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Update on Mercury Monitoring Under CAMR

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 Monitoring Under CAMR

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  1. Update on Mercury MonitoringUnder CAMR Ruben Deza, PhD Clean Air Markets Division, EPA EPRI CEMS Meeting Columbus, OH, May 2006

  2. Overview • Field Demonstrations • Gas Calibration Standards • Instrumental Reference Method • Changes to CAMR Monitoring • Other Technical issues

  3. 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)

  4. 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

  5. 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

  6. 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

  7. 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

  8. 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

  9. 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

  10. 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

  11. Thanks

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