COST ANALYSIS OF MERCURY MONITORING TECHNIQUES TASK 1: COST OF MERCURY MEASUREMENT TECHNIQUES DRAFT REPORT, Revision 1 3 NOVEMBER 2003 Infrastructure, buildings,

environment, communications Cost Analysis of Mercury Monitoring Techniques Task 1: Cost of Mercury Monitoring Techniques Draft Report, Revision 1 Brent Hall Project Manager Carl Singer Project Engineer Michiel Doorn Project Engineer Prepared for:

U. S. Environmental Protection Agency Clean Air Markets Division Prepared by:

ARCADIS G& M, Inc.

4915 Prospectus Drive Suite F Durham North Carolina 27713 Tel 919 544 4535 Fax 919 544 5690 Our Ref.:

RN096402.0001 Date:

3 November 2003 This document is intended only for the use of the individual or entity for which it was prepared and may contain information that is privileged, confidential, and exempt from disclosure under applicable law. Any dissemination, distribution, or copying of this document is strictly prohibited. i Table of Contents List of Tables iii List of Acronyms iv 1. Introduction 1 1.1 Scope 1 1.2 Clear Skies Act 2 1.2.1 Common Provisions 3 1.2.2 Mercury Emissions Reductions 3 1.2.3 Performance Standards for New Sources 4 1.3 General Assumptions 4 2. Ontario Hydro ( OH) Analysis 7 2.1 Background 7 2.1.1 Scope and Applicability 7 2.1.2 Technique 7 2.1.3 Accuracy and Precision 8 2.2 Assumptions 8 2.3 Capital Costs 8 2.4 Annual Costs 9 2.4.1 Labor Costs 9 2.4.2 Subcontract and Other Direct Costs ( ODC) 9 2.4.3 Annualized Capital Costs 9 2.4.4 Total Annualized Cost 10 2.5 Uncertainties 10 3. Carbon Trap Analysis 11 3.1 Background 11 3.1.1 Preliminary Methods 11 3.1.2 Scope and Applicability 13 3.1.3 Technique 13 3.1.4 Accuracy and Precision 15 3.2 General Assumptions 15 3.3 Capital Costs 17 3.4 Annual Costs 18 ii Table of Contents 3.4.1 Labor Costs 18 3.4.2 Subcontract and ODC 19 3.4.3 Annualized Capital costs 19 3.4.4 Total Annualized Costs 19 3.5 Uncertainties 20 4. CEMS Analysis 22 4.1 Background 22 4.1.1 Scope and Applicability 23 4.1.2 Technique 29 4.1.3 Accuracy and Precision 29 4.2 General Assumptions 31 4.3 Capital Costs 31 4.4 Annual Costs 33 4.4.1 Annual Labor Costs 33 4.4.2 Subcontract and ODC 34 4.4.3 Annualized Capital Costs 35 4.4.4 Total Annualized Costs 35 4.5 Uncertainties 35 5. Fuel Analysis 36 5.1 Background and Methods 36 5.1.1 Scope and Applicability 36 5.1.2 Accuracy and Precision 37 5.2 Assumptions 38 5.3 Annual Costs 39 5.3.1 Labor Costs 39 5.3.2 Subcontract and ODC 40 5.3.3 Total Annualized Costs 40 5.4 Uncertainties 40 6. Discussion and Summary 42 6.1 Comparison Carl: please update this section with revised costs. 42 6.2 Barriers to Cost Analysis 43 6.3 Suggestions for Improvements and Additional Research 44 iii Table of Contents List of Tables Table 1 1. Projected Emissions Reductions under Clear Skies Act ( EPA, 2002i.) 3 Table 3 1. Draft MQO for Sorbent Total Mercury by internal Frontier Geosciences Method 12 Table 3.2: Assumed Carbon Trap Analytical Summary 17 Table 4 1. Overview of Mercury CEMs that are ( expected to be) Commercially Available in the United States 24 Table 4 2. Operation & Maintenance 27 Table 4 3. CEMS Capital Cost ( March 2003) 32 Table 5 1. ASTM D 3684 01 Bias 37 Table 6 1. Summary of Mercury Annual Analysis Costs 42 iv Table of Contents List of Acronyms ADAES ADA Environmental Solutions ASTM American Society for Testing and Materials AWMA Air and Waste Management Association BACT Best Available Control Technology BART Best Available Retrofit Technology CAA Clean Air Act CEM Continuous Emission Monitor CEMS Continuous Emission Monitoring System CRM Certified Reference Material CVAAS Cold Vapor Atomic Absorption Spectroscopy CVAFS Cold Vapor Atomic Fluorescence Spectroscopy DOE Department of Energy EPA United States Environmental Protection Agency EPRI Electric Power Research Institute ETV Environmental Test Verification ICR Information Collection Request IGCC Integrated Gasification Combined Cycle LAER Lowest Achievable Emission Rate MESA Mercury Speciation Adsorption MQO Method Quality Objectives v Table of Contents NAAQS National Ambient Air Quality Standards NIST National Institute of Standards & Technology NSPS New Source Performance Standard NSR New Source Review OAQPS Office of Air Quality Planning and Standards ODC Other Direct Costs OH Ontario Hydro PM Particulate Matter QA Quality Assurance QSEM Quick Silver Emissions Monitor RATA Relative Accuracy Test Audit RDF Refuse Derived Fuel RSD Relative Standard Deviation SIP State Implementation Plan SOP Standard Operating Procedures TSCA Toxic Substances Control Act WRAP Western Regional Air Partnership 1 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 1. Introduction 1.1 Scope Anthropogenic mercury emissions are considered a potential serious health hazard. As a by product of combustion processes, mercury emitted to the air can be transformed into the highly toxic methyl mercury form by means of a natural process in the atmosphere. The Mercury Study and the Utility Hazardous Air Pollutant Reports1 to congress have identified coal fired power plants as the largest anthropogenic source of mercury emissions. In December 2000, the United States Environmental Protection Agency ( EPA) made the determination to regulate mercury emissions from coal fired power plants under section 112 of the Clean Air Act ( CAA) Amendments of 1990. EPA is required to promulgate mercury emissions standards to electricity generating utility boilers by December 2004, to be implemented by December 2007. According to the explicit language of the Clean Air Act, these standards must reflect the utilization of " Maximum Achievable Control Technology" ( MACT) for mercury.

As a possible alternative the Bush Administration proposed legislation in 2002 under the Clear Skies Initiative to establish a flexible, market based program to reduce and cap emissions of sulfur dioxide, nitrogen oxides, and mercury from coal fired power plants and other electric power generators. Such a program is already in place for sulfur dioxide and nitrogen oxides under the Acid Rain Program and the NOX State Implementation Plan ( SIP) Call.

As part of a mercury control or cap and trade program, EPA will need to implement monitoring requirements that are cost effective, technically viable, contain sufficient quality assurance ( QA), and are based on technologies and equipment that are compliance capable. Mercury emission reductions under CAA MACT or under Clear Skies may have different monitoring requirements.

EPA has conducted several studies to describe and compare various mercury monitoring technologies, as well as a cost effectiveness study based on preliminary 1 U. S. EPA, 1998. Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units   Final Report to Congress. U. S. EPA, Office of Air Quality Planning and Standards Research Triangle Park, NC 27711. February 1998. EPA 453/ R 98 004a 2 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 information. 2 This report is a continuation of this previous study and provides a detailed cost analysis of four mercury monitoring technologies applicable at coal fired power plants. The technologies are fuel analysis, the American Society for Testing and Materials ( ASTM) Ontario Hydro ( OH) method, iodated carbon traps, as well as continuous emissions monitoring systems ( CEMS).

1.2 Clear Skies Act The Clear Skies Act would amend Title IV of the CAA to establish new cap and trade programs requiring reductions of SO2, NOX, and mercury emissions from electric generating facilities and amends Title I of the CAA to provide an alternative regulatory classification for units subject to the cap and trade programs. The market based approach should allow for the implementation of multi pollutant control systems. Also, the ability to carry over unused allowances is believed to create incentives for early reductions, delivering environmental and human health benefits sooner, in exchange for a longer compliance window for sources. Ultimately, the cap ensures that the emission reduction goals are met and maintained. The EPA projects emission reductions for SO2, NOX, and mercury of 73, 67, and 69 percent respectively, compared to 2000 emissions. Table 1 1 includes projected emissions reductions. The Act does not require reductions in CO2 emissions, although there is a provision to maintain CO2 monitoring and reporting requirements that currently exist under the CAA.

As revised by the Clear Skies Act, Title IV of the CAA has five Parts. Part A contains provisions common to the control of all three pollutants. Part B contains provisions specifically for sulfur dioxide emission reductions. Part C contains provisions specifically for nitrogen oxides emission reductions. Part D contains provisions specifically for mercury emission reductions. Part E contains performance standards for affected units and provisions for research, environmental monitoring, and assessment. Part E of the Clear Skies Act includes substantial changes in the New Source Review ( NSR) and New Source Performance Standard ( NSPS) sections of the existing CAA ( EPA, 2002i). Below, summaries are provided for Parts A, D, and E.

2 Cadmus Group, 2003. Mercury Monitoring Cost Effectiveness Analysis. Draft report prepared for Ruben Deza, U. S. EPA. Clean Air Markets Division, Washington DC. Prepared by The Cadmus Group, 6330 Quadrangle Drive, Chapel Hill. 3 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 1.2.1 Common Provisions The Clear Skies Act establishes a new Part A of Title IV of the CAA, which contains the program elements shared by the SO2, NOX, and mercury programs. A cap and trade program will be implemented for each pollutant. Common definitions, allowance system procedures, monitoring, permitting and compliance requirements, penalties for non compliance, opt ins and auction procedures apply to the new trading programs and are modeled largely after the existing Acid Rain Program.

