Coal Plants Face Strict Startup Plan

By Cathy Cash | ECT Staff Writer Published: September 13th, 2013

When it comes to startup and shutdown, not all power plants function equally.

That’s what the Environmental Protection Agency needs to understand as it reconsiders a proposed rule on startup and shutdown issues for coal-based generation under mandates to limit emissions of hazardous air pollutants or HAPs, NRECA said.

The association is letting EPA know that the proposed startup/shutdown requirements should not interfere with other emission compliance mandates coal plants face.

“We are not certain that all cooperatively owned units can meet HAPS emissions standards by the end of the proposed startup because some are in the process of installing the required emission control technology,” said Rae Cronmiller, NRECA’s environmental counsel, who recently filed comments with EPA on the proposed rule.

“EPA should conclude and state definitively in the final rule that the startup definition for HAPS involving coal-based generation is not applicable for other emission compliance obligations,” Cronmiller said.

NRECA further believes the startup rule should clearly incorporate the law’s “malfunction defense,” that would allow units to avoid noncompliance penalties for startup failures that exceed their proposed time allowed.

The current proposal is “unnecessarily restrictive,” according to NRECA. Instead, EPA should recognize the various unit designs and configurations that result in non-uniform startup periods.

“Our members have experienced planned and unplanned interruptions in startups ranging in duration from a few hours to multiple days,” Cronmiller said.

Fossil units owned and operated by co-ops are required to control traditional emissions and operate various air pollution controls as under the Clean Air Act that can influence a unit’s startup and releases during that initial combustion.

Sixty-five rural electric generating and transmission co-ops provide power to 668 of the country’s 841 distribution cooperatives. About 80 percent of this generation—26,000 megawatts—is coal-based and equipped with low nitrogen oxides controls.

More than 60 percent is equipped with flue gas desulphurization (FGD) units or “scrubbers” to control sulfur dioxide emissions. About 6,000 MWs is also retrofitted with state-of-the-art nitrogen oxides controls or selective catalytic reduction.

For units with dry FGD systems and ash recycling, the startup time following planned outages can range from about six hours to as many as 32 hours for major scheduled outages. Depending on the scrubber system installed, units may require six to 18 hours to achieve sustainable sulfur dioxide reductions, NRECA told the agency.

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