Barrett Parker, EPA Emissions Measurement Center Mercury Monitoring Barrett Parker, EPA Emissions Measurement Center

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

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

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

Test Objectives Determined Investigated all types of mercury monitors 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

Monitoring Types Periodic Testing (ASTM D 6784-02, M29) Reference method Continuous collection, delayed analysis (sorbent tube) Continuous collection and analysis (CEMS) Wet conversion, dry conversion, other

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

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 3rd party instrument certification

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

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

EPRI’s Carbon Tube Sampler

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

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

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

Phase I - Initial

Phase I - Initial

Phase I – Final

Phase I - Final

Phase II - Initial

Phase II - Initial

Phase II - Final

Phase II - Final

Phase III - Pilot Scale

Phase III - Pilot Scale

Phase III - Initial

Phase III - Initial

Selected Phase III – Initial Runs RM RM dup CEMS #6 CEMS #2 CEMS #4 CEMS #5 Xray MS 1 1.36 1.26 1.2 1.6 1.0 1.08 2 5.34 3.05 2.9 2.3 2.4 2.75 4 1.50 1.5 1.4 1.38 6 6.91 4.22 4.4 4.7 3.8 4.39 8 14.27 10.1 13.4 11.8 3.4 19.00 11 3.33 3.36 3.2 3.1 1.1 3.37

Phase III - Final

Phase III - Final

DRAFT Phase IV - Initial

DRAFT Phase IV – Initial and Proposed MACT Limit

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

DRAFT Phase IV - Final

DRAFT Phase IV – Final and Proposed MACT Limit

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

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

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

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

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 / m3 or RSD > 20% if mercury  1 μg / m3

Products (continued) Proposed PS 12A (continued) Requires measurement error test using NIST traceable Hg0 and HgCl2 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)

Concurrent Activities Assist R2 and NJ with PSEG’s NSR settlement Monitor and assist State rulemakings Coordinate with ETV mercury CEMS Phase III

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