Table 1 1. Projected Emissions Reductions under Clear Skies Act ( EPA, 2002i.)

Clear Skies Act emission caps Actual emissions in 2000 First phase of reductions Second phase of reductions Total reduction at full implementation SO2 ( million tons) 11.2 4.5 ( in 20101) 3 ( in 20181) 73%

NOX 2 ( million tons) 5.1 2.1 ( in 20081) 1.7 ( in 20181) 67%

Mercury ( tons) 48 26 ( in 2010) 15 ( in 20181) 69%

Because sources can reduce emissions early, earn allowances for those actions, and use these allowances later, actual emission levels will be higher that the cap in the first years of these phases.

The NOX cap is divided between two zones with separate trading programs under each zone. Zone 1 generally includes Eastern states and Zone 2 includes Western states and territories.

The Administrator must establish an allowance system for SO2, NOX, and mercury that is essentially the same as the current Acid Rain Program but provides for a safety valve, i. e., a direct sale of allowances by the Administrator at a fixed price for use in meeting the requirement to hold allowances at least equal to annual emissions. Criteria and the process will be established by which the Administrator may recommend to Congress adjustment of the total amounts of allowances available ( whether through allocation or auction) starting in 2018 under the new SO2, NOX, and mercury trading programs.

1.2.2 Mercury Emissions Reductions The Clear Skies Act establishes Part D, which contains the new, annual caps on total mercury allowances and new, allocation procedures starting January 1, 2010. The new mercury trading program is analogous to the new SO2 and NOX trading programs and cover the same coal fired units. Annual mercury emissions are capped at 26 tons starting in 2010 and 15 tons starting in 2018. Each year, the percentages of allowances 4 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 allocated and auctioned are the same as under the new sulfur and NOX trading programs.

1.2.3 Performance Standards for New Sources To ensure that all new affected units have appropriate controls, Part E establishes performance standards for all new boilers, combustion turbines, and IGCC plants covered under the Act. " New" units are those that commence construction or reconstruction after the date of enactment.

These statutory performance standards include emission limits for four air pollutants: NOX, SO2, mercury, and particulate matter ( PM). The mercury emission limit applies only to coal. In addition, a PM emission limit is established for existing oil fired boilers to ensure reductions of nickel from such units.

All units subject to a performance standard must monitor emissions using continuous emission monitoring systems ( CEMS) and use averaging times similar to current NSPS.

1.3 General Assumptions The sampling program is assumed to be based on a single stack or single unit testing. No discount has been allowed for multiple site testing at a plant or multiple plant testing. Multiple units being served by a common stack would be tested under a single sampling program.

For cost estimation, it is assumed that the plant will contract for OH sampling and analysis. Costs for the plant to administer the OH analysis program for Hg are based on the Information Collection Request ( ICR) supporting statement, 3 which assumes the following hours on a yearly basis:

For obtaining an OH sampling contract, 40 technical hours.

3" U. S. EPA, " Standard Form 83 1 Supporting Statement for OMB Review of ICR No._____:[ sic] Information Collection Request for Electric Utility Steam Generating Unit Mercury Emissions Information Collection Effort," November 16, 1998. available at http:// www. epa. gov/ ttn/ atw/ combust/ utiltox/ 114_ ss19. pdf. 5 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1

For oversight of OH sampling events, 8 technical hours per test.

To compile and review analytical data, 8 technical hours per sampling event.

To submit test results, 1 technical hour per event.

For all technical work, associated management hours have been assumed to total 5 percent of technical hours and clerical hours have been assumed to total 10 percent of technical hours.

Cost for plant labor hours have been assumed to be the same as used in the ICR Supporting Statement:

Technical hours $ 47.50, Management hours $ 57.27, and Clerical hours $ 26.96.

To estimate the cost associated with OH sampling, ARCADIS obtained three estimates for a sampling event of three OH runs at one location at a utility stack within 500 miles traveling distance from the sampling firm: $ 8,500,4 15,000,5 and between 12,000 and 15,0006. The ICR supporting statement contained an estimated cost of $ 40,020 for concurrent OH tests at two locations7. Consequently, costs for contracting for OH sampling and analysis are estimated at $ 15,000 per sampling event of three tests. It is assumed that this number can be broken out as follows: $ 4,000 for travel and lodging 4 Personal communication from Brian Jacobs, METCO Environmental, to Carl Singer, ARCADIS, on March 26, 2003.

5 Personal communication from Gene Stephenson, ARCADIS, to Carl Singer, ARCADIS, on March 11, 2003.

6 Personal communication from Ralph Roberson, RMB Consulting, to Carl Singer, ARCADIS, on March 11, 2003.

7" U. S. EPA, " Standard Form 83 1 Supporting Statement for OMB Review of ICR No._____:[ sic] Information Collection Request for Electric Utility Steam Generating Unit Mercury Emissions Information Collection Effort," November 16, 1998. available at http:// www. epa. gov/ ttn/ atw/ combust/ utiltox/ 114_ ss19. pdf 6 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 of the OH contractor and $ 11,000 for the three test event. This can be used to estimate the costs of different sampling events. For example, a nine test event would cost ( 3 × $ 11,000) + $ 4,000 = $ 37,000. 7 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 2. Ontario Hydro ( OH) Analysis 2.1 Background The ASTM recently issued the OH method under designation D6784 02 approved April 10, 2002. The OH method is a gas sampling method that differentiates mercury into particle bound, oxidized, and elemental fractions. The OH method was widely used as the basis for sampling plans under the recent mercury ICR phase III.

2.1.1 Scope and Applicability The OH method is applicable to the determination of elemental, oxidized, particlebound and total mercury emissions from coal fired stationary sources. Resulting emissions are expressed in concentration terms, µ g/ Nm3. Conversion of OH results into an annual mass emission will require application of additional methods.

Though the method explicitly claims applicability to coal fired stationary sources, the method does not appear to exclude the use of other fuels such as coke, orimulsion, oil, tires, refuse derived fuel ( RDF), or biomass. Use of alternate fuels may produce ash that may further confound speciation bias in the OH method but is not expected to effect total mercury.

2.1.2 Technique The OH method involves extracting a flue gas sample through either a modified method 5 or method 17 sampling train. Sample location and traverse points are determined using Methods 1 or 2. Mercury is absorbed from the sample into various solutions in the train. The gas volume sampled is metered as the sample exits the sampling train. At the conclusion of an integrated sampling event, the train is recovered generating analytical samples specific to particular mercury forms. The analytical samples are digested and analyzed in a laboratory. 8 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 2.1.3 Accuracy and Precision There are no known biases to the OH method for total Hg, however several conditions can affect the speciation of the sample. 8 The relative standard deviations for gas phase elemental and oxidized Hg were less than 11 percent for concentrations greater than 3 µ g/ m3 and less than 34 percent for concentrations less than 3 µ g/ m3.9 A number of revisions to the OH method have been made since the Method 301 evaluation cited in the OH method. The precision of the OH method is likely to have improved since the initial Method 301 evaluation.

2.2 Assumptions For the purposes of calculating total mercury emissions, 12 OH sampling events are assumed with 3 OH tests required for each sampling event. The resulting 36 tests are expected to provide an accuracy of ± 8.4%, similar to that expected from a nine point Relative Accuracy Test Audit ( RATA) for a CEMS.

For cost estimation, it is assumed that the plant will contract for OH sampling and analysis. Further, the sampling program is assumed to be based on each stack such that multiple units being served by a common stack would be tested under a single sampling program.

2.3 Capital Costs An OH analysis program is likely to be based on sampling after the particulate control device and is not expected to result in any significant capital costs. Current stack sampling locations are expected to be adequate for OH sampling and no system modifications will be required.

For purposes of estimation, it is assumed that plants will contract with sampling firms for OH sampling. Sampling firms are expected to supply their own sampling equipment as part of their cost of doing business.

8 D6784 02 Standard Test Method for Elemental, Oxidized, Particle Bound, and Total Mercury in Flue Gas Generated from Coal Fired Stationary Sources ( Ontario Hydro Method), ASTM International, West Conshohoken Pennsylvania, June 1, 2002.

9 ibid. 9 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 2.4 Annual Costs 2.4.1 Labor Costs Costs for administering the OH analysis program are estimated using values from the ICR supporting statement. 10 The following technical hours have been assumed per year:

For obtaining an OH sampling contract, 40 technical hours.

For oversight of 12 OH sampling events, 288 technical hours.

To compile and review analytical data, 96 technical hours.

To submit test results, 12 technical hours have been assumed annually.

Total Technical hours for administration of the program is therefore expected to be 436 hours per year. Accordingly, labor costs for the Hg analysis program at the stack level are estimated at $ 23,134 annually, including management and clerical costs.

2.4.2 Subcontract and Other Direct Costs ( ODC)

As indicated in Section 1.1.1 costs for contracting for OH sampling and analysis are estimated a $ 15,000 per sampling event of three tests. Subcontracting and ODC costs for an OH sampling program incorporating 12 sampling events is, therefore, estimated at $ 180,000 per year for each stack in the program.

2.4.3 Annualized Capital Costs No significant capital costs are expected for an OH based monitoring plan. Annualized capital costs are therefore estimated at $ 0/ year.

10 U. S. EPA, " Standard Form 83 1 Supporting Statement for OMB Review of ICR No._____:[ sic] Information Collection Request for Electric Utility Steam Generating Unit Mercury Emissions Information Collection Effort," November 16, 1998. available at http:// www. epa. gov/ ttn/ atw/ combust/ utiltox/ 114_ ss19. pdf. 10 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 2.4.4 Total Annualized Cost Total Annualized costs for the OH emissions monitoring plan is estimated at $ 203,134.

