Utility MACT

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 andsomething 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

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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

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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/t
  tn/atw/combust/utiltox/utoxpg.html

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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
1-hr Severe Area Attainment Date
Designate Areas for 8-hr Ozone NAAQS
Assess Effectiveness of Regional Ozone Strategies
Marg-inal 8-hr Ozone NAAQS Attain-ment Date
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
05
06
07
08
09
10
12
13
15
16
17
18
99
01
02
03
11
14
00
Proposed Utility MACT
Final Utility MACT
Mercury Determination
Compliance for BART Sources Under the Trading
Program
Additional HAP Regulation Under 112(d) and (f)
Compliance for BART Sources
Compliance with Utility MACT
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.
EPAs 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
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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