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Summary Details of EPA's Mercury Data Collection (10/23/98)

The document titled, Electric Utility Steam Generating Unit Mercury Emissions Information Collection Effort, which you can download from our FTP site, provides specific details of EPA’s data collection requirements. Basically, all electric utility plants will soon receive a letter from EPA’s Sally Shaver requesting information about the coal-fired boilers operated at that plant. Owner/operators will be required to provide information on each coal-fired boiler including capacity, type of coal burned, and a description of all installed air pollution control technology. Then, beginning on or about January 1, 1999, each plant must maintain records so that the amount of coal received on a per shipment basis can be tabulated and reported to EPA for the 1999 calendar year.

In addition, for every sixth coal shipment, a sample must be collected and analyzed for mercury and chlorine. For each calendar quarter, plants must tabulate and submit all of the analytical results to EPA. As an additional exercise, each plant must calculate a 90 percent confidence interval about the mean mercury concentration and double the number of samples analyzed the next quarter if the confidence interval exceeds 10 percent of the mean mercury concentration. Since EPA knows that there is more than 10 percent analytical variability in the mercury measurement method, the Agency is guaranteed that ultimately each plant will have to sample and analyze every coal shipment.

As a third component of EPA’s data collection exercise, the Agency will "randomly" select 135 coal-fired boilers (3 boilers from each of 45 boiler categories) for mercury speciation stack testing. For each boiler selected, a minimum of three stack testing runs will be required. The tests must be conducted simultaneously at the inlet and the outlet of the air pollution control device. In fabricating its cost estimate, EPA assumed that only 75 boilers will actually have to be tested. To get from 135 boilers to 75 boilers, EPA assumed that some of the boilers with wet scrubbers have already been tested by EPRI and/or DOE and some of the 45 boiler categories will not have any boilers in them, although we cannot understand why EPA would construct a sampling matrix with cells (categories) that have no members. If you are an owner/operator of one of the "lucky 135" and would like to take advantage of RMB’s experience in working with mercury speciation measurements, call Ralph Roberson at (919) 510-0376 or email him at roberson@rmb-consulting.com.

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Last Revised: November 23, 1998