Status of Alternative Reference Methods for Mercury Emission Measurements – Part 1
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Status of Alternative Reference Methods for Mercury Emission Measurements – Part 1 Scott Hedges, USEPA, CAMD EPRI CEM Users Group Meeting Phoenix, AZ May 9 - 11, 2007. Need for Alternative Reference Methods.

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Status of Alternative Reference Methods for Mercury Emission Measurements – Part 1Scott Hedges, USEPA, CAMDEPRI CEM Users Group MeetingPhoenix, AZMay 9 - 11, 2007


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Need for Alternative Reference Methods Measurements – Part 1

  • Reference methods will significantly help in performing RATAs of the mercury CEMS and sorbent trap monitoring systems required by CAMR

  • The currently-available reference method – Ontario Hydro – uses wet chemistry techniques and typically requires 2-3 weeks of laboratory analysis before the test results are known

  • The alternative reference methods should allow for RATA results to be known while the test team is on-site.

  • As such, timely alternatives to the lengthy and complex Ontario Hydro reference method are strongly desired

  • In fact, these alternative reference methods are needed as soon as possible

    • Most Hg CEMS and sorbent trap monitoring systems will need RATAs in 2008 to meet 1/1/2009 deadline

    • Many utilities are also planning RATAs this year


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Evaluation and Validation of Measurements – Part 1Alternative Reference Methods

  • EPA and industry (EPRI and others) are completing remaining field validation tests for the instrumental and sorbent trap-based reference methods

  • An instrumental reference method (IRM) that provides timely RATAs with immediate, real-time results is easier to implement than OH and is consistent with NOX and SO2 trading programs

  • A sorbent trap reference method is considered another viable alternative method. When it combines thermal desorption / direct combustion techniques, it allows for onsite analysis

  • EPA and EPRI are currently completing sorbent trap method comparison studies using a modified EPA Method 301 which compares existing data from sorbent trap systems against data from the Ontario Hydro reference method.

    • Body of sorbent trap data has been favorable (i.e., good agreement with Ontario Hydro)


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Availability of Alternative Reference Methods Measurements – Part 1

EPA is preparing a rule package for both the instrumental and sorbent-based reference methods

  • Process being expedited through direct final rule making effort

  • Final rule tentatively scheduled for early August publication in the Federal Register

  • Would become final in October if no adverse comments are received

  • Methods will be made available at www.epa.gov/ttn/emc


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Mercury Instrumental Reference Method (IRM) Measurements – Part 1

  • Timely (real-time)

  • Performance-based

    • Amenable to multiple and new technologies

    • Test program-specific verification of data quality

    • Agency committed to performance-based methods (Federal Register Notice of Intent 62 FR 52098, 10/6/97)

  • Consistent w/ SOx & NOx instrumental methods

  • Key elements

    • Calibration error/linearity

    • System integrity/conversion efficiency

    • System response time

    • Interference test

    • Dynamic spiking (gaseous method of standard additions)


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Mercury IRM Development Measurements – Part 1

  • Used Methods 6C (SO2) and 7E (NOx) as starting point and factored in lessons learned from Hg CEMS demonstrations

  • Drafted Conceptual IRM and posted 2/28/06 at: www.epa.gov/ttn/emc/

  • Evaluated in field by EPA/ORD, EPRI, and others


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Planned Modifications to 2/28/06 Version of IRM Measurements – Part 1

  • Requiring only pre-test dynamic spiking and making optional until 1/1/09

  • Relaxing Hg0 calibration error criteria

  • Simplifying Hg2+ calibration to a system integrity check

  • Relaxing drift criteria

  • Making interference test optional

  • Waiving Hg stratification testing until 1/1/09 and adding a “low emitter cutoff”


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Sorbent Trap Reference Method for Mercury Measurements – Part 1

  • Performance-based

    • Amenable to new sorbents, equipment, and analytical technologies

      • Lab verification of sorbent performance and analysis

      • Test program-specific verification of data quality

  • Capability for timely results

  • Description

    • Known volume of stack gas is sampled through paired, in-stack 2-section sorbent traps (e.g., iodated carbon)

    • Analysis by any suitable system that can meet performance criteria (e.g., leaching, digestion, thermal desorption/direct combustion coupled with UV AF, UV AA, XRF)


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Sorbent Trap Reference Method for Mercury, cont Measurements – Part 1.

  • Key QA Elements

    • Laboratory

      • Matrix interference test (for wet digestion analyses)

      • Minimum sample mass determination

      • Analytical bias test (Hg0 and Hg2+)

    • Field (for each test)

      • Paired train agreement (assess precision)

      • Sorbent trap second section breakthrough

      • Field recovery test (assess bias)


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Questions? Comments? Measurements – Part 1

THANK YOU!


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