Reducing
Power
Plant
Emissions:

EPA's
New
Proposed
Rules
For
Mercury
William
H.
Maxwell
Combustion
Group
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
North
Carolina
Presentation
to
the
North
Carolina
DENR/
DAQ
Mercury/
CO
2
Workshop
April
20,
2004
Raleigh,
NC
Tuesday,
April
20
8:
00:
Coffee
and
Networking
8:
28­
NC­
Specific
Mercury
Topics
and
Issues
 
Session
2
­
(
Hg­
2)
 
Moderator
 
Steve
Schliesser,
Senior
Environmental
Engineer,
NC
DAQ
(
Question
to
Be
Answered:
What
Mercury
reductions
are
possible,
and
what
makes
sense
in
NC?)

8:
29
USEPA s
Proposed
Mercury
MACT
and
Alternate
Proposals
for
Mercury
Reduction
Trading
Options
­
A
Summary
of
Options
and
Schedule
for
Comments
and
Final
Regulations:
Bill
Maxwell/
Bob
Wayland,
USEPA
(
subject
to
daily
developments)

9:
15
Performance
and
Costs
of
Mercury
Control
Technology
for
Bituminous
Coals
 
Dr.
Michael
Durham,
President,
ADA
Environmental
Solutions
9:
44
BREAK
10:
00/
Achieving
CSA
System­
wide
Reductions
in
(
NOx
&
SO2)
Emissions
at
Duke
Energy
Facilities
and
Reactions
to
Achieving
EPA s
MACT/
Trading
Proposals
for
Mercury
(
Including
limited
comments
on
options
for
new
technologies,
etc.)
 
Robert
A
McMurry,
Duke
Energy
10:
35
Achieving
CSA
System­
wide
Reductions
in
(
NOx
&
SO2)
Emissions
at
Progress
Energy
Facilities
and
Reactions
to
Achieving
EPA s
MACT/
Trading
Proposals
for
Mercury
 
Ben
White,
Progress
Energy
11:
05
Estimated
Emission
Reductions
in
NC
from
Co­
control
as
a
Result
of
CSA,
Using
EPA
Tool
to
Estimate
NC
Coal
Fired
Power
Plant
Mercury
Emissions
 
Paul
Grable
&
Steve
Schliesser,
Environmental
Engineers,
NC
DAQ
11:
25
Developing
Policy
Options
That
Can
Result
in
Integration
of
CO2
and
Mercury
Reductions
and
State
Implementation
Plan
Credits;
Alden
Hathaway,
Environmental
Resources
Trust,
Inc.
Washington,
DC
North
Carolina
Department
of
Environment
and
Natural
Resources,
Division
of
Air
Quality
Mercury/
CO2
Workshop
Held
at
the
Jane
S.
McKimmon
Center,

North
Carolina
State
University,

Raleigh,
North
Carolina
April
19
 
21,
2004
EPA
Proposes
to
Reduce
Utility
Emissions
through
Current
CAA
Authorities 

°
Interstate
Air
Quality
Rule
(
IAQR)
to
address
the
contribution
of
transported
SO2/
NOx
emissions
to
ozone
(
smog)
and
fine
particle
(
PM2.5)
nonattainment
problems
in
the
Eastern
U.
S.

°
Standards
to
Reduce
Mercury
Emissions
and
Deposition
 
Section
112
standards
°
Maximum
achievable
control
technology
(
MACT)

°
Command­
and­
control
°
Take
comment
on
trading
options
 
State­
implemented
section
111
standards
°
Emissions
Guidelines
and
New
Source
Performance
Standards
°
Market­
based,
cap­
and­
trade
program
Coal­
Fired
Power
Plants
 
There
are
about
530
power
plants
with
305
GW
of
capacity
that
consist
of
about
1,300
units,
of
which
1,150
would
be
covered.

 
Coal
plants
generate
the
vast
majority
of
power
sector
emissions:

­
100%
Hg
­
95%
SO
2
­
90%
of
NOx
­
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
(
NO
x)
contribute
to
the
formation
of
both
particulate
matter
(
PM)
and
ground­
level
ozone.

 
Sulfur
Dioxide
(
SO
2)
contributes
to
particulate
matter.

 
Ozone
and
PM
have
been
linked
with
premature
death,

serious
illnesses
such
as
chronic
bronchitis
and
heart
attacks,
and
respiratory
illnesses
such
asthma
exacerbations.

 
NO
x
and
SO
2
are
also
linked
with
acid
rain,
eutrophication
of
water
bodies
including
estuaries
such
as
the
Chesapeake
Bay,
and
regional
haze.

