1. Mercury Monitoring Update for the Utility MACT Working Group Barrett Parker OAQPS 03/04/03

2. Overview Purpose Background Phase I Phase II Planned Phase III

3. Purpose Explain –Where we are –How we got here –Where we intend to go EPA’s goal –Options for continuous mercury monitoring Maximum flexibility Minimum cost

4. Background Partners External –NIST –DOE –ETV –EPRI

5. Background Monitor Types One time –Manual reference test method (wet) Ontario Hydro is ASTM approved Real time –Wet CEMS Automated version of reference method –Dry CEMS Proprietary catalysts and CVAAS or AFS –Other CEMS Carbon impregnated paper tape x ray fluorescence Time delayed –Carbon tube (EPRI)

6. Background German Experience Mercury CEMS on Incinerators –No requirement 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

7. Background Technical Concerns Stability, reliability, and availability of calibration standards Loss of sample in handling system Species conversion

8. Background Concerns CEMS costs, complexity, performance CEMS application on US sources Fuel, equipment, control uniqueness Availability

9. Background Work plan Phase I - summer 01 –Test 2 German certified CEMS at minimally controlled coal-fired power plant Phase II - fall 02 –Test 7 CEMS and EPRI’s carbon tube at minimally controlled coal-fired power plant Phase III - spring 03 to spring 04 –Test most promising CEMS and EPRI’s carbon tube at well controlled coal-fired power plant(s)

10. Phase I Description Installed 2 German certified dry CEMS at a full scale, representative power plant –140 MW PC with cold-side ESP firing bituminous –Plant type provides most challenge to CEMS Collected data over 5 months with 2 Relative Accuracy Test Audits (RATAs) –Total mercury using Ontario Hydro Included ORD’s wet CEMS

11. Phase I Initial RATA

12. Phase I Final RATA

13. Phase I Results Collected evidence of stable, reliable calibration standards –Elemental and ionic Demonstrated no mercury loss in sample handling system Showed wet CEMS met draft RATA criteria

14. Phase II Description Continued with 2 Phase I CEMS –Modified dry CEMS converter –Relocated wet CEMS to trailer Tested 4 new CEMS –3 with differing dry conversion systems –1 with plasma emission spectroscopy Included EPRI’s carbon tube sampler Gathered reliability and operational data

15. Phase II Monitor Trailer Instruments (left to right) –Envimetrics, Mercury Instruments, Genesis, Opsis, Durag, PS Analytical

16. Phase II EPRI’s Carbon Tube Sampler

17. Phase II Results (ready spring 03) Reliability, cost, and operational data over 3 months Analysis of –Differing approaches Plasma emission spectroscopy and X ray fluorescence –Differing interference minimization Larger volume systems and manual response correction

18. Phase II Initial RATA (preliminary)

19. Phase II Final RATA (preliminary)

20. Planned Phase III Determine low level, co-pollutant impacts (by Jun 03) Manage NIST standards development (by Jan 06)

21. Planned Phase III Evaluate CEMS at better controlled full scale power plant (by Aug 03) –Dry FGD with SCR and baghouse firing subbituminous coal –Evaluate carbon tube sampler with EPRI

22. Planned Phase III Evaluate CEMS at full scale power plants (by Jan 04) –Wet scrubber firing bituminous coal or –Uncontrolled unit firing subbituminous coal