2.5 Uncertainties OH is presumed to be the reference method for potential mercury air emissions regulation. The draft performance specification for mercury continuous monitoring systems cites 40CFR266, Appendix IX, Section 3.1. Use of different reference methods such as Method 29, Method 101A or Method 0060 are not expected to drastically affect the cost of each test, however, the monitoring program may require adjusting to achieve acceptable accuracy and precision.

The cost of an OH sampling program for determining emissions is largely driven by the frequency of sampling and the number of samples. For this analysis, we have assumed triplicate runs of OH on a monthly basis. Sites may require more or fewer samples to achieve the same confidence interval depending on the actual variability encountered. Variability is expected to arise from unit operation and method chosen for analysis. 36 OH runs were selected as a basis assuming a 25% relative standard deviation ( RSD) and a desired confidence interval of ± 8.4%.

An OH sampling program for determining emissions relies on a representative sample being collected. Such a program must be designed to collect a representative sample. Confounding factors may include changes in fuel, daily, weekly, and seasonal variations in operations, and catastrophic events. If there is significant serial correlation in mercury sampling, the number of tests may need to be increased to achieve the same confidence interval.

While it appears probable that an OH sampling program could be designed to provide an accurate estimate of the amount of mercury emitted from a stack, OH sampling may be inappropriate for an emission trading program. Specifically, it is doubtful that an OH sampling program could provide information with the same timeliness as a Hg CEMS. With an OH sampling program, it would be difficult to identify changes in emissions resulting from either operational or mechanical changes in the system; failure in a control system, such as a carbon injection system, would not likely be discernable using OH sampling. The applicability of an OH sample program is therefore likely dependent on other records and a workable data substitution mechanism. Long intervals between sampling events risk compromising the credibility of OH based emissions estimates. 11 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 3. Carbon Trap Analysis 3.1 Background The carbon sampling trap method is currently under further development in the U. S. It is in the laboratory/ pilot phase and is being tested on a limited scale. No references were found that support that the method has been applied elsewhere.

Carbon trap sampling involves drawing a gas sample through traps filled with a sorbent, generally activated carbon. Gaseous mercury present in the gas is adsorbed onto the carbon. The traps are subsequently removed from the sampling apparatus and shipped to a laboratory for analysis. For mercury emissions monitoring, exposure of nominally one week is envisioned.

3.1.1 Preliminary Methods Through literature research and industry contacts, two general carbon trap methods under development in the U. S. were identified. One method, using intermittent integrating technology coupled with Method 101A, is being designed by a team headed by Walter S. Smith and Associates, Inc., of Apex, North Carolina. The method is described by the developer as a prototype; technical specifics are not available, and no tests have been performed. 11 The second method is an adaptation by the Electric Power Research Institute ( EPRI, " the manufacturer") of a method that was originally developed by scientists at Brooks Rand Limited and Frontier Geosciences of Seattle, Washington, in 1991.12 The earlier version of the method was identified as Mercury Speciation Adsorption ( MESA). The most recent adaptation combines a larger version of the iodated carbon trap used with the MESA method and a specially designed gas meter and probe assembly to provide a cumulative average mercury concentration for an extended period ( 1 week to 1 month). The EPRI method, the Quick Silver Emissions Monitor ( QSEM), differs significantly from MESA, and no peer reviewed publications are yet available. The QSEM is currently undergoing testing in North Carolina and Missouri. Several groups are assisting with the development of this 11 Personal communication from Walter Smith, Walter Smith Associates, Inc. to Michiel Doorn,

ARCADIS, by email, June 26 and email June 24, 2003.

12 Personal communication from Sharon Sjostrom, ADAES, to Michiel Doorn, ARCADIS, by email June 24, 2003. 12 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 method under contract to EPRI: ADA Environmental Solutions ( ADAES) designed the sampling consoles and is currently coordinating the testing efforts and subcontractor activities, Frontier Geosciences provides the iodated carbon traps and conducts the trap analysis, and Apex Instruments is currently providing the sampling hardware. Results from the Missouri/ North Carolina field tests are expected in the near future. Additional testing is planned for late summer 2003. Draft Method Quality Objectives ( MQO) for laboratory analysis of the iodated carbon traps for sorbent total mercury are included in Table 3 1 below.

Further discussion will only cover the QSEM method. A recent modification ( Model 2) includes an adapter to allow insertion of a smaller diameter trap appropriate for a three hour test to allow for better comparison to an OH test. A draft operating manual for Model 1 is available from the manufacturer. Also available are two proprietary standard operating procedures ( SOP). The first SOP addresses total mercury analysis by Cold Vapor Atomic Fluorescence Spectroscopy ( CVAFS) and is a modified version of EPA Method 1631E. The second SOP is entitled " Digestion for Gas/ Air Samples Collected on Iodated Carbon Traps for Total Mercury Analysis" and is a peerreviewed published method. A recent change to this SOP consists of shipping the traps with gloves to be worn by personnel that work with the traps, to minimize contamination. 13 Table 3 1. Draft MQO for Sorbent Total Mercury by internal Frontier Geosciences Method QA Measurement MQO Value Laboratory Replicate ± 25% RPD Laboratory SRM Spike Recovery 100 ± 20%

Lab Analysis Matrix Spike Recovery 100 ± 20%

Field Sample Spike Recovery 100 ± 30%

Field Sample Duplicate ± 30% RPD Method Detection Limit 0.05 µ g/ m3 @ 30 liters 0.002 µ g/ m3 @ 1500 liters Advantages of the carbon trap method include ease of operation and a simple technology. The method can be cost effective, depending on verification requirements.

13 Personal communication from Sharon Sjostrom, ADAES, to Michiel Doorn, Carl Singer, and Brent Hall, ARCADIS, July 7, 2003 13 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 The main disadvantage is that the method provides a delayed, " blanket" cumulative average without the possibility to identify peaks or periods with minimal emissions. Because continuous information may prove necessary for timely response to control device operations, this could be a very important disadvantage. The method is neither real time, nor continuous and, furthermore, is still in the development stages. In addition, only one manufacturer in the U. S. can currently offer a pilot test ready device or the treated traps.

3.1.2 Scope and Applicability Once the carbon trap method has reached commercial status, it should be applicable to capturing total mercury with 100 percent efficiency from coal fired stationary sources. The method takes a continuous, cumulative sample over a given time period that can range from one hour to one week and possibly up to a month. After this time period the trap is exchanged for a fresh one, and the used trap is sent to an off site laboratory to be analyzed according to standard methods. 14 For use in wet, saturated environments, the manufacturer has designed a modified tip for the trap to minimize wetting by large droplets, as well as a heated carbon trap to avoid operational difficulties due to the potential high pressure drop across the trap. This modified design has not yet been tested. 15 3.1.3 Technique The carbon trap technique uses 6 mm or 10 mm diameter cylindrical traps containing activated carbon impregnated with potassium iodide to adsorb mercury from flue gas. The sampling system consists of a sample probe, Teflon ® tubing, a glass wool plug to collect PM, a two part sorbent trap, a sample pump, and a gas meter mounted in a console. The front section of the sorbent trap is used to chemically adsorb mercury. The back section, separated from the front by glass wool, collects any mercury that breaks through the front section. The flue gas is extracted through the carbon packed trap where the Hg is adsorbed. The sample pump mounted in the console, along with a 14 Personal communication from Sharon Sjostrom, ADAES, to Michiel Doorn, ARCADIS, by email June 24, 2003.

15 Personal communication from Sharon Sjostrom, ADAES, to Michiel Doorn, ARCADIS, by email June 24, 2003. 14 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 flow meter and temperature gauges, creates the vacuum on the carbon trap. The flow meter can be adjusted to achieve any desired flow rate through the sampling system according to the time period of sampling and the flow rate of the stack gas. Typically, the carbon trap and the probe that secures it are the only things extending into the flue gas path. Once the sample has passed the probe and carbon trap, it travels through a heated Teflon line to prevent condensation of any moisture that may build up and cause operational difficulties. The sample then travels through a water knockout and drying column where the moisture is removed before passing through the sample pump and gas meter.

Experiments by the manufacturer have shown that the carbon captures both elemental and oxidized mercury with 100 percent efficiency over at least one week for flue gas concentrations typical of coal fired power plants. 16 The sampling system can be modified to sample isokinetically for particulate mercury as well as gas phase mercury. In the current application, the sampling system has been designed to exclude particulate Hg collection. However, some incidental PM may collect on the glass wool plug prior to the carbon bed. A separate analysis has indicated that particulate Hg is less than 1 percent of total Hg in gas streams after a particulate control device, which is similar to results reported by the OH Method. 17 The system currently operates by drawing gas continuously through the trap at a constant rate. The samples are typically collected for a week, at which time the carbon trap is removed, sealed, and shipped to an analytical laboratory, where the mercury is leached from the carbon using a strong acid and subsequently analyzed with Cold Vapor Atomic Absorption Spectroscopy ( CVAAS).

Research is underway to develop a proportional sampling approach. The new consoles being used incorporate a barometric pressure sensor, a digital manometer, and a flow control valve. The sampling consoles are designed to monitor the duct flow using a standard pitot connected to the digital manometer. Upon installation, the operator can configure the sampling console to use either the duct flow measured by the pitot, or an external 0 5 volt signal ( such as stack flow from the CEMS, or boiler load) to control the sample rate set point. The micro controller in the sampling console automatically 16 Personal communication from Eric Prestbo, Frontier Geosciences, Inc. to Michiel Doorn, ARCADIS, email June 25, 2003 17 Ibid. 15 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 adjusts the sample flow rate based upon the set point signal. The association of the control signal ( i. e. digital manometer, stack flow, load, etc.) to the sample flow set point can be defined by the operator. 18 3.1.4 Accuracy and Precision The carbon trap is analyzed in an off site laboratory. Currently, the only laboratory that analyzes these traps is Frontier Geosciences. The quantity of mercury is measured using a method with a detection limit of 0.5  g/ L ( 5 ppt) in the leachate. Frontier Geosciences estimates that this detection limit is equivalent to about 1  g/ m3 for a oneweek sampling period. 19 In addition, Frontier Geosciences maintains that they can easily match the OH Method for total mercury. 20 There is data available from the MESA method indicating very good accuracy and precision. This method employed a solid trap upstream of the activated carbon to capture oxidized mercury. Frontier Geosciences suggests that the new Iodated Carbon Traps should perform similarly to the carbon portion of the MESA traps and that data should be comparable. Recent tests with Iodated Carbon Traps suggest very good precision in the laboratory analysis. The manufacturer is using components from standard sampling equipment ( i. e. calibrated dry gas meters) and expects the total flow recorded during each sampling run to be within acceptable accuracy. In addition, the manufacturer is currently conducting tests to assess the precision and accuracy of the current equipment and carbon traps by running duplicate simultaneous samples in conjunction with OH testing.

