is what these companies have said publicly:

Other that have installed equipment that reduces the SOX and NOX and can benefit from more credit sales by optimizing there operations.

We have created this page to offer our suggestions on what can be done quickly and to gather ideas from others and share them.

What is it and who does it effect?

See EPA doc Cross-State Air Pollution Rule (CSAPR)


What do they need to do?
What are the immediate steps being taken?
What future steps will be taken?
Where does CleanAir fit in?

Our combination of service offerings between emission testing and boiler efficiency work should translate into opportunities to maximize value for effected utilities. More efficient fuel usage will be a factor in meeting the new limits.

With increased emphasis on NOx reduction over the full calendar year there should be an uptick in SCR installations and thus an increase in tuning opportunities.

As plants add scrubbers to meet the SO2 reduction limits of CSAPR they will also be looking at ACI to reduce mercury in these same scrubbers. We should see an uptick in Hg testing and potentially an increased demand for Hg monitors as well.
Which facilities have the greatest challenges?

What can be done fast? What is low priced fruit? What are the no brainers?

NOX - Add SNRC if there is no SCR installed

This can be done by a number of companies including:

FuelTech's NOxOUT®

(see others listed on WPCA)

Add SNRC to the installed SCR and take one SCR catalyst bed out of service

Tune the SCR - This service is offered by CleanAir- Th

Tune Burners

SO2 - Switch to a coal with a lower sulfur content

Blend present contracted coal and a lower sulfur content coal

improve heat rate ( combustion efficiency )

Use automated 3D probes for EPA methods 2f & 2h to get more accurate flow.

NOTE, most stack gas flow measurements and CEM flow meter calibrations are biased high due to the inherent Method 2 errors. This can result in the emissions being reported high by 10% or more.

Make sure you CEM flow meter is linear over the normal operating range.

If the present flow CEM system go out of calibration quickly and require constant maintenance switch to a low maintenance technology such a automated pitot tube.

Ozone - Tune the SCR

Which potential clients have the greatest challenges?

EPA's Summary
EPA's rule - along with state actions -- will cut SO 2 and NO x emissions in a phased in approach over the next two years:
  • January 1, 2012: CSAPR Phase 1 SO2and annual NOx trading programs begin
  • May 1, 2012: CSAPR ozone season NOx trading program begins
  • Ozone season ends September 30
  • January 1, 2014: Phase 2 SO2and annual NOx trading programs begin
  • May 1, 2014: CSPAR Phase 2 ozone season NOx trading program begins
  • CAIR will be implemented through 2011 compliance periods -CAIR then replaced by CSAPR
  • Compared to 2005, EPA estimates that by 2014 this rule and other federal rules will lower power plant annual emissions in the CSAPR region by:
    • 6.4 million tons per year of SO 2 - a 73% reduction
    • 1.4 million tons per year of NO X - a 54% reduction
    • Including 340,000 tons per year of NO X during the ozone season
  • CSAPR, including states proposed for inclusion in the supplemental notice of proposed rule making,
    • covers 3,642 electric generating units
    • 1,081 coal-, gas-, and oil-fired facilities in 28 states.
  • EPA's modeling projects that by 2014, in the states covered by CSAPR.
    • Approximately 70% of the power generated from coal-fired power plants will come from units with state-of-the-art SO 2 controls (such as scrubbers).
    • Approximately 50 percent of the power generated from coal-fired power plants will come from units with state of the art NO X controls (such as SCR).
  • EPA modeling anticipates that coal use will continue to grow under CSAPR.
  • To meet the requirements of the rule, EPA assumes power plants will:
    • Maintaining effective and frequent operation of already installed NOx and SO2 pollution control equipment,
    • Using low sulfur coal or fuel switching,
    • Increasing generation from relatively cleaner units, and/or
    • Installing existing, commercially proven technologies that are widely available and frequently used in this industry, such as low NO X burners, scrubbers (flue gas desulfurization), or dry sorbent injection.
  • EPA estimates that the $800 million spent annually on this rule in 2014, along with the roughly $1.6 billion per year in capital investments already under way as a result of CAIR, are improving air quality for over 240 million Americans and will result in $120 to $280 billion in annual benefits. These estimates include the costs and benefits of the supplemental proposal.

Below is a chart that shows the relative emission reductions in millions of tons for each pollutant and each stage of the rule.