4­
1
CHAPTER
4.
MERCURY
CONTROL
OPTIONS
This
chapter
provides
the
results
of
analysis
of
hypothetical
pollution
control
options
for
mercury
emissions
from
coal­
fired
electric
generation
units.
It
is
organized
into
two
sections.
These
sections
cover:
(
1)
hypothetical
controls
based
on
the
maximum
achievable
control
technology
(
MACT)
and
(
2)
hypothetical
controls
based
on
a
cap­
andtrade
approach.

The
options
presented
in
this
report
are
hypothetical
approaches
to
emission
controls
on
the
electric
power
industry
for
each
pollutant
and
do
not
represent
the
EPA
or
Administration
position
on
how
any
of
these
pollutants
should
be
reduced
in
the
future.
EPA
has
made
no
determinations
whether
or
how
much
additional
SO2
control
could
be
needed
to
address
fine
particulate
problems,
or
whether
and
to
what
extent
there
should
be
future
reductions
of
mercury
or
carbon
dioxide
emissions.
Specifically
with
regard
to
carbon
dioxide,
the
Administration
has
committed
not
to
implement
the
Kyoto
Protocol
without
the
advice
and
consent
of
the
Senate.

EPA
has
a
substantial
research
program
underway
to
investigate
mercury
emissions
reduction
technologies
for
coal­
fired
power
plants.
1
This
program
is
focusing
on
mercury
removal
rates,
capital
and
operating
costs,
operational
constraints,
and
reliability.
The
analysis
conducted
in
this
study
relies
on
the
best
available
cost
and
performance
data
that
exists
today
on
mercury
control
technology.
This
data
is,
however,
limited
and
preliminary.
(
See
Appendix
C
for
full
discussion
of
the
mercury
control
cost
and
performance
functions
used
in
this
study.)
This
limitation
should
be
kept
in
mind
while
reviewing
the
results
presented
below.

MERCURY
MACT
The
MACT
mercury
control
option
considered
in
this
report
is
for
electric
generation
units
greater
than
25
MW.
MACT
control
is
assumed
to
go
into
effect
in
2007
and
is
based
on
the
use
of
activated
carbon
injection
(
ACI)
technology
with
the
addition
of
spray
cooling
and
fabric
filters
in
certain
circumstances.

The
type
of
coal
used
by
a
coal­
fired
boiler
and
the
pre­
existing
pollution
controls
and
their
configuration
on
a
generation
unit
have
a
significant
effect
on
the
amount
of
mercury
reduction
that
ACI
can
achieve.
The
mercury
flue
gas
emissions
from
a
coalfired
boiler
used
in
electric
generation
could
be
reduced
between
65
percent
to
90
percent
depending
on
the
type
of
coal
a
unit
burns
and
the
existing
pollution
control
equipment
in
place.
Costs
of
control
also
vary
by
these
key
parameters.
Appendix
C
provides
the
mercury
removal
and
cost
assumptions
used
in
this
report
and
the
basis
for
them.

1
The
Electric
Power
Research
Institute
and
the
US
Department
of
Energy
also
have
significant
technology
research,
development
and
demonstration
programs
underway.
4­
2
For
this
analysis,
a
mercury
MACT
was
considered
to
be
imposed
on
coal­
fired
plants
for
the
Base
Case
and
on
top
of
two
of
the
pollution
control
options
that
were
examined
in
Chapter
3.
The
MACT
is
considered
as
an
incremental
action
above
these
three
alternative
"
baselines"
that
are
established
for
evaluating
the
incremental
annual
costs
of
the
MACT
above
each
assumed
baseline.
This
allowed
an
examination
of
the
difference
in
compliance
costs
for
mercury
controls
that
could
occur
when
the
electric
power
industry
also
faced
installation
of
other
types
of
pollution
control
in
the
future.
To
do
this,
the
analysis
subtracted
the
baseline
power
generation
costs
from
the
total
power
generation
costs
of
all
the
controls
to
isolate
the
incremental
annual
costs
that
were
strictly
attributable
to
the
MACT
controls.
The
baselines
are:

1.
Base
Case
2.
Baseline
1,
plus
SO2
Reduction
of
50
Percent
in
2010
3.
Baseline
2,
plus
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
option.

The
details
of
each
of
these
baselines
are
provided
in
Chapters
2
and
3.
The
results
of
this
analysis
are
presented
for
2010
(
when
all
of
the
hypothetical
control
actions
under
each
baseline
will
be
in
effect).

Air
Emissions
Changes
For
each
of
the
baselines,
EPA
compared
the
changes
in
SO2,
NOx,
carbon,
and
mercury
emissions
without
and
with
mercury
MACT
controls.
Exhibits
4­
1
through
4­
5
show
the
national
results
of
the
analysis
for
each
of
the
control
options
compared
to
the
baseline
emissions.
The
last
two
exhibits
in
this
series
show
mercury
emissions
for
all
sources
and
for
just
coal­
fired
units.

Exhibit
4­
5
shows
that
a
mercury
MACT
on
coal­
fired
electric
generation
units
could
lower
mercury
emissions
from
these
units
by
more
than
70
percent
across
all
the
baselines.
However,
since
each
baseline
has
a
different
level
of
mercury
emissions
before
MACT
controls
are
installed,
the
absolute
level
of
mercury
emissions
remaining
after
MACT
control
differs
by
option.
In
2010,
annual
mercury
emissions
from
coalfired
units
drop
from
about
47
tons
to
14
tons
for
the
Base
Case
with
mercury
MACT
controls.
In
2010,
for
the
third
baseline
(
which
adds
SO2
and
carbon
reductions),
adding
mercury
MACT
controls
lower
the
annual
mercury
emissions
from
about
31
tons
to
9
tons.

Exhibits
4­
1
through
4­
3
show
that
mercury
MACT
controls
like
the
hypothetical
ones
used
in
this
study
are
likely
to
have
little
effect
on
SO2,
NOx,
and
carbon
emissions.
This
is
unlike
what
Chapter
3
showed
for
many
of
hypothetical
control
options
for
SO2,
and/
or
carbon
emissions.
Those
SO2
and
carbon
reduction
options
often
led
to
more
substantial
changes
in
the
emissions
of
other
pollutants.

Exhibits
4­
6
through
4­
8
show
the
regional
emissions
for
each
air
pollutant
for
2010
for
mercury
MACT
controls
under
different
baselines.
The
amount
of
regional
4­
3
emissions
reduction
occurring
under
each
control
option
can
be
determined
by
comparing
these
results
to
the
Base
Case
regional
results
in
Chapter
2
(
see
Exhibits
2­
8
and
2­
9)
and
the
control
options
analysis
results
in
Chapter
3
(
see
Exhibits
3­
14
and
3­
15,
and
Exhibits
3­
51
and
3­
52).

