1. APPA Engineering & Operations Technical Conference Presented by: Dale Evely – Southern Company Generation April 17, 2007 Preparing for Mercury Monitoring

2. Basic Outline Regulatory overview Impact on Southern Company Technology review process RFP process followed Implementation plans and staffing Open issues with the technology

3. Regulatory Overview EPA’s Clean Air Mercury Rule (CAMR) issued March 15, 2005 Cap and trade – two phases, 2010 and 2018 –First phase cap set at 38 tons –Second phase cap set at 15 tons Mercury monitoring must be in place and certified by January 1, 2009 Rule left the impression that mercury monitoring technology was already proven

4. Impact on Southern Company Approximately 1000 mercury monitors required across all affected industries in the United States Approximately 56 Southern Company Generation (SCGen) stacks require some sort of monitoring 5 of the 56 are new FGD stacks coming on-line in 2008 4 new FGD stacks coming on-line in 2009 6 additional FGD stack systems needed in 2010 At least 49 mercury monitors required in the near term

5. Technology Review Process EPA began evaluations of mercury monitoring technology using coal combustion test facilities around the year 2000 EPRI CEM Program began high level evaluations of the technology in the same time frame Southern Company followed the issue through EPRI EPRI report 1004076 in 2002 showed existing monitors were semi-continuous and needed further development

6. Technology Review Process Mid-2004 indications were that EPA was working on setting mercury monitoring requirements EPRI setup a supplemental project to work with EPA on monitor evaluation/development and SCGen signed on to it as a funder SCGen decided its own hands-on evaluation would also be required since 61 systems were believed to potentially be needed SCGen needed to begin budgeting for the potential monitoring

7. Initial Budgeting Assumptions (2004) Able to plug a mercury analyzer into our existing SO x /NO x racks in our existing shelters Could slightly modify our existing dilution air clean-up systems Existing probes and sample lines would work for Hg Oxidized to elemental Hg conversion done at analyzer using dry means Calibration gas cylinders would be used Analyzer cost would hold or fall over time

8. SCGen Monitor Review Process Had excellent working relationship with our CEMS integrator since 1992 and a lot of synergies with them Began discussions with our integrator to jointly become more familiar with Hg monitoring technology Had first of three different monitors (from different manufacturers) up and running at Plant Crist in early 2005; moved to Plant Yates in early 2006 Two of the monitors were promising One monitor was a disaster

9. EPA Monitor Review Process EPA desired to “prove” the technology Identified a dry stack in North Carolina and a wet stack in Kentucky as demonstration sites EPA allowed EPRI’s contractor to observe and provide feedback Difficulties at both sites keeping the monitors running and Part 75 QA/QC procedures were not attempted EPA Dry stack work shutdown late 2005 EPA Wet stack work shutdown early 2006

10. EPRI Monitor Review Process EPRI took over the Kentucky wet stack site EPRI desired to work with the manufacturers to further refine the technology EPRI also desired to identify issues to EPA that would impact meeting Part 75 QA/QC requirements Site has provided great value to the manufacturers and to the industry and much needed feedback to EPA Seven different systems are currently installed at this site and will continue until August

11. SCGen CMM Procurement Process SCGen CEMS Task Force began Continuous Mercury Monitor (CMM) procurement planning in early 2006 Concerned that only two manufacturers appeared to be close to an acceptable solution Questionable that industry need for 1000 monitors could be met by just these two manufacturers Decided to “lock” manufacturing and integration capacity to meet our needs

12. SCGen CMM Procurement Process Basic schedule that was followed: – 7/01/06 Begin development of Specification – 8/01/06 Issue RFP – 9/05/06 Begin Bid Evaluation – 9/15/06 Assemble Implementation Team – 9/15/06 Begin refining overall cost estimates –10/05/06 Purchase Recommendation to Management –10/31/06 Award Volume Procurement Contract – 4/05/07 Deliver first System

13. SCGen CMM Specification High Points Must meet 40CFR75 QA/QC, 40CFR75 certification, and CAMR monitoring requirements 90% or better availability on quarterly basis 90 day or better operation on Hg converters Relative accuracy that allows annual testing Easy interface to existing CEMS DAHS NIST traceable, elemental and oxidized, integrated and automatic calibration gas generators Named only two acceptable manufacturers

