Transcript Track B Environmental Risk Analysis

Mercury and CO2 Emissions
from the Power Generation Sector
By
C.V. Mathai, Ph. D.
Manager for Environmental Policy
Arizona Public Service Company
Phoenix, Arizona
A Presentation at the
DENR/DAQ Mercury/CO2 Workshop
Raleigh, North Carolina
April 20, 2004
Overview
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Introduction
Mercury Emissions and Proposed Regulation
Global Climate Change
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United Nations Framework Convention on Climate
Change (UNFCCC)
Kyoto Protocol
Multi-Pollutant Legislation
Summary and Conclusions
Electricity and Fuel Diversity
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Power generation is a major
contributor to national air
pollutant emissions

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SO2:
NOx:
Hg:
CO2:
63%
22%
37%
~40%
A diverse fuel mix is critical to
ensure electrical reliability,
minimize price volatility, and
strengthen national security
Hydro/
Fuel Oil
Other
3%
Renewables
11%
Gas
16%
Coal
51%
Nuclear
20%
Current Generation Mix
(Numbers exceed 100% due to rounding.)
Source: Form EIA-759 and Form EIA-860B
Contributions to Global Anthropogenic
Emissions of Mercury (t/yr)
Oceania
53
Africa
271
United States Rest of North
America
155
71
South & Central
(utilities: 48)
America
194
Europe
560
Asia
1232
Global total: 2536 T/y
Source: EPRI
Is there a mercury management “floor”?
Mercury entering the U.S. from other countries
PORTION OF THE U.S. WHERE LESS
THAN 20% OF THE MERCURY
ORIGINATES IN OTHER COUNTRIES
Percent of
mercury
deposition that
originates
outside of the
U.S.
0 to 20%
20 to 40%
40 to 60%
60 to 80%
80 to 100%
PORTIONS OF THE U.S. WHERE
MORE THAN 60% OF THE
MERCURY ORIGINATES IN OTHER
COUNTRIES
EPRI TEAM regional model, global chemical model
Chlorine and Mercury Emissions
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Mercury emissions from power plants occur in
three forms: Elemental, Oxidized, and Particlebound
Chlorine concentration in coal has a significant
impact on the type of Hg emissions:

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Lower the Cl level, higher the elemental Hg
fraction
higher the Cl level, higher the oxidized and
particulate Hg fractions
Oxidized and particulate Hg fractions are
easily controllable in conventional pollution
control devices, but not elemental Hg

PM and SO2 controls are not efficient to remove
elemental Hg, i.e., little “Co-benefits”
Mercury Emissions from Power Plants: 1999
120,000.00
100,000.00
lbs
80,000.00
60,000.00
40,000.00
20,000.00
0.00
National - lbs
% of total
11 Western States +
ND- lbs
% of total
elemental
52,189.29
54%
8,551.73
85%
oxidized
40,816.99
43%
1,404.46
14%
particulate
2,966.89
3%
126.82
1%
Mercury Removal with PAC Upstream of
Fabric Filters and ESPs
100
FF Bitum
FF PRB
ESP Bituminous
ESP PRB
Mercury Removal (%)
90
80
70
60
50
40
30
20
10
0
0
5
10
15
20
Sorbent Injection Rate (lb/Macf)
25
30
PAC Performance with ESPs:
Bituminous versus PRB
100
Mercury Removal (%)
90
80
70
60
50
40
ESP Low S Bit
30
ESP PRB
20
ESP Hi S Bit
10
0
0
5
10
15
20
Sorbent Injection Rate (lb/MMacf)
25
30
Mercury MACT
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1990 CAA required EPA to Report to Congress on the need
to regulate Hg emissions from power generation sources
(Report submitted in 1998)
In 1999, EPA assembled the “ICR” database
In Dec 2000, EPA made a regulatory finding that
controlling utility Hg emissions was “necessary and
appropriate” triggering the CAA Maximum Achievable
Control Technology (MACT) provision
For existing sources, MACT is defined as the average
emission limitation achieved by the best performing 12%
For new sources, MACT is the “best of the best”
EPA proposed three options to regulate Hg emissions from
coal-fired power plants; Rule to become final by Dec 2004
EPA’s Proposed Mercury Rule

