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Pilot-Plant Performance Testing to Support Development of ...

Pilot-Plant Performance Testing to Support Development of a Dilution Extractive HCl Monitoring System Ty Smith Cemtek Group Inc. and Ken Greaves . Cemtek Instruments Inc Background g Cemtek is researching the concept of using a t trace level l l HCl analyzer l tto measure HCl on existing coal fired boiler CEMS. This Thi iis proposed d tto bbe an option ti ffor sources tto comply with HCl monitoring requirements in the Portland Cement MACT and Electric Utility MATS rules Conducted at the EPA's EPA s ORD facility as part of EPA's Performance Testing to inform decision making. 2. M. Many Things Thi to t Consider C id . HCl emissions i i monitoring it i iis a new requirement with its own challenges M. Multiple lti l ttechnologies h l i are available il bl with ith many ffundamental d t l differences and technical issues EPA is moving towards a Performance based Performance S. Specification ifi ti ththatt iis iinclusive l i off ththese ttechnologies h l i Low level regulatory emission limits present technical challenges HCl CEMS.

Pilot-Plant Performance Testing to Support Development of a Dilution Extractive HCl Monitoring System Ty Smith Cemtek Group Inc. and Ken Greaves . Cemtek Instruments Inc

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1 Pilot-Plant Performance Testing to Support Development of a Dilution Extractive HCl Monitoring System Ty Smith Cemtek Group Inc. and Ken Greaves . Cemtek Instruments Inc Background g Cemtek is researching the concept of using a t trace level l l HCl analyzer l tto measure HCl on existing coal fired boiler CEMS. This Thi iis proposed d tto bbe an option ti ffor sources tto comply with HCl monitoring requirements in the Portland Cement MACT and Electric Utility MATS rules Conducted at the EPA's EPA s ORD facility as part of EPA's Performance Testing to inform decision making. 2. M. Many Things Thi to t Consider C id . HCl emissions i i monitoring it i iis a new requirement with its own challenges M. Multiple lti l ttechnologies h l i are available il bl with ith many ffundamental d t l differences and technical issues EPA is moving towards a Performance based Performance S. Specification ifi ti ththatt iis iinclusive l i off ththese ttechnologies h l i Low level regulatory emission limits present technical challenges HCl CEMS.

2 Reference Methods (RMs). Quality and availability of Reference Gas Standards Practicality of associated procedures 3. EPA Research and Support Objectives E. Establish t bli h d data t supporting ti finalization fi li ti off PS. Evaluate commercial HCl CEMS (extractive only) as per Draft PS under controlled and representative emission environments Stack gas composition HCl emission i i llevels l Demonstrate suitability of candidate RMs Demonstrate status and quality of available Gas Standards Provide environment for vendors to optimize their CEMS. 4. Participating HCl CEMS. 4. 4 Commercially available, extractive C i ll il bl t ti technologies in Test Program 2 Gas Filter Correlation (GFC). 1 FTIR. 1 Dilution Extractive Trace HCl analyzer Span ranges: 0 5 ppm Over span measurement capabilities ( 100 ppm). p p ( pp ). 5. PS 18 Elements and ORD Testing Focus PS-18. Interference Tests Interference Tests Limit of Detection (LOD) Tests 7 Day Drift if Linearity RATAs Dynamic Spiking Dynamic Spiking 6.

3 Test Facility ORD's ORD s Multi-Pollutant Combustion Research Facility 4M Btu/h down-fired combustor firing coal and/or d/ NG. Multiple pollution control configurations possible SCR,ESP,FF,Wet SCR ESP FF Wet Scrubber Duct injection of gases to control emission profiles and combinations HCl, HCl SO2, NOx, CH4, CO, CO NH3, H2O, O CH2O. All CEMS and RM measurements from same basic location 7. Reference Methods Method 26A (MATS only). Paired trains Static spiking? Methods 320/321 (ASTM D6348. D6348-12. 12 too). Looking at 3 different high resolution FTIR analyzers Focus on DLs,, measurement quality q y and RM Performance p at very low HCl levels Point of reference for HCl Gas Standards 9. Testing Status Still in early stages of Testing due to extended facility maintenance All HCl CEMSs and RM FTIRs installed Vendors recently returned for final optimization Testing to date has focused on: FTIR RM measurement capabilities and Performance E l ti HCl G.

