ACC Says EPA Boiler MACT Proposal Is Flawed

Aug. 25, 2010
Faulty Methodology and Data Lead to Unachievable Standards

The American Chemistry Council (ACC) has weighed in on the U.S. Environmental Protection Agency’s proposed National Emission Standards for Hazardous Air Pollutants (NESHAP) for Major Sources: Industrial, Commercial and Institutional Boilers and Process Heaters (Boiler MACT).  ACC Vice President of Technical and Regulatory Affairs Mike Walls issued the following statement:

“ACC believes it is imperative that EPA craft rules that protect public health and the environment without requiring significant financial costs that provide no added environmental benefit.  Unfortunately, EPA’s data and methodology are fundamentally flawed, leading to proposed standards far more stringent than necessary to protect public health and the environment."

According to the ACC, the EPA ‘cherry picks’ the best data in setting each standard, without regard for sources.  “We are particularly troubled by the quality and quantity of data EPA used.  The number and magnitude of errors we have identified provide clear evidence of inadequate factual support for the proposed standards.  Our concerns include the small data set, biased sampling approach, and inadequate treatment for startup and shutdown periods.  ACC does support several proposed elements, including work practices for natural gas-fired boilers, use of surrogates and the absence of fuel-switching requirements, which gives facilities flexibility in fuel choice and encourages energy diversity.

Walls went on to say that the ACC believes EPA has underestimated the rule’s capital costs.  EPA estimates the total capital cost will be $9.5 billion. ACC estimates total capital costs will exceed $20 billion for industry, with $3.8 billion in costs for the chemical industry (i.e. boilers listed as NAICS 325 in the EPA database).

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