Transcript Recommendations on the Utility Air Toxics MACT Final Working Group Report

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
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"
EPA Actions
• Met with various stakeholder groups April
2001
• Convened the Utility MACT working group
August of 2001
Membership of Utility MACT
Working Group
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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
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
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.
Issues
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Subcategories for mercury,
Floor levels for mercury,
Beyond-the-floor levels for mercury,
Format of mercury standard,
Compliance method (monitoring) for
mercury,
6. Compliance time,
7. Non-mercury HAP, and
8. Oil-fired units.
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
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.
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
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
Summary of Positions (Cont.)
• Industry Approach 1
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FBC:
Bituminous:
Subbit.:
Lignite:
2.0 lb/TBtu or 91% removal
2.2 lb/TBtu or 73% removal
4.2 lb/TBtu or 31% removal
6.5 lb/TBtu or 47% removal
Summary of Positions (Cont.)
• Industry Approach 2
– FBC:
– Bituminous:
• Saturated stack:
• Wet Stack:
• Hot Stack:
– Subbituminous:
– Lignite:
2.0 lb/TBtu
or 91% removal
2.2 lb/TBtu
3.2 lb/TBtu
3.7 lb/TBtu
4.2 lb/TBtu
or 55% removal
or 63% removal
or 62% removal
or 31% removal
6.5 lb/TBtu
or 47% removal
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
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.
Approaches to Addressing
Variability
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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)
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.
Topics for Further
Investigation
• Approaches to addressing variability
• IPM and other modeling
THANKS
• To EPA For Providing The Opportunity To
Meet And Discuss The Issues
• To All the Stakeholders For Their
Participation
All Meeting Summaries,
Presentations, Documents and
Data Can Be Found on Website
http://www.epa.gov/ttn/atw/combust/ut
iltox/utoxpg.html#TEC