Environmental Engineering Reference
In-Depth Information
did not comport with the requirements of the CAA, did
not achieve suffi cient mercury emission reductions, estab-
lished compliance deadlines that were overly long, and
could perpetuate or contribute to mercury deposition hot
spots through the rule's trading provisions (Christen, 2004;
NESCAUM, 2004; NACAA, 2005). Because of these concerns,
several states joined in a legal challenge to the rule. This
challenge was ultimately successful, and CAMR was vacated
on February 8, 2008, by the D.C. Circuit Court (U.S. Court
of Appeals, 2008). The EPA initially petitioned the Supreme
Court to review this decision, but on February 6, 2009, fol-
lowing the election of President Barack Obama, the Agency
dismissed this request. On February 23, 2009, the Supreme
Court denied the Utility Air Regulatory Group's request to
review the U.S. Circuit Court of Appeals decision.
In March 2011, the EPA proposed standards for emissions
of mercury and other toxic air pollutants from coal and oil-
fi red EGUs under Section 112 of the Clean Air Act. These
regulations established emission limits based on Maximum
Achievable Control Technology and did not include emis-
sions trading provisions. These standards were fi nalized in
December, 2011. Based on EPA estimates these standards
will control mercury emissions from this sector by approxi-
mately 90% when fully implemented (USEPA, 2011).
Prior to the CAMR vacatur, many states had already
decided to adopt more stringent regulations on EGUs. To
help the states advance their own programs targeting this
sector, NACAA developed a model rule (NACAA, 2005).
This model was largely based on provisions in regula-
tions, and/or legislation, that had already been adopted or
proposed by a number of states, including Massachusetts
and Connecticut (Connecticut General Assembly, 2003;
MassDEP, 2004a; NACAA, 2007). Under the NACAA model
rule, interstate mercury emission trading was not allowed,
addressing state concerns regarding the potential contribu-
tion of EGUs to mercury deposition hot spots. The model
also included more stringent emission-control require-
ments and a faster implementation timeframe using a
two-phase approach. Under the fi rst phase, the model
stipulated that a mercury removal effi ciency of 80% or
an emission limit of 0.010 lb/GWh be achieved by 2009.
The second phase, to be achieved by 2013, required either
90-95% removal effi ciency or an emission limit of 0.0060-
0.0025 lb/GWh. New EGUs were required to meet the
Phase 2 90-95% removal requirement.
By 2007, based on a survey conducted by NACAA, about
a dozen states had adopted legislation or regulations on
mercury emissions from the coal-fi red EGUs that were
more stringent than CAMR (NACAA, 2007).
$50 million on mercury research and monitoring over
the previous 15 years. Of the responding states, 62% indi-
cated that they conducted research and/or studies related
to mercury. Twenty-nine states, 64% of those responding,
reported that they maintained an inventory of in-state mer-
cury sources. These state databases underpin national emis-
sion inventories and are often based on source testing that
exceeds federal requirements both in scope and frequency.
In addition to maintaining inventories of mercury
sources, states are also supporting atmospheric and eco-
logic monitoring and research, including sediment-core
and fi sh-tissue monitoring for both public health purposes
and trend analyses. The states also support air deposi-
tion monitoring, and in 2005, twenty-one states partici-
pated in the National Mercury Deposition Network, often
funding site operation. Michigan, Florida, Massachusetts,
Connecticut, Minnesota, Vermont, Wisconsin, Maine, New
Jersey, and New York have also supported additional moni-
toring and modeling efforts in collaboration with academic
research groups.
Thirty-nine states reported that they engaged in ongo-
ing fi sh tissue sampling for mercury (e.g., Massachusetts
Department of Environmental Protection (MassDEP), 2004b;
Hutcheson et al., 2008). Overall, states have sampled fi sh
from many hundreds of water bodies across the United
States. Twenty-eight states reported that they have con-
ducted other scientifi c research related to mercury. Research
projects have included co-sponsored testing of continuous
emission monitoring technologies for mercury, as part of
the EPA Environmental Technology Verifi cation Program,
research on dental amalgam separators, evaluations of in-
state mercury pollution sources and impacts, assessments
of fugitive mercury releases, mercury transport model
development, assessments of emissions from mine fi res
and oil combustion, and environmental trend analyses.
The states have also supported research on mercury levels
in and releases from mercury-added products, including a
New Jersey assessment of environmental releases from bro-
ken linear fl uorescent tubes and a Maine analysis of indoor
mercury releases attributable to broken compact fl uorescent
lamps (CFLs) (Aucott et al., 2003; Stahler et al., 2008).
Interstate Coordination
The scope and diversity of state activities to address mer-
cury have led to efforts to improve coordination between
the states, enhance information sharing, and build capac-
ity at the state level to both improve effi ciency and infl u-
ence national and international agendas to reduce mercury
pollution. Many examples of multistate coordination and
planning on mercury initiatives exist, including efforts by
the Great Lakes Regional Collaboration Executive Commit-
tee, the Great Lakes Regional Pollution Prevention Round-
table, the Southern States Mercury Task Force, the Interstate
Mercury Education and Reduction Clearing House, the
Quicksilver Caucus (QSC) and its member organizations,
Monitoring and Research
With respect to mercury monitoring and research, states
across the country have invested in numerous initiatives
addressing mercury. Based on 2005 ECOS survey infor-
mation, the states estimated allocating well in excess of
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