# Using the Xact TM 

# Multi

- Metals CEMS 

# as a Mercury Monitor on a Coal

- Fired Power Plant: A Feasibility Study

Cooper Environmental Services 1 

## Krag A. Petterson, John A. 

## Cooper, Troy Pittenger, Mike Nakinishi Cooper Environmental Services, LLC

Joe Doherty, Marty Ladner; Pall Corporation

# Executive Summary

 

## Review of Xact TM 

## Design and Operation

 

## Goals of Feasibility Study

 

## Results of Laboratory Phase of Study

 

## Field Deployment and Performance Test Results

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# The Xact TM 

# Multi

- Metal CEMS

 Developed by Cooper Environmental Services (CES)

 Developed as a Multi

- Metals CEMS

 Based on X

- ray Flourescence Analysis (XRF)

 Beta

– gauge type reel

- to

- reel tape drive and sampling technology

 Can measure up to 20 metals simultaneously including Cr, As, Cd, Hg, and Pb

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# Xact TM



# - CEMS

Control Module Dilution Module Sampling and Analysis Module

Flow Module Connect to Probe and

Transport Line

Main Flow From Stack 60 to 800 Lpm

Sub sample onto Tape ~1 LPMCooper Environmental Services 5



# XACT TM 

# SAMPLING AND ANALYSIS

X

- Ray Tube



## Filter Tape Aerosol Deposit

Sample Flow

Analysis Area



## Filter Tape

# Determination of Stack Concentration

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## CONC (μg/m3) 

# Mass (XRF)

VOLUME (MFM) 

# =7



# Xact TM 

# CEMS

EPA Method 301 Validated for Multi

- Metals AMP EPA Approved

EPA Site Certified ~6 Years On

Stack Operations 

## on Hazardous Waste Incinerator

May 2007

– EPA Clean Air 

## Excellence Award

# Key Goals of Feasibility Study

 

## Demonstrate Xact Operation on a Coal Fired Power Plant

 

## Can the Xact Meet the Mercury Monitoring (PS

- 12A) Requirements for Initial Certification Specified by the Clean Air Mercury Rule (CAMR)?

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# PS

- 12A Initial Certification 

# Requirements (2007) Current PS 12A Requirements Are In Red

Test Required Frequency Required

Standards Passing Criteria

7

- Day Calibration Check 1 x per day

for seven days • Zero

• Upscale 5% of Hg Span Value

- OR

Less than 1 g/m 3 difference Linearity Check Once Hg Standard at Low, Mid and High Span Values 10% of reference value

- OR

Less than 1 g/m 3 difference

3

- Level System Integrity Check Once HgCl 2 Standard Low, Mid, High Span Values 5% of Span Value

Relative Accuracy Test (RATA) Once • Ontario Hydro

• Method 30B (Sorbent Trap) 20% of Reference Method

- OR

Less than 1 g/m 3 difference

Cooper Environmental Services 9 Measurement Error Span Value

10% of Span Value 5%

# HgCl 2 

# and Hg o 

# Generator

 

## Xact TM 

## did not have a HgCl 2 

## or Hg o 

## Generator

 

## Used Commercially Available HovaCal TM



###  

## HovaCal TM 

## operates by evaporating a solution of HgCl 2 

## on a heated surface

 

## HgCl 2 

## Solution of known concentration was metered at a measured flow rate into a measured air flow

 

## Hg o 

## is generated by chemically converting the HgCl 2 

## to elemental Hg (Hova Merc)

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# Initial Laboratory Tests

– Xact TM



# Calibration

 

## XRF Portion of the Xact Calibrated Using Thin Film Standards

 

## These standards are typically used for calibration of XRF equipment for the analysis of Ambient Air Filters (EPA IO 3.3)

 

## Flow Portion of the Xact Calibrated Using Reference Flow Meter

 

## Calibration for Multiple Metals Checked using Quantitative Aerosol Generator (QAG)

 

## QAG Audit similar to that performed EPA Approved Alternative Monitoring Petition

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# Xact Mercury Calibration is 

# Completely Independent of the HgCl 2 

# and Hg o 

# Generator 

# Used to Check It.

# Initial Laboratory Tests With 

# HovaCal TM 

# HgCl 2 

# Linearity

Concentration Level Nominal

Concentration (mg/m 3 ) # of Samples Average Percent Difference (% of Span) Pass Test

Criteria?

