ASH GROVE CEMENT GOMPA_NY 

lo•l CODY STREET 

OVERLAND PARK, KANSAS 66£10 

PHONE 913 /451-8900 FAX 913 /451-1686 

F. (t"RAN) L. STI:•EI'I'NAN 

VICE PRESIDENT ENVIRONMENTAL AFFAIRS WRITER'S ©IRECT LINE BI96057 

October 1, 2007 

Keith Barnett 

Office of Air Quality Planning and Standards 

Minerals and Inorganic Chemicals Group 

Mail Code C504-05 

Research Triangle Park, NC 27711 

Re: 

Dear Keith, 

Ash Grove Cement Company Durkee, Oregon 

Enclosed is a copy of the Mercury Control Slipstream Baghouse Testing 

at Ash Grove's Durkee Cement Facility". 

Please call me if you have any questions regarding this test program 

Sincerely, 

Vice President Environmental Affairs 

Enclosure 

MERCURY CONTROL SLIPSTREAM BAGHOUSE 

TESTING AT ASH GROVE'S DURKEE CEMENT 

FACILITY 

Prepared for: 

Ron Vidergar 

Ash Grove Cement Company 

i011 Cody Street 

Overland Park, KS 66210 

Prepared by." 

Michael L. Jones 

John P. Kay 

Brandon M. Pavlish 

Kevin C. Galbreath 

Energy & Environmental Research Center 

University of North Dakota 

15 North 23rd Street, Stop 9018 

Grand Forks, ND 58202-9018 

September 2007 
TABLE OF CONTENTS 

LIST OF FIGURES iii 

LIST OF TABLES iv 

NOMENCLATURE v 

EXECUTIVE SUMMARY vi 

1.0 

2.0 

INTRODUCTION 

BACKGROUND 

2.1 Process Overview 

2.2 Mercury 2 

2.3 Previous Mercury Studies for Cement Kilns 3 

2.4 Mercury Control Strategy 4 

3.0 PROJECT OVERVIEW 5 

3.1 Goals and Objectives 5 

3.2 Approach/Work Plan 5 

4.0 FACILITIES AND EQUIPMENT DESCRIPTION 6 

4.1 Description of Ash Grove Durkee Facility 6 

4.1.1 Raw Material Handling 6 

4.1.2 Raw Mill 6 

4.1.3 Fuel Systems 6 

4.1.4 The Pyroprocess 6 

4.1.5 Cement Mill 7 

4.1.6 Cement Storage and Shipping 7 

4.1.7 Description of the Main Air Pollution Control Device 7 

4.2 Description of the EERC Slipstream Baghouse 7 

4.3 Mercury Monitoring 9 

4.3.1 Main Stack Mercury Monitor 9 

4.3.2 Slipstream Fabric Filter Baghouse Mercury Monitor 9 

4.4 OH Method Flue Gas Mercury Measurements 10 

4.5 Carbon Trap (EPA Method 30B) Mercury Measurements 

4.6 Powdered Activated Carbons 11 

4.7 Stack RATA Testing II 

4.8 Fixed-Bed Testing 12 

5.0 RESULTS AND DISCUSSION 12 

Continued... 
TABLE OF CONTENTS (continued) 

5.1 Slipstream Baghouse Operation 12 

5.2 SSBH Baseline Testing 13 

5.2.1 Raw-Mill-On Baseline Period 13 

5.2.2 Raw-Mill-Off Baseline Period 16 

5.3 Parametric Testing 18 

5.4 Stack Hg Measurement 29 

5.5 Analytical Methods and Procedures- Their Applicability at the Durkee Facility 35 

5.6 Main Stack RATA Testing 36 

5.7 Fixed-Bed Testing 37 

6.0 CONCLUSIONS 37 

6.1 SSBH Testing 37 

6.2 Performance Monitoring 39 

6.3 Fixed-Bed Option 39 

PERSONNEL RESUMES Appendix A 

EXAMPLE CALCULATIONS Appendix B 

SLIPSTREAM BAGHOUSE MM DATA AND TEST DESCRIPTION Appendix C 

QUALITY ASSURANCE/QUALITY CONTROL Appendix D 

MAIN STACK MM DATA Appendix E 

MAIN STACK DAILY AVERAGE HG CONCENTRATIONS Appendix F 

NATIVE MERCURY CAPTURE STATISTICAL EVALUATION AND 

SUMMARY OF MM VARIANCE Appendix G 

CALCULATION OF A MASS WEIGHED POTENTIAL ANNUAL 

REMOVAL EFFICIENCY Appendix H 

ii 
LIST OF FIGURES 

Cement manufacturing process basic flow diagram 2 

2 SSBH, trailer, and control room 8 

3 Schematic of the SSBH showing the locations of MM sampling and carbon injection 10 

4 Raw-mill-on baseline results comparing MM, carbon traps, and OH method 15 

5 Raw-mill-off baseline results comparing the MM to the carbon trap results 17 

6 PAC injection results for the injection of DARCO Hg at lbEVlacf 19 

7 PAC injection results for DARCO Hg for the injection of 3 and 5 lb/Macf 21 

8 PAC parametric testing results performed at an A/C ratio of 4 with standard PPS bags 22 

9 Bag type comparison showing their effectiveness in regard to Hg removal efficiencies 24 

10 Membrane/fiberglass bags parametric testing results showing effects of varying 

A/C ratio 25 

11 Membrane/fiberglass bag parametric testing results showing effects of varying 

PAC injection rate 26 

12 Raw-mill-off injection testing with membrane/fiberglass bags at an A/C ratio of 8 27 

13 Full-scale carbon injection results 28 

14 Graphical comparison of MM, carbon trap, and OH method for April 15, 2007 30 

15 Comparison MM graphs for April 23 and May showing the variability of HgtotaI 

and Hg ° output 32 

16 Average Hg concentration during raw-mill-on conditions over the entire test period 

compared to various specific days 34 

17 Stack MM data of raw' mill outage overnight April 15 through 16 35 
LIST OF TABLES 

Table I. Brief Description of the Carbons Tested During Parametric Testing Through the SSBH 

Table 2. Results from Carbon Trap and OH Method Testing During Raw-Mill-On Baseline 

Testing ........................................................................................................................................... 14 

Table 3. Results of Carbon Trap Testing During Raw-Mill-Off Baseline Testing 18 

Table 4. Comparison of Bag Type Results 24 

Table 5. Comparison of Sampling Methods Showing Difference of MM with Carbon Trap and 

OH Method ................................................................................................................................... 30 

Table 6. Stack Emission Carbon Trap Data 31 

Table 7. Comparison of Process Data for April 23, 2007, and May 1, 2007 33 

Table 8. RATA Test Results 36 

iv 
NOMENCLATURE 

A/C 

APCD 

acfm 

ASTM 

CVAAS 

EERC 

EPA 

ESP 

FF 

(g) 

Hg 

Hg ° 

Hg 2÷ 

Hgp 

Hgtotal 

IGS 

ILC 

lb 

Macf 

MM 

NESHAP 

NIST 

Nm • 

ODEQ 

OH 

PAC 

PPS 

RATA 

SEA 

SLC 

SSBH 

std. dev. 

TDF 

•.tg 

air-to-cloth 

air pollution control device 

actual cubic foot per minute 

ASTM International (formerly American Society for Testing and Materials) 

cold-vapor atomic absorption spectroscopy 

Energy & Environmental Research Center 

U.S. Environmental Protection Agency 

electrostatic precipitator 

fabric filter 

gas 

mercury 

gaseous elemental mercury 

gaseous inorganic mercuric compounds 

particle-bound mercury 

total mercury for Ontario Hydro measurements, it includes Hg °, Hg 2+, and 

Hg(p), whereas for mercury monitor measurements, it includes Hg ° and Hg 2+. 

inertial gas separation 

in-line calciner 

pound (0.454 kg) 

million actual cubic feet 

mercury monitor 

National Emission Standards for Hazardous Air Pollutants 

National Institute of Standards and Technology 

normal cubic meter (20°C, 7% O,, dry, at atm) 

Oregon Department of Environmental Quality 

Ontario Hydro 

powdered activated carbon 

polyphenylene sulfide 

relative accuracy test audit 

sorbent enhancement additive 

separate-line calciner 

slipstream baghouse 

standard deviation 

tire-derived fuel 

microgram 
MERCURY CONTROL SLIPSTREAM BAGHOUSE TESTING AT ASH GROVE'S 

DURKEE CEMENT FACILITY 

EXECUTIVE SUMMARY 

In early 2007, Ash Grove engaged the Energy & Environmental Research Center (EERC) 

to assist the company in assessing and evaluating mercury (Hg) emission controls suitable for 

use on a cement kiln. Because no other cement plant is known to have installed emission controls 

designed to reduce Hg emissions, this project was highly experimental. The EERC first 

identified powdered activated carbon (PAC) injection as the most promising technology for 

controlling Hg from cement plants. The EERC then arranged for the temporary installation of a 

fabric filter (FF) slipstream baghouse (SSBH) and PAC injection at the Durkee Plant. This pilotscale control system received a small slipstream of air off the main stack (-1% of the total main 

stack exhaust gas), thus enabling the EERC to perform a series of tests over 6 weeks under 

realistic conditions. 

The overall goal of this project was to perform parametric testing on a slipstream of actual 

flue gas from Ash Grove's Durkee cement facility to gain an understanding of how various 

operating and design parameters are likely to impact Hg control for the Durkee cement plant as 

well as to determine whether a predicted I-Ig control efficiency could be established. Carbon 

type, FF bag type, PAC injection rate, and air-to-cloth (A/C) ratio were all evaluated during the 

pilot test. Mercury monitors (MMs) were used in conjunction with carbon traps and Ontario 

Hydro method tests to provide data on Hg emissions. Based on these data, key design parameters 

for a full-scale Hg control installation were assessed, and a predicted control efficiency was 

established for the pilot-scale system. 

The EERC testing identified clear design choices for use in a full-scale Hg control 

installation at the Durkee facility. Monitoring during the pilot test period demonstrated 

significant variability over short periods of time (e.g., hourly, daily) in both total mass of Hg and 

form of Hg (Hgtota• vs. Hg °) at the SSBH inlet. This variability appears to be irrespective of kiln 

operating conditions. Despite this variability, clear design choices were identified for use in 

developing a full-scale Hg control installation. The pilot study demonstrated that the type of 

activated carbon used in the PAC injection system makes no material difference in controlling 

Hg emissions from the Durkee cement kiln. While studies at coal-fired power plants have 

indicated that the use of halogen-treated PAC can result in higher Hg control efficiencies, testing 

on the Durkee exhaust gas indicated that untreated carbon provides equivalent control to 

halogen-treated carbon. This is believed to be due to the low sulfur levels in the Durkee cement 

kiln exhaust gases as compared to coal-fired power plants. The different FF bag types perform 

comparably, but the fiberglass with membrane bags were deemed most appropriate because of 

their ability to withstand the higher temperatures that can occur during kiln upsets. The A/C ratio 

testing documented that high Hg control efficiencies occur at levels in the 6 to 8 range. Hg 

control efficiency dropped oft materially at levels below that range, and Hg control efficiency 

did not change materially at levels higher than this range. PAC injection rates ,,,,.ere varied during 

raw-mill-on conditions between and 5 lb/Macf. Significant increases in Hg control efficiency 

were realized during this testing by increasing the PAC injection rate from to 3 lb/Macf: 
insignificant changes in Hg control efficiency typically occurred when the PAC injection rate 

was increased from 3 to 5 lb/Macf. With the parameters in the optimal ranges/rates, 90% Hg 

removal efficiencies were routinely achieved by the pilot-scale system during raw-mill-on 

conditions. 

Testing was also performed during raw-mill-off conditions. It is necessary to shut down 

the raw mill for short periods each week resulting in kiln exhaust gas being routed directly to the 

main stack baghouse. During these time periods mercury levels are elevated--particularly during 

the first hour after the raw mill is shut down. PAC injection into the SSBH during raw-mill-off 

conditions resulted in a slightly higher Hg control efficiency at 5 lb/Macf than at 3 lb/Macf and 

injection at 3 lb/Macf was significantly higher than at lb/Macf. PAC was also injected into the 

main stack baghouse during raw-mill-off conditions with significantly higher Hg control 

efficiency at 5 lb/Macf than at 3 lb/Macf. The average Hg removal efficiency during the SSBH 

and main stack testing at 5 lb/Macf was 63%. A PAC injection rate of 10 lb/Macf was tried for a 

short period on the SSBH only and the HG removal efficiency increased to 88%. Injection at the 

5 lb/Macf rate appears warranted during raw-mill-off conditions. However, it is unclear that 

injecting PAC at 10 Ib/Macf during raw-mill-off conditions would perform materially better in a 

full-scale installation that had reached equilibrium conditions and so is unlikely to justify the 

additional cost, equipment wear and waste generation. It is recommended that the PAC injection 

system be sized capable of injecting up to 5 lb/Macf during raw-mill-off conditions with testing 

to determine whether injection at that rate is necessary beyond the first hour after shutting down 

the raw mill. 

Based on the 6 weeks of testing performed using the PAC injection installation and SSBH, 

the EERC recommends that a full-scale Hg control installation for the Durkee cement kiln be 

designed with the following parameters: 

Parameter 

PAC Type 

Design Criteria 

Untreated carbon 

Bag Type Fiberglass 

w/membrane 

A/C Ratio 6 to 8 

Injection Rate 3 lb/Macf (raw mill on) 

5 lb/Macf (raw mill 

oft') 

Comments 

Untreated PAC performs comparably to 

halogen-treated PAC, while avoiding 

potential environmental issues associated 

with use of halogens. 

All bags performed comparably, but 

fiberglass with membrane withstands higher 

temperatures. 

Lower A/C ratios resulted in lower control 

efficiency. Increasing A/C ratio over this 

range results in higher energy consumption 

without increased control efficiency. 

Elevated PAC injection rate during rawmill-off conditions may not be necessary 

after first hour. 

vii 
The EERC believes that a Hg control installation design based on these parameter 

selections will provide optimal Hg control for the Durkee cement kiln. The pilot test indicates 

that a 90% Hg control efficiency should be achievable on an annual average basis during the 

approximately 85% of the time that the raw mill is operating. The weighted average Hg control 

efficiency across all operating conditions should be approximately 77%. However, the EERC has 

found that pilot test results are not always reproducible in full-scale installations. Therefore, we 

caution against assuming that a properly designed full-scale Hg control system will necessarily 

be capable of consistently reaching these Hg removal rates. We also note that a well-designed 

installation will vary in control efficiency over the short term and that control efficiency should 

be evaluated based on long-term average performance. Because a PAC injection installation has 

not been previously installed to control cement kiln Hg emissions, a full-scale installation will 

require a period for optimization. The achievement of 90% control efficiency (raw mill on) and 

77% control efficiency (weighted average), even if it is appropriate for a full-scale installation, 

may take 12 to 18 months to consistently reach. Therefore, the EERC recommends that if Ash 

Grove proceeds with a PAC injection Hg control installation as described above, that the 

company plan on 18 months to optimize equipment performance.. 

The full-scale Hg control installation will require periodic testing to document control 

performance. Currently, MMs are not commercially available that could be utilized in a cement 

kiln stack, and no approved relative accuracy testing audit (RATA) method exists to perform a 

RATA for a MM operating in the environment presented by the Durkee cement kiln main stack. 

Therefore, the EERC does not recommend the use of MMs for tracking control system 

performance. The use of carbon sorbent traps worked very well during the pilot test with results 

comparable to the Ontario Hydro method and MM measurements. Carbon sorbent traps provide 

an excellent means of routinely checking Hg air pollution control device performance and are 

recommended for use both during the optimization period and for subsequent periodic testing. 

The EERC planned to evaluate a fixed-bed Hg control installation during the PAC 

injection pilot study. The fixed-bed test was not successful because of problems with the 

equipment. Given the lack of study of fixed-bed Hg controls for systems of the type and scale of 

the Durkee cement kiln, the EERC cannot recommend consideration of this control technology at 

this time. 

viii 
MERCURY CONTROL SLIPSTREAM BAGHOUSE TESTING AT ASH GROVE'S 

DURKEE CEMENT FACILITY 

1.0 INTRODUCTION 

Ash Grove Cement Company (Ash Grove) operates a cement-manufacturing plant located 

in Durkee, Oregon. This plant emits mercury (Hg) that naturally occurs in the plant's raw 

materials and, to a much lesser extent, fuels. In early 2007, Ash Grove engaged the Energy & 

Environmental Research Center (EERC) to assist it in assessing and evaluating Hg emission 

controls suitable for use on a cement kiln. To Ash Grove's knowledge, no cement kiln is known 

to have installed emission controls intended to remove Hg. Therefore, this research effort has 

sparked national interest. 

The EERC has prepared the following report outlining the evaluative process that it has 

engaged in over the past 6 months. Because no other cement plant is known to have installed 

emission controls designed to reduce Hg emissions, this project was highly experimental. The 

EERC identified powdered activated carbon (PAC) injection as the most promising technology 

for controlling Hg from cement plants and fixed-bed carbon as a possible alternative technology. 

The EERC then arranged for the temporary installation of a fabric filter (FF) baghouse and a 

PAC injection installation at the Durkee Plant as well as a fixed-bed carbon unit. These pilotscale control installations received a small slipstream of air off the main stack and enabled the 

EERC to test different PAC types and injection rates under realistic conditions. The information 

gathered and conclusions drawn from those data are presented in this report. 

2.0 BACKGROUND 

2.1 Process Overview 

The cement-manufacturing process is a large industrial process that includes several 

processing steps, beginning with quarrying raw materials, preparing material, and 

pyroprocessing the raw mix in the cement kiln system. Figure 1 shows the basic flow diagram 

for the cement-manufacturing process. The process uses large quantities of raw materials (rock) 

to form clinker, the intermediate product of cement. The pyroprocessing step includes heating 

the raw mix to temperatures in excess of 2750°F in the kiln system, which is fired with large 

quantities of fuel to provide the energy required for processing the kiln feed. Fuels are delivered 

to multiple locations in the kiln system in order to deliver the energy at the most effective 

location for efficient manufacturing. Both the raw materials and the fuel that is used contain 

minute concentrations of Hg, which can become part of the stack emissions when heated in the 

kiln system to the high temperatures necessary to produce quality clinker. The Hg is found to be 

ubiquitous in the raw materials and fuels used to produce cement. As is typical for naturally 

occurring materials, there is normal variability in the concentrations of Hg found in these 

materials. 
EERC JK30394 CDR 

Raw Material 

Stockpiles 

and Crushing m•=• • 

Preblending 

and 

Storage 

Raw Milling Burning 

and 

Homogenization 

Cement 

Milling 

and 

Shipping 

Figure 1. Cement manufacturing process basic flow diagram. 

The cement-manufacturing process includes complex physical and chemical reactions that 

occur during the pyroprocessing in the kiln system. The kiln system at Ash Grove's Durkee 

facility is a preheater/precalciner system, which includes the rotary kiln, a preheater/precalciner 

tower, and the associated air pollution control system. The raw materials are mined, ground, and 

mixed to the appropriate chemical consistency prior to being fed to the kiln system. The 

materials are heated in the kiln system to temperatures that achieve the appropriate chemical 

reactions that result in a quality clinker product. The facility is equipped with an in-line raw mill, 

where the gases from the kiln system are routed directly to the raw mill to provide the heat to dry 

the raw materials. During operating times when the raw mill is off (approximately 15% of the 

annual operating time frame), the gases bypass the raw mill and are routed directly to the 

baghouse. Typically, the Durkee Plant consumes 1,500,000 tons per year of raw materials and 

has the capacity to produce 1,000,000 tons of clinker annually. 