Exhibit
4­
1
Annual
SO2
Emissions
for
the
Electric
Power
Industry
in
2010
for
Three
Baselines
without
and
with
a
Mercury
MACT
Mercury
(
1,000
tons)
Baselines
MACT
2010
Base
Case
(
with
NOx
SIP
Call)
No
9,658
Yes
9,740
50
%
SO2
Reduction
in
2010
No
4,939
Yes
4,856
50
%
SO2
Reduction
in
2010
/
High
No
4,549
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Yes
4,463
Exhibit
4­
2
Annual
and
Summer
NOx
Emissions
for
the
Electric
Power
Industry
in
2010
for
Three
Baselines
without
and
with
a
Mercury
MACT
Mercury
Annual
(
1,000
tons)

Baselines
MACT
2010
Base
Case
No
4,147
Yes
4,121
50
%
SO2
Reduction
in
2010
No
4,019
Yes
3,973
50
%
SO2
Reduction
in
2010
/
High
No
3,210
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Yes
3,206
Summer
(
1,000
tons)

Base
Case
No
1,386
Yes
1,379
50
%
SO2
Reduction
in
2010
No
1,353
Yes
1,342
50
%
SO2
Reduction
in
2010
/
High
No
1,131
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Yes
1,128
4­
4
Exhibit
4­
3
Annual
Carbon
Emissions
for
the
Electric
Power
Industry
in
2010
for
Alternative
Baselines
without
and
with
a
Mercury
MACT
Mercury
(
MMT)
Baselines
MACT
2010
Base
Case
No
621
Yes
617
50
%
SO2
Reduction
in
2010
No
610
Yes
605
50
%
SO2
Reduction
in
2010
/
High
No
515
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Yes
515
Exhibit
4­
4
Annual
Mercury
Emissions
for
All
Sources
in
the
Electric
Power
Industry
in
2010
for
Alternative
Baselines
without
and
with
a
Mercury
MACT
Mercury
(
tons)
Baselines
MACT
2010
Base
Case
No
50.9
Yes
17.6
50
%
SO2
Reduction
in
2010
No
44.5
Yes
15.1
50
%
SO2
Reduction
in
2010
/
High
No
34.8
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Yes
12.8
4­
5
Exhibit
4­
5
Annual
Mercury
Emissions
in
2010
for
the
Coal­
Fired
Units
of
the
Electric
Power
Industry
for
Alternative
Baselines
without
and
with
a
Mercury
MACT
2010
Baselines
Mercury
MACT
Tons
MACT
Reduction
Base
Case
No
46.9
Yes
13.6
71%

50
%
SO2
Reduction
in
2010
No
40.5
Yes
11.1
73%

50
%
SO2
Reduction
in
2010
/
High
No
30.8
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Yes
8.8
71%
4­
6
Exhibit
4­
6
Regional
Electric
Generation
and
Air
Emissions
in
2010
Base
Case
with
a
Mercury
MACT
Billion
kWh
NOx
(
1,000
tons)
SO2
(
1,000
tons)
Mercury
(
tons)
Carbon
(
MMT)

NERC
Region
Summer
Annual
Summer
Annual
Annual
Annual
Annual
MECS
40
92
27
92
274
0.4
16
ECAO
227
542
178
836
2,537
2.5
122
ERCT
136
284
123
250
484
1.2
44
MACE
50
100
16
56
130
0.7
10
MACW
41
98
28
125
460
0.8
18
MACS
27
65
15
66
211
0.4
10
WUMS
25
58
18
64
189
0.4
12
MANO
89
208
53
234
702
1.2
38
MAPP
77
173
149
344
573
1.1
38
UPNY
53
120
18
50
187
0.3
9
LILC
6
14
1
3
0
0.3
1
NENG
50
118
16
44
133
1.0
12
FRCC
98
198
118
239
318
1.1
30
VACA
136
321
70
284
938
1.2
46
TVA
68
159
43
197
452
0.6
27
SOU
108
243
86
276
1,041
1.1
43
SPPN
42
95
54
157
177
0.4
21
SPPS
121
240
142
279
463
1.1
41
CNV
124
283
31
73
50
1.0
22
WSCP
73
173
16
38
124
0.2
7
WSCR
107
249
177
415
297
0.6
51
TOTAL
1,699
3,832
1,379
4,121
9,740
17.6
617
4­
7
Exhibit
4­
7
Regional
Electric
Generation
and
Air
Emissions
in
2010
50%
SO2
Reduction
in
2010
with
a
Mercury
MACT
Billion
kWh
NOx
(
1,000
tons)
SO2
(
1,000
tons)
Mercury
(
tons)
Carbon
(
MMT)

NERC
Region
Summer
Annual
Summer
Annual
Annual
Annual
Annual
MECS
40
92
26
90
259
0.3
16
ECAO
225
533
183
824
1,081
2.0
120
ERCT
136
283
119
231
260
0.9
42
MACE
51
104
16
57
66
0.7
11
MACW
41
98
29
125
90
0.6
18
MACS
26
64
15
66
53
0.4
9
WUMS
25
57
18
61
181
0.4
12
MANO
88
203
52
225
274
1.0
37
MAPP
76
172
147
342
392
0.9
38
UPNY
54
121
18
50
97
0.2
9
LILC
6
15
1
3
0
0.3
1
NENG
49
117
16
43
49
1.0
11
FRCC
98
203
99
207
117
1.1
29
VACA
136
318
68
275
403
1.0
45
TVA
69
159
41
180
353
0.5
25
SOU
107
236
85
261
341
0.7
40
SPPN
44
101
53
154
154
0.4
21
SPPS
122
249
131
252
320
0.9
40
CNV
124
283
31
73
50
1.0
22
WSCP
73
173
16
38
22
0.1
7
WSCR
107
249
177
415
293
0.6
51
TOTAL
1,699
3,830
1,342
3,973
4,856
15.1
605
4­
8
Exhibit
4­
8
Regional
Electric
Generation
and
Air
Emissions
in
2010
50%
SO2
Reduction
in
2010
/
High
Efficiency
­
Carbon
Level
of
515
MMT
in
2008
with
a
Mercury
MACT
Billion
kWh
NOx
(
1,000
tons)
SO2
(
1,000
tons)
Mercury
(
tons)
Carbon
(
MMT)

