Overview. Mercury Monitoring. Regulatory drivers Technology Overview Pros and Cons Alternative Hybrid Approach
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1 Mercury Compliance Monitoring in 2015 and Beyond Volker Schmid Clean Air Engineering March 28, 2013
2 Overview Mercury Monitoring Regulatory drivers Technology Overview Pros and Cons Alternative Hybrid Approach
3 Acknowledgements Tim Rodak Jim Wright CleanAir Joseph Siperstein Ohio Lumex Corporation
4 Regulatory Drivers
5 Regulatory Drivers National Emissions Standard for Hazardous Air Pollutants from Portland Cement Manufacturing Industry (40 CFR 63 Subpart LLL)
6 PC MACT Regulatory Drivers
7 Regulatory Drivers PC MACT Published September 9, 2010 Amended June 22, 2012 Final February 12, 2013
8 Regulatory Drivers PC MACT Electric Generating Utility Mercury and Air Toxics Standards (40 CFR 63, Subpart UUUUU)
9 Regulatory Drivers PC MACT EGU MATS
10 Regulatory Drivers PC MACT EGU MATS Published February 16, 2012 Final April 16, 2012 Reconsideration July, 27, 2012 Proposed Updates November 16, 2012 Final (?) March, 2013
11 Compliance Dates
12 PC MACT Emission Limits Existing Kilns: 12 μg/m 3 New Kilns: 5 μg/m 3
13 MATS Hg Emission Limits Existing Plants: 1.4 μg/m 3 New Plants: μg/m μg/m 3
14 Monitoring Options Continuous Mercury Monitoring System (CMMS) Sorbent Trap Mercury Monitoring System (STMMS)
15 CMMS Performance Specification 12A Procedure 5 (Part 60, Appendix F) PC MACT Appendix A to Subpart UUUUU MATS
16 CMMS Performance Specification 12A Procedure 5 (Part 60, Appendix F) PC MACT Appendix A to Subpart UUUUU MATS Real time data Daily calibration error tests Weekly system integrity checks Quarterly Linearity checks Annual RATA
17 The History of CMMS 2003 CAMR Two T s Expensive Complex Sensitivity?
18 Source: USEPA
19 NIST Calibrators Today 0 10 μg/dscm low point of 2.7 Today Source: EPRI CEMS, 2012, Thermo Supergroup
20 NIST Calibrators Today 0 10 μg/dscm low point of 2.7 Someday 0 1 μg/dscm low point of 0.2 Today Someday Source: EPRI CEMS, 2012, Thermo Supergroup
21 NIST Calibrators Today 0 10 μg/dscm low point of 2.7 Someday 0 1 μg/dscm low point of 0.2 MATS Limit = Today Someday MATS Limit Source: EPRI CEMS, 2012, Thermo Supergroup
22 The status of Hg CEMS Getting better all the time More options Believable to around 0.2 μg/dscm
23 The status of Hg CEMS Getting better all the time More options Believable to around 0.2 μg/dscm Still expensive Still complex Calibration
24 STMMS
25
26 2010 PC MACT
27 2005 CAMR 2010 PC MACT
28 2003 EU MACT 2005 CAMR 2010 PC MACT
29 STMMS
30 STMMS 1. Capture mercury in situ on a sorbent
31 STMMS 2. Sample over a period of several days
32 STMMS 3. Recover traps and send to lab
33 STMMS 4. Analyze for total mercury collected
34 STMMS 5. Calculate emissions
35 6. Repeat STMMS
36 STMMS Purpose An Evolution CMMS Back up CMMS Alternative
37 Simplicity NIST Traceability It works Cost Effectiveness
38 Simplicity Simple mechanical equipment
39 Simplicity No on site Hg calibration materials
40 Certification Requirements CMMS versus STMMS CMMS 7 day calibration error test Linearity test 3 level system integrity check Cycle time test RATA
