PM_2.5 will be a Challenge, according to Hot Topic Presenters Yesterday

If utilities were looking for some assurance that PM_2.5 won’t be a big problem, they did not find it yesterday. In fact they were advised that (1) the regulations will come sooner rather than later, (2) there is going to be all sorts of confusion over monitoring, and (3) control will be achievable but at a cost.

The presenters have more than 100 years of experience in the field. Their bios and pictures are shown at

bios_and_photos_E-Alert876

Allen Dittenhoefer of Enviroplan explained that starting in 2011 states will be considering the condensable fraction of PM_2.5 emissions in setting limits. The Title V permits will be revised accordingly. He cited the major problems with Method 202 and positive biases caused by SO₂ capture. The Dry Impinger Method could be a useful interim method until dilution techniques are refined.

Lysa Modica of AMEC has been developing a database of particulate emissions from gas turbines. There is a big variation from unit to unit and part of this is the way condensibles are measured. States are taking different approaches to PM_2.5 and in particular are calculating the PM_2.5 fraction from the total PM₁₀. NESCAUM has recommended a “Significant Impact Level” (Sils), which would be very tough for turbine operators to meet.

Tom Rose of Eastern Technical Associates offered insights on making opacity testing accurate and avoid some of the risks. The cost of observer testing vs. a transmissometer is considerably less. Mass emissions can also be calculated from opacity.

John Cooper of Cooper Environmental observed that for a polluter to cause an upset condition to conform with requirements for testing is a potentially costly operational exercise. The Quantitative Reference Aerosol Generator provides an alternative for generating PM concentrations over the measurement range. Testing at coal-fired power plants is imminent.

Dan Kietzer of Sick Maihak stated that PM CEMS using scatter light technology are sensitive at less than 5 mg/m³ and with particle sizes less than a micron. With a bypass system they can be used in wet stacks.

Steve Jaasund of A.H. Lundberg explained that wet precipitators have more than 98 percent efficiency on particles as small as 0.2 microns and can capture condensed droplets after a scrubber. New evidence shows that duplex stainless can provide acceptable long term corrosion resistance. Also, emerging data shows better performance than previously anticipated. The result is lower cost.

Anne Minga of Kuttner said that capture of fine particles is maximized by maintaining a filter cake depth, keeping pressure drop low and providing contact to chemically absorb condensibles. The Kuttner “Conditioning Rotor-Recycle Process recycles baghouse fines and redistributes carbon for increased contact.

Anne volunteered some useful documents. They include information on the Wisconsin program to use PM₁₀ as a surrogate for PM_2.5. This includes a summary table with the ratio of PM_2.5 to the total PM at a number of coal-fired power plants.

Continued Implementation of a PM10 Program as a Surrogate for PM_2.5

A Fact sheet summarizes the May 8, 2008 rule governing the implementation of NSR for PM_2.5 http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/EPA PM_2.5 fact sheet 20080508_fs.pdf

The full rule as it appears in the Federal Register is also included

http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Fed Register notice PM2.5 0508 a10768.pdf

Luke Wilkinson of Indigo in Australia started his presentation at 3:00 a.m. his time and explained how the Indigo Agglomerator causes the fine particles to adhere to the large ones. As a result, the fine particle capture in a downstream ESP or even a scrubber is substantially improved.

The individual power point presentations can be viewed in the particulate decision tree as follows:

Allen Dittenhoefer – Enviroplan Consulting

Lysa Modica - AMEC

Continuing Decision Process For: PM2.5

Condensable Particulate Matter: Presented by Allen Dittenhoefer, Enviroplan Consulting, Hot Topic Hour May 29, 2008

http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/CondensablePM.htm
 

PM2.5 and New Source Review Permitting for Power Generation Sources, presented by Lysa Modica, AMEC. Hot Topic Hour May 29, 2008.

http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Modica AMEC PM2 5Webinar R2.pdf

Tom Rose – Eastern Technical Associates

Continuing Decision Process For: Opacity

Facility managers signing compliance statements should make opacity and particulate measurement decisions based upon two factors. One is the real costs of measurement programs and the other is a risk analysis for the company and management personnel. This paper details and summarizes both issues. On the cost side capital purchases, installation, and O & M issues will be discussed. On the risk side the author will discuss how to assure valid measurements and the consequences of invalid measurement.

http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Opacity Measurement - Hot Topic Hour May 29, 2008 presented by Tom Rose.htm

John Cooper – Cooper Environmental

Continuing Decision Process For: Mass Monitoring

Multi-Metals QAG - Hot Topic Hour May 29, 2008

http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/John Cooper.htm

Dan Kietzer – Sick Maihak

Continuing Decision Process For: Products

Scatter Light Technology for PM CEMs

http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Sick Maihak Scatter Light Technology_D Kietzer - Hot Topic Hour May 29, 2008.pdf

Steve Jaasund – A.H. Lundberg

Continuing Decision Process For: Products

Wet ESPs for PM2.5 Emission Control presented by Steve Jaasund, A.H. Lundberg. Hot Topic Hour May 29, 2008.

http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Steve Jaasund McIlvaine Hot Topics May 29, 2008.pdf

Luke Wilkinson - Indigo

Continuing Decision Process For: Products

The Control of Fine PM_2.5 Particulate Matter Emissions, presented by Luke Wilkinson. Hot Topic Hour May 29, 2008.

http://www.mcilvainecompany.com/Particulate_Decision_Tree/subscriber/Tree/DescriptionTextLinks/Fine Particles - Indigo - Hot Topic Hour May 29, 2008.htm