What the Clean Air Mercury Rule and Clean Air Interstate Rules Will Mean to You
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Transcript of What the Clean Air Mercury Rule and Clean Air Interstate Rules Will Mean to You
What the Clean Air Mercury Rule and Clean Air Interstate
Rules Will Mean to You
Jenna Glahn & Christine HeathARIPPA Technical SymposiumGettysburg, PA – July 27, 2005
trinityconsultants.com
Clean Air Mercury Rule
1. Why Mercury and Why You?2. Background on CAMR Rule3. NSPS & Cap-and-Trade Program4. Monitoring and Controlling Hg
Emissions5. Challenges and Lawsuits
Clean Air Mercury Rule(CAMR)
1. Why Mercury and Why You?
Mercury Contamination Persistent toxic that accumulates
in food chain Linked to neurological and
developmental problems In 2000, more than 600,000
newborns exposed to elevated mercury levels
Currently 44 states have issued fish consumption advisories
Mercury Cycle
Source: Mason et. al, 1994
Source Contribution Coal-fired power plants – 48 tons
of Hg emitted each year Total U.S. emissions – 3% of global
Hg
2. Background on CAMR Rule
Clean Air Rules Clean Air Nonroad Diesel Rule Clean Air Ozone Rules
8-hour ozone Clean Air Fine Particulate Rules
8-hour PM2.5
Clean Air Interstate Rule (CAIR) Market-Based, Cap & Trade Program for
SO2 and NOx in Eastern U.S.
Rule Updates Utility units delisted from Section
112(c) list Not appropriate and necessary No public health hazard
Standards of Performance for New and Existing Sources
3. NSPS & Cap-and-Trade Program
Applicable Sources Hg Budget Units
Any fossil fuel-fired combustion unit of > 25 MWe that serves a generator that produces electricity for sale, including cogeneration utility units which supply > 1/3 electric output capacity to the power distribution system
Coal-fired Definitions consistent with Acid Rain
Program and CAIR
Hg New Source Provisions
Revision to 40 CFR 60, Subpart Da Sources constructed after January
30, 2004 Meet performance standards
5 subcategories based on coal rank and process type
Inability to control Hg equally from all ranks
New Source Performance Standards
Subcategory Hg (10-6 lb/MWh)1
Bituminous-fired 21
Subbituminous-fired 42 (Wet FGD)78 (Dry FGD)
Lignite-fired 145
IGCC 20
Coal refuse-fired 1.4
1 – Based on a 12-month rolling average
Note: Standards for new sources only.
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., pet coke,TDF), compliance calculation 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
Cap-and-Trade Program
New and Existing Sources Codified in 40 CFR 60, Subpart
HHHH Managed by EPA
National Hg Allowances
2010 – Phase I Cap of 38 tpy of Hg Co-benefit reductions under CAIR
2018 – Phase II Cap of 15 tpy of Hg Hg-specific controls commercially
available
State Hg Allowances Based on proportionate share of
state’s baseline heat input to the total heat input from all affected sources Adjustment factors to reflect coal rank PA’s Phase I Allocation – 1.78 tpy
(2010) PA’s Phase II Allocation – 0.702 tpy
(2018)
Source Hg Allowances
State allocates Hg allowances to sources Allocations set three years in
advance May set aside allowances for new
sources Banking of unused allowances
Cap-and-Trade Requirements Each State must submit a plan that
demonstrates it will meet its assigned statewide Hg budget by October, 31, 2006 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 choose to implement more stringent Hg emissions requirements
4. Monitoring and Controlling Hg Emissions
Monitoring Hg Emissions (1 of 3) Added Subpart I to 40 CFR 75
Options for Hg Monitoring 2 Monitoring Options:
Hg CEMS Sorbent trap monitoring systems
Low Mass Emitters < 29 lb Hg per year Periodic Hg emissions testing
Monitoring Hg Emissions (2 of 3) All Continuous Monitoring Systems Must
Be Certified Submit unit specific monitoring plan 45
days before commencing certification tests CEMS meet PS 12-A or 40 CFR 75 Sorbent trap meet 40 CFR 75.15 and App.
