Mercury MACT Development for Coal-fired Power Plants

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					Mercury MACT Development
 for Coal-fired Power Plants

            A Presentation by the
           WEST Associates
                at the
    EPA’s HAPs MACT Working Group
      Washington DC, September 9, 2002
               Overview

• Introduction to WEST Associates
• Endorses Industry Recommendations, But
  WEST has Additional Concerns
• Mercury Emissions from Western Coal-fired
  Power Plants: Nature, Extent, and Fate
• Unique Western Concerns Related to the Role
  of Chlorine contents of Coal on Hg Emissions
• Recommendations
     Who is WEST Associates?
• 17 public and private electric utility companies
• Serves 15 million consumers in the rapidly-
  growing 11 Western states and North Dakota
• Played a constructive role since 1964 on energy
  and environmental issues in the West
   – 1990 Clean Air Act Amendments
   – Grand Canyon Visibility Transport
     Commission (GCVTC)
   – Western Regional Air Partnership (WRAP)
        Who is WEST Associates?
AZ Arizona Electric Power          NM Public Service Co of NM, Xcel
        Cooperative                   Energy and
   Pinnacle West Capital Corp.        Tri-State G & T
   Salt River Project              CO Colorado Springs Utilities
                                      Xcel Energy
   Tucson Electric Power Co.
                                      Platte River Power Authority
CA Glendale Public Service Dept.
                                      Tri-State G & T
   Los Angeles Dept. of Water      UT PacifiCorp/Utah Power and
        & Power                            Light
   Southern California Edison      WY PacifiCorp,
OR PacifiCorp                         Xcel Energy and
ID Idaho Power Company                Tri-State G & T
NV Nevada Power Co/ Sierra         ND Basin Electric Power
   Pacific Power Co
                  2000 Total Net Generation
                  (11 Western States & N.D)
      600,000,000
      500,000,000
      400,000,000
MWh




      300,000,000
      200,000,000
      100,000,000
              -
                      Regional Total   WEST Associates
                       546,876,357       306,602,803

                                              Source: EIA, Form 906, 2000
                  2000 Coal Net Generation
                  (11 Western States & N.D)
      250,000,000

      200,000,000
MWh




      150,000,000

      100,000,000

       50,000,000

              -
                      Regional Total   WEST Associates

                       237,509,837       197,787,790

                                              Source: EIA, Form 906, 2000
Western Representation on Working Group
• Western States are not represented on the
  Working Group
• Western utilities are not represented on the
  Working Group
• Western utilities believe that unique Western
  issues of Hg emissions, deposition, and air
  quality are not being adequately addressed
• WEST Associates appreciates its recent
  inclusion in Working Group’s activities
               Western Mercury Issues
• EPA’s “Regulatory Finding” in Dec. 2000 recognized
  the distinctly different Hg conditions in the West, stating
   – “EPA may also consider other relevant factors such as
     geographic conditions in establishing subcategories”
• Western coal has lower Hg, sulfur, and chlorine content
  resulting in lower Hg emissions, mostly as elemental Hg
• Western Hg emissions are less than 10% of Eastern Hg
  emissions in roughly the same size geographic area
• Western Hg deposition levels are significantly lower
  than in the East
Source: 1997 EPA Report to Congress
           Mercury Emissions from Power Plants: 1999
      120,000.00



      100,000.00



       80,000.00
lbs




       60,000.00



       40,000.00



       20,000.00



            0.00
                    National - lbs   % of total   11 Western States - lbs   % of total
      elemental       52,189.29        54%               6,814.13             85%
      ionized         40,816.99        43%               1,127.86             14%
      particulate     2,966.89          3%                92.62                1%
Figure 1. SO2 lb/MBtu vs. Hg0 at outlet of airheater derived from the EPA ICR data
                              100

                              90
  Percent Elemental Mercury


                              80
                              70
                              60

                              50
                              40

                              30
                              20

                              10
                               0
                                    10   100              1000                   10000
                                         Chlorine (ppm, mass)


Figure 3. Kinetic model output of percent Hg0 as a function of chlorine in the flue gas
(line) overlayed on ICR data (dots).
   Sub-categorization by Coal Rank
• Heat content and agglomeration-based ASTM method of
  coal ranking does not distinguish the magnitude and
  controllability of Hg emissions, or Hg species causing
  different public health and environmental impacts
• Same mine can produce coals of differing ranks (e.g.,
  Black Mesa in Arizona -- bituminous & sub-bituminous)
• Coal chlorine content affects controllability of Hg
  emissions and it should be taken into account when using
  ICR data to set MACT levels
• Hg control costs for Western coals are higher than those
  for Eastern coals at plants with PM and SO2 controls
    ICR Data Analysis/Hg Tests
• Our analysis of ICR data shows that coal rank,
  coal mercury content, and the ratio of coal
  mercury to chlorine content are the three most
  statistically significant factors to be considered
  in setting MACT levels
• Additional Hg characterization measurements
  have just been completed using Black Mesa coal
• Results from these tests and a comparison of
  results with ICR data will be available by the
  October 17 Working Group meeting
             Recommendations
• WEST Associates recommends that sub-categorization
  by coal rank be augmented with consideration of
  chlorine content of coal within coal rank
• Leaving out consideration of chlorine content in setting
  MACT levels may render Hg control efficiency data in
  the ICR database inappropriate in the case of Western
  coals
• WEST Associates would like to work with other
  stakeholders and EPA to develop appropriate
  adjustment factors to coal rank-based MACT levels to
  enable continued use of Western coal