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Recommendations on the Utility Air Toxics MACT Final Working Group Report October 2002

Recommendations on the Utility Air Toxics MACT Final Working Group Report October 2002 Working Group on the Utility MACT Formed Under the Clean Air Act Advisory Committee Subcommittee for Permits/New Source Reviews/Toxics Submitted to: Clean Air Act Advisory Committee.

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Recommendations on the Utility Air Toxics MACT Final Working Group Report October 2002

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  1. Recommendations on the Utility Air Toxics MACT Final Working Group Report October 2002 Working Group on the Utility MACT Formed Under the Clean Air Act Advisory Committee Subcommittee for Permits/New Source Reviews/Toxics Submitted to: Clean Air Act Advisory Committee

  2. EPA's December, 2000 Regulatory Finding • HAP of "greatest potential concern" - mercury • HAP's of "potential concern for carcinogenic effects" - "arsenic, and a few other metals (e.g., chromium, nickel, cadmium)" • "Three additional HAP's that are of potential concern" - dioxins, hydrogen chloride, hydrogen fluoride • "it is possible that future data collection efforts or analyses may identify other HAPs of potential concern"

  3. EPA Actions • Met with various stakeholder groups April 2001 • Convened the Utility MACT working group August of 2001

  4. Membership of Utility MACT Working Group • Six members representing State/Local/Tribal Agencies • Eight members representing Environmental Organizations • Fourteen members representing Industry • One member representing Control Equipment Vendors • Two members representing coal interests, producers and Unions • WEST Associates added last summer in order to bring to the table Western interests • Nine Workgroup Members are full CAAAC members

  5. Working Group • Purpose: Recommendations to EPA to maximize benefits of rule in a flexible framework at a reasonable cost. • Approach: • Obtain active participation from stakeholders • Determine the most effective ways to address mercury issues; and • Consider strategies to simplify the regulations and allow flexibility, while maintaining environmental benefits

  6. Working Group (Cont.) • Formed for initial period of one year. • First meeting August 2001. • Subsequent meetings nearly every month through October, 2002. • Goal: consensus of opinion on identified issues. • Quickly determined there was a divergence of opinions. • Refocus: • Identify issues. • Thoroughly discuss issues. • Clearly identify stakeholder positions. • Today: report the issues and the stakeholder positions.

  7. Issues 1. Subcategories for mercury, 2. Floor levels for mercury, 3. Beyond-the-floor levels for mercury, 4. Format of mercury standard, 5. Compliance method (monitoring) for mercury, 6. Compliance time, 7. Non-mercury HAP, and 8. Oil-fired units.

  8. Subcategories For Mercury • Issue: whether and how to subcategorize the source category “oil- and coal-fired electric utility steam generating units” • Emission standards are set for each subcategory • Consensus: oil- and coal-fired boilers should be separate subcategories • No other consensus on this issue

  9. Summary Of Positions • IGCC Units: Industry believes they are not subject to MACT; States/Locals and Environmental support separate subcategory. • FBC units: Environmental, Industry and Texas support separate subcategory; States/Locals do not. • Lignite: States/Locals and Industry support separate subcategory for lignite plants; Environmental do not. • Bituminous and subbituminous: Majority Industry Group, Equipment Vendors and Texas support separate subcategories; States/Locals, Environmental and CEG do not. • Chlorine content: WEST Associates supports further subcategorization by chlorine content.

  10. MACT Floor Levels For Mercury • Issue: how to calculate the mercury MACT “floor level”, considering the ICR data and variability (of mercury and other chemicals in coal, in measurements, in sampling, and in operation of the best performing plants) • Consensus: new source floor is based on the best performing similar source • No other consensus on this issue

  11. Summary Of Positions • Environmental • FBC: 0.19 lb/TBtu • IGCC: 0.54 lb/TBtu • All others: 0.21 lb/TBtu • States (except Texas) • 0.4 – 0.6 lb/TBtu or • 90% removal • Equipment Vendors • Bituminous: 90% removal • Subbituminous: 70% removal

  12. Summary of Positions (Cont.) • Industry Approach 1 • FBC: 2.0 lb/TBtu or 91% removal • Bituminous: 2.2 lb/TBtu or 73% removal • Subbit.: 4.2 lb/TBtu or 31% removal • Lignite: 6.5 lb/TBtu or 47% removal

  13. Summary of Positions (Cont.) • Industry Approach 2 • FBC: 2.0 lb/TBtu or 91% removal • Bituminous: • Saturated stack: 2.2 lb/TBtu or 55% removal • Wet Stack: 3.2 lb/TBtu or 63% removal • Hot Stack: 3.7 lb/TBtu or 62% removal • Subbituminous: 4.2 lb/TBtu or 31% removal • Lignite: 6.5 lb/TBtu or 47% removal

  14. Non-mercury Hap • Issue: whether EPA must set standards other than for mercury • No consensus on this issue • Environmental and States (except Texas) believe EPA must regulate non-mercury HAPs • Industry and Texas cite section 112(n)(1)(a) and believe that the lack of a health determination for non-mercury HAP precludes EPA from regulating anything but mercury

  15. Compliance Time • Issue: applicability of statutory provisions allowing extensions from presumptive 3 year compliance time. • Limited discussion during the Working Group process, primarily by industry which stated 5-8 years may be required depending upon extent of required retrofits. • Consensus: Utility MACT regulation may require extensive retrofits. CAA provides additional time to install controls in some circumstances, which may be triggered here.

  16. Approaches to Addressing Variability • Representativeness of Stack Tests • Worst-case performance • Averaging time • Control technology parameters • Format of standard (30-day ave., annual) • Correlation of mercury and…something else • Statistical approach(es)

  17. So Where Does This Leave Us? • Multiple approaches have been, and can be, used to address variability. • More analyses on each potential approach warranted. • Approaches may be combined. • Advice/recommendations from the members on the approach to be taken are welcomed.

  18. Topics for Further Investigation • Approaches to addressing variability • IPM and other modeling

  19. THANKS • To EPA For Providing The Opportunity To Meet And Discuss The Issues • To All the Stakeholders For Their Participation

  20. All Meeting Summaries, Presentations, Documents and Data Can Be Found on Website http://www.epa.gov/ttn/atw/combust/utiltox/utoxpg.html#TEC

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