Technical Support Document
for the Final
Clean Air Mercury Rule

Air Quality Modeling

U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711

March 2005


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Table of Contents

I.	Introduction	2

II.	Emission Inventories and Estimated Emissions Reductions	3

III.	Model, Domain, Configuration, Inputs, and Application	7

IV.	CMAQ Model Performance Evaluation	12

V.	Impacts of CAMR on Mercury Deposition	16

VI.	Summary of Findings: HUC Level Deposition analysis	19

VII.	References	22


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I. Introduction

This section summarizes the emissions inventories and air quality modeling that serve as
the inputs to the benefits analysis for the Clean Air Mercury Rule (CAMR). EPA used a
sophisticated photochemical air quality model to predict the levels of mercury deposition for a
2001 base year and a 2020 baseline reflecting co-control of mercury from implementation of the
Clean Air Interstate Rule (CAR) as well as two control options for CAMR. The estimated
changes in mercury deposition associated with the control options were then combined with fish
tissue data for use in estimating health and welfare effects. In addition, utility attributable
deposition of mercury was estimated based on zero-out modeling for both the 2001 and 2020
baselines.

The 1997 Mercury Study Report to Congress noted that "a single air quality model which
was capable of model both the local as well as regional fate of mercury was not identified." In
fact, at that time such a model did not exist. Thus, the modeling approach for this report
employed two models: 1) the Regional Lagrangian Model of Air Pollution (RELMAP) to
address regional-scale atmospheric transport, and 2) the Industrial Source Code model (ISC3) to
address local-scale analyses (i.e., within 50 km of source). This approach also required
assumptions to be made about the background concentrations of mercury that were uniformly
added to the regional component and the use of "model plants" to represent typical sources for
the local-scale transport. At this time, the Agency would have significant concerns about using
the ISC3 model for assessments of Hg deposition associated with CAMR. The Agency will later
this year promulgate the American Meteorological Society/Environmental Protection Agency
Regulatory MODel (AERMOD) that will replace ISC3 as the recommended and preferred model
for use in regulatory permit modeling assessments. This model contains the Argonne National
Laboratory (ANL) versions of the wet and dry deposition algorithm which contain refinements
beyond the ISC3 model and are considered more robust through extensive testing and evaluation.
The ISC3 outputs for wet and dry deposition were never fully tested and verified for use in
regulatory applications.

The Agency views the application of a more robust and sophisticated modeling approach
as critical and required for assessing the mercury deposition associated with CAMR because of
the density and properties of mercury and its complex transport and reactions in the atmosphere.
The Community Multiscale Air Quality (CMAQ) modeling system best meets our requirements
and the recommendations of the Report to Congress for a 'single air quality model" to address
mercury deposition. CMAQ is a three-dimensional grid-based Eulerian air quality model
designed to estimate pollutant concentrations and depositions over large spatial scales (e.g., over
the contiguous United States). Because it accounts for spatial and temporal variations as well as
differences in the reactivity of mercury emissions, CMAQ is the best available model for
evaluating the impacts of the CAMR on U.S. mercury depositions. This model appropriately
accounts for the atmospheric reactions of specific mercury emissions and their significance in
the levels of deposition as shown through our results here for CAMR. In addition, the boundary
and initial species concentrations are provided by a three-dimensional global atmospheric
chemistry and transport model, i.e., Harvard's GEOS-CHEM model. The model simulations are
performed based on plant-specific emissions of mercury by species as provided by the Integrated

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Planning Model (IPM).

Section II provides a summary of the emissions inventories that were modeled for this
rule. Section III discusses the model, domain, configuration, inputs, and application. Section IV
summarizes the model performance. Section V summarizes the results of estimating mercury
depositions for the 2001 and 2020 scenarios modeled. Section VI summarizes the deposition
findings at water bodies for the scenarios modeled and Section VII provides the references for
this analysis.

II. Emissions Inventories and Estimated Emissions Reductions

This section summarizes the emissions inventories that serve as the inputs to the air
quality model used for the Clean Air Mercury Rule (CAMR). The CAMR Emissions Inventory
Technical Support Document (TSD) discusses the development of the 2001 and 2020 emissions
inventories for input to the air quality modeling of this final rule in greater detail (EPA, 2005a).
Table 1 provides the emission sources and the basis for current and future-year inventories,
while Table 2 summarizes the mercury emissions by species from utilities, also known as
Electric Generating Units (EGUs), and other sources that were used in modeling of mercury
deposition.

As Table 2 demonstrates, a total of almost 115 tons of mercury were emitted across all
sources in 2001. EGUs emitted a total of 48.6 tons, or 42.3 percent of mercury emissions across
all sources during this base year. Almost 21 tons of the most readily deposited form of mercury,
i.e., reactive gaseous mercury (RGM), were emitted by these utilities and therefore comprised
42.4 percent of their mercury emissions.

