Reducing Reducing Toxic Pollution Pollution from Powe

EPA’s Proposed Mercury and Air Toxics Stan

March 22, 2011
Overview of the Regulatory Action

• On March 16, EPA proposed Mercury and Air Toxics Standards, the first national s

reduce emissions of toxic air pollutants from new and existing coal‐ and oil‐fired p

often the biggest biggest contributors contributors to air pollution pollution

• Standards would reduce emissions of:

• Metals, including mercury (Hg), arsenic, chromium, and nickel

• Acid gases, including including hydrogen hydrogen chloride chloride (HCl) and hydrogen hydrogen fluoride fluoride (HF)• Particulate matter

• These pollutants are linked to cancer, IQ loss, heart disease, lung disease and prem

• S dd tan ards create uniform emi i ss ons‐control requirements b d ase on proven, curre

technologies and processes

• Compliance time line set by Clean Air Act: up to 4 years (3 years plus an additiona

by the permitting permitting authority) authority)

• EPA is also proposing a new source performance standard (NSPS) for particulate, 

(SO2), and nitrogen oxide (NOX) emissions from new sources
Toxic Emissions from Power Plants Are a

Serious Public Health Concern Concern• Power plants release mercury, arsenic, other metals, acid gases, and particles that 

people’s health.

• Uncontrolled releases of mercury from power plants damage children’s devel

reducing their IQ and their ability to learn

• Mercury and many of the other toxic pollutants also pollute our nation’s lakes

fish

• Other metals such as arsenic, chromium, and nickel can cause cancer

• Acid gases cause lung damage and contribute to asthma, bronchitis and other 

respiratory disease, especially in children and the elderly

• Particles cause premature death and a wide range of lung and heart diseases

• People who eat large amounts of fish from mercury‐contaminated freshwater lake

the U.S. are at the greatest risk of exposure

• This includes Native American, Laotian, Vietnamese, African‐American, Hispa

Caucasian subsistence fishers and their families

• The standards would also result in additional reductions of SO2, preventing thousa

and hundreds of thousands of illnesses each year 
Power Sector:

A Major Share of US Air Emissions

Nitrogen Oxides (NOx), 2009

15.3 Million Tons

2.0 Million Tons 

Sulfur Dioxide (SO2), 2009

9.5 Million Tons

Carbon D

6.5 B

j

OtherSector

OtherSectors

13.3 Million Tons

87%

13%

3.8 Million Tons

40%

ElectricPower

OtherSectors

Electric

Other emissions inclu

 Trace metals 

Particulate Matter (PM10), 2008 Mercury (Hg), 2005 105 T Electric

5.7 Million Tons

60%

3.9 Billion Tons

60%

Power

 Trace metals 

selenium and o HCl, HF Dioxin/furan Trace organic Others (e.g., 

14.8 Million Tons 105 TonsElectric Power

Electric

ElectricPower

53 Tons

50% 0.5 Million Tons 4%

 Radionuclide

Emissions have substaenvironment, and othimplications.

Power

OtherSectors

14.3 Million Tons

96%

OtherSectors

52 Tons

50%

Sources:NEI Trends Data (2009) and CAMD Data & Maps (2010) (SO2, NOX)

NEI Trends Data (2009) (PM10)

2005 NATA Inventory Modified for the Utility MACT 2005 Base Year (2010) (Hg)

Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990‐2008 (2010) (CO2)

“Other” sources include transportation, other mobile sources, and industrial sources
In the U.S., Power Plants Emit:

20% of the 

13% of the NOx

30% of

the nickel

60% of

the SO2

x

50

60% of 

the arsenic

organics,dioxins/furans,and others Sources: NEI Tren

IPM (2010) (SO2, rule modeling platfi t d f inventory used for 

Inventory used for toxics)
History of Clean Air Act Power Plant Controls for

Mercury/Air Toxics

• 1990 Clean Air Act Amendments created Acid Rain provisions and revised provisi

to require controls to reduce emissions of toxic air pollutants from industrial sou

• EPA was required to do a study within 3 y , ears and then list power plants for regu

air toxics provisions if the Administrator found that it was appropriate and neces

• 1998: EPA released Utility Toxics Study Report to Congress

• 2000: EPA listed power plants for regulation under the Clean Air Act air toxics pro

• Once listed, EPA had 2 years to issue an air toxics standard

• Mercury cited as pollutant of greatest concern but other toxics include arse

cadmium, nickel, hydrochloric acid, dioxin/furan

• 2005: Bush Administration EPA reversed 2000 finding, de‐listed power plants from 

under air toxics provisions, and finalized Clean Air Mercury Rule (CAMR) – allowi

