Mercury and Air Toxics Standard (MATS) Mercury and the Environment University of Richmond School of Law

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1 Mercury and Air Toxics Standard (MATS) Mercury and the Environment University of Richmond School of Law Michael G. Dowd Director, Air Quality Division Virginia Department of Environmental Quality March 28, 2012 The Road to MATS 1990: Clean Air Act Amendments required EPA to issue standards to reduce toxic air emissions from many sources, and to study whether to do so for power plants 1998: EPA released the UDlity Toxics Study Report to Congress 2000: EPA listed power plants for reguladon under the Clean Air Act (CAA) air toxics provisions EPA determined it was appropriate and necessary to regulate emissions of hazardous air pollutants (HAP) from power plants Mercury cited as pollutant of greatest concern but other toxics of potendal concern include arsenic, chromium, cadmium, nickel, hydrochloric acid, dioxin/furan 2 1

2 The Road to MATS 2005: EPA reversed power plant finding EPA determined it was neither appropriate nor necessary to regulate HAP emissions from power plants and removed those units from the CAA secdon 112(c) source category list EPA issued the Clean Air Mercury Rule (CAMR), which regulated mercury from power plants through a cap and trade program under CAA secdon : DC Circuit Court vacated EPA's acdon removing power plants from the secdon 112(c) source category list and CAMR 2011: EPA under consent decree to propose toxics standards for power plants by March 2011 and issue final standards by December 16, 2011 (published in FR February 16, 2012) 3 Affected Units: Coal and Oil Fired Electric UPlity Steam GeneraPng Units As defined in the rule: EGU [electric generadng unit] means a fossil fuel- fired combusdon unit of more than 25 megawa]s electric (MWe) that serves a generator that produces electricity for sale. A fossil fuel- fired unit that cogenerates steam and electricity and supplies more than one- third of its potendal electric output capacity and more than 25 MWe output to any udlity power distribudon system for sale is considered an electric udlity steam generadng unit 4 2

3 New vs ExisPng EGU New: Commence construcdon or reconstrucdon of the coal- or oil- fired EGU aber May 3, 2011 ExisDng: An EGU is exisdng if it is not new or reconstructed 5 SeRng the Standards New EGUs: must be at least as stringent as the control level achieved in pracdce by the best controlled similar source ExisDng EGUs: must be at least as stringent as the average emission limitadon achieved by the best performing 12 percent of exisdng sources in the source category The EPA also must consider more stringent beyond- the floor control opdons for new and exisdng units 6 3

4 Basic Requirements of MATS Coal- Fired EGUs Mercury: numeric emission limit would prevent 91% of mercury in coal from being released to the air Acid gases: HCl numeric emission limit as a surrogate, with an alternate surrogate of SO 2 Non- mercury metallic toxic pollutants such as arsenic and chromium: numeric emission limit for total PM as a surrogate, with alternate surrogate of total or individual metal air toxics Organic air toxics (including dioxin): Work pracdce standards, instead of numeric standards, due to low- detected emission levels. Would ensure opdmal combusdon, prevendng dioxin/ 7 furan emissions Emission Limits for Coal- fired EGUs New Coal- Fired Unit Not Low Rank Coal New Coal- Fired Unit Low Rank Virgin Coal ExisPng Coal- Fired Unit Not Low Rank Coal ExisPng Coal- Fired Unit Low Rank Virgin Coal Pollutant Lb/MWh Lb/MMBtu Lb/Mwh Lb/MMBtu Lb/MWh Lb/MMBtu Lb/MWh Lb/MMBtu PM Total 7.03E- 03 N/A 7.03E- 03 N/A 3.0E E E E- 02 Total Non Hg Metals 6.0E- 05 N/A 6.0E- 05 N/A 5.0E E E E- 05 Individual HAPs Varies Varies Varies Varies Varies Varies Varies Varies HCl 4.0E- 04 N/A 4.0E- 04 N/A 2.0E E E E- 03 SO2 4.0E- 01 N/A 4.0E- 01 N/A 1.5E E E E- 01 HF N/A N/A N/A N/A N/A N/A N/A N/A Hg 2.0E- 07 N/A 4.0E- 05 N/A 1.3E E E E

