Reducing
Power
Plant
Emissions:

Proposed
Clean
Air
Mercury
Rule
(
CAMR)

Presentation
for
EPA/
Air
&
Waste
Management
Association
Information
Exchange
William
H.
Maxwell
Combustion
Group
EPA
Office
of
Air
Quality
Planning
and
Standards
December
7,
2004
What's
Driving
the
Regulatory
Bus?

°
Ozone
and
Fine
Particle
Attainment
 
We
need
more
NO
x,
SO
2
and
fine
particle
reductions
for
attainment
purposes
(
i.
e.,
PM
2.5
and
8­
hour
ozone)

°
Mercury
 
Current
control
technologies
for
NO
x,
SO
2
and
PM
are
capable
of
significantly
reducing
power
plant
mercury
emissions
 
Hg­
specific
control
technologies
are
not
ready
for
fullscale
commercial
deployment
 
The
Agency
has
a
settlement
agreement
to
propose
Hg
regulations
by
December
15,
2003,
and
promulgate
by
March
15,
2005
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%)
Mercury
Global
Emissions
­

Anthropogenic
Emissions
by
Continent
United
States
131
(
utilities:
42)
South
&
Central
America
176
Europe
326
Africa
246
Oceania
48
Balance
of
North
America
57
Asia
1,138
Global
total:
2,122
Mg/
y
(
Adapted
from
EPRI,
2004)
EPA
Proposes
to
Reduce
Utility
Emissions
through
Current
CAA
Authorities
°
Clear
Air
Interstate
Rule
(
CAIR)
to
address
the
contribution
of
transported
SO
2/
NO
x
emissions
to
ozone
(
smog)
and
fine
particle
(
PM
2.5)
nonattainment
problems
in
the
Eastern
U.
S.

°
Clean
Air
Mercury
Rule
(
CAMR)
which
are
standards
to
reduce
nationwide
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
­
125
­
120
­
115
­
110
­
105
­
100
­
95
­
90
­
85
­
80
­
75
­
70
­
65
Longitude
(
degrees)

25
30
35
40
45
50
Latitude
(

degrees)
0
to
0.025
0.025
to
0.05
0.05
to
0.1
0.1
to
0.5
0.5
to
1.1
Total
Hg
Emissions
for
the
1999
ICR
Plants
Total
Hg
(
tons
per
year)

NOTE:
Excludes
1
plant
in
AK
and
1
plant
in
HI
Proposed
Alternatives
to
Reduce
Mercury
Emissions
from
the
Power
Sector
 
Proposed
Section
112
MACT
requirements
for
coal­
fired
generation
units
 
Reduces
mercury
emissions
from
48
to
34
tons
by
2008
with
controls
based
on
coal
type.
Sets
nickel
standard.

 
Proposed
cap­
and­
trade
approach
to
address
mercury
from
coal­
fired
generation
units
under
Section
111
 
Revises
December
2000
determination
to
use
Section
112
MACT
requirements.

 
Commits
to
phased­
in
caps:
first
cap
at
co­
benefits
level
in
2010;
second
cap
at
15
tons
in
2018.

 
Caps
annual
mercury
emissions
at
15
tons
in
2018
and
after.

 
Also,
discusses
cap­
and­
trade
approach
under
Section
112(
n)(
1)(
A)
Proposed
Section
112
MACT
 
Existing
Sources
 
Six
subcategories
 
Bituminous,
Sub­
bituminous,
Lignite,
IGCC,
Waste/
Refuse
Coal,

Oil
 
Limits
are
based
on
the
average
of
the
top
12%
of
sources
in
each
subcategory
 
Accounted
for
variability
 
Fuel
type,
Unit­
by­
Unit,
Facility­
to­
Facility
 
Emission
standards
applicable
to
each
source
 
No
trading
 
Emissions
averaging
is
allowed
 
New
Sources
 
Six
subcategories
 
Bituminous,
Sub­
Bituminous,
Lignite,
IGCC,
Waste/
Refuse
Coal,

Oil
 
Limits
are
based
on
the
best
performing
similar
source
in
each
subcategory
 
Accounted
for
variability
 
Fuel
type,
Unit­
by­
Unit,
Facility­
to­
Facility
 
Emission
standards
applicable
to
each
source
 
No
trading
Emissions
averaging
is
allowed
 
December
Proposal:

 
Guidelines
for
State
Implementation
Plans
 
111(
d)

 
Sets
emission
rates
for
existing
coal­
fired
utility
units
under
a
cap­

andtrade
program
administered
by
States
 
Phase
1:
2010
(
solicit
comment
on
co­
benefits­
based
cap
level)

 
Phase
2:
2018
Capped
at
15
tons
 
Sets
a
limit
for
nickel
emissions
from
oil­
fired
units
to
ensure
adequate
control
 
Federal
rule
for
new
sources
 
111(
b)

 
Includes
new
utility
emission
limits
for
mercury
and
nickel
 
Supplemental
Proposal:

 
Mercury
model
trading
rule
 
Options
for
allowance
allocation
by
States
 
Benefits
of
111
Alternative:

 
Would
reduce
nationwide
mercury
emissions
by
33
tons
(
69
percent)
from
today s
levels
when
fully
implemented
after
2018.

 
Potential
for
earlier
and
greater
reductions
than
proposed
MACT
alternative.

 
Meshes
well
with
the
CAIR,
creating
an
integrated
multipollutant
approach
to
controlling
emissions
from
power
plants.

