Mercury MACT Emission Standard: Format and Compliance

A Presentation by Larry Monroe

for the Industry Stakeholders

at the

EPA’s MACT Working Group

Washington DC, September 9, 2002

Overview

• Format of Standard

• Compliance Monitoring Method

• Compliance Unit

• Compliance Time

Format of Mercury Standard

• Dual standard with a choice between: – Input-based stack limit (pounds per trillion Btu)

– Percent reduction from coal entering site

• Output-based standards are too complex and therefore too expensive to implement

• Consistent approach used for incinerators

• Mitigates effects for marginal facilities and coals

Compliance Monitoring Method

• Stack tests using EPA Method 101A

– Currently the only approved method available

– Annual for large sources, biennial for small

• CEMs not ready in time; current approaches have limitations (Hg particulate, external auditable standards)

• Compliance between tests assured through Title V Compliance Assurance Monitoring (CAM) plans

Compliance Unit

• Compliance based on facility, not each source– Mercury health concerns are chronic, diffuse

– No real difference in environment

• Precedent in other MACT standards

• Offers flexibility and lower cost compliance

Compliance Time

• 3 years is too short to bring all coal utility boilers into compliance– Reliability of electricity jeopardized– Limited outages, A&E firms, craft labor, steel, AC,

bags, time for startup testing, etc.

• Integrate with other controls; short compliance time could delay scrubbers

• EPA should study the time required for compliance of the industry

• May take 5-8 years for all units to comply, particularly sites that will install scrubbers

Summary

• Dual standard with choice of % reduction from coal or input-based stack limit

• Compliance by annual/biennial stack tests using EPA 101A and Title V CAM plans

• Compliance by facility, not boiler

• Compliance time longer than three years, with more time for high capital sites