 
Mercury
has
been
linked
to
potential
reproductive,
immune
and
nervous
system
effects,
with
special
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
Emissions
from
the
Power
Sector
Proposed
Alternatives
to
Reduce
Mercury
Emissions
from
the
Power
Sector
 
3
individual
approaches
outlined
in
the
January
30,

2004
proposal
 
Propose
traditional,
command­
and­
control
section
112
MACT
requirements
for
utility
units
 
Reduces
mercury
emissions
from
48
to
34
tons
by
January
2008
 
Propose
cap­
and­
trade
approach
under
guidelines
outlined
in
section
112(
n)(
1)(
A)

 
Propose
market­
based,
cap­
and
trade
approach
under
section
111
 
Revises
December
20,
2000
finding
that
it
is
 
appropriate
and
necessary 
to
regulate
Utility
Units
under
section
112
 
Caps
mercury
emissions
at
15
tons
in
2018;
interim
cap
for
2010
proposed
to
encourage
early
reductions
in
SO
2
and
NO
x,
generating
additional
Hg
emissions
reductions
 
Final
approach
to
be
determined
following
completion
of
public
hearings
and
close
of
public
comment
period
 
Final
rule
signed
on/
before
December
15,
2004
Section
112
MACT
°
Affected
source
definition
 
Electric
Utility
Steam
Generating
Unit
(
Utility
Unit)

 
Any
fossil
fuel­
fired
combustion
unit
of
more
than
25
MWe
that
serves
a
generator
that
produces
electricity
for
sale
 
Cogeneration
Utility
Unit
 
unit
that
generates
steam
and
electricity
and
supplies
more
than
one­
third
of
its
potential
electric
output
capacity
and
more
than
25
MWe
output
to
any
utility
power
distribution
system
for
sale
 
Cogeneration
is
defined
as
the
simultaneous
production
of
power
(
electricity)
and
another
form
of
useful
thermal
energy
(
usually
steam
or
hot
water)
from
a
single
fuel­
consuming
process
 
Non­
Utility
Units,
not
subject
to
this
rule
 
Any
unit
that
meets
the
above
definition,
but
combusts
natural
gas
>
98%
of
the
time
 
Simple­
and
combined­
cycle
turbine
units
 
Industrial
boilers
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
(
32%
for
existing
units).
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).
Fuel
Blending
°
Coal
Blending
 
Unit
classified
by
the
predominate
coal
burned
during
the
compliance
period
 
Unit
classified
by
a
 
weighted
emission
limit 
based
on
the
proportion
of
energy
output
(
in
Btu)
contributed
by
each
coal
rank
burned
during
the
compliance
period
°
If
non­
regulated
fuels
are
used
(
e.
g.,
petroleum
coke,
Tire­
derived
Fuel
[
TDF],
etc.),
the
compliance
calculation
would
include:

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

 
Proposed
Performance
Specification
12A
(
PS­
12A)

°
Carbon
Absorption
Tube
 
Proposed
Reference
Method
324
°
Manual
Stack
Test
 
ASTM
Method
D6784­
02
("
Ontario­
Hydro")

 
EPA
Reference
Method
29
°
Emissions
Averaging
Provision
for
Hg
 
Demonstrate
compliance
through
averaging
Hg
emissions
from
multiple
(
two
or
more)
affected
units
located
at
a
common,
contiguous
facility
site
 
Leads
to
a
single
applicable
facility­
wide
emission
limit
°
Ni
Testing
and
Monitoring
Requirements
 
Maximum
allowable
emission
limit;
not
to
be
exceeded
 
Options
for
Ni
monitoring
°
EPA
Reference
Method
29
Section
111
Proposal
°
Section
111(
b)
 
New
Source
Performance
Standards
(
NSPS)

 
Requires
EPA
to
promulgate
standards
of
performance
for
emissions
of
air
pollutants
from
new
sources
 
Monitoring
and
compliance
requirements
are
similar
to
the
section
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
(
10­
6
lb/
MWh)

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

°
Section
111(
d)
 
Emission
Guidelines
(
EG)

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

°
Requiring
sources
to
hold
allowances
to
cover
their
emissions
on
a
one­
for­
one
basis
°
Limiting
overall
allowances
so
that
they
cannot
exceed
specified
levels
(
i.
e.,
the
"
cap
level")

°
Reducing
the
cap
to
less
than
the
amount
of
emissions
actually
emitted,
or
allowed
to
be
emitted,
at
the
inception
of
the
program
°
Allowing
for
a
declining
cap
over
time
°
Creating
market­
based
incentives
for
early
reductions
Section
111
Proposal
(
continued)

°
Section
111
 
Regulatory
Approach
 
Primary
goal
is
to
reduce
Utility
Unit
Hg
emissions
from
current
levels
 
2018
cap
is
permanent
 
Effectively
becoming
more
stringent
as
more
plants
are
required
to
keep
their
collective
emissions
below
15
tons
 