EPA proposed three approaches to control
mercury from coal-fired power plants:
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Traditional, plant-by-plant MACT controls,
achieving 29% reduction by Dec. 2007 (via CAA
Section 112 MACT)
A two-phased cap-and-trade program, reducing
Hg emissions by 69% by 2018, administered by
the EPA (via CAA Section 112(n)(1)(A))
A similar cap-and trade program, but administered
by the States and SIPs (via CAA Section 111)
Public comments are due by April 30, and
EPA to finalize the Rule by Dec. 15, 2004
Global Climate Change

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In 1988, the United Nations Environmental Program and
the World Meteorological Organization established the
Intergovernmental Panel on Climate Change (IPCC)
Based on the IPCC’s 1990 First Assessment Report,
world leaders adopted the United Nations Framework
Convention on Climate Change (UNFCCC) at the Earth
Summit in Rio de Janeiro, Brazil in 1992
UNFCCC’s Objective is “.... stabilization of greenhouse
gas concentrations in the atmosphere at a level that
would prevent dangerous anthropogenic interference
with the Climate system”
The UNFCCC has been ratified by a large number of
countries, including the U.S., and is in effect as of 1994
Conferences of Parties (COPs) to the UNFCCC has been
held annually since 1995
UNFCCC Commitments
Annex I Parties commit themselves ...
 “The policies and measures will aim to return emissions
of CO2 and other greenhouse gases, individually or
jointly, to their 1990 levels”
 “... adopt national policies and take measures on the
mitigation of climate change by limiting its
anthropogenic emissions of greenhouse gases...”
 “These Parties may implement such policies and
measures jointly with other Parties and may assist other
Parties in contributing to the achievement of the
objective of the convention”
THE KYOTO PROTOCOL
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In 1997 COP-3 agreed on a “protocol” establishing legallybinding “differentiated” emission limits for 38 industrialized
countries reducing their annual average GHG emissions by
about 5.2% below its 1990 level, during 2008-2012;
United States’ share is 7% below 1990 emissions
The Protocol incorporates several “compliance flexibility”
measures -- five-year emission budgets, banking, inclusion
of sinks, six greenhouse gases, international emission
trading, joint implementation, and a “Clean Development
Mechanism”
It marks a major first step towards the objective of the
UNFCCC, i.e., to stabilize atmospheric concentrations of
greenhouse gases at a “safe” level
The Protocol does not call for any emission limits for
developing countries
U.S. Actions on Climate Change
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In 2001 U.S. withdrew from the Kyoto Protocol; Bush
Administration is embarking on a voluntary program to
cut carbon intensity (GHG emissions/GDP)
There is momentum building to initiate some form of
domestic action on carbon, independent of the Kyoto
Protocol process
A number of States have initiated programs to reduce
GHG emissions
Proposals to reduce CO2 emissions from power
generation sources are pending before the Congress
McCain/Lieberman Bill failed in the Senate by 43 to 55
Multi-Pollutant Legislation