NERC
Region
Summer
Annual
Summer
Annual
Annual
Annual
Annual
MECS
37
84
28
87
248
0.3
15
ECAO
212
501
193
791
1,129
1.9
112
ERCT
126
264
77
128
151
0.5
31
MACE
46
95
16
53
69
0.7
9
MACW
38
89
27
110
87
0.5
15
MACS
28
70
14
60
44
0.3
10
WUMS
24
55
20
58
167
0.4
11
MANO
77
175
48
182
326
0.9
29
MAPP
69
157
102
236
301
0.7
30
UPNY
52
114
16
37
50
0.1
7
LILC
7
15
1
3
0
0.3
1
NENG
46
111
15
39
65
0.9
10
FRCC
95
201
71
141
107
1.0
26
VACA
124
290
66
241
400
0.9
38
TVA
68
157
38
148
253
0.4
22
SOU
94
197
73
185
446
0.6
30
SPPN
43
95
45
106
96
0.3
17
SPPS
121
258
79
132
210
0.6
31
CNV
117
266
31
72
50
1.0
20
WSCP
71
168
16
38
22
0.1
7
WSCR
97
224
152
359
241
0.6
44
TOTAL
1,591
3,585
1,128
3,206
4,463
12.8
515
4­
9
Costs
and
System
Changes
The
electric
generation
system
will
make
adjustments
to
meet
electric
demand
and
comply
with
the
pollution
control
requirements
of
a
mercury
MACT
on
coal­
fired
units.
Exhibit
4­
9
shows
the
annual
incremental
costs
of
electricity
generation
from
each
of
the
three
baselines
used
in
the
analysis
for
power
companies
installing
controls
and
making
other
changes
to
comply
with
the
alternatives.
Again,
these
cost
estimates
for
a
mercury
MACT
on
coal­
fired
generation
units
are
based
on
a
preliminary
analysis
of
the
costs
and
performance
of
ACI
technology.
(
See
Appendix
C
for
details
on
the
cost
and
performance
functions
of
ACI
technology).

Exhibit
4­
9
Preliminary
Estimate
of
the
Annual
Mercury
Control
Costs
for
the
Electric
Power
Industry
in
2010
for
a
Mercury
MACT
under
Alternative
Baselines
(
Million
1990$)
Baselines
2010
Base
Case
$
1,874
50
%
SO2
Reduction
in
2010
$
1,794
50
%
SO2
Reduction
in
2010
/
High
Efficiency­
Carbon
Level
of
515
MMT
in
2008*
$
1,496
*
Costs
include
the
additional
resources
that
are
expended
to
produce
electric
power,
if
the
industry
is
lowering
carbon
emissions
to
the
levels
specified
in
each
option.
It
does
not
include
purchasing
of
carbon
allowances
in
an
international
trading
program.
A
discussion
of
allowance
purchase
costs
occurs
in
reference
9
in
Chapter
3.

Another
useful
way
to
consider
the
costs
of
MACT
standards
to
control
mercury
emissions
from
coal­
fired
generation
units,
is
to
consider
what
they
could
be
in
conjunction
with
other
hypothetical
control
options,
as
EPA
did
for
other
pollutants
in
Chapter
3.
Exhibit
4­
10
provides
estimates
of
the
annual
incremental
production
costs
for
hypothetical
combination
options
for
(
1)
50
Percent
SO2
Reduction
in
2010
and
a
MACT
for
mercury
emissions
and
(
2)
the
combination
of
Option
1
plus
High­
Efficiency/
Carbon
Level
of
515
MMT
in
2008.
The
Base
Case
is
the
basis
for
measuring
incremental
compliance
costs.
4­
10
Exhibit
4­
10
Annual
Costs
for
the
Electric
Power
Industry
in
2010
for
Combination
Options
Covering
Mercury,
SO2
and
Carbon
Emissions
(
Million
1990$)
Mercury
MACT
plus:
2010
50
%
SO2
Reduction
in
2010
$
4,245
50
%
SO2
Reduction
in
2010
/
High
$
5,125
Efficiency­
Carbon
Level
of
515
MMT
in
2008*

*
Costs
include
the
additional
resources
that
are
expended
to
produce
electric
power,
if
the
industry
is
lowering
carbon
emissions
to
the
levels
specified
in
each
option.
It
does
not
include
purchasing
of
carbon
allowances
in
an
international
trading
program.
A
discussion
of
allowance
purchase
costs
occurs
in
reference
9
in
Chapter
3.

Exhibit
4­
10
does
not
show
for
the
High
Efficiency
 
Carbon
Level
at
515
MMT
in
2008
option
the
costs
of
the
electric
demand
reduction
program
and
its
savings.
This
information
is
provided
in
Exhibit
4­
11,
which
shows
the
increased
electric
generation
production
costs,
demand
reduction
program
costs
and
savings,
and
the
net
costs
that
occur
for
this
option.
Again,
the
exhibit
does
not
include
the
potential
cost
to
the
power
industry
of
purchasing
carbon
allowances.

Exhibit
4­
11
Annual
Costs
in
2010
for
the
Electric
Power
Industry
and
Power
Users
in
the
Mercury
MACT,
50
Percent
SO2
Reduction,
and
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
Case
Cost
Categories
Million
1990$

Increased
Production
Costs*
$
5,125
Investment
in
Energy
Reduction
$
4,986
Savings
from
Energy
Reduction
$
7,864
Net
Costs
of
Combined
Controls*
$
2,247
*
Costs
include
the
additional
resources
that
are
expended
to
produce
electric
power,
if
the
industry
is
lowering
carbon
emissions
to
the
levels
specified
in
the
option.
It
does
not
include
purchasing
of
carbon
allowances
in
an
international
trading
program.
A
discussion
of
allowance
purchase
costs
occurs
in
reference
9
in
Chapter
3.

By
2010,
the
mercury
MACT
appears
to
have
a
modest
influence
in
shifting
electric
generation
towards
gas­
fired
units
from
coal­
fired
units.
Exhibit
4­
12
shows
that
there
is
little
difference
in
the
installation
of
scrubbers
without
and
with
a
mercury
MACT
when
there
is
a
program
to
lower
SO2
emissions
by
50
percent
by
2010.
Exhibit
4­
13
shows
that
the
mercury
MACT
does
not
in
itself
lead
to
that
much
of
a
change
in
the
installation
of
combined­
cycle
natural
gas
capacity.
Exhibit
4­
14
shows
that
there
is
a
similar
amount
of
coal­
and
gas­
fired
capacity
between
the
two
types
of
cases
as
well
as
electric
generation.
4­
11
Exhibit
4­
12
Cumulative
Installation
of
New
Scrubber
Capacity
at
Coal­
Fired
Units
For
50%
Reduction
in
SO2
in
2010
without
and
with
a
Mercury
MACT
Mercury
(
GW)
Baseline
MACT
2010
50
%
SO2
Reduction
in
2010
No
82
Yes
81
Exhibit
4­
13
Natural
Gas
Combined­
Cycle
Capacity
in
2010
for
Alternative
Baselines
with
a
Mercury
MACT
Mercury
(
GW)
Baselines
MACT
2010
Base
Case
No
112
Yes
112
50
%
SO2
Reduction
in
2010
No
118
Yes
120
50
%
SO2
Reduction
in
2010
/
High
No
139
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Yes
139
Note:
These
estimates
include
both
new
combined­
cycle
and
repowered
units
to
combined­
cycle.
4­
12
Exhibit
4­
14
Electric
Generation
Capacity
and
Production
in
2010
for
Units
Using
Fossil
Fuels
for
Alternative
Baselines
with
a
Mercury
MACT
Fuel
Type
Mercury
MACT
Capacity
by
Fuel
Type
(
GW)
Generation
by
Fuel
Type
(
Billion
kWh)
2010
2010
Base
Case
Coal
No
304
2,114
Yes
304
2,099
Oil/
Natural
Gas
No
282
759
Yes
282
774
50%
SO2
Reduction
in
2010
Coal
No
301
2,038
Yes
301
2,017
Oil/
Natural
Gas
No
285
835
Yes
286
855
50%
SO2
Reduction
in
2010
/
High
Efficiency
Carbon
Level
of
515
MMT
in
2008
Coal
No
280
1,657
Yes
279
1,656
Oil/
Natural
Gas
No
260
972
Yes
261
973
Note:
Coal­
fired
units
are
assumed
to
lose
about
2
percent
of
their
capacity
when
they
install
scrubbers.
See
Exhibit
4­
12
to
assess
the
impact
of
scrubber
installation
on
capacity
in
the
50
percent
SO2
reduction
in
2010
option
over
time.
4­
13
Fossil
Fuel
Use
Exhibits
4­
15
through
4­
17
show
forecasted
coal
consumption
that
would
result
for
each
the
mercury
MACT
under
each
of
the
baselines.
Comparing
these
forecasts
to
the
results
for
the
baselines
that
appear
in
Chapters
2
and
3
shows
limited
reductions
in
coal
use.
Exhibit
4­
18
shows
natural
gas
and
oil
use
by
the
power
industry.
The
table
shows
there
is
a
small
increase
in
natural
gas
use
with
a
mercury
MACT
relative
to
the
baselines.