The 2020 baseline emissions shown in Table 2 accounts for increases in economic
activity and population growth between 2001 and 2020 that lead to increased production in the
utility and manufacturing sectors and hence increases in emissions over time, as well as the
implementation of regulatory policies from MACT standards (primarily on non-EGU sources)
and the CAR controls (as applied to EGUs in the eastern U.S.) which decreases emissions over
this time period. Total mercury emissions in 2020 are roughly 87 tons, reflecting a net reduction
of almost 28 tons (or 24 percent) from 2001 levels. As shown, the 2020 baseline with CAR
shows net reductions in mercury emissions for EGUs of 14.2 tons or a 29.1 percent reduction
from 2001 levels. Utility emissions are expected to account for 39.5 percent of total mercury
emissions in 2020, which is only slightly lower than their share in 2001. However, the
reductions associated with CAR co-control show a large reduction of 61.8 percent in their
emissions of reactive gaseous mercury relative to their 2001 level of emissions, i.e., 20.58 tons in
2001 to only 7.87 tons in 2020.

Table 3 shows the reductions in mercury emissions associated with the CAMR Control
Option 1 in 2020. The 2020 EGU emissions are reduced by approximately 10 tons to a total of
25 tons, representing all percent reduction from total baseline emissions in 2020 (with CAR),
or a 27 percent reduction from the EGU sector alone. Under CAMR Control Option 2, EGU
emissions are further reduced by an additional 4 tons to a total of roughly 21 tons. This

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represents a 16 percent reduction from total emissions from the 2020 baseline (with CAR), or a
39 percent reduction from the EGU sector alone.

In comparison to current mercury emissions (i.e., the 2001 base year scenario), the CAR
and CAMR Option 1 achieve a total reduction in EGU emissions of approximately 24 tons (48
percent), while CAR and CAMR Option 2 achieve a total reduction in EGU emissions of
approximately 28 tons (57 percent).

Table 1. Summary of Emissions Sources for 2001 and 2020 Mercury Emissions Inventories

Sector

Emissions Source 2001 Base Year

2020 Base Case Projections

Utilities -
Electric
Generating
Units (EGU)
Non-EGU
point sources

Non-point
sources

Power industry
electric generating
units (EGUs)

Non-Utility Point

All other stationary
sources inventoried
at the county level

1999 National
Emission Inventory
(NEI) data

1999 NEI, with
medical waste
incinerator sources
replaced with draft
2002 NEI

1999 NEI, with
medical waste
incinerator sources
replaced with draft
2002 NEI

Integrated Planning Model (IPM) reflecting growth in
Btu demand as well as regulatory policies
implemented through 2020, such as the Clean Air
Interstate Rule

(1)	Department of Energy (DOE) fuel use projections,

(2)	Regional Economic Model, Inc. (REMI) Policy
Insight® model, (3) decreases to REMI results based
on trade associations, Bureau of Labor Statistics
(BLS) projections and Bureau of Economic Analysis
(BEA) historical growth from 1987 to 2002, (4)
Maximum Achievable Control Technology category
growth and control assumptions

same as above

aThis table documents only the sources of data
technical support memorandum and were held

for the U.S. inventory. The sources of data used for Canada and Mexico are explained in the
constant from the base year to the future years.

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Table 2. Summary of Mercury Emissions by Species: 2001 and 2020 (with CAR) Baselines

Emissions Source

Mercury Emissions Species (tons)

Total Mercury
Emissions (tons)

Elemental

Reactive Gaseous

Particulate

2001 Base Year

EGUs

26.26

20.58

1.73

48.57

Non-EGU Point

37.85

13.33

7.60

58.78

Non-point

5.05

1.53

0.96

7.54

Total, All Sources

69.16

35.44

10.29

114.89

2020 (with CAR) Baseline

EGUs

25.72

7.87

0.83

34.42

Non-EGU Point

28.03

10.37

6.61

45.01

Non-point

5.69

1.30

0.77

7.76

Total, All Sources

59.44

19.54

8.21

87.19

Table 3. Summary of Changes in Mercury Emissions Associated with CAMR Control
Option 1: 2020

Emissions Source

Change in Mercury Emissions Species (tons)

Total Change in

Mercury
Emissions (tons)

Elemental

Reactive Gaseous

Particulate

EGUs

8.07
(31.4%)

1.30

(16.5%)

0.00
(0.0%)

9.37
(27.2%)

Non-EGU Point

n/a

n/a

n/a

n/a

Non-point

n/a

n/a

n/a

n/a

Total, All Sources

8.07
(13.6%)

1.30

(6.7%)

0.00
(0.0%)

9.37
(10.7%)

Note: n/a is not applicable.

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Table 4. Summary of Changes in Mercury Emissions Associated with Control Option 2:
2020

Emissions Source

Change in Mercury Emissions Species (tons)

Total Change in

Mercury
Emissions (tons)

Elemental

Reactive Gaseous

Particulate

EGUs

11.39
(44.3%)

2.16

(27.4%)

0.04
(4.8%)

13.59
(39.5%)

Non-EGU Point

n/a

n/a

n/a

n/a

Non-point

n/a

n/a

n/a

n/a

Total, All Sources

11.39
(19.2%)

2.16
(11.1%)

0.04
(0.5%)

13.59
(15.6%)

Note: n/a is not applicable.

