← Edison Electric Institute
EPARulemakingEPA-HQ-OAR-2009-0234

National Emission Standards for Hazardous Air Pollutants for Coal- and Oil-fired Electric Utility Steam Generating Units

RIN
—
Last modified
Apr 14, 2022
Comment window
closed 3542d ago
Edison Electric Institute filings
4

Activity

Edison Electric Institute filed 4 comments on this docket between Aug 31, 2009 and Jan 9, 2013. 211 other organizations filed here. The comment window closed 3542d ago.

What Edison Electric Institute filed (4)

Jan 9, 2013· Comment submitted by Quinlan J. Shea, III, Vice President, Environment, Edison Electric Institute (EEI)· EPA-HQ-OAR-2009-0234-20295

Filed on regulations.gov — full text not in the inline record.

View on regulations.gov →
Dec 14, 2011· Late comment submitted by Edison Electric Institute (EEI)· EPA-HQ-OAR-2009-0234-19871

Filed on regulations.gov — full text not in the inline record.

View on regulations.gov →
Dec 11, 2009· Comment submitted by Quinlan J. Shea, III, Executive Director, Environment, Edison Electric Institute (EEI)· EPA-HQ-OAR-2009-0234-0086

December 10, 2009 Submitted via www.regulations.gov to Docket No. EPA–HQ–OAR–2009–0234 Re:Agency Information Collection Activities: Submission to OMB for Review and Approval; Comment Request; Information Collection Effort for New and Existing Coal- and Oil-fired Electric Utility Steam Generating Units; EPA ICR No. 2362.01, OMB Control No. 2060–New (74 Fed. Reg. 58,012, Nov. 10, 2009) Dear Sir or Madam: The Edison Electric Institute (EEI) appreciates the opportunity to submit comments on the Environmental Protection Agency's (EPA) proposed Information Collection Request (ICR) for national emission standards for coal- and oil-fired electric utility steam generating units (EGUs) which has been sent to OMB for review and approval. EEI is the association of shareholder-owned electric companies, international affiliates and industry associates worldwide. Our U.S. members serve more than 90 percent of the ultimate customers in the shareholder-owned segment of the industry, and nearly 70 percent of all electric utility ultimate customers in the nation. They generate almost 70 percent of the electricity generated by U.S. electric utilities. General Comments EEI observes that this version of the ICR represents a significant improvement over the July 2009 draft that EPA made available for public comment. This version more appropriately meets the requirements of the Paperwork Reduction Act and should provide useful information for developing MACT standards. Specifically, in response to comments, EPA expanded the time to complete stack sampling from six months to eight months. EPA also reduced some of the sampling requirements contained in the draft ICR. EEI supports these modifications and concurs with the concept of rolling reporting of stack sampling results. These changes should help to ensure that there is an adequate stack sampling capability available to conduct the still rather aggressive proposed testing regime. EPA provided helpful clarification on how the agency intends to use the data from this ICR to set MACT limits. Based on EPA's answer in the Response to Comments document, it appears that EPA selectively chose only the best controlled units for testing. This comports with EEI's assertion that MACT limits must be based on emissions information from the top 12 percent of the entire EGU source category, not on the basis of the top 12 percent of the data collected. EEI supports EPA's decision to remove radionuclide and carbon testing requirements from the ICR. Also, revisions to dioxin and organic testing represent a good balance of developing useful information for the upcoming MACT rulemaking without burdening the utility industry with unnecessary and excessive testing requirements. We note, however, that the ICR still requires revision. It contains two major requirements that will not yield useful information for setting MACT limits. Those two requirements, which are discussed below, will impose more than $25 million in unnecessary costs on EGUs required to conduct stack testing. In addition, insufficient time is given to complete the ICR. Based on the enormous amount and type of information requested by Parts 1 and 2 of the ICR, more than three months is needed to compile and report the information to EPA. Finally, while more time has been given to complete the stack testing, more time and a revision to the testing schedule may be needed, especially for smaller utility systems. Specific Comments •Fifty Randomly-Selected EGUs Should Not be Required to Conduct Stack Sampling for All HAPs Except Dioxins The draft ICR focused stack sampling on those EGUs that are expected to be among the best performing units in EPA's four hazardous air pollutant (HAP) groupings. The current version of the ICR requires 50 randomly-selected coal-fired EGUs to test for all HAPs except dioxins. Based on EPA's estimate, the cost of this new testing requirement could be about $12 million. It is common…

