Sorbent Trap Sampling - Overview

1. Sorbent Trap Sampling - Overview Ohio Lumex examines what we’ve learned since CAMR announced March 15th, 2005

2. Brief Timeline of Regulations

4. US Power Plants

5. US Cement Kilns

6. WHY Sorbent Trap Monitoring • Simple • Proven • Reliable • Low Levels Data Logger

7. Key Advantages of Sorbent Trap Monitoring System • Simple to Install, Implement and Operate • Typically 1 Day To Install, 1-3 Days To Certify ( RATA ) • Highly Accurate/Precise Method for Analysis – NIST Traceable SRM • Multi-section sorbent tube with very low detection levels 1 – 3 ng • Relatively Inexpensive & Very Reliable compared to CEMs • Generally less than 25% of the 1st Year Cost Of Hg CEMs • Sorbent has a 10+ Year Track Record • Applied Widely To Coal-Utility Industry and is the EPA Reference Method for RATA ( Method 30B ) • Sample captured directly in stack – no Hg transport issues • Little or no stack or facility engineering costs • No calibration gas costs (or daily, weekly calibrations only quarterly audit) • Traps are small, non-hazardous, require no special storage or handling, have no expiration and are very simple to analyze or ship to lab ( On-Site Analysis Can be Done Quickly )

8. SORBENT TRAP Hg MONITORING TECHNOLOGY Ohio Lumex Sorbent Traps conform to PS-12B or Appendix K sampling and analysis specifications.High concentration of Iodine deposited on acid washed activated carbon ensure extreme mercury capturing capacities without “Breakthrough” for extended test periods in “wet” or “dry” stack emissions from coal-fired power plants. PLEASE NOTE: High Iodine is a major interference in alternative method 1631 analysis and requires our competition to limit iodine concentration on carbon resulting in higher potential for breakthrough and low “spike” recoveries. Specifications:1. Mercury “background level less then 0.3 ng per section.2. Sorption capacity up to 2,500,000ng.3. Long term storage stability in provided container.4. Unique numbering with high temperature ink and “chain of custody.”5. Easy On/Off “leak check” cap plugs. 6. Third section is pre-spiked with elemental Hg at customized level. Three sections 10mm OD trap Gas inlet Gas outlet Spiked, Recovery must be 75% to 125% of Spike 3 Primary capture of Hg Hg Breakthrough, <_5% of Sect. 1 1 2

9. Speciation Traps 1 2 3 4 5 Acid Gas Scrubber Elemental Hg Analytical Bed Elemental Hg Breakthrough Bed Oxidized Hg Analytical Bed Oxidized Hg Breakthrough Bed SPECIATION TRAPS ● 2 types of sorbent allow you to separately capture oxidized and elemental Hg. ● Made with Extra durable thick glass for rugged field use. ● Our Speciation traps come standard for moisture resistance. ● Data has shown a bias with Acid Gases and the capture of oxidized Hg so our Speciation Traps have Acid Gas Scrubbers built in. ● We can spike with elemental and oxidized Hg. ● Used in “Wet” and “Dry” stacks as well as high particulate sources. ● We will always consult you on how best to conduct your testing for the most optimal and accurate results. ● Extensively Field Tested! PLEASE KEEP IN MIND ● Temperature (May need to use a cooling probe) ● Flow ● Sample Duration

10. Mats Rule Emissions 40CFR Part 60 & 63 Emission Limits (§63.9991): Table 1. Proposed emission limits for existing sources Pollutant(s) Emission Limits (Existing Coal-Fired EGUs) Mercury (Hg) 1.0 lb/TBtu or 0.008 lb/GWh

11. Mats Compliance Requirements 40CFR Part 60 & 63 • Appendix A to Subpart UUUUU - HG Monitoring Provisions Summary • Can use HG Cems or Sorbent Trap Sampling system for monitoring requirements • Not required to substitute for missing data for HG Cems or Sorbent Trap Sampling ( Monitoring System Down Time ) • Must designate what system is primary HG Cems or STS and then use to report hourly data ( 30 or 90 day collection ) option: If the units in an averaging group are designed to burn coal with GCV ≥ 8,300 Btu/lb, there are alternate Hg limits for the group (1.0 lb/TBtu or 1.1 x 10-2 lb/GWh based upon a 90-day rolling average instead of 30-day • Plants can opt to have a backup CMS or have a redundant CMS and they must be certified as well • NOTE: CMS can be HG Cems or Sorbent Trap System Terms: STS = Sorbent Trap Sampling System CMS = Continuous Monitoring System PS-12B = Performance Standard 12B

