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Finalizing the HAP MACT Rules

December 21, 2011

HAP MACT rules from EPA this afternoon are inline with expectations
EPA’s finalized HAP MACT or MATS rules released this afternoon were inline
with our expectations, largely leaving intact most of the impact of HAP MACT
regulations. Tweaks to the final rule will slightly mitigate total capex; all in,
proposed changes do not shift our retirement thesis. Notably, EPA backed away
from a total particulate matter (PM) std. (incl. condensable particulates), opting for
a filterable target (mitigating baghouse needs for some units). Other reforms
provided for latitude around unit startup, and greater flexibility around facilitywide
averaging of emissions (for sites w/ multiple units). The final rules also
incorporate the 1.2lb/TBtu target for mercury (shy of the 1.4lb/Tbtu target the
industry has strenuously pursued), previously updated by EPA from the proposal.(Read more view attachment below)
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Alissa Oppenheimer,
Dec 28, 2011, 9:56 AM
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