1. Massachusetts’ Power Plant Mercury Regulations Sharon Weber Massachusetts Department of Environmental Protection WESTAR Fall Business Meeting - September 22, 2005 - San Diego, CA

2. September 22, 20052 Mercury Policy Context New England Governors/Eastern Canadian Premiers’ Regional Mercury Action Plan 50% reduction by 2003 75% reduction by 2010 Virtual elimination of anthropogenic discharges of mercury is long term goal MA Zero Mercury Strategy 75% reduction by 2010 Virtual elimination of anthropogenic discharges and use of mercury is long term goal

3. September 22, 20053 MA Hg Emissions: Point Sources Control efforts 2000 regs. 3X more stringent vs. federal 90-98% control Source separation regs. Control efforts: P2 Health care Products

4. September 22, 20054 MA Hg Emissions: Area Sources

5. September 22, 20055 Affected Facilities’ Contribution to Generation and Hg Emissions The 4 facilities subject to the power plant mercury regulations represent 8% of 2003 New England megawatts of generating capacity The 4 facilities emitted 17% of 2002 MA point source mercury emissions

6. September 22, 20056 Major Provisions Effective May 11, 2001 Standards Output-Based Emission Rates - SO 2, NO x, CO 2 Annual caps for CO 2 (tons) and Hg (lbs) Hg data collection for cap and 2003 proposed standard Hg control feasibility report by December 2002 Compliance schedules Dates depend on compliance approach standard path - 10/04 and 10/06 repowering path - 10/06 and 10/08 Hg cap effective at first compliance date

7. September 22, 20057 Mercury Standard Setting Process Regulation 310 CMR 7.29: Emissions Standards for Power Plants: promulgated May 11, 2001 http://www.mass.gov/dep/bwp/daqc/files/regs/7c.htm#29 Mercury coal/emissions baseline testing: 2001-2002 Stakeholder meetings: Aug/Sep/Oct 2002, Jan 2003 Feasibility Report: December 2002 http://www.mass.gov/dep/bwp/daqc/daqcpubs.htm#other Proposed regulation: September 2003 Final regulation: released May, effective June 4, 2004 http://www.mass.gov/dep/bwp/daqc/daqcpubs.htm#regs

8. September 22, 20058 Mercury Data Collection Sampling for concentration of mercury and chlorine in each shipment of coal received at the 4 coal-fired facilities from May 2001- August 2002 Sampling for concentration of speciated mercury at inlet (pre-ESP) and outlet (stack) of 8 coal-fired units (3 sets of tests in summer 2001, winter 2001-2002, and summer 2002)

9. September 22, 20059 Brayton 1 Emissions Test Results 250 MW, Bituminous Coal

10. September 22, 200510 Average Baseline Mercury Results by Unit

11. September 22, 200511 Mercury Control Feasibility Report – December 2002 “Evaluation of the Technological and Economic Feasibility of Controlling and Eliminating Mercury Emissions from the Combustion of Solid Fossil Fuel” 85-90+% removal of flue gas Mercury is feasible

12. September 22, 200512 Control Feasibility Report Technology Conclusions (1) Mercury controls are technologically feasible Some existing US power plant units are achieving up to 98% mercury removal Some MA power plant units are already removing close to 90% of mercury Controls to meet MA SO2 and NOx standards are expected to achieve mercury reduction co- benefits

13. September 22, 200513 Control Feasibility Report Technology Conclusions (2) Mercury controls are technologically feasible DOE field testing shows >90% mercury removal MA Municipal Waste Combustors are removing 90% of mercury; some ≥ 95% removal Extensive funding for research has resulted in mercury control technologies that have reached the field testing stage

14. September 22, 200514 Control Feasibility Report Economic Conclusions Mercury controls are economically feasible Sorbent-based mercury controls costs are similar to historically accepted NO x control costs (mills/kWh) Multi-pollutant regs (like MA’s) improve cost- effectiveness

15. September 22, 200515 Final Mercury Standard Effective June 4, 2004 Form of the standard Output-based and % control efficiency options Level of the standard Phase 1: 85% or 0.0075 lb/GWh by 1/1/2008 Phase 2: 95% or 0.0025 lb/GWh by 10/1/2012 Demonstrating compliance with the standard Every other quarter stack tests 10/06-1/1/2008 CEMs required beginning 1/1/2008 Averaging time of the standard Rolling 12-month basis

16. September 22, 200516 Media Transfer & Off-Site Mercury Reductions Facility mercury caps include mercury emissions due to on-site re-burn of ash or off-site high temperature processing in Massachusetts (e.g., use of ash in cement kiln or asphalt batching plant) Mercury standards must be met while including mercury emissions due to on-site re-burn of ash Units shutting down can use early or off-site reductions to 2010. Facilities emitting less than 5 lb in 2001 can use early or off site reductions to phase 2.

17. September 22, 200517 Expected Annual Reductions due to 2001 and 2004 Standards Mercury: 85% (about 155 pounds) SO 2 : 50-75% (about 56,000-84,000 tons) NO x : 50% (about 15,000 tons) CO 2 : 10% (about 1,954,000 tons, implemented on-site or off-site)