November
30,
2005
MEMORANDUM
From:
William
H.
Maxwell
CG/
ESD
(
C439­
01)

To:
CAMR
Project
Files
Subject:
Meeting
with
National
Mining
Association,
November
30,
2005
Attendees
National
Mining
Association
(
NMA):
Todd
Johnston,
NMA
Dennis
James,
North
American
Coal
Usha
Turner,
TXU
Greg
Schaefer,
Arch
Coal
Gary
Slagel,
Consol
Energy
Steve
Winberg,
Consol
Energy
Dennis
Hughes,
Peabody
Energy
Mark
Davies,
Kennecott
EPA:
Jason
Burnett,
OAR/
OA
Sam
Napolitano,
OAR/
OAP/
CAMD
Kevin
Culligan,
OAR/
OAP/
CAMD
Robert
J.
Wayland,
OAR/
OAQPS/
ESD
Bill
Maxwell,
OAR/
OAQPS/
ESD
Discussion
The
attached
presentation
was
discussed.
Clean
Air
Mercury
Rule
(
CAMR)

Presentation
for
the
Meeting
with
National
Mining
Association
Robert
J.
Wayland,
Ph.
D.

U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
September
28,
2005
There
Have
Been
Two
Ways
to
Address
Transported
and
Hg
Emissions
from
Power
Plants
°
The
President's
Clear
Skies
legislation
is
the
preferred
approach
to
achieving
multi­
pollutant
emission
reductions:

 
Multipollution
caps
apply
to
entire
country.

 
Legislation
can
provide
more
certainty,
coordination,
and
less
complexity.

°
Use
of
existing
Clean
Air
Act
authority
to
address
interstate
transport
of
pollution
and
Hg:

 
Until
legislation
passes,
our
attainment
deadlines
and
other
problems
related
to
power
plant
emissions
demand
we
act
now.

 
Settlement
conditions
set
up
Hg
actions.

 
Clean
Air
Interstate
Rule
(
CAIR)
and
Clean
Air
Mercury
Rule
(
CAMR)

°
CAIR
and
CAMR
will
provide
very
significant
air
quality
attainment,

health,
and
environmental
improvements
in
a
cost­
effective
manner.
°
Concentrations
of
mercury
in
the
air
are
usually
low.
However,
atmospheric
mercury
falls
to
Earth
through
rain,
snow
and
dry
deposition
and
enters
lakes,
rivers
and
estuaries.
Once
there,
it
can
transform
into,
methyl­
mercury,
and
build
up
in
fish
tissue.

°
Americans
are
exposed
to
methyl­
mercury
primarily
by
eating
fish
that
contain
mercury.

°
Because
the
developing
fetus
is
the
most
sensitive
to
the
toxic
effects
of
methyl­
mercury,
women
of
childbearing
age
are
regarded
as
the
population
of
greatest
concern.

°
Children
who
are
exposed
to
relatively
high
levels
of
methyl­
mercury
before
birth
may
be
at
increased
risk
of
poor
performance
on
neurobehavioral
tasks,
such
as
those
measuring
attention,
fine
motor
function,
language
skills,

visual­
spatial
abilities
and
verbal
memory.

°
Methyl­
mercury
contained
in
fish
may
also
reduce
the
cardio­
protective
benefits
of
fish
consumption
and
cause
other
health
effects.

°
Ecosystems
may
be
affected
by
mercury
deposition.
Mercury
Concerns
Mercury
Emissions
Are
a
Global
Problem
Source:
Based
on
Pacyna,
J.,
Munthe
J.,
Presentation
at
Workshop
on
Mercury,
Brussels,
March
29­
30,
2004
U.
S.
Power
Plant
Emissions
1%

U.
S.
All
Other
Sources
2%
Emissions
from
All
Other
Countries
97%

1999
Global
Mercury
Emissions
Mercury
Emissions
Are
a
Global
Problem
Sources:
Mercury
exposure
data
is
based
on
Carrington,
C.
D.,
B.
Montwill
and
P.
M.
Bolger.
2004.
"
An
Intervention
Analysis
for
the
Reduction
of
Exposure
to
Methylmercury
from
the
Consumption
o
Seafood
by
Women
of
Child­
Bearing
Age."
U.
S.
utility
contribution
data
is
from
Pacyna,
J.,
Munthe
J.,
Presentation
at
Workshop
on
Mercury,
Brussels,
March
29­
30,
2004.