2.2 Mercury 

Mercury is found in the environment in one of the four following forms: 

Elemental Hg (Hg °) 

"Liquid silver" or Hg vapor 

Inorganic Hg (oxidized) 

Mercuric compounds Hg 2+ (e.g., HgS, HgCl_•, HgO, HgSO4) 

Mercurous compounds Hg •-+ (e.g., Hg2CI2) 

Organic Hg 

Methylmercury species CH3Hg or MeHg 

Particulate-bound Hg- Hgp 
All four of these forms of Hg can exist in the environment. Elemental, inorganic, and Hgp 

are the types that are emitted from the cement-manufacturing process. Organic Hg is not emitted 

from the cement-manufacturing process because organic Hg is thermodynamically precluded 

from forming. 

The form of Hg emitted dictates the way in which the Hg will behave in the environment. 

Mercury that is emitted from a cement kiln stack is deposited in the local environment or is lost 

to the global Hg cycle. Elemental Hg is not water-soluble and, upon being emitted, has a 

residence time in the atmosphere of 6 months to 2 years. During this time, Hg ° 

can travel 

thousands of miles before being deposited. Oxidized Hg, by contrast, has a residence time of 

days once emitted to the atmosphere. Oxidized Hg is water-soluble and has greater potential to 

enter into rainfall and waterways. Particle-bound Hg, upon being emitted, has a residence time in 

the atmosphere of between hours and years, depending on the size of the particle. Inhalation of 

atmospheric Hg species is not a serious health hazard, even at the highest ambient levels. 

Similarly, ingestion of Hg ° does not pose a serious hazard. Some of the Hg that is deposited into 

waterways is converted to MeHg by biological processes. The small percentage of the overall Hg 

emissions that is deposited in wetlands and converted to MeHg is the Hg that is focused on from 

an ecological and human health perspective. Recent studies in Clear Lake, California, have 

indicated that Hgtotat levels in waterways may not impact MeHg levels. The Oregon Department 

of Environmental Quality (ODEQ) has estimated that, in the western portion of Oregon, 

approximately 83% of all Hg being deposited from air originating in Asia. 

2.3 Previous Mercury Studies for Cement Kilns 

Only limited data are available relating to Hg emissions from cement kilns. Equilibrium 

calculations suggest that HgCI2 is the dominant Hg species in the flue gases from cement kilns at 

<480°-590°C. 2 Flue gas Hg speciation measurements and kinetic calculations indicate that Hg ° 

chlorination reactions generally do not attain equilibrium because of gas quench rates. Schreiber 

et al. 3 reviewed the results from previous Hg mass balance studies and comprehensive stack Hg 

measurement results on cement kiln systems and concluded that cement kiln systems inherently 

control stack Hg emissions to varying degrees. Likely hosts for Hg in cement kilns are threefold: 

1) cement kiln dust, 2) raw materials in the in-line raw mills, and 3) cement clinker) 

Schreiber et al. 3 also describes how levels in Hg emissions could change as a result of the 

raw mill operating or not operating. Data collected during the SSBH testing indicates a higher 

Hg emission level with the raw mill not operating as compared to that with the mill in operation. 

One hypothesis given for this release of Hg when the raw mill is shut off and bypassed is 

explained by the fact that the in-line raw mill has the capability to capture Hg when the raw mill 

is online. This Hg capture is possible because when the raw mill is online, the kiln gas containing 

volatilized Hg is used to dry raw materials and sweep the mill of the finely ground and dr3, raw 

kiln feed material. Because the mill temperature operates at 90°-120°C, the fine feed particles 

Hope. B.: Science of the Total En,,ironment. 2006. p 356. 

Senior. C.: Sarotim. A.: Eddings. E. Beha,,ior and Measurement of Mercur? in Cement Kilns. Presented at the 

2(/03 IEEE-IAS/PCA Cement Industry Technical Conference. Dallas. TX. May 4-9, 2003. 

Schreiber. R.J.. Jr.: Kellett. C.D.: Joshi. N. h•here,•g ,.•Iercucv Cont,o!s •,Vighii,• t/ze P,•,t/a•zd Ceme•,• Kiln 

R&D Serial No. 2841, Portland Cement Association. Skokie. [L. 2005: pp 24. 
can absorb Hg from the gas stream as the Hg condenses on them. This Hg is then stored in the 

kiln feed silos, which supply the feed into the kiln system, thereby reintroducing the Hg, which 

will again volatilize in the higher-temperature zones of the pyroprocess. When the raw mill is 

shut off, the Hg that has built up in the system through this process is no longer captured in the 

raw mill, but instead travels through the facility's APCD and out the stack, causing increased 

levels of Hg. 

Mercury control for cement kilns has not been extensively studied. As the U.S. 

Environmental Protection Agency (EPA) determined in trying to evaluate the availability of Hg 

controls for the portland cement National Emission Standards for Hazardous Air Pollutants 

(NESHAP), cement plants have not installed controls for Hg emissions. EPA has stated air 

pollution control devices (APCDs) such as wet scrubbers may provide Hg control as an 

unintended benefit, but the level of Hg control has not been adequately studied. EPA recently 

required the few cement kilns with wet scrubbers to perform inlet and outlet Hg sampling so as 

to identify Hg control efficiency. Those data have not been collected and assessed. Even when 

those data are collected and available, there will be significant questions as to the transferability 

of results from one cement plant to another given the variability in relative proportion of Hg 

forms encountered in different parts of the country. 

2.4 Mercury Control Strategy 

Ash Grove has recognized the concerns regarding Hg emissions at its Durkee facility and 

has voluntarily collaborated with the Oregon DEQ to investigate commercially viable solutions 

to the issue. In mid-2006, Ash Grove was supplied with data suggesting that the process Hg 

emissions were greater than previously thought. As noted above, the data concerning cement kiln 

Hg emissions are limited, and data collected at one cement plant may not be relevant to 

emissions from another cement plant. Therefore, in order to better quantify its emissions, Ash 

Grove engaged in extensive Hg testing in September and December 2006. This testing generated 

detailed information about the form, quantity, and variability of Hg emissions from the Durkee 

facility. Based on these data, Ash Grove contracted with the EERC to evaluate potential Hg 

control strategies for the Durkee cement plant. The EERC is a nonprofit branch of the University 

of North Dakota and is a national leader in the research, development, and commercialization of 

air pollution control and emission-monitoring equipment. Ash Grove is unaware of any cement 

plant having installed controls specifically to control Hg. Therefore, the EERC's extensive 

experience developing Hg controls for the coal-fired electric utility industry made it uniquely 

qualified to assist Ash Grove in this innovative control technology project. 

The EERC's evaluation of potential Hg controls identified PAC injection as the most 

promising technology for controlling Hg from cement plants. PAC injection, fixed-bed carbon, 

and wet scrubbing have all been identified as potential Hg control technologies for cement kilns. 

The scarcity of water in the Durkee Plant vicinity and the limited efficacy of wet scrubbing for 

controlling H• °• make it an inferior control method. Therefore, this study was focused on the 

feasibility and optimization of PAC injection for cement kilns. A secondary study was performed 

on fixed-bed carbon, but this technology was not more comprehensively studied because it has 

not been employed in comparable installations. 

4 
The utilization of a PAC injection system at the Durkee Plant would require the installation 

of a new FF baghouse. PAC is typically injected upstream of a particulate APCD. In the case of a 

cement facility, an additional APCD is needed downstream of the existing particulate APCD. 

The Durkee facility recycles the raw material collected in their primary particulate APCD, thus 

eliminating waste and enhancing the efficiency of the process. At Ash Grove's Durkee Plant, the 

particulate APCD is a FF baghouse. Injecting PAC upstream of the existing FF baghouse would 

eliminate the ability to recycle baghouse dust, resulting in large amounts of waste and lower 

process efficiency. By injecting PAC downstream of the existing FF baghouse and capturing that 

PAC in a secondary FF baghouse, the plant would be able to continue recycling of the baghouse 

dust collected in the existing primary baghouse. 

The EERC designed this project in order to better understand the site-specific control 

characteristics of the Durkee Plant. The efficiency of a PAC injection installation is expected to 

vary with the relative proportions of Hg forms in a particular gas stream as well as the proportion 

of naturally occurring oxidizing agents such as chlorine. Control efficiency is also expected to 

vary as the Hg levels vary over time. In order to test these hypotheses and draw meaningful 

conclusions as to the level of Hg control that can be anticipated from a PAC injection 

installation, the EERC installed a temporary PAC injection system on a slipstream from the 

Durkee stack, downstream of the existing particulate APCD. Inlet and outlet emissions were 

studied over the course of approximately 4 weeks, during which time the types and amounts of 

PAC were varied. This pilot study provides a basis for predictions as to the anticipated control 

level that can be achieved and the design parameters for consideration in engineering a full-scale 

installation. However, it is important to note that this pilot system did not operate under steadystate conditions for an extended period and that the performance documented during this testing 

may or may not be sustained during long-term, full-scale operation. 

3.0 PROJECT OVERVIEW 

3.1 Goals and Objectives 

The overall goal of this project was to use a small-scale mobile FF baghouse operating in 

series with an existing Durkee baghouse to perform parametric testing on a slipstream of actual 

flue gas from Ash Grove's Durkee cement facility to gain an understanding of how various 

operating and design parameters are likely to impact Hg control at the full scale. The Hg control 

strategies under consideration involved injection of various sorbents into the second baghouse 

operating in series with the existing particulate control device. 

3.2 ApproachAVork Plan 

The EERC was on-site at the Durkee facility from April 10 to May 16, 2007. Appendix A 

contains the resumes of all EERC personnel who participated in this project. Appendix B 

contains the sample calculations used during testing and the analysis of the data collected. 

Appendix C contains a daily description of the testing performed at the Durkee facility. 

Appendix D desctibes the quality assurance/quality control procedures. 
4.0 FACILITIES AND EQUIPMENT DESCRIPTION 

4.1 Description of Ash Grove Durkee Facility 

4.1.1 Raw Material Handling 

Three of the four raw materials are found on-site in the Durkee quarry: limestone, shale, 

and clay. Iron slag is the only imported raw material for the cement process. Iron slag is 

imported from off-site sources, unloaded, and utilized as a feed stream supplement. Raw 

materials are withdrawn from storage silos in proportioned amounts and conveyed to the raw 

mill system. 

4.1.2 Raw Mill 

The raw mill grinds and dries the raw materials to raw meal. The mill is referred to as an 

"in-line" raw mill because it utilizes exhaust gases from the pyroprocess to dry and separate the 

raw meal. The raw mill operates approximately 85% of the time the kiln operates on an annual 

basis. The raw meal is combined with recycled material from the main baghouse to make kiln 

feed, which is stored in silos. The raw mill is shut off once a week for scheduled routine 

maintenance. Typically, maintenance can be performed over an 8- to 12-hour period. The kiln 

typically continues in operation while the raw mill is off, utilizing kiln feed stored in the silos. 

4.1.3 Fuel Systems 

The plant has the capability to use coal, natural gas, used oil, and tire-derived fuel (TDF) to 

provide the energy required for the processing of the kiln feed in the pyroprocess. Fuels are 

delivered to the multichannel burner pipe in the kiln, to the in-line calciner, and to the separateline calciner (SLC). During the time that this test was performed, coal and TDF were the only 

fuels combusted. 

4.1.4 The Pyroprocess 

The heart of the plant is a pyroprocess with a kiln and two preheater/precalciner strings; 

one string is referred to as the in-line calciner (ILC) string and the other as the SLC string. In this 

system, combustion offgases from the kiln and dual-string preheater are utilized for drying and 

separation of fine raw material in the in-line raw mill. Within the precalciner system, cool raw 

materials entering the top stages of the preheater tower mix with hot combustion gases from the 

kiln and calciners. The resulting heat transfer increases the temperature of the raw meal as it 

proceeds down the preheater tower. When the raw meal temperature reaches approximately 

1650°F, calcination begins liberating carbon dioxide (CO,_) from limestone (calcium carbonate 

[CaCO3]), resulting in the formation of lime (CaO), which reacts with alumina, silica, and iron in 

the kiln to make clinker. Clinker nodules are gray pea- to walnut-sized nodules that contain the 

minerals that, when ground with gypsum, other additives, and reacted with water, give concrete 

its strength. The design of the preheater/precalciner system results in highly calcined material 

reaching the rotary kiln; thus the kiln length is shortened (versus a conventional dry process 
kiln), and less residence time is needed for clinkering. Consequently, preheater/precalciner kilns 

are shorter and more fuel-efficient than conventional wet and long-dry process kilns. 

4.1.5 Cement Mill 

The facility operates two cement mill systems that grind the clinker with gypsum and other 

additives to a fine powder to produce the various types of cement. 

4.1.6 Cement Storage and Shipping 

Finished cement is stored in silos or a dome prior to being loaded into tracks or railcars for 

distribution. 

4.1.7 Description of the Main Air Pollution Control Device 

The exhaust gases from the pyroprocess and in-line raw mill pass through a conditioning 

tower and baghouse system that control emissions of particulate matter. The baghouse is a 

reverse-air design. This design isolates one compartment of bag filters from the gas stream and 

utilizes process gases to dislodge collected particulate matter from the interior of the filter media. 

The particulate matter loosened from the bags falls into collection hoppers, and screw conveyors 

remove the material for recycling to the process via the kiln feed silos. 

The dedusted gases are discharged to the atmosphere through the plant's main stack. The 

stack height is 295 feet. Test ports are available in. the main stack at a height of approximately 

230 feet. 

4.2 Description of the EERC Slipstream Baghouse 

Shown in Figure 2 is the EERC's trailer-mounted baghouse that was transported to the 

Durkee cement facility and connected in a slipstream fashion to enable the testing on "real" flue 

gases under actual operating conditions. The slipstream baghouse (SSBH) chamber 

accommodates twelve 6-inch FFs, with bag lengths up to 12 feet. This equates to approximately 

226 ft 2 of filtration area. To connect the SSBH to the flue gas of the plant, two separate 10-inch 

flanges were required: one at the exit of the cement facility's FF and the other downstream of 

this location. The plant provided these connections. 
• gn•a-"ouse 

Exit Duct 

EERC BP30305. CDR 

Stack 

•SBH 

Figure 2. SSBH, trailer, and control room. 

A variable-speed fan is used to draw between 450 and 2700 actual cubic foot per minute 

(acfm) of flue gas (•300°F) through the slipstream device to vary FF face velocity between 2 and 

12 ft/min. The fan speed is controlled at a rate sufficient to draw gases at or near the maximum 

system flow of 2700 acfm for all test conditions. In comparison to the full-scale unit, the SSBH 

would be treating only approximately 1.0%-1.1% of the total facility's flue gas. An 8-inch 

baghouse bypass line was utilized as a flow control mechanism. Flow control was provided by an 

orifice meter on the baghouse effluent stream, with a flow control valve inserted in the 8-inch 

bypass line. Utilization of the bypass line enabled a constant draw of flue gas and isokinetic flow 

at the inlet nozzle for all test conditions. In addition, pipe velocities were maintained near 

75 ft/sec for all test conditions, preventing dropout of particulate matter. The baghouse chamber 

utilized between one and three inlet ports (5-inch diameter), depending on test conditions. Gases 

were drawn from an 8-inch header at the baghouse inlet. The baghouse chamber and inlet piping 

were insulated, with heat-traced lines used to maintain temperatures above a specified minimum, 

assumed to be 280°F. 

The following was provided for testing purposes: 

Access to the Durkee cement facility 

Assistance and cooperation from plant personnel during planning and while on-site 

Assistance from plant personnel to adjust valve positions, if required, and change out 

SSBH catch collection barrels between tests 

8 
site location with level grade to place trailer and mobile unit 

A 10-inch duct connected after the facility's baghouse (SSBH inlet) 

A 10-inch return duct connected at the base of the stack (SSBH outlet) 

An adequate source of low-voltage (480-V) 3-phase electricity (=60 amp) 

Approximately 120 amp of 3-phase (120-V) electricity 

An adequate source of compressed air (3/8- to l/2-inch line) 

Approximately week was used to install and shake down the slipstream equipment before 

testing was initiated. Several operating parameters, such as gas flow, air to cloth (A/C) ratio, 

injection rate, etc., were varied during shakedown testing. 

4.3 Mercury Monitoring 

4.3.1 Main Stack Mercury Monitor 

Mercury monitoring was performed at the main stack using a Tekran Model 3300 atomic 

fluorescence-based Hg vapor analyzer. The mercury monitor (MM) was used in conjunction with 

a Tekran dry pretreatment/conversion unit to rapidly monitor Hg ° and Hgtota• concentrations. 

Samples of flue gas were extracted from the main stack and drawn through an inertial gas 

separation (IGS) filter to remove particulate matter. The IGS filter consists of a heated stainless 

steel tube lined with sintered material. 

The Tekran instrument, which was located 230 feet above ground along the main kiln 

stack, traps the Hg vapor from the conditioned sample onto a cartridge containing an ultrapure 

gold sorbent. The amalgamated Hg is then thermally desorbed and detected using atomic 

fluorescence spectrometry. A dual-cartridge design enables alternate sampling and desorption, 

resulting in a nearly continuous measurement of the sample stream. An automatic Hg ° 

permeation source was used to calibrate the instrument daily. Manual Hg ° injection calibration 

on both cartridges was also performed for verification. The Tekran instrument measures either 

Hgtotal or Hg °, with an analysis occurring approximately every 2.5 minutes. To prevent the 

saturation of the unit's conditioner, the flue gas stream was diluted at a ratio of 180:1. At this 

dilution rate, the system could measure concentrations exceeding 20,000 btg/m 3. 

4.3.2 Slipstream Fabric Filter Baghouse Mercury Monitor 

Mercury measurements were made at the slipstream FF baghouse inlet and outlet using a 

Horiba/Nippon Instruments Corporation DM-6B. The DM-6B uses dual individual channel 

atomic absorption spectroscopy to measure Hg ° and Hgto•at concurrently every 10 seconds. The 

DM-6B uses a dry thermal catalytic pretreatment/conversion system to transform all Hg 

compounds to Hg ° for analysis so that Hgtotal concentrations can be determined. A dilution 

system was also utilized with the Horiba to prevent saturation. A dilution ratio of 10:I allowed 
this system to measure concentrations above 10,000 btg/m 3. The Horiba MM is not considered to 

be a robust system but is a very good research tool. Figure 3 is a schematic showing the 

connection of the Horiba system to the SSBH. 

ILl" 

Main 8aghouse 

Carbnn Baghouse 

Irlent'°n Height 26' 

Locatior 

Inlet Samplin• 

2750 acfm 

EERC Mobile Slipstream Baghouse 

Ptpe 

Trailer Footpnnt 48' 22" 

iVlair• Slack 

Figure 3. Schematic of the SSBH showing the locations of MM sampling and carbon injection. 

