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There are a number of Mercury (Hg) emission measurement issues raised by the Environmental Protection Agency's (EPA’s) proposed Utility Mercury Reduction Rules. Regardless of the form of the final rule, the issues are the same. From a Hg emissions measurements perspective, it does not matter if the final rule emerges as a conventional MACT rule or as a cap and trade rule. The technical support documentation in the rulemaking docket and information available from industry research clearly shows that Hg continuous emissions monitoring system (CEMS) technology is not commercially available at the level of reliability, accuracy and cost needed for either a continuous compliance or trading program. It is a simple fact that no continuous Hg CEMS or carbon trap method has ever met all of the requirements of the proposed rules. In some cases, the required QA/QC tests in proposed Performance Specification 12A or Method 324 have never been attempted.

EPA appears to recognize that there are significant impediments to the commercial application of Hg continuous monitoring technology. EPA has plans to initiate an extensive dual site evaluation project to define and refine continuous Hg monitoring technology. Three different EPA groups are involved: (1) Office of Air Quality Planning and Standards (OAQPS), (2) Clean Air Markets Division (CAMD), and (3) Office of Research and Development (ORD). Below is a summary of major technical issues associated with Hg CEMS technology. It is critical that the EPA projects not only resolve the major technical issues associated with Hg CEMS but also demonstrate the reliable continuous operation of Hg CEMS.

Major Technical Issues Associated With Hg Continuous Measurements

• The precision, accuracy and time lag associated with the Ontario Hydro wet chemical reference test method
• Availability and demonstration of an instrumental reference method for Hg
• Availability and demonstration of continuous Hg monitor calibration techniques for elemental Hg
• Availability and demonstration of continuous Hg monitor calibration techniques for oxidized Hg
• Demonstration of oxidized Hg converter performance
• Demonstration of calibration drift and linearity of the continuous Hg monitor
• Quantification of lower measurement limit for continuous Hg monitors
• Reliability and operability of Hg monitoring systems
• Performance of Hg carbon traps (Method 324) relative to other measurement methods

RMB has structured a Hg CEMS implementation project to work with EPA, vendors and EPRI to ensure that the technical issues are addressed in a timely fashion and in a realistic manner. While certain of the issues above can be dealt with in a laboratory setting, others must be resolved in the field at significant cost. Unfortunately, many of the issues simply have never been addressed. Our objective is to ensure that all of the issues are addressed and that results can be obtained in a normal field setting and at a reasonable cost.

All utilities are invited to join in support of this project. We anticipate that the project will last through the end of 2005 or approximately 18 months. Several utilities have already expressed interest in joining this effort and we hope that broad support can be obtained. Both direct and EPRI TC funding mechanisms are available. Please contact Richard McRanie at 919-510-0483 or mcranie@rmb-consulting.com for more information.

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RMB Consulting & Research, Inc.
Last Revised: February 22, 2005