# Presentation: 827550

## Utility MACT

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

- December 4, 2002

## Purpose

- To provide update on utility MACT project

- December 4, 2002

## 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

- December 4, 2002

## 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

- December 4, 2002

## 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

- December 4, 2002

## 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

- December 4, 2002

## 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

- December 4, 2002

## 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

- December 4, 2002

## 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

- December 4, 2002

## 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

- December 4, 2002

## 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

- December 4, 2002

## 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)

- December 4, 2002

## 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

- December 4, 2002

## Timeline: Electric Power Sector Faces Numerous CAA Regulations

- Phase II
- Acid Rain
- Compliance

- Mercury
- Determination

- Proposed
- Utility
- MACT

- New  Fine PM NAAQS
- Implementation Plans

- Designate Areas
- for Fine PM NAAQS

**Ozone**

**Acid Rain****, ****PM****2.5****, ****Haze****,**** ****Toxics**

- 1-hr Severe Area
- Attainment Date

- Compliance for BART Sources

**NSR Permits** for new sources & modifications that increase emissions

- 99

- 01

- 02

- 03

- 04

- 05

- 06

- 07

- 08

- 09

- 10

- 11

- 12

- 13

- 14

- 15

- 16

- 17

- OTC NOx
- Trading

- 1-hr Serious Area Attainment Date

- NOx
- SIPs
- Due

- Designate Areas for
- 8-hr Ozone NAAQS

- Section 126 NOx Controls 1

- NOx
- SIP Call
- Red-uc-tions

- 00

- 18

- Final
- Utility
- MACT

- Compliance
- with Utility MACT

- Assess Effectiveness of Regional Ozone Strategies

- Regional Haze SIPs due

- Latest Attainment
- Date for Fine PM NAAQS 3

- Compliance for BART Sources Under the Trading Program

- Second  Regional Haze SIPs due

- Marg-inal 8-hr Ozone NAAQS Attain-ment Date

- Possible Regional NOx Reductions?
- (SIP Call II) 2

**Interstate Transport Rule to Address SO****2****/ NO****x**** Emissions for Fine PM NAAQS and Regional Haze**

**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

- Serious 8-hr Ozone NAAQS attainment Date

- Moderate 8-hr Ozone NAAQS Attainment
- Date

- 8-hr
- Ozone
- Attain-
- ment
- Demon-
- stration
- 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.

- Additional HAP Regulation Under 112(d) and (f)

- December 4, 2002

## 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

_**PM**_**2.5**_** 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

- December 4, 2002