Mercury Reporting Structure Basics ECMPS Stakeholder Meeting Phoenix, Arizona May 8, 2007 By Matthew Boze

Disclaimer! uThis presentation is intended to provide a basic overview of EPA’s plans regarding the reporting format for the various Hg monitoring options uDetails are subject to change

Reporting Instruction Development uFirst drafts of reporting instructions are being posted separately on EPA’s ECMPS website uThe reporting instructions show only sections of the main reporting instruction documents that would be modified to accommodate Hg reporting uAll Hg provisions are shown in red text uEPA will eventually merge the Hg instructions into the main reporting instruction documents

Hg Monitoring Plan uAppropriate codes will be added to various existing fields to identify: ã monitoring methodologies, ãcontrols, ãmonitoring systems & components ãetc. uNew records will be added to the XML data structure ãCalibration Standard Data elements to identify whether the daily calibrations for Hg CEMS are conducted with elemental or oxidized Hg ã“HgConvereterIndicator” added to the Component Data Record to identify if a Hg analyzer has a converter ãHg LME qualification record

Hg Quality Assurance Records uThe standard QA data structure for the following test types will be used to report Hg QA: ãRATA ãBias Test ãCycle Time ã7-day Calibration Error

New Quality Assurance Records for Hg uNew records will be developed to handle testing requirements unique to Hg monitoring, such as: ãFor Hg CEMS: m3-level system integrity checks ( will be similar to linearity data structure ) mHg Linearity Record mEach will be similar to standard linearity data structure, except that the results would be calculated as a percent of span, and not reference value ãFor Appendix K sorbent trap systems: mSample Flow Meter Calibrations (for dry gas meters this would include the initial 3 level calibration, to determine the calibration factor and quarterly calibration factor checks) mOther QA (such as temperature sensor calibrations) will be reported as P/F using the miscellaneous test data record similar to transmitter cals for Appendix D

Emissions Data changes for Hg uDaily and weekly QA data ãNo changes for reporting daily calibrations ãRecord added for reporting weekly single-level system integrity checks if daily calibrations are conducted using elemental Hg and the analyzer has a converter

Hg CEMS Data uHourly Hg concentration to be recorded in the MonitorHourlyValueData record including: ãUnadjusted hourly value ãBias adjusted hourly value ãMODC ãSystem and Component ID ãPMA uHourly Hg mass to be recorded in the MonitorDerivedValueData record including: ãBias adjusted mass value ãMODC ãFormula ID

Appendix K uUnlike Hg CEMS, Appendix K sorbent trap monitoring does not fit into the generic data structures developed for traditional data monitors uAppendix K will require the use two new records ãAn hourly sample flow rate data record; and ãSorbent train data record

Hourly Sample Flow Meter Data uAn Hourly Sample Flow Meter Data record will be used to: ãReport the hourly volume of sample flue gas pulled through the sampling train; ãTrack the Hourly Stack Flow to Sample flow Rate ratio during the collection period; and ãVerify the total sample volume used to calculate Hg concentration for the collection period

Sorbent Train Data uThis record will collect all the relevant data for a sorbent train over the course of the collection period, including: ãBegin and end date and hour for the collection period ãMonitoring system ID and component ID’s ãSorbent Trap Serial numbers ãSection 1, and 2 Hg catch ãSection 3 Hg spike recovered, and Spike reference value ãTotal sample volume for the collection period ãUnadjusted Hg concentration for the trap

Sorbent Train Data (continued) uThis record will also collect the QA results for the sorbent train over the course of the collection period, including: ãP/F of post collection leak check ã% Breakthough ã% Spike Recovery ã% Trap agreement (reported in the record for each of the paired traps for a collection period) ãOverall QA status code for the sample (P/F/X for Pass/Failed/Lost or Damaged) (does not include % trap agreement) ãSample Damage Explanation/Comment

Appendix K Hg Concentration uThe Hg concentration is then reported in the MonitorHourlyValueData record for each hour of the collection period. ãIf two, validated, Sorbent Train Data records are reported, then the average Hg concentration is to be used ãIf only one valid sorbent train data record is available, then EPA has proposed a STAF adjustment of to that validated result in lieu of substitute data ãIf data for both sorbent trains are validated but the % trap agreement is beyond the limit, then the higher of the two traps may be used instead of substitute data ãAppropriate MODC’s must be used uHg mass is calculated and reported in the DerivedHourlyValueData record (Same as for CEMS)

Combining CEMS and Appendix K uSome sources may choose to operate a Hg CEMS as a primary monitor and have an Appendix K system as a backup uThis can be done, EPA will expect that for any hour that the primary (CEMS) monitor is available that the Hg concentration comes from that system. (Sources may not pick and choose the lower Hg value on an hourly basis!) uWhen data from the primary monitor is unavailable, data from the App K system may be used if: ãAll relevant App K data for the entire collection period are reported including: the Hourly Sample Flow Meter Data, and Sorbent Trap Data records ãAll QA for the Sorbent trap system are up-to-date

Hg LME uInitial Qualification Record to be reported in the QA schema (showing potential to emit) uInitial and ongoing stack tests required to establish and update default Hg concentration. Also reported in the QA schema uDo not report the Hg concentration in the hourly record uDo report the hourly Hg mass in the DHV record consistent with CEMS and Appendix K