41 Certification Requirements CMMS versus STMMS CMMS 7 day calibration error test Linearity test 3 level system integrity check Cycle time test RATA STMMS RATA
42 NIST Traceability Meter Calibrations Analytical SRMs Factory Spikes
43 It works No Hg transport issues Very low MDL possible Built in QA/QC
44 It works No Hg transport issues Very low MDL possible Built in QA/QC Spike recovery Breakthrough Paired trap agreement Proportional sampling
45 Cost Effectiveness Hardware about ⅓ the cost of CMMS Operating costs about ½ cost of CMMS
46 STMMS Performance How accurate is it? How reproducible is it? How reliable is it? How low can we go? 2012 Clean Air Engineering
47 Accuracy Hg conc. (μg/dscm) RM MET80 RATA Results Run* C RM - Avg C CMMS-AVG DIFF %DIFF % % % % % % % % % % % All data (n=11) % Hg Conc. (ug/dscm)*** RM 30B MET Run I.D.* 2012 Clean Air Engineering
48 Accuracy Hg conc. (μg/dscm) RM MET80 RATA Results Run* C RM - Avg C CMMS-AVG DIFF %DIFF % % % % % % % % % % % All data (n=11) % Hg Conc. (ug/dscm)*** RM 30B MET Run I.D.* 2012 Clean Air Engineering
49 Reproducibility 0.7% Difference 64 trap pairs 2.4% Difference 47 trap pairs 2012 Clean Air Engineering
50 Reliability
51 Reliability Case study Dominion Salem Harbor Compliance monitoring since 2008 Three MET 80 systems 2012 Clean Air Engineering
52 MET 80 Data Validity Unit 1 Valid Invalid Apr 08 Jul 08 Oct 08 Feb 09 May 09 Aug 09 Nov 09 Mar 10 Jun 10 Sep Clean Air Engineering
53 MET 80 Data Validity Unit 1 Valid Leak check Breakthrough < 5% Spike Recovery = % Proportional Flow Rate =± 25% Relative Deviation < 20% Invalid Apr 08 Jul 08 Oct 08 Feb 09 May 09 Aug 09 Nov 09 Mar 10 Jun 10 Sep Clean Air Engineering
54 MET 80 Data Validity Unit 1 Valid Leak check Breakthrough < 5% Spike Recovery = % Proportional Flow Rate =± 25% Relative Deviation < 20% Invalid Apr 08 Jul 08 Oct 08 Feb 09 May 09 Aug 09 Nov 09 Mar 10 Jun 10 Sep Clean Air Engineering 94% reported availability
55 MET 80 Data Validity Unit 1 Valid Mean = 0.4 μg/dscm Invalid Apr 08 Jul 08 Oct 08 Feb 09 May 09 Aug 09 Nov 09 Mar 10 Jun 10 Sep Clean Air Engineering 94% reported availability
56 MET 80 Data Validity Unit 2 Valid Mean = 0.5 μg/dscm Invalid Mar 08 Jul 08 Oct 08 Jan 09 May 09 Aug 09 Nov 09 Feb 10 Jun Clean Air Engineering 91% reported availability
57 MET 80 Data Validity Unit 3 Valid Mean = 0.8 μg/dscm Invalid Jul 08 Nov 08 Feb 09 May 09 Aug 09 Dec 09 Mar 10 Jun 10 Oct Clean Air Engineering 96% reported availability
58 2012 Clean Air Engineering How low can we go?
59 2012 Clean Air Engineering
60 2012 Clean Air Engineering
61 Western Bituminous 2012 Clean Air Engineering
62 Western Bituminous 2012 Clean Air Engineering
63 μg/scm Clean Air Engineering
64 Problem with Sorbent Traps Real Time Data
65
66 Need for Real Time Data COMPLIANCE CONTROL Active Hg control Process Hg control
67 Hybrid System Advantages Real time CMMS trending data NIST traceable STMMS compliance data
68 A Hybrid Approach Process Hg Analyzer Internal zero/cal Compliance Analyzer check
69 Questions? cleanair.com Clean Air Engineering
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