3.2 General Assumptions For the purposes of cost estimation, it is assumed that the method will be developed in adequate detail for EPA to include carbon traps as an acceptable method of 18 Personal communication from Sharon Sjostrom, ADAES, to Michiel Doorn, ARCADIS, by email June 24, 2003.

19 Personal communication from Eric Prestbo, Frontier Geosciences, Inc. to Michiel Doorn and Carl Singer, ARCADIS, May 30, 2003 20 Personal communication from Eric Prestbo, Frontier Geosciences, Inc. to Michiel Doorn,

ARCADIS, email, June 24, 2003 16 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 determining annual total mercury emissions. We further assume carbon traps will typically sample for one week consistent with the current design strategies. A range of sampling strategies may prove viable; each with QA/ QC adequate to demonstrate annual emissions accuracy.

Since the currently proposed carbon trap techniques utilized fixed point sampling, similar to other CEMS measurements covered in Part 75, it is assumed that a QA/ QC program will be required to ensure representativeness and accuracy for carbon trap measurements. The reference method for mercury is assumed to be the OH method. While a RATA of carbon traps sampling for one week does not appear practical due to widely differing sampling times with OH, a RATA of carbon traps sampling for 3 hours, using an adapter and smaller traps, is assumed to be adequate for determining representativeness and accuracy. For costing purposes, an annual 9 sample RATA against OH is assumed.

In addition to a RATA, it is assumed that some QA/ QC program will be implemented to ensure accurate emission estimates are made throughout the year. For cost estimating purposes, the QA/ QC program will consist of 4 quarterly checks of each sample gas metering system and 3 quarterly matrix spike checks. The fully developed carbon trap technique is assumed to provide proportional sampling of the stack gas; auditing of proportionality is assumed to be integral to the monitoring system. Accuracy of the total sample volume measurements is expected to be confirmed with quarterly calibration of the sample gas metering system. It is assumed that Hg concentration accuracy will be confirmed with some form of spiked carbon trap analysis. For costing purposes, it is assumed that mercury spiked carbon traps will be available and will sample flue gas in parallel with an unspiked carbon trap over the typical one week sampling period. It is further assumed that an unexposed carbon trap will be analyzed as a blank on a quarterly basis.

It is assumed that carbon trap sampling will be performed in duplicate. If the QA/ QC validating carbon trap based emission measurements is performed on a quarterly basis, failure to meet QA/ QC objectives could invalidate a large portion of the annual emissions measurement. Replication is one method of ensuring against the need to use currently undefined data substitution. Duplication is therefore expected to represent the minimum application of replication adequate for QA/ QC requirements and reasonable data invalidation protection. Assumed annual requirements for carbon trap emission measurements are summarized in Table 3.2 17 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Table 3.2: Assumed Carbon Trap Analytical Summary Carbon Trap Requirements Other QA/ QC Requirements RATA 9 3 h traps + 1 weekly tube 9 OH runs + 2 gas meter cals 12 weeks 24 weekly traps QA/ QC check 1 3 weekly traps: matrix, matrix spike, blank 2 gas meter cals 12 weeks 24 weekly traps QA/ QC check 2 3 weekly traps: matrix, matrix spike, blank 2 gas meter cals 12 weeks 24 weekly traps QA/ QC check 3 3 weekly traps: matrix, matrix spike, blank 2 gas meter cals 12 weeks 24 weekly traps Annual Total 9 3 h traps + 106 weekly traps 9 OH runs + 8 gas meter cals Travel expenses associated with installation, training, and maintenance by the manufacturer are not included. Travel expenses associated with the RATA are included in the cost of subcontracting.

3.3 Capital Costs Capital costs for a carbon trap system ( sampling console, probe, water knockout assembly) is approximately $ 8,500.21 Installation costs ( for equipment location, setup, electrical hook up and probe insertion) are estimated to require two hours of technical labor for a total labor cost of $ 106 per carbon trap system. As two carbon trap systems are assumed, total capital costs are estimated at $ 17,212.

21 Personal communication from Sharon Sjostrom, ADAES, to Michiel Doorn, ARCADIS, by email June 24, 2003. 18 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 3.4 Annual Costs 3.4.1 Labor Costs This section addresses annual labor costs for the plant. The following technical hours are estimated to be associated with this method on an annual basis:

For operations, 4 hours per week per carbon trap system, to remove the used trap, install a new trap, mail the used trap to the manufacturer ( or other future laboratories/ providers), and complete associated paperwork.

For routine checks, 3 hours per week per carbon trap system ( 8 minutes per 8 hour shift).

For carbon trap flow calibration, 2 hours per quarter per carbon trap system Accordingly, it is estimated there are 744 technical hours associated with operation of two carbon trap systems.

It is assumed that awarding a contract for carbon trap analysis will require eight technical hours. It will also require eight hours to compile an emissions report. As this will occur four times annually, it will result in an additional 32 technical hours. Finally, it will require one technical hour to submit the report, but again, this will occur four times annually, resulting in another four hours. This results in 44 technical hours for reporting, or $ 2,334 annually, including management and clerical labor. Routine operations are therefore estimated to require 788 technical hours annually for a cost of $ 41,812 including management and clerical costs.

Plant labor associated with RATA testing is estimated to require 121 technical hours. It will require 40 hours to obtain a contract for RATA testing, 72 hours for oversight of nine tests, 8 annual hours to compile and review analytical data, and 1 hour annually to submit test results. Plant labor costs for verification testing are estimated at $ 6,420 Thus, combined labor costs for routine operation and verification are estimated at $ 48,232 19 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 3.4.2 Subcontract and ODC Basic analytical costs performed by the manufacturer to analyze and replace one carbon trap are $ 200.22 These costs include packing the traps with gloves for sample handling ( installation and removal), data collection and chain of custody forms, and post test analysis. These costs do not include any additional analyses, and the special tip for wet stack applications. For cost estimation purposes, all traps; 3 h, weekly, or spiked, are assumed to cost the same $ 200 for complete turnaround. In addition to the above, $ 20 per week is assumed for shipping and handling ( two ways). Based on the assumed 115 annual trap requirement, analytical costs are estimated at $ 24,040 annually.

A nine test OH sampling event is estimated to cost $ 37,000 to subcontract.

Estimated total subcontracting costs and ODC are $ 61,040.

3.4.3 Annualized Capital costs Based on a three year straight line depreciation, annualized capital costs are estimated at $ 5737.

3.4.4 Total Annualized Costs Total annualized costs for mercury emissions determination with the carbon trap method are estimated at $ 115,009.

This may be compared to the preliminary cost estimate submitted for the prototype by Walter S. Smith and Associates. No tests have been performed, but total annual costs, including a lease, are estimated to be less than $ 50,000. Technical specifics are confidential at this point. 23 Assuming this technique would be performed in duplicate and would require a RATA as well, total annual costs for the Walter S. Smith and Associates monitoring technique would be less than $ 137,000.

22 Personal communication from Sharon Sjostrom, ADAES, to Michiel Doorn, ARCADIS, by email, June 24, 2003.

23 Personal communication from Walter Smith, Walter Smith Associates, Inc. to Michiel Doorn, ARCADIS, by email, June 26 and email June 24, 2003. 20 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 3.5 Uncertainties Application of carbon traps for mercury emissions measurements will be dependent on continued development and acceptance of the technique as a method. Methods are often validated against various spiking techniques or against a standard method. EPA acceptance may require such validation on multiple sources, depending on how EPA views source categories.

Implementation of carbon traps for mercury emissions will likely require the development of QA/ QC procedures and limits as part of published procedures. The procedures to be defined include:

Leak check documentation and limits

Sample metering calibration

Proportional sampling validation

Chain of Custody

Back half capture limits

Laboratory calibration, continuing calibration verification, independent calibration verification

Laboratory duplicates

Blanks

Carbon tube analytical hold times.

In addition, methods to audit both sample collection and analysis are likely to be crucial to acceptance of the technique. One route to auditing both collection and analysis is the development of a standard technique to spike mercury onto a carbon trap. Techniques for spiking the carbon traps, either in the field or in the laboratory, have been implemented by method developers.

The effectiveness of the carbon traps depends on various parameters, such as sorbent properties, coal type, flue gas conditions and composition, and reaction kinetics. These conditions will vary with site configuration and coal composition. Although the 21 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 method does not distinguish between the elemental and oxidized forms of mercury, the efficiency of adsorption for both oxidized and elemental mercury must be validated over a variety of stack conditions, as well as fly ashes. One method of validation would be analysis of duplicates samples, one collected on a clean carbon trap and one collected on a mercury spiked carbon trap. 22 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 4. CEMS Analysis 4.1 Background Hg CEMS are undergoing continuing development, with current technology being tested under various programs. Few, if any, applications at coal fired power plants currently exist in the United States, but the technology is developing rapidly. Many CEMS have been undergoing field tests, and some have participated in several. Most manufacturers are in the process of making significant improvements or refinements to their monitors as time proceeds. Consequently, the CEMS information in this report, and similar reports, may need to be updated in the relatively short term.