(
5
Percent)

Mercury
Exposure
Attributable
to
Freshwater
Fish
Mercury
Exposure
Attributable
to
Saltwater
Fish
(
95
Percent)

U.
S.
utilities
contribute
about
1
percent
to
the
global
mercury
pool
which
is
deposited
in
both
saltwater
and
freshwater
environments
Notes:
This
chart
provides
information
on
the
contribution
of
different
kinds
of
fish
to
mercury
exposure
for
the
U.
S.
population
as
a
whole.

The
degree
of
exposure
to
mercury
is
due
to
the
total
amount
and
type
of
fish
eaten
and
the
concentration
of
mercury
in
each
fish.
It
is
important
to
remember
that
an
individual's
exposure
is
related
to
the
amount
and
type
of
fish
the
individual
consumes
and
individual
consumption
of
different
types
of
fish
varies
throughout
the
U.
S.
Mercury
concentration
data
is
primarily
from
Mercury
in
Fish:
FDA
Monitoring
Program
1990
­
2003
(
http://
www.
cfsan.
fda.
gov/~
frf/
seamehg2.
html).
Some
fish
tissue
samples
were
tested
for
methylmercury
and
some
fish
tissue
samples
were
tested
for
total
mercury.
Mercury
exposure
estimates
rounded
to
the
nearest
5
percent.
0
50
100
150
200
250
1990
Emissions
1996
Emissions
1999
Emissions
Tons
Per
Year
Other
Gold
Mines
Hazardous
Waste
Incineration
Chlorine
Production
Institutional
Boilers
Medical
Waste
Incinerators
Utility
Coal
Boilers
Municipal
Waste
Combustors
220
tons
195
tons
120
tons
Source:
EPA
1990,
1996
NTI
and
EPA
1999
NEI.
Short
tons
per
year.
Adjusted
for
gold
mines
in
1990
and
1996.

*
The
1990
and
1996
NEI
did
not
include
gold
mining
emissions
data.
The
emissions
shown
here
for
gold
mines
in
those
years
are
assumed
to
be
equal
to
emissions
for
those
mines
in
1999.

U.
S.
Emissions
of
Anthropogenic
Mercury
Have
Dropped
45%
since
1990
°
Existing
Controls:

 
Almost
all
units
have
particulate
matter
(
PM)
control
devices
 
About
one­
third
of
capacity
has
sulfur
dioxide
(
SO2)
scrubbers
 
Most
have
initial
nitrogen
oxides
(
NOx)

controls
(
low­
NOx
burners)

 
About
one­
third
of
the
capacity
(
primarily
in
the
east)
will
have
advanced
NOx
control
(
SCR)
when
NOx
SIP­
call
is
fully
implemented
°
Future
Controls:

 
About
two­
thirds
of
the
capacity
(
primarily
in
the
east)
will
have
SO2
scrubbers
when
CAIR
is
fully
implemented
 
About
one­
half
of
the
capacity
(
primarily
in
the
east)
will
have
advanced
NOx
control
(
SCR)
when
CAIR
is
fully
implemented
Coal­
Fired
Power
Plants
in
the
U.
S.

°
Affected
Facilities:

 
About
1,300
coal­
fired
generation
units
(~
500
coal­
fired
power
plants),
representing
about
305
GW
of
generation
capacity
Power
Plant
Equipment
and
Mercury
Factors
that
influence
mercury
control:


Coal
type

Time/
temperature
profile

Flue
gas
composition
(
chlorine)
and
fly
ash
characteristics
(
carbon,
calcium,
iron,

porosity)


Air
pollution
controls
already
in
place
Wet
Scrubber
Hg0
>
2500
°
F
Flue
Gas
Hg(
0),
Hg(
II),
Hgp
­
form
important
for
capture1
700
°
F
SCR
ESP
or
FF
Coal
&
Air
Ash
Residue
Ammonia
Stack
Limestone
or
lime
slurry
1
Hg(
0)
=
elemental
Hg;
Hg(
II)
=
oxidized
Hg;
Hg
p
=
particulate
Hg
Key
Elements
of
CAMR
°
The
Clean
Air
Mercury
Rule
establishes
"
standards
of
performance"
limiting
mercury
emissions
from
new
and
existing
coal­
fired
power
plants
and
creates
a
market­
based
cap­
and­
trade
program
that
will
reduce
nationwide
utility
emissions
of
mercury
in
two
distinct
phases.

