Clean Air Act Advisory Committee

Permits/New Source Review/Air Toxics Subcommittee

Utility MACT Working Group

Summary of Working Group Meeting 09/09/02

The eleventh meeting of the working group established under the Clean Air Act Advisory Committee's (CAAAC) Permits/New Source Review/Air Toxics Subcommittee was held on September 9, 2002 at the Edison Electric Institute offices in Washington, D.C.

The focus of the meeting was for presentation and discussion of the "advice" to the Agency being put forth by the respective stakeholder groups. All groups provided background papers documenting their presentations. These papers and the available presentations are on the utility MACT website (http://www.epa.gov/ttn/atw/combust/utiltox/utoxpg.html).

Michael Rossler, Michael Geers, and Larry Monroe presented the general utility industry position. David Steele and C.V. Mathai presented a western coal perspective. Bill Bumpers and Michael Shore presented information on the oil-fired generators. Mark Brownstein provided a slightly different position on behalf of the Clean Energy Group (CEG). Following are summaries of the questions discussed following the presentations.

Why is the general industry not in favor of output-based standards? Output standards are being used now (e.g., in California, in the subpart Da utility NOx. NSPS).

o	The majority (75 to 80 percent) of the cost of operating a utility boiler is in the fuel so saving fuel (i.e., operating efficiently) is saving money and efficiency is "built in." The efficiency of an existing boiler cannot be improved significantly and expensive monitoring would be required for little improvement.

How will the CAM plans ensure compliance between infrequent performance tests?

o	The CAM plan would use equipment monitoring, opacity, etc. to ensure compliance between stack tests.

How would having separate standards for bituminous and subbituminous coals (as advocated by the CEG) inhibit flexibility?

o	Having separate standards would complicate the situation where a blend of the coals is used. It is likely that a utility would be required to disclose their coal use beyond that which they currently do; they don't want to do this in an unregulated environment. In addition, it is possible that the coal blend would/could be written into a permit, requiring the utility to reopen the permit every time they wanted to change the coal blend to respond to different economic situations. They were not sure that a common standard would be disadvantageous to subbituminous users.

Why is the general industry advocating EPA Method 101A for mercury testing? Why not Method 29, from which you could also get results for the other metals?

o	The industry would consider Method 29 equivalent to Method 101A.

Is the industry proposing that model CAM plans be developed or are they relying on individual States to develop the CAM plans?

o	Some MACT standards already include model CAM plans.

The general industry seems to be supporting multiple subcategories based on coal type as well as on chlorine content (eastern vs. western bituminous) as opposed to the CEG position of combining bituminous and subbituminous coals. This could lead to a significant number of subcategories.

o	The western coal and utility interests would disagree with the CEG position.

o	The general industry position is that subcategories are needed as follows:

three bituminous (hot, wet, dry)

subbituminous

lignite

FBC (no coal distinctions)

IGCC (if covered by the resulting MACT standard)

What would the general industry recommendations lead to with respect to a nationwide mercury emission level?

o	26 to 32 tons/year

Felice Stadler presented the general environmental caucus position. Following are summaries of the questions discussed following the presentation.

What would the general environmental caucus recommendations lead to with respect to a nationwide mercury emission level?

o	2 to 7 tons/year

What about averaging times?

o	The environmental community would prefer shorter averaging times.

The FBC and regular boiler numbers presented are virtually identical. Why then have separate subcategories for these type units?

o	The FBC units could be treated differently.

With a plant-wide average, could a unit convert to gas-firing in order to comply with the MACT?

o	Yes. A unit could also change coal, improve the efficiency of the boiler, etc. It is felt that units can improve their efficiency but just have never been given the incentive to do so.

o	The industry opinion is that if a unit switched to gas, then it would be out of the MACT and not available for "averaging" with other units at a site.

o	If a unit were a coal-boiler and then switched to gas, then it would still be a coal boiler under the "once in, always in" concept. A new gas unit, or one that never burned coal, could not be used for such "averaging" purposes.

Bill O'Sullivan and Praveen Amar presented the general State/local representative position. Following are summaries of the questions discussed following the presentation.

How broad is the State support for the advice presented?

o	The presentation drew on previous STAPPA/ALAPCO positions and was taken before the STAPPA/ALAPCO toxics subcommittee prior to being presented to the Working Group. It is recognized that not all States would be in total agreement.

On the subject of the non-mercury HAP, the State/local position would lead to every coal boiler having a fabric filter and FGD system by December 2007.

o	The State/local position would set an emission limit, not dictate how to achieve it.

There is no State/local support for a separate FBC subcategory?

o	There is insufficient data to justify separate subcategories.

The State/local position advocated a percent reduction across the control device (as opposed to from the coal to the stack) with any improvement resulting from coal cleaning showing up in the emission rate. What did the other groups mean when they discussed percent reduction?

o	General industry position: coal to stack

o	General environmental community position: coal to stack

Review of action items and discussion of next steps

The next meeting will be October 17, 2002 at the Edison Electric Institute facilities in Washington, D.C., and will be from 9:30 a.m. to 4:00 p.m. The writing mini-group will bring to the table the draft final report to the CAAAC for Working Group discussion and review/revision.

CLEAN AIR ACT ADVISORY COMMITTEE

PERMITS/NEW SOURCE REVIEW/AIR TOXICS SUBCOMMITTEE

UTILITY MACT WORKING GROUP

September 9, 2002

Edison Electric Institute

Thomas A. Edison Conference Center, Fourth Floor

701 Pennsylvania Avenue, N.W.

Washington, D.C. 20004-2696

AGENDA

9:30 a.m. - 9:45 a.m.	Introductions and opening remarks by Sally Shaver and John Paul, Co-chairs

9:45 a.m. - 11:15 a.m.	Presentation by Industry stakeholder group of their "advice" followed by Working Group question and answer

11:15 a.m. - 12:00 p.m.	Lunch

12:00 p.m. - 1:30 p.m.	Presentation by Environmental stakeholder group of their "advice" followed by Working Group question and answer

1:30 p.m. - 3:00 p.m.	Presentation by State/local stakeholder group of their "advice" followed by Working Group question and answer

3:00 p.m. - 3:45 p.m.	Open discussion

3:45 p.m. - 4:00 p.m.	Review of action items and discussion of next steps

4:00 p.m.	Adjourn