In Germany, automatic mercury sampling devices have been applied since the early 1990s. The Federal Republic of Germany issued regulations for both emission limits and continuous monitoring of total mercury in incinerator flue gases. Under the regulation, CEMS need certification for approval. The German emission limit of 0.05 µ g/ m3 was adopted for the European Union in 1994.24 CEMS can be classified according to their method of converting oxidized Hg to elemental Hg as dry or wet. Wet systems convert Hg in impinger solutions, while dry systems thermally or catalytically convert the Hg species. Most CEMS can provide speciated Hg emissions values, but the development trend in industry is toward total Hg measurement.

Based on operational experience and industry knowledge, the dry systems appear to offer more operational availability and require less maintenance compared to wet systems. They provide quick real time Hg concentrations and many have inherent auto zeroing and system checks built into them. The dry systems are easier to operate overall and offer a more reliable Hg number because of not having any chemical interactions. The disadvantages of wet systems include increased maintenance and potential problems with the gas conditioning systems malfunctioning. Also, the solutions used in wet systems may react with flue gas components in unexpected ways. Another disadvantage of current wet systems is that they only yield a mercury 24 Sigl, W., 2000. Continuous monitoring of mercury emissions in combustion flue gases with the Hg CEMS ' MERCEM'. In " Recent advances in the science and management of air toxics", Proceedings of the joint international specialty conference, exhibition and workshop of the Air and Waste Management Association, 9  12 April 2000, Banff, Canada. 23 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 concentration every 4 6 minutes, depending on the cycle set up; they are not truly " continuous" Hg monitors. For the purpose of further discussion, only the dry systems are addressed.

It is apparent through the results from each subsequent field evaluation that the reliability and accuracy of Hg CEMS has greatly improved. Hg CEMS are viewed as a viable choice for Hg monitoring because of the continuous data delivery, as well as their improving accuracy. It is anticipated that Hg CEMS would be a preferred method of Hg monitoring, provided the costs are comparable to other viable methods.

For this report and other recent associated draft reports, technical, performance, and cost information was requested from 12 vendors. Eleven vendors provided technical and performance information, while seven manufacturers responded with cost information. Table 4 1 summarizes technical information of 12 different Hg CEMS. Table 4 2 includes performance information related to operation and maintenance. All data in Tables 4 1 and 4 2 are from manufacturer responses.

4.1.1 Scope and Applicability There is currently no regulatory driver or performance standard for CEMS; although a draft performance standard has been developed25 against which Hg CEMS can be evaluated. However, quality requirements can not be fully defined at this point. A regulation for Hg could, conceivably, require monitoring of elemental, oxidized, or total Hg, resulting in different potential equipment needs.

Hg CEMS could find wide use for monitoring flue gas emissions at coal fired power plants. As indicated earlier, there is widespread use of Hg CEMS in Europe, but mostly at municipal, or medical waste incinerators.

25 Draft Performance Specification 12   Specifications and test procedures for total mercury continuous monitoring systems in stationary sources. http:// www. epa. gov/ ttnemc01/ propperf/ ps

12. pdf 24 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Table 4 1. Overview of Mercury CEMs that are ( expected to be) Commercially Available in the United States Model Principles of operation Speciation Interferences Zero Drift Calibration Drift Relative Accuracy Field Application US Detection Limit Sampling/

Response time Cooper X CMM X ray fluorescence Total none No zero adjustment is necessary Calibration every few months na na 0.1 µ g/ m3 10 20 min Durag HM 1400 TR Dual Beam CVAAS Total and Elemental None below 1500 ppm SO2 < ± 1.5% F. S.

per week < ± 2 % F. S.

per week ± 5% F. S.

( total accuracy) none < 1 mg/ m3 180 s Ecochem HG  MKII CVAAS with gold trap Total and Elemental none Uses preset intervals with alert system No information na none na na Envimetrics Argus Hg Plasma source spectrometer Elemental,

Oxidized na No zero adjustment is necessary Automatic calibration with built in Hg standard na na 0.03 µ g/ m3 na Genesis Quicksilver Sky Monitor Dry method Particulate,

Oxidized, Elemental na na No errors, proprietary technology na na na na Nippon26 AM 2/ AM 3 CVAAS with gold trap Elemental Cl2 and to a lesser extent HCl Hg0 0.96 µ g/ m3 Hg0 2.93 µ g / m3 Hg0 18%

Hg0 16% Hg0 14%

Hg0 23% none 0.1 µ g/ m3 5 13 min 26 Nippon Instruments Corporation Model AM 2 Elemental Mercury Continuous Emission Monitor; Environmental Technology Verification Report. U. S. Environmental Protection Agency in cooperation with Battelle, Inc. August 2001. 25 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Model Principles of operation Speciation Interferences Zero Drift Calibration Drift Relative Accuracy Field Application US Detection Limit Sampling/

Response time Nippon27 MS1/ DM5 CVAAS and wet scrubbing plus chemical for total Hg Elemental and Oxidized HCl ` 0.1 µ g/ m3 ` 0.1 ug/ m3 ` 0.1 µ g/ m3 ` 0.1 µ g/ m3 Hg0 14%

Hg+ 2 13%

Hg0 12%

Hg+ 2 11% HgT 13%

Hg0 11%

Hg+ 2 55%

HgT 39%

Hg0 49%

Hg+ 2 50% none 0.1 µ g/ m3 Ionic Hg 60 s.

Detector 35

50 s.

Ohio Lumex28 CVAAS, with Zeeman highfrequency polarization background correction Total and Elemental HCl and Cl2 0.20 HgT 0.37 Hg0 2.45 HgT 0.17 Hg0 62% HgT 92% Hg0 24% HgT 18% Hg0 HgT 58%

Hg0 50%

Hg+ 2 99%

HgT 71%

Hg0 107%

Hg+ 2 69% none na 20 48 s Opsis HG200 Dual beam absorption photometer Total and Elemental SO2 may be issue na na na Two test sites 0.5 pg 8 min 27 Nippon Instruments Corporation Model MS 1/ DM 5 Elemental Mercury Continuous Emission Monitor; Environmental Technology Verification Report. U. S. Environmental Protection Agency in cooperation with Battelle, Inc. August 2001.

28 Lumex Ltd. Mercury Continuous Emission Monitor; Environmental Technology Verification Report. U. S. Environmental Protection Agency in cooperation with Battelle, Inc. August 2001.

Table 4 1 continued. 26 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Model Principles of operation Speciation Interferences Zero Drift Calibration Drift Relative Accuracy Field Application US Detection Limit Sampling/

Response time PS Analytical29 Sir Galahad II Atomic fluorescence with gold trap Total,

Oxidized, and Elemental Elemental: Cl2 0.003 µ g/ m3 0.013 µ g/ m3 12% 11% HgT 21%

Hg0 23%

Hg+ 2 27%

HgT 33%

Hg0 30%

Hg+ 2 33% 18 units,

mainly for research 0.1 pg 6 min ST2 SM 3 CVAAS Total SO2 < 1 µ g/ m3 after 1 week of testing See TüV report See page 38 of TüV report none na na Tekran Atomic fluorescence with gold trap Total and Elemental None On line automated zero and multi level span checks Automatic recalibration using internal permeation source na none < 0.05 µ g/ m3 2.5 min na = not applicable 29 PS Analytical Ltd. Sir Galahad II Mercury Continuous Emission Monitor; Environmental Technology Verification Report. U. S.

Environmental Protection Agency in cooperation with Battelle, Inc. August 2001.

Table 4 1 concluded. 27 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Table 4 2. Operation & Maintenance Model Principles of operation Operation continued Conditioning System Filter Trap Other Cooper X CMM X ray fluorescence Works with filter tape No pre treatment necessary Automatic No No calibration gases needed Durag HM 1400 TR Dual Beam CVAAS nav Heated lines;

Thermo catalytic converter Particle filter Gold trap; Cleaned 1x/ day by heat;

Aromatics, SO2, NO2 are interferences NH3 can cause flow problems Ecochem HG  MKII CVAAS with gold trap nav Teflon or heated parts; Dry catalytic device nav Gold trap; Desorption into pure N2 nav Envimetrics Argus Hg Plasma source spectrometer No chemical reagents Solid catalytic converter; Peltier cooling nav  Automated calibration;

Maintenance only every 6 months Genesis Quicksilver Sky Monitor Dry method SOX removal by scrubbing  nav  Calibration 1x per year; Trade secret for background correction Nippon MS1/ DM5 CVAAS and wet scrubbing plus chemical for total Hg nav Distilled water scrubber;

Dehumidifier; Two coolers Dust filter, membrane filter Gold trap/

Heater; Needs purified air nav OhioLumex CVAAS, with Zeeman highfrequency polarization background correction Two channel instrument " Pyrolyzer"

converter Particle filter and zero Hg absorption filter No gold trap Charge battery;

Manual available on line Opsis HG200 Dual beam absorption photometer nav Dilution system;

Dry thermocatalytic converter;

Cooler nav Gold trap Two calibration gases 28 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Model Principles of operation Operation continued Conditioning System Filter Trap Other PS Analytical Sir Galahad II Atomic fluorescence with gold trap Converts Hg into Hg0 with aqueous reagent Scrubber; Tubing and agents replaced every 2 weeks Filter Gold trap, Preconcentration trap;

Needs argon gas Heated diaphragm pump;

Built in calibration ST2 SM 3 CVAAS nav nav nav No carrier gas Maintenance free pump Tekran Atomic fluorescence with gold trap Inert probe, dry converter nav nav Gold trap Maintenance 1 4 hours per 4 weeks; Built in automatic calibration nav = not available or not provided by the vendor Table 4 2 concluded. 29 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 4.1.2 Technique EPA defines the CEMS as " The total equipment required for the determination of a pollutant concentration. 30" Total equipment includes the major sub systems such as the sampling interface, pollutant analyzer, diluent analyzer, and data recorder.

