Mercury Monitoring by States. Robert Vollaro U.S. EPA Clean Air Markets Division (May 2009). Background. In May 2005, EPA published the Clean Air Mercury Regulation (CAMR)
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In May 2005, EPA published the Clean Air Mercury Regulation (CAMR)
CAMR provided a model rule for a mercury (Hg) cap-and-trade program, to be implemented in all 50 States, beginning on January 1, 2009. The regulation applied to all coal-fired EGUs that serve a generator > 25MW
CAMR required continuous monitoring of total vapor phase Hg for most affected units. Either Hg CEMS or sorbent trap monitoring systems could be used to meet this requirement.
In support of CAMR, mercury mass emissions monitoring provisions were added to 40 CFR Part 75.
However, the CAMR rule was challenged, and in 2008, the rule was vacated by the DC Court of Appeals.
An EPA appeal for a rehearing was denied, and the DC Court issued a mandate, effectively terminating the regulation.
Although the Court did not specifically address the Hg monitoring provisions of Part 75 in its decision to vacate CAMR, the opinion of EPA’s Office of General Counsel is that these provisions were also vacated.
We understand that at least 20 States presently have or plan to have Hg control regulations:
The 20 states are Massachusetts, New Jersey, Illinois, New York, Minnesota, Connecticut, Pennsylvania, Delaware, New Mexico, Georgia, Montana, Colorado, Iowa, Nevada, North Carolina, New Hampshire, Maryland, Utah, Wyoming and Oregon
At least 13 States also plan to incorporate continuous monitoring requirements into their rules:
The 13 states are Oregon, Massachusetts, Illinois, Colorado, Georgia, Florida, New York, Oklahoma, Delaware, Nevada, Maryland, Wyoming and New Mexico
Some State rules are requiring only periodic Hg emissions tests, rather than continuous emission monitoring (e.g., Iowa)
However, EPA encourages all States to consider requiring continuous monitoring (except perhaps for very small, low-emitting sources) to ensure continuous compliance, rather than relying on infrequent, short-duration data from stack tests
Soon after the NESCAUM protocols were posted, the National Association of Clean Air Agencies (NACAA) announced to all States the availability of the protocols. NACCA suggested that States should consider using the protocols to develop their own Hg monitoring rules.
So far, EPA is aware of only one State (Massachusetts) that has embraced the NESCAUM protocols. Massachusetts is incorporating the bulk of the Hg CEMS and sorbent trap protocols into their Hg rule, with a few modifications tailored to the needs of their program. The State is not allowing sources to use the low mass emissions alternative methodology.