
Reducing
Power
Plant
Emissions:

EPA's
New
Proposed
Rules
For
Mercury
Dr.
Robert
J.
Wayland
Leader,
Combustion
Group
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
North
Carolina
Presentation
to
the
Institute
of
Clean
Air
Companies
March
1,
2004
Research
Triangle
Park,
North
Carolina
Call
Call­
in
Attendee
List
in
Attendee
List

Dave
Dave
Foerter
Foerter/
Chad
Whiteman;
ICAC
/
Chad
Whiteman;
ICAC

Bob
Thomas;
NORIT
Americas,
Inc.

Bob
Thomas;
NORIT
Americas,
Inc.


Mike
O'Donnell/
Scott
Mike
O'Donnell/
Scott
Renninger
Renninger;
Babcock
&
Wilcox,
Inc.

;
Babcock
&
Wilcox,
Inc.


Steve
Mandel;
Spectra
Gases,
Inc.

Steve
Mandel;
Spectra
Gases,
Inc.


William
Morris;
Parsons
Energy
and
Chemicals
Group
William
Morris;
Parsons
Energy
and
Chemicals
Group

John
John
Rectenwald
Rectenwald;
Norit
Norit
Americas,
Inc.

Americas,
Inc.


Ken
Snell/
Paul
Farber;

Ken
Snell/
Paul
Farber;
Sargent
Sargent
&
Lundy
&
Lundy

Rich
Jarrett/
Dave
Thompson/
Robert
Rich
Jarrett/
Dave
Thompson/
Robert
Denyszyn
Denyszyn;
Praxair,
Inc.

;
Praxair,
Inc.


Stephanie
Stephanie
Procopis
Procopis;
Powerspan
Powerspan
Corporation
Corporation

Vince
Albanese;
Fuel
Tech
Vince
Albanese;
Fuel
Tech

Mike
Mike
Sandel/
Sankar
Sandel/
Sankar
Seetharama
Seetharama;
Wheelabrator
Wheelabrator
Air
Pollution
Control
Air
Pollution
Control

George
George
Wensell
Wensell/
Tom
Hastings;

/
Tom
Hastings;
Cormetech
Cormetech,
Inc.

,
Inc.


Jim
Downey/
Dave
Jim
Downey/
Dave
Vojtko
Vojtko;
Horiba
Instruments,
Inc.

;
Horiba
Instruments,
Inc.


Ron
Jernigan/
Mike
Ron
Jernigan/
Mike
Nemergut
Nemergut;
Thermo
Electron
Corporation
;
Thermo
Electron
Corporation

Jill
Elmendorf;
ALSTOM
Power
Jill
Elmendorf;
ALSTOM
Power

Bob
Bob
McIlvaine
McIlvaine;
McIlvaine
McIlvaine
Company
Company

Rudi
Muenster;
VIM
Technologies,
Inc.

Rudi
Muenster;
VIM
Technologies,
Inc.


Mike
Durham;
ADA
Environmental
Solutions,
LLC
Mike
Durham;
ADA
Environmental
Solutions,
LLC

Robert
J.
Wayland/
William
H.

Robert
J.
Wayland/
William
H.
Maxwell;

Maxwell;
EPA/
OAQPS
EPA/
OAQPS
EPA
Proposes
to
Reduce
Utility
EPA
Proposes
to
Reduce
Utility
Emissions
through
Current
CAA
Emissions
through
Current
CAA
Authorities 

Authorities 


Interstate
Air
Quality
Rule
Interstate
Air
Quality
Rule
(
IAQR)
to
address
the
(
IAQR)
to
address
the
contribution
of
transported
SO
contribution
of
transported
SO2/
NO
/
NOx
emissions
to
ozone
emissions
to
ozone
(
smog)
and
fine
particle
(
PM
(
smog)
and
fine
particle
(
PM2.5
2.5)
nonattainment
problems
in
)
nonattainment
problems
in
the
Eastern
U.
S.

the
Eastern
U.
S.


Standards
to
Reduce
Mercury
Emissions
and
Standards
to
Reduce
Mercury
Emissions
and
Deposition
Deposition
 
Section
112
standards
Section
112
standards

Maximum
achievable
control
technology
(
MACT)

Maximum
achievable
control
technology
(
MACT)


Command
Command­
and
and­
control
control

Take
comment
on
trading
options
Take
comment
on
trading
options
 
State
State­
implemented
section
111
standards
implemented
section
111
standards

Emissions
Guidelines
and
New
Source
Performance
Standards
Emissions
Guidelines
and
New
Source
Performance
Standards

Market
Market­
based,
cap
based,
cap­
and
and­
trade
program
trade
program
Coal
Coal­
Fired
Power
Plants
Fired
Power
Plants

There
are
about
There
are
about
530
power
530
power
plants
plants
with
with
305
305
GW
of
capacity
GW
of
capacity
that
that
consist
of
consist
of
about
1,300
about
1,300
units
units.


