Pennsylvania Draft Regulations for the Control of Mercury From Coal-

fired Electric Generating Units

Allegheny Section- AWMAAir Quality Issues Workshop

May 23, 2006

Action Resulted from

PennFuture Petition—8/9/04 EPA’s Clean Air Mercury Rule

(CAMR) March 2005 A region-wide cap and trade program

General Principles PA Draft Mercury Rule

No trading of Hg emission allowances. Achieve greater reductions in Hg than

EPA's CAMR. Maximize the Hg reduction co-benefits

from other SO2 and NOx emission control programs such as CAIR.

Discourage fuel switching from bituminous coal.

No adverse impact on the capacity and reliability of power generation.

Conceptual Approach Applicability - Any coal-fired EGU with

a nameplate capacity of 25 MW or more.

Each EGU would be required to meet – a numerical emission standard or

minimum control efficiency and an annual emission limit in ounces of Hg

emitted (as backstop).

Exception The owner or operator of an existing EGU

that enters into an enforceable agreement before 12/31/07 for the shutdown of an EGU and replacement with Integrated Gasification Combined Cycle (IGCC) by 12/31/12 will be exempted from compliance with both the Phase 1 Hg emission standards and the Phase 1 annual emission limit requirements.

Compliance Deadlines Phase 1 (January 1, 2010)

Initial level for numerical emission standard or control efficiency, and

an annual emission limit by unit. Phase 2 (January 1, 2015)

More stringent emission standard or control efficiency, and

Lower annual emission limit by unit.

Emission Standards New EGU standards apply at construction

for: IGCC PC-Fired CFB

Phase 1 and 2 standards for existing EGU units: Pulverized Coal (PC) – Fired Circulating Fluidized Bed (CFB)

Emission Standards for New EGUs

PC-Fired - output based emission standard of 0.011 lb/GWh or 90% control efficiency (coal to stack).

CFB - output based emission standard of 0.011 lb/GWh or 90% control efficiency.

IGCC - output based emission standard of 0.0048 lb/GWh or 95% control efficiency.

Phase 1 Existing EGU Standards

(1/1/10 to 12/31/14)

PC-Fired - output based emission standard of 0.024 lb/GWh or 80% control efficiency.

CFB - output based emission standard of 0.0058 lb/GWh or 95% control efficiency.

Phase 2 Existing EGU Standards

(beginning 1/1/15)

PC-Fired - output based emission standard of 0.012 lb/GWh or 90% control efficiency.

CFB - output based emission standard of 0.0058 lb/GWh or 95% control efficiency.

Annual Emission Limit Established for each EGU on

ounces of Hg per year basis. Based on CAMR allocation distribution

methodology using three highest heat input from the years 2000-2004.

CFB unit annual emission limit in Phase 1 is identical to the Phase 2 limit.

Provides regulatory assurance for Pennsylvania to meet the EPA CAMR Hg budgets.

Phase 1 Emission Standards Compliance Options

Unit-by-unit basis. Emissions averaging among the

units at a specific facility. Compliance Presumption – cold-

side ESP or FF, and wet FGD where 100% bituminous coal is fired.

Alternative emission standard/compliance schedule.

Phase 2 Emission Standards Compliance Options

Unit-by-unit basis. Emissions averaging among the

units at the same facility. Compliance Presumption – cold-side

ESP or FF, wet FGD and SCR where 100% bituminous coal is burned.

Alternative emission standard/compliance schedule.

Annual Emission Limit Compliance Components

Allocate to each EGU an available amount of non-tradable allowances based on CAMR caps.

Set asides for New Source EGUs and CFB units. Each affected unit must draw up to the available

amount of allowances based on their actual emissions for compliance with the annual emission limit.

The owner/operator of the EGU may petition DEP for additional allowances from surplus allowances

Order of preference established for additional allowances.

Allocation Method Total allowances

56,960 ounces (3,560 pounds, 1.78 t) of Hg for Phase 1.

22,464 ounces (1,404 pounds, 0.70 t) of Hg for Phase 2.

The DEP will set aside 5% of the Phase 1 total and 3% of the Phase 2 allowance total for new sources.

Same set asides for CFB units in both Phases.

Allocation for Existing Units

The maximum number of annual non-tradable Hg allowances set aside for existing sources will be determined by using the average heat input (MMBtu) data from the DEP’s acid rain database for the three highest calendar years from 2000 through 2004.

Additional Allowances Petition Process

An existing affected EGU that emits amounts of Hg in excess of its maximum number of allowances may petition the DEP for additional allowances from the Emission Limit Supplement pool by no later than January 31.

A separate petition for each calendar year. Application information is similar to that required

under the alternative emission standard/compliance application.

Order of Preference for Additional Allowances

Standby units CFBs combusting 100% waste coal or bituminous coal. EGUs combusting 100% bituminous coal which have: SCR, cold-side ESP or FF, wet FGD, and Hg-specific

control technology. SCR, cold-side ESP or FF, and wet FGD. wet FGD and Hg-specific control technology. Cold-side ESP or FF, and wet FGD. other air pollution control technologies and measures

to control emissions of air contaminants including Hg.

Other Requirements Monitoring Requirements

Similar to CAMR

Testing Requirements Similar to CAMR

Recordkeeping and Reporting Requirements Similar to CAMR

Anticipated Results - Calculation

Used the EGU’s average of three highest years heat-input within years 2000-2004.