4.4 OH Method Flue Gas Mercury Measurements 

For verifying the MM measurements in the flue gas, ASTM International (ASTM) Method 

D6784-02 (Standard Test Method for Elemental, Oxidized, Particle-Bound, and Total Mercury in 

Flue Gas Generated from Coal-Fired Stationary Sources Ontario Hydro Method) was used. OH 

method samples were withdrawn from the flue gas stream isokinetically through a probe/filter 

system, maintained at 120°C or the flue gas temperature, whichever was greater, followed by a 

series of impinger solutions in an ice bath. Particle-bound Hg, Hgp, was collected on a quartz 

2+ filter in the front half of the sampling train. Hg was collected in impingers containing a chilled 

aqueous potassium chloride solution. Hg ° 

was collected in subsequent impingers (an impinger 

containing a chilled aqueous acidic solution of hydrogen peroxide and three impingers 

containing chilled aqueous acidic solutions of potassium permanganate). Samples were 

recovered and analyzed on-site by cold-vapor atomic absorption spectroscopy (CVAAS) using a 

CETAC M6000A automated Hg analyzer. The OH method samples were typically prepared and 

analyzed the same day of collection or the following day. 

10 
4.5 Carbon Trap (EPA Method 30B) Mercury Measurements 

In addition to using the OH reference method, the U.S. Environmental Protection Agency's 

(EPA's) draft reference Method 30B (Determination of Total Vapor-Phase Mercury Emissions 

from Coal-Fired Combustion Sources Using Carbon Sorbent Traps) was used. Proposed Method 

30B is a procedure for measuring Hgtota• emissions from coal-fired combustion sources using 

sorbent sampling and an extractive or thermal analytical technique. The method is intended for 

flue gases that are not particulate-laden (e.g., sampling downstream from particulate control 

devices). 

4.6 Powdered Activated Carbons 

The sorbents used for this project were PACs obtained from vendors that had a product on 

the market readily available for use. Many experimental carbons do exist but were not 

considered for this project because they are not widely available commercially. The selected 

activated carbons were NORIT DARCO Hg and NORIT e-1 I. The selected treated activated 

carbons were NORIT DARCO Hg LH and Envergex e-Sorb e-11. NORIT DARCO Hg is a 

multipurpose activated carbon created from lignite coal. The NORIT e-11 is a coarser version of 

the DARCO product line. A coarser carbon was selected to determine if any significant 

differences, such as bag blinding, could be found with the SSBH operation with this product over 

the more generic DARCO Hg. The treated carbons were both treated with a proprietary process, 

adding the benefit of increased reaction with the material with the gas stream through 

halogenation. The carbons chosen represent the available carbons on the market today. Different 

carbon vendors do exist, but their products fall under the carbon types tested (halogen-treated 

and untreated). Table contains information about each carbon chosen for evaluation in this 

study, including a brief description of the carbon material. 

Table 1. Brief Description of the Carbons Tested During Parametric Testing 

Through the SSBH 

Carbon Name Manufacturer Availability Description 

DARCO Hg 

DARCO Hg eDARCO Hg LH 

Envergex e-Sorb 

e-ll 

NORIT Americas 

NORIT Americas 

NORIT Americas 

Envergex 

Commercially 

available 

Commercially 

available 

Commercially 

available 

Readily available 

Lignite coal-based 

Lignite coal-based, larger 

particle size than DARCO Hg 

Lignite coal-based, halogentreated 

Proprietary treated carbon 

4.7 Stack RATA Testing 

A relative accuracy test audit (RATA) was conducted at the conclusion of sorbent testing 

to aid in the identification of the challenges that would be encountered in certifying a MM for 

regulatory purposes. Dates of testing are listed in Appendix C. Sampling at the stack with 
15 paired OH method trains was conducted over a 4-day period for the RATA. Analyses of the 

OH method trains were performed on-site immediately after being sampled. The results of the 

paired OH method samples were then compared to the averaged stack MM data from the same 

time period. A traverse was not conducted before OH method sampling began. Examination of 

previous testing performed at the facility's stack did not indicate that stratification of gas flow or 

stratification of Hg was occurring. 4 

4.8 Fixed-Bed Testing 

The EERC built a small fixed-bed apparatus with the capability to provide a slipstream of 

flue gas to a fixed-bed contactor to investigate this technology for applicability to this system as 

a Hg reduction strategy. The intent was to determine the life of a typical granular activated 

carbon when exposed to the Durkee process gas. Several attempts were made at running the 

apparatus. Because of the low flow rate and limited time line of the project, the apparatus failed 

to achieve normal baseline conditions (no carbon in the bed) because the metal in the system was 

absorbing Hg. Therefore, no results were obtained, and the carbon life was not determined. 

5.0 RESULTS AND DISCUSSION 

5.1 Slipstream Baghouse Operation 

Mercury control testing occurred across the SSBH over a 4-week period. During this time, 

the EERC evaluated several parameters, including bag type, A/C ratio, activated carbon type, 

activated carbon injection rate, and baghouse operation. The first week of testing involved a 

setup and shakedown period of the SSBH; during this time, baseline data were gathered to 

evaluate the normal Hg concentrations through the baghouse with a standard polyphenylene 

sulfide (PPS) bag. Testing then continued with the evaluation of several carbon types, which 

included treated and untreated carbons. 

After results from parametric testing with the four sorbents, identified in Table 1, were 

evaluated, comparative results were analyzed to determine the best-performing carbon, which 

was then used to conduct the remaining tests. This was done to control the number of variables in 

the system when other parameters such as differential pressure, bag type, and A/C ratio were 

evaluated. The remaining baghouse testing involved the evaluation of two other bag types, 

membrane and membrane/fiberglass, with varying injection rates and A/C ratios. Pressure 

change values were used in determining the baghouse operability and bag type performance. 

During the injection of PAC, the differential pressure was measured to determine if bag 

blinding was a concern. After several injection periods, it was determined that the differential 

pressure was not an issue for this test. The highest differential pressure that occurred during 

testing with the PPS bags was l. 11 inches of water during the highest injection rate of Envergex 

e-11. During injection into the membrane bags, the highest differential pressure was 0.04 inches 

of water. This is a very low differential pressure, but during the use of the membrane bags, smalf 

Cobb. G. Me*c',_Hv E••i,ssie)•zs Te•t Rep()t-t: Prepared •or Ash Glt•e Cement C(•mpan? Dec 5 through 8, 2006, 

_\irSource Technologies. Inc., Sha•nee, KS, 2(•06: p (•. 

2 
quantities of fine carbon were determined to have bled through the bags. The highest differential 

pressures for the membrane/fiberglass bags was 2.42 inches of water. Appendix C contains the 

differential pressure data in table form for all injection periods. 

5.2 SSBH Baseline Testing 

Two days of baseline testing occurred on April 16 and 17, 2007. During these 2 days, 

baseline data were gathered that demonstrated the two main operating cycles: raw mill on and 

raw mill off. The primary goal of collecting baseline data was to demonstrate the typical Hg 

concentrations throughout the SSBH system. 

5.2.1 Raw-Mill-On Baseline Period 

Baseline results during the raw-mill-on period were variable, with an •.verage daily Hg 

concentration at the inlet of the SSBH equal to 485 _+ 64 btg/Nm 3 and at the outlet equal to 461 _+ 

79 btg/Nm 3 to one standard deviation. Since it was not expected that the SSBH would remove Hg 

without the aid of a Hg control technology (such as the injection of PAC into the system), the Hg 

removal efficiency during baseline conditions (the native capture) was expected to be zero. This 

means that the average Hg concentrations during a baseline period should be the same at the inlet 

and outlet locations of the SSBH. Based on the experience of EERC and the statistical evaluation 

presented in Appendix G, it can be said that the native capture is, in fact, zero and the Hg 

concentration at the inlet and the exit of the SSBH during the baseline raw-mill-on period are 

essentially the same. 

To compare methods, modified carbon traps and OH method sampling were used in 

conjunction with the Horiba MM located at the inlet and outlet of the SSBH. These methods 

were performed as a set, with each method being performed at both the inlet and outlet side of 

the SSBH. 

In order to allow a comparison between data collected by the Horiba MM, carbon traps, 

and OH method testing, all three methods were employed during this baseline period. The 

Horiba MM was collecting and analyzing samples from the inlet and outlet of the SSBH. For 

approximately 15 minutes, data were simultaneously collected at the inlet and the outlet via 

carbon traps. The difference between the carbon trap inlet and carbon trap outlet data is 12.2%, 

indicating good correlation. Inlet MM data correlated very closely with inlet carbon trap data. 

Outlet MM data differed by 21.8% from outlet carbon trap data with the carbon trap appearing to 

be biased high. For approximately 30 minutes, data were simultaneously collected at the inlet 

and the outlet via the OH method. The difference between the OH method inlet and the OH 

method outlet data is 29.0%. The inlet OH method results indicate a percent difference of 28.6% 

from the MM average at the inlet. This suggests that there may have been an error with the inlet 

OH method test as the inlet MM data correlates well with the outlet MM data as well as the 

outlet OH method data. The outlet MM monitor data correlated well with the outlet OH method 

data. Table 2 shows the results from this testing. Figure 4 shows the real-time Hg monitor data 

compared to carbon trap and OH method results. 

13 
Table 2. Results from Carbon Trap and OH Method Testing During Raw-Mill-On Baseline 

Testing 

Test Method Test Method 

Test Inlet MM Hg Hg Inlet Outlet MM Hg Hg Outlet MM 

Method Concentration Concentration Difference Concentration Concentration Difference Difference 

,tt g/N m3 % bt g/N m3 % % 

Carbon 

Trap 422 423 0.2% 384 478 21.8% 9.4% 

Ontario 

Hydro 512 384 28.6% 442 514 15.1% 14.7% 

!4 
1000 

900- 

8oo 

700 

600 

5OO 

4O0 

300 

2OO 

tO0 

0 

1000 

900 

800 

700 

600 

500 

400 

300 

200 

100 

0 

600 1 

500 1 

400 

300 

200 

100 

SSBH Inlet MM 

SSBH Outlet MM 

!•SSBH Inlet Carbon Trap 

•SSBH Outlet Carbon Trap 

•SSBH Inlet OH 

I•SSBH Outlet OH 

'4/16/07 (1'0:30 24:00) 

SSBH Inlet MM 

SSBH Outlet MM 

I-I•SSBH Inlet Carbon Trap 

•SSBH Outlet Carbon Trap 

•-,,-SSBH Inlet OH 

•SSBH Outlet OH 

0 I) 4/16/07 (14:00 17:0 

Figure 4. Raw-mill-on baseline results comparing MM, carbon traps, and OH method. 

15 
5.2.2 Raw-Mill-Off Baseline Period 

On the second day of baseline testing, the cement facility's in-line raw mill was shut off 

for planned routine maintenance. During this period, measurements of typical raw-mill-off Hg 

concentrations were obtained through the SSBH. The results of this testing indicated an initial 

spike in the Hg concentration for a brief period of time followed by a period of Hg 

concentrations at a somewhat steady state condition. This level of Hg concentration slowly 

decreased throughout the testing period. The spike observed during this raw-mill-off condition 

reached Hg concentrations close to 5000 btg/Nm 3 for a short period of time before stabilizing to a 

concentration of approximately 2700 ,ug/Nm 3. The baseline Hg concentration at the inlet of the 

SSBH before the raw mill was shut off was 484 95 gg/Nm •, and the Hg concentration at the 

outlet of the SSBH before the raw mill was shut off was 505 +_ 94 ,u,g/Nm 3. The average rawmill-off baseline Hg concentrations for the inlet and outlet of the SSBH were 2570 _+ 

260 #,g/Nm 3 and 2980 _+ 483 btg/Nm 3, respectively. This yields a 14.8% difference between the 

inlet and outlet MM. Again, based on the statistical analysis of the native capture results and the 

experience of the EERC, we assume that these are essentially the same, indicating a zero native 

capture. 

During the raw-mill-off baseline testing, carbon traps were used and compared with the 

MM. Three carbon trap tests were performed: two at the inlet and one at the outlet of the 

baghouse. The results of carbon trap testing for the first set of traps indicate a percent difference 

of 12.4% between the carbon trap and MM data at the inlet of the SSBH and an 11.0% difference 

between carbon trap and MM data at the outlet of the SSBH. The difference between the inlet 

and outlet Hg concentrations measured by the MM at the SSBH during this set of traps indicated 

34.8%, and because of this, a second carbon trap test was performed at the SSBH inlet. The 

results of this test yielded a percent difference of 17.9% from the SSBH inlet MM to the inlet 

carbon trap, these results can be seen in Table 3. During this second test, the SSBH inlet MM 

agreed with the outlet MM with a percent difference of 8.6%. These results can also be seen in 

Figure 5. 
cco 

tO 

to 

5500 

5000 

4500 

4000 

3500 

3000 

2500 

2000 

1500 

1000 

500 

0 

5500- 

5000 2 

4500 2 

40001 

35001 

30002 

25001 

20002 

15001 

10001 

5002 

5508- 

5000 

4500 

4000 

3500 

3000 

2500 

2000 

1500 

1000 

500 

0 

EERC J•30457 CDR 

SSBH Inlet MM 

SSBH Outlet MM 

:::-.• SSBH Inlet Carbon Trap1 

• SSBH Outlet Carbon Trap 

• SSBH Inlet Carbon Trap 2 

4/17/2007 Time (0:00-24:00) 

SSBH Inlet MM 

SSBH Outlet MM 

z:7:= SSBH Inlet Carbon Trap1 

• SSBH Outlet Carbon Trap 

• SSBH Inlet Carbon Trap 2 

4/17/2007 Time (6:00-8:30) 

Figure 5. Raw-mill-off baseline results comparing the MM to the carbon trap results. 

17 
Table 3. Results of Carbon Trap Testing During Raw-MilioOff Baseline Testing 

Test Method Outlet MM Test Method 

Test Inlet MM Hg Hg Inlet Hg Hg Outlet 

Method Concentration Concentration Difference Concentration Concentration Difference 

MM 

Difference 

,tt g/N m' % ,u g/N m• % % 

Carbon 

Trap 2439 2762 12.4% 3468 3106 11.0% 34.8% 

Carbon 

Trap 3031 2533 17.9% 3302 8.6% 

5.3 Parametric Testing 

Four parameters were tested during the pilot test: PAC type, PAC injection rate, bag type 

and A/C ratio. Each of these parameters were evaluated during periods where the raw mill was 

operating so as to maintain comparable results. This parametric testing resulted in 

recommendations for use in designing the full-scale Hg control system. 

Parametric testing began on April 18, 2007, with the evaluation of PAC type. DARCO Hg 

was the first PAC to be tested. Because of the Hg concentrations observed in the system, three 

injection rates (1, 3, and 5 lb/Macf) were chosen for evaluation. Before carbon injection began, 

the Hg concentration at the inlet of the SSBH was 594 _+ 70 gg/Nm 3, and the Hg concentration at 

the outlet of the SSBH was 629 _+ 76 btg/Nm 3. The PAC injection began with a feed rate of 

lb/Macf. When the feeder was turned on, the Hg concentration at the outlet of the SSBH 

trended downward quickly. After a couple of hours of injection, the outlet Hg concentration 

reached a steady state, or a period of time where the data appear to have leveled off during the 

injection testing, with an average calculated to be 136 _+ 45 btg/Nm •, a 73.4% reduction in Hg. 

This average is based on the data that correspond to the time when the system reached a steady 

state, as defined above, during injection. The percent removal is based on the calculated average 

Hg concentration from the inlet MM compared to the calculated average Hg concentration from 

the outlet MM during the steady state condition. 

Results of this injection test can be seen in Figure 6. Several blanks in the data are 

observed during PAC injection and SSBH recovery. These blanks correspond to times when MM 

maintenance (e.g., filter changes) was occurring. When injection stopped, the SSBH was cleaned 

and allowed to return to baseline conditions before further testing was initiated. The SSBH 

t8 
3500-. 

3000- 

2500- 

2000- 

1500 

1000 

500 

1400 

1200. 

1000. 

900 

8oo700. 

600. 

500 

400 

3oo • 

2oot 

8O0 

600 4 

5oo400 

300 

200- 

O0 

EERC JK30458 CDR 

Inlet MM 

o OutletMM 

Injection Period 

(1 Ib/Macf) 

/ Injection Period \' _/ (DARCO Hg- I•/•c0 

,I / • •ag.o•se•olsin• \ 

Expanded Injection Period, 4/18/2007 (8:00-16:00) 

512 +_ 85 73.4 % Removal 

136 + 45 

Inlet MM Outlet MM Percent 

Removal 

100 

90 

80 

70 •E 

60 

50 o 

E 

40 

30 

20 P 

10 :• 

0 

Figure 6. PAC injection results for the injection of DARCO Hg at lb/Macf. 

tg 
recovery took longer than expected based on what is typically seen in a coal-fired utility system. 

This was, in part, due to the relatively clean (particulate-free) gas stream seen in the cement 

facility versus a coal-fired power plant system. It was observed that after the SSBH went through 

a system-pulsing sequence for bag cleaning, the Hg concentration in the SSBH outlet gas 

dropped slightly. One possible reason this occurred is that the pulse air created a situation where 

mixing occurred in the system, exposing fresh carbon surface sites for the Hg to be adsorbed. 

The additional two rates, 3 and 5 lb/Macf, for the DARCO Hg PAC were tested on the 

second day (April 19, 2007) of PAC injection testing. Results showed similar trends noted at an 

injection rate of lb/Macf in that, upon the start of PAC injection, the Hg concentrations 

decreased steadily until a steady state was reached. When the PAC injection was increased from 

3 to 5 lb/Macf, the Hg levels actually increased slightly, but during this period, so did the inlet 

Hg concentrations. As a method for comparison, a Hg removal efficiency is calculated based on 

the inlet and outlet Hg concentrations measured at the time of injection. For the two rates tested 

on this day, the Hg removal efficiencies were 92.4% and 91.9% for 3 and 5 [b/MacE 

respectively. It appears that no additional benefit is gained by increasing the PAC injection 

above 3 lb/Macf. The results from testing the additional two rates for DARCO Hg can be seen in 

Figure 7. 

20 
o 

EERC JK30459 CDR 

Started Injection • Inlet MM 3 Ib/Macf • Outlet MM 

Increased Injection 

to 5 Ib/Macf 

• •letMMM•iecti°n Te•'•°d' 4/19/2007 (10:40-15:01 

Ib/Macf 

800 

700: 

600: 

500: 

400- 

300- 

200- 

lOOo8O0 

700 

600 

50O 

400 

3OO 

2O0 

•00 

0 

400- 

300- 

200- 

100- 

0- 

Expanded View 4/19/2007 (12:40-15:00) 

• DARCO Hg @ 3 Ib/Macf DARCO Hg @ 5 Ib/Macf 

•_ 553 _+ 37 

--• 499 ÷ 29 

• 

° 

O .•- 

38el 45e10 

120 

110 

100 •, 

o 

90 c80 ._o 

70 ILl 

0 

50 E 

40 

r• 

30 • 

20 • 

I0 

0 

Figure 7. PAC injection results for DARCO Hg for the injection of 3 and 5 lb/Macf. 

21 
The remaining PAC injection testing occurred in the same manner as it did l-or the DARCO 

Hg injection testing. When testing for all PAC types and injection rates was complete, a Hg 

removal efficiency curve was generated in order to create a means of comparison among the 

other carbon types. The Hg removal efficiency curves for all PACs tested are compared in 

Figure 8. The results indicate that each carbon tested performs differently in the SSBH system, 

with the untreated carbons performing better than the treated carbons. 

100 

9O 

>:, 80 

• 7O 

I.U 60 

4o 

• 

2O 

10 

0 

EERC JK30455. CDR 

DARCO Hg 

0 2 3 4 5 6 

PAC Injection Rate, Ib/Macf 

Figure 8. PAC parametric testing results performed at an A/C ratio of 4 with standard PPS bags. 

