Burns & McDonnell completed a Phase 1 study with the the University of Missouri-Columbia (UMC) Power Plant. UMC was subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers and Process Heaters (the Industrial Boiler Maximum Achievable Control Technology, or MACT). The Industrial Boiler MACT required the UMC Power Plant to meet emission limits for particulate matter (PM), mercury (Hg) and hydrogen chloride (HCl).
In 2004, shortly after the final Boiler MACT Rule was published, UMC requested that Burns & McDonnell perform the baseline emissions testing and provide analysis of the results. Upon completion of the baseline testing and a review of the results and other available data (coal fuel analyses, operations information, etc.), a number of compliance alternatives were considered and included:
- Compliance demonstration for PM, Hg, and HCl by stack testing for all boilers.
- Compliance demonstration for Hg and HCl by fuel analysis for all boilers.
- Compliance demonstration for HCl by health-based demonstration for all boilers.
- Compliance demonstration by emissions averaging.
- Compliance demonstration by a combination of the above methods.
The evaluation also took into account the impact of existing operations including hydrated lime injection and burning of tire-derive fuel (TDF) on compliance with the Industrial Boiler MACT rule.
The compliance alternatives evaluation resulted in a recommended compliance plan which included a recommended compliance approach (stack test, fuel analysis, health-based demonstration) for each boiler, how the compliance approach should be implemented (e.g., boiler operating conditions, hydrated lime injection on or off, TDF firing or not), and a compliance schedule indicating when notifications are due, testing should be completed, etc.
- Industrial Boiler MACT-related stack testing (Hg, HCl, PM)
- Review of coal analyses, stack testing results and develop design basis
- Technology screening and alternatives evaluation
- Cost estimates