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Update on Mercury Monitoring Under CAMR. Ruben Deza, PhD Clean Air Markets Division, EPA EPRI CEMS Meeting Columbus, OH, May 2006. Overview. Field Demonstrations Gas Calibration Standards Instrumental Reference Method Changes to CAMR Monitoring Other Technical issues. Demonstrations.
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Update on Mercury MonitoringUnder CAMR Ruben Deza, PhD Clean Air Markets Division, EPA EPRI CEMS Meeting Columbus, OH, May 2006
Overview • Field Demonstrations • Gas Calibration Standards • Instrumental Reference Method • Changes to CAMR Monitoring • Other Technical issues
Demonstrations • Test Sites: • North Carolina (EPA-funded) and Kentucky (EPRI-funded), WE Energy, Lehigh University, and also at NIST and ORD labs • The focus: issues that affect program implementation: • Reliability of monitoring systems • Development of certified gas standards • Development and testing of an instrumental reference method (IRM)
Demonstrations- cont. • Lehigh Field Study • 8 day test scheduled for late June, 2006 at a coal-fired power plant in PA • Draft Hg IRM will be compared to paired OH trains. Concurrent data will be collected from 2-3 Hg CEMS, including two portable Hg analyzers with newly designed probes, and sorbent traps • Will investigate traversing capability of the equipment and the time required per run • Will test dynamic spiking procedures • Will fine-tune CEMS performance criteria
Calibration Standard Issues • Two forms of vaporized Hg are needed for the calibration of mercury CEMS and reference methods • CAMR requires “NIST Traceable” Hg gas standards for both Hg0 and Hg2+ • EPA defines NIST traceability
Calibration Standard Issues – cont. • Currently, working with ORD and NIST to develop Hg traceability protocols, so that vendors can produce accurate Hg gases or gas generators for the regulated community • Hg0 gas cylinders: • Working with NIST to establish Hg0 standards (known as NTRMs) that gas vendors can use with a traceability protocol to mass-produce Hg calibration gas cylinders for the regulated community • EPA and NIST are working to establish a traceability protocol • Hg0 calibration gas generators • EPA and NIST are also working to establish a traceability protocol for elemental Hg gas generators • There is a good chance that the development of the traceability protocol will follow the pattern of ozone generators
Instrumental Reference Method • Issues • Provide an alternative to OH, consistent to what is done under other trading programs • Minimizes data loss and testing costs in cases where a RATA is failed • Measures “real-time” Hg concentrations in the stack gas and is suitable for multiple Hg CEMS technologies • Quality of data obtained must be comparable to OH data • Emphasis on simplicity and practicality and ease of implementation • Limited available data was used to support development of Draft Conceptual Instrumental Reference Method • Draft Conceptual IRM released, available at : http://www.epa.gov/ttn/emc/new.html http://www.epa.gov/ttn/emc/prelim.html
Instrumental Reference Method – cont. • Method has not been fully demonstrated • Considerable testing and data collection needed to make IRM viable • EPA and EPRI teaming up to find sites suitable for the demonstrations • Dynamic spiking of sampled stack gas with Hg+2 for assessment of site-specific matrix effects • Two portable instruments will be tested on site • To verify achievable performance and address practical implications such as implementation that are IRM-specific to later modify draft, if necessary
Changes to CAMR • In our re-engineering rule package, we will propose to add Method 29 as an alternative Hg reference method. • RM 29 is similar to the OH method, but is more familiar to testers, does not speciate Hg, and uses fewer impingers, • RM 29 could be used for RATAs and low-mass emitter testing under CAMR. Many States accept Method 29 data. • Various technical corrections will be proposed to Subpart I of Part 75, e.g., adding multiple/common stack heat input procedures • The proposed rule is expected in Summer 2006
Technical Issues of Concern • Wet Stack Issues – Probes - Alternate Probe Designs • Industry is working to address the problem; promising advances have been made • Stratification- use of SO2 as surrogate • Tests will be done at the Lehigh demo to study the practicality and accuracy of such procedure • Hg CEMS Performance at very low Hg levels • Vendors are addressing the technical difficulties and making significant progress • Other issues under consideration: • Revisit the need for dual trains for the OH • Injection of multiple levels of elemental and Hg+2 calibration gas at probe, dilution orifice and analyzer • Continue supporting the work on thermal desorption of sorbent traps