One possible explanation for the untreated carbon (DARCO Hg) performing better at this 

site takes into consideration the carbon's adsorption capacity and system reaction time. Treated 

carbons (DARCO Hg LH and Envergex) have been shown to perform better than untreated 

carbons in coal-fired boilers, especially when reaction times are short (electrostatic precipitator 

[ESP] systems). Thus the halogens used to treat the carbon act like a catalyst, oxidizing the Hg in 

the system and allowing for faster adsorption onto the carbon. This is critical in systems with 

higher SO,. concentrations, because SO• species have been shown to compete for active sites on 

the carbon surface; therefore, the halogens on the treated carbon allow the oxidized Hg to bind to 

the carbon surface before the SO• species consume the active sites. 

At the Durkee facility, in the SSBH, the SO,, concentrations are very low compared to a 

coal-fired utility system. The high calcium concentration in the cement manufacturing 

pyroprocess enables the removal of SOt species from the gas phase by forming calcium sultate. 

In cases such as this, the halogens may still increase reactivity, but one would expect a decrease 

in sorbent adsorption capacity as the halogens reduce the amount of active surface ,•rea available 

on the carbon surface. In addition, it is reasonable to assume that Hg ° would be physisorbed on 
the surface of the sorbent along with NO> which could facilitate oxidation of the Hg and 

subsequent chemisorption of the oxidized species and, therefore, removal in the baghouse. This 

is reflected in the trends shown in Figure 8. 

At low injection rates, the untreated carbon performed better because of its additional 

sorbent capacity. At the higher rate of 5 lb/Macf, the treated carbons appear to perform as well as 

the untreated carbons, possibly because the large amount of carbon injected into the system 

provided for ample active surface area, allowing the halogens to improve reactivity without 

jeopardizing active sites. However, injection of the treated carbons at 5 lb/Macf does not result in 

a significant difference in Hg control efficiency as compared to untreated carbon injected at 

3 lb/Macf. There is no reason to choose halogenated carbon over untreated carbon, particularly in 

light of potential concerns associated with the use and disposal of halogen-treated materials. 

A small carbon particle size was initially thought to be a concern because of the possibility 

of bag blinding. It was thought that the fine particle size and small particle distribution may blind 

the bags, causing a high pressure drop in the system. Because of this, a fourth carbon, DARCO 

Hg e-11, was tested that had larger particles and a larger particle-size distribution. The injection 

of DARCO Hg e-11 yielded a trend similar to the finer DARCO Hg, but the Hg removal results 

were lower by 10%-15%. This was most likely caused by the larger particle sizes not having as 

much exposed active surface area as the finer carbon. 

At the start of testing, a baseline A/C ratio of 4 was chosen because, at the time of the 

sorbent injection parametric testing, an optimal A/C ratio was unknown. Typically, in a coalfired utility that has carbon injection into a baghouse, the A/C ratio is chosen to be anywhere 

between 4 and 8. Because of the fine-particle baghouse-blinding concern, a lower A/C ratio of 4 

was chosen for the initial evaluation of sorbent effectiveness. Based on the evaluation of the 

results presented in Figure 8, the DARCO Hg carbon was chosen as the best-performing carbon 

tested which, in turn, was then used to evaluate the remaining parameters. 

Once the PAC-type parametric testing was complete, bag type and A/C ratio parametric 

testing began. The tests were conducted in a similar manner as the PAC-type evaluation testing. 

The results from testing the three different bag types suggest that at PAC injection rates of 

3 lb/Macf or higher the bag type does not play a role in Hg removal. Shown in Figure 9 is a 

comparison of the three bag types at an A/C ratio of 4. It can be seen that at 3 lb/Macf of PAC, 

all three bag types perform similarly with the largest percent difference being 10% when the PPS 

and membrane bags are compared. Based on the variability discussed previously between the 

inlet and the outlet MM measurements, it is likely that the bags are performing essentially the 

same at these conditions. A comparison showing the calculated percent differences of the three 

bag types can be seen in Table 4. Because of the nature of the process, operating temperatures in 

the bag filter area of the process can vary as much as 120°F and can exceed 400°F. Based on 

information provided by GE Energy, the membrane/fiberglass bags were the only bags tested 

that can withstand continuous operating temperatures above 400°F. This is a similar material to 

the bag material currently used in the facility's main APCD. Therefore, based on the results seen 

23 
110- 

lOO• 

90• 

8oZ 

7oZ 

6oZ 

E 5oZ 

r• 4o• 

"• 3o• 

¢) 20• 

o• 

EERC BP30311 COR 

Membrane 

PPS 

Membrane/Fiberglass 

0 2 3 4 5 

PAC Injection Rate, Ib/Macf 

Figure 9. Bag type comparison showing their effectiveness with regard to Hg removal 

efficiencies. 

in Table 4 and Figure 9, the membrane/fiberglass bags appear to be the preferred bag choice as 

they performed similarly to the other two bags and are the only bag type that is recommended for 

continuous operation when experiencing temperatures above 400°F. 

Table 4. Comparison of Bag Type Results 

Mercury Removal Efficiency, % 

Bag Type i lb/Macf 3 lb/Macf 5 lb/Macf 

PPS 73 93 92 

Membrane 46 84 98 

Percent Difference 45 % 10 % 6 % 

PPS 73 93 92 

Membrane + 

Fiberglass 62 86 100 

Percent Difference 16% 8% 8% 

Membrane 46 84 98 

Membrane + 

Fiberglass 62 86 100 

Percent Difference 30% 2% 2% 

In order to evaluate ,•C ratios, DARCO Hg was injected at the same three PAC injection 

rates {1, 3, and 5 lb/Macf) and at f'our A/C ratios (4, 6, 8, and I0). The results for the 

24 
membrane/fiberglass bags indicated that at the lowest injection rate, lb/Macf, the Hg removal 

efficiency increased with increasing A/C ratio. This could be caused by the greater flow rates 

causing more mixing in the system. These results can be seen in Figure 10. With this type of bag, 

it appears that A/C ratios above 6 have little effect on the Hg removal efficiency. Mercury 

110 

100 

2O 

I0 

0 

EERC BP303og. CDR 

[] 

0 2 4 6 8 10 

Air-to-Cloth Ratio 

Figure 10. Membrane/fiberglass bags parametric testing results showing effects of varying A/C 

ratio. Tests at 5 lb/Macf were not performed. 

removal efficiencies of approximately 90% were achieved at A/C ratios of 6, 8, and 10 with PAC 

injection rates of 3 and 5 lb/Macf. Figure 11 displays the results with respect to PAC injection 

rate versus Hg removal efficiency. The results indicate that injection rates higher than 3 lb/Macf 

give insignificant increases in Hg removal efficiencies at an A/C ratio of 6. Similarly, there is 

essentially no material difference in control efficiency achieved by increasing the PAC injection 

rate above 3 lb/Macf. Increased PAC injection rates raise concerns regarding greater solid waste 

generation rates, and so absent any material increase in control efficiency, there is no reason to 

operate at a higher PAC injection rate for a system designed for an A/C ratio of 6. 

25 
110- 

lOO . 

!90- 

8oZ 

70: 

602 

502 

4o: 

30: 

0 

EERC BP30310 CDR 

2 3 4 5 

PAC Injection Rate, Ib/Macf 

Figure 11. Membrane/fiberglass bag parametric testing results showing effects of varying PAC 

injection rate. 

During the testing of the membrane/fiberglass bags the injection of DARCO Hg was 

evaluated during a raw-mill-off operating period. This test was performed in order to evaluate 

the achievable Hg removal efficiency during an operation period when the Hg concentrations 

were elevated, typical of raw-mill-off conditions. Four PAC injection rates were evaluated: 1, 3, 

5, and 10 lb/Macf. The results indicated that only moderate Hg removals (approximately 52% 

and 58%, respectively) were achievable with injection rates of 3 and 5 lb/Macf. Because of this, 

the injection rate was increased to I0 lb/Macf to gain an understanding of the level of impact on 

Hg control efficiency. The results at the injection rate of 10 Ib/Macf yielded a Hg removal 

efficiency of 88%. Results for this testing are summarized in Figure 12. 

26 
0 0 EERC JK30449. CDR 

9O 

o• 80 

z0 

"• 60 

so 

a0 

20 

10 

Membrane/Fiberglass Bags 

/ •Raw Mill Off with 

0 2 4 6 8 10 

PAC Injection Rate, Ib/Macf 

Figure 12. Raw-mill-off injection testing with membrane/fiberglass bags at an A/C ratio of 8. 

Carbon injection at full scale prior to the main baghouse was conducted on three different 

days (April 26, May 3, and May 10) with the raw mill off, coinciding with planned routine 

maintenance. For purposes of this test the Darco Hg LH carbon was utilized. Injection rates 

were changed on each of the three days from 1, 3, and 5 lb/Macf. The effect of carbon injection 

was measured with the Tekran MM located at the main stack. The result of full-scale carbon 

injection is shown in Figure 13. A more significant reduction is seen with 5 versus 3 lb/Macf due 

to the high Hg emission levels during raw-mill-off conditions as compared to the raw-mill-on 

conditions during the other parametric testing. The difference is significant enough to suggest the 

higher injection rate during this condition. The level of Hg reduction measured was very similar 

with that of testing conducted on the SSBH during raw-mill-off conditions. Using the average 

value between the full-scale and SSBH injection tests at a rate of 5 lbfMacf yields an 

approximation of the Hg removal during raw mill off of 63%. 

27 
O0 EERC JK30456 CDR 

9O 

• 80 

•) 7O 

6o 

4o 

• 30 

• 20 

]0 

• Full-Scale Raw-Mill-Off 

Injection of DARCO Hg LH 

0 2 3 4 5 

PAC Injection Rate, Ib/Macf 

Figure 13. Full-scale carbon injection results. 

Based on the parametric testing, the EERC recommends that a full-scale 

installation should be designed based on the following parameters: 

Parameter 

PAC Type 

Design Criteria 

Untreated carbon 

Comments 

Untreated PAC performs 

comparably to halogentreated PAC, while avoiding 

potential environmental 

issues associated with use of 

halogens. 

Bag Type Fiberglass with 

membrane 

All bags performed 

comparably, but fiberglass 

with membrane withstands 

higher temperatures. 

A/C Ratio 6to8 Lower A/C ratios resulted in 

lower control efficiency. 

Increasing A/C ratio over 

this range results in higher 

energy consumption without 

increased control efficiency. 

Hg control 

28 
Injection Rate 3 lb/Macf (raw mill 

on) 

5 lb/Macf (raw mill 

off) 

Elevated PAC injection rate 

during raw-mill-off 

conditions may not be 

necessary after first hour. 

Based on the pilot-scale testing, there is a reasonable likelihood that a full-scale installation 

designed using these parameters would be expected to perform as follows: 

• Approximately 90% Hg control during raw-mill-on conditions (annual average). 

• Approximately 60% Hg control during raw-mill-off conditions (annual average). 

• A weighted average of approximately 77% control (annual average). 

Calculations used to determine the above parameters can be found in Appendix H. 

5.4 Stack Hg Measurement 

A Tekran Model 3300 MM was installed in the main stack to measure Hg ° and Hgto,al- This 

was done with the intention of determining the potential for future use as a continuous 

monitoring device rather than determining the ability to certify the instrument for compliance 

purposes. The MM located in the stack began logging data on April 13, 2007. The instrument 

logged data 24 hours a day until May 13. One technician was dedicated to monitor the operation 

of the instrument each day. The typical day ran from 6:30 a.m. to the end of scheduled testing, 

which varied from 4:00 p.m. to 6:00 p.m. Each day the zero and span of the analyzer was 

checked along with the gas dilution factor. All connections, umbilical temperature, system 

pressure, and gas flow rate were also checked. Daily spikes to the analyzer and also the probe 

were conducted using a calibration source. The previous night's data were also reviewed daily 

for any indications of machine malfunction. 

The mechanical operation of the analyzer allows for a single data point to be logged 

approximately every 2.5 minutes. The theoretical number of data points that could be logged in a 

day would be 576. While calibration, zero and span checks, and spiking are being performed, the 

measurement of the gas stream is interrupted; thus the theoretical maximum was never reached. 

On average, 505 _+ 24 data points at one standard deviation were logged per day, which is 88% of 

theoretical maximum. 

During April 15 through 17, a daily OH method test and a draft method carbon trap were 

conducted to verify that the MM was measuring Hg levels accurately. A graphical example of 

the correlation for April 15 is shown in Figure 14. Sampling occurred during raw-mill-on 

conditions. A numerical comparison for all 3 days is shown in Table 5. The correlation was 

29 
5O0 

450 

400 

350 

300 

250 

200 

150 

100 

5O 

0 

4/15 4/15 4/15 4/15 4/15 4/15 4/15 4/15 

4:00 6:00 8:00 10:00 12:00 14:00 16:00 18:00 

Date/Time 

Figure 14. Graphical comparison of MM, carbon trap, and OH method for April 15, 2007. 

Table 5. Comparison of Sampling Methods Showing Difference of MM with Carbon 

Trap and OH Method 

Date 

Carbon 

MM, Trap, 

gg/Nm 3 ,ttg/Nm 3 

MM to MM to OH Trap to OH 

Carbon Trap Method Method 

Absolute OH Absolute Absolute 

Difference, Method, Difference, Difference, 

% •g/m 3 % % 

April 15 279 299 6.9 306 9.2 2.3 

April 16 374 388 3.7 329 12.8 16.5 

April 17 2046 2039 0.3 2460 18.4 18.7 

sufficient enough to allow the use of modified carbon traps as a check for the stack Hg 

monitoring. The modified carbon trap results are shown in Table 6. Appendix E contains daily 

plots of the MM data. 

30 
Table 6. Stack Emission Carbon Trap Data 

Carbon Trap, 

Sample Date MM, •ttg/Nm 3 •tg/Nm 3 

Absolute 

Difference, % 

4/l 5/07 279 299 6.9 

4/16/07 374 388 3.7 

4/17/07 2046 2039 0.3 

4/19/07 527 514 2.5 

4/20/07 443 375 16.6 

4/22/07 37 381 2.7 

4/23/07 363 364 0.3 

4/24/07 480 528 9.5 

4/25/07 435 446 2.5 

4/26/07 1375 1607 15.6 

4/27/07 227 205 10.2 

4/28/07 411 344 17.7 

4/29/07 345 395 13.5 

4/30/07 459 416 9.8 

5/1/07 691 626 9.9 

5/1/07 611 533 13.6 

5/2/07 527 505 4.3 

5/3/07 2570 2458 4.5 

5/4/07 373 403 7.7 

5/4/07 393 380 3.4 

5/5/07 227 253 10.8 

5/5/07 332 371 11.1 

5/6/07 277 304 9.3 

5/11/2007 154 148 4.0 

5/11/2007 124 112 10.2 

3! 
Mercury concentration at the stack was observed to be variable on a daily, even an hourly, 

basis. Figure 15 shows graphs for the Hg•o•a• and Hg ° stack output for April 23 and May 1. The 

1000 

EERC BP30308 CDR 

800 

600 

400 

200 

Total Hg 

Elemental Hg 

2:00 4:00 6:00 8:00 10:00 12:00 14:00 16:00 18:00 20:00 22:00 

April 23, 2007 

1000" 

0:00 

0 800 

600 

400 

200 

0 

0:00 2:00 4:00 6:00 8:00 10:00 12:00 14:00 16:00 18:00 20:00 22:00 0:00 

May 1,2007 

Figure 15. Comparison MM graphs for April 23 and May showing the variability of Hgtotal and 

Hg ° output. 

variability between these 2 days is high. Also of note is that the ratio of Hg ° to Hgtotal is highly 

variable as welt. The analysis of process data collected on these 2 days shows the pyroprocess 

and raw grinding systems were operated under similar conditions. Table 7 illustrates the 

similarities. The data indicate kiln and raw mill feed rates and kiln fuel rates are similar. The 

daily average of critical temperatures in the system also shows that the temperature profile of the 

pyroprocess and raw milling system on each of the 2 days were similar. Stack conditions as well 

show that the gas flow, temperatures, and oxygen levels at that location were similar over the 

2 days. 
Table 7. Comparison of Process Data for April 23, 2007, and May 1, 2007 

April 23, 2007 May l, 2007 

Description Units Average Std. Dev. Average Std. Dev. 

Kiln Feed Rate Mtph 235 2.36 236 4.13 

Stack Gas Flow Rate Dry scfm 138,437 5812 144,595 78t5 

Stack O•_ % 6.5 0.72 6.6 0.70 

Stack Temperature °C 101 2.3 103 3.30 

Main FF Inlet Temp. °C 111 9.00 117 12.70 

ILC Stage 1E Exit Temp. °C 392 5.90 397 5.20 

ILC Stage 1W Exit Temp. °C 408 7.40 415 7.60 

SLC Stage Exit Temp. °C 339 3.50 338 5.40 

SLC Coal Feed Mtph 6.3 0.18 6.2 0.32 

Kiln Coal Feed Mtph 7.2 0.32 7 0.28 

TDF Feed Lb/hr 2000 NA 2000 Na 

Raw Mill Feed Mtph 200 NA 201 Na 

Raw Mill Exit Temp. °C 97 0.92 97 1.30 

Raw Mill Motor Power kWh 1007 41.30 989 46.60 

Figure 15 helps to explain the lack of comparability of previous OH method tests 

conducted for Ash Grove. It is clear to see that two sampling tests conducted on even the same 

day will most certainly not yield similar results. The variability of past OH method tests along 

with this day-to-day variability provides an approximation of the variability of the Hg in the 

limestone from the on-site mine and its impact on emissions. 

To further illustrate the variability, Figure 16 charts the overall average stack Hg output 

alongside the daily averages of some selected days for the period when the raw mill was on. 

Error bars display one standard deviation of the average value. The average raw-mill-on value 

was 408 +_ 118 •g/Nm 3 for Hgtotal and 215 _+ 113 gg/Nm 3 for Hg °. During raw-mill-off periods 

measured during the testing period, the average value was 2254 + 981 •ug/Nm 3 for Hgtota• and 

305 _+ 182 [tg/Nm • 

for Hg °. A weighted average combining the relative times of raw-mill-on 

with raw-mill-off periods yielded an average Hgtota• output of 685 + 408 •ug/Nm • 

and an average 

Hg ° output of 229 ___ 127 •tg/Nm •. The error for the weighted averages is calculated using a 

pooled standard deviation based on the combined data sets of raw mill on and raw mill off. 

Graphs of daily average Hg concentration at the main stack can be found in Appendix F. A 

statistical discussion of the variability is given in Appendix G. 
EERC BP30307. CDR 

8OO 

700 

600 

500 

400 

300 

200 

100 

0 

L• Hg 

[/Elemental Hg ] 

Overall 14-Apr 23-Apr 25-Apr -May 4-May 

Figure 16. Average Hg concentration during raw-mill-on conditions over the entire test period 

compared to various specific days. 

When the raw mill shuts off, the Hg emissions increase. Figure 17 shows the MM data 

during a typical raw-mill-off period. The increase is shown to affect the oxidized portion much 

more than the elemental portion. Oxidized Hg levels rose over 400%, whereas the elemental 

portion increased by roughly one-third. Reaction of the system to the mill outage was fairly 

quick, as the rise of Hg at the beginning of the outage and the reduction back to typical levels 

when the mill is turned back on occur within the span of approximately 30 minutes. The increase 

in emission during raw-mill-off conditions is discussed in detail in Section 2.3. 