Proposed
Section
111
Alternative
Notice
of
Data
Availability
°
Notice
of
Data
Availability
(
NODA)
issued
on
December
1,
2004
(
69
FR
69864)

 
Solicits
additional
public
input
on
a
number
of
issues
related
to
 
Power­
sector
modeling
and
assumptions
used
 
Speciated
mercury
emissions
 
Benefits
methodology,
including
 
Mercury
emissions
from
other
sources
 
Air
dispersion
modeling
capabilities
 
Modeling
ecosystem
dynamics
 
Fish
consumption
and
human
exposure
 
Comment
period
ends
January
3,
2005
°
CAMR
NODA
December
1,
2004
°
Finalize
CAIR
By
end
of
2004
°
Finalize
CAMR
March
15,
2005
Next
Steps
Further
Information:

www.
epa.
gov/
interstateairquality
www.
epa.
gov/
mercury
Mercury
Monitoring
Under
a
Cap
and
Trade
Program
Ruben
Deza,
Ph.
D.

Clean
Air
Markets
Division
U.
S.
Environmental
Protection
Agency
Monitoring
Emissions
 
Why
is
emissions
monitoring
important?

 
Because
every
unit
of
emission
needs
to
be
accurately
accounted
for
 
Is
needed
to
achieve
environmental
integrity
 
Provides
the
"
Gold
Standard"
behind
the
currency
of
allowances
 
Elements
of
a
successful
emissions
measurement
program
are:

 
Accurate
Monitoring
 
Complete
accounting
of
mass
emissions
 
Consistent
and
Transparent
 
Comprehensive
quality
assurance
 
Efficient
administration
 
Cost
effective
Important
Considerations
of
our
Monitoring
Process
In
Cap
and
Trade
Programs
 
Emissions
data
are
measured
 
Stringent
monitor
quality
assurance
criteria
 
Built­
in
regulatory
incentives
for
good
quality:

 
Missing
data
substitution
procedures
 
Quality
assurance
testing
frequency
based
on
monitor
performance
Two
Alternative
Monitoring
Systems
 
Continuous
Emissions
Monitoring
System
 
Similar
to
current
systems
 
Sorbent
Tubes
 
Accumulation
of
Hg
over
an
extended
period
of
time,
e.
g.,
a
few
days
or
weeks
 
Lab
analysis
of
the
tubes
at
end
of
use
 
Overall
Assessment:

 
Under
controlled
conditions,
both
monitoring
systems
are
capable
of
providing
adequate
measurements
 
It
is
reasonable
to
expect
that
full
commercialization
will
be
achievable
before
the
rule's
compliance
date
Comments
Regarding
Monitoring
Issues
 
Significant
number
of
comments
 
Commenters
addressed
issues
related
to:

 
Method
324
 
Utilization
of
Sorbent
traps
under
a
cap
and
trade
program
 
QA/
QC
procedures
for
sorbent
traps
 
PS
12
A
 
Reliability
of
Hg
CEMS
 
Need
of
an
instrumental
method
 
Changes
in
the
ISO
certification
for
labs
conducting
tests
Response
to
Comments
 
Over
800,000
comments
received
 
Highest
priority
will
be
to
address
major
issues
receiving
significant
comments
AWMA
Information
Exchange
2004
Mercury
Emissions
Monitoring
Robin
Segal
Emission
Monitoring
and
Analysis
Division
EPA
Office
of
Air
Quality
Planning
and
Standards
December
7,
2004
AWMA
Information
Exchange
2004
Mercury
Emissions
Monitoring
 
Both
proposed
MACT
and
cap­

andtrade
approaches
rely
on
mercury
emissions
monitoring
 
Electric
Utility
Mercury
Rule
proposed
1/
30/
04
and
Supplemental
Notice
with
cap­
and­
trade
details
3/
16/
04
 
CEMS
 
Sorbent
trap
(
Method
324)

 
Received
many
comments
Mercury
Emissions
Monitoring
°
Partnership
of
OAQPS
with
CAMD,
ORD,

NIST,
and
EPRI
°
Prior
Activities
°
Conducted
several
field
demonstrations
of
mercury
monitoring
systems
°
Docket
items
OAR­
2002­
0056­
0023,
24,
25,
26,
27
°
Developed
PS
12A
and
edited
Method
324
for
rule
proposals
Mercury
Emissions
Monitoring
 
Current
Activities
 
Field
demonstration
of
available
monitoring
systems
to
inform
promulgation
of
rule
 
Initiate
development
of
an
instrumental
reference
method
for
certifying
mercury
CEMS
 
Consideration
of
comments
in
regard
to
potential
monitoring
requirements
for
final
rule
(
3/
15/
05)
Mercury
Emissions
Monitoring
 
Field
Demonstration
Objectives
 
Install
monitoring
technologies
at
site(
s)
with
fuel
use
and
control
equipment
expected
to
be
prevalent
under
future
rules
 
Eastern
bituminous
coal
 
ESP
with
SCR
and
wet
scrubber
 
Evaluate
CEMS
performance
with
regard
to
proposed
requirements
for
MACT
and
cap­
and­
trade
rules
Mercury
Emissions
Monitoring
 
Field
Demonstration
Objectives
(
continued)

 
Assess
ability
of
CEMS
to
provide
reliable
data
on
a
long­
term
basis
 
Durability,
up­
time,
maintenance
requirements
 
Refine
measurement
performance
criteria
for
Performance
Specification
12A,
Method
324,
and
Part
75
 
Allow
for
evaluation
of
potential
performance
requirements
for
a
draft
instrumental
reference
method