12. Mats Compliance Requirements 40CFR Part 60 & 63 • Appendix A to Subpart UUUUU - HG Monitoring Provisions Summary Cont. • Must convert HG analytical data collected ( ug/scm ) to reporting format of lb/TBtu or lb/GWh • The STS must be operated in accordance with PS-12B and all applicable QA/QC requirements • The STS requires the use of a Certified stack gas flow monitor to establish sampling flow rate/ stack flow rate ratio and hourly data logging verifying percent proportional sample to stack flow rate • A rata of STS is required for initial certification and conducted annually there after for compliance • Each pair of sorbent traps can be used to sample stack gas for up to 14 operating days Terms: STS = Sorbent Trap Sampling System CMS = Continuous Monitoring System PS-12B = Performance Standard 12B

13. Sorbent Sampling System QA/QC, Maintenance & Records • Requirements: QA/QC Plan, Preventive Maintenance & Records • Plant shall develop & implement a quality assurance program for the sorbent trap sampling system and the program shall include a written plan that describes step by step procedures for operation of system as well as QA/QC procedures to be followed also ( Quarterly Audit Requirements per PS-12B ) • Plant shall develop a monitoring plan for each unit or common stack for the STS, flow monitor & gas measurement system the monitoring plan shall contain all essential information to verify all systems are operated in accordance with specific standards for each instrument • Plant shall keep a written record of procedures to maintain the STS in proper operating condition and list • procedures including all procedures specified by MFG in addition to any procedure required by facility to • operate and maintain the system • Keep record of all testing, preventative maintenance & repairs for the STS in a format and location suitable • for inspection • Keep records for monitoring system integrity and data quality as well as procedures for trap COC and trap analysis • All equipment used for audits & calibration shall have a schedule for annual verification & re-certification and calibration documentation to certify device is calibrated to a specific standard

14. QA/QC Plan, Preventive Maintenance & Records Cont. • Record keeping provisions for STS , Flow Monitor, Gas Measurement & Moisture systems and equipment ID or serial numbers also a log showing activity relating to operation & maintaining instrumentation • Additional data required is hourly gross unit load data rounded to nearest MW to be used for emission reporting format in either lb/TBtu or lb/MWh • For all trap samples collected a code must be assigned in your records indicating concentration for the hour met all PS-12B QA/QC criteria • Data from STS shall include: flow rate, Gas meter reading ( dscm to nearest hundredth ) including beginning, ending and at least once during each hour also the ratio of sample flow/stack flow using certified stack flow monitor as specified in PS-12B • Monitor data availability must be documented as a % of unit operating hours calculated according to CFR 75.32 • Note Emission calculations are referenced in 40CFR part 60 & 63 sect. 6.2.1.1 & 6.2.1.2 and EPA Meth.19 Appendix A-7

15. Mats Startup/Shutdown Rule changes - Nov 30th, 2012 • Startup and Shutdown Provisions: • Startup & shutdown periods are now changed to work practice standards as follows: • The sources are required to burn clean fuels during startup & shutdown as listed below • You must operate all CMS ( Continuous Measurement Systems ) during startup and vent to main stack also start your APC ( Advanced Pollution Controls ) with the exception of limestone injection for FBC, SNCR’s & SCR’s which must be started as soon as conditions permit • EGU must conduct a boiler tune-up every 36 calendar months Clean fuels for start-up: Natural gas, Syngas, Ultra Low Sulfur Diesel, Propane Note: Other fuels are being considered and updated list should be issued in March Mats rule next updated release.

16. HG Emissions Reporting Overview • For units that continuously monitor mercury emissions: • KEY to Success is a monitoring plan must be developed and maintained • The Hg CEMS or sorbent trap monitoring system and any required additional monitoring • systems must be documented in your monitoring plan • Your monitoring plan data must be submitted to EPA electronically and updated when necessary, • using the Emissions Collection and Monitoring Plan System (ECMPS) Client Tool • For STS the Hg concentration obtained from the analysis of a pair of traps is reported for each • hour of the data collection period • Quarterly electronic reporting of Hg emissions is required, no later than 30 days after the end of • each calendar quarter

17. HG Emissions Reporting Overview Cont. • Hourly records of any additional data needed to convert Hg concentration to units of the emission • standard ( stack gas flow rate and / or moisture content, CO2 or O2 concentration, electrical load) • must be included in the electronic quarterly reports • The additional monitoring systems used to convert Hg concentration to units of the • standard must meet the requirements of 40 CFR Part 75 • The data acquisition and handling system (DAHS) must be programmed to provide an hourly data sent • in the units of the applicable Hg emission standard lb/TBtu or lb/GWh • The results of all required certification and QA tests of Hg CEMS or STS and the additional monitoring • system used to convert Hg concentration to units of the standard must be reported electronically using • the ECMPS Client Tool. • For Hg CEMS and STS RATA results and test details must also be submitted to the WebFIRE database • via ERT within 60 days after completing each test. • Compliance with the 30 (or in some cases, 90) operating day rolling average Hg emission rates is • assessed in the semiannual reports which are required

18. Sorbent Trap Sampling Systems Vendors CleanAir Met-80 Environmental Supply HGK-PFI Altech Amesa M Apex Instruments XC-6000 M&C STS