• 2008: DC Circuit found the de‐listing to be illegal and vacated CAMR

• EPA must propose utility MACT standards by March 16, 2011, and issue fina

November 16, 2011, pursuant to a consent decree

• EPA’s proposed rule requires power plant controls for toxics, including mercury, t

p p q p p g y

2011 and require compliance by existing sources 3‐4 years later

• A quarter of a century will have passed since the 1990 Clean Air Act became 
Power Plants Are the Largest Remaining

Source of Mercury Mercury Emissions Emissions in the U.S.

• In 1990 three industry

categories made g 1990 2005 

approximately two‐thirds

of total U.S. mercury

emissions

– Two of the three are now

bj i i

Industrial Category

Emissions

tons per 

year (tpy)

Emissions

(tpy)

subject to air toxics

standards

– So are many other

industries such as cement

plants and steel

Power Plants 59 53 Municipal W t 57 2 

pmanufacturers

• Today, 20 years after the

1990 CAA Amendments

d Fd l li i f

Waste 

Combustors

57 2 

Medical Waste 51 <1 

passed, no Federal limit fortoxic emissions – including

mercury – exists for coal‐

or oil‐fired power plants

IncineratorsSource: EPA’s 2005 NATA Inventory Modified for the ToxYear (2010) 
Affected Facilities: 1,350 Coal and

Oil‐Fired Units at 525 Power Plants• Approximately 1,200 coal-fired units

• 45% p yg ercent of nationwide electricity generation

• Bituminous coal ~ 50% of coal generation• Subbituminous ~45% of coal generation• Lignite ~ 5% of coal generation

• Includes units that burn coal, coal refuse, or a 

synthetic gas derived from coal or solid oil (e.g. petroleum coke) either exclusively, in any 

combination together or in any combination with combination together, or in any combination with

other supplemental fuels (e.g., tire-derived fuels)

• Approximately 150 oil-fired units

• 1% of nationwide electricity generation

• Natural gas power plants are not affected by this rule• EPA expects most facilities would install technologies to 

comply with this rule
Location of Coal‐ and Oil‐Fired Power Plan

Source: National Electric Energy Data System (NEEDS 4.10) (EPA, December 2010) 
What the Toxics Rule Proposes

• Coal‐ and oil‐fired power plants are covered by this rule

• All hazardous air pollutants must have standards

• EPA must set emi i ss on st dd an ar s for exi ti s ng sources in the categ

are at least as stringent as the emission reductions achieved by t

average of the top 12% best controlled sources for source catego

30 or more sources sources

• Requirements for Coal‐Fired Units

– Mercury: numeric emission limit would prevent 91% of mercury in 

b i e ng rel d ease to the air

– Acid Gases: HCl numeric emission limit as a surrogate, with an alte

surrogate of SO2

– Non‐mercury mercury metallic metallic pollutants pollutants (e g. ., arsenic arsenic, chromium): chromium): numer

numer

limit for total PM as a surrogate, with an alternate surrogate of tota

toxics

– Organic air toxics ( g including dioxin/ ) furans): work practice standard

of numeric emission limits, due to low‐detected emission levels in t

data. Would ensure optimal combustion preventing dioxin/furan e
What the Toxics Rule Proposes (cont.)

• Requirements Requirements for Oil‐Fired Units

– Acid Gases: HCl and HF numerical emission limits

– Metal Air Toxics: numerical emission limits for total metal air toxic

mercury) mercury) with individual individual metal air toxic numerical numerical limits as an alter

alter

– Organic air toxics (including dioxin/furans): work practice standard

of numeric emission limits, due to low‐detected emission levels in t

data. Would ensure optimal combustion p g reventing dioxin/furan e

• Emissions averaging within a contiguous facility is allo

• Monitoring Requirements

– Hg CEMS or sorbent traps for mercury– HCl CEMS or SO2 CEMS for acid gases

– PM CEMS for metals

– Emissions testing, parameter monitoring, and fuel analyses allowed 

and acid gases

– Thirty day averaging period for monitoring accommodates process 

and, coupl de with CEMS, f ilit t acilitates compliance

– Records of work practice standards (annual tune ups) are proposed 

HAP emissions 
Emissions from Covered Sources

5 8

7

SO2 Emissions

52.9 60

Hg Emissions

5.8

3.8 3.7 3.5

1.7 1.7 1.7 2

3456

Million Tons

52.9

29.1 29.4 

20304050

Tons

Th b i ld th T t R l 

1.7 1.7

012

2009 2015 2020 2030

M

6.4 

0

10

20

2005 2015 20

► The base case includes the Transport Rule 

other existing federal and state controls aagreements.

