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ICAC Success Stories

An Industry Success Story

ADA Environmental Solutions 

Many trade associations work on behalf of its members to ensure that their collective voice is heard on Capitol Hill and beyond. ICAC delivers far more by enabling its members to share technical information with EPA and other government entities that help shape regulations based on practical, achievable and measurable emissions limitations for clean air policies. For ADA-ES, a leader in environmental technologies, by being part of ICAC it allowed them to leverage opportunities generated by the 2012 EPA Mercury and Air Toxic Standard (MATS) to gain a foothold in the Activated Carbon Injection (ACI) and Dry Sorbent Injection (DSI) systems marketplace for controlling acid gases.

 

The Challenge

When MATS was issued as a final regulation in April 2012, EPA's limit on mercury emissions for new sources was considered by many to be unrealistic.  While ICAC member companies felt comfortable that the MATS mercury limit for existing sources was achievable, they concluded that they could neither measure the low mercury concentrations nor reduce the emissions to meet the EPA standard for new sources. ADA-ES, a pioneer in environmental technologies, specialty chemical products, and consulting services for coal-fired power plants, industrial boilers and Portland cement kilns, believed this was a serious issue. "We agreed with the other ICAC member companies that provided mercury measurement and control technology that new power plants could not be built because of the lack of available technology to meet the mercury limit," said Michael Durham, President and CEO of ADA-ES. "And we came to realize that the most cost-effective way to address the issue was to take advantage of the important role that ICAC played in the policy discussions that occurred after MATS was made final."

Over several months, ICAC became deeply involved in trying to resolve this matter which had significant implications for US national energy policies. Meeting with EPA and providing public comments on the availability of technologies based in solid technical data, ICAC represented the collective voices of suppliers of air pollution monitoring and control systems, equipment, and services for stationary sources in the U.S. and Canada. With this strong supporting information, EPA was able to modify the MATS regulation and established a more achievable limit for mercury emissions from new power plants.

 

"We renewed our ICAC membership because we are becoming more active in our networking. ICAC is an ideal way to remain connected with the industry while realizing significant business opportunities for growth."

 

The Opportunity

With the MATS rule now finalized, policy discussions have turned toward the control of greenhouse gases and emissions of carbon dioxide.  ADA-ES along with other ICAC members are developing technologies to capture CO2 from power plants and industrial sources.  “We have a strong interest in keeping abreast of the status of the developing regulations and participating in the national discussions among stakeholders and policy makers,” said Durham.

Through ICAC, ADA-ES and other ICAC member companies have the opportunity for their collective voice to be  heard and to help educate regulators and legislators with the most up-to-date and accurate technical information on the capabilities and availability of emission control technology to meet the challenges of climate change.

 

The Result

Since joining ICAC, ADA-ES has grown from a dozen people to over 300 employees.  The company is now publicly traded on NASDAQ as Advanced Emissions Solutions (ADES) with a market cap in excess of $500 Million. ADA-ES attributes much of its success to its relationships with different ICAC member companies of varying sizes and a wide range of expertise.  ADA-ES believes that ICAC offers the ultimate advocacy initiatives through its technical information outreach efforts which impact and connect with the leading regulatory drivers. 

"I would recommend that any company involved in the measurement and control of air pollution join ICAC and take an active role in the regulatory processes that create markets and drive their businesses," Durham says.  "ICAC provides an affordable and effective means to help define your future."

 

ICAC Success Stories

MATS

When MATS was issued as a final regulation in April 2012, EPA’s limit on mercury emissions for new sources was considered by many to be unrealistic.  While ICAC member companies felt comfortable that the MATS mercury limit for existing sources was achievable, they concluded that they could neither measure the low mercury concentrations nor reduce the emissions to meet the EPA standard for new sources.   Over several months, ICAC became intensely involved in trying to resolve this significant national US energy policy issue.  ICAC members met with the EPA and provided public comments on the availability of technologies based on solid technical data. With this strong supporting information from its members, the EPA modified the MATS regulation and established a more achievable limit for mercury emissions from new power plants.

