1. 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

2. Overview Format of Standard Compliance Monitoring Method Compliance Unit Compliance Time

3. 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

4. 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

5. 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

6. 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

7. 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