Exhibit
4­
15
Coal
Consumption
in
the
Electric
Power
Industry
in
2010
by
the
Major
Supply
Regions
for
the
Base
Case
with
a
Mercury
MACT
(
million
tons)
Coal
Supply
Areas
2010
Northern
Appalachia
111
Central
and
Southern
Appalachia
216
Midwest
127
West
499
Central
West
and
Gulf
58
Total
1,011
Exhibit
4­
16
Coal
Consumption
in
the
Electric
Power
Industry
in
2010
by
the
Major
Supply
Regions
for
the
50%
Reduction
in
SO2
Case
with
a
Mercury
MACT
(
million
tons)
Coal
Supply
Areas
2010
Northern
Appalachia
142
Central
and
Southern
Appalachia
169
Midwest
133
West
482
Central
West
and
Gulf
47
Total
974
4­
14
Exhibit
4­
17
Coal
Consumption
in
the
Electric
Power
Industry
in
2010
by
the
Major
Supply
Regions
for
the
50
Percent
SO2
Reduction
and
High
Efficiency
­
Carbon
Level
at
515
MMT
Case
with
a
Mercury
MACT
(
million
tons)
Coal
Supply
Areas
2010
Northern
Appalachia
121
Central
and
Southern
Appalachia
141
Midwest
116
West
375
Central
West
and
Gulf
22
Total
776
Exhibit
4­
18
Natural
Gas
and
Oil
Consumption
in
the
Electric
Power
Industry
in
2010
under
Alternative
Baselines
with
a
Mercury
MACT
Fuel
Type
Units
2010
Base
Case
Natural
Gas
Trillion
cubic
feet
5.4
Oil
Million
Barrels
0.0
50%
SO2
Reduction
in
2010
Natural
Gas
Trillion
cubic
feet
5.9
Oil
Million
Barrels
0.0
50%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
Natural
Gas
Trillion
cubic
feet
6.4
Oil
Million
Barrels
0.0
4­
15
MERCURY
CAP­
AND­
TRADE
This
report
also
examined
lowering
mercury
emissions
from
coal­
fired
generation
units
greater
than
25
MW
through
a
cap­
and­
trade
option
that
would
begin
in
2007.
The
hypothetical
mercury
emissions
cap
was
set
for
coal­
fired
units
to
achieve
the
same
level
of
emissions
reduction
nationwide
that
the
mercury
MACT
achieved
from
2007
to
2025
under
each
of
the
three
baselines
that
were
used
in
the
MACT
analysis.
This
was
done
to
make
the
national
emissions
reduction
objective
comparable
for
each
alternative.
During
the
year,
coal­
fired
generation
units
could
trade
with
each
other
anywhere
in
the
contiguous
US
the
mercury
emissions
allowances
that
they
had
received
for
their
mercury
emissions
in
that
year.
Banking
of
emissions
allowances
was
not
allowed.
Again,
this
was
done
as
part
of
an
effort
to
make
the
MACT
and
cap­
and­
trade
options
as
comparable
as
possible
in
what
they
would
achieve
in
terms
of
overall
emissions
reduction
in
2010,
the
year
in
which
this
report
is
providing
results.

The
same
mercury
control
cost
and
removal
assumptions
for
ACI
were
used
here
as
in
the
MACT
analysis.
However,
under
a
cap­
and­
trade
system
power
companies
are
likely
to
have
additional
compliance
options
beyond
ACI
controls
that
are
examined
in
IPM.
They
include:

 
changing
the
dispatch
of
generation
units,
 
adding
new
gas­
fired
units
to
pick
up
a
larger
share
of
the
power
load,
 
converting
units
over
to
natural
gas,
or
more
efficient
use
of
coal
through
integrated
gas
combined
cycle
(
IGCC),
 
switching
to
coals
with
lower
mercury
concentrations
per
energy
content,
or
 
changing
to
coals
where
ACI
is
more
effective
at
removing
mercury
(
generally,
ACI
is
assumed
in
the
cost
analysis
to
be
more
effective
at
removing
mercury
from
bituminous
coals
over
other
coal
grades).

In
the
future,
power
companies
may
consider
more
coal
cleaning
with
current
methods
and
application
of
advanced
coal­
cleaning
techniques.
2
EPA
was
unable
to
gather
sufficient
cost
and
performance
information
on
coal
cleaning
for
use
in
this
analysis.
The
Department
of
Energy
(
DOE)
is
currently
implementing
a
significant
research
program
in
this
area.

