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DAQ Progress Report on Hydrogen Sulfide Study at Paper Mills. Presentation Summary - Rule requirements for monitoring study - Conduct and reporting of study - DAQ review for approval - Study purpose:

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daq progress report on hydrogen sulfide study at paper mills
DAQ Progress Report on Hydrogen Sulfide Study at Paper Mills
  • Presentation Summary

- Rule requirements for monitoring study

- Conduct and reporting of study

- DAQ review for approval

- Study purpose:

Replace prior uncertain data with quality- assured data from actual monitoring

rule requirements for emission study
Rule Requirements for Emission Study
  • April 2005 effective date reducing hydrogen sulfide (H2S) Acceptable Ambient Level (AAL) from 2.1 to 0.12 mg/m3 (1,500 ppb to 83 ppb)
  • Included exemption of wastewater treatment systems (WWTS) at paper mills
  • Required paper industry to conduct WWTS study estimating H2S & total reduced sulfur (TRS) compounds emissions
  • Study report to DAQ in November 2005
  • DAQ report to EMC in January 2006
rule requirements for dispersion modeling
Rule Requirements For Dispersion Modeling
  • Use estimates from study in dispersion modeling
  • If dispersion modeling shows predicted H2S level below AAL, no further action required.
  • Submit favorable modeling data to DAQ by July 1, 2006, with DAQ reporting results to EMC by September 1, 2006.
  • If modeling shows H2S AAL exceeded, industry submit ambient air monitoring plan to assess actual H2S levels typical of mill operations by September 30, 2006 for DAQ approval.
scope of phase i study
Scope of Phase I Study
  • Minimum scope: Estimate air emissions at typical paper mills for H2S and TRS
  • Implemented scope:
  • Measure air emissions at 3 paper mills

for H2S, TRS, and methane

  • Measure water composition and flow
  • Combine air and water data for mass balance
  • Develop model to predict air emissions
  • Synthesize emissions for one mill
air emission monitoring
Air Emission Monitoring
  • Identified method from similar 1989 mill study
  • Method consists of measuring downwind plume:

- At 10+ horizontal locations

  • At 4 vertical elevations
  • Using mobile sampling cart and tethered balloon
  • 6 and 30 ft high weather stations
  • Considered sophisticated and advanced approach
daq involvement in study
DAQ Involvement in Study
  • Started in May 2004
  • Team of DAQ chemists, engineers, and dispersion modelers
  • With 2 NCSU professors
  • Hired expert analyst with experience in same method with same sulfur compounds
  • Collaborated with US EPA chemists and engineers
daq review for approval
DAQ Review for Approval
  • Sampling and math procedures approved
  • However, given key QA criterion not routinely met, found most analytical data unacceptable
  • EPA found analytical data “questionable, …

hopes more suitable study conducted in future”

  • Feasible Phase II study data collected and modeled in time for July 2006 milestone
phase ii study plan
Phase II Study Plan
  • Industry submitted Phase II Plan in February 2006
  • DAQ approved plan with one minor change
  • Re-measure emissions at Plymouth & Roanoke Rapids

- Synthesize emissions for other 2 mills

  • Key analytical QA data good in Pre-Phase II work
  • Perform dispersion modeling for all 4 mills to predict hydrogen sulfide levels at property lines
  • Plan to submit emission study and dispersion modeling results by July 2006