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LEE Qualification for Hg (1/6/14)

The MATS rule includes a provision that exempts sources with very low Hg emissions from the requirement of continuously monitoring vapor phase Hg emissions (i.e., no Hg CEMS or sorbent trap monitoring requirements.  This provision is known as "LEE" (i.e., Low Emitting EGU) status.  For Hg, qualifying for LEE status must be done each year and requires thirty (30) boiler operating days of Hg data collected using EPA Reference Method 30B.  To qualify, the test data must demonstrate that the emissions are either less than 10% of the applicable emissions limit or that the maximum potential emissions of Hg are less than 29 lbs/yr.  LEE Qualification testing can be performed up to 1 year prior to the MATS compliance date.  As a result, Utilities that believe they can meet the requirements of this provision may perform the required testing starting this April!

RMB has a tremendous amount of field experience with all aspects of Reference Method 30B and the associated analytical requirements that can be applied to help one conduct these qualification tests.  In addition, RMB personnel proposed an alternative moisture determination method specifically for use during Hg LEE qualification in lieu of costly and time consuming EPA Method 4 measurements. This alternative method (Alt-091) was accepted by EPA and can be found on their website at the following link: http://www.epa.gov/ttn/emc/approalt.html. RMB personnel have already assisted numerous facilities in successfully completing all the requirements necessary for demonstrating LEE qualification. This support included, but was not limited to: procuring testing equipment, performing testing and providing onsite training, conducting onsite analysis and analytical training, and performing all necessary calculations to demonstrate LEE qualification.

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RMB Consulting & Research, Inc.
Last Revised: February 16, 2016