Subject: Mercury audit system needed
McIlvaine has proposed to EPA that mercury annual emissions in tpy be measured with an audit system. EPA already admits that better quality control and quality assessment is needed. But, where there is the possibility of cap and trade, you are measuring money. At $35,000/lb. this is big money. The mercury protocol gases are plus or minus 10 percent. The CEM itself adds another variable. This is just to measure gaseous mercury. EPA says particulate mercury doesn’t need to be measured because it is only a few percent of the total. However, one control technology relies on condensing all gaseous mercury to particulate. If you just use mercury CEMs, you are going to have an accuracy range of plus or minus 15-20 percent. So, one plant could be under reporting by 20 percent, and another over reporting by 20 percent. This could be 100 lbs. difference at $35,000/lb. or $3.5 million/yr.
Hence a different system has to be selected. McIlvaine submits that when you have an analysis which utilizes multiple inputs and requires analysis, you have a situation comparable to an accountant auditing a financial statement. If sorbent traps are operated some portion of the year, and if particulate mercury samples are obtained periodically, the accuracy can be improved greatly. With multiple inputs including measurements of the mercury in the coal, flyash, and wastewater, it should be possible to improve accuracy to plus or minus 1 or 2 percent. This is the range needed to satisfy the CFO.
Check out the project details at: Utility Environmental Upgrade Tracking System http://www.mcilvainecompany.com/energy.html .
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Bob McIlvaine
847-784-0012