1 mercury emissions rules overview of hoosier environmental council’s petition and epa’s utility...

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Mercury Emissions RulesMercury Emissions Rules

Overview of Hoosier Environmental Council’s Overview of Hoosier Environmental Council’s Petition Petition

and and EPA’s Utility Mercury RuleEPA’s Utility Mercury Rule

Robin Mills Ridgway, PhD. P.E.Robin Mills Ridgway, PhD. P.E.Purdue University Physical Facilities Purdue University Physical Facilities

Environmental Regulatory ConsultantEnvironmental Regulatory Consultant

[email protected]@purdue.edu

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OverviewOverview

Rule language and motivationRule language and motivation What is known about mercury and What is known about mercury and

chlorine in coals nationallychlorine in coals nationally What is known about mercury and What is known about mercury and

chlorine in Indiana coalschlorine in Indiana coals The problem of variabilityThe problem of variability EPA’s mercury ruleEPA’s mercury rule SummarySummary

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Coal’s Role in Energy ProductionCoal’s Role in Energy Production

From ABEC (http://www.balancedenergy.org/state/in.asp)

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Motivation:Motivation: HEC’s proposed mercury rule language includes HEC’s proposed mercury rule language includes

Purdue (recent word from IDEM indicates that the Purdue (recent word from IDEM indicates that the petition’s scope may have changed)petition’s scope may have changed)– ““Coal Fired Electric Utility”: Title V permit, generate Coal Fired Electric Utility”: Title V permit, generate

electricity, >10% heat input from coalelectricity, >10% heat input from coal– 0.6 lb/TBtu or 90% reduction by 20080.6 lb/TBtu or 90% reduction by 2008– Compliance demonstrated with mercury CEMS Compliance demonstrated with mercury CEMS

(continuous emission monitoring system) (continuous emission monitoring system) In addition, Purdue’s boilers are subject to “Boiler In addition, Purdue’s boilers are subject to “Boiler

MACT” containing a mercury limit of 9 lb/TBtuMACT” containing a mercury limit of 9 lb/TBtu Purdue University burns Indiana coal.Purdue University burns Indiana coal. First homework assignment on the path to Boiler First homework assignment on the path to Boiler

MACT compliance by September 2007: MACT compliance by September 2007: understand our fuelunderstand our fuel

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Coal in the Wild #1:Coal in the Wild #1: Coal deposited in a stream system; note trees for scaleCoal deposited in a stream system; note trees for scale

Courtesy K.D. Ridgway, Purdue University

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Coal in the Wild #2:Coal in the Wild #2: Coal deposited in a stream environment; person for scaleCoal deposited in a stream environment; person for scale

Courtesy K.D. Ridgway, Purdue University

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Mercury in CoalMercury in Coal Where in coal does mercury occur?Where in coal does mercury occur?

The primary association is in pyrite, as The primary association is in pyrite, as indicated by indirect leaching studies, direct indicated by indirect leaching studies, direct determinations by microanalysis, and determinations by microanalysis, and limited XAFS data.limited XAFS data.

What other forms can be present?What other forms can be present? Include an organic association, and in some Include an organic association, and in some unusually mercury-rich coals, HgSe unusually mercury-rich coals, HgSe (tiemannnite), HgS (cinnabar), and even (tiemannnite), HgS (cinnabar), and even native mercury.native mercury.

Slide courtesy Allan Kolker, USGS

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NEXT:NEXT:Several very distilled, Several very distilled,

simplified, summarized, simplified, summarized, organized depictions of the organized depictions of the mercury (and other stuff) mercury (and other stuff) content of coals in the US content of coals in the US

probably prepared by a probably prepared by a control-freak engineer like mecontrol-freak engineer like me

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But First: A Primer on Units of But First: A Primer on Units of MeasurementMeasurement

““ppm”:ppm”:– ““parts per million”; parts per million”; – one part per million parts, one part per million parts, – a very dry martini -1 drop of vermouth per 16 gallons of a very dry martini -1 drop of vermouth per 16 gallons of

gin gin ““lb/TBtu” or “lb Hg/10lb/TBtu” or “lb Hg/101212 btu”: btu”:

– lb Hg/10lb Hg/101212 btu = lb Hg/1,000,000,000,000 btu btu = lb Hg/1,000,000,000,000 btu– Pounds per trillion BtuPounds per trillion Btu– One pound of coal has approximately 11,000 Btu; 2000 One pound of coal has approximately 11,000 Btu; 2000

lbs of coal per tonlbs of coal per ton– HEC’s proposed 0.6 lbs/TBtu is 0.6 lb per 46,000 tons of HEC’s proposed 0.6 lbs/TBtu is 0.6 lb per 46,000 tons of

coalcoal Therefore: 0.6 lb Hg/TBtu ≈ 0.0066 ppm Hg Therefore: 0.6 lb Hg/TBtu ≈ 0.0066 ppm Hg

in the coalin the coal

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COALQUAL mercury loadings for selected U.S. coal regions. Mercury and Btu/lb calculated to as-received (moisture containing) basis.