 
The
first
phase
cap
is
38
tons
and
emissions
will
be
reduced
by
taking
advantage
of
"
co­
benefit"

reductions
 
that
is,
mercury
reductions
achieved
by
reducing
sulfur
dioxide
(
SO2)
and
nitrogen
oxides
(
NOx)
emissions
under
CAIR
 
the
new
Base
Case.

 
In
the
second
phase,
due
in
2018,
coal­
fired
power
plants
will
be
subject
to
a
second
cap,
which
will
reduce
emissions
to
15
tons
upon
full
implementation.

°
New
coal­
fired
power
plants
("
new"
means
construction
starting
on
or
after
Jan.
30,
2004)
will
have
to
meet
new
source
performance
standards
in
addition
to
being
subject
to
the
caps.

°
CAMR
sets
an
emission
reduction
requirement
for
each
State
and
Indian
country,
by
distributing
the
national
emissions
cap
among
the
States
and
Indian
country.

°
Provides
an
optional
cap
and
trade
program
based
on
successful
Acid
Rain
and
NOx
Budget
Trading
programs
as
a
method
to
implement
the
necessary
reductions.

°
Allows
States
flexibility
on
how
to
achieve
the
required
reductions,
including
whether
to
join
the
trading
program.
New
Source
Requirements
°
New
coal­
fired
power
units
(
Subpart
Da
electric
generating
units)
constructed
after
Jan.
30,
2004
will
have
to
meet
new
source
performance
standards
in
addition
to
being
subject
to
the
caps.

°
Since
new
sources
are
included
in
the
cap,
new
sources
will
also
need
to
hold
allowances
equal
to
their
emissions.

°
Compliance
with
the
NSPS
is
determined
on
a
12­
month
rolling
average
basis,
using
data
from
a
CEMS
or
sorbent
trap
monitoring
system
°
Performance
Specification
12­
A
(
certification
procedure
for
the
Hg
CEMS
required
under
Subpart
Da)
has
also
been
promulgated
as
part
of
the
CAMR
rule
package
1.0
175
66
97
20
Hg
(
10
­
6
lb/
MWh)
**

1.4
Coal
refuse­
fired
20
IGCC
145
Lignite­
fired
42
78
Subbituminousfired

­
Wet
FGD
­
Dry
FGD
21
Bituminous­
fired
Hg
(
10
­
6
lb/
MWh)
*

Subcategory
New
Source
NSPS
Limits:

*
Final
CAMR
emission
limits
**
CAMR
emission
limits
proposed
on
reconsideration
Hg
Monitoring
Requirements
°
Stringent
emission
monitoring
and
reporting
requirements
ensure
that
monitored
data
are
accurate,
that
reporting
is
consistent
among
sources
 
and
that
the
emission
reductions
occur.

°
All
units
would
have
the
flexibility
to
install
sorbent
traps
or
CEMS

Some
low­
emitting
units
(<
29
lbs/
yr)
may
qualify
for
a
third
option
­
Two­
tiered
approach
requires
annual
stack
testing
if
Hg
emissions
are<
9
lb/
yr
and
semi­
annual
testing
if
emissions
are
greater
than
9
lb/
yr,
but
<
29
lb/
yr

Sources
may
also
petition
to
use
an
alternative
monitoring
system,
under
Subpart
E
of
Part
75
°
The
blueprint
for
the
Hg
trading
program
is
found
in
Subpart
HHHH
of
40
CFR
Part
60.