► Emission totals presented here reflect all 

IGCC electric generating units > 25 MW.Th li i d HCl 

351.6

250300350400

ons

HCl Emissions

► The policy case imposes mercury and HCl 

limitations on these units, and requires faof those units.

► The mercury content of the coal consume

EGUs > 25 MW is 75 tons in 2015; emissio

under the Toxics Rule represent more tha

74.4 70.8 64.8

6.6 6.9 7.2

0

50

100150200

250

ThousandTo

Note: Historic HCl emissions based on single emission factor; projected

emissions based on fuel‐specific Cl assumptions and removal efficiencies.

under the Toxics Rule represent more thathat mercury.

0

2005 2015 2020 2030
Sources Can Achieve These Standards

• Proven control technologies to reduce these emissions such as scrubbers, 

and activated carbon injection are widely available

• Many units already use one or more of these technologies• As a result of this standard, some power plants will upgrade existing contro

particulate matter controls like electrostatic precipitators)

• Power plants may also install new controls (such as fabric filters, dry sorbe

activated carbon injection) activated carbon injection)

243 250

300350

GW)

BaseProposed Toxics Rule

Retrofit pollution coon coal-fired capactechnology) with the with the proposed T

174

141

53

77

175

54 65

146 146

100150200250

2015 Capacity(G(measured in GW c

Integrated Planning EPA, 2011

FGD: flu gas desu

(scrubber)

29

9

0

50

Wet FGD Dry FGD DSI SCR ACI FF

2( )

DSI: dry sorbent inSCR: selective catACI: activated carFF: fabric filter

FGD 96% SO l 99% HCl l DSI 70% SO l 90% HCl lFGD – 96% SO2 removal; 99% HCl removal DSI – 70% SO2 removal; 90% HCl removalSCR – 80% NOx removal ACI – 90% Hg removalFF – PM control
Cost and Retirement Projections

► Private compliance costs to utilitie

the overall social cost of the policy

costs depicted are increased costs 

$15 electric generation system through

Incremental Compliance Cost for the

Power Sector

electric generation system through

► Incremental retired coal capacity in 

GW. Also, it is important to recogn

► EPA identified about 11 GW 

$10.9 $10.1 $10.0

$5

$10

$15

Billions $2007 ► EPA identified about 11 GW 

announced for 2010‐2015 th

from modeling

► EPA modeling suggests forec

prices alone close about 4 GW 

$0

2015 2020 2030

B

capacity in 2015 in the base 

Rule may close an additional 

► Toxics Rule and Transport Ru

together close 11 GW of coa

Cl di ib d h 

9.87

1015

W)

Incremental Retired Capacity in 2015

2015 Capacity

(before retirements)

► Closures are distributed thro

‐0.18 ‐0.46 ‐0.77

05

Capacity (GW

Total: 1,028 GW

Coal Steam & IGCC: 314 GW

‐5

Coal Steam CC CT Nuclear
Average Consumer Electricity Price Projections

150

h

Average National Retail Electricity Price

Base Proposed Toxics Rule

140160

2015 Retail Elect

Base Proposed T

90 89

102 93 92 104

50

100

07‐year mills/kWh

406080

100120

140

2007 mills/KWh

National average increase of 3.7% in 2015 that

0

2015 2020 2030

200

0

20

declines over time

100120140160

KWh

2020 Retail Elect

Base Propose

0

20406080

100

2007 mills/K
Generation and Capacity Projections

0.29 0.29

0 25 0 25 0.29 0.29

0.33 0.33

45 Generation Mix Other

Oil 

10

Incremental New 

Natural Gas CC Wind 

2.00 1.96 2.02 1.98 2.06 2.01

0.83 0.83 0.83 0.84 0.81 0.820.69 0.73 0.83 0.87 1.16 1.21 0.29 0.29 0.29 0.29 0.25 0.25

1234

Million GWhNon‐Hydro Renewables Hydro Natural Gas

N l

0 02

0.08

468

Capacity (GW)