Courtesy Allan Kolker, USGS

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USGS COALQUAL DATA (mean = 0.17 ppm; median = 0.11;

standard deviation = 0.17)n = 7,430

[One outlier is removed]


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Take home message:Take home message:

Mean of 0.17 ppm is 26 times the limit proposed by HEC

Therefore a source burning “mean”, or average, quality coal would have to reduce mercury emissions by 96% to meet 0.6 lb/TBtu

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Comparison of Average Mercury Comparison of Average Mercury Concentrations in Coal Concentrations in Coal (courtesy EERC)(courtesy EERC)

0

0.02

0.04

0.06

0.08

0.1

0.12

0.14

AppBit.

Int Bit. West.Bit.

W. Sub. FU Lig. GulfLig.

Mer

cury

, p

pm

0

2

4

6

8

10

12

14

Mer

cury

, lb

/TB

tu

Hg, ppm

Hg, lb/TbtuLimit proposed by HEC

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Comparison of Average Comparison of Average Coal CharacteristicsCoal Characteristics

0

5000

10,000

15,000

20,000

25,000

30,000

35,000

App.Bit.

Int. Bit. West.Bit.

W.Sub.

FU Lig. GulfLig.

Ca

an

d F

e, p

pm

, dry

02004006008001000120014001600

Cl,

pp

m, d

ry

Ca, ppm

Fe, ppm

Cl, ppm

(slide courtesy EERC)(slide courtesy EERC)

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Mercury Variability in Coal BedsMercury Variability in Coal Beds

Mercury content of coals can vary by coal Mercury content of coals can vary by coal basin, by rank, and within individual beds.basin, by rank, and within individual beds.

Within coal beds, zones that greatly exceed Within coal beds, zones that greatly exceed mean values tend to be localized.mean values tend to be localized.

Distribution of mercury reflects geologic Distribution of mercury reflects geologic processes, such as fluid migration, that processes, such as fluid migration, that operate on various scales, and can occur in operate on various scales, and can occur in the peat stage, during coalification, and/or the peat stage, during coalification, and/or post-date coal formation.post-date coal formation.


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Mercury Levels in U.S. Coals Mercury Levels in U.S. Coals (courtesy EERC)(courtesy EERC)

J.C. Quick, T.C. Brill, and D.E. Tabet, Mercury in US coals: observations using COALQUAL and ICR data, Environmental Geology (2003) 43:247-259.

Take home messages:1. ICR data represents only a subset of all coal2. Note variability

HEC’s 0.6 lb/TBtu

How to read the box plot

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Comparison ofComparison of USGS and EPA ICR Data SetsUSGS and EPA ICR Data Sets

EPA ICR database reflects mercury EPA ICR database reflects mercury content of commercial coals delivered content of commercial coals delivered in 1999 to U.S. power plants in 1999 to U.S. power plants 25 MW. 25 MW.

USGS database includes data for USGS database includes data for about 40 elements and many coal-use about 40 elements and many coal-use parameters.parameters.

SubsetsSubsets11 give averages of give averages of 0.10 ppm0.10 ppm for ICR and for ICR and 0.17 ppm0.17 ppm for COALQUAL. for COALQUAL.

1 Quick et al. , 2003, Environmental Geology


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So, what about Mercury in So, what about Mercury in Indiana Coal?Indiana Coal?

M. Mastalerz, et al., 2004

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Mercury in Indiana Coal Mercury in Indiana Coal vs. vs.

US TotalUS Total


HEC’s proposed limit= 0.0066 ppmthus requiring 94% reductionfor sources burning Indiana coal

2020

Chlorine Content of Indiana CoalsChlorine Content of Indiana Coals


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Chlorine in Indiana Coal Chlorine in Indiana Coal vs. vs.

US TotalUS Total


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Mercury Variabilty Through Danville Coal Seam at the Farmersburg Mine in Indiana

(data from M. Mastalerz, et al., 2004)

0 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.1 0.11 0.12 0.13

0 - 33

33 - 69

69 - 96

96 - 117

Sam

ple

dep

th (

cm)

Concentration (ppm)

Mercury (ppm)

HEC’s proposal

Indiana Average

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Summary (for geologists)- Mercury Summary (for geologists)- Mercury in Coalin Coal

Mercury content of coal varies by coal basin, by rank, Mercury content of coal varies by coal basin, by rank, and within individual coal beds. Variation is a and within individual coal beds. Variation is a consequence of geologic processes.consequence of geologic processes.

