Update on CAMR Mercury Monitoring Program

1. Update on CAMR Mercury Monitoring Program Charles Frushour EPA, CAMD CAIR/CAMR Implementation WorkshopArlington, Virginia December 5, 2007

2. Mercury Emission Monitoring Under CAMR • The Clean Air Mercury Rule (CAMR) requires affected units (coal-fired units that generate electricity for sale and serve a generator > 25 MW) to continuously monitor and report mercury mass emissions • Existing units must install and certify mercury monitoring systems by January 1, 2009 • New units must install and certify mercury monitoring systems within 90 operating days or 180 calendar days (whichever comes first)after commencement of commercial operation • Owners/operators of affected units may monitor mercury using a continuous emission monitoring system (CEMS) or a sorbent trap monitoring system • Many have already begun ordering monitoring and data acquisition systems and will begin certification testing of their systems in the first quarter of 2008

3. Mercury Emission Monitoring Under CAMR • Low- emitting units (< 29 lbs/yr mercury emitted) may also qualify for a less rigorous monitoring approach, using conservative emission factors derived from emission testing • Development of the mercury monitoring program has been a collaborative effort between EPA (OAQPS, ORD, CAMD), NIST and industry (EPRI, utility representatives and others) • We’re still on schedule to have a strong monitoring capability in place by Jan 2009, which is CAMR’s practice year for mercury data monitoring and reporting

4. Mercury Monitoring Progress • Finalizing Part 75 rule modification package, rule to become final within a month • Completed and published direct final rule package which includes instrumental and sorbent trap reference methods – both alternative reference methods became final on November 6th • Preparing NIST-traceable calibration gas certification procedures and protocols • Continuing field demonstration testing of alternative mercury reference methods • Developing training materials and conduct training for EPA Regions, States and sources • CAIR/CAMR implementation workshops in Atlanta, Chicago, Dallas, Kansas City, and Arlington VA (tomorrow) • CAMR mercury monitoring training workshop in Washington, D.C. • Additional workshops to follow

5. Proposed Monitoring Changes to Part 75 • Proposed changes to Part 75 were published August 22, 2006 (comment period was closed in October 06) • Proposed rule includes • a “re-engineered” Part 75 data collection and processing system incorporating a user-friendly XML format • minor technical/procedural changes to Subpart I of Part 75 (Hg Mass Emission Provisions) including adding multiple/common stack heat input procedures • Reference Method 29 proposed as an alternative Ontario Hydro reference method • Waiver of the elemental and oxidized Hg gas traceability requirements as specified in the interim traceability protocols untilJanuary 1, 2010 • Rule expected to become final within a month

6. Alternative Reference Methods Included as Part of Direct Final Rule Package Final instrumental and sorbent trap-based reference methods (Method 30A and 30B) • The direct final package is posted on OAQPS Emission Measurement Center website and linked to CAMD’s website - refer to Method 30A and 30B posted at: http://www.epa.gov/ttn/emc/new.html http://www.epa.gov/airmarkets/emissions/rules.html • This posting helps power plants and stack testers plan for upcoming certification tests • Rule was signed August 17th and published in the Federal Register September 7th • Rule became final November 6th

7. Additional Hg-Related Part 75 Changes in Direct-Final Rule • The following changes to Subpart B (Monitoring Provisions) and Appendix K are being included in the Alternative Reference Method Rule Package • Providing minor clarifications to the Hg monitoring and measurement provisions • Requiring same type of sorbent material used during an Appendix K RATA also be used during daily operation • Allowing smaller sorbent traps to be used during an Appendix K RATA than used during daily operation • will reduce the required sampling time per run • Removing spike recovery normalization correction to sorbent trap monitoring systems • Providing alternatives to dry gas meters in Appendix K (e.g., allowing the use of thermal mass flow meters)

8. Mercury Instrumental Reference Method (IRM) • Timely (real-time) • Performance-based • Amenable to multiple and new technologies • Test program-specific verification of data quality • Agency committed to performance-based methods (Federal Register Notice of Intent 62 FR 52098, 10/6/97) • Consistent w/ SOx & NOx instrumental methods • Key elements • Calibration error/linearity • System integrity/conversion efficiency • System response time • Interference test • Dynamic spiking (gaseous method of standard additions)

9. IRM Advancements - Update on Demonstration Testing • More portable IRM equipment are now available (e.g., 25 pound probes as compared to 150 pound probes or higher just a year ago) • We can traverse, conduct tracer gas flow measurements and conduct dynamic spiking with latest IRM sampling equipment • We are working with vendors to optimize their equipment • These new equipment will be used for upcoming Hg stratification testing • Stratification testing is our highest remaining priority for IRM verification testing

10. Sorbent Trap Reference Method for Mercury • Performance-based • Amenable to new sorbents, equipment, and analytical technologies • Lab verification of sorbent performance and analysis • Test program-specific verification of data quality • Capability for timely results • Description • Known volume of stack gas is sampled through paired, in-stack 2-section sorbent traps (e.g., iodated carbon) • Analysis by any suitable system that can meet performance criteria (e.g., leaching, digestion, thermal desorption/direct combustion coupled with UV AF, UV AA, XRF)

