Florida Department of Environmental Protection Mercury from Electric Utilities: Monitoring and Emission Reductions Greg DeAngelo & Tiffany Miesel Florida DEP, Division of Air Resource Management July 30, 2009

Outline and Introduction Update since our March workshop Interaction with cement industry Federal regulatory updates Inventory Testing and sampling Monitoring (Mark Calloway, Tekran Instruments) July 30, 2009 | 2

Update on Department's Activities Feb 12—held informational workshop May 5 & 6—tested OUC Stanton, Units 1 & 2 Stack testing; Method 30B, with speciated results Concurrent material sampling; coal, combustion byproducts, scrubber sludge Analyzed by Department's lab June 22—met with FCG mercury task force Status of the project, mercury (Hg) test data, Hg emission estimates, additional data needs July 30, 2009 | 3

Other Department Activities Added data from 2007 TRI, May FCG letter Provided inventory to DEP staff working on TMDL standard for Hg Current (2008) emissions Emissions with controls to be installed in 2009 Tracked federal rulemaking developments MACT proposals and activity for utilities, cement Examined non-utility coal use and utility non-coal generation Followed Tampa Electric fly ash reinjection testing July 30, 2009 | 4

Interaction with Cement Industry March—DEP met with FDOT and cement experts at the FDOT research center in Gainesville. Summarized emissions from cement kilns in the U.S. Outlined likely range of future EPA limits, control options Discussed concept of filter dust shuttling to ultimately encase some Hg in cement/concrete Agreed to support demonstration efforts by testing cement for compliance with FDOT physical/chemical specifications DEP's expert consultant has found that substitution of small amounts of filter dust for clinker: Reduces air emissions, and Will not disqualify the product as a Type I/II or masonry cement. National associations are moving toward dust shuttling. DEP is looking for participants interested in testing. Contact at DEP is Al Linero. July 30, 2009 | 5

Federal Rulemaking (Cement MACT) May 6, 2009—EPA proposed revisions Tighter Hg standard, on a 30-day rolling average basis Compliance through continuous Hg measurement CEMS (PS–12A) or sorbent trap monitors (PS–12B) Performance specifications for ongoing quality assurance "[Could] apply to sources from categories other than…cement" No restriction on types of utility boiler fly ash that cement kilns can use June 9, 2009—EPA extended the comment period Three public hearings in June Comments due Sept 4, 2009 July 30, 2009 | 6

Federal Rulemaking (Utility MACT) In response to having CAMR vacated, EPA will propose a MACT rule for utilities. Negotiations with litigants to settle the rulemaking schedule continue. EPA believes they are very close to settling that schedule. EPA plans to move "as quickly as [their] understanding of the issues allows." EPA may have a final rule as early as Summer EPA is not reconsidering their previously proposed MACT. EPA will now (re-)evaluate all HAP (metals, acid gases, organics) 114 information collection request (ICR) letters will be necessary and are under development. Will EPA require stack tests to get the baseline data they will need? EPA is soliciting comments on the proposed ICR. Review of the ICR was noticed in Federal Register on July 2, Comments are due August 31. July 30, 2009 | 7

Mercury Reductions with CAIR Controls July 30, 2009 | 8

Hg Testing Results—Percent Removal July 30, 2009 | 9 Hg (lbs/hr) Unit 1 (ESP + FGD) Unit 2 (SCR + ESP + FGD) In (via coal) Emitted from stack Removal75%95%

Hg Testing Results—MACT Comparison July 30, 2009 | 10 lbs/hrMWlbs x /MWh Previously proposed MACT standard (lbs x /MWh) Unit 1 (ESP + FGD) (existing sources) Unit 2 (SCR + ESP + FGD) (new sources)