Subpart
HHHH
includes
monitoring
provisions
(
§
§
60.4170­
76)

°
Subpart
I
has
been
added
to
Part
75

Establishes
monitoring
methods
for
Hg
mass
emissions

Similar
to
Subpart
H
for
the
NOx
SIP
Call
°
Revisions
have
been
made
to
key
sections
of
Parts
72
and
75
to
facilitate
implementation
of
the
Subpart
I
monitoring
provisions
Cap
and
Trade
Mechanism:

Allowance
Allocation
and
Markets
°
EPA
is
working
to
provide
a
smooth
transition
to
new
trading
program
 
Designed
with
existing
cap
and
trade
programs
in
mind
 
Integration
with
CAIR
program
°
Set
state
budgets
°
Establish
trading
program
and
market
procedures
°
Administer
tracking
systems
°
Define
allowance
allocation
parameters
°
State
Plan
detailing
how
it
will
meet
its
budget
for
reducing
mercury
from
coal­
fired
power
plants
°
Voluntary
trading
program
­
Adopt
rules/
program
in
18
months
­
Allocate
Hg
allowances
EPA
ROLE
STATE
ROLE
°
States
must
submit
a
State
plan
under
111(
d)
that
includes:

 
A
description
of
control
measures
to
meet
the
statewide
mercury
budget
 
Fully­
adopted
State
rules
for
the
mercury
reduction
strategy
with
compliance
dates
providing
for
control
by
2010
°
Each
State
must
impose
control
requirements
that
demonstrate
it
will
meet
its
assigned
statewide
Hg
emissions
budget.

°
States
may
join
the
trading
program
by
adopting
or
referencing
the
model
trading
rule
(
40
CFR
part
60,
subpart
HHHH)
in
State
regulations
or
adopting
regulations
that
mirror
the
necessary
components
of
the
model
trading
rule.

°
States'
responsibilities
include:

 
Identification
of
affected
sources,
permitting
and
allocation
of
allowances
 
Verification:
reviewing
monitoring
plans
and
approving
certification
applications;

observing
QA
testing
and
performing
audits
 
Lead
in
pursuing
enforcement
actions
°
State
can
choose
to
implement
more
stringent
Hg
emissions
requirements.
State
Requirements
under
CAMR
Benefits
of
the
Clean
Air
Mercury
Rule
(
CAMR)

°
The
Clean
Air
Mercury
Rule
will
build
on
EPA's
Clean
Air
Interstate
Rule
(
CAIR)
to
significantly
reduce
emissions
from
coal­
fired
power
plants
­­
the
largest
remaining
sources
of
mercury
emissions
in
the
country.

°
When
fully
implemented,
these
rules
will
reduce
utility
emissions
of
mercury
from
48
tons
a
year
to
15
tons,
a
reduction
of
nearly
70
percent.

°
Because
excess
emissions
reductions
can
be
banked
under
the
first
phase,
Hg
emissions
are
projected
to
be
31
tons
in
2010
­
­
a
35%
reduction
in
total
Hg
emissions
and
a
proportionally
higher
reduction
of
non­
elemental
mercury.

°
EPA's
modeling
shows
that
CAIR
will
significantly
reduce
the
majority
of
the
coal­
fired
power
plant
mercury
emissions
that
deposit
in
the
United
States,
and
those
reductions
will
occur
in
areas
where
mercury
deposition
is
currently
the
highest.

°
The
Clean
Air
Mercury
Rule
is
expected
to
make
additional
reductions
in
emissions
that
are
transported
regionally
and
deposited
domestically,
and
it
will
reduce
emissions
that
contribute
to
atmospheric
mercury
worldwide.

°
Emission
reductions
occur
while
economic
strength
is
preserved.
U.
S.
maintains
both
low
electricity
prices
and
fuel
diversity.

The
first­
ever
federal
rule
to
permanently
cap
and
reduce
mercury
emissions
from
coal­
fired
power
plants.
Total
Mercury
Deposition
Deposition
from
All
Sources
in
2001
Deposition
from
All
U.
S.
and
Canadian
Sources
in
2001
Source:
US
EPA
2005
using
Community
Multiscale
Air
Quality
(
CMAQ)
model.
Power
Plant
Mercury
Deposition
Deposition
from
U.
S.
Power
Plants
in
2001
Deposition
from
U.
S.
Power
Plants
After
CAIR,
CAMR,
and
Other
Clean
Air
Act
Programs
in
2020
Source:
US
EPA
2005
using
Community
Multiscale
Air
Quality
(
CMAQ)
model.
Mercury
Deposition
in
the
U.
S.