Used actual coal mercury contents and actual mercury removal efficiencies calculated from reported emission rates wherever available.

If not available, used EPA’s default mercury removal efficiencies.

Anticipated Results Pennsylvania Hg reductions

beyond CAMR for Phase 1 approximately 29%

Pennsylvania Hg reductions beyond CAMR for Phase 2 approximately 36 %

Status of Draft Hg Rule Air Quality Technical Advisory

Committee (AQTAC) voted 7-2 on 3/30/06 to recommend the rule for public comment to the PA Environmental Quality Board (EQB).

Listed nine topics to solicit public comments on.

Next Steps

Place proposal on the regulatory calendar

Presented proposed rulemaking to EQB for consideration

Tentative Mercury Rule Timeline

May 3, 2006 Submited proposed mercury rulemaking to EQB for consideration

May 17, 2006 EQB Action on the proposed rulemaking

Late June, 2006 Publish Notice of Proposed Rulemaking in the Pa. Bulletin

Tentative Mercury Rule Timeline

July 2006 Three public hearings in Southeast, Southcentral and Southwestern PA

July/August 2006 Summarize public comments/develop final-form regulations. Meet with AQTAC/CAC/Workgroup to discuss final-form mercury regulation

September/October 2006 EQB considers final-form mercury regulation

November 2006 Independent Regulatory Review Commission Meeting

November 2006 Publish final mercury rulemaking. Submit State Plan to EPA Region III

Pennsylvania Draft Regulation for the Control of Mercury From Coal-fired Electric Generating Units

The End

Alternative Emission Standard/Compliance

Application An application including a brief description of the

EGU in need of an alternative emission standard or schedule must be submitted to the Department; The application must also include:

The date of installation and operation of all control technologies and measures to control emissions, including Hg from each EGU;

For each of the technologies and measures listed above, an explanation of how they were installed and if they are being operated properly;

A list of any other technologies or measures that are proposed to be installed and operated to control emissions, including Hg from the EGU;

Alternative Emission Standard/Compliance

Application Where an alternative compliance schedule

is sought, the owner or operator must submit a proposed schedule, which includes increments of progress and a date for final compliance as soon as practicable.

Where an alternative reduction requirement is sought, the owner or operator must submit an emission reduction proposal and information on the technological feasibility of meeting the Hg emission standard requirements.

Hg Content in Coal on a Facility Basis

Facilityppb Hg

lb Hg /TBtu

ppb Hglb Hg /TBtu

ppb Hglb Hg /TBtu

Number of

Samples

Facility A 60 4.49 265 20.9 2920 218.5 225Facility B 20 1.51 110 12.4 10140 768 180Facility C 20 1.47 120 8.8 1000 73.3 204Facility D 55 4.8 299 26.1 655 57.3 18Facility E NA NA 207 19.2 NA NA 24Facility F 70 5.3 94 7.1 170 13 65Facility G 30 2.3 84 6.37 150 11.4 102Facility H 79 5.93 105 7.8 132 9.89 11Facility I 50 4.3 360 32.2 750 74.5 62Facility J 120 9.1 120 9.1 120 9.1 1Facility K 372 29.8 372 29.8 372 29.8 1Facility L 70 5.2 105 8 140 10.8 2Facility M 26 2 133 10.2 240 18.4 2Facility N 30 27.3 410 34.3 1770 122 56

AVERAGE: 16.6 953MEDIAN: 11.3

Low Average High

Mercury Removal Rates (PA ICR Data)

Bituminous Coal No of Tests

Low Average HighControl ConfigurationCS-ESP 16% 65% 98% 12

CS-ESP + SNCR 37% 37% 37% 1

CS-ESP + SCR 4% 37% 84% 6CS-ESP + FGD 69% 80% 88% 5FGD + SCR 85% 85% 85% 1Venturi Scrubber 5% 5% 5% 1CS-ESP + FGD + SCR 90% 94% 98% 2CS-ESP + FGD + SNCR 75% 74% 75% 2CFB Boiler + Fabric Filter (Waste Bitum.)

99.12% 99.54% 99.96% 8

CFB Boiler + Fabric Filter (Waste Anthracite)

97.21% 99.18% 99.92% 10

Mercury Control Level (Coal to Stack)

Mercury Removal Rates Comparison

Coal Type Fired Sub-bituminous Coal

Control Configuration PA Data (Mean) EPA IPM EPA IPMCS-ESP 65% 36% 3%CS-ESP + SCR 37% 36% 3%CS-ESP + FGD 80% 66% 16%CS-ESP +FGD+ SCR 94% 90% 16%

EPA IPM - EPA's Integrated Planning Model used for CAMR CS - ESP - Cold Side Electrostatic PrecipitatorSCR - Selective Catalytic ReductionFGD - Fluegas Desulfurization

Bituminous Coal

Mercury Control Level

Controls for CAIR Compliance

SCR FGD SCR+FGD SCR FGD SCR+FGD SCR FGD SCR+FGD

Number of Units 12 18 5 15 32 14 26 37 25

MW Affected 8166 6375 3218 9009 14091 8500 13530 15383 13458

% of total MW 48% 37% 19% 53% 82% 50% 79% 90% 79%

Current 2010 2015