1. Massachusetts Multi-pollutant Power Plant Regulations Sharon Weber Massachusetts Department of Environmental Protection EPA Utility MACT Working Group – March 4, 2003 –Washington DC

2. Background of regulation 310 CMR 7.29: Emissions Standards for Power Plants • http://www.state.ma.us/dep/bwp/daqc/files/regs/7c.htm#29 • Mercury coal and emissions testing results • Mercury control feasibility report • Mercury standard-setting process

3. Environmental Concerns • Acid Deposition • Climate Change • Mercury • Nitrification, Eutrophication • Ozone • PM 2.5 • Regional Haze • Visibility

4. Capacity Context

5. Major Provisions Effective May 11, 2001 • Standards • Output-Based Emission Rates - SO2, NOx, CO2 • Annual caps for CO2 (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 • Proposed compliance date for Hg standard will be October 1, 2006

6. SO2 and NOx Standards • SO2 and NOx • 2 phase SO2 requirement • 6.0 lb/MWh at first compliance date • 3.0 lb/MWh at second compliance date • 1.5 lb/MWh for NOx at first compliance date • Compliance measured as a 12 month rolling average and monthly average at 2nd date

7. CO2 Standards • CO2 • Annual facility cap based on three years of data at first compliance date • Annual facility rate of 1800 lb CO2/MWh at second compliance date • Compliance measured as a calendar 12 month average

8. Implementation • Compliance Flexibility • Two Compliance Options - standard and repowering • Averaging within facility • Early reduction credit for SO2 • Use of SO2 Allowances • Off-site Reductions for CO2 • Greenhouse gas banking and trading regulation in development

9. Hg Data Collection • Sampling for concentration of mercury and chlorine in each shipment of coal received at the 4 coal-fired facilities from May 2001-May 2002 • Sampling for concentration of speciated mercury at inlet (pre-ESP) and outlet (stack) of 8 coal-fired units (3 sets of tests over one year)

10. Coal Mercury Data

11. Coal Chlorine Data

12. Hg Emissions Data • Sampling for concentration of mercury at inlet (pre-ESP) and outlet (stack) of 8 coal-fired units • Round 1: summer 2001 • Round 2: winter 2001-2002 • Round 3: summer 2002

13. Brayton 1 Emissions Test Results250 MW, Bituminous Coal

14. Average Baseline Mercury Results by Unit

15. 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 Hg is feasible • http://www.state.ma.us/dep/bwp/daqc/ daqcpubs.htm#other

16. Control Feasibility Report Technology Conclusions (1) • Hg controls are technologically feasible • Some existing US units are achieving up to 98% Hg removal • Some MA units are already removing close to 90% of Hg • Controls to meet MA SO2 and NOx standards are expected to achieve Hg reduction co-benefits

17. Control Feasibility Report Technology Conclusions (2) • Hg controls are technologically feasible • DOE field testing shows >90% Hg removal • MA Municipal Waste Combustors are removing 90% of Hg • Extensive funding for research has resulted in Hg control technologies that have reached the field testing stage

18. Control Feasibility Report Economic Conclusions • Hg controls are economically feasible • Sorbent-based Hg controls costs are similar to historically accepted NOx control costs (mills/kMWh) • Multi-pollutant regs (like MA’s) improve cost-effectiveness

19. Schedule for standard setting process • Three stakeholder meetings: Aug/Sep/Oct 2002 • Release of Feasibility Report: December 2002 • Stakeholder feedback on Feasibility Report and input on regulation issues: January 2003 • “Rule review” meeting to discuss working draft regulation: Spring 2003 • Release of proposed regulation for public comment & hearing: June 2003 (as per 7.29 regulation)

20. Major Issues for Proposed Standard • Form of the standard • Units of the standard • Level of the standard • Averaging time of the standard • Demonstrating compliance with the standard • Waste issues • Unit and facility specific issues