The
power
industry
may
also
have
additional
types
of
controls
in
the
future
that
are
commercially
available
for
lowering
mercury,
or
the
ability
to
remove
both
mercury
and
SO2,
such
as
dry
scrubber
pollution
control
units
that
this
study
could
not
consider.
3
2
Akers,
David
J.
and
Clifford
E.
Raleigh,
Jr.
(
CQ
Inc.)
and
Barbara
Toole­
Oneil
(
Electric
Power
Research
Institute),
"
The
Use
of
Coal
Cleaning
for
Trace
Element
Removal,"
EPRI
Mega­
Conference
Paper,
August
1997.
3
Other
potential
future
mercury
pollution
control
technologies
include
impregnated
activated
carbon,
sodium
sulfide
injection,
activated
carbon
fluidized
bed,
noble
metal
sorption,
sorbent
injection
alone
and
with
humidification
that
directly
aimed
at
mercury
control
and
spray
dryer
FGD
and
dry
scrubbers
that
remove
both
mercury
and
SO2.
See
U.
S.
Environmental
Protection
Agency,
Mercury
Study
Report
to
Congress
Volume
VIII:
An
Evaluation
of
Mercury
Control
Technologies
and
Costs,
December
1997.
4­
16
It
is
also
possible
that
there
could
be
improved
versions
of
the
sorbent
injection
technology
that
ACI
is
based
on,
where
less
costly
sorbents
are
used
for
certain
coalburning
situations.
4
There
have
been
several
workshops
and
conferences
over
the
last
year
that
have
identified
areas
of
promising
technological
research
into
mercury
controls
and
EPA,
DOE,
and
EPRI
are
planning
more
work
in
the
future.
5
Notably,
EPA
and
eastern
States
have
found
that
in
the
four
years
that
they
have
taken
to
develop
the
program
that
became
the
NOx
SIP
call,
vendors
developed
two
additional
economically
viable
NOx
control
technologies
which
were
not
commercially
available
four
year
ago.
6
There
is
considerable
variation
in
individual
shipments
from
coalmines,
but
regionally
there
appear
to
be
clear
differences
in
average
mercury
concentrations.
7
8
9
10
Power
companies
should
be
able
to
find
coals
coming
from
different
supply
areas
that
will,
on
average
vary
in
their
mercury
content
over
time.
11
12
13
For
the
purposes
of
this
study,
it
was
assumed
that
coal
suppliers
would
be
able
to
work
with
the
electric
power
industry
in
the
future
to
create
an
administratively
practical
and
reliable
way
to
provide
companies
coals
annually
with
different
levels
of
mercury
concentrations
"
on
average."
It
was
also
assumed
that
the
constraints
that
IPM
places
on
coal­
fired
generation
units
to
select
only
coals
that
States
have
allowed
them
to
use
in
the
past
(
as
part
of
CAAA
SIP
requirements)
will
ensure
that
switching
among
these
allowed
types
of
coal
will
not
lead
to
other
types
of
emissions
concerns
at
coal­
fired
units.

As
explained
in
Appendix
A,
EPA
used
a
cluster
analysis
to
develop
average
coal
concentrations
for
various
coal
supply
regions
in
the
country.
It
provides
a
reasonable
approximation
of
average
mercury
concentrations
for
the
purpose
that
it
is
used
here
 
to
illustrate
the
value
of
a
cap­
and­
trade
program
for
mercury
emissions
that
would
4
See
reference
it
2.
Research
discussion
on
this
topic
occurred
at
EPA
Workshop
on
Control
of
Mercury
Emissions
from
Combustion
Sources,
October
1998.
5
Workshops
and
conferences
include
EPA
Workshop
on
Control
of
Mercury
Emissions
from
Combustion
Sources,
October
1998,
CEC­
NESCAUM
Mercury
Workshop,
"
A
Critical
Evaluation
of
Existing
and
Emerging
Mercury
Control
Technologies
for
Electric
Utilities,"
Washington,
D.
C.
November
1998,
and
Conference
on
Air
Quality,
Mercury,
Trace
Elements,
and
Particulate
Matter,
Energy,
&
Environmental
Research
Center,
McLean,
VA,
December
1998.
6
Vendors
are
now
installing
and
selling
two
types
of
hybrid
systems
that
combine
selective
catalytic
reduction
and
selective
noncatalytic
reduction
(
SNCR)
technologies
and
combine
gas
reburn
and
SNCR.
7
U.
S.
Environmental
Protection
Agency,
Study
of
Hazardous
Air
Pollutant
Emissions
from
Electric
Utility
Steam
Generating
Units
 
Final
Report
to
Congress.
Volumes
I
and
II,
February
1998.
8
Finkelman,
Robert
B.
(
U.
S.
Geological
Survey),
"
Mercury
in
Coal
and
Mercury
Emissions
from
Coal
Combustion,"
paper
delivered
by
USGS,
at
EPA
Workshop
on
Control
of
Mercury
Emissions
from
Combustion
Sources,
October
1998.
9
Electric
Power
Research
Institute,
U.
S.
Geological
Survey,
and
CQ,
Inc.,
"
Mercury
concentration
in
coal
 
unraveling
the
puzzle,
paper
in
press
January
1998.
10
Lengyel
Jr,
John,
and
Matthew
S.
Devito
and
Richard
A.
Bolonick
(
CONSOL,
Inc.),
"
Interlaboratory
and
Intralaboratory
Variability
in
the
Analysis
of
Mercury
in
Coal,"
technical
paper,
Journal
of
the
Air
&
Waste
Management
Association,
April
1996.
11
See
references
7,
8,
9,
and
10
above.
12
Personal
communication
with
Matthew
S.
Devito,
CONSOL,
Inc.,
October
1998
at
EPA
Workshop
on
Control
of
Mercury
Emissions
from
Combustion
Sources.
13
Personal
communication
with
Curtis
Palmer
,
U.
S.
Geological
Survey,
October
1998,
at
EPA
Workshop
on
Control
of
Mercury
Emissions
from
Combustion
Sources.
4­
17
encourage
switching
to
lower
mercury
coal
supplies.
The
administrative
costs
of
this
were
not
factored
into
the
analysis.

In
considering
a
mercury
cap­
and­
trade
option,
the
primary
interest
was
to
contrast
it
to
the
MACT
requirements
analyzed
in
the
preceding
section.
Comparisons
of
the
MACT
and
cap­
and­
trade
results
for
2010
are
provided
below.

Air
Emissions
Changes
For
each
of
the
pollution
control
baselines,
this
study
compares
the
changes
in
SO2,
NOx,
carbon,
and
mercury
emissions
that
would
occur
under
a
hypothetical
MACT
control
and
a
hypothetical
cap­
and­
trade
option.
Exhibits
4­
19
through
4­
23
show
the
national
emissions
results
of
the
analysis.
The
last
two
exhibits
in
this
series
show
mercury
emissions
for
all
sources
and
for
coal­
fired
generation
units
only.
Because
the
cap­
and­
trade
options
were
keyed
to
the
MACT
results
of
mercury
emissions,
the
results
in
Exhibit
4­
23
are
the
same
for
both
options.
Exhibits
4­
24
through
4­
26
show
the
regional
emissions
for
each
air
pollutant
for
2010.
The
amount
of
regional
emissions
reduction
occurring
under
each
control
option
can
be
determined
by
comparing
these
results
to
the
Base
Case
regional
results
in
Chapter
2
(
see
Exhibit
2­
9)
and
to
the
other
baselines
that
use
hypothetical
options
in
Chapter
3
(
see
Exhibits
3­
12
and
3­
52).

