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“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. We are also concerned that EPA significantly underestimates costs and burdens to industry. Our comments suggest several changes that could result in more effective, achievable standards.
“EPA’s faulty methodology begins with pollutant-by-pollutant analyses that select a different set of ‘best performing sources’ for each pollutant. In other words, EPA ‘cherry picks’ the best data in setting each standard, without regard for sources. The result is a set of standards achieved by a hypothetical set of ‘best performing’ sources able to maximize emission reductions for each hazardous air pollutant (HAP), rather than standards representative of actual performance of real sources. EPA’s approach produces unachievable standards and is contrary to the statute, which requires standard-setting to be source-based.
“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.
“ACC believes EPA has significantly underestimated the rule’s capital costs. Although 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).
“We recognize the time and effort EPA has put into developing this proposed rule. We strongly encourage the Agency to take adequate time to review and correct the data used, consider our detailed comments and make essential changes to the Boiler MACT.”
For additional details, visit www.americanchemistry.com.