Mercury CEMS typically measure only Hg0 using some variation of CVAAS or CVAFS. Many incorporate a process that converts gaseous ionic Hg to gaseous Hg0, resulting in measurements of total gaseous Hg. PM is typically filtered from the sample before analysis, which removes particle bound Hg. This process therefore results in underestimates of total Hg; it also may cause bias in speciation and bias in total gaseous Hg. Some fly ashes react with Hg, resulting in the oxidation of Hg0 in the probe and on filters, which in turn overestimates ionic Hg. Fly ash may also adsorb or desorb Hg, which biases estimates of total gaseous Hg because the ash is not subsequently analyzed for Hg.

The measurement techniques used by CEMS are often affected by common coal combustion contaminants. The draft performance specification lists eight potentially interfering components: carbon monoxide, carbon dioxide, oxygen, sulfur dioxide, nitrogen dioxide, water vapor, hydrogen chloride, and chlorine. Such interferences are often dealt with in a manner specific to each CEMS. One common mechanism is to amalgamate the Hg on a gold trap and regenerate the mercury captured on the gold trap into a carrier gas that is then analyzed.

4.1.3 Accuracy and Precision Evaluation of Accuracy and Precision of Hg CEMS is confounded by the rapid and continuing development of Hg CEMs by vendors and the lack of published information on CEM performance. Evaluation of the performance of CEMs will improve when suitable reference materials or procedures become available. A National Institute of Standards & Technology ( NIST) approved elemental mercury gas standard is still under development. EPA has developed a draft performance specification, PS 12, which defines relative accuracy requirements for Hg CEMS measurement along with 30 Draft Performance Specification 12   Specifications and test procedures for total mercury continuous monitoring systems in stationary sources. Website: http:// www. epa. gov/ ttnemc01/ propperf/ ps 12. pdf. 30 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 certain other QA requirements; a relative accuracy of 20% is currently specified in PS 12.

EPA's Office of Research and Development conducted Relative Accuracy tests on four Hg CEMs under the Environmental Test Verification ( ETV) program in January 2001. The ETV program was created to facilitate the use of innovative environmental technologies [ including continuous emission monitors ( CEM)] by testing their performance and making the results available to those involved in their design, distribution, permitting, purchase, and use. These ETV tests were performed on a pilotscale natural gas fired combustor. 31 As shown in Table 4 1, a vintage 2001 Nippon CEMs was able to achieve 13% relative accuracy during the ETV tests.

Six Hg CEMs were also recently evaluated under the ETV program at a Department of Energy ( DOE) Toxic Substances Control Act ( TSCA) incinerator in Oak Ridge, Tennessee; this source category was not pursued as a source of CEM data due to expected differences in the flue gas composition. Results from the TSCA incinerator were presented at the Air and Waste Management Association ( AWMA) conference in San Diego. 32 EPA's Office of Air Quality Planning and Standards ( OAQPS) is undertaking a series of field tests of several mercury CEMs at coal fired power plants. The first series of Relative Accuracy tests at a full scale coal fired power plant were conducted in October 2002 but are not yet published. OAQPS is currently conducting two Hg CEM demonstrations/ evaluations at full scale coal fired power plants. The results of these tests are expected to be available in October 2003. EPRI recently published CEMs measurements of Hg emissions at several coal fired power plants; QA information regarding the performance of the CEMs was not found in the paper. 33 31 Environmental Technology Verification Program. Website: http:// www. epa. gov/ etv/ verifications/ vcenter1 11. html 32 Dunn, J. E., et al. 2003. Evaluation of Mercury Continuous Emission Monitors at the U. S.

DOE TSCA Incinerator. AWMA, 96th Annual Conference, June 22 26, 2003, San Diego, CA.

33 Chu, Paul, et al., Characterization of " Longer Term" Mercury Emissions from Coal Fired Power Plants, 2003 MEGA Symposium, Washington, DC. 31 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 4.2 General Assumptions

A three year, straight line write off for capital costs is assumed.

Capital costs do not include installation costs.

Technician training is assumed to be included in capital costs.

Costs for utilities ( water, electricity, heat, cooling) are not included.

Calibration costs have not been included, pending guidance from EPA. None of the manufacturers submitted calibration cost information.

Because of the trend in the industry, only systems that can measure total Hg are considered. This includes systems that can do both total and elemental Hg.

The trend in the industry seems to be toward dry systems. The labor, sampling and analysis costs reflect estimates for dry systems only, while the capital cost analysis includes all systems.

Similar to the performance verification of SO2 monitors, it is assumed that the plant would perform one RATA annually using the OH method, consisting of nine ( 9) tests, as well as perform three ( 3) cylinder audits on the Hg CEMS. The cylinder audits are assumed to be performed by the plant. A cylinder audit would typically require using a certified gaseous elemental Hg standard and introducing this gas through the probe or directly to the detector and the entire sampling system. This would facilitate determining if there were any bias being imparted by the sampling systems as opposed to the detector. It is assumed that the cylinder audits could be performed by the plant personnel with the procurement of a gas standard.

4.3 Capital Costs Capital costs for CEMS that are available on the U. S. market, or that are expected to be available soon, are listed in Table 4 3. This information was collected through an email request and ensuing telephone conversations with individual vendors. Costs have been standardized to the extent possible to reflect a complete CEMS and to exclude installation. Capital costs are especially dependent on the configuration of the system. Also, the systems differ in both basic and ancillary supporting technology. For several vendors, these costs are preliminary. 32 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Table 4 3 includes 15 entries representing CEMS from 11 manufacturers. When a manufacturer provided a large range for capital cost, as was the case with Genesis and OhioLumex, both the low end and the high end estimate were included in the table and in the summary calculations. In other words, the submittals were regarded as separate instruments. The Nippon MS 1A instrument was excluded because it can not measure total mercury.

Table 4 3. CEMS Capital Cost ( March 2003)

Vendor Name Model Capital Cost Notes Mercury System Type Dry Systems:

Cooper Environmental Services X CMM $ 100,000 Estimate for complete system. Filters would cost around $ 5,000 per year. Total Dry, uses filter tape Durag HG 1400 TR $ 45,000 Does not include heated sample line. Heated probe of $ 3,000 is optional. Speciating Dry Ecochem HG MKII $ 59,400  Speciating Dry Envimetrics Argus Hg 1000 $ 54,200 Estimate. Includes sample probe, heated sample line and controller. Speciating Dry Genesis Laboratory Systems Quicksilver Sky Monitor $ 35,000 Estimate for CEM ($ 20,000) plus low end gas conditioning system. Speciating Dry Genesis Laboratory Systems Quicksilver Sky Monitor $ 85,000 Estimate for CEM ($ 20,000) plus high end, specialized gas conditioning system. Speciating Dry OhioLumex CEM $ 40,000 Low end estimate. " CEM, based on AA with Zeeman correction for interferences, dry converter system, total Hg, detection limit 0.1 µ g/ dscm. Installation is not included." Speciating Dry OhioLumex CEM $ 60,000 High end estimate. Speciating Dry Opsis HG200 $ 80,000 Basic instrument: $ 30k, Basic instrument ( 30k) with converter ($ 50k) and conditioning system. Speciating Dry ST2 Service Technologies SM 3 $ 47,666 Complete system, simple probe. Total Dry Tekran $ 85,000 Preliminary estimate Speciating Dry 33 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Vendor Name Model Capital Cost Notes Mercury System Type ( Semi) wet systems Nippon Instruments DM 6 $ 38,000 Standard gas generator and KOH scrubber an optional Speciating Semi dry Nippon Instruments DM 6A $ 34,000  Speciating Semi dry PS Analytical Mercury CEM $ 80,000 Low end estimate. " The PS Analytical Mercury CEM can be configured in a number of ways using its stream selection capability. Systems include the unique calibration device." Speciating Wet Not considered:

Nippon Instruments MS 1A $ 13,000 Not including probe unit Elemental Semi dry The average capital cost of the speciating and total Hg CEMS is $ 60,233, while the median value is $ 56,800. The lowest value is $ 35,000 and the highest value is $ 100,000. Additional information, such as copies of correspondence with manufacturers and copies of quotations may be found in a draft EPA report. 34 In the ensuing cost calculations, the average capital cost of $ 60,233 is used.

4.4 Annual Costs 4.4.1 Annual Labor Costs Based on the ARCADIS expert review and review of the data submitted by the vendors, a yearly technical labor allocation for dry systems of 219 hours is estimated. This number is built up of one 10 minute inspection per shift, three shifts per day, and 365 days per year, as well as three hours of maintenance per month. Thirty two technical hours are assumed for compiling and validating four quarterly emissions reports. Four additional hours are estimated for submission of these four reports. Routine operations of Hg CEMs are therefore estimated to require 255 technical hours.

34 EPA, 2003. Cost of Mercury Measurement Techniques. Draft Report submitted on March 28, 2003, by Perrin Quarles Associates, Inc. 34 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 As mentioned, three cylinder audits per year are assumed. Four technical hours are estimated for the performance of a single cylinder audit and to prepare a report, a total of 12 hours per year. Additional labor costs associated with the performance of three cylinder audits is therefore estimated at $ 637.

Plant labor costs associated with relative accuracy verification testing ( one events with nine tests) are estimated to be 121 technical hours including:

40 hours for OH contacting

72 hours for OH oversight

8 hours for report review

1 hour for report submission Including managerial and clerical support. the labor costs for the verification component for this program are estimated to be $ 6,420.

