# Presentation: 553065

## Update on EPA Utility MACT Development

- February 5, 2002
- Washington, D.C.

- Sally Shaver
- US EPA

## 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

## 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

## 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

## When does EPA need closure from Working Group?

- Subcategories -- April 2002
- Floors -- April 2002
- Regulatory alternatives/MACT standard -- December 2002

## Subcategorization Examples

- February 5, 2002
- Washington, D.C.

- Sally Shaver
- US EPA

## 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...”

## 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

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

- 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

## 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

## 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

## 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

## 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

## 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