5 Basic Requirements of MATS Oil- Fired EGUs Acid gases: Numerical HCl and HF emission limits Metal air toxics: Numerical emission limits for total metal air toxics (including Hg) with individual metal air toxics as alternate Organic air toxics (including dioxin): Work pracdce standards, instead of numeric standards, due to low- detected emission levels. Would ensure opdmal combusdon, prevendng dioxin/furan emissions. 9 Affected FaciliPes NaPonwide 525 Power Plants EsDmated 1,200 coal- fired units (45% percent of nadonwide electricity generadon) EsDmated 150 oil- fired units (1% of nadonwide electricity generadon) 10 5

6 LocaPon of Coal and Oil Power Plants Source: National Electric Energy Data System (NEEDS 4.10 MATS) (EPA, December 2011) and EPA s Information Collection Request (ICR) for New and Existing Coal- And Oil-Fired Electric Utility Stream Generation Units (2010) 11 Why Control Mercury Emissions? Fish Advisories for Mercury are Everywhere 12 6

7 MATS IN VIRGINIA 13 The Clean Air Act s Federal- State Partnership EPA Establishes Major clean Air Program States implement Air Quality Standards EPA set NaDonal Ambient Air Quality Standards (NAAQS) Technology Driven Standard EPA develops NSPS and MACTs States implement, permit and enforce 14 7

8 Virginia Likely Will Seek DelegaPon of the MATS Program Out of 125 promulgated MACT standards, VA has refused delegadon of only nine DelegaDon of a MACT refused when number of sources covered are so great that DEQ lacked resources to adequately implement Not an issue with MATS 15 DEQ Path for Obtaining Delegated Authority for MATS DEQ reviews all air related federal reguladons promulgated during the previous year (July 1 to June 30) and decides which ones to incorporate into the Virginia air reguladons and seeks approval from the SAPCB at their December board meedng Upon approval, the reguladon is incorporated by reference into the Virginia air reguladons Once the amended reguladon has been published, DEQ formally requests delegadon of the reguladon from EPA DEQ andcipates becoming the delegated authority for the MATS rule by early

9 ImplementaPon of MATS DEQ to determine facilides subject to rule Conduct compliance and enforcement acdvides at affected facilides Amend Title V permit of affected facilides at appropriate Dme No special perminng required DEQ cannot revise limits established in rule Sources are free to achieve as they see fit 17 Compliance Dates New or Reconstructed EGUs must comply with MATS rule by April 16, 2012 or upon startup of EGU, whichever is later ExisDng EGUs must comply with MATS rule no later than April 16, 2015 EPA or delegated authority may approve up to one addidonal year if needed to install controls Under certain circumstances, EPA may approve a 5 th year and is considering further steps if necessary to keep the lights on 18 9

10 How Will EGUs Comply? Proven control technologies to reduce these emissions such as scrubbers, fabric filters, and acdvated carbon injecdon are widely available Many units already use one or more of these technologies Some power plants will upgrade exisdng controls (especially pardculate ma]er controls like electrostadc precipitators) Power plants may also install new controls (such as fabric filters, dry sorbent injecdon, or acdvated carbon injecdon) Some units may convert to natural gas or wood and some older inefficient units may be shut down 19 Power Plants In Virginia Out of the current 33 power plants and 125 EGUs in Virginia 16 power plants and 46 EGUs are potendally affected Up to half of the older inefficient EGUs may shut down or convert to gas or biomass rather than comply with MATS At this Dme, Virginia does not have any new EGUs. Dominion s Wise County plant commenced construcdon prior to new source date of May 3,

11 Dominion s Wise County Power Plant 21 Wise County Plant s Permi^ed vs MATS Emission LimitaPons Pollutant EGU Standard for ExisDng Units Permi]ed Emission Limits Total PM 0.03 lb/mmbtu 0.01 lb/mmbtu HCl or lb/mmbtu lb/mmbtu SO lb/mmbtu lb/mmbtu (3 hr ) lb/mmbtu (24 hr) lb/mmbtu (30 day) Mercury lb/gwh lb/gwh 22 11