Coal
plants
Coal
plants
generate
the
generate
the
vast
majority
of
vast
majority
of
power
sector
power
sector
emissions:

emissions:

­
100%
Hg
100%
Hg
­
95%
SO
95%
SO
2
­
90%
of
NOx
90%
of
NOx
­
83%
of
CO
83%
of
CO
2
EPA
uses
the
Integrated
Planning
Model
(
IPM)
to
consider
the
emissions,
costs,
and
fuel
impacts
of
controlling
pollution
from
these
plants
and
all
other
fossil
fuel­
fired
generating
units
in
the
lower
48
States.
The
Agency
adapted
this
commercial
capacity
planning
tool
for
application
to
pollution
control
strategies.
It
was
used
in
the
WRAP
process,
by
FERC
for
restructuring
issues,
by
environmental
groups,
and
power
companies.
Power
Generation
Is
a
Major
Source
of
Emissions
2000
Sulfur
Dioxide
2000
Nitrogen
Oxides
*
Other
stationary
combustion
includes
residential
and
commercial
sources.

1999
Mercury
Fuel
Combustionelectric
utilities
Other
stationary
combustion
*
Industrial
Processing
Transportation
Miscellaneous
Utilities
(
63%)

Utilities
(
40%)
Utilities
(
22%)

Nitrogen
Oxides
Nitrogen
Oxides
(
NO
(
NO
x)
contribute
to
the
formation
)
contribute
to
the
formation
of
both
particulate
matter
(
PM)
and
ground
of
both
particulate
matter
(
PM)
and
ground­
level
level
ozone.

ozone.
Sulfur
Dioxide
Sulfur
Dioxide
(
SO
(
SO
2)
contributes
to
)
contributes
to
particulate
matter
particulate
matter

Ozone
and
PM
Ozone
and
PM
have
been
linked
with
premature
have
been
linked
with
premature
death,
serious
illnesses
such
as
chronic
bronchitis
and
death,
serious
illnesses
such
as
chronic
bronchitis
and
heart
attacks,
and
respiratory
illnesses
such
asthma
heart
attacks,
and
respiratory
illnesses
such
asthma
exacerbations
exacerbations

NO
NO
x
and
SO
and
SO
2
are
also
linked
with
acid
rain,

are
also
linked
with
acid
rain,

eutrophication
of
water
bodies
including
estuaries
eutrophication
of
water
bodies
including
estuaries
such
as
the
Chesapeake
Bay,
and
regional
haze
such
as
the
Chesapeake
Bay,
and
regional
haze

Mercury
Mercury
has
been
linked
to
potential
reproductive,

has
been
linked
to
potential
reproductive,

immune
and
nervous
system
effects,
with
special
immune
and
nervous
system
effects,
with
special
concerns
for
pregnant
women
and
young
children
concerns
for
pregnant
women
and
young
children
Pollutants
and
Concerns
Mercury
Contamination
in
Fish
 
Currently
44
states
have
issue
fish
consumption
advisories
for
some
or
all
of
their
waters
due
to
contamination
from
mercury.*

States
with
Fish
Advisories
Due
to
Mercury
*
Note:
For
more
information
about
the
relationship
between
fish
advisories
and
human
exposure
to
mercury,
see
the
EPA
Report
 
America's
Children
and
the
Environment:
Measures
of
Contaminants,
Body
Burdens,
and
Illnesses 

available
at
http://
yosemite.
epa.
gov/
o
chp/
ochpweb.
nsf/
content/

publications.
htm
Mercury
Advisories
by
Type
Advisories
for
specific
waterbodies
only
Statewide
freshwater
advisory
only
Statewide
coastal
advisory
No
mercury
advisory
Statewide
freshwater
advisory
+

advisories
for
specific
waterbodies
Proposal
to
Reduce
Mercury
Proposal
to
Reduce
Mercury
Emissions
from
the
Emissions
from
the
Power
Sector
Power
Sector
Proposed
Alternatives
to
Reduce
Mercury
Proposed
Alternatives
to
Reduce
Mercury
Emissions
from
the
Power
Sector
Emissions
from
the
Power
Sector

3
individual
approaches
outlined
in
the
December
15,
2003
3
individual
approaches
outlined
in
the
December
15,
2003
proposal
proposal
 
Propose
traditional,
command
Propose
traditional,
command­
and
and­
control
section
112
MACT
control
section
112
MACT
requirements
for
utility
units
requirements
for
utility
units

Reduces
mercury
emissions
from
48
to
34
tons
by
December
2007
Reduces
mercury
emissions
from
48
to
34
tons
by
December
2007
 
Propose
cap
Propose
cap­
and
and­
trade
approach
under
guidelines
outlined
in
section
trade
approach
under
guidelines
outlined
in
section
112(
n)(
1)(
A)

112(
n)(
1)(
A)

 
Propose
market
Propose
market­
based,
cap
based,
cap­
and
trade
approach
under
section
111
and
trade
approach
under
section
111

Revises
December
20,
2000
finding
that
it
is
 
appropriate
and
Revises
December
20,
2000
finding
that
it
is
 
appropriate
and
necessary 
to
regulate
Utility
Units
under
section
112
necessary 
to
regulate
Utility
Units
under
section
112

Caps
mercury
emissions
at
15
tons
in
2018;
interim
cap
for
2010
Caps
mercury
emissions
at
15
tons
in
2018;
interim
cap
for
2010
proposed
to
encourage
early
reductions
in
SO
proposed
to
encourage
early
reductions
in
SO
2
and
NO
and
NO
x,
generating
,
generating
additional
Hg
emissions
reductions
additional
Hg
emissions
reductions

