Beyond Federal Standards Nevada Mercury Air Emission Control Program

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Beyond Federal StandardsNevada Mercury Air
Emission Control Program

• Leo M. Drozdoff, P.E.
• Administrator
• Nevada Division of Environmental Protection
• December 15, 2005

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Building on the success of the voluntary program

• The Nevada Mercury Air Emission Control Program
  (NMCP) is the first regulatory program of its
  kind to control mercury emissions from precious
  metal mining operations

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Overview

• Voluntary program background
• Reductions achieved
• Re-evaluation
• New goals
• Regulatory program
• Vision for the future

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Genesis of the voluntary mercury reduction program

• 1998 Metal mining industry required to submit
  mercury emissions with Toxic Release Inventory
  (TRI)
• 2000 Released 1998 TRI numbers show five mining
  operations account for more than 90 of emissions
  
• 2001 EPA site tours to analyze sources and
  controls
• 2002 NDEP and EPA develop Voluntary Mercury
  Reduction Program with four largest mining
  companies

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Goals for Voluntary Mercury Reduction Program

• Achieve significant, permanent and rapid
  reductions in mercury air emissions from precious
  metal mining operations
• Achieve reductions through approaches that are
  most suitable for each individual mining facility
• Encourage flexibility in technology innovation
  and greater reductions per transaction cost

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Program resulted in rapid and significant
reductions

• From a 2001 baseline of 21,098 pounds, reduced
  emissions by
• 50 in 2002
• 74 in 2003
• 82 in 2004

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2005 timeline for re-evaluating voluntary program

• Envisioned extension of the program beyond 2005
• Throughout 2005 initiated meetings with
  stakeholders including EPA, state regulators, the
  environmental community and industry
  representatives to identify opportunities for
  enhancing Nevadas mercury program
• Incorporated proposals and concerns from
  stakeholders into goals for a new program

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Quantum leap from voluntary program

• Significant differences in new program
• Regulatory and permitting process
• Enhanced monitoring, testing, recordkeeping and
  reporting
• Expanded coverage to all precious metal mining
  operations
• Improved and additional controls
• Unit level applicability instead of by facility

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Through the new regulatory program NDEP focused
on

• Controlling Hg emissions from thermal processes
• Regulatory and permitting process designed to
  ensure that Maximum Achievable Control Technology
  (MACT) level controls are permitted and operated
• Control mercury air emissions to the maximum
  extent possible

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Nevada Mercury Control Program approach

• Most stringent levels of mercury control feasible
  through a case-by-case NV MACT
• Enhanced ability for NDEP to implement the
  program through regulations and permits
• Early reductions encouraged through Early
  Reduction Credit
• Provide for public participation throughout the
  process

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Nevada Mercury Reduction Program overview

• Three Tiered Program
• Tier 1 - Current voluntary program units
• Tier 2 - All other units at precious metal mining
  facilities
• Tier 3 - De minimus or no mercury emissions

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Why we focused on mercury control

• Data availability timeliness, complexity,
  capability and resources
• Avoid duplication of work done by other groups
  and agencies
• Fastest way to achieve measurable reductions
• This is the next phase of Nevadas mercury
  program, not the end of the story

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Nevada Mercury Control Program next steps

• Public workshops anticipated in December 2005 to
  January 2006
• Depending on timing and outcome of public
  workshops, draft regulations submitted to State
  Environmental Commission in January or April
• Anticipate adopting program in 2006

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Nevada Mercury Control Program vision for the
future

• Enforceable mercury controls at all affected
  precious metal mining operations in Nevada
• Best achievable control technology
• Full implementation of Nevada MACT by 2013