34 
6000 

5OOO 

4000 

3000 

20O0 

1000 

0 

0:00 

Total Hg 

Elemental Hg 

4:00 8:00 12:00 16:00 20:00 0:00 4:00 8:00 12:00 16:00 20:00 0:00 

April 15 through 16 

Figure 17. Stack MM data of raw-mill-outage overnight April 15 through 16. 

5.5 Analytical Methods and Procedures Their Applicability at the Durkee Facility 

The temporary installation of the stack MM did not follow EPA Method PS-12a for several 

reasons. PS-12a is intended to assess the MM performance for minimum maintenance 

requirements for a permanent installation. This project was intended to attempt the measurement 

of the Hg levels at the Durkee facility under many conditions, with the expectation to evaluate 

the performance of sorbent additions and how they affect Hg reduction. To achieve this, the MM 

was scrutinized much more closely than would be desired or contemplated for routine 

measurement. 

Further, the method requires the use of National Institute of Standards and Technology 

(NIST)-traceable standards for both Hg ° and Hg +. An elemental source was used for calibration 

purposes. Oxidized sources are a new commodity, and the EERC does not yet have access to 

them. None of these is NIST-traceable. NIST-traceable standards for Hg simply do not yet exist. 

Parameters such as the maximum potential concentration and high span were not 

determined because of limited information about the nature of the Hg levels at this facility. 

Stratification was not checked but was deemed not necessary based on previous testing 

conducted at Durkee. Drift tests were not conducted because the systems were being evaluated 

daily by a technician. 

It is important to mention that the operation of the MM during this project was not simply 

plugging in the instrument and turning it on. The Hg levels encountered at this facility were 

much higher than intended for routine MMs. The sampled gas stream had to be diluted before the 

35 
instrument conducted its measurements to prevent saturation of the detection cells. Also, factors 

such as the difference of the Hg output between raw mill off and raw mill on, temperature 

changes in the room in which the instrument was housed, and inherent instrument drift required 

that a dedicated technician carefully check the instrument daily. 

The use of draft method carbon traps as a replacement for the modified OH method 

worked very well at this facility. Values obtained were comparable to the OH method and MM 

measurements. The benefits of this method are that the training and investment to use the needed 

equipment are small, and the method is easy to perform, making it inherently more reliable in a 

plant setting. Analyses of the samples can be completed in under an hour, so this method 

generates timely results. The exact length of time a trap can sample before being saturated has 

not been determined. However, carbon traps provide an excellent means of routinely checking 

Hg APCD performance. 

5.6 Main Stack RATA Testing 

The Tekran MM installed on the main stack did not pass a RATA. A summary of the 

results can be seen in Table 8. Only five of the 12 paired OH method samples were within the 

passing 20% difference limits. Three additional paired trains were conducted and passed within 

limits. Even with the additional three tests, the RATA failed, with only eight of the needed nine 

passing pairs. Agreement between the two OH method pairs was very good, but two of the pairs 

had to be thrown out because they differed by more than 10%. 

Table 8. RATA Test Results 

OH Method Probe OH Method OH MethodSide, Relative OH Method MM to-MM 

RATA btg/m 3 Difference, Value, Value, Difference, 

Run No. A B % gg/m 3 btg/m 3 % Pass/Fail 

5220 5397 1.7 4438 3673 18.9 Pass 

2 351 312 5.9 276 467 53.2 Fail 

3 410 395 1.9 337 516 42.0 Fail 

4 191 220 7.1 170 540 104.2 Fail 

5 379 349 4.1 305 324 6.0 Pass 

6 393 338 7.5 306 315 2.9 Pass 

7 474 408 7.5 369 328 11.8 Pass 

8 933 797 7.9 732 766 4.5 Pass 

9 6624 6519 0.8 5573 3318 50.7 Fail 

10 6499 9431 18.4 6762 3632 60.2 Fail 

11 6416 6805 2.9 5652 3775 39.8 Fail 

12 577 460 11.3 430 459 6.5 Fail 

13 449 390 7.0 349 366 4.8 Pass 

14 394 348 6.2 311 342 9.5 Pass 

15 359 335 3.5 294 286 2.8 Pass 

Noapproved method exists to perform a RATA for a MM operating at Hg levels above 

150 tt•/m 3. Concentrations during the testing were 2 to 45 times that level. When measuring at 

36 
these levels, both the MM analyzer and the reference method lab bench analyzer require that the 

sample undergo significant dilutions. This increases the opportunity for significant error. If a 

MM is ever intended to be permanently installed at the Durkee facility and be required to pass a 

RATA, then a procedure would need to be written. 

5.7 Fixed-Bed Testing 

The work at Durkee to evaluate the fixed-bed option for Hg control was not successful, as 

stated earlier in Section 4.8. 

The EERC is, however, involved in ongoing research evaluating fixed beds for use in 

removing Hg for process gas streams. The results to date indicate that it is possible to capture a 

high level of Hg while maintaining a low differential pressure through the fixed bed, but several 

parameters are unknown and are site-specific. The main unknown at this time is the carbon life. 

Several gas components can potentially lead to decreased carbon life and are currently being 

evaluated. The technology itself has not gone through the rigorous testing that PAC injection into 

APCDs has. As a result, EERC cannot recommend the technology at this time. 

6.0 CONCLUSIONS 

6.1 SSBH Testing 

The EERC performed extensive SSBH testing at Ash Grove's Durkee Plant from April 17, 

2007, through May 8, 2007. The main focus of the SSBH testing was to evaluate whether the 

injection of PAC into a secondary baghouse is a viable option for Hg removal from the Durkee 

facility and what design parameters should be utilized in order to design a robust, highperformance control installation. Significant variability was identified in Hg mass and form at 

the SSBH inlet. Nonetheless, by comparing inlet Hg concentrations to outlet Hg concentrations, 

the EERC was able to identify clear design choices for a full-scale Hg control installation 

appropriate for the Durkee cement kiln. 

The following parameters were tested during the pilot project: PAC type, FF bag type, A/C 

ratio, and PAC injection rate. Based on this testing, the EERC is able to make recommendations 

as to the predicted optimal design and operating parameters for the full-scale PAC injection 

installation. 

PAC Type: Results indicated that for the variety of PACs tested (halogen-treated and untreated), 

the untreated carbon, DARCO Hg, performed as well or better than the halogen-treated carbons. 

Use of the untreated carbon avoids the potential for secondary environmental impacts associated 

with the use of halogenated products. Therefore, the untreated carbon, DARCO Hg, was chosen 

to evaluate the other parameters. 

Bag Type: Of the three bags tested (PPS, membrane, and membrane/fiberglass), all three 

performed well. However, dust found downstream of the membrane bags indicated that a small 

amount of PAC was able to penetrate the bags. As this could lead to higher particulate loading in 

37 
the main stack exhaust gas, the membrane bags were dropped from consideration. The fiberglass 

with membrane bags are rated for a maximum continuous operating temperature of 500°F, while 

the PPS bags are only rated for a maximum continuous operating temperature of 375°F. Because 

of concerns over bag failure due to elevated temperatures as a result of process upsets, the 

fiberglass with membrane bags were identified as the best bags for use in a full-scale system. 

A/C Ratio: Four A/C ratios were evaluated: 4, 6, 8, and i0. The one common trend existing 

between testing the A/C ratios with the three different bags was that when the A/C ratio was 

increased, the Hg removal efficiency also increased. However, the results indicated that an A/C 

ratio greater than between 6 and 8 did not provide a material additional benefit in terms of Hg 

removal efficiency. Performance was not significantly different between the 6 and 8 A/C ratios, 

and so the choice of A/C ratio within this range should be left to the FF baghouse manufacturer. 

In summary, the EERC recommends that the secondary baghouse serving the full-scale PAC 

injection installation be designed with an A/C ratio of between 6 and 8. 

PAC Injection Rate: Three PAC injection rates were evaluated during raw-mill-on conditions: 1, 

3, and 5 lb/Macf. The data showed that at an A/C ratio of between 6 and 8, there is not a 

significant additional Hg removal efficiency gained by increasing the injection rate above 3 

lb/Macf during raw-mill-on conditions. Testing was performed during raw-mill-off conditions 

using four PAC injection rates: I, 3, 5, and 10 lb/Macf. These tests showed that Hg control 

increased with increased PAC injection. The highest control efficiencies were reached during the 

time when 10 lb/Macf were injected. Based on the expense and system wear of injecting at a rate 

of 10 lb/Macf and the uncertainty whether a baghouse system would maintain the control levels 

seen in the short term injection test, an increased injection rate of 5 lb/Macf during raw-mill-off 

conditions is warranted. Therefore, we recommend that the full-scale installation be designed for 

a PAC injection rate of 3 lb/Macf during raw-mill-on conditions and 5 lb/Macf during raw-milloff conditions. As testing suggested that the highest Hg emissions occur during approximately 

the first hour of a raw-mill-off period, the elevated PAC injection rate may not be necessary for 

the full duration of the raw-mill-off event. 

Control Efficiency and Optimization Period: The results gathered from testing the SSBH are 

only an indication of the relative differences between the different parameters tested. While the 

data indicate that a 90% Hg control efficiency can be reached on a long-term average basis 

during raw-mill-on conditions, we caution Ash Grove against assuming that the SSBH results 

will match the performance on the full-scale unit, particularly in the first 12 to 18 months of 

operation. It is our expectation that a PAC injection unit designed and operated consistent with 

the parameter choices outlined above has a reasonable likelihood of reaching the 90% control 

level on an annual average basis during raw-mill-on conditions. Likewise, it is our expectation 

that that a PAC injection unit designed and operated consistent with the parameter choices 

outlined above has a reasonable likelihood of reaching a 77% Hg control level on an annual 

average and mass-weighted basis. However, the differences between what occurs when 

controlling 1% of the exhaust gas over short periods and controlling 100% of the exhaust over 

long periods could result in a lower control efficiency. In addition, our experience suggests that 

Ash Grove will require at least 12 and more likely 18 months to optimize a t'ull-scale installation 

,,,,here, as here, the installation would be the first of its kind in the industry. At the end of that 

38 
period, Ash Grove should have adequate data to determine whether a 77% weighted control 

efficiency (annual average) is a realistic target. 

6.2 Performance Monitoring 

In order to demonstrate the performance of a PAC injection system, Ash Grove will need 

to implement some sort of periodic Hg-monitoring program. Such programs can rely upon 

continuous monitoring or periodic monitoring. Although two types of continuous MMs were 

used during this study, neither of these monitor types, nor any other that we are aware of, is 

robust enough to withstand a cement kiln stack environment nor analyzes Hg at the 

concentrations found in the Durkee exhaust gases. Each MM used in the pilot study required a 

dedicated technician. Such an allocation of resources is simply not realistic in an operating plant. 

In addition, there is no approved method for performing a RATA should a continuous MM be 

installed on the Durkee main stack. Therefore, at this time, we do not recommend the use of 

continuous MMs for monitoring the performance of the PAC injection installation. 

The EERC recommends that carbon sorbent traps would be the best method to allow Ash 

Grove to monitor Hg emissions at the Durkee facility. Carbon sorbent traps present numerous 

advantages over MMs in the workplace, including their inherent reliability. Results from carbon 

sorbent traps compared favorably with results obtained from OH method testing and the MMs 

during the pilot study. The periodic testing of Hg emissions using carbon sorbent traps will 

enable Ash Grove to confirm the performance of the PAC injection installation while avoiding 

the significant issues currently posed by MMs. 

6.3 Fixed-Bed Option 

The work at Durkee to evaluate the fixed-bed option for Hg control was not successful 

because of problems with the test equipment. Although fixed-bed technologies appropriate for 

cement kiln exhaust gases may be developed in the future, the current lack of system 

performance data make it difficult at best to design a full-scale fixed-bed system for use at 

Durkee. Based on the research to date, the EERC cannot recommend the fixed-bed technology 

for application at the Durkee Plant. 

39 
APPENDIX A 

PERSONNEL RESUMES 
Table A-1. List of Personnel and Task Responsibilities 

Person Project Task 

Michael Jones 

John Kay 

Brandon Pavlish 

Richard Schulz 

Jay Gunderson 

Kirk Williams 

Robert Jensen 

Brace Dockter 

Don Toman 

William Wilson 

Kyle Martin 

Eric Zacher 

Steve Sollom 

Ray DeWall 

Ray Johnson 

Scott Schulz 

Dave Westerman 

Bill Gerszewski 

Ken Jerik 

Project Manager 

Field Manager 

Field Manager 

Sampling Manager 

SSBH Operator 

SSBH Operator/Sorbent Injection 

SSBH Operator/Sorbent Injection 

Sorbent Injection 

MM Operator 

MM Operator 

MM Operator 

MM Operator/Chemist 

Chemist 

Chemist 

Sampler (no resume available) 

Sampler (no resume available 

Sampler 

Sampler (no resume available 

Sampler (no resume available 

A-I 
DR. MICHAEL L. JONES 

Senior Research Advisor 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701 777-5000, Fax (701 777-5181, E-Mail: mjones @ undeerc.org 

Principal Areas of Expertise 

Dr. Jones' principal areas of interest and expertise include management of and technical 

direction for multidisciplinary science and engineering research teams focused on a wide range 

of integrated energy and environmental technologies. Specific program areas of interest include 

clean and efficient combustion of low-rank fuels, matching of fuel characteristics to system 

design and operating parameters, development of advanced power systems based on low-rank 

fuels, fundamentals of combustion and gasification, ash deposition in combustion and 

gasification systems, and analysis of inorganic materials. Projects emphasize a cradle-to-grave 

approach from resource assessment, to optimum utilization systems, to minimization of 

emissions and waste management featuring by-product utilization. 

Qualifications 

Ph.D., Physics, University of North Dakota, 1978. 

M.S., Physics, University of North Dakota, 1973. 

B.S., Physics, Bemidji State University (Minnesota), 1971. 

Professional Experience 

2004-Present: Senior Research Advisor, Energy & Environmental Research Center (EERC), 

University of North Dakota (UND), Grand Forks, ND. Dr. Jones' responsibilities include 

management of and technical direction for multidisciplinary science and engineering research 

teams focused on a wide range of integrated energy and environmental technologies. Specific 

program areas of interest include clean and efficient use of low-grade fuels, matching of fuel 

characteristics to system design and operating parameters, development of advanced power 

systems based on low-grade fuels, fundamentals of low-grade fuel combustion, ash behavior in 

low-grade fuel conversion systems, and analysis of inorganic materials in low-grade fuels. 

Projects emphasize a cradle-to-grave approach from resource assessment, to optimum utilization 

systems, to minimization of emissions and waste management featuring by-product utilization. 

2004-Present: Adjunct Professor, Physics, UND. 

1994-20t)4: Adjunct Assistant Professor, Physics, UND. 

1983-2004: Associate Director, Industrial Relations and Technology Commercialization, EERC, 

UND. Dr. Jones' responsibilities include planning, staffing, and technical direction of 

combustion and gasification research, including projects in combustion chemistry or gasification 

chemistry, behavior during coal utilization, fluidized-bed combustion, coal-water fuels, 

SO•/NO• removal, and particulate removal and characterization. Special emphasis was given to 

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low-rank coal systems; activities ranged from field testing of full-scale power plants, to pilotscale studies, to laboratory investigations that examine both l-uel and system characteristics and 

their impacts on overall performance. 

1990-1994: Adjunct Professor, Department of Chemical Engineering, The University of Utah, 

Salt Lake City, Utah. 

1979-1983: Grand Forks Energy Technology Center, U.S. Department of Energy. Dr. Jones' 

responsibilities included technical direction of research and development projects related to 

combustion technology for low-rank coals, with specific responsibility for fundamental research 

on pulverized coal combustion. Directed research on new, specialized analytical procedures for 

determination of inorganics and trace elements in coal and materials derived from coal 

combustion and conversion processes. Instrumentation included methods Auger/ESCA 

spectrometer, scanning electron microscope, x-ray diffraction, x-ray fluorescence, argon plasma 

spectrometer, and atomic absorption spectrometer. 

Professional Memberships 

Adjunct Membership, Graduate Faculty, University of North Dakota, 1994 

Chair, ASME Research Committee on Corrosion and Deposits from Combustion Gases 

Utility Advisory Task Force for DOE-FE Study on RCRA Impact on Coal-Fired Utilities 

Sigma Xi The Scientific Research Society 

Society for Applied Spectroscopy 

The Combustion Institute 

North Dakota Academy of Science 

Publications and Presentations 

Has authored or coauthored over 80 publications 

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JOHN P. KAY 

Research Manager 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: jkay@undeerc.org 

Principal Areas of Expertise 

Mr. Kay's principal areas of interest and expertise include applications of scanning electron 

microscopy (SEM), x-ray diffraction (XRD), and x-ray fluorescence (XRF) techniques to the 

analysis of coal, fly ash, biomass, ceramics, high temperature specialty alloys, and biological 

tissue. He is also interested in computer modeling systems, high-temperature testing systems, 

and gas separation processes and is a FLIR Systems, Inc.-certified infrared thermographer. He is 

currently involved in field-testing site management and sampling techniques for mercury control 

in combustion systems. 

Qualifications 

B.S., Geological Engineering, University of North Dakota, 1994. 

Associate Degree, Engineering Studies, Minot State University, 1989. 

Professional Experience 

2005-Present: Research Manager, EERC, UND. Mr. Kay's responsibilities include the 

management and supervision of research involving the design and operation of bench-, pilot-, 

and demonstration-scale equipment for development of clean coal technologies. The work also 

involves the testing and development of fuel conversion (combustion and gasification) and gas 

cleanup systems for the removal of sulfur, nitrogen, particulate, and trace elements. 

1994-2005: Research Specialist, EERC, UND. Mr. Kay's responsibilities included conducting 

SEM, XRD and XRF analysis and maintenance; creating innovative techniques for the analysis 

and interpretation of coal, fly ash, biomass, ceramics, alloys, high-temperature specialty alloys, 

and biological tissue; managing the day-to-day operations of the Natural Materials Analytical 

Research Laboratory; supervising student workers; developing and performing infrared analysis 

methods in high-temperature environments; and performing field work related to mercury 

control in combustion systems. 

1993-1994: Research Technician, Agvise Laboratories, Northwood, North Dakota. Mr. Kay's 

responsibilities included receiving and processing frozen soil samples for laboratory testing of 

chemical penetration; maintaining equipment and inventory; and training others in processing 

techniques utilizing proper laboratory procedures. 

1991-1993: Teaching Assistant, Department of Geology and Geological Engineering, UND. Mr. 

Kay taught Introduction to Geology Recitation, Introduction to Geology Laboratory, and 

Structural Geology. Responsibilities included preparation and grading of assignments and 

administering and grading class examinations. 

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1990-1992: Research Assistant, Natural Materials Analytical Laboratory, EERC, UND. 

Mr. Kay's responsibilities included operation of an x-ray diffractometer and interpretation and 

manipulation of XRD data; performing software manipulation for analysis of XRD data; 

performing maintenance and repair of the XRD machine and sample carbon coating machine; 

preparing samples for XRD and scanning electron microscope analysis; and performing point 

count analysis on the scanning electron microscope. 

Professional Memberships 

ASM International 

American Ceramic Society 

Microscopy Society of America 

Publications and Presentations 

Has authored or coauthored numerous publications 

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BRANDON M. PAVLISH 

Research Engineer 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: bpavlish@undeerc.org 

Principal Areas of Expertise 

Mr. Pavlish's principal areas of interest and expertise include gas separation technologies, carbon 

dioxide sequestration, activated carbon technologies, and emission control related to mercury, 

sulfur, and particulates. 

