# Presentation: 529567

## Update on Mercury MonitoringUnder CAMR

- Ruben Deza, PhD
- Clean Air Markets Division, EPA
- EPRI CEMS Meeting
- Columbus, OH, May 2006

## Overview

- Field Demonstrations
- Gas Calibration Standards
- Instrumental Reference Method
- Changes to CAMR Monitoring
- Other Technical issues

## Demonstrations

- Test Sites:
- North Carolina (EPA-funded) and Kentucky (EPRI-funded), WE Energy,  Lehigh University, and also at NIST and ORD labs
- The focus:  issues that affect program implementation:
- Reliability of monitoring systems
- Development of certified gas standards
- Development and testing of an instrumental reference method (IRM)

## Demonstrations- cont.

- Lehigh Field Study
- 8 day test scheduled for late June, 2006 at a coal-fired power plant in PA
- Draft Hg IRM will be compared to paired OH trains.  Concurrent data will be collected from 2-3 Hg CEMS, including two portable Hg analyzers with newly designed probes, and sorbent traps
- Will investigate traversing capability of the equipment and the time required per run
- Will test dynamic spiking procedures
- Will fine-tune CEMS performance criteria

## Calibration Standard Issues

- Two forms of vaporized Hg are needed for the calibration of mercury CEMS and reference methods
- CAMR requires “NIST Traceable” Hg gas standards for both Hg0 and Hg2+
- EPA defines NIST traceability

## Calibration Standard Issues – cont.

- Currently, working with ORD and NIST to develop Hg traceability protocols, so that vendors can produce accurate Hg gases or gas generators for the regulated community
- Hg0 gas cylinders:
- Working with NIST to establish Hg0 standards (known as NTRMs) that gas vendors can use with a traceability protocol to mass-produce Hg calibration gas cylinders for the regulated community
- EPA and NIST are working to establish a traceability protocol
- Hg0 calibration gas generators
- EPA and NIST are also working to establish a traceability protocol for elemental Hg gas generators
- There is a good chance that the development of the traceability protocol will follow the pattern of ozone generators

## Instrumental Reference Method

- Issues
- Provide an alternative to OH, consistent to what is done under other trading programs
- Minimizes data loss and testing costs in cases where a RATA is failed
- Measures “real-time” Hg concentrations in the stack gas and is suitable for multiple Hg CEMS technologies
- Quality of data obtained must be comparable to OH data
- Emphasis on simplicity and practicality and ease of  implementation
- Limited available data was used to support development of Draft Conceptual Instrumental Reference Method
- Draft Conceptual IRM released, available at :
- 		http://www.epa.gov/ttn/emc/new.html
- 		http://www.epa.gov/ttn/emc/prelim.html

## Instrumental Reference Method – cont.

- Method has not been fully demonstrated
- Considerable testing and data collection needed to make IRM viable
- EPA and EPRI teaming up to find sites suitable for the demonstrations
- Dynamic spiking of sampled stack gas with Hg+2 for assessment of site-specific matrix effects
- Two portable instruments will be tested on site
- To verify achievable performance and address practical implications such as implementation that are IRM-specific to later modify draft, if necessary

## Changes to CAMR

- In our re-engineering rule package, we will propose to add Method 29 as an alternative Hg reference method.
- RM 29 is similar to the OH method, but is more familiar to testers, does not speciate Hg, and uses fewer impingers,
- RM 29 could be used for RATAs and low-mass emitter testing under CAMR. Many States accept Method 29 data.
- Various technical corrections will be proposed to Subpart I of Part 75, e.g., adding multiple/common stack heat input procedures
- The proposed rule is expected in Summer 2006

## Technical Issues of Concern

- Wet Stack Issues – Probes - Alternate Probe Designs
- Industry is working to address the problem; promising advances have been made
- Stratification- use of SO2 as surrogate
- Tests will be done at the Lehigh demo to study the practicality and accuracy of such procedure
- Hg CEMS Performance at very low Hg levels
- Vendors are addressing the technical difficulties and making significant progress
- Other issues under consideration:
- Revisit the need for dual trains for the OH
- Injection of multiple levels of elemental and Hg+2 calibration gas at probe, dilution orifice and analyzer
- Continue supporting the work on thermal desorption of sorbent traps

##  Thanks