NOx Control

ICAC is instrumental in advocating and sharing information regarding the use of NOx control technology in the United States.  ICAC members continue to take a leading role in demonstrating NOx technology for a wide range of applications while ensuring EPA regulations are consistent with the technology and measurement capabilities. 
Greenhouse Gas Control

ICAC members are leading the development and deployment of critical technologies for greenhouse gas control. Technologies for non-CO2 gas control are already being deployed globally, and ICAC is using its access to regulators to provide evidence of control for such greenhouse gases as nitrous oxide (N2O), chlorinated fluorinated hydrocarbons (CFC), and methane.  The development and deployment of carbon capture and sequestration technologies from power plants is the preeminent topic in air pollution control in the US today. ICAC has been solicited by all interested parties – Administration, EPA, Congress, and other environmental groups - as to the state of the technology and readiness for deployment.  No other trade association has the collective knowledge to provide current and relevant data on this topic.  ICAC continues to work with all parties to ensure that the development and deployment of a broad range of technologies for greenhouse gas control are properly funded, and realistic targets established for reliable deployment.

Industrial

ICAC members are instrumental in deploying innovative control technology leading the VOC emission reductions typically of 99%, with energy efficiency (heat recovery) exceeding 95%. ICAC submitted comments to various MACT’s - ICI Boiler MACT, Cement MACT, and RICE engines - resulting in changes consistent with the control and measurement technology capabilities.

 

ICAC Division Success Stories

Emissions Measurement Division

Many trade associations work on behalf of its members to ensure that their collective voice is
heard on Capitol Hill and beyond. ICAC delivers far more by enabling its members to share technical information with EPA and other government entities that help shape regulations based on
practical, achievable and measurable emissions limitations for clean air policies. By participating in the Emissions Measurement Division, MKS Instruments Inc. was able to bring their issues and questions directly to the EPA on the issue of Continuous Emissions Monitoring (CEM).

 

The Challenge

If a customer wants to use a Fourier Transform Infrared Spectrometer (FTIR) for a Continuous Emission Monitor (CEM) for their facility emissions, they must follow Performance Specification 15 to validate their CEM system and then perform the reference method (RM), EPA M320 for the initial and on-going RATA of that system. If the user is measuring hydrogen chloride (HCl) and are a Portland Cement (PC) Kiln or Electrical Generating Utility (EGU), then they may use either PS15 or the newly developed PS18 for validation of the CEM upon installation.

CEM systems that do not use FTIR technologies may use performance specifications other than PS15 and reference method M320 that have been made technology neutral. PS15 and EPA M320 were written over 15 years ago, have several small errors, are outdated, and require many layers of unnecessary QA/QC steps that are no longer necessary with the latest FTIR advancements on the market.

These older FTIR methods have become burdensome and restrictive to FTIR instrumentation and biased against FTIR when potential customers are considering FTIR against other technologies to use in their CEM. In addition, PS15 required a quarterly submission of raw spectra of the process to EPA, which contains information about many other compounds emitted by the customer for which they may not want public, which may be used against them at a later date should new regulations be developed.


“The ICAC gave us a voice when sitting down with EPA during one of their EPA roundtable meetings and allowed us to present the issues with FTIR CEM use.” - Dr. Peter G. Zemek

The Opportunity

As an ICAC member, MKS gained access to many of the EPA personnel directly responsible for writing and enforcing these regulations and standards for CEM technologies.  MKS also gained input and strength in numbers from the participation of other FTIR manufacturers and users in the ICAC trying to get EPA to modify or rewrite the standards and regulations affecting the use of FTIR CEMs.

 

The ICAC gave us a voice when sitting down with EPA during one of their EPA roundtable meetings and allowed us to present the issues with FTIR CEM use with these outdated standards and regulations.  We also have the power and support of the entire ICAC membership and board of directors when backing up our claims and requests to EPA.

 

This allows FTIR to remain one of the most versatile, powerful, and cost effective solutions for many existing and new users with the new capabilities in detectors, broad spectrum target compound capabilities, and new hardware and software capabilities to obtain relevant low concentration emissions information.