Exhibit
4­
27
highlights
the
mercury
emissions
levels
in
2010
in
each
region
in
IPM
for
the
baseline,
mercury
MACT,
and
cap­
and­
trade
options.
At
the
regional
level
there
is
little
difference
between
the
cap­
and­
trade
approach
and
the
MACT
option.
This
suggests
that
a
cap­
and­
trade
approach
for
controlling
mercury
emissions
may
be
effective
in
providing
an
even
level
of
reduction
throughout
the
country.
This
is
important
to
any
effort
to
ensure
that
a
trading
program
does
not
inequitably
affect
communities
near
power
plants.
A
more
detailed
look
at
this
type
of
result
at
the
power
plant,
or
county
level
in
the
future
could
potentially
be
useful.

Further
investigation
is
needed
as
to
whether
it
is
necessary
in
certain
areas
of
the
country
to
have
additional
mercury
reductions
occur
from
electric
generation
units,
because
of
the
high
levels
of
existing
mercury
contamination
in
surface
waters.
Also,
the
results
in
Exhibit
4­
27
occur
when
there
is
a
limited
number
of
pollution
options
available
for
coal­
fired
generation
units
to
use
and
assumed
limited
economies
of
scale
for
mercury
control.
These
factors
would
be
important
to
decisions
by
the
power
industry
on
which
generation
units
should
control
mercury,
and
which
should
not
and
buy
emissions
allowances
from
other
units
under
a
cap­
and­
trade
program.
4­
18
Exhibit
4­
19
Annual
SO2
Emissions
in
the
Electric
Power
Industry
in
2010
by
Mercury
MACT
and
Cap­
and­
Trade
Options
Annual
(
1,000
tons)
Baselines
MACT
Cap­
and­
Trade
Base
Case
9,740
9,826
50%
SO2
Reduction
in
2010
4,856
4,766
50%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
4,463
4,774
Exhibit
4­
20
Annual
and
Summer
NOx
Emissions
in
the
Electric
Power
Industry
in
2010
by
Mercury
MACT
and
Cap­
and­
Trade
Options
Annual
(
1,000
tons)
Baselines
MACT
Cap­
and­
Trade
Base
Case
4,121
4,067
50
%
SO2
Reduction
in
2010
3,973
3,943
50
%
SO2
Reduction
in
2010
/
High
3,206
3,259
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Summer
(
1,000
tons)

Base
Case
1,379
1,368
50
%
SO2
Reduction
in
2010
1,342
1,328
50
%
SO2
Reduction
in
2010
/
High
1,128
1,134
Efficiency­
Carbon
Level
of
515
MMT
in
2008
Exhibit
4­
21
Annual
Carbon
Emissions
in
the
Electric
Power
Industry
in
2010
by
the
Electric
Power
Industry
for
Mercury
MACT
and
Cap­
and­
Trade
Options
(
MMT)
Baselines
MACT
Cap­
and­
Trade
Base
Case
617
612
50%
SO2
Reduction
in
2010
605
603
50%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
515
518
4­
19
Exhibit
4­
22
Annual
Mercury
Emissions
for
All
Sources
in
2010
for
the
Electric
Power
Industry
by
Mercury
MACT
and
Cap­
and­
Trade
Options
Tons
Baselines
MACT
Cap­
and­
Trade
Base
Case
17.6
17.5
50%
SO2
Reduction
in
2010
15.1
15.1
50%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
12.8
12.8
Exhibit
4­
23
Annual
Mercury
Emissions
in
2010
by
the
Coal­
Fired
Generation
Units
of
the
Electric
Power
Industry
for
Mercury
MACT
and
Cap­
and­
Trade
Options
under
Alternative
Baselines
Tons
Baselines
MACT
Cap­
and­
Trade
Base
Case
13.6
13.6
50%
SO2
Reduction
in
2010
11.1
11.1
50%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
8.8
8.8
4­
20
Exhibit
4­
24
Regional
Electric
Generation
and
Air
Emissions
in
2010
Base
Case
with
Mercury
Cap­
and­
Trade
Billion
kWh
NOx
(
1,000
tons)
SO2
(
1,000
tons)
Mercury
(
tons)
Carbon
(
MMT)

NERC
Region
Summer
Annual
Summer
Annual
Annual
Annual
Annual
MECS
40
92
27
92
268
0.4
16
ECAO
227
542
179
838
2,660
2.5
122
ERCT
136
284
121
234
418
1.0
42
MACE
51
103
17
57
129
0.7
11
MACW
41
98
28
125
463
0.8
18
MACS
26
62
15
66
216
0.3
9
WUMS
25
58
18
63
187
0.5
12
MANO
88
206
53
229
749
1.2
37
MAPP
76
169
146
332
539
1.1
37
UPNY
53
121
18
50
220
0.2
9
LILC
6
13
1
3
0
0.3
1
NENG
49
118
16
44
123
1.0
12
FRCC
98
199
113
229
305
1.1
30
VACA
136
320
69
282
905
1.2
46
TVA
68
158
42
191
482
0.6
26
SOU
108
242
86
274
1066
1.1
42
SPPN
44
98
54
159
176
0.5
21
SPPS
121
242
140
271
449
1.0
41
CNV
121
274
31
73
50
1.0
21
WSCP
77
181
17
39
124
0.2
8
WSCR
108
249
177
416
300
0.8
51
TOTAL
1,699
3,830
1,368
4,067
9,826
17.5
612
4­
21
Exhibit
4­
25
Regional
Electric
Generation
and
Air
Emissions
in
2010
50%
SO2
Reduction
in
2010
with
Mercury
Cap­
and­
Trade
Billion
kWh
NOx
(
1,000
tons)
SO2
(
1,000
tons)
Mercury
(
tons)
Carbon
(
MMT)

NERC
Region
Summer
Annual
Summer
Annual
Annual
Annual
Annual
MECS
40
92
28
92
188
0.4
16
ECAO
226
533
184
827
1,087
2.0
121
ERCT
135
283
118
229
259
0.9
41
MACE
50
103
16
57
66
0.7
11
MACW
41
98
29
125
93
0.6
18
MACS
26
64
15
67
58
0.3
10
WUMS
26
58
19
63
91
0.2
12
MANO
86
194
49
208
323
0.9
34
MAPP
78
175
146
339
379
0.9
38
UPNY
54
121
18
50
96
0.2
9
LILC
6
14
1
3
0
0.3
1
NENG
49
117
16
43
49
0.9
11
FRCC
99
205
92
201
118
1.1
30
VACA
136
319
69
275
388
1.0
45
TVA
70
163
40
182
353
0.6
25
SOU
106
235
82
254
297
0.7
40
SPPN
44
101
53
153
157
0.5
21
SPPS
121
250
129
248
402
1.0
40
CNV
121
274
31
73
50
1.0
21
WSCP
76
181
17
39
22
0.1
8
WSCR
108
249
177
416
290
0.7
51
TOTAL
1,699
3,829
1,328
3,943
4,766
15.1
603
4­
22
Exhibit
4­
26
Regional
Electric
Generation
and
Air
Emissions
in
2010
50%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
with
Mercury
Cap­
and­
Trade
Billion
kWh
NOx
(
1,000
tons)
SO2
(
1,000
tons)
Mercury
(
tons)
Carbon
(
MMT)