4.4.2 Subcontract and ODC Based on the expert review and review of the data submitted by the vendors, ARCADIS estimates an annual materials operations and maintenance budget associated with sampling and analysis for a generic dry CEMS of $ 2,500. This budget includes the cost for replacement parts, including the catalyst, tubing, pumps, and fittings. Because many CEMS are still in the pilot stage and the technologies are often proprietary, this estimate is preliminary.

It is assumed that the procurement of the gas standard associated with the three cylinder gas audits the standard would cost $ 5,000 annually. 35 One nine test OH RATA is estimated to cost $ 37,000 to subcontract. This number consists of $ 4,000 in travel and $ 33,000 in testing costs.

35 Current rate quoted by Spectrum Gases. 35 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 Accordingly, subcontracting and ODC for generic a dry CEMS are estimated to be $ 44,500.

4.4.3 Annualized Capital Costs Based on a three year straight line depreciation, annualized capital costs are estimated to be $ 20,077 based on the capital cost average for both wet and dry systems, as submitted by the vendors.

4.4.4 Total Annualized Costs Total annualized costs for mercury monitoring with a CEMS are estimated at $ 84,142.

Note that this estimate may be low, in regard to administrative, sampling and analysis cost, for the first year, because the CEM is likely to undergo extra scrutiny from management. Also, additional vendor maintenance calls may take place which will increase the vendor's budget as well as require time from plant personnel.

4.5 Uncertainties

The technology is still under development.

Limited field experience has been collected.

No performance standard has been defined for CEMS.

No calibration method has been defined.

Demonstration of oxidized Hg conversion efficiency is difficult without OH testing. Currently envisioned cylinder audit would not demonstrate conversion. 36 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 5. Fuel Analysis 5.1 Background and Methods Fuel analysis as an emissions measurement technique implicitly utilizes an emission factor approach; mercury emissions are some fraction of all the mercury inputs. Mercury in the fuel is generally considered the sole source of mercury emissions though other mercury inputs could easily be incorporated into this approach if deemed necessary. Mercury content in the fuel and the amount of fuel burned are used to determine the mercury inputs to a unit. In the extreme or maximum emissions case, mercury emissions from a unit could be estimated as the total measured mercury inputs, discounting mercury retained in residuals such as fly ash or gypsum. An alternate approach is to apply an emission factor, either based on unit specific emission measurements or some classification average emission measurements, to the measured mercury inputs.

Measuring mercury content in the fuel and fuel inputs to units appears to be an integral part of proposed mercury control legislation. Mercury inputs provide the baseline which emissions are compared to in control based legislation. Similarly, the proposed Clear Skies Act of 2003 reverts, should the administrator not establish the emissions trading system, to a control based mercury emissions requirement based on fuel mercury content36.

5.1.1 Scope and Applicability Fuel analysis will determine the total amount of mercury in the fuel. Mercury in the fuel can be expressed on either a mass basis, either wet or dry, or can be normalized to the heating value of the fuel and be expressed on an energy basis. When the fuel is burned, the mercury in the fuel will be converted to elemental, oxidized, and particlebound mercury. Though the fuel analysis is most directly related to total mercury emissions, it may be possible to estimate the partitioning of the mercury based on other fuel components and fuel firing conditions.

36 " Clear Skies Act of 2003" accessed at http:// www. epa. gov/ air/ clearskies/ Air_ 005. pdf 37 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 5.1.2 Accuracy and Precision Accuracy and Precision for mercury fuel analysis appear to be dependent upon both the analytical method and the specific matrix being analyzed. ASTM D 3684 01 is reported to have a bias with respect to three reference materials analyzed, as summarized in Table 5 1. Bias was significant at a 95 percent confidence level for all three reference materials but appears to be dependent on the specific matrix. The mean Hg content from ICR phase II for bituminous coals at electric utilities was 0.11 ppm37. This was quite comparable to the Certified Reference Material ( CRM) used to evaluate bias in the ASTM method. Repeatability of the method is reported as 0.036 ppm, while reproducibility of the method is reported as 0.054 ppm. 38 Table 5 1. ASTM D 3684 01 Bias 39 CRM Description CRM value, ppm Bias, ppm SRM 1630a Bituminous Coal, PA40 0.0938 0.0081 SRM 2692b Bituminous Coal, WV41 0.1333  0.0087 SARM 20 Subbituminous to Bituminous Coal,

South Africa42 0.25  0.06 37 National Risk Management Research Laboratory, " CONTROL OF MERCURY EMISSIONS FROM COAL FIRED ELECTRIC UTILITY BOILERS: INTERIM REPORT INCLUDING ERRATA DATED 3 21 02," EPA 600/ R 01 109, April 2002.

38 D3684 01 Standard Test Method for Total Mercury in coal by the Oxygen Bomb Combustion/ Atomic Absorption Method, ASTM International, West Conshohoken Pennsylvania 39 D3684 01 Standard Test Method for Total Mercury in coal by the Oxygen Bomb Combustion/ Atomic Absorption Method, ASTM International, West Conshohoken Pennsylvania 40 http:// patapsco. nist. gov/ srmcatalog/ certificates/ view_ cert2gif. cfm? certificate= 1630a 41 http:// patapsco. nist. gov/ srmtcatalog/ certificates/ 2692b. pdf 42 http:// energy. er. usgs. gov/ products/ papers/ B1823/ append. htm 38 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 5.2 Assumptions For this cost estimate, the fuel Hg sample is assumed to be derived from fuel samples already being collected and shipped for analysis. The equipment and techniques required to take the sample are therefore assumed to be established for each unit. It is assumed that fuel analysis will be contracted.

The form of any regulation is expected to specify the sampling and analysis frequency. Under ICR phase II, over 152,400 shipments were recorded and over 39,500 analyses performed43. One thousand one hundred and forty ( 1,140) coal fired units were identified at approximately 450 facilities44. Assuming a similar frequency for potential regulation will result in approximately 35 analyses per unit per year. Assuming an unbiased measurement technique and 15% RSD with respect to mercury inputs, 35 analyses should provide an annual estimate within 5.2% of actual mercury inputs with 95% confidence.

There are several ASTM methods available for measuring mercury including D3684 01, D6414 01, and D6722 01. Without further regulatory guidance, ASTM D 3684 is assumed to be the utilities method of choice and will be used in this cost estimate. ASTM D 3684 appears to have been widely, though not uniformly, chosen for fuel analysis in the ICR.

Costs for emission factor development, if implemented, are assumed to be on a unit basis. The emission factor is assumed to validate the percentage of mercury inputs emitted from the stack. The emission factor could similarly be required to demonstrate no significant bias in the mercury analysis technique. While procedures for implementing such a validation have yet to be developed, this cost estimate will include quarterly ( 4) OH sampling events with three tests per sampling event. No additional coal samples and analysis are assumed to be associated with the emission factor validation.

43 U. S. EPA, " ICR Data Analysis Presentation for NWF; September 8, 2000,"

http:// www. epa. gov/ ttn/ atw/ combust/ utiltox/ nwf_ 9_ 8. pdf 44 ibid. 39 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 5.3 Annual Costs 5.3.1 Labor Costs Costs for administering the fuel analysis program for Hg are derived using estimates from the ICR supporting statement. 45 Though not specified in the ICR Supporting Statement, two technical hours per year have been included to support contracting for additional analysis. Thirty two technical hours, 8 hours per quarter, are assumed for compiling and reviewing analytical data. Four technical hours are estimated for quarterly submission of analytical results. Routine operations are therefore expected to require 38 technical hours per year. Labor costs for routine operation of a mercury sampling program are estimated at $ 2,016, including management and clerical costs.

If an emission factor verification were included, additional costs would be associated with administering this program. The program is assumed to consist of four ( 4) OH sampling events with three ( 3) tests per sampling event. The following technical hours have been assumed on an annual basis for verification testing:

For obtaining an OH sampling contract, 40 technical hours.

For oversight of 12 tests, 96 technical hours.

To compile and review analytical data, 32 technical hours.

To submit test results, 4 technical hours.

Total technical hours for administration of the emission factor verification program are therefore expected to be 172 per year. Including management and clerical hours labor costs for the emission factor verification program at the stack level are estimated at $ 9,126 annually.

45 U. S. EPA, " Standard Form 83 1 Supporting Statement for OMB Review of ICR No._____:[ sic] Information Collection Request for Electric Utility Steam Generating Unit Mercury Emissions Information Collection Effort," November 16, 1998. available at http:// www. epa. gov/ ttn/ atw/ combust/ utiltox/ 114_ ss19. pdf 40 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 5.3.2 Subcontract and ODC Cost of mercury analysis is estimated at $ 54 per occurrence, which is the average of vendor indicated analysis costs of $ 5046 and $ 5847. Shipping to the contract laboratory is expected to be covered by current analytical requirements. A total of 35 mercury analysis per year results in a mercury analysis cost of $ 1,890 per year per unit.

As mentioned in section 1.1.1, costs for contracting for OH sampling and analysis are estimated a $ 15,000 per sampling event with three tests each. An emission factor verification program consisting of four ( 4) sampling events is, thus, estimated to cost $ 60,000 per year for each unit.

5.3.3 Total Annualized Costs Annual costs for the mercury analysis program are estimated to be $ 3,906 with no emission factor verification program. Cost of an emission factor verification program is estimated to be $ 69,126. Whether an emission factor verification program would be required for all units or just for those wishing to demonstrate a level of mercury control would have to be defined by regulation. Annual cost for the mercury analysis program with an emission factor verification program is estimated at $ 72,926 per unit.

5.4 Uncertainties Use of Hg fuel analysis for quantifying mercury emissions is confounded by the matrix specific bias associated with the analytical technique. Reducing this bias or quantifying the matrix effects may greatly influence the need to perform emission factor verification testing. It may also be necessary to estimate bias associated with non coal fuels such as pet coke, RDF or biomass with respect to the chosen analytical technique. Additionally, QA necessary for defensible analysis at the desired detection levels must be established.