Final
approach
to
be
determined
following
completion
of
Final
approach
to
be
determined
following
completion
of
public
hearings
and
close
of
public
comment
period
public
hearings
and
close
of
public
comment
period
 
Final
rule
promulgated
on/
before
December
15,
2004
Final
rule
promulgated
on/
before
December
15,
2004
Section
112
MACT
Section
112
MACT

Affected
source
definition
Affected
source
definition
 
Electric
Utility
Steam
Generating
Unit
(
Utility
Unit)

Electric
Utility
Steam
Generating
Unit
(
Utility
Unit)


Any
fossil
fuel
Any
fossil
fuel­
fired
combustion
unit
of
more
than
25
MWe
that
fired
combustion
unit
of
more
than
25
MWe
that
serves
a
generator
that
produces
electricity
for
sale
serves
a
generator
that
produces
electricity
for
sale
 
Cogeneration
Utility
Unit
Cogeneration
Utility
Unit
 
unit
that
generates
steam
and
unit
that
generates
steam
and
electricity
and
supplies
more
than
one
electricity
and
supplies
more
than
one­
third
of
its
potential
electric
third
of
its
potential
electric
output
capacity
and
more
than
25
MWe
output
to
any
utility
power
output
capacity
and
more
than
25
MWe
output
to
any
utility
power
distribution
system
for
sale
distribution
system
for
sale
 
Cogeneration
is
defined
as
the
simultaneous
production
of
power
Cogeneration
is
defined
as
the
simultaneous
production
of
power
(
electricity)
and
another
form
of
useful
thermal
energy
(
usually
(
electricity)
and
another
form
of
useful
thermal
energy
(
usually
steam
or
hot
water)
from
a
single
fuel
steam
or
hot
water)
from
a
single
fuel­
consuming
process
consuming
process
 
Non
Non­
Utility
Units,
not
subject
to
this
rule
Utility
Units,
not
subject
to
this
rule

Any
unit
that
meets
the
above
definition,

Any
unit
that
meets
the
above
definition,
but
but
combusts
natural
combusts
natural
gas
>
98%
of
the
time
gas
>
98%
of
the
time

Simple
Simple­
and
combined
and
combined­
cycle
turbine
units
cycle
turbine
units

Industrial
Boilers
Industrial
Boilers
Existing
Source
MACT
Limits
Existing
Source
MACT
Limits
4.1
0.38
Coal
refuse­
fired
200
19.0
IGCC
98
9.2
Lignite­
fired
61
5.8
Subbituminous­
fired
21
2.0
Bituminous­
fired
Hg
(
10­
6
lb/
MWh)
1
Hg
(
lb/
TBtu)
1
Subcategory
1
 
Based
on
a
12­
month
rolling
average
0.002
210
Oil­
fired
Ni
(
lb/
MWh)
2
Ni
(
lb/
TBtu)
2
Subcategory
2
 
Based
on
a
not­
to­
exceed
annual
limit
NOTE:
Output­
based
standards
are
referenced
to
a
baseline
efficiency
(
35%
for
new
units;
32%
for
existing
units).
New
Source
MACT
Limits
New
Source
MACT
Limits
1.1
Coal
refuse­
fired
20
3
IGCC
62
Lignite­
fired
20
Subbituminous­
fired
6.0
Bituminous­
fired
Hg
(
10­
6
lb/
MWh)
1
Subcategory
1
 
Based
on
a
12­
month
rolling
average
3
 
Based
on
a
90%
reduction
for
beyond­
the­
floor
control
0.0008
Oil­
Fired
Ni
(
lb
/
MWh)
2
Subcategory
2
 
Based
on
a
not­
to­
exceed
annual
limit
NOTE:
Output­
based
standards
are
referenced
to
a
baseline
efficiency
(
35%
for
new
units;
32%
for
existing
units).
Floor
Determination
Process
Floor
Determination
Process

New
Source
MACT
New
Source
MACT
 
Best
performing
similar
source
Best
performing
similar
source

Bituminous:

Bituminous:
Fabric
filter
Fabric
filter
0.132
lb/
TBtu
0.132
lb/
TBtu

Subbituminous:

Subbituminous:
Fabric
filter
Fabric
filter
0.663
lb/
TBtu
0.663
lb/
TBtu

Lignite:

Lignite:
ESP
ESP
6.902
lb/
TBtu
6.902
lb/
TBtu

IGCC:

IGCC:
Uncontrolled
Uncontrolled
5.471
lb/
TBtu
5.471
lb/
TBtu

Coal
refuse:

Coal
refuse:
Fabric
filter
Fabric
filter
0.094
lb/
TBtu
0.094
lb/
TBtu

Oil:

Oil:
ESP
ESP
0.0046
lb/
TBtu
0.0046
lb/
TBtu
 
Assessment
of
variability
Assessment
of
variability

Existing
Source
MACT
Existing
Source
MACT
 
Average
of
the
top
performing
12%

Average
of
the
top
performing
12%


Bituminous:

