From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

To: Sharon Nizich/RTP/USEPA/US@EPA Cc: Steve Fruh/RTP/USEPA/US@EPA, JohnB Chamberlin/DC/USEPA/US@EPA Date: 11/22/2010 11:55 AM Subject: Part of E.O. 12866 Review: Interagency Discussion about additional edits/materials for the MCA preamble pertaining to NESHAP: Mercury Emissions from Mercury Cell Chlor

- Alkali Plants 2060

- AN99 Hi Sharon, Attached are redline comments on the mercury health effects section. For the GHG benefits at 7%, see the example below from a recent DOE rule where they included the GHG benefits at 3% in the 7% number and there’s explanatory text in the preamble as well as a footnote. Let me know if you have any questions.

*** Preamble: Using a 7

- percent discount rate and the SCC value of $21.40/ton in 2010 (in 2007$), which is discounted at 3 percent (see note below in Table I.2), the cost of the standards pro posed in today’s rule is $ 1,841 million per year in increased equipment costs, while the annualized benefits are $2,112 million per year in reduced equipment operating costs, $316 million in CO2 reductions , and $7 million in reduced NOX emissions. In this case, the net benefit amou nts to $594 million per year. Using a 3

- percent discount rate and the SCC value of $21.40/ton in 2010 (in 2007$), the cost of the standards proposed in today’s rule is $1,849 million per year in increased equipment costs, while the benefits are $2,929 mill ion per year in reduced operating costs, $316 million in CO2 reductions, and $33 million in reduced NOX em issions. At a 3

- percent discount rate, the net benefit amounts to $1,429 million per year. Table I.2. Annualized Benefits and Costs of Proposed Stand ards for Refrigeration Products for 2014

- 2043 Period Discount Rate Primary Estimate* Low Estimate* High Estimate* Monetized (million 2009$/year) Benefits Operating Cost Savings 7% 2112 1852 2377 3% 2929 2520 3335 CO 2 Reduction at $4.7 /t** 5% 85 85 85 CO 2 Reduction at $21.4/t** 3% 316 316 316 CO 2 Reduction at $35.1/t** 2.5% 492 492 492 CO 2 Reduction at $64.9/t** 3% 963 963 963 NO X Reduction at $2,519/t** 7% 7 7 7 3% 33 33 33 Total (Operating Cost Savi ngs, CO 2 Reduction and NO x Reduction)† 7% plus CO 2 range 2204

- 3082 1944

- 2822 2469

- 3348 7% 2435 2175 2700 3% 3278 2869 3684 3% plus CO 2 range 3047

- 3925 2638

- 3516 3453

- 4331 CostsIncremental Product Costs 7% 1841 173 3 1950 3% 1849 1729 1969 Net Benefits/Costs Total (Operating Cost Savings, CO 2 Reduction and NO x Reduction, minus Incremental Product Costs)† 7% plus CO 2 range 363

- 1241 211

- 1089 519

- 1397 7% 594 442 750 3% 1429 1140 1714 3% plus CO 2 range 1198

- 2076 909

- 1787 1483

- 2362 * The Primary, Low, and High Estimates utilize forecasts of energy prices and housing starts from th e AEO2010 Reference case, Low Economic Growth case, and Low Economic Growth case, respectively. * * The CO2 values represent global monetized values (in 2007$) of the social cost of CO2 emissions in 2010 under several scenarios. The values of $4.70, $21.40, and $35.10 per ton are the averages of SCC distributions calculated using 5%, 3%, and 2.5% disco unt rates, respective ly. The value of $64.90 per ton represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The value for NOX (in 2009$) is the average of the low and high values used in DOE ’s analysis. NOx savings are in addition to the regulatory emissions reductions modeled in the Annual Energy Outlook forecast. † Total Benefits for both the 3% and 7% cases are derived using t he SCC value calculated at a 3% discount rate, which is $21.40/ton in 2010 (in 2007$). In th e rows lab eled as “7% plus CO2 range” and “3% plus CO2 range,” the operating cost and NOX benefits are calcul ated using the labeled discount rate, and those values are added to the full range of CO2 values with the $4.70/ton value at the low end, and the $64.90/ton value at the high end.