Qualifications 

B.S., Chemical Engineering, University of North Dakota, 2006 

Professional Experience 

2006-Present: Research Engineer, EERC, UND, Grand Forks, ND. Mr. Pavlish's 

responsibilities include preparing proposals, interacting with industry and government 

organizations, researching literature, designing and conducting experiments as a principal 

investigator, performing calculations and interpreting data, writing technical reports and papers, 

and presenting information. Current projects involve mercury control technologies, biomass for 

energy, and hydrogen production. 

2002-2006: Student Engineer, EERC, UND, Grand Forks, ND. Mr. Pavlish's responsibilities 

included: 

Performed a broad range of engineering functions including literature research, conducting 

experiments (lab- and bench-scale testing), pilot-scale testing, sampling and sample tracking, 

tracking project activities, data reduction, writing and presenting technical results, proposal 

writing, presenting at conferences, and preparation of technical papers and project reports. 

Specific EERC intern/coop experience in hydrogen: Involved in the preparation of the Hydrogen 

short-course, literature searches, ChemCad simulations related to hydrogen production, hydrogen 

production via ethanol + water and catalyst reactions. 

During intern/coop at the EERC was involved in numerous projects that were focused on 

emissions control. The primary focus of the work completed during this time was mercury control 

technologies, and included pilot- and bench-scale testing, data reduction, proposal writing, 

technical reporting, and presentation. 

Professional Memberships 

American Institute of Chemical Engineers 

PabHcations and Presentations 

Has coauthored numerous publications 

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EERC , 

RICHARD L. SCHULZ 

Manager, Analytical Research Laboratory 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: rschulz@undeerc.org 

Principal Areas of Expertise 

Flue gas emissions testing of combustion gases produced from coal-based fuels, both on-site and 

in the field. 

Qualifications 

B.S., Chemistry, University of North Dakota, 1973. 

Professional Experience 

1994-Present: Manager, Particulate Research Laboratory, EERC, UND. Responsibilities 

include conducting and overseeing emissions testing at bench-, pilot-, and full-scale facilities. 

Field work includes sampling at industrial process sites and coal-fired power plants. Recent work 

includes a heavy emphasis on mercury continuous emission monitors, measurement, and control 

technologies. 

1990-1994: Research Specialist, EERC, UND. Responsibilities included performing particle 

sampling and sizing including EPA-5 dust loading, impactors, SASS training, multicyclone, and 

laser particle-size analysis. Performed EPA wet tests for flue gas analysis. Other work included 

bench-scale testing of fly ash characteristics, equipment fabrication and modification, and 

supervision and coordination of lab activities for the personnel in the particulate lab both inhouse and on field trips. 

1985-1990: Pilot Plant Operator, EERC, UND. Responsibilities included assisting in the 

operation and maintenance of several types of test combustors used to research various aspects of 

low-rank coal combustion and utilization. Performed several types of testing, including flue gas 

monitoring of SO2, NO, NOx, CO, CO2, O•_, unburned hydro-carbons, and particulates. 

Performed field tests on actual flue gas emissions, including EPA dust loading and gas sampling. 

Field work involved setting up sample systems, calibration of instruments and equipment, and 

collection of samples. Additional duties as shift supervisor included coordinating the work of 

other operators and preparing various types of coal for use in the test combustors. 

1981-1982: EG&G, Washington Analytical Services, Grand Forks Energy Technology Center, 

Grand Forks, North Dakota. Responsibilities included performing duties in the operation of pilot 

plant test facilities used in conjunction with low-rank coal research. Responsible for testing, 

repair, and calibration of equipment used to sample particulates in the field and at the pilot plant 

facilities. 

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1973-1977: Teacher, Fisher School District, Fisher, Minnesota. Responsibilities 

planning and developing a curriculum for high school chemistry and physics classes. 

Publications and Presentations 

Has coauthored numerous publications 

included 

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.lAY R. GUNDERSON 

Research Engineer 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701 777-5000, Fax (701 777-5 81, E-Mail: jgunderson @ undeerc.org 

Principal Areas of Expertise 

Mr. Gunderson's principal areas of interest and expertise include fireside performance testing, 

mercury sampling, design of pilot-scale equipment, and full-scale performance evaluation for 

coal-, oil-, and biomass-fired boilers. 

Qualifications 

M.S. Studies, Chemical Engineering, University of North Dakota, 1987-present. 

B.S., Chemical Engineering, University of North Dakota, 1987. 

Professional Experience 

1988-Present: Research Engineer, Fuels Performance, EERC, UND. Mr. Gunderson's 

responsibilities involve pilot-scale combustion projects for residential-, commercial-, and utilityscale applications of coal-fired combustion systems, including fuel characterization, emission 

monitoring and testing, evaluation of flame stability, and evaluation of ash fouling potential. His 

duties include documentation and reporting of pilot-scale testing results and relating these results 

to the operation of full-scale units. Mr. Gunderson has also managed numerous pilot-scale 

projects investigating ash fouling and gaseous emissions for oil-fired and biomass-fired systems. 

1988: Research Assistant, Combustion and Environmental Systems Research Institute, Energy 

and Mineral Research Center, UND. Mr. Gunderson's responsibilities involved the development 

of a coal-water fuel-fired residential- and commercial-scale furnace. 

Professional Memberships 

American Institute of Chemical Engineers 

Publications and Presentations 

Has coauthored numerous publications 

A-9 
 EERC 

KIRK D. WILLIAMS 

Research Engineer 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701 777-5181, E-Mail: kwilliams @ undeerc.org 

Principle Areas of Expertise 

Mr. Williams' principle areas of expertise and interest include materials engineering, analytical 

metallurgy, advanced structural composites, mechanical engineering, and thermal imaging 

applications. Mr. Williams has additional expertise in applied environmental engineering, 

applied and theoretical geophysical techniques, hydrogeology, ground and surface water 

modeling techniques, geodetic global positioning surveying, and geographical information 

systems. 

Qualifications 

M.S., Geological Sciences, University of California, Riverside, 1998. 

B.S., Geophysics/Computer Science, University of California, Riverside, 1995. 

Professional Experience 

2001-Present: Research Engineer, EERC, UND. Mr. Williams is presently involved in several 

projects related to renewable energy; carbon capture and sequestration; hydrogen end use 

demonstration, education, and outreach; and water quantity and quality issues. 

Mr. Williams is working with commercial partners to lower the overall cost of current biogas 

treatment technoiogy while maintaining the efficiency for smaller applications. He is also 

guiding the development of more economical and durable stationary power generation 

equipment that is capable of utilizing low-Btu fuel sources derived from renewable sources. 

Mr. Williams has a working knowledge of carbon credit trading as it applies to CO•_ capture and 

sequestration and how this relates to methane gas capture from landfill and wastewater treatment 

plant sites. He is also knowledgeable with compliance regulations related to CO2 capture and 

sequestration issues and is experienced with the basic procedures and requirements of 

combustion gas sampling. 

Mr. Williams' involvement with hydrogen education and outreach has led to the successful 

production of an introductory video that details H•_ production and end uses in the upper Midwest 

along with a half dozen fact sheets spanning H• safety, production, and utilization. He has 

general experience with electrolyzers, hydrogen internal combustion engine conversions, and the 

system integration of H•_-fueled PEM fuel cell stacks with electric drive units. 

Mr. Williams has demonstrated responsibility for numerous local and national projects involving 

surface water and groundwater quality modeling and compliance with federal and state 

regulations. He is involved with regional NPDES Phase II storm water ruling; phosphorus fate 

and transport issues; and in-basin alternative water supply options. Mr. Williams also has 

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experience reviewing, preparing and submitting environmental impact statements to the EPA in 

compliance with the National Environmental Policy Act. 

Mr. Williams has demonstrated skills in high-temperature research on metal alloys and ceramics, 

infrared imaging and analysis of high-temperature combustion processes, and the corrosion 

properties of flowing slag on ODS alloys MA956 and MA754 utilizing the dynamic slag 

application furnace. Mr. Williams also has extensive thermal imaging knowledge and experience 

conducting energy audits and providing nondestructive thermal imaging analysis for hightemperature applications. 

Ongoing duties include authoring proposals, managing funded projects, interacting with industry 

and government organizations, researching literature, designing and conducting effective 

experiments as a principal investigator, performing calculations and interpreting data, writing 

technical reports and papers, and presenting information. 

2000-2001: Environmental Scientist, Camp Dresser & McKee, Western Division. Mr. Williams' 

responsibilities included providing groundwater modeling and characterization for evaluation of 

extraction and recharge projects; extensive research and reporting on storm water pollution 

control and management, groundwater recharge systems, storm drain inlet cleaning, litter solids 

removal device evaluation, and storm water monitoring, sampling, and analysis plans; 

meteorological analysis for storm event coordination and storm water management projects; soil 

vapor extraction and gas flux measurements; and analytical field hydrogeology including 

groundwater well installation, monitoring, and water sample analysis. 

2000: Contract Geophysicist, Parsons Engineering Science, Unexploded Ordinance Division, 

Fort Ord Project. Mr. Williams provided field data collection and processing expertise including 

data reduction, post processing, and interpretation leading to a final dig list. 

1995-2000: Staff Research Associate, Department of Earth Sciences Institute of Geophysics and 

Planetary Physics, University of California, Riverside. Mr. Williams' responsibilities included 

providing project field management for investigation and remediation of groundwater 

contamination studies; collection of geodetic GPS and gravity survey data; managed field 

seismic refraction/reflection line data collection, processing, and interpretation; performed 

hydrogeologic computer simulation design, calibration, validation, and sensitivity analysis; 

developed detailed subsurface fluid flow and mass transport models; performed hydrochemical 

investigations; studied environmental hydrogen and oxygen isotope effects on characterization 

and applications to hydrologic evaluations; prepared site maps using GIS application software; 

served as a teaching assistant for introductory geophysics, mineralogy and crystallography, and 

evolutionary geology; reviewed environmental proposals and reports; authored research 

proposals and operational grants. Also served as an instructor for mathematics, physics, and 

applied geophysics. 

Professional Memberships 

American Geophysical Union 

Geological Society of America 

American Association of Petroleum Geologists 

Association of Ground Water Scientists and Engineers 

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Certifications 

ITC Level and II Infrared Thermography 

Publications and Presentations 

Has attthored or coauthored numerous publications 

A-[2 
 EERC 

ROBERT R. JENSEN 

Research Manager 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: bjensen@undeerc.org 

Principal Areas of Expertise 

Mr. Jensen's principal areas of interest and expertise include development of computerized 

models and other computer-related tools. Mr. Jensen has most recently been involved in several 

modeling projects for ash deposition and fouling models for coal-fired power systems. 

Education 

B.S., Computer Science and Mathematics (minor in Data Processing), Bemidji State University, 

Bemidji, Minnesota, 1984. 

Professional Experience 

1996-Present: Research Manager, EERC, UND. Mr. Jensen's responsibilities 

supervision of projects and personnel dealing with computer models and databases. 

include 

1994-1996: Research Specialist, EERC, UND. Mr. Jensen's responsibilities included designing 

and implementing graphical interface for groundwater modeling in Microsoft Windows 

environment using Borland C++4.0. 

1987-1994: Lecturer/Graduate Teaching Assistant, UND. Mr. Jensen's responsibilities included 

"C" programming language on several platforms, computer programming I (Modula-2 and 

Pascal), computer programming I lab, programming in BASIC (Microsoft QBASIC), 

introduction to computers, introduction to computers lab (Microsoft Works). 

1989-1990: Graduate Research Assistance, UND. Mr. Jensen's responsibilities included 

developing expert system for airline gate scheduling for an Airport Airline Operation 

Management project. 

1989-1990: Lecturer, University of North Dakota Lake Region, Grand Forks Air Force Base. 

Mr. Jensen's responsibilities included instructing "C" programming language (Borland Turbo C). 

1985-1987: System Manager, Strom Engineering, Contracted to 3M Company. Mr. Jensen's 

responsibilities included system administrator on UNIX PDP 11/34 and RT-It PDP 11/34. 

Developed software for the interface to the 3M laser imager, decode, transfer, and print medical 

images from magnetic tape, develop utility programs for Electrical Engineering group. 

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1984-1985: Software Engineer, Northern Micro Systems. Mr. Jensen's responsibilities included 

programming in Z-80 assembly language to develop an editor for the KROY 80k lettering 

machine. This project has given me a working knowledge of LCD display controls, counter time 

chips, stepper motor controls, and a simple functioning operating system. 

Professional Memberships 

Upsilon Pi Epsilon honor society for the computing sciences 

Publications and Presentations 

Has authored and coauthored numerous publications 

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BRUCE A. DOCKTER 

Research Engineer 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701 777-5000, Fax (701 777-518 I, E-Mail: bdockter@ undeerc.org 

Principal Areas of Expertise 

Mr. Dockter's principal areas of interest and expertise include physical and chemical analysis of 

fly ash and examination of coal ash for utilization in high- and low-volume applications. In 

addition, he has also worked extensively in the field of high-temperature research on the physical 

and chemical properties of coal ashes and slags. 

Qualifications 

Registered Professional Engineer, 1993. 

M.E., Civil Engineering, University of North Dakota, 1991. 

B.S., Civil Engineering, University of North Dakota, 1983. 

Professional Experience 

1991-Present: Research Engineer/Manager, Fuels and Materials Research Laboratory, EERC, 

UND. Mr. Dockter's responsibilities include supervisory management of laboratory projects and 

testing procedures and coordination of research efforts between laboratory facilities and EERC 

project managers for evaluating coal by-products for utilization options. Tasks also include 

methodology evaluations, proposal writing, and paper publications and presentations. 

1985-1991: Chemist II/Manager, Coal By-Products Utilization Laboratory, EERC, UND. Mr. 

Dockter's responsibilities included daily operation of laboratory emphasizing setting daily work 

objectives, supervision of full-time and student employees, and general lab maintenance. He was 

also responsible for training new employees, conducting seminars, keeping test result books, and 

writing final report papers. 

1984-1985: Chemist I, Fine Coal Cleaning Project, Grand Forks Energy Research Center. Mr. 

Dockter's responsibilities included data interpretation for methods including oil agglomeration 

and froth flotation. 

1983-1984: Engineering Technician III, Fine Coal Cleaning Project, Grand Forks Energy 

Research Center. Mr. Dockter's responsibilities included performing washability and other 

beneficiation tests for the physical separation of mineral-rich materials from coal samples. 

Professional Memberships 

American Society for Testing and Materials 

National Society of Professional Engineers 

Transportation Research Board 

Publications and Presentations 

Has authored or coauthored over 70 publications 

A-15 
 EERC 

DONALD L. TOMAN 

Research Scientist 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701 777-5000, Fax (701 ) 777-5181, E-Mail: dtoman @ undeerc.org 

Principal Areas of Expertise 

Mr. Toman's principal areas of interest and expertise include design, fabrication, and operation 

of bench-, intermediate-, and pilot-scale combustion systems and full-scale testing of gaseous 

and particulate emissions. 

Qualifications 

B.S., Natural Sciences, University of North Dakota, 1980. 

Professional Experience 

1989-Present: Research Scientist, Systems Development, EERC, UND. Mr. Toman's 

responsibilities include designing, fabricating, and operating various types of bench-scale 

systems to produce and collect chars and ash from coal under closely controlled conditions; fullscale utility boiler testing and collection of gaseous and particulate emissions; collecting, 

interpreting and reporting of data; and preparing budgets, proposals, and reports. 

1985-1989: Pilot Plant Operator Supervisor, Operations Division, EERC, UND. Mr. Toman's 

responsibilities included supervision and evaluation of operations personnel; planning project 

and work schedules; maintaining production records; quality assurance and quality control; and 

ensuring that regulations and rules were observed on housekeeping, conduct, and safety. 

1983-1985: Pilot Plant Operator III, Pilot Plant Operations, Coal Utilization Research Division, 

Energy Research Center, UND. Mr. Toman's responsibilities included supervision of personnel 

and facility operations, maintenance, and trouble-shooting of pilot plant test equipment. 

1982: Operations Group Supervisor, EG&G Washington Analytical Services Center, Inc., Grand 

Forks, North Dakota. Mr. Toman's responsibilities included all aspects of combustion pilot plant 

operations, including supervision and evaluation of operations personnel, scheduling, and 

supervising performance of combustion pilot plant testing, reviewing data collected from 

combustion pilot plant testing, preparing weekly summaries and monthly reports, and 

documenting work performed by the Operations Group. 

1982: Shift Supervisor, Operations Group, EG&G Washington Analytical Services Center, Inc., 

Grand Forks, North Dakota. Mr. Toman was responsible for all aspects of facility operation and 

supervision of operations personnel during shift. 

1980-1982: Pilot Plant Operator, Operations Groups, EG&G Washington Analytical Services 

Center, Inc., Grand Forks, North Dakota. Mr. Toman's responsibilities included operations, 

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maintenance, data collection, and trouble-shooting of pilot plant equipment. Pilot plant 

equipment included two pulverized coal-fired combustors, an AFBC coal-fired combustor, a wet 

scrubber flue gas desulfurization test unit, a direct injection flue gas desulfurization test unit, and 

various coal processing equipment (pulverizer, crusher, classifier, dryer, conveyors, and lift 

trucks). Experienced in the operation of solid feeders, particulate collection equipment, flue gas 

sampling equipment, and process instrumentation. 

1980: Lab Technician, Grand Forks Energy Technology Center, UND, Grand Forks, North 

Dakota. Mr. Toman's responsibilities included preparing samples for analysis and performing 

routine coal and ash analysis. 

Publications and Presentations 

Has authored or coauthored numerous publications 

A-t7 
 EERC 

WILLIAM I. "JIB" WILSON IV 

Research Specialist 

Energy & Environmental Research Center (EERC) 

University of North Dakota (UND) 

15 North 23rd Street, Stop 9018 

Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181 

E-Mail: j wilson @ undeerc.org 

Principal Areas of Expertise 

Mr. Wilson's principal areas of interest and expertise include residential energy efficiency, 

residential construction, and real estate sales and finance. 

Qualifications 

A.S., Electronic Engineering Technologies, Maui Community College, Kahului, Hawaii, 1998. 

Real Estate Securities and Syndication Institute, Carmel, California, 1979. 

Professional Experience 

2006-Present: Research Specialist, EERC, UND. Mr. Wilson's work focuses on residential 

building programs, environmental systems, and energy conversion technologies. His responsibilities include proposal preparation, writing reports and papers, and presentation of research 

findings. 

2005-2006: Technician, HB Sound & Light, Grand Forks, North Dakota. Mr. Wilson's 

responsibilities included assisting in commercial installations of projectors and sound systems, 

computer networks, and surveillance cameras; repairing, maintaining, and troubleshooting GF 

Public Schools sound systems for the hearing impaired; and assisting in the setup of concert 

sound systems, including the setup and operation of concert lighting. 

1998-2004: Residential Program Manager, Maui Electric Company, Ltd (MECO), Kahului, 

Hawaii. Mr. Wilson's responsibilities included expanding the number of Residential Efficient 

Water Heating (REWH) technologies installed in homes throughout Maui County, meeting 

shareholders incentives, kW and kWh goals, and financial goals; retaining customers through the 

Demand Side Management Program; providing/assisting in monthly, semiannual, and annual 

reports that are filed with the PuNic Utilities Commission; and developing and maintaining 

cooperative relationships between community, industry, and state and local government to 

educate the punic on energy efficiency to decrease Maui's dependence on fossil t\•els. 