III. Model, Domain, Configuration, Inputs, and Application

Air quality modeling for mercury deposition was conducted using the Community
Multiscale Air Quality Model (CMAQ). The CMAQ modeling system is a comprehensive three-
dimensional grid-based Eulerian air quality model designed to estimate pollutant concentrations
and depositions over large spatial scales (Dennis et al., 1996; Byun and Ching, 1999; Byun and
Schere, 2004). The CMAQ model is a publically available, peer-reviewed, state-of-the-science
model consisting of a number of science attributes that are critical for simulating the oxidant
precursors and non-linear chemical relationships associated with the formation of mercury.
Version 4.3 of CMAQ (Byun and Schere, 2004, Bullock and Brehme, 2002) was used for
CAMR. This version reflects updates to earlier versions in a number of areas to improve the
underlying science and address comments from peer review. The updates in mercury chemistry
used for CAMR from that described in (Bullock and Brehme 2002) are as follows: (1) the
elemental mercury (HgO) reaction with H202 assumes the formation of 100 percent reactive
gaseous mercury (RGM) rather than 100 percent particulate mercury (HgP), (2) the HgO reaction
with ozone assumes the formation of 50 percent RGM and 50 percent HgP rather than 100
percent HgP, (3) the HgO reaction with OH assumes the formation of 50 percent RGM and 50
percent HgP rather than 100 percent HgP, and (4) the rate constant for the HgO + OH reaction
was lowered from 8.7 to 7.7 xl0"14cm3molecules"1s"1. CMAQ simulates every hour of every day
of the year and requires a variety of input files that contain information pertaining to the
modeling domain and simulation period. These include hourly emissions estimates and
meteorological data in every grid cell as well as a set of pollutant concentrations to initialize the
model and to specify concentrations along the modeling domain boundaries. These initial and
boundary concentrations were obtained from output of a global chemistry model. We use the
model predictions in a relative sense by first determining the ratio of mercury deposition
predictions. The calculated relative change is then combined with the corresponding fish tissue
concentration data to project fish tissue concentrations for the future case scenarios. The
following sections provide a more detailed discussion of the modeling and a summary of the
results. Key science aspects of CMAQ as applied for CAMR include:

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•	Gas-Phase Chemical Solver: Euler Backward Iterative (EBI) scheme
Advection Scheme (vertical and horizontal): Piecewise Parabolic Method (PPM)
scheme

Vertical Diffusion: K-theory eddy diffusivity scheme; minimum diffusivity is 1
m2/sec

•	Dry Deposition: M3DRY module, modified RADM scheme with Pleim-Xiu land
surface model

•	Aqueous Chemistry: RADM Bulk scheme
Cloud Scheme: RADM Cloud scheme

Vertical Coordinate: Terrain-following Sigma coordinate

A. CMAQ Modeling Domain and Configuration

As shown below in Figure 1, the CMAQ modeling domain encompasses all of the lower
48 States and extends from 126 degrees west longitude to 66 degrees west longitude and from 24
degrees north latitude to 52 degrees north latitude. The modeling domain is segmented into
rectangular blocks referred to as grid squares. The model predicts pollutant concentrations and
depositions for each of these grid cells. For this application the horizontal domain consisted of
16,576 grid cells that are roughly 36 km by 36 km. The modeling domain contains 14 vertical
layers with the top of the modeling domain at about 16,200 meters, or 100 millibar. The vertical
layer structure for CMAQ used for the CAMR applications is shown in Table 5 (this table can be
found below, in the section C.). The height of the surface layer is 38 meters.

Figure 1. CMAQ Modeling Domain

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B.	Time Period Modeled For Mercury Deposition

CMAQ was ran for a full year for each of the six CAMR emissions scenarios modeled.
The overall model run time for completing an annual simulation was reduced by dividing the
year into two six-month periods which were run in parallel on different computer processors.
That is, the annual simulation was performed as two separate six month model runs. One run
was for January through June and the other run was for July through December. Each six-month
runs included a 10-day ramp-up (i.e., "spin-up") period designed to minimize the influence of the
initial concentration fields (i.e., initial conditions) used at the start of the model run. The
development of initial condition concentrations is described in Section D, below. The ramp-up
periods used for the CAMR CMAQ applications are as follows:

-	first six-month ramp-up period is December 22 - 31, 2000

-	second six-month ramp-up period is June 21 - 30, 2001

Model predictions from these ramp-up periods were disCAIRded and not used in analyses of the
modeling results. The meteorological conditions, initial conditions and boundary conditions
were held constant for each of the emissions scenarios modeled and are described below in
sections C and D.

