Chemical Engineering March 2012 - 21

TABLE 2. BASE COST
ASSUMPTIONS FOR A
RESOURCES AVAILABLE ONLINE
250 MILLION Btu/h BOILER
Fabric filter (FF)
Scrubber
Scrubber/FF/ESP upgrade
Combustion,
fuel feed
improvements or catalyst
for CO
$7 million
$8 million
$4 million
Carbon injection for Hg $1 million
$3 million
The following resources, which are referenced by number in brackets within this story,
are available for download in the online version of this story*:
1. EPA's No Action Assurance Letter
2. EPA's December 2011 Proposed Reconsideration of Final Rule
3. CIBO's " How Costs Were Determined for CIBO Boiler MACT Impacts Study "
4. CIBO's Economic Impact Analysis: Estimate of State Level Impacts of Potential Jobs
at Risk
5. EPA's updated cost-impact analysis (12/2012)
6. Multi-association letter to Congress, urging support for EPA Regulatory Relief Act
* The story and further developments can be found at www.che.com, under Web Extras. To access
these files, look under the Online Extras Tab at the top of the story.
in whatever vehicle is available to
move it, " says CIBO's Bessette.
Legislative vehicles come in unexpected
forms, and at CE press time,
consideration to include the act as
part of the conference agreement on
payroll tax-cut extension legislation
(H.R. 3630) appeared to have been
discarded. (For more on the status as
it develops, check the online version of
this story at www.che.com.)*
The reasons for passing the Relief
Act, as detailed in a multi-association
letter to members of Congress [6], are
that serious challenges still remain:
Jobs are in jeopardy. In the re-proposed
rules, some standards became
more stringent, and some limits may
not be achievable, especially in the current
three-year compliance timeframe.
Serious legal uncertainty. The
court decision overturning EPA's stay
of the March 2011 rules is yet another
example of the continuing morass of
uncertainty surrounding the rules -
a problem legislation would solve.
Important biomass materials are
still not listed as fuels. This means
that the boilers burning these materials
could be regulated under the
onerous and stigmatizing incinerator
standards, or the material would be
land filled.
Inadequate capital planning time.
The rules do not provide enough time
for capital planning and compliance,
given their complexity and competition
for a limited pool of qualified domestic
vendors and installers. Businesses
need five years to fully comply with
the rules, not the two or three years in
the current rules.
Inadequate time to finalize rules.
EPA's current rulemaking schedule
is so accelerated that it is unlikely all
the comments and data that will be
received during the current comment
period can be fully analyzed and utilized.
Moving too fast increases the
likelihood that the final rules will be
overturned again.
EPA declined to comment on the act
that is being considered in Congress. ■
Rebekkah Marshall
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CHEMICAL ENGINEERING WWW.CHE.COM MARCH 2012 21

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Chemical Engineering March 2012

Table of Contents for the Digital Edition of Chemical Engineering March 2012