11. Sorbent Trap Reference Method for Mercury, cont. • Key QA Elements • Laboratory • Matrix interference test (for wet digestion analyses) • Minimum sample mass determination • Analytical bias test (Hg0 and Hg2+) • Field (for each test) • Paired train agreement (assess precision) • Sorbent trap second section breakthrough • Field recovery test (assess bias)

12. Advancements in Sorbent Trap Method - Update on Demonstration Testing • EPA has successfully demonstrated the efficacy and timeliness of the sorbent trap reference method during recent (May 07) demonstration tests • Good spike recoveries (within ± 15% of complete recovery) • Reduced quantity of Hg needed for analysis (about 20 ng minimum sampling mass) • Reduced sampling time (one hour or less) • We will conduct additional sorbent trap testing within the next few months to verify performance on a wet stack with elevated SO3 • Tests to be run at different flow rates and with different sorbent materials

13. Hg Gas Standard Traceability • Our Part 75 monitoring rule requires “NIST Traceable” elemental and oxidized Hg gas standards to be developed and used • A "NIST-traceable" Hg gas generator is one that has been compared and certified directly (without intermediate standards) to another Hg gas generator that has been certified by NIST at its laboratories • Gas standards must be traceable to a measured, not theoretical, concentration

14. Update on NIST-Traceable Hg Calibration Gas Standards • EPA and NIST continue their collaborative work to provide NIST traceability for elemental and oxidized mercury calibration standards • NIST has completed certification testing for their NIST primary gas generator and for the first round of “vendor-prime” generators • EPA is working with Western Research Institute, NIST and vendors to conduct variability/uncertainty testing of mercury gas generators and cylinders • We have developed a draft interim traceability protocol for elemental mercury gas generators and are developing a comparable protocol for oxidized mercury gas generators

15. Update on NIST-Traceable Hg Calibration Gas Standards (cont.) • Manufacturers have shipped elemental mercury gas cylinders to NIST to establish NIST traceability • Elemental mercury gas cylinder traceability procedures will be added to the existing Green Book (the existing EPA traceability protocol for SO2/NOx calibration gas standards) • Shelf life and stability of mercury gas cylinders will be assessed by NIST and EPA with input from vendors and Western Research Institute

16. How NIST Traceability Works for Elemental Hg Generators • NIST calibrates individual set points that are used to certify vendor-prime generators • NIST certifies vendor-prime generators using ID-ICP/MS • It is the responsibility of the vendor to qualify and certify their field generators using the procedures in the traceability protocol • It is the responsibility of the end user to perform the QC checks once their generators have been placed into field operation • The draft interim traceability protocol • certification tests form the “back-bone” of the traceability protocol • these tests used to establish traceability of field generators (user-primes) to NIST-certified generators (vendor-primes) • draft protocol also includes criteria to qualify for certification and periodic QC check procedures to evaluate generator performance in the field

17. Certification Tests for Establishing Traceability/ Draft Interim Elemental Gas Generator Protocol • Certification tests have been designed to establish quantitative relationships between each field generator and a certified vendor-prime generator • These quantitative relationships will be ultimately be available in easy-to-use spreadsheet software that vendors can use to enter generator set point vs measured concentration • The spreadsheet will establish the predictive relationship of generator set point to output concentration with a known uncertainty as a relative function of concentration

18. Traceability of Oxidized Hg (HgCl2) • HgCl2 gas standards complications • Harder to measure • Multiple technologies • Availability of current technologies • NIST focus has been on Hg0 standards • EPA working with NIST to develop their HgCl2 capabilities • EPA working with NIST to consider multiple HgCl2 gas standard traceability approaches • Traditional – traceable to NIST HgCl2 standard • Traceable to Hg0 standards (Hg0 to HgCl2 converters) • Verification of intrinsic performance (Hg solution. evaporators)

19. New Phased Approach to NIST Traceability • We propose to waive the elemental and oxidized Hg gas traceability requirements as specified in the interim traceability protocols untilJanuary 1, 2010 • This does not change the requirement for certifying mercury monitoring systems – these systems still need to be installed and certified by January 1, 2009 • We invited EPRI/utilities/vendors to participate in a field demonstration program that implements the interim traceability protocols and provide us with the data called out in the interim protocols, such as extended uncertainty, repeatability and relative difference calculations – demonstration program planning will begin shortly with program implementation in 2008 • Based on the results, we will complete the traceability protocols

20. New Phased Approach to NIST Traceability • This is a phased approach to NIST traceability and to implementing the mercury monitoring program under CAMR • We invited utilities and vendors to participate in the development of implementable protocols that produce the highest quality calibration gases possible • The first phase (2008) would be devoted to certifying the Hg monitoring systems • The second phase (2009) would then be devoted to certifying Hg generators/calibrators to establish NIST traceability prior to allowance accounting in 2010 • This will allow time for us to analyze the demonstration results and allow industry time to more fully develop the infrastructure to implement the protocols

21. Providing Interim Traceability for Elemental and Oxidized Hg Generators used for IRM Testing • We are preparing procedures that may be used to provide interim traceability to elemental and oxidized Hg calibration gases used in the instrumental reference method (IRM) • This “interim traceability” provision can be used only for IRM calibration gases and only until the formal EPA traceability protocols are finalized, then the IRM gases will need to be certified according to these protocols • We intend to post the interim procedures on the OAQPS and CAMD website by the end of the year

22. Questions??? Comments?? Thank You!!