Achievements include the following: 

® Increased the number of solar water-heating (SWH) systems installed on new homes from 

16% to over 40% in 6 years, averaging a 22.5% increase per year. 

• Developed and coordinated multidisciplinar,v contracts between home owners, builders, 

developers, lenders, Fannie Mae, U.S. Environmental Protection Agency (EPA), and other 

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key county, state, federal, and private agency supervisors and staff personnel. Provided 

and or assisted in creating monthly, semiannual, and annual reports that are filed with the 

Public Utilities Commission and writing county and federal grants. 

• Improved the way homes were being built by recruiting Hawaii's first builders and 

developers to make solar water heating a standard feature in all their new homes. 

• Created and presented education seminars for Hawaii's Building Industry Association, 

Hawaii Association of Realtors, state and local lenders, and the Maui Contractor's 

Association's Annual Home Show. 

• Assisted in creating Maui Electric's Commercial Solar Program. 

• Contributed to the creation of the Solar Water Heating Test Center for Maui Community 

Colleges Sustainable Technology Program. 

• Received the Outstanding Achievement Award U.S. Department of Energy, Energy Star 

Homes Program -2002, 2003, and 2004. 

• Recognized by the state of Hawaii's Department of Business, Economic Development, and 

Tourism for accomplishments with Maui's Building Industry. 

• Best Progress Award One of three National Awards, awarded by the U.S. Department of 

Energy. 

• Researched and cowrote county and federal grants. 

• Published in industry and local magazines. 

1996-1998: Intern for Department of Defense Contract, Maui High Performance Computer 

Center, Kihei, Hawaii. Mr. Wilson's responsibilities included assisting in the design and 

construction of an eight-node NT Cluster at the Maul High Performance Computer Center for the 

U.S. Department of Defense and assisting in writing Perl scripts. 

1996-1998: Solar Inspector, Maui Electric Company, Ltd, Kahului, Hawaii. Mr. Wilson's 

responsibilities included verifying compliance of over 85 items in Maui Electric's solar water 

heating program's standards and specifications by inspecting installations done by participating 

contractors; serving as primary troubleshooter for customers complaining about the lack of hot 

water; and assisting in troubleshooting the cause of high bill complaints. 

1992-1997: Owner, Light and Sound Tech, Kihei, Hawaii. Mr. Wilson's responsibilities 

included working as a light and sound engineer for shows and productions for the entertainment 

community in the state of Hawaii, creating and maintaining multiple light and sound contracts 

for numerous national and statewide performing arts, entertainment, and lighting and sound 

companies. 

1983: Principal Broker, ERA Pacific Land, Wailuku, Hawaii. Mr. Wilson's responsibilities 

included negotiating and processing sales contracts, leases, agreements, deeds, title searches, etc. 

while managing day-to-day operations. 

1983-1990: Real Estate Licensing Instructor, ERA Pacific Land dba Maui School of Real Estate, 

Wailuku, Hawaii. Mr. Wilson's responsibilities included instructing students on real estate 

mathematics for real estate licensing course on the island of Maui. Taught weekly classes as well 

as participated in class recruitment and real estate course tutoring. 

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Publications and Presentations 

Has authored and coauthored numerous publications and symposium presentations on residential 

energy efficiency, construction, and finance. 

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EERC 

KYLE E. MARTIN 

Research Engineer 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: kmartin @ undeerc.org 

Principal Areas of Expertise 

Mr. Martin's principal areas of interest and expertise include cogeneration, biomass energy, and 

fuel cells. His experience also includes power plant testing for pollutants such as ammonia, 

chlorine, sulfur compounds, and mercury as well as development and testing of continuous 

emission monitors; thermomechanical pulping; and agricultural processing system design, 

development, and installation, including a growth scoring system and a light canopy project. 

Qualifications 

M.S., Chemical Engineering, University of North Dakota, 2006 

B.S., Chemical Engineering, University of North Dakota, 2002 

B.S., Chemistry, University of North Dakota, 2001. 

Professional Experience 

2001-Present: Research Engineer, EERC, UND. Mr. Martin's current responsibilities include 

research focused on cogeneration, biomass energy, and fuel cells. Duties include proposal 

preparation, system design and construction, experimental planning and design, preparation of 

reports, and presentation of results. Mr. Martin's experience at the EERC also includes power 

plant testing for pollutants such as ammonia, chlorine, sulfur compounds, and mercury as well as 

development and testing of continuous emission monitors. 

2000-2001: Process Engineer, Champion/International Paper, Sartell, Minnesota. Mr. Martin's 

responsibilities focused on thermomechanical pulping, including optimizing the system and daily 

troubleshooting. Projects involved development of a quality control reporting system, justification of projects, and experiments to improve profit. 

1999: Project Engineer, Cargill Oilseeds Ltd., Clavette, Saskatchewan, Canada. Mr. Martin's 

responsibilities included designing, pricing, ordering, and overseeing installation of a new 

$500,000 system which involved managing up to 30 employees. 

1998: Research Engineer, Agriculture & Agri-Food, Scott, Saskatchewan, Canada. Mr. Martin's 

responsibilities included recording experimental data, mixing and applying chemicals, and 

performing special projects, including the development of a new growth scoring system and a 

light canopy project. 

Publications and Presentations 

Has coauthored numerous publications 

A-2I 
ERICK J. ZACHER 

Research Assistant 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: ezacher@undeerc.org 

Principal Areas of Expertise 

Mr. Zacher's principal areas of interest and expertise include ash chemistry, leaching procedures, 

ultratrace mercury analysis with a double-gold amalgamation atomic fluorescence apparatus, 

environmental impacts of coal combustion by-product (CCB) use and disposal, environmental 

sampling analysis, and surface and groundwater environmental impacts. Recent research has 

included an extensive mercury and air toxic elements project and work in various other projects 

involved in evaluating the environmental impacts of CCB utilization. Mr. Zacher has laboratory 

experience with organomercury compound analysis utilizing gas chromatography organic 

synthesis, atomic fluorescence spectroscopy, atomic absorption and inductively coupled argon 

plasma spectroscopy, ultraviolet and fluorescence analysis, gas chromatography, and ion 

chromatography. 

Qualifications 

B.S. Environmental Geology and Technology, University of North Dakota, May 2005. 

Professional Experience 

2005-Present:Research Scientist, EERC, UND. Mr. Zacher's responsibilities include 

performing laboratory experiments to evaluate the characteristics of industrial by-products, 

especially coal combustion by-products, including sample preparation; environmental performance testing (leaching, elevated- and ambient-temperature vapor-phase release experiments for 

trace elements and microbiologically mediated release experiments); and instrumental analyses, 

including spectrophotometric methods (atomic fluorescence, atomic emission, and atomic 

absorption) and gas chromatography with solid-phase microextraction. 

2002-2005: Research Assistant, Coal Ash Research Laboratory, EERC, UND. Mr. Zacher's 

responsibilities included research focused primarily on the environmental impacts of CCB use 

and disposal, ultratrace mercury analysis, and data interpretation and management. 

Summer 2001: Laboratory Assistant, North Dakota Department of Health Chemistry 

Laboratory. Mr. Zacher's responsibilities included environmental sample preparation for organic 

contaminant analysis, gas chromatographic organic contaminant analysis for drinking water and 

groundwater samples, biological oxygen demand (BOD) analysis of environmental samples, total 

dissolved solids (TDS) analysis of surface water samples, performance of the toxicity 

characteristic leaching procedure (TCLP) on various environmental samples, and data 

interpretation. 

A-22 
Professional Membership 

Phi Beta Kappa 

Publications and Presentations 

Has coauthored several publications 
STEPHEN E. SOLLOM 

Research Engineer 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: ssollom@undeerc.org 

Principal Areas of Expertise 

Mr. Sollom's principal areas of interest and expertise include pilot-scale combustion systems and 

emission control related to mercury, sulfur, and particulate matter. 

Qualifications 

B.S., Chemical Engineering, University of North Dakota, 2006. 

Professional Experience 

2006-Present: Research Engineer, EERC, UND. Mr. Sollom's responsibilities include 

researching literature, designing and conducting effective experiments, performing calculations 

and interpreting data, and writing technical reports and papers. Work focuses on the pilot-scale 

combustion systems and emission control related to mercury, sulfur, and particulate matter. 

2003-2006: Research Assistant, EERC, UND. Mr. Sollom's responsibilities included 

researching the literature, designing and conducting effective experiments, performing 

calculations, interpreting data, helping to write technical reports and prepare presentations. 

Specifically, he performed literature reviews on mercury emissions, mercury control 

technologies, and full-scale mercury removal; NOx emission and control; SO2 emission and 

control; and patents on mercury control technologies; drafted reports and reviewed final data for 

the Leland Olds and Antelope Valley Stations and assisted in pilot-scale tests with carbon 

injection by calibrating and monitoring the feeder during pilot-scale testing; was responsible for 

data reduction and analysis on various aspects of the Leland Olds and Antelope Valley Station 

projects; and assisted in field trip installation of a selective catalytic reduction system at the 

Coyote Station. 

Publications and Presentations 

Has coauthored numerous publications. 

A-24 
 EERC 

RAYMOND A. DEWALL 

Research Scientist 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: rdwall@ undeerc.org 

Principal Areas of Expertise 

Physical and chemical coal cleaning and preparation of coal-water fuels. 

Qualifications 

B.S., Chemistry and Microbiology, South Dakota State University, 1982. 

Professional Experience 

1988-Present: Chemist III, Applied Chemistry, EERC, UND. Responsibilities include preparation of coal-water fuels from low-rank and beneficiated low-rank coal. Utilize physical and 

chemical cleaning methods on coal. Develop new processes for cleaning coal. Analyze and 

report data for reports and publications. Present research results at conferences. Supervise 

students working on the project. 

1986-1988: Chemist II, Energy and Mineral Research Center, UND. Responsibilities included 

same tasks as above. 

1985-1986: Chemist I, Energy Research Center, UND. Responsibilities included using physical 

coal cleaning methods on a database of samples. Analyzed products for moisture, ash, sulfur, and 

heating value. 

1983-1985: Chemist I, Energy Research Center, UND. Responsibilities included analyzing coal 

liquefaction products by wet and instrumental analytical methods. Gained considerable knowledge in the operation, maintenance, and repair of a gas chromatograph and carbon-hydrogennitrogen analyzer. 

1982-1983: Lab Technician III, Engineering Experiment Station, UND. Responsibilities 

included setup and analysis of products from hot-water drying of coal using ASTM methods of 

analysis. Ordered lab supplies and trained students in lab operation. 

Professional Memberships 

American Chemical Society 

Publications and Presentations 

Has coauthored numerous publicatJ.ons 

A-25 
 EERC 

DAVID G. WESTERMAN 

Research Specialist II 

Energy & Environmental Research Center (EERC), University of North Dakota (UND) 

15 North 23rd Street, Stop 9018, Grand Forks, ND 58202-9018 USA 

Phone (701) 777-5000, Fax (701) 777-5181, E-Mail: dwesterman @undeerc.org 

Principal Areas of Expertise 

Mr. Westerman's primary expertise is related to the technical aspects of soil and groundwater 

field work, including the installation, development, and maintenance of groundwater monitoring 

wells, lysimeters, piezometers, tensiometers, and other instrumentation for the collection of data 

pertaining to soils and hydrogeology; odor control and testing equipment; freeze-thaw facility 

installation and operation; wind monitoring system installation, monitoring, and maintenance. 

QUALIFICATIONS 

Boiler School, Area Vocational Technical Institute (AVTI), East Grand Forks, Minnesota 

Boiler School, Wahpeton, North Dakota 

Aircraft Maintenance Jet Engine School, Sheppard AFB, Texas, 1970 

Beaver County Community College, Freedom, Pennsylvania, 1970 

Minnesota Class Engineer, License No. 1821 

Professional Experience 

1985-Present: Research Specialist II, EERC, UND. Mr. Westerman's responsibilities include 

the installation, development, and maintenance of groundwater monitoring wells, lysimeters, 

piezometers, tensiometers, and other instrumentation for the collection of data pertaining to soils 

and hydrogeology; installation of barIey straw on wastewater ponds and biofilters for odor 

control; construction and operation of freeze-thaw unit; construction of wind monitoring towers 

for feasibility studies. Other duties include collecting water and soil samples for a variety of 

chemical analyses and performing various testing procedures for the determination of 

hydrogeologic properties of the subsurface. He has experience with a variety of sampling 

techniques for both organic and inorganic contaminants in groundwater, use of sniffometer odor 

testing, and a variety of hydrogeologic testing techniques, including slug tests, drawdown and 

recovery tests, and pump tests. He is also experienced in sampling for mercury in soils. He is 

adept at using neutron soil moisture probes, computer data loggers, instrumentation for the 

determination of chemical parameters such as pH and conductivity, and a variety of watersampling devices. He also has laboratory experience preparing soil for chemical analysis, 

performing dry-sieve testing for grain-size analysis, operating filtering equipment, and 

determining soil moisture parameters through the use of ASTM testing procedures. He also 

worked with the EERC team on underground coal gasification in Thailand. 

1985-1990: Maintenance Worker II, EERC, UND. Mr. Westerman performed maintenance of 

EERC buildings and equipment. 

1979-1985: Boiler Operator, LIND Boiler Plant. 

A-26 
1977-1979: Salesman, American National Insurance Company, Grand Forks, North Dakota. 

1970-1977: Military, United States Air Force. Mr. Westerman performed aircraft 

maintenance. 

Professional Memberships 

National Ground Water Association 

jet 

A-27 
APPENDIX B 

EXAMPLE CALCULATIONS 
EXAMPLE CALCULATIONS 

Sample calculations are included for each of the calculated parameters. 

OH Method Sampling 

Volume of Gas Sample 

Vm(std) volume of gas sample measured by the dry gas meter, corrected 

to standard conditions, dscf 

Vm(std) (dscf) K• xVmcxPm 

Tm + 460 

17.64x 45.472x x 29.665 

Vm(std) 42.190 dscf 

104 + 460 

Where: 

K 

Pm 

17.64 R/in. Hg 

Vm x Cm volume of gas sample as measured by dry gas meter 

corrected for meter calibration 

(Cm meter calibration coefficient) (dcf) 

meter pressure (in. Hg) 

meter temperature (°F) 

Volume of Water Vapor 

Vw(std) 

Vw(std) (scf) 

Vw(std) 

volume of water vapor in the gas sample, corrected to standard 

conditions, scf 

K2 x H•_O(g) 

0.04715 x 137.5 6.483 scf 

Where: 

H20(g) 

0.04715 ft3/g 

mass of liquid collected in impingers and silica gel (g) 

Water Vapor in the Gas Stream 

BWS water vapor in the gas stream, proportion by volume 

BWS Vw(std) 

Vm(std) + Vw(std) 

B-! 
6.483 

Bws =0.1332 

Dry Molecular Weight 

Md 

Md (lb/lb-mol) 

Md 

Where: 

%(CO2, 02, N2, CO) 

Molecular Weight 

Ms 

Ms (lb/lb-mol) 

Ms 

42.190 + 6.483 

dry molecular weight of stack gas, lb/lb-mol 

0.440 x (%CO2) + 0.320 x (%0-2_) + 0.280 x (%N2 + %CO) 

0.440 x 15.9 + 0.320 x 3.1 + 0.280 x 81.0 30.7 lb/lb-mol 

percent (CO2, 02, N2, CO) by volume, dry basis 

molecular weight of stack gas, wet basis, lb/ib-mol 

Md x (1 -Bws) + 18.0 x Bws 

30.7 x (l -0.1332) + 18.0 x 0.1332 29.0 lb/lb-mol 

Average Stack Gas Velocity 

Vs Average stack gas velocity, ft/sec 

• [-Ts +4601':2 Vs (ft/sec) K3 xCpx(Ap)"2 tavg)x• •s•Ms _] 

685+460 

Vs 85.49x0.84x0.4472x 30--•-9--•..0_] 36.6ft/sec 

Where: 

K 3 

Cp 

Ap 

(•p)": (•vg) 

Ts 

Ps 

lb xin. Hg ]•/•- 85.49 x | lb mol 

pitot tube coefficient, dimensionless 

velocity head of stack gas (in. Hg) 

average of the square root of Ap values 

Stack gas temperature (•'F) 

Stack pressure (in. Hg) 

B-2 
Isokinetic Sampling Rate 

I(%) 

Where: 

An 

percent of isokinetic sampling, % 

K• x(Ts + 460)x Vm(std) x 144 

Psx Vsx An x0x(l Bws) 

0.09450x (685 + 460)x 42.190x 144 

30.49 × 36.6 x 0.0707 x 90x (l 0.1332) 

0.09450% (in. Hg )(rain 

R x sec 

cross-sectional area of nozzle (in. 2) 

total sampling time (min) 

107% 

Volume of Gas Sample Corrected to 7% O2 

Vm*(std) volume of gas sample measured by the dry gas meter (Vm[std]), 

* corrected to 7% oxygen, Nm 3 

Vm*(std) K 5 

x Vm(std)x 21 %0 2 

14 

Vm*(std) 0.02832 x 42.190 x 

21 -3.1 

14 

1.188Nm 

Where: 

K5 

Mercury 

Hg (,ug/Nm 3) 

0.02832 m•/ft 3 

btg 

Vm * (std) 

Hg 

Particulate Hg 

Oxidized Hg 

6.99 

1.188 

5.88 ,ttg/Nm 3 

sum of Hg from filter and nozzle rinse 

sum of Hg from KCI impingers 

B-3 
Elemental Hg sum of Hg fi'om H202 and KMnO4 impingers 

MERCURY MONITORS 

Corrected Mercury Concentration at Stack 

Hg STK Hg concentration, 7% O-,, dry basis, stack location, ,ug/dNm 3 

Hg ST• (,ug/dNm 3) 

Hg STK 

21-7 

Hg MM X 

21-%O %H•O) × 1+• 

100 

2.68x 

21-4.6) 

x +I-• l'85'ug/dNm3 

PAC INJECTION 

IpAC amount of PAC injected into duct, based on gas flow, lb/Macf 

[pAc (lb/Macf) FpAc 

X 

1000X528 

60 F s x(T +460) 

47.8 1000x528 

IpAc X 0.46 lb/Macf 

60 1213.5x(300+460) 

Where: 

FpAc 

Fs 

PAC feed rate (lb/hr) 

stack gas flow (kscfm) 

PERCENT DIFFERENCE 

Applied when comparing two experimental quantities, E and E2, neither of which can be 

considered the "correct" value. The percent difference is the absolute value of the difference over 

the mean times 100. 

B-4 
THIS PAGE INTENTIONALLY LEFT BLANK. 
APPENDIX C 

SLIPSTREAM BAGHOUSE MM DATA AND TEST 

DESCRIPTION 
C-t 
C-2 


C-5 
•' 0 0 0 © 0 0 0 
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APPENDIX D 

QUALITY ASSURANCE/QUALITY CONTROL 
QUALITY ASSURANCE/QUALITY CONTROL 

Detailed quality assurance/quality control (QA/QC) procedures that were used for the flue 

gas-sampling activities and implementation of the Hg control technologies at the Durkee Cement 

Facility are described herein. The QA/QC plan, which provided guidelines as to how testing 

activities detailed in the site-specific test plan were to be performed, was adhered to during all 

testing, sample preparation, sample analysis, and data reduction activities. 

