Air Pollution Control for the 21st Century Issue 1, 2004

EPA Proposes Rules for SO2, NOx & Hg In separate but closely related actions, EPA has ties in the eastern U.S. The IAQR is a call to 29 proposed to regulate emissions of sulfur dioxide, states and D.C. to revise their State Implementation Clearing the Air nitrogen oxides and mercury (Hg) from existing Plans (SIPs). Dedicated to providing insight and new electric utility power plants. A total of 29 to utilities affected by emerging states and D.C. would be affected by what EPA calls States Affected emissions standards the Interstate Air Quality Rule (IAQR), which would SO2: Figure 2 shows the affected states and regulate SO2 and NOx emissions. Mercury emissions indicates the percentage reduction in annual SO2 from coal-fired units would be regulated nationwide emissions required by the IAQR in 2010 compared to For more information, contact under one of two options proposed for the “Mercury actual emissions during 2002. Doug Riedel at (816) 822-3391 Rule.” Compliance dates would be as early as or [email protected] December 2007 for Hg, depending on which option NOx: Figure 3 displays the percentage NOx reduction required by the IAQR in 2010 compared to actual prevails, and January 2010 for SO2 and NOx. Carl’s Corner 2002 emissions. A Substitute for Clear Skies? This issue explains how EPA will The proposed regulations would achieve some of the Emission Budgets implement, through edict, the same goals as the president’s Clear Skies plan, but SO2: State-by-state annual tonnage budgets for 2010 next generation of air pollution would not require action by Congress. The Mercury are based on a 50% reduction in existing total control standards for electric utilities. Seven years after Rule options both would achieve emission reductions statewide Acid Rain Program SO2 allowance issuing new NAAQS for PM2.5, similar to those in the latest version (see sidebar on allocations for the years 2010 and beyond. EPA is finally acting to address Page 2) of the Clear Skies Act of 2003. For 2015, the reduction is 65%. the nonattainment problem. The (See Figure 1). coordination of pollution control NOx: State-by-state annual budgets are based on plans in 29 states will provide Interstate Air Quality Rule emission rates of 0.15 lb/mmBtu for 2010 and 0.125 some regulatory consistency, The IAQR is a cap-and-trade program for SO and lb/mmBtu for 2015. The heat input for the and the cap-and-trade feature 2 will reduce overall cost to NOx to be implemented by the affected states. The calculation is the maximum aggregate annual heat input from all utility sources in the state for the industry. The IAQR could even emission reductions would occur in two phases, with be called “Clear Skies Light.” compliance dates in 2010 and 2015. period from 1999 through 2002. So if your facility is not in one Legal Basis Coordination with Existing Programs of the 29 states affected by the EPA is requiring certain states to reduce utility SO2 SO2: Within each affected state, the IAQR regulates IAQR, you have nothing to worry about except mercury, right? and NOx emissions in order to help alleviate ground the same set of sources as the existing Acid Rain level concentrations of PM2.5 (fine particulate mat- Program, yet requires additional SO2 reductions. ter) and ozone that currently exceed the National Wrong. As detailed in a prior To prevent the collapse of the current SO2 allowance issue of Clearing the Air, the Ambient Air Quality Standards (NAAQS) in 317 coun- market, the IAQR proposes to have the affected Regional Haze Rule will require many facilities in almost all of Figure 1 the remaining states to comply Comparison of the nationwide SO2, NOx, and mercury emission caps proposed by the Clear Skies Act, the IAQR, and the with stricter NOx and SO2 Mercury Rule. emission requirements. To see all prior issues, and to view expanded coverage of the topics 12 60 from this issue, go to www.burnsmcd.com/overview/clearair.html tons) 50

6 10 tons) ( Regulatory uncertainty is easing, 40 8 but by no means going away. 6 30 Please don’t hesitate to call me if you need help in deciphering 4 20 the ever-changing world of air pollution control. 2 10 Nationwide Emission Caps Caps Emission Nationwide

Nationwide Emission Caps (10 Caps Emission Nationwide 0 0 SO2 NOx Mercury Carl V. Weilert 2000 Emissions Clear Skies Act (2018) 1999 Emissions Clear Skies Act (2018) Manager, Air Pollution Control Clear Skies Act (2010) IAQR (2015) Clear Skies Act (2010) Mercury Rule - Op. 2 (2018) Burns & McDonnell IAQR (2010) Mercury Rule - Op. 2 (2010) Air Pollution Control for the 21st Century Issue 1, 2004

Figure 2 Figure 3 9400 Ward Parkway Kansas City, MO 64114 SO NOx Phone: 816 333-9400 2 Fax: 816 333-3690 < 50% 50-60% To receive future copies of 60-70% Clearing the Air >70% via e-mail, please send a request to [email protected] Note: Your e-mail address will be kept confidential.

