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Mercury Monitoring

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.

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Mercury Monitoring

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  1. Mercury Monitoring Barrett Parker, EPA Emissions Measurement Center

  2. 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

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

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

  5. Test Objectives • Determined • 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

  6. 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

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

  8. 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

  9. 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

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

  11. EPRI’s Carbon Tube Sampler

  12. 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

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

  14. 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

  15. Phase I - Initial

  16. Phase I - Initial

  17. Phase I – Final

  18. Phase I - Final

  19. Phase II - Initial

  20. Phase II - Initial

  21. Phase II - Final

  22. Phase II - Final

  23. Phase III - Pilot Scale

  24. Phase III - Pilot Scale

  25. Phase III - Initial

  26. Phase III - Initial

  27. Selected Phase III – Initial Runs

  28. Phase III - Final

  29. Phase III - Final

  30. DRAFT Phase IV - Initial

  31. DRAFT Phase IV – Initial and Proposed MACT Limit

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

  33. DRAFT Phase IV - Final

  34. DRAFT Phase IV – Final and Proposed MACT Limit

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

  36. 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

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

  38. 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

  39. 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

  40. 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)

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

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

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