K CEMS - Calibration Drift and Quarterly
RATA and 3 Error Tests (App. F or B) Sorbent Trap - Annual RATA and App. K
Monitoring Hg Emissions (3 of 3) Resemble current monitoring of
SO2 and NOx under the Acid Rain and NOx SIP Call programs
Comprehensive QA/QC program Commensurate with CAIR cap-and-
trade programs Flexibility of using alternate
monitoring Accurate, certain, and consistent
quantification of emissions
Controlling Hg Emissions (1 of 2) Co-Benefits of Existing Controls and
Controls Installed under CAIR Dependent on Hg speciation Dependent on control type and coal rank
FFs and ESPs – PM-Hg removed effectively FGD scrubbers – Adsorb Hg+2
Spray dryer absorbers – Hg0 and Hg+2 removal NOx controls may enhance ability to capture
Hg Better capture for higher rank coals
Controlling Hg Emissions (2 of 2) Hg-Specific Control Technologies
Adequately Demonstrated for Sufficient Use by 2018 Required to meet Phase II cap Sorbent injection (ACI or halogenated
ACI) available for commercial application after 2010 ACI – Hg removal 60-90% Optimized multipollutant controls –90-
95%
Compliance Deadlines January 1, 2009 - Hg Budget Unit
that Commences Commercial Operation Before 1/1/08
Later of January 1, 2009 or 90 unit operating days or 180 calendar days (whichever comes first) after start of operation – Hg Budget Unit that Commences Commercial Operation on or after 1/1/08
5. Challenges and Lawsuits
PA Opposition PA included in at least 2 lawsuits
March 31 – Appropriate and necessary to regulate Hg
May 18 – Cap and trade not appropriate for Hg Hot spots and downwind increases 90% reduction and earlier compliance
date under MACT
Bias towards western coal
Congressional Opposition EPA Inspector General - Hg limits pre-
selected to conform w/ CAIR Snowe(R)-Leahy(D) Bill – “Omnibus
Hg Emissions Reduction Act” Coal and oil fired power plants MWCs, commercial and industrial
boilers, chlor-alkali plants, and cement plants
Require labeling of Hg containing products
90% reduction in Hg emissions
What’s Next?
PA likely to regulate Hg! Per PennFuture lawsuit:
Conduct residual risk assessment Report results and basis for rulemaking
in August Program similar to NJ and include
other sources?
CAIR Clean Air Interstate Rule
OrWhy should you CARE about
CAIR?
CAIR
March 10, 2005, EPA issued CAIR (May 12, 2005 FR)
Previously known as Interstate Air Quality Rule (IAQR)
Addresses PM2.5 and ozone non-attainment from upwind sources
“Cap and Trade” program for SO2 and NOX from utilities
Alternative to Bush’s “Clear Skies” initiative
CAIR - Applicability
CAIR - Applicability
28 States NOX and SO2 only Aimed at electrical generating
units (EGU), but states may choose to implement differently
CAIR - Applicability Implementation options
EGU interstate cap and trade EGU caps without emissions trading Combination of caps on EGU and other
sources to meet caps EPA did not include non-EGU sources because
No cost effective controls for large emitters Many sources already regulated by NOX SIP Call or
ozone nonattainment
Given short timeline and limited options, states will likely follow EPA recommendations
CAIR - Applicability
Electric Generating Unit Definition A stationary fossil fuel fired boiler or
combustion turbine serving a generator with a nameplate capacity greater than 25 MWe, or
A cogeneration unit serving a generator with a nameplate capacity greater than 25 MWe and supplying in any calendar year more than 1/3 of the unit’s output capacity or 219,000 MWh, whichever is greater, to a utility power distribution system for sale
CAIR - Timeline
Affected states submit revised SIP within 18 months of rule (September 2006)
Rapid timeline Allows for upwind controls to be
used in downwind (Ozone/PM2.5 NAAQS) compliance demonstrations
Addresses 3-year regulatory timeline (from 1997) and lawsuits
CAIR - Timeline