Bituminous:
32
units
32
units
Top
4
used
for
Floor
Top
4
used
for
Floor

Subbituminous:

Subbituminous:
32
units
32
units
Top
4
used
for
Floor
Top
4
used
for
Floor

Lignite:

Lignite:
12
units
12
units
Top
5
used
for
Floor
Top
5
used
for
Floor

IGCC:

IGCC:
2
units
2
units
All
data
used
for
Floor
All
data
used
for
Floor

Coal
refuse:

Coal
refuse:
2
units
2
units
All
data
used
for
Floor
All
data
used
for
Floor

Oil:

Oil:
17
units
17
units
Top
2
used
for
Floor
Top
2
used
for
Floor
 
Assessment
of
variability
Assessment
of
variability
Fuel
Blending
Fuel
Blending

Coal
Blending
Coal
Blending
 
Unit
classified
by
the
predominate
coal
burned
during
Unit
classified
by
the
predominate
coal
burned
during
the
compliance
period
the
compliance
period
 
Unit
classified
by
a
"
weighted
emission
limit"
based
on
Unit
classified
by
a
"
weighted
emission
limit"
based
on
the
proportion
of
energy
output
(
in
Btu)
contributed
by
the
proportion
of
energy
output
(
in
Btu)
contributed
by
each
coal
rank
burned
during
the
compliance
period
each
coal
rank
burned
during
the
compliance
period

If
non
If
non­
regulated
fuels
are
used
(
e.
g.,
petroleum
regulated
fuels
are
used
(
e.
g.,
petroleum
coke,
Tire
coke,
Tire­
Derived
Fuel
(
TDF),
etc.),
the
Derived
Fuel
(
TDF),
etc.),
the
compliance
calculation
would
include:

compliance
calculation
would
include:

 
Energy
output
(
in
Btu)
of
Energy
output
(
in
Btu)
of
all
all
fuels
fuels
 
Hg
emissions
considered
would
be
Hg
emissions
considered
would
be
all
all
measured
by
the
measured
by
the
stack
monitor
stack
monitor
 
However,
the
blended
emission
limitation
is
based
only
However,
the
blended
emission
limitation
is
based
only
on
the
regulated
fuels
on
the
regulated
fuels
Monitoring
and
Compliance
Monitoring
and
Compliance

Hg
Testing
and
Monitoring
Requirements
Hg
Testing
and
Monitoring
Requirements
 
12
12­
month
rolling
average
Hg
emission
level
month
rolling
average
Hg
emission
level
 
Options
for
Hg
monitoring
Options
for
Hg
monitoring

Continuous
Emission
Monitors
(
CEM)

Continuous
Emission
Monitors
(
CEM)

 
Proposed
Performance
Specification
12A
(
PS
Proposed
Performance
Specification
12A
(
PS­
12A)

12A)


Carbon
Absorption
Tube
Carbon
Absorption
Tube
 
Proposed
Reference
Method
324
Proposed
Reference
Method
324

Manual
Stack
Test
Manual
Stack
Test
 
ASTM
Method
D6784
ASTM
Method
D6784­
02
("
Ontario
02
("
Ontario­
Hydro")

Hydro")

 
EPA
Reference
Method
29
EPA
Reference
Method
29

Emissions
Averaging
Provision
for
Hg
Emissions
Averaging
Provision
for
Hg
 
Demonstrate
compliance
through
averaging
Hg
emissions
from
multi
Demonstrate
compliance
through
averaging
Hg
emissions
from
multiple
ple
(
two
or
more)
affected
units
located
at
a
common,
contiguous
fac
(
two
or
more)
affected
units
located
at
a
common,
contiguous
facility
site
ility
site
 
Leads
to
a
single
applicable
facility
Leads
to
a
single
applicable
facility­
wide
emission
limit
wide
emission
limit

Ni
Testing
and
Monitoring
Requirements
Ni
Testing
and
Monitoring
Requirements
 
Maximum
allowable
emission
limit;
not
to
be
exceeded
Maximum
allowable
emission
limit;
not
to
be
exceeded
 
Options
for
Ni
monitoring
Options
for
Ni
monitoring

EPA
Reference
Method
29
EPA
Reference
Method
29
112(
n)
Rescission
Notice
112(
n)
Rescission
Notice

Revision
to
EPA's
December
20,
2000
regulatory
finding
Revision
to
EPA's
December
20,
2000
regulatory
finding
(
65
FR
79825)

(
65
FR
79825)

 
Proposes
that
regulation
of
coal
Proposes
that
regulation
of
coal­
and
oil
and
oil­
fired
Utility
Units
under
fired
Utility
Units
under
section
112
is
not
"
appropriate
and
necessary"
within
the
meanin
section
112
is
not
"
appropriate
and
necessary"
within
the
meaning
of
section
112(
n)(
1)(
A)

of
section
112(
n)(
1)(
A)

 
Propose
to
delete
such
units
from
section
112(
c)

Propose
to
delete
such
units
from
section
112(
c)

 
Does
not
revise
the
12/
20/
00
finding
with
respect
to
HAP
emissio
Does
not
revise
the
12/
20/
00
finding
with
respect
to
HAP
emissions
ns
from
natural
gas
from
natural
gas­
fired
units
fired
units