C.	Meteorological Inputs to CMAQ

Meteorological data, such as temperature, wind, stability parameters, and atmospheric
moisture contents influence the formation, transport, and removal of air pollution. The CMAQ
model requires a specific suite of meteorological input files in order to simulate these physical
and chemical processes. For the CAMR CMAQ modeling, meteorological input files were
derived from a simulation of the Pennsylvania State University / National Center for
Atmospheric Research Mesoscale Model (Grell et al., 1994) for the entire year of 2001. This
model, commonly referred to as MM5, is a limited-area, nonhydrostatic, terrain-following
system that solves for the full set of physical and thermodynamic equations which govern
atmospheric motions. For this analysis, version 3.6.1 of MM5 was used. The MM5 horizontal
domain consisted of a single 36 x 36 km grid with 165 by 129 cells, selected to maximize the
coverage of the Eta model analysis region and completely cover the CMAQ modeling domain
with some buffer to avoid boundary effects. The MM5 was run on the same map projection as
CMAQ. The 2001 meteorological modeling utilized 34 vertical layers with a surface layer of
approximately 38 meters. The MM5 and CMAQ vertical structures are shown in Table 5.

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Table 5. Vertical layer structure for MM5 and CMAQ (heights are the top of layer).

CMAQ Layers
(14)

MM5 Layers
(34)

Sigma

Approximate
Height (m)

Approximate
Pressure (mb)

0

0

1.000

0

1000

1

1

0.995

38

995

2

2

0.990

77

991



3

0.985

115

987

3

4

0.980

154

982



5

0.970

232

973

4

6

0.960

310

964



7

0.950

389

955

5

8

0.940

469

946



9

0.930

550

937



10

0.920

631

928

6

11

0.910

712

919



12

0.900

794

910



13

0.880

961

892

7

14

0.860

1130

874



15

0.840

1303

856



16

0.820

1478

838

8

17

0.800

1657

820



18

0.770

1930

793

9

19

0.740

2212

766



20

0.700

2600

730

10

21

0.650

3108

685



22

0.600

3644

640

11

23

0.550

4212

595



24

0.500

4816

550



25

0.450

5461

505

12

26

0.400

6153

460



27

0.350

6903

415



28

0.300

7720

370



29

0.250

8621

325

13

30

0.200

9625

280



31

0.150

10764

235



32

0.100

12085

190



33

0.050

13670

145

14

34

0.000

15674

100

A complete description of the configuration and evaluation of the 2001 meteorological
modeling is contained in McNally (2003), however some of the key model physics options are as
follows:

Cumulus Parameterization: Kain-Fritsch
Planetary Boundary Layer Scheme: Pleim-Chang
• Explicit Moisture Scheme: Reisner 2

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Radiation Scheme: RRTM longwave scheme

Land Surface Model: Pleim-Xiu

Four-Dimensional Data Assimilation (FDDA): analysis nudging only

The annual MM5 simulation was divided into four separate periods: 12/16/00 to 4/05/01,
3/16/01 to 7/05/01, 6/14/01 to 10/02/01, and 9/17/01 to 2/04/02. Within each of these periods
the model was run for 5 V2 days blocks with a restart occurring at 1200 UTC every fifth day. To
assure continuity in the surface moisture, the model initial conditions were updated with the soil
conditions from the end of the previous 5 V2 day period using the EPA "INTERPX" processor.

In terms of the 2001 MM5 model performance evaluation, we used an approach which
included a combination of qualitative and quantitative analyses to assess the adequacy of the
MM5 simulated fields. The qualitative aspects involved comparisons of the model estimated sea
level pressure and radar reflectivity fields against observed values of the same parameters from
historical weather chart archives. The statistical portion of the evaluation examined the model
bias and error for temperature, water vapor mixing ratio, and the index of agreement for the wind
fields. These statistical values were calculated on a regional basis. The results of the evaluation
indicate that the 2001 model data had a bias in surface temperature of -0.6 degrees Celsius and
the error averaged 2.1 degrees C. The humidity fields had a bias of -0.2 g/kg and an error of 1.0
g/kg. The wind speed index of agreement averaged 0.86. The model was found to overestimate
precipitation, on average by about 1.6 cm. The precipitation bias was strongest in the summer.
Qualitatively, the model fields closely matched the observed synoptic patterns, which is expected
given the use of FDDA. In general, the bias and error values associated with the 2001 data are in
the range of model performance found from other non-EPA regional meteorological model
applications (Environ, 2001).

The MM5 outputs were processed to create model-ready inputs for CMAQ using the
Meteorology-Chemistry Interface Processor (MCIP) as described in EPA (1999b). MCIP
version 2.2gvm was used to convert the MM5 output to CMAQ meteorological input. This
version contained two differences from the main MCIP version 2.2 in that: 1) it allowed for
treatment of the graupel associated with the Reisner 2 microphysics scheme and 2) it included a
patch to compensate for a minor error in MM5 associated with vegetation fractions.

D. Initial and Boundary Condition Inputs to CMAQ

In this section we describe the approach used to provide the boundary conditions (BCs)
and the concentrations used to initialize the model runs for the CAMR CMAQ modeling. Non-
episodic national modeling, such as the CAMR annual mercury modeling, requires the
prescription of BC's to account for the influx of pollutants and precursors from the upwind
source areas outside the modeling domain. The pollutant influxes from the upwind boundaries,
which are often dynamic in nature, can affect pollutant concentrations within the modeling
domain. For example, a number of recent studies show that long-range, intercontinental
transport of pollutants is important for simulating seasonal/annual ozone, PM and mercury
(Jacob, et al., 1999; Jaffe et al., 2003; Fiore, et al., 2003, Selin 2005). A scientifically sound
approach to estimate incoming pollutant concentrations associated with intercontinental transport

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is to use a global chemistry model to provide dynamic BCs for the regional model simulations.

