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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

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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)


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