Mercury MACT Development for Coal-let go Power Plants

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Outline. Prologue to WEST AssociatesEndorses Industry Recommendations, But WEST has Additional ConcernsMercury Emissions from Western Coal-let go Power Plants: Nature, Extent, and FateUnique Western Concerns Related to the Role of Chlorine substance of Coal on Hg EmissionsRecommendations. Who is WEST Associates?.

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´╗┐Mercury MACT Development for Coal-terminated Power Plants A Presentation by the WEST Associates at the EPA's HAPs MACT Working Group Washington DC, September 9, 2002

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Overview Introduction to WEST Associates Endorses Industry Recommendations, But WEST has Additional Concerns Mercury Emissions from Western Coal-let go Power Plants: Nature, Extent, and Fate Unique Western Concerns Related to the Role of Chlorine substance of Coal on Hg Emissions Recommendations

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Who is WEST Associates? 17 open and private electric service organizations Serves 15 million shoppers in the quickly growing 11 Western states and North Dakota Played a useful part since 1964 on vitality and natural issues in the West 1990 Clean Air Act Amendments Grand Canyon Visibility Transport Commission (GCVTC) Western Regional Air Partnership (WRAP)

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AZ Arizona Electric Power Cooperative Pinnacle West Capital Corp. Salt River Project Tucson Electric Power Co. CA Glendale Public Service Dept. Los Angeles Dept. of Water & Power Southern California Edison OR PacifiCorp ID Idaho Power Company NV Nevada Power Co/Sierra Pacific Power Co NM Public Service Co of NM, Xcel Energy and Tri-State G & T CO Colorado Springs Utilities Xcel Energy Platte River Power Authority Tri-State G & T UT PacifiCorp/Utah Power and Light WY PacifiCorp, Xcel Energy and Tri-State G & T ND Basin Electric Power Who is WEST Associates?

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Western Representation on Working Group Western States are not spoken to on the Working Group Western utilities are not spoken to on the Working Group Western utilities trust that one of a kind Western issues of Hg outflows, testimony, and air quality are not being sufficiently tended to WEST Associates values its current incorporation in Working Group's exercises

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Western Mercury Issues EPA's "Administrative Finding" in Dec. 2000 perceived the unmistakably unique Hg conditions in the West, expressing "EPA may likewise consider other applicable variables, for example, geographic conditions in building up subcategories" Western coal has bring down Hg, sulfur, and chlorine content bringing about lower Hg emanations, for the most part as natural Hg Western Hg discharges are under 10% of Eastern Hg outflows in generally a similar size geographic zone Western Hg statement levels are fundamentally lower than in the East

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Source: 1997 EPA Report to Congress

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Sub-arrangement by Coal Rank Heat substance and agglomeration-based ASTM technique for coal positioning does not recognize the size and controllability of Hg discharges, or Hg species creating diverse general wellbeing and ecological effects Same mine can deliver coals of contrasting positions (e.g., Black Mesa in Arizona - bituminous & sub-bituminous) Coal chlorine content influences controllability of Hg discharges and it ought to be considered when utilizing ICR information to set MACT levels Hg control costs for Western coals are higher than those for Eastern coals at plants with PM thus 2 controls

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ICR Data Analysis/Hg Tests Our investigation of ICR information demonstrates that coal rank, coal mercury content, and the proportion of coal mercury to chlorine substance are the three most measurably huge components to be considered in setting MACT levels Additional Hg portrayal estimations have recently been finished utilizing Black Mesa coal Results from these tests and a correlation of results with ICR information will be accessible by the October 17 Working Group meeting

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Recommendations WEST Associates prescribes that sub-classification by coal rank be enlarged with thought of chlorine substance of coal inside coal rank Leaving out thought of chlorine substance in setting MACT levels may render Hg control proficiency information in the ICR database unseemly on account of Western coals WEST Associates might want to work with different partners and EPA to create proper change elements to coal rank-based MACT levels to empower proceeded with utilization of Western coal