EPA Revises Boiler Regulations

To: Calvin M. Dooley, President and CEO of the American Chemistry Council

Congratulations to you on your success in forcing the EPA to reduce their stringent requirements for pollution control on industrial boilers. Attached is an article in Chemical and Engineering News, which elaborates on this topic.


The article says that in the reduced number of targets for the regulations, the application would involve only 1% of the industrial boilers in the US, However, it is also said that the cost to businesses will be about $2.3 billion annually, with a potential life-saving potential of reducing premature deaths by 8100.

You have complimented the EPA for reducing the number of industrial boilers, to which the restrictions will apply. However, the lack of detail brings up some questionable factors. For example, an outright expenditure of $2.3 billion may or may not prevent 8100 premature deaths annually. The question is whether these people would be dying of something else anyhow and how the EPA could come up with that number in the first place. The other lacking detail is on the specific pollutants and the concentrations that which they present a hazard? If CO2 control is involvement in the restriction, it is a ridiculous assertion to do so. S02 has already been controlled for many years and has drastically reduced acid rain. There would seem to be no basis for further reduction of SO2 concentration. Some control of NOx and mercury would seem advisable, but we need to consider the levels to which they should be reduced.

You have made considerable progress with the EPA, I encourage you to continue to press them for practical controls, which will have some economic and health benefits.