For the CAMR annual mercury modeling, we used the predictions from a global three-
dimensional chemistry model, the GEOS-CHEM model (Yantosca, 2004), to provide the BCs
and initial concentrations. The global GEOS-CHEM model simulates atmospheric chemical and
physical processes driven by assimilated meteorological observations from the NASA's Goddard
Earth Observing System (GEOS). This model was run for 2001 with a grid resolution of 2
degree x 2.5 degree (latitude-longitude) and 20 vertical layers. The predictions were used to
provide one-way dynamic BCs at 3-hour intervals and initial concentration field for the CMAQ
simulations. We used an interface utility tool developed at the University of Houston (Byun and
Moon, 2004; Moon and Byun, 2004) to link the GOES-CHEM with CMAQ. The scale,
chemical, and dynamic linking between the two models are needed since the horizontal and
vertical coordinates, chemical species representations, and model output time are different. A
detailed description of how the GEOS-CHEM model outputs were used to develop inputs to
CMAQ including the data preparation, spatial and temporal conversion procedures, and species
mapping tables are given in Moon and Byun (2004).

E. CM A Q Model Applications

For CAMR, CMAQ was run for six emissions scenarios: a 2001 base year, a 2001 base
year with utility mercury emissions zeroed-out, a 2020 projection with CAR incorporated, a
2020 projection with CAR incorporated and utility mercury emissions zeroed-out, a 2020
projection with CAR and CAMR control option 1 incorporated, and a 2020 projection with CAR
and CAMR control option 2 incorporated.

IV. CMAQ Model Performance Evaluation

At this point in time, it is difficult to assess model performance for total mercury
deposition. Scientist currently believe through analysis of very limited measurements that wet
and dry deposition are approximately equal in magnitude. There currently is no measurement
network to evaluate the performance of models in estimating dry deposition of mercury. Thus,
we are not able to evaluate the performance of air quality models in predicting dry deposition,
which is thought to be roughly half of total mercury deposition. There is a network of mercury
wet deposition monitors, which are scattered throughout remote locations in the United States
and Canada, mostly in the east. Thus, model predictions of wet deposition can be evaluated by a
monitoring network.

An operational model performance evaluation for mercury wet deposition for 2001 was
performed to estimate the ability of the CMAQ modeling system to replicate base-year wet
depositions of mercury. The wet deposition evaluation principally comprises statistical
assessments of model versus observed pairs that were matched in time and space on a seasonal
and annual basis. The statistics are presented separately for the entire domain, the East, and the
West (using the 100th meridian to divide the eastern and western United States).

A. Performance Statistical Definition

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Below are the definitions of statistics used for the evaluation. The statistics are similar
to those used for a previous evaluation (Wayland, 1999). The format of all the statistics is such
that negative values indicate model predictions that were less than their observed counterparts.
Positive statistics indicate model overestimation of observed counterparts.

Mean Observation: The mean observed mercury wet deposition (ug/m2) averaged over all
monitored weeks in the year and then averaged over all sites in the region.

0b<>

N i= i

where: N = the number of measurement sites

Obs = observed deposition at monitoring site x over time t (i.e., Annual)

Mean Prediction: The mean model predicted mercury wet deposition (ug/m2) paired in time and
space with the observations and then averaged over all sites in the region.

1 N

PRED = — £ Pred^f
N f=i

where: N = the number of measurement sites

Pred = model predicted deposition at monitoring site x over time t (i.e., Annual)

Ratio of the Means: Ratio of the predicted over the observed values. A ratio of greater than 1
indicates on overprediction and a ratio of less than 1 indicates an underprediction.

i N Pred'
RATIO = — E

N i= i Obslxt

Mean Bias (ug/m2): This performance statistic averages the difference (model - observed) over
all pairs in which the observed values were greater than zero. A mean bias greater than zero
indicates that the model overpredicts and a bias less than zero indicates the model underpredicts.
This model performance estimate is used to make statements about the absolute or unnormalized
bias in the model simulation.

BIAS= | 2 (pr<, - ObsJj)

Ni= i

Mean Fractional Bias (percent): Normalized bias can become very large when a minimum

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threshold is not used. Therefore fractional bias is used as a substitute. The fractional bias for
cases with factors of 2 under- and over-prediction are -67 and + 67 percent, respectively.
Fractional bias is a useful model performance indicator because it has the advantage of equally
weighting positive and negative bias estimates.

2 N (Pred' - Obs')

FBIAS = — E 		^^ * 100

N i= 1 (Pred' + Obs')

Mean Fractional Error (percent): It is similar to the fractional bias except the absolute value
of the difference is used so that the error is always positive.