Natural Gas CC Wind 

1.96 1.98

01

Base Tox R Base Tox R Base Tox R

NuclearCoal

2015 2020 2030

2.77

0.02

0.02

02

2015 2020 

C

► Coal‐fired generation is slightly reduced as a result of the proposed rul► Increase in demand is met largely with additional natural gas‐fired gen► IPM results suggest that the sector will be able to comp yl with the Tox

relying primarily on existing generating assets

► Overcapacity at existing combined cycle units responds to displace

in 2015

► An additional 8 GW of new capacity is projected by 2030 relative t

case, most of which is natural gas combined cycle.
Impacts on Coal Consumption and Natural Gas

• Coal use from major region

from the proposed Toxics R

increase in use of interior co

Th i i i bi

183 168 174 165 154 153

30 30 37 37 38 38

800

1,0001,200

s

Power Sector Coal Use

Imports Waste Coal Appalachia Interior West

• There is some increase in bi

and decline in other coal typ

942

551 543 557 553 599 567

227 233 239 228 240 252

200400600800

Million Ton

C l U b R k

0

Base Tox R Base Tox R Base Tox R

• Natural gas consumption is 

3‐6 percent by the power sect

• Over this time “delivered” na

7,762 7,668 7,984 7,885 8,599 8,073

904 609 1,059 651 718 657

15,00020,00025,000

Btu

Coal Use by Rank

Lignite Subbituminous Bituminous

• Over this time, delivered na

power sector and at Henry Huhave an average increase less million Btus, about 1.3 percen

• Over this time residential con

11,450 11,628 11,297 11,547 11,440 11,703

0

5,000

10,000

Trillion

• Over this time, residential con

an average price increase of le

0

2015 Base2015 Tox R2020 Base2020 Tox R2030 Base2030 Tox R
Proposed Toxic Rule Health Benefits

• The value of the improvements to health alone total $59 billion to $140 b

year

• This means that for every dollar spent to reduce this pollution pollution, we would 

in health benefits

• Each year, the proposed rule would prevent serious health effects includi

– 6 800 , ‐17 000 , premature premature deaths– 11,000 heart attacks

– 120,000 asthma attacks

– 850 000 850,000 mi d sse work or “ i k” s c days

• Avoiding “sick days” saves companies and families money. It is particularl

for the millions of Americans whose jobs do not provide paid sick leave a

losing their jobs if they miss work too often

– The proposed rule would also prevent 12,200 hospital admissions and em

room visits; 4,500 cases of chronic bronchitis; and 5,100,000 days when p

restrict their activities each year

Source: EPA Regulatory Impact Analysis
The Toxics Rule: Implementation

• When we compare the investments that will be required to comply wi

standards with investments that this same industry has made in the p

not look out of line.

– In each of 2007 through 2010, over 20 GWs of advanced pollution control 

installed. This includes a peak of over 35 GWs of scrubbers and SCRs in 2

• The act contains key flexibilities such as providing permitting agencies 

discretion to provide one‐year extensions (beyond the general three y

frame for compliance required by the Act) that will be key to addressin

specific concerns.

• While we project some retirements of old/inefficient and less frequen

fired generation, generation, the large amounts amounts of extra generating generating capacity capacity that c

c

will be key to being able to ensure reliable electricity (NERC default re

are 15%, absent the rule, average capacity margins are about 25%).
Public Hearings and Comment

• The public is encouraged to provide EPA with comment

proposed Toxics Rule

• The Agency will seek comments for 60 days following publicat

Federal Register and the proposed rule is currently available o

website.

• Public Hearings

• Locations

• Philadelphia Philadelphia, PA (EPA Region 3 Headquarters) Headquarters)• Atlanta, GA (EPA Region 4 Headquarters)

• Chicago, IL (EPA Region 5 Headquarters)

• For more information on how to attend these public hearing ,s 

http://www.epa.gov/airquality/powerplanttoxics

• Technical Contact:

• Bill Maxwell Maxwell (919‐541‐5430, maxwell bill@epa gov) maxwell.bill@epa.gov)
Summary – Bottom‐Line

• This proposed proposed rule will result in tremendous tremendous public health benefits benefits, wo

times the cost.

• The rule will require require the power sector to invest in commercially commercially availab

availab

effective, proven technology. That investment will provide jobs for ten

thousands of Americans during a period of high unemployment, create 

for products like cement, that are experiencing low demand, and creat

modern clean A i mer can power sector.

• This rule has been long delayed. It is important for public health, that t

we issue conform conform to the dictates dictates of the Clean Air Act as interpreted interpreted by 

so that it will withstand a judicial challenge.

Thank