Basis
of
revision
Basis
of
revision
 
"
Necessary"
finding
was
overbroad
in
two
cases
"
Necessary"
finding
was
overbroad
in
two
cases

Regulation
of
all
HAP:

Regulation
of
all
HAP:
record
supports
only
a
finding
that
Hg
and
Ni
record
supports
only
a
finding
that
Hg
and
Ni
emissions
warrant
regulations
emissions
warrant
regulations

Emissions
of
HAP
result
in
"
serious 
environmental
hazards":

Emissions
of
HAP
result
in
"
serious 
environmental
hazards":
Utility
Utility
RTC
study
(
mandated
by
section
112(
n)(
1)(
A))
focused
solely
on
RTC
study
(
mandated
by
section
112(
n)(
1)(
A))
focused
solely
on
hazards
to
public
health
hazards
to
public
health
 
Section
111
provides
another
viable
statutory
mechanism
that
wil
Section
111
provides
another
viable
statutory
mechanism
that
will
l
adequately
address
Hg
and
Ni
emissions
from
coal
adequately
address
Hg
and
Ni
emissions
from
coal­
and
oil
and
oil­
fired
fired
Utility
Units
Utility
Units
Section
111
Proposal
Section
111
Proposal

Section
111(
b)

Section
111(
b)
 
New
Source
Performance
Standards
New
Source
Performance
Standards
(
NSPS)

(
NSPS)

 
Requires
EPA
to
promulgate
standards
of
performance
for
Requires
EPA
to
promulgate
standards
of
performance
for
emissions
of
air
pollutants
from
new
sources
emissions
of
air
pollutants
from
new
sources
 
Monitoring
and
compliance
requirements
are
similar
to
the
sectio
Monitoring
and
compliance
requirements
are
similar
to
the
section
112
MACT
requirements
112
MACT
requirements
0.00082
Oil­
fired
1.11
Coal
refuse­
fired
201
IGCC
621
Lignite­
fired
201
Subbituminous­
fired
6.01
Bituminous­
fired
Emission
Limit
(
lb/
MWh)

Subcategory
1
 
Hg
emissions
2
 
Ni
emissions
Section
111
Proposal
(
continued)

Section
111
Proposal
(
continued)


Section
111(
d)

Section
111(
d)
 
Emission
Guidelines
(
EG)

Emission
Guidelines
(
EG)

 
Requires
EPA
to
prescribe
regulations
that
outline
a
procedure
b
Requires
EPA
to
prescribe
regulations
that
outline
a
procedure
by
which
which
each
State
each
State
shall
submit
plans
which
create
standards
of
shall
submit
plans
which
create
standards
of
performance
for
existing
sources
for
which
air
quality
criteria
performance
for
existing
sources
for
which
air
quality
criteria
have
have
not
been
set
but
for
which
NSPS
have
been
established
not
been
set
but
for
which
NSPS
have
been
established
 
Cap
Cap­
and
and­
Trade
program
reduces
the
overall
amount
of
emissions
Trade
program
reduces
the
overall
amount
of
emissions
by:

by:


Requiring
sources
to
hold
allowances
to
cover
their
emissions
on
Requiring
sources
to
hold
allowances
to
cover
their
emissions
on
a
one
one­
for
for­
one
basis
one
basis

Limiting
overall
allowances
so
that
they
cannot
exceed
specified
Limiting
overall
allowances
so
that
they
cannot
exceed
specified
levels
levels
(
i.
e.,
the
"
cap
level")

(
i.
e.,
the
"
cap
level")


Reducing
the
cap
to
less
than
the
amount
of
emissions
actually
Reducing
the
cap
to
less
than
the
amount
of
emissions
actually
emitted,
or
allowed
to
be
emitted,
at
the
inception
of
the
progr
emitted,
or
allowed
to
be
emitted,
at
the
inception
of
the
program
am

Allowing
for
a
declining
cap
over
time
Allowing
for
a
declining
cap
over
time

Creating
market
Creating
market­
based
incentives
for
early
reductions
based
incentives
for
early
reductions
Section
111
Proposal
(
continued)

Section
111
Proposal
(
continued)


Section
111
Section
111
 
Regulatory
Approach
Regulatory
Approach
 
Primary
goal
is
to
reduce
Utility
Unit
Hg
emissions
by
70%
from
Primary
goal
is
to
reduce
Utility
Unit
Hg
emissions
by
70%
from
current
levels
by
2018
current
levels
by
2018

2018
cap
is
permanent
2018
cap
is
permanent
 
Effectively
becoming
more
stringent
as
more
plants
are
required
Effectively
becoming
more
stringent
as
more
plants
are
required
to
keep
to
keep
their
collective
emissions
below
15
tons
their
collective
emissions
below
15
tons

Near
Near­
term
interim
cap
in
2010
term
interim
cap
in
2010
 
Level
will
reflect
the
maximum
level
of
Hg
reductions
achievable
Level
will
reflect
the
maximum
level
of
Hg
reductions
achievable
through
through
FGD
and
SCR
installations
(
for
SO
FGD
and
SCR
installations
(
for
SO
2
and
NO
and
NO
x
emission
reductions)
on
units
emission
reductions)
on
units
covered
under
the
IAQR
covered
under
the
IAQR
 