Careful consideration was used during on-site flue gas monitoring and sampling 

procedures to ensure that all QA/QC requirements were met. Sorbent enhancement additive 

(SEA) addition and powdered activated carbon (PAC) injection systems were installed, 

calibrated, and operated with QA/QC procedures in mind. All analytical work, performed either 

on-site or at EERC facilities, was performed according tO QA/QC guidelines. 

FLUE GAS MERCURY MEASUREMENTS 

Mercury Monitoring 

The Tekran Model 3300 atomic fluorescence-based Hg vapor analyzer was used to 

continuously monitor Hg ° and Hgtota• concentrations. The Tekran instrument traps the Hg vapor 

from the conditioned sample onto a cartridge containing an ultrapure gold sorbent. The 

amalgamated Hg is then thermally desorbed and detected using atomic fluorescence 

spectrometry. A dual-cartridge design enables alternate sampling and desorption, resulting in a 

nearly continuous measurement of the sample stream. An automatic Hg ° permeation source was 

used to calibrate the instrument daily. Manual Hg ° injection calibration on both cartridges was 

also performed for verification. The Tekran instrument measures either Hgtota! or Hg °, with an 

analysis occurring approximately every 2.5 minutes. 

A four-point calibration curve was then completed using matrix-matched standards. The 

detector response for a given standard was logged and compared to specifications to ensure the 

instrument was properly set up. A QC standard of a known analyte concentration was analyzed 

immediately after the instrument was standardized in order to verify the calibration. This QC 

standard was prepared from a different stock than the calibration standards. The values obtained 

read within 5% of the true value. After the initial QC standardization was completed, standards 

were run every ten samples to check the slope of the calibration curve. One in every ten samples 

was run in triplicate and spiked to verify analyte recovery. A QC chart was also maintained by 

the Energy & Environmental Research Center (EERC) chemist to monitor the long-term 

precision of the instrument. 

ASTM International Method D6784-01 

The ASTM International Method D6784-01 (Ontario Hydro [OH] Method) was used to 

monitor flue gas Hg concentrations and verify MM measurements. Hg species samples were 

collected at the air heater (AH) outlet and the stack at each condition, as outlined in the test plan. 

U.S. Environmental Protection Agency (EPA) methods to determine flue gas flow rate at both 

D-1 
locations were used, and EPA Reference Methods 1-5 and 17 requirements for isokinetic 

sampling were followed. The impinger trains were weighed before and after sampling to 

determine flue gas moisture. The sampling trains used in-stack filtration (EPA Method 17 

configuration) at all sampling locations. All analyses of the liquid samples collected using the 

OH Hg speciation method were performed by the EERC, either on-site or at a nearby location, 

including the field blanks and spikes. 

Presampling Preparation. All data sheets, volumetric flasks, and petri dishes used for 

sample recovery were marked with preprinted labels to ensure proper cross-referencing. The 

liquid samples were recovered into premarked volumetric flasks, logged, and then analyzed onsite or at a nearby location. Filter samples were placed in premarked petri dishes and then taken 

back to the EERC, where they were analyzed. The prestack filter samples were placed in 

premarked containers, logged, and then analyzed on-site. The labels contained identifying data 

including date, time, run number, sample port location, and the name of the sampler. 

Glassware and Plasticware Cleaning and Storage. All glass volumetric flasks and 

transfer pipets used in the preparation of analytical reagents and calibration standards were Class 

"A" as designated by federal specifications. Prior to being used for sampling, all glassware was 

washed with hot soapy water, rinsed with deionized (DI) water three times, soaked in 10% V/v 

nitric acid for a minimum of 4 hours, rinsed an additional three times with DI water, and dried. 

The glassware was stored in closed containers until used at the plant. 

Analytical Reagents. All acids used for the analysis of Hg were trace metal grade. Other 

chemicals that were used in the preparation of analytical reagents were analytical reagent grade. 

The calibration standards used for instrument calibration and the QC standards used for 

calibration verification were purchased commercially and certified to be accurate within _+0.5% 

and traceable to National Institute of Standards and Technology (NIST) standard reference 

materials. 

Blanks and Spikes. As part of QA/QC, a field blank was associated with sampling at each 

location for each test condition. A field blank is a complete impinger train including all 

glassware and solutions that is taken to the field during sampling and exposed to ambient 

conditions. These sample trains were taken apart and the solutions recovered and analyzed in the 

same manner as those sample trains used for sampling activities. The blanks were used to verify 

low background levels. 

As part of QA/QC, a field spike was associated with each OH test day. A field spike was 

prepared by the field manager at a level similar to the field samples. These sample trains were 

then taken apart, and the solution recovered and analyzed in the same manner as those sample 

trains used for sampling activities. The target range for recovery of a field spike is 20%. 

Comparison of MM and ASTM International Method D6784-01 

Analysis Results 

The ASTM International Method D6784-01, (OH method) is considered to be a reference 

method by EPA for evaluating the relative accuracy of MM results. 

D-2 
THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX E 

MAIN STACK MM DATA 
The following graphs display the mercury monitor data collected at the stack during the 

test program listed by date. All data have been corrected and are presented on a ,ttg/Nm basis. 

For days where the concentration measured was above 1000 ,ttg/Nm •, two graphs are provided: a 

graph at full scale of concentration to show the overall range and a graph at a maximum 

concentration of 1000 gg/Nm • 

to show more detail between Hgto• and Hg °. The low-scale graph 

was made standard across all days so that comparisons between days are more easily made. Data 

are not shown during the period between April 20 and 22 because of a plant shutdown. 

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APPENDIX F 

MAIN STACK DAILY AVERAGE HG 

CONCENTRATIONS 
The following graphs display the daily averaged mercury monitor data collected at the 

stack d,uring the test program listed by date. All data have been corrected and are presented on a 

gtg/Nm' basis. For days with a raw-mill-off condition, the raw-mill-on and raw-mill-off averages 

were separated. Error bars show one standard deviation. 

t::-i 
4oo] % 3501- l 

•c• 300 

• 250 

[] Total Hg [] Elemental Hg 

EERC JK30416 CDR 

200 

150 

100 

50 

No 

Testing 

8-Apt 

No 

Testing 

9-Apr 

No No 

Testing Testing 

10-Apr 11 -Apr 

Condition, date 

No 

Testing 

12-Apt 

Raw 

Mill 

On 

13-Apr 

Raw 

Mill 

On 

14-Apr 

3500 EERC JK304 7. CDR 

3000 

•2500 

2000 

500 

m 1000 0 

[] Total Hg [] Elemental Hg 

tOn15-Apr 

• Raw R Raw R• Raw R•, Raw Plant 

frill Mill I•' Mill M Mill M Mill Offline 

On, ( On O On C _•Onpro-A 16-Apr 17-Apr 18-Apr 19-Apt 21-Apr 

Condition, date 

F-2 
3500 

3000 

2500 

2000 

1500. 

1000 

500 

0 

EERC JK30418. CDR 

--liE] Total Hg [] Elemental Hg 

Mill Mill Mill 

On On On 

22-Apt 23-Apr 24-Apr 

Raw 

Mill 

On 

25-Apr 

On 

26-Apr 27-Apt 

Condition, Date 

4000 

EERC JK30419. CDR 

3500 

3000 

2500 

2000 

1500 

1000 

500 

0 

Raw Raw 

Mill Mill 

On Off 

29-Apr 

[] Total Hg [] Elemental Hg 

Raw 

Mill Mill 

On Off 

30-Apr 1-May 

Raw 

Mill Mill 

On Off On 

2-May 3-May 

Condition, date 

Raw 

Mill 

Off 

5-May 
6000 

5OOO--- 

4000 

3000 

2000 

1000 

---[ i-q Total Hg [] Elemental Hg 

Mill Mill •! • • Mill II Mill 

On Off On •f On 

6-May 7-May 8-May 9-May 10-May 11-May 12-May 

Condition,date 

400. EERC JK30421. CDR 

350 

300 

250• 

200 

150- 

100- 

50- 

Raw 

On 

13-May 

L [] Total Hg [] Elemental Hg 

No 

Testing 

14-May 

No 

Testing 

15-May 

No No 

Testing Testing 

16-May 17-May 

Condition, date 

No 

Testing 

18-May 

No 

Testing 

19-May 

F-4 
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APPENDIX G 

NATIVE MERCURY CAPTURE STATISTICAL 

EVALUATION AND SUMMARY OF MM 

VARIANCE 
SUMMARY OF MM VARIANCE 

The following analysis is intended to evaluate the variance of the mercury monitor (MM) 

measurement data and determine 1) if the magnitude of the standard deviation is considered 

statistically and practically significant and 2) if the standard deviation is consistent from run to 

run. First is determined whether the data come from a normal distribution. Next a comparison of 

the magnitude of the standard deviation and the average measurement is made followed by a 

statistical comparison of the varlances. All data are m gg/Nm corrected to 7% oxygen on a dry 

basis. 

In order to understand whether the standard deviation from each of the steady state periods 

is consistent, it must be first known whether the MM data are considered to be derived from a 

normal distribution. Some of the data sets while the raw mill is off can be considered to be from 

a normal distribution, but others cannot because there is often extra weight on one of the tails of 

the distribution. Figure G-1 shows the results of the normality test of Run Period 1, while 

Figure G-2 shows the corresponding histogram with a normality curve superimposed. If the data 

on Figure G-1 follow the plotted straight line perfectly, the data are considered normal. The 

probability plot data in some cases follow a straight line, but typically fall off at the tails. The PValue of 0.029 (<0.05) derived from the Anderson-Darling normality test indicates that the data 

are considered not normal at the 95% confidence level. 

This exercise was repeated for all of the run periods. For the data sets with the raw mill on, 

data from three of the thirteen periods can be considered to be from a normal distribution. When 

the raw-mill-off data is looked at, only one of the twelve data sets can be considered to be 

normal. It should be noted that many of the raw-mill-off data sets had very few data points and 

the accuracy of the normality test decreases with decreasing data points. Additionally, some of 

the distributions are close to normal and may be considered normal if some outlier data points 

are thrown out. However, one of the statistical tests described in the next section used to evaluate 

the standard deviation can be used with nonnormal data, so the data sets were not modified for 

the analysis. 

G-1 
EERC JK30450 CDF4 

Probability Plot of 1 

Normal 

Mean 290. 3 

st. D•. so.82 /•" 

N tgs -./-.•" 

P-Value 0.029 

100 150 200 250 300 350 400 450 

Mercury Concentration, #gl N rn3 

Figure G- 1. Normal probability plot of the mn period data. 

Histogram (with normal curve) of 1 

EERC JK304.51. CDR 

35- 

30- 

25- 

20- 

15- 

10- 

5- 

0 

200 240 

Mean 290.3 

St. Dev. 50.82 

/"-• N 195 

280 320 360 400 

Mercury Concentration, •g/Nm 3 

Figure G-2. Histogram of the run period data with a normal curve. 

G-2 
Evaluation of the variance of the data can be accomplished by comparing the standard 

deviation to the mean. While there is not a good statistical test to evaluate this, practical 

experience with MMs, mercury measurements, and emission limits can be used to understand 

what the variation might mean for emission limits and control strategies. For a normal 

distribution, 99.74% of the data points are expected to fall within _+3 standard deviations of the 

mean. In the case of Run Period 13, the data were found to be normally distributed with an 

average of 328 •ug/Nm 3 and a standard deviation of 48. Evaluating the data range at _+3 standard 

deviations shows that 99.74% of the data points will fall between 184 and 472 ug/Nm 3. The 

magnitude of the range is very close to the magnitude of the average, and the upper limit is 

2.5 times greater than the lower limit. Therefore, from a practical evaluation standpoint, the 

variation seems very significant. 

Run Period 13 can be used as a benchmark to evaluate the variance of the other run data. 

Figures G-3 and G-4 depict the 95% confidence intervals of the standard deviations calculated 

for each of the run periods. Figure G-3 shows the calculated standard deviations with the raw 

mill on, and Figure G-4 shows the standard deviations with the raw mill off. The graph shows 

that the standard deviations of each run period range from about 30 to 130 p,g/Nm 3. The 

corresponding 95% confidence intervals do not overlap in many cases, indicating that the 

variation is changing from run period to run period. Two tests were used to determine whether 

the standard deviations from run period to run period were statistically different. Bartlett's test 

and Levene's test are two common statistical tests to determine whether multiple data sets have 

equal variances. Bartlett's test can be used when the data are known to come from a normal 

distribution. Levene's test can be used on nonnormal but continuous data sets. Since many of the 

data sets were shown to be nonnormal, Levene's test is probably the better indicator. The results 

of both tests are shown in Figures G-3 and G-4. Both tests on both graphs yielded P-Values of 

0.000, meaning that at least standard deviation is statistically different than the others. 

Further evaluating the raw mill on data and using Run Period 13 as the benchmark, it is 

shown that the confidence interval for the standard deviation is similar to Run 13 on the 

remaining runs. The magnitude of the standard deviation varies significantly on several runs, and 

the confidence intervals do not overlap for many of the runs. The raw-mill-off data shows 

increased variability over the raw-mill-on data. Much of this can be attributed to a low number of 

data points and a high level of variability when high concentrations of mercury are measured. 

The noted variation is either caused by the variation of mercury levels in the plant or 

measurement problems with the MM. A RATA will determine whether the average mercury 

level over time is being accurately measured by the MM. A gauge R&R study would be needed 

to determine if the point-to-point variation is caused by the measurement system or the process. 

G-3 
13" 

2" 

3" 

4" 

5" 

6" 

7" 

8" 

9" 

EERC JK30453 CDR 

Test for Equal Variances with Raw Mill On for :•3 Run Peri,•ds 

• Bartlett's Test 

• Test Statistic 668.32 

P -Value 0.000 

Lev ene's Test 

Test S•a•c 36.73 

P-Value 0.000 

20 40 60 80 100 120 140 

95% Bonferroni confidence intervals for st devs.; unit is Hg conc. in pg/Nm 3. 

Figure G-3. Test for equal variances with raw mill on for 13 run periods 

14 

15 

16" 

17" 

18" 

19" 

20" 

21 

22 

23 

24 

25" 

EERC JK30452. CDF• 

Test for Equal Variances with Raw Mill Off for 12 Run Periods 

• Bartle•s Test 

95% 

Test S•t•c 839.37 

P-Value 0.000 

Levene's Test 

Test Statistic 36.53 

P-Value 0.000 

0 1000 2000 3000 4000 5000 6000 

Bonferroni confidence intervals for st devs,; unit is Hg conc, in pg/Nm 3, 

Figure G-4. Test for equal variances with raw mill off for 12 mn periods. 

G-4 
To determine if there is significant native mercury capture in the baghouse, the inlet and 

outlet CMM data were analyzed when no carbon injection or other mercury capture technique 

was being tested. The periods analyzed were either baseline runs or start-up conditions before 

injection. The percent mercury removal was calculated for each of the 11 baseline or startup 

conditions. The data were then compared to zero (representing no native capture) using a onesample t-test. The MINITAB output from the test is shown below. The average mercury removal 

for the periods was 1.0% with a standard deviation on 16.6%. The 95% confidence interval 

ranges from about -10% to 12%. The confidence interval crosses zero and, therefore, cannot be 

proven to be different from zero. The p-value of 0.846 is greater than 0.05 and, therefore, 

indicates that we cannot prove the average native capture is different from zero. A box plot of the 

data is also shown below, along with a more detailed explanation of the test method. 

One-Sample T: % Removal 

Test of mu 0 vs. not 0 

Variable N Mean St. Dev. SE Mean 95% CI T P 

% Removal 11 1.00000 16.59187 5.00264 (-10.14657, 12.14657) 0.20 0.846 

EERC JK304,.54. CDR 

Box Plot of °/o Removal 

(with Ho and 95% t-confidence interval for the mean) 

Ho 

-20 10 0 10 20 30 40 

% Removal 

G-5 
Stat > Basic Statistics > 1-Sample t 

Performs a one sample t-test or t-confidence interval for the mean. 

Use l-Sample to compute a confidence interval and perform a hypothesis test of the mean when 

the population standard deviation, •, is unknown. For a two-tailed one-sample t, 

H,,: !u •t., versus H,: la • •, 

where iu is the population mean and •t, is the hypothesized population mean. 

The confidence interval and t-value calculations are shown below 

Lower Confidence Limit Upper Confidence Limit 

S S 

t-value 2 + t-value 

value from student's table for •/2 and (n-l) degrees of freedom 

s sample std. deviation 

n sample size 

x sample mean 

o• alpha risk 

X--/.10 tWhere: xbar is the sample mean 

n is the sample size. 

uo is the target mean. 

s is the sample standard deviation. 

G-6 
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APPENDIX H 

CALCULATION OF A MASS WEIGHED 

POTENTIAL ANNUAL REMOVAL EFFICIENCY 
A mass weighted estimation of the potential annual removal efficiency based on Tekran 

mercury monitor (MM) measurements made at the stack was calculated using the information 

given in Table H-I. 

Table H-1. Calculation of a Mass Weighted Potential Annual Removal Efficiency 

Raw-Mill-On Annual Run Time 

Raw-Mill-Off Annual Run Time 

Average Raw-Mill-On Hg Emission, no Hg control 

Average Raw-Mill-Off Hg Emission, no Hg control 

Annualized Weighted Average Hg Emission, no Hg control 

Estimated Hg Removal Efficiency, raw mill on 

Estimated Hg Removal Efficiency, raw mill off 

Estimated Raw-Mill-On Hg Emission, with control 

Estimated Raw-Mill-Off Hg emission, with control 

Annualized Weighted Average Hg Emission, with control 

85% 

15% 

408 gg/Nm 3 

2254 ,ttg/Nm 3 

685 ,ttg/Nm 3 

90% 

63% 

41 gg/Nm 3 

834 ,ug/Nm 3 

160 •.tg/Nm 3 

Calculating the percent reduction based on the annualized weighted Hg emission yields a 

value of 77% reduction. 

The values were determined as described below: 

Average raw-mill-on and raw-mill-off emission values are taken from the MM data 

from April 15 through May 10, 2007. 

Annualized weighted average Hg emission, no Hg control (raw-mill-on annual run 

time*raw-mill-on Hg emission, no Hg control) + (raw-mill-off annual run time*rawmill-off Hg emission, no Hg control): 

(0.85*408btg/Nm 3) + (0.15*2254,ug,q',,lm 3) 685gg/Nm 3 

Estimated Hg removal efficiency, raw mill on was taken from Figure 10. 

Estimated Hg removal efficiency, raw mill off was taken from an average value taken 

from Figures 12 and 13 for removal efficiency at 5 lb/Macf. Average value of 70% and 

55% 63%. 

Estimated raw mill on Hg emission, with control average raw mill on Hg emission, no 

control*( estimated Hg removal efficiency, raw mill on) 

408 btg/Nm 3 * 0.90) 41 ,ttg/Nm 

Estimated raw-mill-off Hg emission, with control average raw mill off Hg emission, 

with control'*( estimated Hg removal efficiency, raw mill off) 

H-1 
2254 ,ttg/Nm 3 * 0.63) 834 ,ug/Nm 

Annualized weighted average Hg emission, with control (raw mill on annual mn time 

raw mill on Hg emission, with control) + (raw mill off annual mn time * raw-mill-off 

Hg emission, with control) 

(0.85"41 btg/Nm •) + (0.15 * 834 btg/'Nm 3) 160 btg/Nm 3 

Percent reduction based on the annualized weighted Hg emission (annualized 

weighted average Hg emission, with control/annualized weighted average Hg emission, 

no Hg control) 

1- ( 160 btg/Nm3/685 ,ug/Nm 3) 77% 

H-2