NERC
Region
Summer
Annual
Summer
Annual
Annual
Annual
Annual
MECS
37
84
29
89
235
0.4
15
ECAO
214
502
192
789
1,126
1.8
112
ERCT
127
266
73
120
136
0.4
30
MACE
43
90
16
52
68
0.7
9
MACW
40
94
30
118
118
0.6
17
MACS
28
70
16
66
60
0.3
10
WUMS
24
55
19
58
167
0.4
11
MANO
74
165
42
159
240
0.6
26
MAPP
70
160
101
231
277
0.6
30
UPNY
51
113
17
44
74
0.1
8
LILC
7
15
1
3
0
0.3
1
NENG
45
110
14
39
93
0.9
10
FRCC
94
201
77
187
247
1.1
28
VACA
125
291
69
252
560
1.0
40
TVA
70
162
35
141
247
0.3
22
SOU
95
198
76
190
507
0.6
30
SPPN
42
96
42
104
90
0.3
17
SPPS
120
258
72
119
187
0.5
30
CNV
112
253
31
72
50
1.0
19
WSCP
72
169
16
38
22
0.1
7
WSCR
103
237
164
388
269
0.7
48
TOTAL
1,591
3,586
1,134
3,259
4,774
12.8
518
4­
23
Exhibit
4­
27
Comparison
of
Mercury
Emissions
for
Baseline,
Mercury
MACT
and
Mercury
Cap­
and­
Trade
Options
in
2010
(
tons)

Base
Case
50%
SO2
Reduction
in
2010
50%
SO2
Reduction
in
2010
/
High
Efficiency
­
Carbon
Level
of
515
MMT
in
2008
Region
Baseline
MACT
Cap­
and­
Trade
Baseline
MACT
Cap­
and­
Trade
Baseline
MACT
Cap­
and­
Trade
MECS
1.1
0.4
0.4
1.0
0.3
0.4
0.7
0.3
0.4
ECAO
8.4
2.5
2.5
7.3
2.0
2.0
6.7
1.9
1.8
ERCT
4.3
1.2
1.0
3.7
0.9
0.9
1.7
0.5
0.4
MACE
1.2
0.7
0.7
1.3
0.7
0.7
1.2
0.7
0.7
MACW
2.5
0.8
0.8
2.1
0.6
0.6
1.8
0.5
0.6
MACS
1.1
0.4
0.3
1.0
0.4
0.3
0.6
0.3
0.3
WUMS
1.0
0.4
0.5
1.0
0.4
0.2
0.8
0.4
0.4
MANO
4.5
1.2
1.2
3.3
1.0
0.9
2.8
0.9
0.6
MAPP
3.7
1.1
1.1
3.5
0.9
0.9
2.3
0.7
0.6
UPNY
1.1
0.3
0.2
0.7
0.2
0.2
0.5
0.1
0.1
LILC
0.3
0.3
0.3
0.3
0.3
0.3
0.3
0.3
0.3
NENG
1.5
1.0
1.0
1.3
1.0
0.9
1.3
0.9
0.9
FRCC
2.0
1.1
1.1
1.9
1.1
1.1
1.7
1.0
1.1
VACA
3.7
1.2
1.2
3.1
1.0
1.0
2.7
0.9
1.0
TVA
2.2
0.6
0.6
1.9
0.5
0.6
1.4
0.4
0.3
SOU
4.0
1.1
1.1
3.0
0.7
0.7
2.2
0.6
0.6
SPPN
1.4
0.4
0.5
1.3
0.4
0.5
0.8
0.3
0.3
SPPS
2.7
1.1
1.0
2.4
0.9
1.0
1.2
0.6
0.5
CNV
1.2
1.0
1.0
1.2
1.0
1.0
1.2
1.0
1.0
WSCP
0.4
0.2
0.2
0.3
0.1
0.1
0.3
0.1
0.1
WSCR
2.7
0.6
0.8
2.7
0.6
0.7
2.5
0.6
0.7
TOTAL
50.8
17.6
17.5
44.5
15.1
15.1
34.8
12.8
12.8
4­
24
Costs
and
System
Changes
The
electric
generation
system
will
make
adjustments
to
meet
electric
demand
and
comply
with
the
pollution
control
requirements
under
a
cap­
and­
trade
approach
for
lowering
mercury
emissions
from
coal­
fired
generation
units.
Exhibit
4­
28
shows
a
comparison
of
the
incremental
annual
production
costs
of
mercury
cap­
and­
trade
and
MACT
options
for
the
three
baselines.
Exhibits
4­
29,
4­
30,
and
4­
31
show
the
differences
in
scrubber
installation,
natural
gas
combined­
cycle
capacity,
coal
and
natural
gas
generation
capacity,
and
coal
and
natural
gas
electric
generation.

The
cap­
and­
trade
approach
has
its
greatest
value
in
lowering
costs
under
the
baseline
of
50%
SO2
Reduction
in
2010
/
High
Efficiency
­
Carbon
Level
of
515
MMT
in
2008.
Here
the
mercury
cap­
and­
trade
option
is
23
percent
less
expensive
than
the
MACT
option.
Under
the
50%
SO2
Reduction
in
2010
baseline,
the
cap­
and­
trade
approach
is
6
percent
less
expensive.
Under
the
Base
Case,
the
cap­
and­
trade
option
is
10
percent
less
expensive.
In
the
past,
analysis
of
controls
on
other
pollutants
from
the
power
industry,
such
as
NOx,
have
shown
greater
savings
occurring
from
cap­
and­
trade
options
over
command­
and­
control
approaches
than
were
found
in
these
three
cases.
14
There
are
several
reasons
for
the
results.
First,
there
is
only
one
control
technology
(
ACI)
that
electric
generation
units
can
choose
and
it
is
assumed
to
provide
a
relatively
high
level
of
mercury
reduction.
The
cost
functions
used
also
assume
limited
economies
of
scale.
Consequently,
the
power
industry
can
not
capitalize
on
larger
more­
efficient
units
carrying
a
greater
part
of
the
emission
reduction
burden
at
a
lower
cost
and
providing
allowances
to
other
units
that
select
a
less
effective
pollution
control
option,
or
do
not
apply
controls.
Additionally,
there
is
a
trade­
off
that
electric
generation
unit
operators
face
in
selecting
coals,
which
in
some
cases
will
lower
sulfur
emissions,
but
will
not
lower
mercury
emissions.
Given
that
scrubbers
cost
generation
units
more
to
install
and
operate
than
ACI,
electric
generation
units
will
make
more
effort
to
avoid
scrubber
installation.