Tons
of
Mercury
2001
deposition
from
U.
S.
power
plants
2020
deposition
from
U.
S.
power
plants
11
12
121
0
20
40
60
80
100
120
140
160
11.1
3.4
0
2
4
6
8
10
12
Tons
of
Mercury
144
Deposition
from
U.
S.
Power
Plants
Source:
U.
S.
EPA
2005
=
2001
total
deposition
in
the
U.
S.
from
Canadian
and
non­
power
plant
U.
S.
sources
=
2001
deposition
in
the
U.
S.
from
U.
S.
utilities
=
2001
deposition
in
the
U.
S.
from
sources
outside
of
the
U.
S.
and
Canada
Total
Deposition
in
2001
Projected
2020
Hg
Emissions
for
Power
Plants
Under
CAMR
Scale:
5.5
tons
in
Pennsylvania
under
CAIR
New
Base
Case:
CAIR
Original
Base
Case
CAMR
5.5
tons
on
PA
in
Original
Base
Case
Are
Trading
Programs
Effective?

Acid
Rain
Program
SO
2
Trading
Experience
Scale:

2.2
million
tons
(
1990
Emissions,
Ohio)

1990
Emissions
Phase
I
Average
Emissions
(
1995­
1999)

Phase
II
Average
Emissions
(
2002­
2003)
Notes:

°
The
non­
OTC
states
are
shaded
°
In
2004,
the
control
period
for
non­
OTC
states
was
May
31
through
September
30
°
Allocated
Allowances
are
equal
to
the
Trading
Budget
plus
CSP
Allowances
Effectiveness
of
Trading
Programs
 
The
NOx
SIP
Call
Experience
$
0.16
$
0.10
$
0.75
$
0
$
1
$
2
$
3
$
4
$
5
$
6
2010
2015
2020
Billions
($

1999)
Annualized
Private
Cost
of
CAMR
Note:
From
IPM.
Cost
of
CAIR
is
$
2.4
billion
in
2010,
$
3.6
billion
in
2015,
and
$
4.4
billion
in
2020,
with
a
net
present
value
of
$
41.1
billion.

°
The
net
present
value
of
CAMR
incremental
to
CAIR
for
the
years
2007­
2025
is
$
3.9
billion.
0
1,000
2,000
3,000
4,000
5,000
6,000
CAIR
CAMR
CAIR
CAMR
CAIR
CAMR
TWh
Note:
Henry
Hub
prices
Regional
Retail
Electricity
Prices
Other
Projected
Impacts
Note:
Retail
prices
for
2000
are
from
AEO2003.
Natural
Gas
prices
for
2000
are
from
Platts
GASdat.
All
other
data
is
from
EPA's
Integrated
Planning
Model.

Natural
Gas
Prices
Coal
Production
for
Electricity
Generation
(
million
tons)

Generation
Mix
Coal
Gas/
Oil
Nuclear
Hydro
Renewables
Other
2020
2010
2015
CAMR
2000
2010
2020
Appalachia
299
303
330
Interior
131
169
224
West
475
589
572
National
905
1,061
1,127
2003
275
135
526
936
0.0
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
2000
2010
2015
2020
Cents/

kWh
CAIR
CAMR
$­

$
0.50
$
1.00
$
1.50
$
2.00
$
2.50
$
3.00
$
3.50
$
4.00
$
4.50
2000
2010
2015
2020
$/

mmBtu
CAIR
CAMR
Current
and
Projected
Coal
Production
for
the
Power
Sector
with
CAMR
West
Interior
Appalachia
National
Coal
Production
for
the
Power
Sector:
Continued
Growth
with
CAMR
2000
2003
2010
2015
2020
2000
2003
2010
2015
2020
2000
2003
2010
2015
2020
Notes:
Coal
production
for
the
power
sector.
This
data
is
from
the
Final
CAMR
Regulatory
Impact
Analysis.
Scale:
Appalachia
2000
=
299
million
tons
By
2020,
nationwide
coal
production
is
projected
to
increase
by
20%,
with
growth
occurring
in
all
major
supply
regions.

