“CEMS for MACT and MATS Compliance” was Hot Topic Hour on April 16, 2015
Testing and monitoring challenges under MATS will be substantial, so will the
cost.
Speakers yesterday outlined the difficulties in testing and monitoring under the
MATS regulations which came into effect this week.
Kevin J. Crosby,
Vice-President, Technical, Montrose
Environmental Group, Inc. started the program with analysis of all the
decisions needed to plan the testing program.
Summary
§
Decide
how to conduct initial performance test
- stack
test, CEMS, CPMS?
- FPM
or metals, HCl or SO2, etc.
§
Decide
how to determine continuous compliance (this likely drives the decision)
-
Quarterly tests, CEMS, CPMS, etc.
§
Plan
carefully – operations, testing schedule, notifications and reporting
-
Quality testing will save overall cost!
-
Consider pre-compliance engineering tests (may be more important than compliance
tests!)
§
Prepare
differently for S/N 1, latest monitor
Careful planning is needed in setting up a MATS testing program. Consideration should be made as to whether to try to combine MATS with other testing.
Revision Date: 4/16/2015
Tags: 221112 - Fossil Fuel 化石燃料, Montrose Environmental, Testing, Continuous Emissions Monitor
Ed McCall
of PCME explained all the
different PM measurement options.
PM Compliance Options for MACT and MATS Rules by Ed McCall, PCME - Hot Topic Hour April 16, 2015
Light scatter extractive method is a good choice to measure PM for MATS where a wet stack is encountered.
Revision Date: 4/16/2015
Tags: 221112 - Fossil Fuel 化石燃料, PCME, Continuous Emissions Monitor, Particulate
Derek Stuart,
Product Manager - Combustion & Environmental AMETEK, provided cost and
performance data for the PM measurement options.
PM-CEMS and PM-CPMS for Dry Stacks by Derek Stuart, AMETEK - Hot Topic Hour April 16, 2015
Various options are available to measure particulate under MAT; the insitu forward scattering approach works well for dry stacks.
Revision Date: 4/16/2015
Tags: 221112 - Fossil Fuel 化石燃料, Land/AMETEK, Continuous Emissions Monitor, Particulate
Matt Pollack, P.E., Novinda Corporation, explained all the difficulties in measuring mercury in the area where sorbent is injected. The particulate makes the use of sorbent traps difficult. The probe/filter for the CEMS needs a special design to provide reliability. However, the effort is worthwhile when one considers the cost of sorbent.
Measuring mercury prior to the precipitator is challenging but necessary.
Revision Date: 4/16/2015
Tags: 221112 - Fossil Fuel 化石燃料, Novinda, Continuous Emissions Monitor
Karl R. Wilber,
Executive Vice-President and General Manager,
Tekran Instruments Corporation,
has submitted updated information on mercury CEMS vs. sorbent traps and also
weighed in on the methods of measuring compliance. When testing contractors
perform RATAs, they employ paired traps which need only be within a Relative
Deviation (RD) of 20 percent. On the other hand, RATA tolerances seem
overly restrictive.
Mercury CEMS are less expensive than sorbent traps over time. Stack CEMS with additional sample lines can be used for process measurement.
Revision Date: 4/16/2015
Tags: 221112 - Fossil Fuel 化石燃料, Tekran Instruments, Continuous Emissions Monitor
Tekran supports a RATA tolerance of ±0.4 µg/m3 for RATA’s conducted at concentrations less than the regulatory limit of 1.5 µg/m3. After the first years of operations under the EGU MATS, and after reviewing additional data, there may be a case for lowering this tolerance further. In the interim, the levels proposed by EPA do not seem to be in alignment with the level of uncertainty that can be expected using the current technology and Method 30B at the regulatory mercury levels. Thus, the current proposed RATA tolerances are considered overly restrictive and present undue hardship on both owner/operators and electronic HgCEM Systems suppliers.
Tekran Perspectives on NESHAPS Docket Relative Accuracy Test Audits (RATA) results submitted to EPA.
Less restrictive mercury RATA tolerance proposed.
Revision Date: 4/16/2015
Tags: Tekran Instruments, MATS, Mercury, Testing, Regulation
There was an agreement on the challenges of creating artificially high
particulate levels in order to calibrate the PM instruments. Shutting down a
precipitator field may not be enough. Since wet scrubbers remove particulate, it
may be necessary to reduce the slurry flow to the scrubber.
There was also agreement that CPMS could be used following dry scrubbers where
acid mist would have been removed and the temperature would be well above the
acid dew point. CPMS cannot be used to measure particulate in situ in a wet
stack.
CEMS for MACT and MATS Compliance Webinar - Hot Topic Hour April 16, 2015
Testing and monitoring challenges under MATS will be substantial, so will the cost.
Revision Date: 4/16/2015
Tags: 221112 - Fossil Fuel 化石燃料, Tekran Instruments, Novinda, Land/AMETEK, PCME, Montrose Environmental, Continuous Emissions Monitor, Testing, Particulate
