November 16, 2006

Mercury CEMS: Commercial Availability

Within the last few months the CEMS supplier industry has been able to compile some good evidence of reliable operation of mercury CEMS. Yesterday in our hot topic hour

Reynaldo Forte of EPA provided the very lastest insights on mercury CEMS  including CAMR requirements, technical issues and next steps in improving performance in challenging environments.

 Thermo Electron, ADA-ES, Tekran, and Sick Maihak provided the latest in hardware development. Cooper detailed a CEMS which measures mercury as well as other metals.

The sense of the discussions was that mercury CEMS are proving to be accurate enogh and reliable enough but they will be expensive. The initial cost could be $ 200,000 to $ 400,000 for a complete system.  The major ongoing expense will be labor.

 Semi formal presentations

• Reynaldo Forte: EPA
• Michael Corvese: Thermo Electron
• Susan Sjostrom: ADA
• Greg Muldrew: Tekran
• John Cooper: Cooper Environmental

Experts are on hand to answer questions

• CEMS suppliers:  GE, Sick Maihak, Cisco, Durag,
• Engineering firms ( Burns & McDonnell, URS, Bibb, EQ, MPR)

Testing: Resolution Analytics, Clean Air Engineering

Some of the questions

• What is accuracy and reliability of the first generation of CEMS?
• What will or can be done to improve the second generation?
• Will CEMS be available in sufficient quantities?
• What is the annual anticipated cost of mercury monitoring?
• Are sorbent traps a viable alternative or complementary technology?
• Does it make sense to buy a redundant CEMS?
• Is redundancy only attractive if allowance trading values are high?
• What are the advantages and disadvantages of the various instruments?
• Are the state programs going to push the technology too far too fast?
• What about operation of probes in wet stacks?
• Can instruments handle 50-1 Hg excursions?
• Can some of the IRM requirements be simplified?

PARTICIPANTS WERE INFORMED ABOUT A PREVIOUS SUPER GROUP MEETING. ITS CONTENTS HAVE BEEN WOVEN INTO THE DECISION TREE AND REPORTED IN THE

AIR POLLUTION
MONITORING
& SAMPLING   NEWSLETTER                 December  2006  No. 326

Latest Mercury Measuring Intelligence Provided at Thermo Electron Super Group II Meeting in September

More than 150 people convened in Chicago for Super Group II, a gathering of industry participants, organized by Thermo Electron Corporation, who according to Michael Corvese strongly believe that open, frank dialogue is critical to helping U.S. power generators effectively prepare for and meet the requirements of the Clean Air Mercury Rule (CAMR) issued by the U.S. Environmental Protection Agency (EPA) in March of 2005. The meeting included representatives of the U.S. power generation industry, U.S EPA, the Electric Power Research Institute (EPRI), and leading university researchers, as well as environmental consultants and stack emissions testers.

Rich McRanie of RMB gave an insightful summary of significant technical issues and results. Here are the points he displayed

Lessons Learned

If you put stainless in a wet stack, it will not be there when you return!

·        Loss of probe heater trips are essential.

o       Current or temperature

o       Otherwise, days of acid cleaning

·        Operating without an oxidized calibrator tells you nothing.

·        Ditch the 4-20 ma signals.

Regulatory Issues

·        range and span rule language are obsolete.

o       Modern digital analyzers don’t have ranges

o       Ditch 4-20 ma, it creates an artificial range

·        How do we handle 10/50-1 Hg excursions?

·        There are alternatives if one understands how Hg CEMS and calibrators work.

Range and Span

·        Experiments are being conducted to illustrate the wide range capability of Hg CEMS.

·        Initial Experiments are very encouraging

Instrument Reference Method Issues

·        IRM is very complex.

·        Equipment is very expensive – ~$200,000 and

·        Extremely time consuming – 3-4 days minimum.

·        Are all the requirements necessary?

IRM Requirements

·        3-point elemental calibration

o        2% of span or ±0.2 µg/m³ criteria

·        3-Point oxidized calibration

o        5% of span or ±0.5 µg/m³ criteria

·        Pre-test dynamic spike – 2 levels, 3 runs

o        100 ±5% recovery plus <5% RSD, or if either failed, alternatively <0.2 µg/m³ difference  between theoretical and actual spike

·        Make sample runs

o       Nominally 30 minutes each run

·        single level system integrity test

o       Minimum of every 4 runs

o       5% of span or ±0.5 µg/m³ criteria

·        Post-test dynamic spike, 2 levels, 3 runs

o       100 ±10%, recovery plus <5% RSD, or if either failed, alternatively <0.2 µg/m³ difference between theoretical and actual spike

What Can Be Eliminated?

·        Pretest Elemental Calibration

o        Not needed in addition to oxidized calibration.

·        All spiking — Only Adds Time and Cost

o        Not telling us anything except that the spiking equipment did not work or that the stack Hg concentration had changed.

o        There has never been any evidence of stack matrix or spectral interference.

The full presentation is found at http://supergroup2.blogspot.com/2006/09/richard-mcranies-presentation-mercury.html.

Sharon Sjostrum of ADA-ES presented performance data and addressed problems encountered in utilizing the CEMS. Her power point presentation is found at http://supergroup2.blogspot.com/2006/09/sharon-sjostroms-presentation-thermo.html

Bobby Chen of Western Kentucky provided coverage of the activities of the ICSET with a mobile laboratory making mercury measurements at a number of midwest utilities

http://207.190.199.52/thermo/supergroup/bobbychen.pdf

Dennis Laudal of EERC provided the latest details on sampling with sorbent traps and comparisons of sorbent traps measured by the Ohio Lumex and to CMMs.

http://207.190.199.52/thermo/supergroup/dennislaudal.pdf

BIOGRAPHIES OF TWO OF THE PARTICIPANTS IN MCILVAINE HOT TOPIC HOUR

Forty years experience developing environmental measurement methods and investigating the origin, transport and fate of pollutants. Recently developed multi-metals CEMS that measures 20 elements including mercury using XRF and reactive filter tape, which has been approved by EPA for compliance demonstration at a hazardous waste incinerator. Developed a NIST-traceable quantitative reference aerosol generator with stabilities on the order of a two percent over days, which has been approved by EPA for audits of multi-metal CEMS including mercury.

Ph.D. - Nuclear Chemistry – University of California. - 1966

BS - Chemistry - Humboldt State –1962

Rey Forte

Rey is the Branch Chief of the Emissions Monitoring Branch in the Clean Air Markets Division of the EPA. He is responsible for the implementation of emissions monitoring programs for major regulations of electric power generators and industrial boilers in the U.S.  He manages the design, implementation of emissions measurement and reporting requirements for the Acid Rain and the NOx Budget Trading Programs, the Clean Air Interstate Rule, and the Clean Air Mercury Rule. This includes managing the development and implementation of the mercury monitoring program required to support Cap-and-Trade under CAMR. Rey also provides consultation and assists several countries in the design and implementation of emission control, monitoring, reporting, verification, and compliance programs.

Mr. Forte has a bachelor’s degree in chemical engineering from the University of Puerto Rico, masters in mechanical engineering from the Catholic University of America, and a Maintainability Engineering Diploma from the Department of the Army. Rey has been a registered professional engineer in the state of Virginia since 1995 and has published numerous technical papers in professional journals and conference proceedings.