46 Personal communication from Kim Risi, PSC Analytical Services to Carl Singer, ARCADIS on March 24, 2003.

47 Personal communication from Ken Munger, SGS Commercial Testing and Engineering, to Carl Singer, ARCADIS, on March 12, 2003. 41 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 The cost of Hg fuel analysis for quantifying Hg emissions could be significantly reduced if a reliable emission factor were developed for important equipment and fuel classes. This approach may be particularly applicable to units expecting little or no Hg control. Units burning sub bituminous or lignite coals controlled only by ESPs appear to exhibit limited control. 48 On the other hand, use of a single emission factor for a unit may not be appropriate in all cases, especially for units which change fuel or fuel blends, because the emission factor may change significantly dependent on the fuel due to changes in Hg partitioning between elemental, oxidized, and particle bound forms.

The use of fuel analysis for quantifying Hg emissions may not be appropriate for all units or within and market based trading scenario. The Hg emissions can be influenced by a number of factors, which may vary due to plant operating conditions and may not be representatively captured during verification tests. These parameters may include fuel sources, combustion conditions, and control device operations.

48 EPA 600/ R 01 109 42 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 6. Discussion and Summary 6.1 Comparison Carl: please update this section with revised costs.

Table 6 1 includes an overview of the estimated annual costs associated with the four methods that have been reviewed. The costs for OH analysis for annual emissions estimation is $ 203,134. The cost for carbon trap analysis for annual Hg emissions estimation is$ 115,009 . The cost for CEMS and fuel analysis for annual Hg emissions estimation are $ 85,164 and $ 73,032, respectively. A large portion of the monitoring costs are associated with validating the proposed measurement against a reference method. In this case, the reference method, OH, samples representatively across the stack as opposed to point sampling used for Carbon Traps and CEMS or inlet Hg based fuel analysis..

Table 6 1. Summary of Mercury Annual Analysis Costs OH Method Carbon Trap CEMS Fuel Analysis Labor Routine Operations, Technical Hours 436 772 255 38 Verification Testing, Technical Hours n/ a 137 133 172 Total Technical Hours 436 909 388 210 Technical Labor, $ 20,710 43,178 18,430 9,975 Management Labor, $ 1,248 2,603 1,111 601 Clerical Labor, $ 1,175 2,451 1,046 566 Total Labor, $ 23,134 48,232 20,587 11,142 Subcontract & ODC Verification Testing 180,000 39,400 37,000 60,000 Other Analysis n/ a 21,640 n/ a 1,890 Audit Cylinder n/ a n/ a 5,000 n/ a Parts & Consumables n/ a n/ a 2,500 n/ a Total Subcontract & ODC, $ 180,000 61,040 44,500 61,890 Annualized Capital Cost Annualized Capital Cost, $ 0 5737 20,077 n/ a Total Annual Costs, $ 203,134 115,009 85,164 73,032 43 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 6.2 Barriers to Cost Analysis The accuracy of cost estimates is limited by the developing nature of the mercury emission monitoring industry. The accuracy and precision of the measurement methods are improving but are largely unquantified. The requirements of mercury monitoring are similarly undefined by regulation. The validation requirements must also be developed to satisfy the accuracy and precision requirements defined by regulation. Finally, the market for these validations will mature dependent on the requirements of the mercury emission monitoring industry.

The accuracy and precision of OH testing, carbon trap testing, and CEMS are currently undergoing evaluation under several coal fired plant configurations. While OH testing is widely used as the reference method, the precision of the method is poorly established confounding comparisons to alternative methods. Alternatively, generally accepted independent standards by which to judge accuracy and precision are not available; an elemental mercury gas standard is under development but an oxidized or total mercury gas standard is unavailable.

Mercury emissions from coal fired boilers are not currently regulated under federal authority. The measurement and reporting requirements of any proposed regulation, including incentives and penalties, will shape the type and frequency of mercury measurements. The marketplace will either develop based on industry perception of risk and reward or based on regulatory command and control requirements. Information on the reliability, O& M costs, and other metrics of various monitoring techniques are largely unavailable, though they are being evaluated by EPA during short term testing at coal fired power plants.

Validation of the mercury monitoring can have a large impact on the total costs of a mercury monitoring approach. Validation will depend on the regulatory framework required for mercury monitoring. Our estimates assumed validation techniques to provide results nominally equivalent to a RATA.

Finally, the cost of validation of mercury monitoring will likely change as the market for these services develop. These costs are currently based on OH testing at an individual stack in the current market. The volume of contracting required may significantly affect costs as the amount of travel and number of deployments are reduced. The number and location of sampling firms providing this service will be affected by the amount of contracting that develops. Competitive pressures are also likely to drive down costs. 44 Task 1: Cost of Mercury Measurement Techniques Draft Report, Revision 1 6.3 Suggestions for Improvements and Additional Research The accuracy and precision of the OH tests need to be quantified in order to establish appropriate validation procedures with this method. This precision may define the number of tests required to achieve desired accuracy. It is particularly important to understand the precision at low levels of mercury where analytical variability may become a large fraction of the total variability. Improvements to the accuracy and precision, especially at low mercury levels, should be incorporated into the method prior to the evaluation of precision. A sampling program to evaluate the precision and accuracy of the OH method is therefore recommended to evaluate low, medium, and high concentration sources.

A more accurate estimate of annual monitoring costs will require additional information regarding continuous application of each method. While short term evaluations of CEMS and a version of carbon traps are ongoing or planned, these evaluations are not likely to extend for a year, the benchmark typically encountered in Part 75. Quantitative information regarding operation and maintenance and reliability will be necessary for method comparison. Preferably, these evaluations should encompass a wide range of coals and plant configurations. End of Document


[Federal Register Volume 76, Number 205 (Monday, October 24, 2011)]
[Notices]
[Page 65720]
[FR Doc No: 2011-27385]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Project No. 14136-000; Project No. 14139-000]

Lock+ Hydro Friends Fund XXXV, Riverbank Hydro No. 4, LLC; Notice
Announcing Preliminary Permit Drawing

    The Commission has received two competing preliminary permit
applications deemed filed at the same time for proposed hydropower
projects at the U.S. Army Corps of Engineers' Lock and Dam No. 5,
located on the Mississippi River near Minnesota City, Minnesota, in
Winona County, Minnesota, and Buffalo County, Wisconsin.\1\ The
applications were filed by Lock+ Hydro Friends Fund XXXV for Project
No. 14136 and Riverbank Hydro No. 4, LLC, for Project No. 14139.
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    \1\ The applications were received after Commission business
hours on March 31, 2011. Under the Commission's Rules of Practice
and Procedure, any document received after regular business hours is
considered filed at 8:30 a.m. on the next regular business day. 18
CFR 385.2001(a)(2) (2011). Therefore, the applications are deemed
filed at 8:30 a.m. on April 1, 2011.
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    On October 27, 2011, at 2 p.m. (eastern time), the Secretary of the
Commission, or her designee, will conduct a random drawing to determine
the filing priority of the applicants identified in this notice. The
Commission will select among competing permit applications, as provided
in section 4.37 of its regulations.\2\ The priority established by this
drawing will be used to determine which applicant will be considered to
have the first-filed application.
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    \2\ 18 CFR 4.37 (2011).
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    The drawing is open to the public and will be held in room 2C, the
Commission Meeting Room, located at 888 First St., NE., Washington, DC
20426. A subsequent notice will be issued by the Secretary announcing
the results of the drawing.

    Dated: October 18, 2011.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2011-27385 Filed 10-21-11; 8:45 am]
BILLING CODE 6717-01-P


[Federal Register: July 12, 2010 (Volume 75, Number 132)]
[Rules and Regulations]
[Page 39632-39633]
[DOCID:fr12jy10-3]

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DEPARTMENT OF HOMELAND SECURITY

Coast Guard

33 CFR Part 165

[Docket No. USCG-2009-0139]
RIN 1625-AA11

Regulated Navigation Area; Gulf Intracoastal Waterway, Inner
Harbor Navigation Canal, Harvey Canal, Algiers Canal, New Orleans, LA;
Correction

ACTION: Interim rule; Correction.

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SUMMARY: In the Federal Register published on June 8, 2010, the Coast
Guard placed the Interim Rule for the Regulated Navigation Area; Gulf
Intracoastal Waterway, Inner Harbor Navigation Canal, Harvey Canal,
Algiers Canal, New Orleans, LA into the Code of Federal Regulations.
That publication contained an error in the DATES section, stating an
incorrect May 21, 2010 effective date. This error does not impact the
Interim Rule's correct May 24, 2010 effective date because the rule is
to be enforced only 24 hours in advance of, and during the duration of
specified predicted weather conditions. In fact, the conditions to
enforce this rule between the published effective date and the correct
effective date did not occur. But, this error may cause confusion among
members of the public.

DATES: This correction is effective July 12, 2010.

FOR FURTHER INFORMATION CONTACT: For information about this correction,
contact Kevin d'Eustachio, Office of Regulations and Administrative
Law, telephone<PHONE_NUMBER>, e-mail<EMAIL_ADDRESS>For
information about the original regulation, contact Lieutenant Commander
(LCDR) Marty Daniels, Coast Guard; telephone<PHONE_NUMBER>, e-mail
<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:
    In FR Vol. 75, No. 109, USCG 2010-0139, appearing on page 32275 in
the issue of Tuesday, June 8, 2010, the following correction is made:

    1. On page 32275, in the third column, in the DATES section, remove
``May 21, 2010'' and add in its place ``May 24, 2010''.

    Dated: June 30, 2010.
Kathryn Sinniger,
Acting Chief of the Office of Regulations and Administrative Law (CG-
943), U.S. Coast Guard.
[FR Doc. 2010-16375 Filed 7-9-10; 8:45 am]
BILLING CODE 9110-04-P