Level
is
not
prescribed
in
current
proposal
because
of
uncertain
Level
is
not
prescribed
in
current
proposal
because
of
uncertainties
ties
associated
with
the
ability
of
these
controls
to
reduce
Hg
emiss
associated
with
the
ability
of
these
controls
to
reduce
Hg
emissions
ions
 
EPA
seeks
comment
and
technical
information
on
the
Phase
I
cap
l
EPA
seeks
comment
and
technical
information
on
the
Phase
I
cap
level
evel
 
EPA
believes
that
a
carefully
designed
 
multi
EPA
believes
that
a
carefully
designed
 
multi­
pollutant 
approach
pollutant 
approach
 
a
program
designed
to
control
NO
a
program
designed
to
control
NO
x,
SO
,
SO
2,
and
Hg
at
the
same
time
,
and
Hg
at
the
same
time
 
is
the
most
effective
way
to
reduce
emissions
from
the
electric
is
the
most
effective
way
to
reduce
emissions
from
the
electric
power
sector
power
sector

Details
of
the
section
111
trading
program
are
outlined
in
Details
of
the
section
111
trading
program
are
outlined
in
a
Supplemental
Notice
of
Proposed
Rulemaking
(
SNPR),

Supplemental
Notice
of
Proposed
Rulemaking
(
SNPR),

which
was
signed
on
February
24,
2004
which
was
signed
on
February
24,
2004
SNPR:

SNPR:
Hg
Program
Requirements
Under
Section
111
Hg
Program
Requirements
Under
Section
111

Each
state
must
submit
a
plan
that
demonstrates
it
will
meet
Each
state
must
submit
a
plan
that
demonstrates
it
will
meet
its
assigned
statewide
Hg
emissions
budget
its
assigned
statewide
Hg
emissions
budget
 
States
may
join
the
trading
program
by
adopting
or
referencing
States
may
join
the
trading
program
by
adopting
or
referencing
the
model
trading
rule
in
State
regulations;
or,
adopting
the
model
trading
rule
in
State
regulations;
or,
adopting
regulations
that
mirror
the
necessary
components
of
the
model
regulations
that
mirror
the
necessary
components
of
the
model
trading
rule
trading
rule
 
States
can
choose
not
to
join
the
federal
trading
program
and
States
can
choose
not
to
join
the
federal
trading
program
and
meet
their
budget
through
intra
meet
their
budget
through
intra­
state
trading
or
no
trading
state
trading
or
no
trading
 
States
can
also
choose
to
implement
more
stringent
Hg
emissions
States
can
also
choose
to
implement
more
stringent
Hg
emissions
requirements
requirements

EPA
has
taken
comment
on
a
proposal
to
promulgate,
under
EPA
has
taken
comment
on
a
proposal
to
promulgate,
under
section
112(
n)(
1)(
A),
a
cap
section
112(
n)(
1)(
A),
a
cap­
and
and­
trade
program
for
Hg
from
trade
program
for
Hg
from
coal
coal­
fired
utility
units
fired
utility
units
 
Trading
program
would
be
federally
implemented
with
the
EPA,

Trading
program
would
be
federally
implemented
with
the
EPA,

instead
of
states,
serving
as
the
permitting
authority
instead
of
states,
serving
as
the
permitting
authority
SNPR:
Hg
Program:
State
Emission
Budgets
SNPR:
Hg
Program:
State
Emission
Budgets

Proposed
methodology
for
calculating
State
emission
budgets
Proposed
methodology
for
calculating
State
emission
budgets
for
2010
and
used
methodology
to
calculate
2018
budgets
for
2010
and
used
methodology
to
calculate
2018
budgets

The
state
budgets
are
the
sum
of
hypothetical
allocations
to
The
state
budgets
are
the
sum
of
hypothetical
allocations
to
each
existing
affected
utility
unit
in
the
state
each
existing
affected
utility
unit
in
the
state
 
Hypothetical
allocations
are
based
on
the
proportionate
share
of
Hypothetical
allocations
are
based
on
the
proportionate
share
of
the
baseline
heat
input
to
total
heat
input
of
all
affected
unit
the
baseline
heat
input
to
total
heat
input
of
all
affected
units
 
Each
unit s
baseline
heat
input
is
adjusted
to
reflect
the
ranks
Each
unit s
baseline
heat
input
is
adjusted
to
reflect
the
ranks
of
of
coal
combusted
by
the
unit
during
the
baseline
period
coal
combusted
by
the
unit
during
the
baseline
period
 
Proposed
adjustment
factors
of
1
for
bituminous,
1.25
for
Proposed
adjustment
factors
of
1
for
bituminous,
1.25
for
subbituminous,
and
3
for
lignite
coals
subbituminous,
and
3
for
lignite
coals
 
Also
proposed
adjustment
factors
based
on
the
proposed
MACT
Also
proposed
adjustment
factors
based
on
the
proposed
MACT
emission
rates:
1
for
bituminous,
2.9
for
subbituminous,
and
4.6
emission
rates:
1
for
bituminous,
2.9
for
subbituminous,
and
4.6
for
lignite
coals
for
lignite
coals
SNPR:
Hg
Model
Trading
Rule:
Necessary
Components
SNPR:
Hg
Model
Trading
Rule:
Necessary
Components