0
200
400
600
800
1000
1200
2000
2003
2010
2015
2020
Million
Tons
CAIR
and
CAMR
Implementation
Timeline
Phase
I:
CAIR
NOx
Programs
(
ozone­
season
and
annual)

(
09)
Phase
I:
CAIR
SO2
Program
(
10)

States
develop
SIPs
(
18
months)
SIPs
Due
(
Sep
06)

CSP
Early
Emission
Reduction
Period
(
annual
CAIR
NOx
program)

(
07
and
08)
NOx
Monitoring
and
Reporting
Required
(
08)
SO2
Monitoring
and
Reporting
Required
(
09)
Phase
II:
CAIR
NOx
and
SO2
Programs
Begin
(
15)

Early
Reductions
for
CAIR
NOx
ozone­
season
program
and
CAIR
SO2
program
begin
immediately
because
NOx
SIP
Call
and
title
IV
allowances
can
be
banked
into
CAIR
Note:
Dotted
lines
indicate
a
range
of
time.

05
06
07
08
09
10
12
13
14
11
15
CAMR
Rule
signed
18
17
16
CAIR
CAMR
States
develop
SIPs
(
18
months)

CAIR
Rule
signed
SIPs
Due
(
Nov.
06)
Phase
I:
Hg
Program
(
10)
Phase
II:
Hg
Program
(
18)

Hg
Monitoring
and
Reporting
Required
(
10)
Summary
CAMR
significantly
cuts
emissions
of
mercury
from
power
plants
and:

°
Builds
on
EPA's
Clean
Air
Interstate
Rule
(
CAIR)
to
allow
power
industry
to
address
mercury,
SO2
and
NOx
emissions
in
a
coordinated
effort.

°
Along
with
CAIR,
will
help
protect
public
health
and
the
environment
without
interfering
with
the
steady
flow
of
affordable
energy
for
American
consumers
and
business.

°
Along
with
CAIR,
is
expected
to
make
reductions
in
emissions
that
are
transported
regionally
and
deposited
domestically,
and
it
will
reduce
emissions
that
contribute
to
atmospheric
mercury
worldwide.
Status
of
Federal
Register
Publications
°
Section
112(
n)
revision
was
published
in
the
Federal
Register
on
March
29,
2005
(
70
FR
15994)

°
CAMR
was
published
in
the
Federal
Register
on
May
18,
2005
(
70
FR
28606)

°
Section
112(
n)
revision
technical
correction
was
published
in
the
Federal
Register
on
June
7,
2005
(
70
FR
33000)

°
CAMR
technical
correction
was
published
in
the
Federal
Register
on
August
30,
2005
(
70
FR
51266)
Legal
Challenges
 
Section
112(
n)
Revision
Rule
°
State
of
NJ,
et
al.,
v.
EPA
(
03­
29­
05)

 
DC
Circuit
No.
05­
1097
°
10
Petitions
for
Judicial
Review
 
14
States
(
CA,
CT,
DE,
IL,
ME,
MA,
MN,

NH,
NJ,
NM,
NY,
PA,
VT,
and
WI)

 
10
Environmental
Groups
(
National
Wildlife
Federation,
Sierra
Club,

Environmental
Defense,
Chesapeake
Bay
Foundation,
Conservation
Law
Foundation,

Waterkeepers
Alliance,
Ohio
Environmental
Council,
Public
Interest
Research
Group,

Natural
Resources
Council
of
Maine,
and
NRDC)

 
Also
intervenors
on
both
sides
°
Petition
for
Judicial
Stay
 
Denied
August
4,
2005
Legal
Challenges
 
111
CAMR
°
State
of
NJ
et
al.
v.
EPA
(
05­
18­
05)

 
DC
Circuit
No.
05­
1162
°
15
Petitions
for
Review
 
14
States
and
1
City
(
CA,
CT,
DE,
IL,

ME,
MA,
MN,
NH,
NJ,
NM,
NY,
PA,
VT,

and
WI;
City
of
Baltimore)

 
9
Environmental
Groups
(
NWF,
Sierra
Club,
ED,
CBF,
WA,
OEC,
PIRG,

NRCM,
and
NRDC)

 
14
Industry
Groups
(
IWSA;
S.
MT
Elec.

Gen
&
Trans.
Coop.;
Amer.
Coal
for
Balanced
Hg
Reg;
Coal
Assoc.
of
AL,
KY,

MD,
OH,
PA,
VA,
and
WV;
ARIPPA;