12 Other Air RegulaPons ImpacPng Power Plant and Hg Emissions Cross- State Air PolluDon Rule (CSAPR)? CAIR sdll in effect 1 Hr Source Specific SO2 Standard (NAAQS) Will drive deep SO2 emissions at exisdng coal plants Green House Gas New Source Performance Standard (NSPS)? 23 Other Source Categories with RegulaPons to Control Mercury Emissions Municipal Waste Combustors Medical Waste Incinerators Portland Cement Plants Industrial, Commercial and Institutional Boilers and Process Heaters Iron & Steel Foundries Electric Arc Furnaces Mercury Cell Chlor-Alkali Plants Commercial Industrial Solid Waste Incinerators Other Solid Waste Incinerator 24 12

13 Impact of MATS to Virginia EPA claims benefit to Va of $1 2.5 billion Impacts related to deposidon Virginia Mercury Study (2008) Out- of- date but instrucdve Established deposidon baseline DeposiDon reducdons based on implementadon of CAMR and CAIR, not MATS h]p:// vamercurystudy.html 25 H.B (2006) The Department of Environmental Quality shall conduct a detailed assessment of mercury deposi9on in Virginia in order to determine whether par9cular circumstances exist that jus9fy, from a health and cost and benefit perspec9ve, requiring addi9onal steps to be taken to control mercury emissions within Virginia. The assessment shall also include (i) an evalua9on of the state of mercury control technology for coal- fired boilers, including the technical and economic feasibility of such technology, and (ii) an assessment of the mercury reduc9ons and benefits expected to be achieved by the implementa9on of the CAIR and CAMR regula9ons. The Department shall report the final findings and recommenda9ons... no later than October 15,

14 MODELED MERCURY DEPOSITION IN VIRGINIA DURING % from global background 14% from nearby out-of-state EGUs 3% from in-state EGUs 3% from in-state non-egus 3% from nearby out-of-state non-egus 3% from remaining U.S., Mexico, and Canada 27 SUMMARY OF BASE YEAR MODELING RESULTS FOR VIRGINIA Contribution by Geographic Area 1% 3% 3% 14% Contribution by Geographic Area w/o Global Background 6% 1% 14% 13% 3% 2% 0% 12% 74% Virginia (EGU) Surrounding States (EGU) Remaining US Global Background Virginia (Non-EGU) Surrounding States (Non-EGU) Canada & Mexico Natural Sources Virginia (EGU) Surrounding States (EGU) Remaining US 54% Virginia (Non-EGU) Surrounding States (Non-EGU) Canada & Mexico 28 14

15 MERCURY DEPOSITION IN VIRGINIA Study predicted a 20.4% drop in mercury deposition in Virginia between and 2018, which follows implementation of federal Clean Air Interstate Rule (CAIR) and Clean Air Mercury Rule (CAMR) 29 MERCURY DEPOSITION IN VIRGINIA 61% of predicted drop in Hg deposition between base year and 2018 comes from reductions at nearby out-of-state EGUs 7.2% from reductions at in-state EGUs 5.7% from reductions at in-state non EGUs 4.6% from reductions at nearby out-of-state non-egus 2.8% from reductions in remainder of U.S

16 MERCURY DEPOSITION IN VIRGINIA Individual Virginia facilities do contribute to mercury deposition within the state, and the greatest impacts from in-state sources are near the source

17 FISH TISSUE IMPACTS Predicted drop in mercury deposition between and 2018 could result in reduction of mercury sensitive water bodies with fish consumption advisories from 13 to 9 or 10 based on current VDH 0.5 ppm average fish mercury concentration level 33 Effect of New EPA Air Rules on Virginia Coal GeneraPon Coal generadon at following VA facilides likely will cease in next few years: GenOn Potomac River (482 MW) Dominion Yorktown Units 1 and 2 (323 MW) Dominion Chesapeake (595 MW) Dominion Bremo Bluff (227 MW) Dominion Alta Vista (63 mw) Dominion Hopewell (63 MW) Dominion Southampton (63 MW) AEP Glyn Lyn (335 MW) AEP Clinch River (705 MW) Over 2800 total megawa]s 34 17

18 QUESTIONS? 35 18