2 N \Pred't - Obs' J
FERROR = — E J	^100

N i= i Pred't + Obs't

x,t	x,t

B. Results of CMAQ Model Performance Evaluation

For mercury wet deposition, this evaluation includes comparisons of model predictions to
the corresponding measurements from the Mercury Deposition Network (MDN). The statistics
were calculated using the predicted-observed pairs for the full year of 2001 and for each season,
separately. Only sites where data was available more than half the weeks in a season were
utilized for the seasonal performance evaluation and only sites that had four seasons meeting this
data completeness requirement were utilized for the annual performance evaluation. There were
52 MDN sites in 2001 that meet the annual data completeness requirements, of those sites 48
were located in the east and 4 were located in the west. The results for the annual performance
evaluation are shown below in Table 6.

Table 6. CMAQ Performance Statistics for Mercury Wet Deposition: 2001

Area

No. of
MDN
Sites

Mean
CMAQ
Predictions
(ug/m2)

Mean

Observations
(ug/m2)

Ratio of

Means

(pred/obs)

Bias
(ug/m2)

Fractional
Bias (%)

Fractional
Error (%)

Entire
Domain

52

7.29

9.46

0.77

-2.17

-23.2

30.2

East

48

7.25

9.79

0..74

-2.55

-27.0

30.2

West

4

7.76

5.41

1.43

2.34

21.7

30.5

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The results contained in Table 6 shows that averaged annually over all MDN monitoring
sites, CMAQ underestimates mercury wet deposition by approximately 23 percent with an
fractional error of approximately 30 percent. The 4 MDN sites in the west do not provide an
adequate or representative basis for inferring model performance.

A scatter plot of the observed versus predicted annual mercury wet deposition for all the
sites is shown below in Figure 2. It can be seen that although the CMAQ model tends to
underpredict mercury wet deposition on average, the majority of predictions are within 30
percent of observed values. Most of the remaining sites have predictions that are within 50
percent of observations. There is one site in the west in British Columbia where the model
overpredicts by greater than a factor of 2. However, the precipitation at this site was
overpredicted by the meteorological input model by 55 percent.

CMAQ 2L1U1 Wet Hg Depositoion

Annual Deposition

Monitor Value (ug/'^rr^)

One tD One line

	+/— 30*5 line

	+ 100*/— 50z line

O Eastern Monrtors
O Western Monitors

Figure 2. Scatter Plot of Modeled versus Monitored Mercury Wet Deposition: 2001

V. Impacts of CAMR on Mercury Depositions

Section A discusses the results of the mercury deposition modeling for the 2001 base case, 2020
CAR and 2020 CAMR modeling. Section B discusses the potential effects of CAR in 2015 on
mercury deposition, although this was not explicitly modeled.

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A. Mercury Depositions for 2001 Base Case, 2020 CAR and 2020 CAMR

Maps showing the mercury deposition results are provided below. The annual total
modeled mercury deposition for the 2001 base case is shown in Figure 3. The reduction in total
mercury deposition that would result if all US power plant mercury emissions were zeroed-out is
shown in Figure 4. The change in total mercury deposition in 2020 with CAR relative to 2001 is
shown in figure 5. The annual total mercury deposition for 2020 with CAR is shown in Figure 6.
The change in 2020 CAR total mercury depositions with CAMR Option 1 is shown in Figure 7.
The change in 2020 CAR total mercury depositions with CAMR Option 2 is shown in Figure 8.
It can be seen in Figures 4 and 5 that the implementation of CAR and other minor non-utility
mercury emissions decreases in 2020 result in a similar reduction in total mercury deposition as
completely eliminating power plant mercury emissions. The main cause of this result is CAR
results in a very large decrease in reactive gaseous mercury (RGM) emissions from Power Plants
through the implementation of scrubber control technology (see Table 2). RGM is the most
readily deposited form of mercury. It can be seen in Figures 7 and 8 that the implementation of
CAMR Option 1 and CAMR Option 2 results in some scattered total mercury deposition
reductions beyond CAR in 2020, but for the most part these reductions are not very significant
compared to those obtained by CAR. Most of the mercury emissions reductions from CAMR are
in the form of elemental mercury (HgO). This form of mercury is not readily deposited, but
enters the global pool of mercury. Thus, CAMR will result in a reduction of the transport of
mercury to other places in the world.

148

10.000
5.000

0.000
ug/m2

January 1,0 0:00:00
Min= 3.348 at (33,19), Max= 133.229 at (21,84)

Figure 3. Base Case Total Mercury Deposition: 2001

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¦ 16.000112
' 14.000
12.000

10.000

8.000

6.000

4.000

2.000

0.000
ug/m2

January 1,0 0:00:00
Min= 0.000 at (1,88), Max= 33.589 at (118,64)

Figure 4.