________________________________________________ Cortney Higgins, PhD Policy Analyst OMB/OIRA/NRE 202.395.7856 chiggins@omb.eop.gov (See attached file: health effects

- supplem ental_EO12866comments.docx)***E.O. 12866 Review

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EO12866_Mercury Emissions from Mercury Cell Chlor

- Alkali Plants 2060

- AN99 NPRM MCA _20101122 A

. What are the effects of mercury?
Mercury is a naturally occurring element that is found in air, water, and soil in various form s. In general, industrial sources emit different combinations of three different forms (or species) of mercury to the atmosphere: gaseous elemental mercury (also know as elemental mercury vapor) , gaseous inorganic mercury compounds (e.g., mercuric chlori de) , and particulate bound mercury. Mercury emissions from some industries are primarily in the form elemental mercury vapor (such as gold mine ore processing and production, and producers of blood pressure devices and fluorescent lighting). T he majority of mercury emitted from mercury cell chlor

- alkali plants is also in the form of elemental mercury vapor , with a small fraction (approximately 2 percent) being gaseous inorganic mercury. Other industries (such as coal

- fired power plants and municipal wast e combustion facilities) emit a combination of gaseous inorganic mercury and elemental m ercury vapor and particulate bound mercury. The deposition of these emissions could, under circumstances described below, lead to formation of an organic form, methylm ercury. In general, for elemental mercury, inhalation is the primary direct exposure route of potential concern. Effects on the nervous system appear to be the most sensitive toxicological endpoint and can include tremors, nervousness, insomnia, neuromu scular changes (such as weakness, muscle atrophy, and muscle twitching), headaches, polyneuropathy, and memory loss. Comment [A1]: What is the citation for this? We do not see these endpoints listed on the EPA webpage at http://www.epa.gov/mercury/effects. htmIn general, for inorganic mercury compounds , both i nhalation and ingestion exposure

routes are of potential interest. Effects associa ted with h igh exposures to inorganic mercury compounds include damage to the gastrointestinal tract, the nervous system, and the kidneys

. The most sensitive general systemic adverse effect due to exposure to inorganic mercury compounds is the formation of autoimmune glomerulonephritis (that is, inflammation of the kidney). Specific s ymptoms of high exposures to inorganic mercury can include skin rashes and dermatitis; mood swings; memory loss; mental disturbances; and muscle weakness.
Mercury is emitted to the air from various man

- made and natural sources. These emissions transport through the atmosphere and eventually deposit to land or water bodies. This deposition can occur locally, regionally, or globally, depending on the form of mercury emitted a nd other factors such as the weather. Gaseous elemental mercury can be transported very long distances, even globally, to regions far from the emissions source (becoming part of the global “pool”) before deposition

occurs. Gaseous i norganic ionic (divale nt) mercury has a shorter atmospheric lifetime and can deposit to land or water bodies closer to the emissions source. Furthermore, gaseous elemental mercury in the atmosphere can undergo transformation into ionic mercury, providing a significant pathway for deposition of emitted elemental mercury. Once deposited, natural processes, particularly in water bodies, can transform some of the mercury into methylmercury,

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Comment [A2]: What is the citation for this?which is a highly toxic, more bioavailable form that

bioaccumulates in organisms and then bi omagnifies in the aquatic food chain (such as in fish). Thus, the ingestion route via fish consumption dominates the pathway for human and wildlife exposure to methylmercury. Symptoms of methylmercury poisoning may include: impairment of the peripheral vision; disturbances in sensations; lack of coordination of movements; impairment of speech, hearing, walking; and muscle weakness. In general, while adults can experience effects from high ingestion exposure to methylmercury, exposures to developing fet uses, infants, and children can pose the highest concerns. For fetuses, infants, and children, the primary health effect of methylmercury is impaired neurological development. M ethylmercury exposure in the womb can adversely affect a baby's growing brain and nervous system. Impacts on cognitive thinking, memory, attention, language, and fine motor and visual spatial skills have been seen in children exposed to methylmercury. In general, avoidance of any potential for these health effects can result fr om reducing the amount of mercury released to the air, water, and other media. The four existing mercury cell chlor

- alkali plants emit around 640 pounds of mercury each year to the air, based on recent estimates. They also release a total of just under 1 ton of mercury per year to other media, including around 50 pounds per year to water. The proposed amendments would result in the

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Comment [A3]: What is the citation for this?elimination of these releases in the future, and therefore could have beneficial non

- air quality

health and environmental im pacts.
In addition, mercury cell chlor

- alkali plants are commonly identified as contaminated sites and designated for correction action under the EPA Superfund or Resource Conservation and Recovery Act (RCRA) corrective action programs. In fact, three of the four currently operating mercury cell plants have been identified under the RCRA corrective action program

.

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Comment [A4]: How commonly? Is ther e a percentage that can be given?