Pyrite (FeSPyrite (FeS22) is the primary host for mercury in ) is the primary host for mercury in bituminous coals. An organic association is common bituminous coals. An organic association is common in some low-rank coals.in some low-rank coals.

Averages: 0.17 ppm Hg for in-ground coals (USGS Averages: 0.17 ppm Hg for in-ground coals (USGS COALQUAL database); 0.10 ppm Hg for coals COALQUAL database); 0.10 ppm Hg for coals delivered to U.S. coal-fired power stations.delivered to U.S. coal-fired power stations.

Mercury loading is a function of mercury content and Mercury loading is a function of mercury content and calorific value. Coals should be compared on a calorific value. Coals should be compared on a common energy-equivalent basis.common energy-equivalent basis.


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Summary (for the rest of us): Summary (for the rest of us): Mercury in CoalMercury in Coal

Why not buy coal with low mercury content?Why not buy coal with low mercury content?– Coal-fired units are designed based upon specific fuel Coal-fired units are designed based upon specific fuel

characteristics, therefore switching coal types is not an optioncharacteristics, therefore switching coal types is not an option Mercury content is not the only variable in choosing a fuel: Mercury content is not the only variable in choosing a fuel:

cost, availability, sulfur, and heating value are key.cost, availability, sulfur, and heating value are key. Fuel variability must be taken into account when Fuel variability must be taken into account when

considering regulatory schemes.considering regulatory schemes. Wide margins of error must be built into pollution control Wide margins of error must be built into pollution control

designs. designs.

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What About EPA’s What About EPA’s Mercury Rule?Mercury Rule?

The Clean Air Mercury Rule The Clean Air Mercury Rule (“CAMR”)(“CAMR”)

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Timeline to Federal Mercury Timeline to Federal Mercury RegulationRegulation

1998 – EPA issued Information Collection Request 1998 – EPA issued Information Collection Request (ICR) to utilities(ICR) to utilities

1999 – Data collection for ICR1999 – Data collection for ICR– EPRI later developed Hg emission prediction correlations EPRI later developed Hg emission prediction correlations

from 88 units tested and coal samples taken from all from 88 units tested and coal samples taken from all unitsunits

2000 – EPA decides to regulate utilities under 2000 – EPA decides to regulate utilities under MACTMACT

2002 – Utility MACT working group met 14 times 2002 – Utility MACT working group met 14 times from August 2001 to March 2003from August 2001 to March 2003

2003 – EPA proposed draft rule issued on 2003 – EPA proposed draft rule issued on December 15December 15

2005 – EPA to issues final rule mid March2005 – EPA to issues final rule mid March 2010 – Mercury compliance begins for utilities2010 – Mercury compliance begins for utilities

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Final CAMR OverviewFinal CAMR Overview Establishes cap-and-trade program under Establishes cap-and-trade program under

CAA §111 for new and existing sourcesCAA §111 for new and existing sources Cap of 38 tons/year in 2010 and cap of 15 Cap of 38 tons/year in 2010 and cap of 15

tons/year in 2018tons/year in 2018 EPA justifies phase 2 due to new sources EPA justifies phase 2 due to new sources

having control requirements and push for having control requirements and push for new technology, with U.S. role as world new technology, with U.S. role as world leaderleader

Unlimited banking allowedUnlimited banking allowed New sources are subject to cap-and-trade New sources are subject to cap-and-trade

rulerule

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CAMR Overview (continued)CAMR Overview (continued) Establishes “standards of performance”:Establishes “standards of performance”:

– New units: emission rate standardNew units: emission rate standard– Existing units: cap-and-trade programExisting units: cap-and-trade program

Builds on CAIR to allow power industry to address Builds on CAIR to allow power industry to address Hg, SOHg, SO22 and NOx in coordinated effort and NOx in coordinated effort

EPA projects annual costs to the power industry of EPA projects annual costs to the power industry of $160 million in 2010, $100 million in 2015, and $160 million in 2010, $100 million in 2015, and $750 million in 2020 ($1999)$750 million in 2020 ($1999)

EPA projects annual benefits of approximately EPA projects annual benefits of approximately $0.2 million to $3 million through 2020 ($1999)$0.2 million to $3 million through 2020 ($1999)

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CAMR TimelineCAMR Timeline October 31, 2006: initial state allocation October 31, 2006: initial state allocation

decisions to EPAdecisions to EPA November 17, 2006: state programs due November 17, 2006: state programs due

to EPAto EPA January 1, 2009: emissions January 1, 2009: emissions

monitoring/reporting begins (plants in monitoring/reporting begins (plants in operation before July 1, 2008)operation before July 1, 2008)

January 1, 2010: Phase 1 cap-and-trade January 1, 2010: Phase 1 cap-and-trade program beginsprogram begins