State
adoption
of
the
model
rule
would
ensure
consistency
in
the
State
adoption
of
the
model
rule
would
ensure
consistency
in
the
following
key
operational
elements
of
the
program
among
following
key
operational
elements
of
the
program
among
participating
states:

participating
states:

 
Allowance
management
Allowance
management
 
Banking
Banking
 
Emissions
monitoring
(
according
to
40
CFR
Part
75)
and
reporting
Emissions
monitoring
(
according
to
40
CFR
Part
75)
and
reporting
 
Accountability
for
affected
sources
Accountability
for
affected
sources
 
Enforcement
requirements
Enforcement
requirements

State
rule
may
deviate
from
the
model
rule
only
in
the
area
of
State
rule
may
deviate
from
the
model
rule
only
in
the
area
of
allowance
allocation
methodology
allowance
allocation
methodology

Trading
program
to
be
administrated
jointly
by
states
that
elect
Trading
program
to
be
administrated
jointly
by
states
that
elect
to
participate
and
EPA
to
participate
and
EPA
 
EPA
is
responsible
for
state
plan
review
and
oversight,
and
EPA
is
responsible
for
state
plan
review
and
oversight,
and
administration
of
emissions
tracking
system
and
mercury
allowanc
administration
of
emissions
tracking
system
and
mercury
allowance
tracking
system
tracking
system
SNPR:
Hg
Model
Trading
Rule:
Allocations
&
Safety
Valve
SNPR:
Hg
Model
Trading
Rule:
Allocations
&
Safety
Valve

States
are
free
to
allocate
as
they
see
fit
within
Hg
Budget
lim
States
are
free
to
allocate
as
they
see
fit
within
Hg
Budget
limits
its
and
deadlines
set
by
EPA
and
deadlines
set
by
EPA

SNPR
includes
example
allocation
scheme
as
guidance:

SNPR
includes
example
allocation
scheme
as
guidance:

 
Input
Input­
based
allocations
for
existing
coal
units
(
with
different
ratios
based
allocations
for
existing
coal
units
(
with
different
ratios
based
based
on
coal
on
coal­
type),
with
updating
to
take
into
account
new
coal
generation
on
type),
with
updating
to
take
into
account
new
coal
generation
on
a
modified
output
basis
(
without
coal
a
modified
output
basis
(
without
coal­
type
ratios)

type
ratios)

 
Demonstrates
one
possible
approach
that
incorporates
new
generat
Demonstrates
one
possible
approach
that
incorporates
new
generat
ion,

ion,

addresses
the
safety
addresses
the
safety­
valve
mechanism,
and
is
administratively
valve
mechanism,
and
is
administratively
straightforward
straightforward

Safety
valve
sets
a
maximum
marginal
cost
for
Hg
emissions
Safety
valve
sets
a
maximum
marginal
cost
for
Hg
emissions
reductions
($
2,187.50
per
oz)

reductions
($
2,187.50
per
oz)

 
Intended
to
address
uncertainty
in
the
cost
of
control
Intended
to
address
uncertainty
in
the
cost
of
control
 
Sources
may,
at
any
time,
buy
allowances
at
the
safety
valve
pri
Sources
may,
at
any
time,
buy
allowances
at
the
safety
valve
price,
reducing
the
ce,
reducing
the
relevant
state s
budget
in
the
future
relevant
state s
budget
in
the
future
 
The
safety
valve
mechanism
would
need
to
be
incorporated
into
a
The
safety
valve
mechanism
would
need
to
be
incorporated
into
a
State s
chosen
State s
chosen
allocation
methodology
to
ensure
the
availability
of
undistribut
allocation
methodology
to
ensure
the
availability
of
undistributed
allowances
from
ed
allowances
from
which
purchasers
could
borrow
which
purchasers
could
borrow
SNPR:
Monitoring
Hg
Emissions
SNPR:
Monitoring
Hg
Emissions

Monitoring
of
Hg
will
resemble
current
monitoring
of
SO
Monitoring
of
Hg
will
resemble
current
monitoring
of
SO
2
and
NO
and
NO
x
under
the
Acid
Rain
and
NO
under
the
Acid
Rain
and
NO
x
SIP
Call
programs
SIP
Call
programs

A
comprehensive
QA/
QC
program
ensures
the
adequacy
of
A
comprehensive
QA/
QC
program
ensures
the
adequacy
of
emissions
data
emissions
data

Current
monitoring
in
the
Acid
Rain
and
NO
Current
monitoring
in
the
Acid
Rain
and
NO
x
SIP
Call
programs
SIP
Call
programs
averages
over
98%
availability
averages
over
98%
availability

Hourly
emissions
data
are
submitted
to
EPA
every
quarter
Hourly
emissions
data
are
submitted
to
EPA
every
quarter

A
petition
process
enables
monitoring
flexibility
and
facilitate
A
petition
process
enables
monitoring
flexibility
and
facilitates
the
s
the
resolution
of
issues
resolution
of
issues

