Sunday, December 25, 2011

Mercury and Air Toxics Standard (MATS) rule

This is not the kind of mat that you lie on for yoga relaxation. It takes skill to interpret and understand a 1,117 paged rule. I'm looking into the rule now for my job as an Environmental Analyst. It's different than studying and cramming for an exam. I really am motivated to look at something to understand it not to memorize it. On December 21, 2011, the EPA released the final version of a rule aimed to curb mercury emissions. Upon reading the name, it's obvious to a lay person that this rule makes sense. Why wouldn't the U.S. need a rule to enforce reductions in mercury emissions. People generally ingest mercury through fish. According to the EPA, the implementation of this rule will avoid 4,700 cases of heart attacks, 2800 cases of bronchitis, 130,000 cases of asthma, and 4000-11,000 cases of premature deaths. Mercury, itself, does not cause bronchitis or asthma. It's the particulate matter that is also emitted along with the mercury and air toxins that cause the respiratory diseases. I am not a doctor, so I could be wrong. Mercury, and other air toxins, at high levels in the bloodstream of pregnant women can be harmful to babies (source). The ads from Sierra Club say it all.

Some notes
  • Rule applies to boilers that burn more than 10% of their fuel in fossil fuels over 3 years or 15% in one year after 2015
  • Changes for oil units- I'm trying to understand the changes. A limited use category exempts any boilers with annual capacity factors less than 8%. How is the 8% calculated? Using the fuel heat input for just oil and using a 24 month average after
  • Work practice standards such as tune-ups every 3 years or 4 years for neural network adjustments instead of emission testing
  • Just test moisture content to ensure comply with HCL and HF for existing oil unit
On December 16, 2011, EPA's Office of Enforcement and Compliance Action also released a memo specifying how power plants could get a one-year extension to comply if they impact reliability. The memo mentions that the "policy does not address installation of controls and/or instances of noncompliance" that do not pertain to reliability (p 2, memo). I have questions:
  1. On p4 of the memo, EPA mentions that companies will begin planning early if there are reliability issues and thinks companies will notify their "reliability entities" if there are issues. Then on Pg 5, EPA mentions specific steps such as notifying EPA's Enforcement office within a year of the rule's publication (likely late Feb to early Mar 2012) of the dates when companies plan to shut plants down or control. This signals the timing of potential reliability concerns. After writing all this, I realize that my question may not be a question but a thought. Do companies have to submit a separate request to the "reliability entities" or does EPA just assume companies will already do this so they don't give specific criteria. In part D on page 6 of the memo, EPA specifies that companies need to get validation from the "reliability entities" confirming that there is, in fact, a reliability concern, but there are no specifics on how companies should work with their reliability entities. At least, this is my interpretation.
On December 21, Obama also released a presidential memo in which he instructs EPA on 3 points: 1) EPA to make the one-year extension "broadly available to sources." The use of "broadly" suggests EPA to apply it the extension to a variety of issues other than reliability; 2) to work with NERC, FERC, RTOs, and reliability experts and alert companies early of extensions, creating more certainty per EO 13563; and 3) make information available to the public on the execution of MATS.

After reading this rule and blogging, I realize that I have come to no conclusion but merely blog as a way to write this rule into my memory. I'm not sure if any readers can take away anything interesting.

To learn more about this rule and the impacts of mercury, see: http://www.epa.gov/mats/index.html