Percentage reduction in 2002 annual emission required by the IAQR in 2010. Clear Skies Act Update states require the surrender of Acid Rain Program Option 2 allowances on a greater than 1:1 basis to offset emis- EPA rescinds its December 2000 On November 10, 2003, the latest sions starting in 2010. Pre-2010 vintage Acid Rain determination that mercury should be regulated version of President Bush’s Clear allowances would be used on a 1:1 basis. Allowances under §112(d) of the CAA and instead regulates it Skies Act was introduced to Congress with vintages 2010 to 2014 would be exchanged 2:1 under §111(d) as a combination of NSPS for new by Senator Inhofe (R-OK) and Senator to offset emissions. Allowance for years 2015 and sources and emissions guidelines for existing Voinovich (R-OH). This latest version beyond would be exchanged 3:1. sources. The NSPS limits would be the same as of the Clear Skies Act, S.1844, contains several significant changes the MACT limits for new sources in Option 1. The to S.485 as described below: NOx: States already covered by the NOx SIP call have emission guidelines for existing sources would be allowance trading programs in place for use during based on a cap-and-trade program designed to • The first phase (2010) mercury the five-month ozone season. Because the IAQR will achieve the same nationwide mercury emission caps emission cap is increased from extend NOx reduction requirements throughout the as Clear Skies: 34 tons in 2010 and 15 tons in 2018. 26 tons to 34 tons. year, NOx allowance allocations will need to increase correspondingly. Existing NOx allowances would be Relation to the IAQR • Minnesota and the western part useable for IAQR compliance. Option 1 requires the greatest mercury emission of Missouri are moved into the reduction from units burning bituminous coal. western NOx allowance trading Mercury Rule: Two Options Most bituminous coal-fired units are located in zone (Zone 2). Under the terms of a prior agreement, EPA was to states affected by the IAQR, and co-benefits of propose a Mercury Rule for electric utility units by mercury emission reductions would result from • The Zone 2 NOx allowances are December 15, 2003. Instead of proposing one rule, retrofit of FGD or SCR to units in that region for increased by 176,794 tons (from EPA chose to propose two options for mercury SO2 and NOx reduction. 538,000 tons to 714,794 tons) control. and the Zone 1 NOx allowances are To achieve Option 2’s nationwide mercury emission decreased by 88,397 tons (from Option 1 caps, EPA establishes mercury budgets for each 1.562 million tons to 1.474 million EPA establishes Maximum Achievable state. These budgets use a mercury allowance tons). Control Technology (MACT) standards in accordance allocation scheme based on apportionment by with §112(d) of the Clean Air Act (CAA). MACT limits adjusted historical annual heat input. Adjustment • S.1844 creates a pool of SO2, NOx, for mercury are based on fuel type or process type factors are 125% for subbituminous coal and 300% and mercury allowances each year and are expressed as either pounds per trillion Btu for lignite. So the burden of mercury reductions for new units, while S.485 did not. of heat input (lb/TBtu) or as pounds per megawatt- would fall mainly on bituminous coal-fired units, hour of gross electric generation (lb/MWh). All emis- which are located mainly in the IAQR affected states. • S.1844 eliminates the auction sion limits are 12-month rolling averages. EPA’s pro- system proposed by S.485 (S.1844 does not give increasing amounts posal includes provisions for mercury Continuous Monitoring Requirements of allowances auction status each Emissions Monitoring Systems (CEMS). The five sub- Because both options would require determination year as proposed in S.485). categories of electric utility units utilizing coal are: of 12-month rolling aveage mercury emissions from all coal-fired utility boilers, continuous emissions New • S.1844 gives incentives for early monitoring systems (CEMS) for mercury will be SO , NO , and mercury reductions, Subcategory Existing Sources Sources necessary. The rule establishes a Performance 2 x by Coal Type lb/TBtu or lb/MWh lb/MWh while S.485 did not. Specification for Hg CEMS. Bituminous 2.0 21 x 10-6 6 x 10-6 Subbituminous 5.8 61 x 10-6 20 x 10-6 Look to future issues of Lignite 9.2 98 x 10-6 62 x 10-6 Due to space considerations, we were forced to condense Clearing the Air for updates the mailed version of Clearing the Air. The document you on the status of multi-pollutant -6 -6 Coal Refuse 0.38 4.1 x 10 1.1 x 10 see posted here includes the deleted material. It is control legislation. IGCC 19.0 200 x 10-6 20 x 10-6 highlighted for your convenience.