non hg haps a utility view
Download
Skip this Video
Download Presentation
Non-Hg HAPs: A Utility View

Loading in 2 Seconds...

play fullscreen
1 / 8

Non-Hg HAPs: A Utility View - PowerPoint PPT Presentation


  • 121 Views
  • Uploaded on

Non-Hg HAPs: A Utility View. Larry S. Monroe, Ph.D. EPA MACT Working Group July 9, 2002. Outline . Health risks (or lack of) Data (real lack of) MACT Process Implications. Non-Hg HAPs and Health Risks. No EPA finding of health concerns for non-Hg HAPs

loader
I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
capcha
Download Presentation

PowerPoint Slideshow about 'Non-Hg HAPs: A Utility View' - ostinmannual


An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript
non hg haps a utility view

Non-Hg HAPs: A Utility View

Larry S. Monroe, Ph.D.

EPA MACT Working Group

July 9, 2002

outline
Outline
  • Health risks (or lack of)
  • Data (real lack of)
  • MACT Process
  • Implications
non hg haps and health risks
Non-Hg HAPs and Health Risks
  • No EPA finding of health concerns for non-Hg HAPs
  • For non-carcinogens, MACT not invoked for Cl2 & HCl by EPA for chlor-alkali plants due to “below threshold” determination (Fed. Reg. 7/3/02)
  • EPA in Report to Congress stated only two HAPs (arsenic and dioxins) are “of potential concern” but “further evaluations and reviews” are needed
  • EPRI (1994) found that multimedia risk for all carcinogens was below 1 in 1 million for all plants studied and that, for non-carcinogens, all exposures were below threshold levels
non hg haps data for utilities
Non-Hg HAPs Data for Utilities
  • Existing data - old, questionable
    • Organics very bad, especially dioxin
    • Trace metals best of bad lot
    • Acid gases limited
  • Source plant selection - no design!
    • funding and DOE projects determined site measured
    • coal type, control tech., boiler type, etc. not selected
  • Conclusion - Data not sufficient to determine “achieved” performance of best or top 12% of sources
mact floor determination process
MACT Floor Determination Process

1. Regulatory determination

2. Data assessment

  • Get more data?

3. Subcategory determination

4. Floor level set

  • “achieved performance”
  • variability, process differences, etc.

5. Beyond the floor

6. Compliance

  • Method, time scale, etc.

7. Draft rule

mact floor determination process1

Equipment &

Work Practice

Standard

MACT Floor Determination Process

1. Regulatory determination

2. Data assessment

  • Get more data?

3. Subcategory determination

4. Floor level set

  • “achieved performance”
  • variability, process differences, etc.

5. Beyond the floor

6. Compliance

  • Method, time scale, etc.

7. Draft rule

mact floor determination process2

Equipment &

Work Practice

Standard

Equipment &

Work Practice

Standard

MACT Floor Determination Process

1. Regulatory determination

2. Data assessment

  • Get more data?

3. Subcategory determination

4. Floor level set

  • “achieved performance”
  • variability, process differences, etc.

5. Beyond the floor

6. Compliance

  • Method, time scale, etc.

7. Draft rule

implications
Implications
  • Clean Air Act calls for regulation of industry if and only if there is a health basis
  • As proposed, the surrogate approach would swallow virtually the whole Clean Air Act
  • Costs could approach $100+ billion, severe impact to world economy
  • Draconian impact on the industry with no finding of health concerns
  • No non-carcinogen has been shown to be near a health threshold (EPA & EPRI)
ad