Decrease in Total Mercury Deposition with Power Plant Zero-Out Simulation: 2001

16.000112

14.000

12.000

10.000

8.000

6.000

4.000

2.000

January 1,0 0:00:00
Min= -30.130 at (21,84), Max= 43.963 at (98,50)

Figure 5. Change in Total Mercury Deposition for all Sources: 2020 with CA R Relative to
2001

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148

4O.000I12

35.000

30.000

25.000

20.000

15.000

10.000

5.000

O.OOO
ug/m2

January 1,0 0:00:00
Min= 3.261 at (71,95), Max= 163.359 at (21,84)

January 1,0 0:00:00
Min= —1.240 at (128,60), Max= 9.408 at (124,56)

Figure 7. Change in Mercury Depositions from Power Plants Due to CAMR Option 1: 2020

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January 1,0 0:00:00
Min= -1.122 31(128,60), Max= 9.518 at (124,56)

Figure 8. Change in Mercury Depositions from Power Plants Due to CAMR Option 2: 2020

B. Mercury Deposition in 2015 with CAR

Although EPA did not directly model the effects of CAR on mercury deposition in 2015, the
impacts are not expect to differ too much from the modeling for the 2020 baseline with CAR. The
estimated total mercury emissions of just over 34 tons from EGUs in 2015 with CAR will be
virtually the same as the estimated total in 2020 with CAR. The readily deposited non-elemental
mercury emissions from EGUs are estimated to be 10 tons in 2015 but roughly 9 tons in 2020. The
non-elemental mercury emissions consists of the sum of the reactive gaseous mercury and
particulate mercury species. It could be inferred that although 2015 was not modeled here that the
mercury deposition levels that are estimated to occur with CAR in 2020 as shown in Figure 6 are
similar to those that would occur in 2015 with CAR. Thus, the difference in mercury deposition
from 2001 to CAR in 2020 as shown in Figure 7 should also be indicative of the change between
2001 and CAR in 2015.

The similarity between these scenarios will depend upon the following three factors:

1)	The levels of criteria pollutant emissions are different across these years and would effect the
mercury deposition through the atmospheric reactions accounted for by CMAQ. However, the
potential for these interactions to cause notable differences is limited as the emissions differences are
not significant enough for these interactions to be more that a second-order impact.

2)	The spatial distribution of mercury emissions reductions in emissions across these years will

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influence the spatial nature of mercury deposition. Despite the fact that the level of total mercury
emissions is virtually the same for both years, the spatial distribution of these emissions reductions
across EGUs will likely differ between 2015 and 2020. This difference should lead to the spatial
coverage of reductions in mercury deposition to be somewhat less in 2015 than 2020 similar to the
reduced spatial coverage observed in the modeling for the 2020 baseline with CAR compared to
2020 CAMR options.

3) The level of mercury emissions reductions by species across these years would effect the
modeled levels of mercury deposition. Despite the fact that the level of total mercury emissions is
virtually the same for both years, the more readily deposited non-elemental emissions are different
by roughly 10 percent, or 10 vs 9 tons respectfully for 2015 and 2020. This difference should also
contribute to a lessening of the spatial coverage of mercury deposition reductions in 2015 than 2020.
The mercury emissions from sectors other than EGUs are also expected to differ between these
years. In addition to the spatial differences, these differences in emissions will contribute to an
undetermined difference in the spatial coverage of mercury deposition reductions in 2015 than 2020.

VI. Summary of Findings: HUC Level Deposition Analysis

The cumulative distribution of Hydrologic Unit Code (HUC) level depositions across
watersheds are provided in Table 7 and Figure 9. The cumulative percentage of HUCs that have
deposition less than the value on the x-axis for each of the six modeled scenarios are shown in
Figure 9. For example, 90 percent of the HUCs have depositions below 22.16 ug/m2 in the 2001
base case. For the 2020 CAR plus CAMR Option 1 scenario, 90 percent of the HUCs have
depositions belowl9.48 ug/m2.

Table 7. Summary Statistics of Total Mercury Depositions (ug/m2) by Modeling Scenario



2001
Base
Case

2001 Utility
Hg Zero-Out

2020 CAR

2020 Utility
Hg Zero-Out

2020 CAR
& CAMR
Option 1

2020 CAR
& CAMR
Option 2

Minimum

6.994

6.942

6.078

5.898

6.075

6.075

Maximum

54.54

54.38

62.76

62.72

62.76

62.75

50th percentile

15.92

14.60

14.59

13.92

14.44

14.39

9ffh percentile

22.16

19.48

19.46

19.04

19.37

19.33

99th percentile

32.35

27.20

29.15

28.93

28.96

28.95

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Cumulative Distributions of Total Hg Deposition

Deposition (units)

Figure 9. Cumulative Distribution of Total Mercury Deposition (ug/nr) at HUC-8 Level by Modeling Scenario