The Result

After careful deliberation and listening to presentations, review of data submissions, and field trials, the EPA has informed the ICAC that they will rewrite PS15 and RM 320 and that these tasks are on their calendar and EPA has started the modification process. In addition, EPA has verbally confirmed that they will no longer require quarterly submission of raw spectral data from anyone using an FTIR as a CEM as per PS15.    EPA will only require final reported concentrations like any other type CEM instrumental technology.  This eliminates the ability of EPA to use any previously reported data to be used in the future against the owners of FTIR CEM technology.

Lessons Learned

Presently, EPA’s Office of Air Quality Planning and Standards (OAQPS) and Office of Air and Radiation (ORD) are short staffed and have a large work backlog.   Unless you can get your voice heard with the backing of a larger organization and direct talks with EPA by leveraging the relationship ICAC has carefully crafted over the years, you will be hard pressed to get EPA to address your problem in a timely matter. ICAC gives you the tools and leadership to bring your issues and questions directly to EPA or directly to the other members with a vast knowledge base and experience.  It is better to work through your needs as a team than to go it alone in the vast, tangled world of environmental regulations and standards.

 

Mercury Control Division

Presently, EPA’s Office of Air Quality Planning and Standards (OAQPS) and Office of Air and Radiation (ORD) are short staffed and have a large work backlog.   Unless you can get your voice heard with the backing of a larger organization and direct talks with EPA by leveraging the relationship ICAC has carefully crafted over the years, you will be hard pressed to get EPA to address your problem in a timely matter. ICAC gives you the tools and leadership to bring your issues and questions directly to EPA or directly to the other members with a vast knowledge base and experience.  It is better to work through your needs as a team than to go it alone in the vast, tangled world of environmental regulations and standards.

 

The Challenge

The National Fire Protection Agency (NFPA) was developing a new standard that had draft language that was alarming and misleading regarding activated carbon. An ICAC member brought this to the division's attention and other suppliers agreed that it was an important issue.  ICAC supported the effort and the mercury control division put together a workgroup to get involved in NFPA's public comment process.

 

The Opportunity

NFPA has a very rigorous process for developing standards. This was an opportunity to learn about the process and to influence the language that went into the final standard. NFPA relies on experts who donate their time to develop standards, and ICAC has important technical information to offer in some cases. This can apply to a new standard or a revision, NFPA updates its standards periodically.  For those that are important to ICAC members, ICAC can be an important voice that elevates input above just an individual company's viewpoint.


 

"As a united voice of multiple suppliers, the NFPA took ICAC's input seriously and was very responsive to our efforts to present and discuss our viewpoint." - Sheila Glesmann

 

The Result

As a united voice of multiple suppliers, the NFPA took ICAC's input seriously and was very responsive to our efforts to present and discuss our viewpoint. NFPA is an organization that protects life and property, and rightly takes its mission very seriously.  By interfacing with NFPA as an organization, ICAC was able to mitigate the severity of the language and present it in a more accurate light.

 

Lessons Learned

Rules and regulations are not just driven by EPA. There are other areas where our members can benefit from influencing the process and having a voice at the right time.  It is challenging for every company to stay on top of every change in policy, rule, standard or regulation that is going on out there. Any individual can identify an issue and raise it to the group, and your influence on the area where you are advocating can be amplified, collectively benefitting both your message and the group.

 

ICAC Testimonials

"For the past decade, ADA Environmental Solution has been an active member of the Institute of Clean Air Companies (ICAC). We've appreciated the considerable benefits this membership has provided for the company. Being a small company, we took advantage of the opportunity to be part of a larger industry organization and have an influential voice in Washington, participating in the development of laws and regulations that drive our markets. This increased awareness of future regulations has helped us guide our development of technologies and products to meet evolving markets. ICAC also provides us access to other key individuals and companies in the air pollution field, several of which have become customers of ADA's products and business partners. The return on our investment in ICAC membership has paid off for ADA many times over."

— ADA Environmental Solutions


 

View the printable version of the ICAC Success Stories.  

View the printable version of the ICAC Emissions Measurement Division Success Story.

View the printable version of the ICAC Mercury Control Division Success Story.

 

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