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MEETING YOUR MERCURY MONITORING REQUIREMENTS

MEETING YOUR MERCURY MONITORING REQUIREMENTS. 2007 ARIPPA Conference Presented By: AVOGADRO Environmental Corporation. Outline. Tailored to ARIPPA members All effected EGU’s of ARIPPA members use stack flow monitors to determine heat input for Part 75 monitoring

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MEETING YOUR MERCURY MONITORING REQUIREMENTS

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  1. MEETING YOUR MERCURY MONITORING REQUIREMENTS 2007 ARIPPA Conference Presented By: AVOGADRO Environmental Corporation

  2. Outline • Tailored to ARIPPA members • All effected EGU’s of ARIPPA members use stack flow monitors to determine heat input for Part 75 monitoring • All effected EGU’s of ARIPPA members expect to use Excepted Monitoring Methodology; i.e. <29 pounds/year. • Stepwise path • Key Considerations AVOGADRO Environmental Corporation • www.avogadro.net

  3. Who Has To Monitor Hg? • All coal-fired EGU’s >25 MWe for sale must monitor and report mercury emission, even low emitters. • Thus, all EGU’s must submit a Phase I Monitoring Plan. • Two Monitoring Approaches • “Excepted Monitoring Methodology”; EGU with <29 pounds/year. • Continuous Emission Monitoring; Any EGU • PA monitoring requirements are essentially those contained in Part 75, Subpart I. Future revisions to PA CSMM will address Hg. AVOGADRO Environmental Corporation • www.avogadro.net

  4. Emission Limits • 12-month rolling period, starting 2009 • 0.0096 pounds/gigawatt-hour (lb/GWh) for coal-refuse fired circulating fluidized bed • Or, 95% capture efficiency; difference between mercury entering the unit through fuel and mercury leaving through stack emissions. • Through request, credit may be given toward capture requirement from fuel pre-treatment. • Comply by averaging facility-wide emissions; i.e. average emissions < average limit. AVOGADRO Environmental Corporation • www.avogadro.net

  5. Excepted Monitoring MethodologyPrinciple • Emissions factor, micrograms per standard cubic meter. • Determine by periodic stack test. • Use default value (0.50 microgram per standard cubic meter (ug/scm)) • Monitor stack flow-rate continuously • Monitor electrical production • Use factor, flow-rate and electrical production to continuously monitor/report Hg emissions in lb/GWh AVOGADRO Environmental Corporation • www.avogadro.net

  6. Excepted Monitoring MethodologyStep 1 Submit Phase I by 8/17/07 and > 45 days before Certification Test • Basis for using Excepted Monitoring Methodology. • Stack test results • Material Balance • Guesstimate • Methodology for periodic Hg sampling • Means for monitoring stack flow-rate; must meet requirements of Part 75 • Electrical production • Methodology for sampling fuel Hg for units monitoring control efficiency AVOGADRO Environmental Corporation • www.avogadro.net

  7. Excepted Monitoring MethodologyStep 2 Submit Phase II Monitoring System Certification Protocol >45 days before Certification Test • Procedures for performing gaseous Hg sampling • Currently Ontario Hydro • Proposed Part 75 Revisions include Method 29 • Two new methods (30A and 30B) due out soon. Expected to be incorporated into Part 75. • Procedures for Certifying Flow CEM. • Use existing certified system certified per Part 75 AVOGADRO Environmental Corporation • www.avogadro.net

  8. Excepted Monitoring MethodologyStep 3 Perform “certification test” in 2008. • Three paired test-runs for Hg • Calculate estimated annual mass-emission using: • the higher of either the highest concentration measured by the three test runs or 0.50 microgram per standard cubic meter (ug/scm) • The maximum potential stack flow-rate • 8760 hours/year. • Certify flow-rate monitoring system, if needed. AVOGADRO Environmental Corporation • www.avogadro.net

  9. Excepted Monitoring MethodologyStep 4 Evaluate test data • Applies to Certification test or retest • Annual Estimated Hg Emissions of <29 pounds/yr validates Excepted Monitoring Methodology monitoring system. • Annual Estimated Hg Emissions of >29 pounds/yr = continuous emission monitoring system • Submit Certification Application <45 days of test. AVOGADRO Environmental Corporation • www.avogadro.net

  10. Excepted Monitoring MethodologyStep 5 Report emissions, starting January 1, 2009 • Calculate hourly Hg emissions in lb/GWh using: • Hg emission factor, the higher of: • highest concentration measured by highest of most recent certification test or retest runs test runs • 0.50 ug/scm • Actual stack flow-rate measured by CEM. • Measured electrical production AVOGADRO Environmental Corporation • www.avogadro.net

  11. Excepted Monitoring MethodologyStep 6…on Perform Periodic Certification Retest • Within 720 operating hours of fuel change • Based on most recent test data • Calculate estimated annual emissions per Step 3 using the higher of the highest most recent test/retest runs or 0.50 ug/scm. If estimated annual emissions are: • <9 pounds/year, perform next retest by 4 operating quarters after calendar quarter of last test/retest • >9 pounds/year and <29 pounds/year, perform next retest by 2 operating quarters after calendar quarter of last test/retest AVOGADRO Environmental Corporation • www.avogadro.net

  12. Excepted Monitoring MethodologyTest Methods • Ontario Hydro • Relatively Expensive • Provides information about types of Hg; particle-bound, elemental, reduced, oxidized • Data availability 24 hours-2 weeks. • Method 29 • Less costly than OH. • Provides information on total particle-bound and total gaseous Hg • Data availability 24 hours-2 weeks AVOGADRO Environmental Corporation • www.avogadro.net

  13. Excepted Monitoring MethodologyTest Methods (continued) • Draft EPA Method 30A • Instrument-based; real-time data availability! • Track trends easily • EPA is pushing strongly • Equipment geared toward emission testing still under development • Draft EPA Method 30B • Uses dry sorbent tube. • Relatively inexpensive • Proven, reliable methodology; equipment readily available • Data availability 1 hour – 2 weeks • Long-term test runs; up to 1 week • 0.0001 ug/dscm sensitivity possible for a twenty-four sample AVOGADRO Environmental Corporation • www.avogadro.net

  14. Excepted Monitoring MethodologyKey Considerations • Test firm for both Hg test and flow monitoring system RATAs must be accredited per draft Part 75 revisions. • Fuel variability and retesting. Graph is for daily samples taken at different intervals over three month period. Highest value is >2X lowest value. • Maximum allowances set aside for CFB’s • Emission trading prohibitions AVOGADRO Environmental Corporation • www.avogadro.net

  15. Fuel Variability AVOGADRO Environmental Corporation • www.avogadro.net

  16. Additional Resources • Avogadro Environmental Corporation www.avogadro.net • Thomas Mattei – tmattei@avogadro.net • George Wagner – gwagner@avogadro.net • PADEP Mercury Monitoring page http://www.dep.state.pa.us/dep/deputate/airwaste/aq/cemspage/cems_mercury.htm • 40 CFR 75, draft revisions http://www.epa.gov/airmarkets/emissions/docs/rlso_p75v1.pdf; http://www.epa.gov/airmarkets/emissions/docs/rlso_p75v2.pdf • EPA Mercury page. http://www.epa.gov/mercury/ AVOGADRO Environmental Corporation • www.avogadro.net

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