March 6, 2008

Very Hot Mercury Monitoring Webinar Raises Lots of Questions

More than 60 individuals or groups participated yesterday in a very good exchange of information and speculation on future of mercury monitoring with the vacature of CAMR.

N. Levin and C. Yanca of Frontier Concepts answered questions and provided a detailed analysis of the CAMR vacature from a legal perspective. They believe that EPA is unlikely to pursue and even more unlikely to win any appeal. The Court, in a unanimous decision, said EPA correctly originally identified coal-fired power plants as emitters of hazardous air pollutants which should be subject to Maximum Achievable Control Technology (MACT).

The monitoring rules are part of CAMR and therefore they are no longer applicable.  However there are four classifications of states. One class includes states that passed their own rules, so the State EPA is relying on the specific state law. These states can proceed without disruption. Those that embraced CAMR or a modified version of CAMR are back to Square One. The fourth group are states that don’t have coal-fired power plants. The participants asked these lawyers why EPA couldn’t just issue monitoring rules to keep that part of the program going. Their answer was that without CAMR there is no legal authority for such an action.

Scott Hedges of EPA indicated that efforts would continue to resolve accuracy and other technical issues but that EPA is reviewing options to move forward.

John Cooper of Cooper Environmental described four years of successful performance of the Xact mercury and multi-metal CEMS at a hazardous waste incinerator at Eli Lilly. It measures cadmium, chromium, lead and mercury from the outlet of a wet scrubber.  Now that power plants are reclassified as toxic emitters they will have to address these particulate heavy metals including mercury. This device will measure the particulate as well as gas phase metals.

Terry Marsh of Shaw says that based on their considerable experience as an integrator, there are six key factors to achieving continuous accuracy. They are:

• Instrument Air (Instrument air should be above 90 psi at the inlet to the N₂ generator and the outlet set at 60 psi.)
• Chlorine Regulation
• A good daily calibration
• Temperatures
• Calibration Gas Flow
• Patience

Shaw recommends:

• After each System Integrity Check run the oxidizer calibration from the analyzer (with chlorine bottle shut OFF) for at least two or more hours on a low value (2.5 ug/m³).

• Run in Sample mode for 30 minutes or more
• Verify that the System Zero is at or below the daily calibration value. (Could take more than an hour.)
• Place system back in Sample mode for at least 15 minutes. This places moisture in the filter assembly and the rest of the sample train.

Karl Wilbur of Tekran cited four ramifications:

• Recent CAMR vacature has had minimal impact on current Capability Maturity Model (CMM)-related actions
• CAMR replacement legislation likely to be more stringent
• Hg Regulatory “Net” may be broader – may extend to smaller emitters and other processes such as Cement, Steel, Chlor-Alkali, Mining, Incinerators, etc.
• Incremental focus expected on greater Hg abatement and low-level mercury measurements performance of CMMs.

Relative to replacement regulations, Karl made six crystal ball predictions:

1. MACT – type approach likely?
2. MACT approach combined with CAIR and year-round SCR operations = low-level mercury measurement.
3. Additional focus on NIST traceability and CMM System Accuracy.
4. Renewed investigation into Hg⁰, Hg²⁺, and Hg^P.
5. Greater use of CMMs for Abatement System Control and Optimization
6. Outlet Levels of Hg will be lower yet.

Karl speculated that the Pennsylvania rule may be widely imitated. The requirements are:
 

• (2010 – 2014) – Mandatory 84 percent reduction from Hg in coal or alternative emission limit = 0.024 lb/GW
• 2015 and Beyond – Mandatory 94 percent reduction from Hg in coal or alternative emission limit = 0.012 lb/GW.

Michael Corvese of Thermo Fisher reports that their customers are going forward with installation and operation of CEMS. He cited one exception, which is a plant which will store the CEMS until it is required. Field study of calibrators and mercury chloride generators is continuing. Over 400 Mercury Freedom Systems have been shipped and 100 are operational. Thirty systems have been tested and met performance criteria.

The individual power points can be accessed as follows:

John Cooper – Cooper Environmental Services

Continuing Decision Process For: Products

CES Xact Mercury & MM-CEMS: Recent Developments & Acceptance - Presented by John A. Cooper, Hot Topic Hour March 6, 2008

http://www.mcilvainecompany.com/Mercury_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Cooper March 6 2008 Hot Topic Xact 640.htm
 

Terry Marsh – Shaw Environmental

Continuing Decision Process For: Products

Managing your HG CEMS Maintenance and Certification. Presented by Terry Marsh, Shaw Environmental Hot Topic Hour March 6, 2008.

http://www.mcilvainecompany.com/Mercury_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Terry Marsh, Shaw Mcilvaine Presentation March 2008.pdf
 

Karl Wilber - Tekran

Continuing Decision Process For: Products

Overview of the State of Hg CEMS - One Company's Perspective "Mercury Monitoring Without CAMR" presented by Karl R. Wilber, Tekran Instruments Corp. Hot Topic Hour March 6, 2008.

http://www.mcilvainecompany.com/Mercury_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Mercury Monitoring Karl Wilber - Tekran.htm

Michael Corvese – Thermo Fisher Scientific

Continuing Decision Process For: Products

Mercury Freedom presented by Michael Corvese, Thermo - Hot Topic Hour March 6, 2008. http://www.mcilvainecompany.com/FGD_Decision_Tree/subscriber/Tree/DescriptionTextLinks/McIlvaine-Thermo 41207.pdf