Several proposals are pending before
Congress calling for a coordinated,
market-based approach to reduce
multiple pollutant emissions from the
power generation sector:
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Clear Skies Act (Bush Bill)
Clean Air Planning Act (Carper Bill)
Clean Power Act (Jeffords Bill)
The Alternative under the Clean Air Act is a Complex Set
of Requirements Covering the Power Sector
Note: Dotted lines indicate a range of possible dates.
NSR Permits for new sources & modifications that increase emissions
Designate 1-hr Severe Margareas for
Area
inal 8-hr
8-hr Ozone Attainment Ozone
NAAQS
Date
NAAQS
AttainNOx
ment
SIP
Date
Call
Ozone
1-hr Serious
Area Attainment
Date
NOx
SIPs
Due
OTC
NOx
Trading
99
00
01
Section
126 NOx
Controls 1
02
Mercury
Determination
Phase II
Acid Rain
Compliance
03
8-hr
Ozone
Attainment
Demonstration
SIPs due
Reductions
04
Proposed
Utility
MACT
05
06
Final
Utility
MACT
Designate Areas
for Fine PM NAAQS
Interstate Transport Rule to Address
SO2/ NOx Emissions for Fine PM
NAAQS and Regional Haze
Acid Rain, PM2.5, Haze, Toxics
07
08
1
The D.C. Circuit Court has delayed the May 1, 2003
EGU compliance date for the section 126 final rule
Assess
Effectiveness
of Regional
Ozone
Strategies
Moderate
8-hr
Ozone
NAAQS
Attainment
Date
Possible
Regional NOx
Reductions ?
(SIP call II) 2
09
10
Regional Haze SIPs due
Further action on ozone would be considered based
on the 2007 assessment.
3
The SIP-submittal and attainment dates are keyed off
the date of designation; for example, if PM or ozone are
designated in 2004, the first attainment date is 2009
EPA is required to update the new source performance
standards (NSPS) for boilers and turbines every 8 years
Serious 8-hr Ozone
NAAQS attainment
Date
11
12
13
14
Compliance for
BART Sources
Compliance
with Utility
MACT
New Fine PM NAAQS
Implementation Plans
2
Latest attainment
date for Fine PM
NAAQS 3
15
16
17
18
Compliance for BART
sources under the
Trading Program
Second Regional
Haze SIPs due
In developing the timeline of current CAA requirements,
it was necessary for EPA to make assumptions about
rulemakings that have not been completed or, in some
case, not even started. EPA’s rulemakings will be
conducted through the usual notice-and-comment
process, and the conclusions may vary from these
assumptions.
Multi-Pollutant Control Legislative Proposals
Proposed Emissions Caps (Tons / Year)
Actual
2001
S. 485 Clear
Skies
Sulfur Dioxide
(SO2)
S. 366 Jeffords
S. 843 –
Carper
10.6 M
4.5 M in 2010
3.0 M in 2018
2.25 M in 2009
4.5 M in 2009
3.5 M in 2013
2.25 M in 2016
Nitrogen
Oxides
(NOx)
4.8 M
2.1 M in 2008
1.7 M in 2018
1.51 M in 2009
1.87 M in 2009
1.7 M in 2013
Mercury
(Hg)
48 (1999)
26 in 2010
15 in 2018
5 in 2008
24 in 2009
10 in 2013
2.05 B in 2009
2.57 B (est.) in
2009
2.47 B (est.) in
2013
Carbon
Dioxide
(CO2)
2.47 B (est.)
Source: EIA AEO 2003 Reference Case Forecast, S.485, S.366, S.843
N.A.
Power Sector Emission Reductions
Summary and Conclusions
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Mercury is a global air pollutant and U.S. Power Plants’
emissions contribute only about 2% of the total manmade Hg emissions
Recent studies show that 60% or more of the Hg
deposition in the U.S., except for some areas in the East,
originate outside the U.S.
Activated Carbon Injection can effectively control mercury
at coal-fired power plants
EPA has proposed three approaches to control Hg
emissions from coal-fired power plants -- A MACT
program and two cap-and-trade programs; a final Rule is
expected by Dec 2004
Summary and Conclusions
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(Contd.)
Global CO2 emissions and atmospheric CO2 concentrations
are steadily increasing and there is increasing public
support for climate-related action
The Kyoto Protocol appears to be “dead;” global
agreement for action on climate is likely only if the U.S.
provides leadership
Current pollutant-by-pollutant, source-by-source Clean Air
Act regulatory program is complex, costly, and inefficient
An integrated emission reduction strategy, like the
proposed Clear Skies Act, is necessary to make costeffective and timely emission reductions to achieve
improved air quality and to ensure affordable and reliable
electric power supply