The cumulative distribution of Hydrologic Unit Code (HUC) level depositions attributable to
utilities are provided in Table 8 and Figure 10. The cumulative percentage of HUCs that have
deposition less than the value on the x-axis for 4 of the modeled scenarios are shown in Figure 10.
For example, 90 percent of the HUCs have depositions attributable to utilities below 4.08 ug/m2in
the 2001 base case. For the 2020 CAR plus CAMR Option 1 scenario, 90 percent of the HUCs
have depositions attributable to utilities below 1.16 ug/m2. CAR shifts the distribution of utility
attributable deposition significantly, resulting in a 75 percent reduction in the 99th percentile of
utility attributable deposition, and a 20 percent reduction in the 50th percentile. CAMR Option 1
and Option 2 results in an additional reduction in 2020 utility attributable deposition in the 99th
percentile of 15 and 20 percent, respectively. At the 50th percentile, CAMR Option 1 and Option
2 result in an additional reduction of 2020 utility attributable deposition of 16 and 29 percent,
respectively. As can be seen in Figure 11, CAR also shifts the distribution of percentage of HUCs
with deposition attributable to utilities. In the 2001 base case, 10 percent of HUCs had greater
than 20 percent of deposition attributable to utilities. In the 2020 with CAR scenario, 10 percent
of HUCs had greater than 10 percent of deposition attributable to utilities. In the 2020 CAR plus
CAMR Option 1 scenario, 10 percent of HUCs had greater than 7 percent of deposition
attributable to utilities.

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Table 8. Utility Attributable Deposition (ug/m2) Statistics

Statistics

2001 Base Case

2020 CAR

2020 CAR &
CAMR Option
1

2020 CAR &
CAMR Option
2

Minimum

0.00

0.00

0.00

0.00

Maximum

19.71

4.03

3.85

3.80

50th percentile

0.39

0.31

0.26

0.22

90th percentile

4.08

1.38

1.16

0.99

99th percentile

10.15

2.56

2.17

2.04

Figure 10. Cumulative Distribution of Utility Attributable Mercury Deposition (ug/m2) at
HUC-8 Level by Modeling Scenario

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Cumulative Distribution of Percent of Deposition Attributable to Utilities

Percent of Total Deposition

Figure 11. Cumulative Distribution of Percent Deposition Attributable to Utilities at HUC-8
Level by Modeling Scenario

II. References

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Formulation, Description, and Analysis of Wet Deposition Results," Atmospheric Environment 36,
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Byun, D.W., and Ching, J.K.S., Eds, 1999. Science algorithms of EPA Models-3 Community
Multiscale Air Quality (CMAQ modeling system, EPA/600/R-99/030, Office of Research and
Development, U.S. Environmental Protection Agency.

Byun D.W., N.K.Moon, Daniel Jacob, and Rokjin Park, "Regional Transport Study of Air Pollutants
with Linked Global Tropospheric Chemistry and Regional Air Quality Models,"2nd ICAP workshop,
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Byun, D.W., and Schere, K.L., 2004. Review of the Governing Equations, Computational
Algorithms, and Other Components of the Models-3 community Multiscale Air Quality (CMAQ)
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Dennis, R.L., Byun, D.W., Novak, J.H., Galluppi, K.J., Coats, C.J., and Vouk, M.A., 1996. The next
generation of integrated air quality modeling: EPA's Models-3, Atmospheric Environment, 30,
1925-1938.

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Environ, Enhanced Meteorological Modeling and Performance Evaluation for Two Texas Episodes.
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EPA, 1999b. Science Algorithms of the EPA MODELS-3 Community Multiscale Air Quality
(CMAQ) Modeling System, EPA/600/R-99/030, March 1999.

EPA, 2005a. Clean Air Mercury Rule Emission Inventory Technical Support Document. Office of
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EPA, 2005b. Updated CMAQ Model Performance Evaluation for the 2001 Annual Simulation,
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Fiore, A.M., D.J. Jacob, H. Liu, R.M. Yantosca, T.D. Fairlie, and Q. Li, "Variability in surface
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Grell, G., J. Dudhia, and D. Stauffer, 1994: A Description of the Fifth-Generation Penn State/NCAR
Mesoscale Model (MM5), NCAIR/TN-398+STR., 138 pp, National Center for Atmospheric
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Jacob, D.J., J. A. Logan, and P.P. Murti, "Effect of Rising Asian Emissions on Surface Ozone in the
United States," Geophy. Res. Lett., 26, 2175-2178, 1999.

Jaffe D., McKendry I., Anderson T., and Price H. "Six 'new' episodes of trans-Pacific transport of
air pollutants," Atmos. Envir. 37, 391-404, 2003.

McNally, D, Annual Application of MM5 for Calendar Year 2001, Topical report submitted to EPA,
March 2003.

Moon N.K., and D.W. Byun, "A Simple User's Guide for "geos2cmaq" Code: Linking CMAQ with
GEOS-CHEM, Version 1.0," Interim Report from Institute for Multidimensional Air Quality Studies
(IMAQS), University of Houston, TX, August 2004,
http://www.math.uh.edu/~dwbyun/Meetings/icap/.

Selin, N.E., "Mercury Rising: Is Global Action Needed to Protect Human Health and the
Environment?", Environment 47, 22-35, February 2005.

Wayland, R.J., 1999. REMSAD- 1990 Base Case Simulation: Model Performance evaluation-
Annual Average statistics, Office of Air Quality Planning and Standards, Research Triangle Park,
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Yantosca, B., 2004. GEOS-CHEMv7-01-02 User's Guide, Atmospheric Chemistry Modeling
Group, Harvard University, Cambridge, MA, October 15, 2004

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