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EPA Utility MACT Development Update

Detailed progress report on EPA Utility MACT development process, timelines, subcategorization examples, and tools used for regulatory modeling. Requesting input on subcategorization options and the need for prompt feedback.

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EPA Utility MACT Development Update

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  1. Update on EPA Utility MACT Development February 5, 2002 Washington, D.C. Sally Shaver US EPA

  2. Where are we on the schedule? • Must work backwards from end-date • Proposal on/before December 15, 2003 • Package to Administrator by November 30 • Package to OMB by August 1 • Package to EPA/D.C. by June 1 • Prepare package December 2002 - May 2003

  3. Where does this leave the Working Group? • Subcategorization options by April 2002 • Floor options by April 2002 • IPM runs of options May - June 2002 • REMSAD runs of options July - August 2002 • Working Group review of analyses September - November 2002 • Working Group feedback December 2002

  4. How does this mesh with existing schedule? • In draft “Charge and Process” document • Have slipped some from that schedule • Preliminary subcategory/floor options - 12/01 • Preliminary regulatory alternatives - 01/02 • Further discussions - to 04/02 • Final MACT subcategory/floor recommendations still can be on-schedule

  5. When does EPA need closure from Working Group? • Subcategories -- April 2002 • Floors -- April 2002 • Regulatory alternatives/MACT standard -- December 2002

  6. Subcategorization Examples February 5, 2002 Washington, D.C. Sally Shaver US EPA

  7. EPA’s take on “subcategorization” • Believe that section 112 clearly gives EPA the authority to subcategorize…or not • 112(d)(1): “…Administrator may distinguish among classes, types, and sizes of sources within a category or subcategory in establishing such standards…”

  8. How has EPA subcategorized previous MACT standards? • By process • BMA/Andrussow vs. Sohio vs. neutralization HCN processes • Loop slitter vs. flame lamination flexible polyurethane foam fabrication processes • Batch vs. continuous polymers and resins processes • Kraft vs. sulfite vs. soda vs. semi-chemical pulp and paper production processes

  9. By equipment • Short vs. tall by-product coke oven batteries • Open vs. semi-submerged ferroalloy furnaces • Blast vs. reverberatory 2d lead furnaces

  10. By product • Ferro- vs silico-manganese ferroalloys • Various polymers and resins products • Publication vs. product and packaging vs. wide-web rotogravure printing • By source of influent • Industrial vs. non-industrial POTW • By power input • Ferroalloy

  11. Basis for subcategorization • Subcategories established based on • Differences in processes/equipment • Differences in emission reduction techniques • Differences in raw materials • All lead to differences in emission characteristics

  12. What we’d like from Working Group • Seeking input on various potential options for subcategorization that can be used in future analyses • No subcategorization is clearly an option • Can not handle multitudes of options • Maximum of five options for analyses would be ideal

  13. Why we need your input soon • As part of the analyses, we plan to run IPM and REMSAD models • Take time to run so need input sooner rather than later • Want analyses back in time for Working Group assessment of results

  14. Integrated Planning Model • IPM • Developed by ICF Consultants • Utilized by EPA in Acid Rain and NOx SIP call programs and as a component in the Administration’s Multi-pollutant Strategy • Dynamic economic forecast model • Allows for different emissions scenarios • Allows technologies to be brought on/taken off line • Outputs directly applicable to air quality benefits assessment modeling

  15. Regulatory Modeling System for Aerosols and Deposition • REMSAD • 3D, gridded Eulerian atmospheric transport model • Nested grids - allows both regional and fine-scale evaluations • Used by EPA in TMDL program and in developing PM/Regional Haze guidance • Takes IPM outputs and translates emission changes into actual mercury deposition values • Deposition results can be used to assess relative economic benefits of various approaches

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