1 / 8

Non-Hg HAPs: A Utility View

Non-Hg HAPs: A Utility View. Larry S. Monroe, Ph.D. EPA MACT Working Group July 9, 2002. Outline . Health risks (or lack of) Data (real lack of) MACT Process Implications. Non-Hg HAPs and Health Risks. No EPA finding of health concerns for non-Hg HAPs

ostinmannual
Download Presentation

Non-Hg HAPs: A Utility View

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Non-Hg HAPs: A Utility View Larry S. Monroe, Ph.D. EPA MACT Working Group July 9, 2002

  2. Outline • Health risks (or lack of) • Data (real lack of) • MACT Process • Implications

  3. Non-Hg HAPs and Health Risks • No EPA finding of health concerns for non-Hg HAPs • For non-carcinogens, MACT not invoked for Cl2 & HCl by EPA for chlor-alkali plants due to “below threshold” determination (Fed. Reg. 7/3/02) • EPA in Report to Congress stated only two HAPs (arsenic and dioxins) are “of potential concern” but “further evaluations and reviews” are needed • EPRI (1994) found that multimedia risk for all carcinogens was below 1 in 1 million for all plants studied and that, for non-carcinogens, all exposures were below threshold levels

  4. Non-Hg HAPs Data for Utilities • Existing data - old, questionable • Organics very bad, especially dioxin • Trace metals best of bad lot • Acid gases limited • Source plant selection - no design! • funding and DOE projects determined site measured • coal type, control tech., boiler type, etc. not selected • Conclusion - Data not sufficient to determine “achieved” performance of best or top 12% of sources

  5. MACT Floor Determination Process 1. Regulatory determination 2. Data assessment • Get more data? 3. Subcategory determination 4. Floor level set • “achieved performance” • variability, process differences, etc. 5. Beyond the floor 6. Compliance • Method, time scale, etc. 7. Draft rule

  6. Equipment & Work Practice Standard MACT Floor Determination Process 1. Regulatory determination 2. Data assessment • Get more data? 3. Subcategory determination 4. Floor level set • “achieved performance” • variability, process differences, etc. 5. Beyond the floor 6. Compliance • Method, time scale, etc. 7. Draft rule

  7. Equipment & Work Practice Standard Equipment & Work Practice Standard MACT Floor Determination Process 1. Regulatory determination 2. Data assessment • Get more data? 3. Subcategory determination 4. Floor level set • “achieved performance” • variability, process differences, etc. 5. Beyond the floor 6. Compliance • Method, time scale, etc. 7. Draft rule

  8. Implications • Clean Air Act calls for regulation of industry if and only if there is a health basis • As proposed, the surrogate approach would swallow virtually the whole Clean Air Act • Costs could approach $100+ billion, severe impact to world economy • Draconian impact on the industry with no finding of health concerns • No non-carcinogen has been shown to be near a health threshold (EPA & EPRI)

More Related