Annual
thru
Annual
thru­
up
compares
emissions
to
allocated
allowances
up
compares
emissions
to
allocated
allowances
SNPR:
Hg
Monitoring:
One
Proposal
SNPR:
Hg
Monitoring:
One
Proposal
 
Two
Alternatives
Two
Alternatives

Because,
in
addition
to
continuous
emissions
monitoring
systems
Because,
in
addition
to
continuous
emissions
monitoring
systems
(
CEMS),
a
new
and
promising
technology
is
available,
two
(
CEMS),
a
new
and
promising
technology
is
available,
two
alternatives
are
proposed:

alternatives
are
proposed:

 
Alternative
one:

Alternative
one:


Units
with
the
highest
Hg
emissions
install
CEMS
Units
with
the
highest
Hg
emissions
install
CEMS

Lowest
emitters
have
the
option
to
install
sorbent
tubes
Lowest
emitters
have
the
option
to
install
sorbent
tubes
 
Alternative
two:

Alternative
two:


All
units
would
have
the
flexibility
to
install
sorbent
tubes
or
All
units
would
have
the
flexibility
to
install
sorbent
tubes
or
CEMS
CEMS

Units
using
sorbent
tubes
would
require
stringent
QA
Units
using
sorbent
tubes
would
require
stringent
QA

Commensurate
with
the
SO
Commensurate
with
the
SO
2
and
NO
and
NO
x
cap
cap­
and
and­
trade
programs,

trade
programs,

regulated
sources
would
have
the
flexibility
of
using
alternativ
regulated
sources
would
have
the
flexibility
of
using
alternative
monitoring
approaches
as
long
as
such
approaches
meet
the
monitoring
approaches
as
long
as
such
approaches
meet
the
performance
requirements
in
the
rule
performance
requirements
in
the
rule
Summary
Summary

Recent
proposals
are
based
on
3
major
points
regarding
public
he
Recent
proposals
are
based
on
3
major
points
regarding
public
health
alth
 
Science
continues
to
tell
us
to
move
aggressively
on
fine
partic
Science
continues
to
tell
us
to
move
aggressively
on
fine
partic
les
les
 
There
is
growing
evidence
that
ozone
may
be
a
larger
problem
tha
There
is
growing
evidence
that
ozone
may
be
a
larger
problem
than
previously
expected
previously
expected
 
Mounting
scientific
evidence
and
public
concern/
interest
indicat
Mounting
scientific
evidence
and
public
concern/
interest
indicat
e
that
Hg
e
that
Hg
emissions
must
be
controlled
emissions
must
be
controlled

Administration
strongly
prefers
the
Clear
Skies
Act
legislation
Administration
strongly
prefers
the
Clear
Skies
Act
legislation
instead
of
instead
of
controlling
NO
controlling
NO
x,
SO
,
SO
2
and
Hg
under
the
existing
CAA
and
Hg
under
the
existing
CAA
 
EPA
will
stay
with
the
current
package
of
proposals,
absent
any
EPA
will
stay
with
the
current
package
of
proposals,
absent
any
movement
movement
on
the
legislation
on
the
legislation
 
EPA
is
committed
to
action
EPA
is
committed
to
action

Power
sector
is
not
the
only
industrial
sector
EPA
is
looking
to
Power
sector
is
not
the
only
industrial
sector
EPA
is
looking
towards
to
wards
to
make
significant
reductions
make
significant
reductions
 
Petroleum
refining,
car/
truck/
engine
manufacturing,
and
construc
Petroleum
refining,
car/
truck/
engine
manufacturing,
and
construction
tion
equipment
industries
are
making
reductions
through
the
Tier
II,

equipment
industries
are
making
reductions
through
the
Tier
II,
Heavy
Heavy
Duty
Diesel,
and
Non
Duty
Diesel,
and
Non­
road
Diesel
rules
road
Diesel
rules
 
EPA
is
also
requiring
a
variety
of
industries
to
meet
new
MACT
s
EPA
is
also
requiring
a
variety
of
industries
to
meet
new
MACT
standards,

tandards,

which
will
create
emission
reductions
of
both
criteria
and
air
t
which
will
create
emission
reductions
of
both
criteria
and
air
t
oxics
oxics
pollutants
pollutants
Next
Steps
Next
Steps

Supplemental
Notice
on
Supplemental
Notice
on
Mercury
Rule
Mercury
Rule
February
24,
2004
February
24,
2004

Hold
Public
Hearings
Hold
Public
Hearings
February
25
February
25­
26,
2004
26,
2004
 
Philadelphia,
PA
Philadelphia,
PA
 
Chicago,
IL
Chicago,
IL
 
Research
Triangle
Park,
NC
Research
Triangle
Park,
NC

Public
Comment
Periods
Close
Public
Comment
Periods
Close
April
2004
April
2004

Supplemental
Notice
on
Supplemental
Notice
on
Interstate
Air
Quality
Rule
Interstate
Air
Quality
Rule
April
2004
April
2004

Finalize
Mercury
Rule
Finalize
Mercury
Rule
December
2004
December
2004

Finalize
Interstate
Air
Quality
Finalize
Interstate
Air
Quality
Rule
Rule
December
2004
December
2004