4 Evaluating Gas St Standards d d Preliminary interference tests Preliminary LOD tests Reference Method Performance While while firing on NG with HCl injection Target g HCl stack concentrations 2 pp ppm Coal combustion 20-40ppm HCl produced 10. Testing . Mostly proof-of-concept at this time Learningg and p practicing . g Mostly NG with HCL injection at Some coals, but HCl concentrations too high Dilution CEMS HCl performed well from to 38ppm Slower response time due to in in-stack stack style dilution probe used. Experience p tells us that using g an out-of-stack dilution probe will greatly speed response. RM FTIR sampled from dilution panel closely matched Trace HCl analyzer 11. Interference Testing . What gases and concentrations to test? How practical is performing the test? How do individual vs. combined gases compare? The dilution HCL performed well when tested for formaldehyde interference and none was seen seen. No interference from other gasses due to HCl specific laser used in analyzer analyzer.

5 12. LOD Testing How well does the approach work? The results below are very promising below 2ppm when h compared d tto th the EPA'. EPA's R. Reference f FTIR. FTIR. Reference FTIR HCl CEMS. 0 5 ppm Point avg 0 61. 0 57. std LOD 2 ppm Point avg std LOD ppm Point avg std LOD 13. H. HCl Concentration (ppm). 0. 05. 1. 2. 9:00:0. 09 3. 9:08:18. 9:16:3. 30. 9:24:4. 45. 20. 9:32:5. 51 ppm Target 9:41:0. 06. 9:49:2. 21. 9:57:2. 27. 10:05:4. 45. 1 98. 10:13:4. 48. FTIR HCl 10:22:0. 03. M321/ASTM. 10:30:0. 09. 10:38:2. 24. 10:46:3. 39. 2 01. 10:54:5. 54. M-26A. ppmv / wet ppmv / wet 11:03:0. 02. 11:11:15. 11:18:2. 27. 11:26:4. 42. 1 99. 11:34:5. 59. Time 11:43:0. 03. ppmv / wet HCl Avg HCl CEMS "A". 11:51:18. 11:59:3. 33. 12:07:3. 39. 12:15:5. 54. 12:24:0. 09. 12:32:17. 12:40:3. 30. 12:48:3. 36. 12:56:5. 51. Trend Data 13:05:0. 06. 13:13:12. 13:21:2. 27. 13:29:4. 44. 13:37:4. 48. 13:46:0. 03. 13:54:0. 09. 14:02:2. 24. 14:10:3. 39. 14:18:5. 54. 14:27:0.

6 00. 14:35:15. 14:43:2. 21. 14. HCl CEMS "A". Reference FTIR. 15. Gas Standards Gas Standards are needed as ppart of PS and on-going Quality Assurance operations Conventional compressed p g gases ((dry), y), evaporative (wet), and humidification of dry gases being considered NIST traceable gas standards do not yet exist (but are in the works). Reference Gas quality at low concentrations and p practicality y of use a focus of our efforts 16. Test Status Unfortunately the Tiger Optics HCl analyzer sample cell was contaminated when the sample inlet was disconnected while still under high vacuum. This is potentially a major issue in the field. Tiger Optics Analyzer was removed from the test and shipped back to the factory for cleaning & recalibration recalibration. This process takes several weeks. The next phase of the test will be performed on site at a coal fired facility to test the system response on existing dilution probes and sample lines.

7 The assumption is that dilution probes will need to be replaced with new silca coated probes. The sample lines may need to be replaced with silca coated SS. sample lines but on site Testing will confirm or rule this out. 17. Potential Issues For compliance reasons we are concerned about supplying or recommending an analyzer that can easily be contaminated on site iff the sample inlet is disconnected. Several weeks to clean, realigning and recalibrating an analyzer is unacceptable for compliance applications. Not possible to clean this in the field. Analyzer does not have the option to calibrate zero & span on site. This is done at the factory. Analyzer communications need improving. Intermittent data lost when EPA DAS polled the Tiger Optic analyzer. analyzer Tiger Optic analyzer locked up several times and had to be rebooted. 18. Future Plans . Expect to be Testing through end of CY13. Sourcing additional trace HCl analyzer suppliers. These are however very limited at this time.

8 We are evaluating 2 alternate suppliers. The goal is to have an analyzer that can be cleaned and serviced on site and wont cause a facility to be out of compliance for several weeks. Weeaalso so need eed a an a analyzer a y e tthat at will not ot be contaminated when the sample inlet is disconnected. 19. Questions . 20.


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