For
the
baseline
case
of
a
50%
SO2
Reduction
in
2010
/
High
Efficiency­
Carbon
Level
of
515
MMT
in
2008,
the
lower
electric
demand
leads
to
a
lower
need
to
reduce
SO2
emissions
in
2010
and
creates
greater
freedom
for
generation
units
to
select
coals
with
lower
mercury
rather
than
lower
sulfur
content.
The
lower
electric
demand
also
creates
more
freedom
to
use
capacity
differently
throughout
the
power
grid
to
lower
demand.
In
the
MACT
option
with
this
baseline,
all
coal­
fired
units
greater
than
25
MW
install
ACI
(
a
small
amount
of
capacity
closes).
In
the
cap­
and­
trade
option
about
10
percent
of
the
coal­
fired
units
above
25
MW
do
not
install
controls.
(
These
results
can
be
reviewed
in
detail
in
Appendix
D.)

14
EPA
found
that
command­
and­
control
regulation
in
the
NOx
SIP
call
could
be
30
to
60
percent
more
expensive
than
a
cap­
and­
trade
approach.
See
US
Environmental
Protection
Agency,
"
Economic
Impact
of
the
NOx
SIP
Call
on
Electric
Power
Generation,"
presented
at
the
Electric
Utilities
Environment
Conference,
Tucson,
Arizona,
January
1999.
4­
25
Exhibit
4­
28
Preliminary
Assessment
of
the
Annual
Mercury
Costs
in
2010
of
Mercury
MACT
and
Cap­
and­
Trade
Under
Alternative
Baselines
(
Million
1990$)
Baselines
MACT
Cap­
and­
Trade
Base
Case
$
1,874
$
1,681
50
%
SO2
Reduction
in
2010
$
1,794
$
1,680
50
%
SO2
Reduction
in
2010
/
High
Efficiency­
Carbon
Level
of
515
MMT
in
2008
$
1,496
$
1,149
Exhibit
4­
29
Cumulative
Installation
of
New
Scrubber
Capacity
in
Coal­
Fired
Electric
Generation
Units
in
2010
by
Mercury
MACT
and
Cap­
and­
Trade
Options
Under
Alternative
Baselines
(
GW)
Baseline
MACT
Cap­
and­
Trade
Base
Case
8
8
50
%
SO2
Reduction
in
2010
81
87
50
%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
47
50
Exhibit
4­
30
Natural
Gas
Combined­
Cycle
Capacity
in
2010
by
Mercury
MACT
and
Cap­
and­
Trade
Options
Under
Alternative
Baselines
(
GW)
Baseline
MACT
Cap­
and­
Trade
Base
Case
112
113
50
%
SO2
Reduction
in
2010
120
122
50
%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
139
136
4­
26
Exhibit
4­
31
Electric
Generation
Capacity
and
Production
in
Units
Using
Fossil
Fuels
in
2010
by
the
Mercury
MACT
and
Cap­
and­
Trade
Options
under
Alternative
Baselines
Fuel
Type
Mercury
Capacity
by
Fuel
Type
(
GW)
Generation
by
Fuel
Type
(
Billion
kWh)
Base
Case
Coal
MACT
304
2,099
Cap­
and­
Trade
304
2,073
Oil/
Natural
Gas
MACT
282
774
Cap­
and­
Trade
282
799
50%
SO2
Reduction
in
2010
Coal
MACT
301
2,017
Cap­
and­
Trade
301
2,006
Oil/
Natural
Gas
MACT
286
855
Cap­
and­
Trade
285
866
50%
SO2
Reduction
in
2010
/
High
Efficiency
Carbon
Level
of
515
MMT
in
2008
Coal
MACT
279
1,656
Cap­
and­
Trade
284
1,681
Oil/
Natural
Gas
MACT
261
973
Cap­
and­
Trade
255
949
Note:
Coal­
fired
units
are
assumed
to
lose
about
2
percent
of
their
capacity
when
they
install
scrubbers.
See
Exhibit
3­
20
to
assess
the
impact
of
scrubber
installation
on
the
capacity
over
time.

Fossil
Fuel
Use
Exhibits
4­
32
through
4­
34
show
the
coal
consumption
occurring
under
the
MACT
and
Cap­
and­
Trade
options
in
2010.
Exhibit
4­
35
shows
the
natural
gas
and
oil
use
by
the
power
industry
in
2010
under
the
MACT
and
Cap­
and­
Trade
options.

Exhibit
4­
32
Coal
Consumption
for
the
Electric
Power
Industry
in
2010
by
Supply
Region
Under
Mercury
MACT
and
Cap­
and­
Trade
Options
Using
the
Base
Case
(
million
tons)
Coal
Supply
Areas
MACT
Cap­
and­
Trade
Northern
Appalachia
111
105
Central
and
Southern
Appalachia
216
203
Midwest
127
131
West
499
504
Central
West
and
Gulf
58
50
Total
1,011
992
4­
27
Exhibit
4­
33
Coal
Consumption
in
the
Electric
Power
Industry
in
2010
by
Supply
Region
Under
Mercury
MACT
and
Cap­
and­
Trade
Options
Using
the
50%
SO2
Reduction
Baseline
(
millions
tons)
Coal
Supply
Areas
MACT
Cap­
and­
Trade
Northern
Appalachia
142
130
Central
and
Southern
Appalachia
169
156
Midwest
133
162
West
482
470
Central
West
and
Gulf
47
47
Total
974
964
Exhibit
4­
34
Coal
Consumption
in
the
Electric
Power
Industry
in
2010
by
Supply
Region
Under
a
Mercury
MACT
and
Cap­
and­
Trade
Option
Using
the
50
Percent
SO2
Reduction/
High
Efficiency­
Carbon
Level
at
515
MMT
in
2008
Baseline
(
million
tons)
Coal
Supply
Areas
MACT
Cap­
and­
Trade
Northern
Appalachia
121
113
Central
and
Southern
Appalachia
141
143
Midwest
116
149
West
375
357
Central
West
and
Gulf
22
14
Total
776
776
4­
28
Exhibit
4­
35
Natural
Gas
and
Oil
Consumption
in
2010
Under
Mercury
MACT
and
Cap­
and­
Trade
Options
for
the
Electric
Power
Industry
Fuel
Type
Units
MACT
Cap­
and­
Trade
Base
Case
Natural
Gas
Trillion
cubic
feet
5.4
5.5
Oil
Million
Barrels
0.0
0.0
50%
SO2
Reduction
in
2010
Natural
Gas
Trillion
cubic
feet
5.9
5.9
Oil
Million
Barrels
0.0
0.0
50%
SO2
Reduction
in
2010
/
High
Efficiency
 
Carbon
Level
of
515
MMT
in
2008
Natural
Gas
Trillion
cubic
feet
6.4
6.2
Oil
Million
Barrels
0.0
0.0