Zero (DI Water) 0 6 0.40% Yes

Low 2 8

- 2.37% Yes

Low Mid 4 6

- 0.69% Yes
High Mid 11 6

- 4.10% Yes
High 18 8

- 4.17% Yes

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# Also Passed Current 12A Criteria

# Initial Laboratory Tests with 

# HovaCal TM 

# Elemental Hg Linearity

Concentration Level Nominal

Concentration (mg/m 3 ) # of Samples Average Percent Difference (% of Span) Pass Test Criteria?

Low 4 7 0.57% Yes

Mid 11 6 4.46% Yes
High 18 8 0.45% Yes

Cooper Environmental Services 13 Concentration Level Nominal Concentration (mg/m 3 ) # of Samples Average Percent Difference (% of Reference) Pass Test Criteria?

Low 4 7 2.66% Yes

Mid 11 6 8.69% Yes

High 18 8 0.45% Yes


# With New PS12A Criteria 

# Xact TM 

# Met All Tested PS

- 12A Criteria During Laboratory Evaluation

# Field Deployment

 

## Xact TM 

## installed at PGE’s Boardman Facility

 

## 585 MW Facility, ESP Controls

 

## Lab XRF Calibration Used

– Not Recalibrated in Field

 

## Installed and operating within 2 days

 

## Side by side comparison with Thermo Mercury Freedom Unit

 

## Two week field deployment

 

## Performed initial performance specification including:

- 7 Day Calibration Check

- Linearity Check

- System Integrity Check

- RATA

– Method 30B

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# Field Test Arrangement

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# Seven Day Drift Test Results

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###  

## Zero Drift Met on all Days

– indicating little loss of Hg

 

## Difficulty Meeting Upscale

– Problems with HovaCal TM

# Field HgCl 2 

# Linearity (System Integrity 

# Check)

Cooper Environmental Services 17

# Field Hg o 

# Linearity

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# Problems with HovaCal Conversion of 

# HgCl2 to Hg0 Because of Low Temps in Converter

# Why we think there was a problem



# with HovaCal TM



###  

## Visible Rust in Tubing Exiting HovaCal TM



###  

## Problems Maintaining Heating

– heater would frequently 

## fail requiring the HovaCal TM 

## to cool down and restart

 

## Were Using HovaCal TM 

## at the Very High End of Recommended Emission Range

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# Thermo Hg Freedom Comparison

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# RATA Results

Cooper Environmental Services 21 Thermo QA Period 

# 3.53% RELATIVE ACCURACY FOR CES 

# XACT

# Conclusions

 

## CES Xact Can Accurately Measure Mercury in a Coal Fired Power Plant

 

## If the Xact TM 

## had recalibrated to the mercury generator (HovaCal TM 

## ) as most Hg CEMS do

– it would likely have failed the RATA

 

## It is feasible to use the Xact to Measure Mercury on a Coal Fired Power Plant

– 

### Need a Mercury Generator Designed to Operate on Xact TM 

### Flows

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# Differences Between Xact TM 

# and AF



# Based Mercury Monitors

 

## Xact TM 

## Requires Longer Sampling Times (15 minutes versus 1 to 2 minutes)

 

## XRF Calibrations are very stable (1 year or more) AF needs to be recalibrated frequently

 

## Xact TM 

## is less dependant on the accuracy of the Hg generator

 

## Since XRF is Non Destructive Samples Can be Archived and Potentially Reanalyzed if Data needs to be validated

 

## Xact TM 

## could be used to monitor for other metals

– 

### PM is a surrogate for HAP Metals

– 

### If EPA requires PM CEMS on CFPP Xact could potentially be used for Hg and HAP metals

– 

### Therefore 1 CEMS (multi

- metals including Hg) instead of 2 Hg 

### CEMS and PM CEMS Cooper Environmental Services 23

# QUESTIONS?

Krag Petterson kragp@cooperenvironmental.com

Cooper Environmental Services 24