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Stakeholder Positions on Utility MACT Issues

This report provides an update on the Utility MACT project, including stakeholder positions on key issues such as subcategorization, mercury floor levels, non-mercury HAP regulation, and compliance methods.

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Stakeholder Positions on Utility MACT Issues

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  1. Utility MACT Air & Waste Management Association/EPA Information Exchange December 4, 2002 William H. Maxwell Combustion Group/ESD

  2. Purpose • To provide update on utility MACT project

  3. CAAAC Working Group • Purpose • Recommendations to EPA on Utility MACT • 31 members • Six State/Local/(Tribal) Agency representatives • Eight Environmental Group representatives • Seventeen industry representatives • Goal -- consensus of opinion on identified issues • Quickly determined there would be no consensus • Refocus -- identify issues, thoroughly discuss issues, clearly identify Stakeholder positions

  4. Issues identified by stakeholders • Subcategories for mercury from coal-fired units • Floor levels for mercury from coal-fired units (including variability) • Non-mercury HAP from coal-fired units • Beyond-the-floor levels for mercury from coal-fired units • Format of coal-fired unit mercury standard • Compliance method (monitoring) for mercury from coal-fired units • Compliance time • Oil-fired units

  5. 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 relating to coal-fired units

  6. Summary of stakeholder positions on subcategorization • Subcategorization by coal type • Lignite • States/Locals and Industry support separate subcategory • Environmentals do not • Bituminous and subbituminous • Majority Industry Group, Equipment Vendors, and Texas support separate subcategories • States/Locals, Environmentals, and CEG do not • Chlorine content • WEST Associates supports chlorine content subcategorization • FBC units • Environmental, Industry, and Texas support separate subcategory • States/Locals do not

  7. MACT floor levels for mercury • Issue -- how to calculate the mercury MACT “floor level” for coal-fired units, considering the ICR data and variability (of mercury and other chemicals in coal, in sampling and measurements, 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

  8. Summary of stakeholder positions on MACT floors • Environmental Groups • Recommendations that lead to 2 - 7 tpy mercury emissions based on emission rate • States (except Texas) • Recommendations that lead to 10 - 15 tpy mercury emissions based on emission rate/percent reduction • Equipment Vendors • Recommendations based on percent reduction • Essentially beyond-the-floor • Majority Industry Group • Recommendations that lead to 26 - 32 tpy mercury emissions based on emission rate/percent reduction

  9. Approaches to addressing variability • Multiple approaches have used on other MACTs, and can be used, to account for variability in data • Worst-case performance • Averaging time • Control technology parameters • Format of standard (30-day avg., annual) • Correlation of mercury and…something else • Statistical approach(es) • More analyses on each potential approach warranted • Approaches may be combined

  10. Non-mercury HAP • Issue -- whether EPA must set standards other than for mercury for coal-fired units • No consensus on this issue • Environmentals and States/Locals (except Texas) believe EPA must regulate non-mercury HAP • 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

  11. Other issues • Beyond-the-floor mercury levels for coal-fired units • No consensus • Major Industry Group believes no beyond-the-floor is warranted • ICAC based their recommendations on beyond-the-floor • Others relatively non-committal • Format of mercury standard for coal-fired units • Stakeholders split • Input vs. output • Emission limit vs. percent reduction vs. both • Also disagreement on averaging time – 30 days to annual

  12. Other issues (cont.) • Compliance method for coal-fired unit mercury standard • No consensus • Industry believes mercury CEM will not be available and that periodic, manual testing would be required • Others believe CEM will be available and should be required • Oil-fired units • No general consensus • Consensus on subcategorization from coal but no further • Other issues similar to those of coal (e.g., floors, adequacy of data, HAP to be regulated)

  13. The future • Under settlement agreement, proposal of MACT rule on or before December 15, 2003 UNLESS multipollutant legislation enacted before then that amends CAA and eliminates MACT requirement • Promulgation on or before December 15, 2003 • Expect requests for extension to 3-year compliance schedule (normally December 15, 2007) • Also, PM Transport Rule (similar to NOx SIP call) scheduled to run concurrent with MACT rule • Materials relating to MACT at http://www.epa.gov/ttn/atw/combust/utiltox/utoxpg.html

  14. Timeline: Electric Power Sector Faces Numerous CAA Regulations Note: Dotted lines indicate a range of possible dates. 1 The D.C. Circuit Court has delayed the May 1, 2003 EGU compliance date for the section 126 final rule 2 Further action on ozone would be considered based on the 2007 assessment. 3 The SIP-submittal and attainment dates are keyed off the date of designation; for example, if PM or ozone are designated in 2004, the first attainment date is 2009 EPA is required to update the new source performance standards (NSPS) for boilers and turbines every 8 years NSR Permits for new sources & modifications that increase emissions 8-hr Ozone Attain- ment Demon- stration SIPs due Designate Areas for 8-hr Ozone NAAQS 1-hr Severe Area Attainment Date Marg-inal 8-hr Ozone NAAQS Attain-ment Date Assess Effectiveness of Regional Ozone Strategies Moderate 8-hr Ozone NAAQS Attainment Date Ozone 1-hr Serious Area Attainment Date NOx SIP Call Red-uc-tions Possible Regional NOx Reductions? (SIP Call II) 2 NOx SIPs Due Section 126 NOx Controls 1 OTC NOx Trading Serious 8-hr Ozone NAAQS attainment Date 04 06 07 08 09 10 12 13 15 16 17 18 05 99 00 01 02 03 11 14 Proposed Utility MACT Final Utility MACT Mercury Determination Additional HAP Regulation Under 112(d) and (f) Compliance for BART Sources Under the Trading Program Compliance with Utility MACT Compliance for BART Sources Second Regional Haze SIPs due New Fine PM NAAQS Implementation Plans Designate Areas for Fine PM NAAQS Latest Attainment Date for Fine PM NAAQS 3 Phase II Acid Rain Compliance Regional Haze SIPs due In developing the timeline of current CAA requirements, it was necessary for EPA to make assumptions about rulemakings that have not been completed or, in some case, not even started. EPA’s rulemakings will be conducted through the usual notice-and-comment process, and the conclusions may vary from these assumptions. Interstate Transport Rule to Address SO2/ NOx Emissions for Fine PM NAAQS and Regional Haze Acid Rain, PM2.5, Haze,Toxics

  15. Clean Air Act Implementation 8-hr Ozone Standards 2003 States recommend nonattainment designations 2004 EPA makes nonattainment designations 2005-09 New NOx Rule? 2007-08 SIPs due 2008-09 EPA finalizes SIPs PM2.5 Standards 2003 States recommend nonattainment designations 2004-05 EPA makes nonattainment designations, completion of NAAQS review 2005 EPA Issues SOx/NOx transport rule 2004-08 States develop/submit SIPs 2008-09 EPA finalizes SIPs Regional Haze Program 2007-08 States submit regional haze SIPs 2008-09 EPA approves SIPs 2013-18 Plants must install BART or comply with backstop trading program Mercury 2003 Propose MACT standard 2004 Finalize MACT standard 2004 New plants must begin to comply 2007 Existing plants must begin to comply

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