19. Apex Instruments XC-6000 Clean Air Met-80 Sorbent Sampler Systems Environmental Supply HGK-PF Altech Environment Amesa-M M&C STS

20. Challenging Sources & Environments

21. Sampling System Configurations Configuration 2 Configuration 1 Sampling system in shelter at base Sampling system near sample port

22. Very Poor Stack Conditions

23. High Particulate, Wet FGD & Lime Injection are some of the sampling challenges for 7 day runs

24. Trap Interferences Particulate, SO2, SO3, moisture • Particulate can scrub mercury before its absorbed in 1st section • Acid gases can cause excess breakthrough or loss of spike • High Moisture can cause breakthrough or loss of spike

25. 1 solution for these challenges of wet FDG & high particulateTrap Shields

26. Another Solution is your sampling Profile • Whether its high particulate or wet stack conditions – Keep your flow rates low typically 250 to 350 ccm or lower if possible. • For wets stacks keep your probe temperature hot enough - typically 300 to 350F. • Use the right trap for your stack conditions – Longer traps, Acid gas scrubber section, particulate filter option

27. Custom Traps – Designed for your source These traps were all ran for 7 days at different sources

28. Custom Solutions for Various Stack Conditions • High particulate/High Vacuum: • Coiled Pre-filter • Fluffy Pre-filter • Static Pre-filter • High Flow Glass (HFG) offered in 185mm, 240mm, & 450mm length glass (Provides roughly 27% less pressure drop over standard glass.) • Acid Gasses/Spike Loss or Breakthrough: • Acid Gas Scrubber (AGS) Sodium Carbonate Bed. (Custom Lengths Available) • Acid Resistant Carbon (ARC) • Custom Length Carbon Beds • High Moisture: • 300mm, 450mm, & 450mm HFG Length Glass for extended dry bed.

29. Keys to Success with Traps for Compliance • Look at the Data! • Ongoing Data Review • Have a “Go-To” Person who will take accountability for the success of your Mercury Monitoring • Open Dialogue with Ohio Lumex • We try to Catch it before you do…but, if you do the analysis, then stay in touch.

30. Lessons Learned: Sorbent Trap Analysis • When Mercury concentration is unknown, it is essential to break up the analytical carbon section into several ladles in order to make sure the runs will remain in range. • It is IMPERATIVE that each and every carbon particle is analyzed. Due to the strength of our carbon, even one tiny carbon particle has the ability to capture most, if not all, of the Mercury present in the section. • If you must use a Lumex Mercury Analyzer to analyze traps produced by companies other than Ohio Lumex, please be very cautious. We have had loaded ladles literally ignite while inside the furnace attachment. • It is essential to allow the analyzer to warm-up for approximately one hour before calibrating. Calibrations performed immediately upon startup tend to drift quickly.

31. Lessons Learned: Sorbent Trap Analysis (Continued) • Be sure to run check standards every ten ladle runs while performing analysis. A “second source” bottle will be used for these checks. A successful check will ensure that the calibration is still accurate. If you notice a calibration slowly drifting towards the 10% deviation range, it may be wise to recalibrate the analyzer in order to maximize precision. • Throughout the day, it is important to check the sodium carbonate buildup inside the attachment. If necessary, disconnect the tubes from the filter and vacuum out the attachment. Excessive buildup can block the light path inside the cell. (REMEMBER TO RECONNECT THE TUBES TO THE FILTER BEFORE RESUMING ANALYSIS).

32. Other Lessons Learned • Not all Labs are created equal • Some are inexperienced even if they have Ohio Lumex analyzers • Not all Sorbents in Traps are created equal • Traps have ignited inside Ohio Lumex Analyzer Furnaces • Traps have fogged up Ohio Lumex Analyzer Windows • Don’t put gun power in your Lumex even if it does look like Carbon • Not all stack testers are created equal • If you are doing Speciation traps testing around an SCR and your stack tester tells you he does not plan to use a cooling probe, get concerned! • If he tells you he plans to take the sample out of the stack and have feet of lines in front of the speciation traps, please tell them to talk to us. • If he tells you that he can measure particulate bound Hg with a sorbent trap, be cautious! • You can always ask us for recommendations, it is our Mission to make sure your Mercury Test is a success • Not all consultants are created equal • If they are giving you recommendations on how to do analysis with an Ohio Lumex Analyzer that goes against what Ohio Lumex says, be weary! • If the traps were Made in China and say “Ohio Lumex” on them, think…… bad idea! But fried rice for lunch on the other hand… delicious! • Sorry for the Negative nature of this slide, we have seen some CRAZY things!

33. NELAP Certified

34. The Ohio Lumex Philosophy We base our business values on trust, accuracy, and reliability. We have more than 15 years of experience in the field of mercury testing at a wide variety of plants. Take advantage of our capabilities.

35. www.ohiolumex.com Phone: (330) 405-0837 or (888) 876-2611 Fax: (330) 405-0847 sales@ohiolumex.com