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Mercury Monitoring Barrett Parker, EPA Emissions Measurement Center.

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Presentation on theme: "Mercury Monitoring Barrett Parker, EPA Emissions Measurement Center."— Presentation transcript:

1 Mercury Monitoring Barrett Parker, EPA Emissions Measurement Center

2 Basis for Mercury Monitoring Utility air toxics report to Congress –EPA made determination for MACT rule Proposed rule 1/30 (69 FR 4652) New PS included Comment period closed 3/30

3 Electric Utility MACT 12 month rolling average mercury emission limit Cap and trade system is an alternative

4 EMC Involvement Collected data on mercury monitors Made recommendations for proposal Partnered with CAMD, ORD, NIST, EPRI

5 Test Objectives Determined –Ability for reliable data over time –Durability, availability, maintenance requirements –Suitability of draft PS-12 for CEMS Investigated all types of mercury monitors –Sought options for flexibility and accountability

6 Monitoring Types Periodic Testing (ASTM D , M29) – Reference method Continuous collection, delayed analysis (sorbent tube) Continuous collection and analysis (CEMS) –Wet conversion, dry conversion, other

7 Monitoring Types (continued) CEMS and sorbent tube selected –Requested comments on monitoring for sources emitting less than 25 pounds of mercury per year

8 German Experience Mercury CEMS on Incinerators –No requirements for coal-fired power plants Visited six incinerators –One co-fired lignite to produce electricity Sources are well controlled –ESPs, scrubbers, carbon adsorption, and SCR 3 rd party instrument certification

9 Test Phase Description Phase I (summer 01) –140 MW firing bituminous coal with cold side ESP –Use 2 German-certified CEMS Phase II (fall 02) –Same site –Use 6 CEMS and EPRI monitor

10 Test Facility During Phase II Instruments (left to right) –Envimetrics, Mercury Instruments, Genesis, Opsis, Durag, PS Analytical

11 EPRIs Carbon Tube Sampler

12 Test Phase Description (continued) Phase III Pilot (spring 03) –Low level detection and interference checks –Pilot scale facility firing natural gas and lignite, bituminous, and subbituminous coals –Use 3 CEMS and EPRI monitor

13 Test Phase Description (continued) Phase III (summer 03) –550 MW firing subbituminous coal with dry FGD, SCR, and baghouse –5 CEMS and EPRI monitor

14 Test Phase Description (continued) Phase IV (fall 03) –440 MW firing bituminous coal with wet FGD and reverse-air baghouse –2 CEMS and EPRI monitor –3 three-hour test periods

15 Phase I - Initial

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17 Phase I – Final

18 Phase I - Final

19 Phase II - Initial

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21 Phase II - Final

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23 Phase III - Pilot Scale

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25 Phase III - Initial

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27 Selected Phase III – Initial Runs Run RM RM dup CEMS #6 CEMS #2 CEMS #4 CEMS #5 Xray MS

28 Phase III - Final

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30 DRAFT Phase IV - Initial

31 DRAFT Phase IV – Initial and Proposed MACT Limit

32 DRAFT Phase IV – Initial and Proposed MACT Limit (Rescaled)

33 DRAFT Phase IV - Final

34 DRAFT Phase IV – Final and Proposed MACT Limit

35 DRAFT Phase IV – Final and Proposed MACT Limit (Rescaled)

36 Findings No sample loss in 200 feet of line Monitors improving between Phases Monitors can meet RA requirements of draft PS-12, but low-level correction needed

37 Findings (continued) Dual train reference method testing is important Monitors can operate for up to 3 months with routine maintenance

38 Products Monitoring operational characteristics and costs Data for GPRA report on Mercury CEMS and coal combustion Proposed PS 12A –Covers only vapor phase (no particulates) –Designed for fossil fuel fired boiler exhaust –Allows use of existing equipment

39 Products (continued) Proposed PS 12A (continued) –Requires at least 9 paired sets of 2 hour (minimum) runs –Allows up to 3 sets to be rejected –Specifies results to be within 20% of reference method or 10% of MACT limit –Identifies outliers as RSD > 10% if mercury > 1 μg / m 3 or RSD > 20% if mercury 1 μg / m 3

40 Products (continued) Proposed PS 12A (continued) –Requires measurement error test using NIST traceable Hg 0 and HgCl 2 at zero, mid, and high levels Calibration standards from NIST –Certified elemental mercury in cylinders 2, 5, and 20 micrograms per cubic meter –Ionic mercury to follow (1/06)

41 Concurrent Activities Assist R2 and NJ with PSEGs NSR settlement Monitor and assist State rulemakings Coordinate with ETV mercury CEMS Phase III

42 Next Steps Respond to proposal comments Potential additional testing –Longer term subbituminous and bituminous coals with cold side ESP


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