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Mercury Monitoring Approaches for Small Units Under CAMR

Mercury Monitoring Approaches for Small Units Under CAMR. Ruben Deza, PhD Clean Air Markets Division U.S. Environmental Protection Agency. Introduction – Why Monitoring is Important.

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Mercury Monitoring Approaches for Small Units Under CAMR

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  1. Mercury Monitoring Approaches for Small Units Under CAMR Ruben Deza, PhD Clean Air Markets Division U.S. Environmental Protection Agency

  2. Introduction – Why Monitoring is Important • Monitoring and reporting of an affected source’s emissions are integral parts of a cap and trade program, such as the one described in the Clean Air Mercury Regulation (CAMR) • Emissions monitoring establishes a “level playing field”, ensures the integrity of the allowances, and instills confidence in the trading program • There is considerable variability in the type, size, operation and fuel mix of sources affected by CAMR

  3. Introduction – Why Monitoring is Important (cont’d) • Emissions from the larger units must be monitored continuously with rigorous quality assurance and quality control requirements, to meet the emission reduction goals and ensure the value of allowances and emission control investments. • For smaller units, less rigorous monitoring and QA may be appropriate

  4. Mercury Monitoring Under CAMR (The Basics) • Required continuous monitoring for CAMR units: • Hg concentration • Stack gas flow rate • Moisture---if needed • Diluent gas (CO2 or O2)---if needed for heat input • Monitor certification deadlines • For existing units--- January 1, 2009 • For new units---90 operating days or 180 calendar days after commencement of commercial operation

  5. What Hg Monitoring Options are Available Under CAMR ? • Continuous Emissions Monitoring System (CEMS) • Similar to current CEM systems used in the Acid Rain & NOx budget programs • Measures “real-time” vapor phase Hg concentration in the stack • Sorbent Trap Monitoring System • Continuously samples the stack gas---collects vapor phase Hg on sorbent media (e.g., activated carbon) • Hg accumulates in the sorbent traps over an extended period of time, e.g., a few days or weeks • Lab analysis of the traps is required at the end of the data collection period • Alternative Monitoring System (via petition process under §75.66) • Low Mass Emitter Option • Available only to units with very low annual Hg mass emissions • Requires the use of conservative Hg emission factors derived from stack testing. • Also requires continuous monitoring of the stack gas flow rate.

  6. Mercury CEMS -Status • There are several Hg CEMS available in the market: Tekran, Horiba/Nippon, Durag, Opsis, Thermo, Lumex, Forney/Genesis, and GE/PSA • Most manufacturers have made significant improvements to these instruments in recent years, to correct problems identified in field demonstrations. • While the reliability and accuracy of Hg CEMS continues to improve, some technical issues still remain, e.g., probe “survivability” on wet stacks, unexplained calibration error test failures. • CEMS are the preferred Hg monitoring option for large utility boilers because of operational similarities to SO2, NOx and CO2 instruments

  7. Mercury Sorbent Trap - Status • Sorbent trap systems generally have performed well in field demonstrations • The capital investment required for these systems is smaller than for CEMS but the operation and maintenance requirements are time-intensive. • Remaining issues associated with sorbent trap systems include the limited availability of sorbent materials and analytical laboratories, and the length of time required for lab analysis of the traps • Note that a new manufacturer of sorbent trap systems is now in the market and will be participating in EPA’s field demonstrations

  8. Mercury Monitoring at Smaller Units, The Basics • CAMR provides as much flexibility in Hg mass emission monitoring as possible, while maintaining the high data quality needed to run a market-based program • CAMR requires Hg mass emissions monitoring in accordance with Subpart I of 40 CFR Part 75 • Any affected unit may use an Hg CEMS or a sorbent trap system. • Consistent with the SO2 and NOx cap-and-trade programs, sources may also petition to use an alternative monitoring system (AMS), under Subpart E of Part 75 • For an AMS, other monitoring approaches or variations may be proposed to meet the performance requirements in Part 75. • However, the requirements for an AMS are very rigorous. The AMS must provide data of the same precision, reliability, accessibility, and timeliness as a CEMS.

  9. Mercury Monitoring at Smaller Units, The Basics-(cont’d) • A less rigorous monitoring approach (§75.81(b)) may be used for low emitting units—may be a good option for smaller units • For a unit to qualify as a low emitter, the owner/operator must perform Hg emission testing to demonstrate that the unit’s potential to emit is < 29 lbs/yr of Hg. • If the unit qualifies, a default Hg concentration is used for reporting, i.e., the greater of: the highest concentration from the testing or 0.50 µg/m3 • Periodic retesting is required, using a two-tiered approach • Semiannual testing if potential to emit is > 9 lb/yr but < 29 lb/yr • Annual testing if potential to emit is < 9 lb/yr

  10. Other Issues • Demonstrations • IRM • NIST • Rulemaking changes • Additional rule info

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