View on regulations.gov →
Aug 31, 2009· Comment submitted by Quinlan J. Shea, III, Executive Director, Environment, Edison Electric Institute (EEI)· EPA-HQ-OAR-2009-0234-0013

Re:Agency Information Collection Activities: Proposed Collection; Comment Request; Information Request for National Emission Standards for Coal- and Oil-fired Electric Utility Steam Generating Units; EPA ICR No. 2362.01 Dear Sir or Madam: The Edison Electric Institute (EEI) appreciates the opportunity to submit comments on the U.S. Environmental Protection Agency's (EPA) proposed Information Collection Request (ICR) for coal- and oil-based electric utility steam generating units (EGUs). EEI is the association of shareholder-owned electric companies, international affiliates and industry associates worldwide. Our U.S. members serve 95 percent of the ultimate customers in the shareholder-owned segment of the industry, and represent approximately 70 percent of the U.S. electric power industry. EEI agrees with EPA "that it needs additional data from both coal- and oil-fired electric utility steam generating units." However, the proposed $105 million stack testing program, over a short six-month timeframe, is excessive in scope and unrealistic. EEI questions whether there is an adequate stack sampling capability available to conduct the proposed testing regime in the time allotted. We strongly believe that EPA should either significantly reduce or modify the program or provide more time for testing. Furthermore, as discussed below, we believe that numerous sampling protocols are inadequate and would produce questionable data or data of limited usefulness. Also, several substances proposed for sampling are not hazardous air pollutants (HAPs) and should be removed from the program. Purpose and Design of the ICR It is unclear how EPA plans to use the information collected from the ICR to calculate maximum achievable control technology (MACT) floors. Section 112(d) of the Clean Air Act requires the MACT floor to be set on the average performance of the best performing 12 percent of sources in a source category. This leads to the question of how many of the units tested will be used by EPA to set a MACT limit. We believe that EPA should choose units for testing and setting of MACT standards from the entire universe of coal-based EGUs. The proposed ICR does not discuss how EGUs could be subcategorized for the four groups of HAPs delineated in the ICR (halides; dioxins and furans; non-dioxin/furans; and mercury and non-mercury metals). The ICR should be designed in such a way that EPA identifies possible approaches to subcategorization for each HAP grouping and requires sufficient testing to assess whether subcategorization is feasible. Allotted Time for Sampling Program EEI and its members believe that the six-month timeframe for stack sampling as delineated in the proposed ICR is unrealistically short. Based on the number of stack sampling companies in the U.S. and their annual business volume, it is highly unlikely that the current stack sampling companies would be able to take on the extra sampling burden that the proposed ICR would impose. It will take about three months for the bid, bidder selection, and contract award process; to get in the testing contractor's queue and schedule the test; and get the samples analyzed, field results quality assured and final report written. Based on these important real-world considerations, EPA's six-month stack testing schedule allows only three months for actual field sampling. It would be more practical and cost-effective for EPA to allow a one-year timeframe for testing as was the case in the 1999 ICR. Concerns Regarding Proposed Test Methods We have concerns with some of the proposed test methods. Some of the testing methods specified in the proposed ICR are not normally performed by testing companies. For example: the method for hydrogen cyanide (CTM-033) has neither been proposed nor subject to notice and comment rulemaking. Problems with the hydrogen halide method (Method 26/26A) have been recognized by EPA in several Federal Register notices. Inclusion of Non-HAPs and Radionuclid…

View on regulations.gov →

Abstract

Support material for the Utility MACT rule development under CAA section 112

View on regulations.gov →

Co-filers (211)

See everyone who commented →