14. Options for standalone shelters, dual unit shelters, installation at factory in already purchased shelters, installation at site in existing shelters, and more CMMS must pass all required certification tests CMMS software updates and system upgrades to meet performance specifications included beyond January 2009 Bulk of deliveries staggered from April 2007 through July 2008 SCGen CMM Specification High Points

15. Technological Cost Impacts Probes and sampling systems more complicated and expensive than SO x /NO x expectation Umbilical lines cost about twice SO x /NO x lines Calibration gas cylinders not viable Entire rack needed per measurement point Compressed air need greater than expected Air clean-up needs increased with volume Higher Risk = Higher Cost Craft labor and installation cost increases

16. CMM System Overview Sample Transport Umbilical Calibration Gas Generator Dilution Probe Controller Mercury Analyzer Zero Air Supply Sample Extraction, Dilution & Conversion Inertial Probe Sample Analysis Rack

17. CMM Budgeting Assumptions (2007) Average hardware/software cost twice (or more) of what was originally expected Average installation cost twice (or more) of what was originally expected –Some sites require air compressors, platforms, etc. Certification testing cost unknown but could be $100,000 each or more Annual maintenance cost expected to be $200,000 or more per monitor

18. CMM Program Implementation Assembled a multi-discipline, dedicated team consisting of: –Program Lead Engineer –I&C, Electrical, Mechanical, and Civil Design Leads –Scheduler & 2 Project support engineers –2 construction liaisons Team assisted by: –Retrofit project liaisons –Environmental compliance liaisons

19. CMM Program Implementation Standardized approach to ensure: –Each system uses a standard vendor drawing package –Each system tested at Integrator’s factory –Mounting pad and infrastructure in place before system arrives at plant site –Installation schedule to support certification testing of all systems in 2008 following expected SO x /NO x RATA testing schedule –First system arrives 7 weeks before next system to allow some back fitting of lessons learned

20. CMM Technology Open Issues Current SO x /NO x CEMS regularly gives 95%+ data availability SCGen and EPRI testing have shown availability only in the high 50%’s (but improving) Biggest problems have been probe plugging and mercury hide-out in the sampling systems Certification/Accuracy verification is both a technological and a regulatory issue

21. CMM Compliance is a 3 legged Stool Calibration Reliability RATA Testing Manufacturers have been making great strides on improving reliability issues Certification and Accuracy verification issues are in EPA & NIST courts

22. Accuracy Verification Issues Calibration gas in cylinders not a good option Monitored mercury must include total of both elemental and oxidized mercury Elemental mercury gas generators proven Oxidized mercury generators still in development NIST still investigating all three mechanisms Once done EPA must issue a NIST traceability protocol Systems already being manufactured & installed

23. Certification Test & RATA Issues Ontario Hydro Method (OHM) requires great care, skill and much time Instrumental Reference Method (IRM) is still in development and start-up cost may be extreme Sorbent trap Reference Method (TRM) promised this year and only real hope for 2008 testing SCGen has 52 systems to certify in 2008 and 52+ to RATA every year afterwards OHM would take more than 1 week each

24. CMM Reliability Open Issues Mercury hides out in the sampling system Flue gas (and calibration gas) moisture seems to minimize this hide out Selenium and other flue gas constituents tend to poison the mercury converters Sampling systems can plug up over time Ambient temperature at probe can be an issue

25. CMM Summary Write a Performance Based Specification Sign up an Integrator and lock analyzer system and integration shop capacity Educate your management that capital and O&M costs right now are a shot in the dark Educate your local regulators that EPA is behind Expect CAMR monitoring requirements to be revised (DFR) by mid 2007 and respond as needed Realize you have a lot of company and use your EPRI investment if you have made one

26. Industry CMM Status EPRI CEM business meeting 2/28/2007 with 19 coal utilities represented 290 CMM systems needed among this group 142 of these 290 already committed to Average expectation is one technician needed for every two monitors for O&M Sorbent trap based RM being counted upon by most for certification test purposes

27. Questions ?