Reductions Phase I: January 1, 2009 (NOX)
January 1, 2010 (SO2) Phase II: January 1, 2015 (NOX & SO2)
Incentives for early reductions Allows 2-3 years for installation of
controls Ozone attainment date June 2009 PM2.5 attainment date April 2010
CAIR - Controls NOX Reductions
0.15 lb/MMBtu system average by 2009 0.125 lb/MMBtu system average by 2015 Tonnage based on historical heat inputs Allowances allocated by state
SO2 reductions 50% reduction from Acid Rain allowances
by 2010 65% reduction from Acid Rain allowances
by 2015
CAIR - Controls CAIR rule assumes
NOX controlled by SCR SO2 controlled by FGD
Projected controls for CAIR
CAIR - Impacts
CAIR - ImpactsProjected Nonattainment Areas in 2010 after Reductions from
CAIR and Existing Clean Air Act Programs (Diesel Rules, Tier II Vehicle Rule, NOX SIP Call)
CAIR - ImpactsProjected Nonattainment Areas in 2015 after Reductions from
CAIR and Existing Clean Air Act Programs (Diesel Rules, Tier II Vehicle Rule, NOX SIP Call)
CAIR – Pennsylvania SO2 Budget
PA 2003 SO2
Emissions (tons)
PA SO2 Budget 2010 (tons)
PA SO2 Budget 2015 (tons)
Percent Reduction (%)
967,000 275,990 193,193 80%
CAIR – Pennsylvania NOx Budget
PA 2003 NOx Emissions
(tons)
PA NOx Budget 2009
(tons)
PA NOx Budget 2015
(tons)Percent
Reduction (%)174,000 99,049 82,541 53%
ARIPPA’s Comments on CAIR
Due to Congress’ exemption of certain IPPs from the Title IV Acid Rain Program, sources originally exempted under Title IV should not be subject to the SO2 control requirements of CAIR
EPA Response: EPA has determined that emissions reductions from EGUs are highly cost effective. States can choose to implement the trading program or control sources
ARIPPA’s Comments on CAIR
If sources originally exempted under Title IV are subject to the SO2 provisions CAIR, allocations of SO2 allowances to such sources should reflect current SO2 emission levels;
EPA Response: CAIR allocations will be based on existing Title IV program. Sources without allowances shall obtain them from the market or the Title IV Auction
ARIPPA’s Comments on CAIR
Waste coal-fired CFB boilers should not be required to comply with both NOx and SO2 reduction requirements in CAIR, because of the interrelationship of NOx and SO2 emission controls within boilers
EPA Response: The EPA does not agree that the SO2 reduction capability of a CFB boiler already equipped with limestone injection cannot be improved further (e.g., increased limestone injection and spray dryer adsorber)
ARIPPA’s Comments on CAIR
If waste coal fired CFB units are subject to NOx reduction requirements in CAIR, complete and accurate baseline heat input data reflecting all regulated sources must be used in the allocation process
EPA Response: EPA revised its determination of State NOx budgets by supplementing Acid Rain Program data with annual heat input data from US Energy Information Administration
ARIPPA’s Comments on CAIR
Implementation of CAIR should not result in the imposition of any additional burden on waste coal fired CFB sources, in the form of additional monitoring, recordkeeping or reporting requirements for non-acid rain sources
EPA Response: Part 75 monitoring and reporting requirements entail the appropriate monitoring approach for a program that is relied upon by numerous States to ensure that interstate transport of pollutants is reduced
CAIR Current Status
ARIPPA filed an appeal on CAIR Main concern – cost of SO2
allowances ARIPPA met with PADEP 7/25/05 to
discuss a motion to intervene EPA projects that PA sources will
sell allowances
CAIR - Summary
NOX and SO2 cap and trade program for EGU’s in 28 eastern states
SCR and FGD Controls Implemented by 2009/2010 with
further reductions by 2015 Will assist with ozone/PM2.5
nonattainment in PA Reduce PM2.5 NAA Counties from 23 to 1 Reduce ozone NAA Counties from 37 to 5
Questions?