UARG;
UMW;
and
Producers
of
Electric
Reliability)

 
Also
intervenors
on
both
sides
°
Petition
for
Judicial
Stay
 
No
request
to
date.
Administrative
Petitions
for
Review
 
Section
112(
n)
Revision
Rule
°
2
Petitions
for
Administrative
Review
 
Submitted
to
EPA
on
May
31,
2005
 
14
States
(
CA,
CT,
DE,
IL,
ME,
MA,
MN,

NH,
NJ,
NM,
NY,
PA,
VT,
and
WI)

 
5
Environmental
Groups
and
4
Native
American
Groups
°
NRDC,
CATF,
OEC,
PIRG,
and
NRCM
°
Aroostook
Band
of
Micmacs,
Houlton
Band
of
Maliseet
Indians,
Penobscot
Indian
Nation,
and
Passamaquoddy
Tribe
of
Maine
°
Petition
for
Administrative
Stay
°
EPA
Action
 
By
letter
dated
June
24,
2005:

°
Announced
plans
to
initiate
reconsideration
process
for
the
section
112(
n)
revision
rule;

and,

°
Stated
the
Agency
would
not
stay
the
rule
pending
completion
of
the
reconsideration
process.
Administrative
Petitions
for
Review
 
111
CAMR
°
4
Petitions
for
Review
 
Submitted
to
EPA
on
July
18,
2005
 
15
States
(
CA,
CT,
DE,
IL,
ME,
MA,

MN,
NH,
NJ,
NM,
NY,
PA,
RI,
VT,
and
WI)

 
5
Environmental
Groups
(
NRDC,

CATF,
OEC,
PIRG,
and
NRCM)

 
Integrated
Waste
Services
Association
(
IWSA)

 
Jamestown
Board
of
Public
Utilities
°
Petition
for
Administrative
Stay
°
EPA
Action
 
By
letter
dated
August
19,
2005:

°
Announced
plans
to
initiate
reconsideration
process
for
the
Section
111
CAMR;
and
°
Stated
the
Agency
would
not
stay
the
rule
pending
the
reconsideration
process.
Status
of
Reconsideration
Process
°
EPA
published
two
notices
announcing
issues
that
were
being
reconsidered
in
the
Federal
Register
on
October
28,
2005
 
70
FR
62200
for
the
section
112(
n)
revision
rule
reconsideration
 
70
FR
62213
for
the
CAMR
reconsideration)

°
A
public
hearing
was
held
on
November
17,

2005
°
Public
comments
due
December
19,
2005
 
Note:
the
EPA
e­
docket
system
has
been
superseded
by
the
Federal
Data
Management
System
(
FDMS)
which
is
accessible
through
www.
regulations.
gov
°
Expect
to
complete
the
reconsideration
process
by
late
Spring
2006
What
EPA
is
Reconsidering
°
Section
112(
n)
revision
notice
 
Legal
interpretations
 
EPA's
methodology
and
conclusions
concerning
why
utility
Hg
emissions
remaining
after
imposition
of
the
requirements
of
the
CAA
are
not
reasonably
anticipated
to
result
in
hazards
to
the
public
health
 
Detailed
discussion
of
certain
reconsideration
issues
as
set
forth
in
section
VI
of
the
final
section
112(
n)
revision
rule
 
EPA's
decision
related
to
nickel
(
Ni)
emissions
from
oil­
fired
utility
units
 
Documents
identified
by
petitioners
that
are
dated
after
the
close
of
the
public
comment
period
°
CAMR
 
2010
phase
I
statewide
Hg
emission
budgets
and
the
unit­
level
Hg
emission
allocations
on
which
those
budgets
are
based
 
Definition
of
"
designated
pollutant"
under
40
CFR
60.21
 
EPA's
subcategorization
for
subbituminous
coal­
fired
units
in
the
context
of
the
new
source
performance
standards
(
NSPS)

 
Statistical
analysis
used
for
the
NSPS
 
Hg
content
in
coal
used
to
derive
the
NSPS
 
Definition
of
covered
units
as
including
municipal
waste
combustors
(
MWC)

 
Definition
of
covered
units
as
including
some
industrial
boilers
To
Learn
More ..

Clean
Air
Mercury
Rule
www.
epa.
gov/
mercury