January 1, 2018: Phase 2 cap-and-trade January 1, 2018: Phase 2 cap-and-trade program beginsprogram begins

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Mercury Rule Compliance: Mercury Rule Compliance: Issues to ConsiderIssues to Consider

Whether Boiler MACT, Indiana Mercury Whether Boiler MACT, Indiana Mercury Rule (HEC petition), and/or CAMR, issues Rule (HEC petition), and/or CAMR, issues are the same:are the same:– Coal properties (e.g., chlorine content) impact Coal properties (e.g., chlorine content) impact

potential Hg capture performancepotential Hg capture performance– Significant variability in baseline Hg capture of Significant variability in baseline Hg capture of

existing pollution controls has been observedexisting pollution controls has been observed– The mercury capture “darling”: Activated The mercury capture “darling”: Activated

Carbon Injection effectiveness depends on coal Carbon Injection effectiveness depends on coal type and plant configurationtype and plant configuration

– More long-term evaluation of ACI is necessary More long-term evaluation of ACI is necessary to determine realistic cost and performance to determine realistic cost and performance estimates for various plant arrangementsestimates for various plant arrangements

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Mercury Rule Compliance: Mercury Rule Compliance: Issues to Consider (continued)Issues to Consider (continued)

– Uncertainties remain regarding capture Uncertainties remain regarding capture effectiveness with various coal ranks and effectiveness with various coal ranks and existing pollution control configurations, existing pollution control configurations, balance-of-plant impacts, and byproduct use balance-of-plant impacts, and byproduct use and disposaland disposal

– Baseline Hg capture performance for lignite Baseline Hg capture performance for lignite and PRB coal-fired plants with ESP or SDA/FF is and PRB coal-fired plants with ESP or SDA/FF is relatively low and untreated ACI performance relatively low and untreated ACI performance is limitedis limited

– Hg capture may be enhanced through addition Hg capture may be enhanced through addition of halogens via coal blending, coal additives, or of halogens via coal blending, coal additives, or use of chemically-treated activated carbonuse of chemically-treated activated carbon

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……and just when you think the rules and just when you think the rules are final and you can get on with are final and you can get on with

compliance…compliance…

here come the lawyers…here come the lawyers…

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The CAMR Litigation Landscape:The CAMR Litigation Landscape:

Numerous challenges to both §112 Numerous challenges to both §112 Revision decision and CAMRRevision decision and CAMR

Several environmental groups requested a Several environmental groups requested a stay on §112 Revision decision – denied by stay on §112 Revision decision – denied by CourtCourt

14 States have sought review of §112 14 States have sought review of §112 Revision decision in D.C. CircuitRevision decision in D.C. Circuit

14 States have challenged CAMR14 States have challenged CAMR 6 states filed in support of EPA6 states filed in support of EPA Court decision(s) likely in late 2006 or Court decision(s) likely in late 2006 or

early 2007early 2007

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SummarySummary

Various layers of regulations to consider:Various layers of regulations to consider:– For utilities, CAMR and Indiana Mercury RuleFor utilities, CAMR and Indiana Mercury Rule– For non-Utilities, Boiler MACT and Indiana For non-Utilities, Boiler MACT and Indiana

Mercury RuleMercury Rule Complex issues regarding fuel Complex issues regarding fuel

characteristics and control technologiescharacteristics and control technologies Potential impacts on mining and Potential impacts on mining and

reclamation cannot be discountedreclamation cannot be discounted

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Many Thanks to:Many Thanks to: Allan KolkerAllan Kolker, U.S. Geological Survey, Eastern Energy , U.S. Geological Survey, Eastern Energy

Resources Team, Reston, VA 20192Resources Team, Reston, VA 20192

Energy and Environmental Research CenterEnergy and Environmental Research Center (EERC); (EERC); http://www.eerc.und.nodak.edu/http://www.eerc.und.nodak.edu/

Maria MastalerzMaria Mastalerz (Indiana Geologic Survey), A. Drobniak, (Indiana Geologic Survey), A. Drobniak, G. Filipelli: “Distribution of Mercury in Indiana Coals and G. Filipelli: “Distribution of Mercury in Indiana Coals and Implications for Mining and Combustion, Final Report to the Implications for Mining and Combustion, Final Report to the Indiana Department of Commerce, July, 2004 Indiana Department of Commerce, July, 2004 ((http://igs.indiana.edu/http://igs.indiana.edu/))

Dr. Kenneth D. Ridgway, Purdue University Department of Dr. Kenneth D. Ridgway, Purdue University Department of Earth and Atmospheric SciencesEarth and Atmospheric Sciences

Gary Spitznogle, AEP, Advanced Technology and ControlGary Spitznogle, AEP, Advanced Technology and Control

1 mercury emissions rules overview of hoosier environmental council’s petition and epa’s utility...

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