Near­
term
interim
cap
in
2010
 
Level
will
reflect
the
maximum
level
of
Hg
reductions
achievable
through
FGD
and
SCR
installations
(
for
SO
2
and
NO
x
emission
reductions)
on
units
covered
under
the
IAQR
 
Level
is
not
prescribed
in
current
proposal
because
of
uncertainties
associated
with
the
ability
of
these
controls
to
reduce
Hg
emissions
 
EPA
seeks
comment
and
technical
information
on
the
Phase
I
cap
level
 
EPA
believes
that
a
carefully
designed
 
multi­
pollutant 
approach
 
a
program
designed
to
control
NO
x,
SO
2,
and
Hg
at
the
same
time
 
is
the
most
effective
way
to
reduce
emissions
from
the
electric
power
sector
°
Details
of
section
111
trading
program
are
outlined
in
a
Supplemental
Notice
of
Proposed
Rulemaking
(
SNPR),
which
was
published
on
March
16,
2004
SNPR:
Hg
Program
Requirements
Under
Section
111
 
Each
State
must
submit
a
plan
that
demonstrates
it
will
meet
its
assigned
statewide
Hg
emissions
budget
 
States
may
join
the
trading
program
by
adopting
or
referencing
the
model
trading
rule
in
State
regulations;
or,
adopting
regulations
that
mirror
the
necessary
components
of
the
model
trading
rule
 
States
can
choose
not
to
join
the
federal
trading
program
and
meet
their
budget
through
intra­
state
trading
or
no
trading
 
States
can
also
choose
to
implement
more
stringent
Hg
emissions
requirements
 
EPA
has
taken
comment
on
a
proposal
to
promulgate,
under
section
112(
n)(
1)(
A),
a
cap­

andtrade
program
for
Hg
from
coal­
fired
utility
units
 
Trading
program
would
be
federally
implemented
with
the
EPA,
instead
of
states,
serving
as
the
permitting
authority
SNPR:
Monitoring
Hg
Emissions
 
Monitoring
of
Hg
will
resemble
current
monitoring
of
SO
2
and
NO
x
under
the
Acid
Rain
and
NO
x
SIP
Call
programs
 
A
comprehensive
QA/
QC
program
ensures
the
adequacy
of
emissions
data
 
Current
monitoring
in
the
Acid
Rain
and
NO
x
SIP
Call
programs
averages
over
98%
availability
 
A
petition
process
enables
monitoring
flexibility
and
facilitates
the
resolution
of
issues
 
Commensurate
with
the
SO
2
and
NO
x
cap­
and­
trade
programs,
regulated
sources
would
have
the
flexibility
of
using
alternative
monitoring
approaches
as
long
as
such
approaches
meet
the
performance
requirements
in
the
rule
Summary
 
Recent
proposals
are
based
on
3
major
points
regarding
public
health
 
Science
continues
to
tell
us
to
move
aggressively
on
fine
particles
 
There
is
growing
evidence
that
ozone
may
be
a
larger
problem
than
previously
expected
 
Mounting
scientific
evidence
and
public
concern/
interest
indicate
that
Hg
emissions
must
be
controlled
 
Administration
strongly
prefers
the
Clear
Skies
Act
legislation
instead
of
controlling
NO
x,
SO
2
and
Hg
under
the
existing
CAA
 
EPA
will
stay
with
the
current
package
of
proposals,
absent
any
movement
on
the
legislation
 
EPA
is
committed
to
action
 
Power
sector
is
not
the
only
industrial
sector
EPA
is
looking
towards
to
make
significant
reductions
 
Petroleum
refining,
car/
truck/
engine
manufacturing,
and
construction
equipment
industries
are
making
reductions
through
the
Tier
II,
Heavy
Duty
Diesel,
and
Non­
road
Diesel
rules
 
EPA
is
also
requiring
a
variety
of
industries
to
meet
new
MACT
standards,

which
will
create
emission
reductions
of
both
criteria
and
air
toxics
pollutants
Next
Steps
 
Supplemental
Notice
on
Mercury
Rule
March
16,
2004
 
Hold
Public
Hearings
February
25­
26,
2004
 
Philadelphia,
PA
 
Chicago,
IL
 
Research
Triangle
Park,
NC
 
Denver,
CO
March
30,
2004
 
Public
Comment
Periods
Close
April
30,
2004
 
Supplemental
Notice
on
Interstate
Air
Quality
Rule
April
2004
 
Finalize
Mercury
Rule
December
2004
 
Finalize
Interstate
Air
Quality
Rule
December
2004
