Abstracts of Presentations on CEMS & HCL MONITORING made in Track B at EUEC 2015, San Diego, CA. are listed below the summary:
B3.1 Experience using Cavity Enhanced Absorption Spectroscopy (CEAS) for HCl Measurement on a Coal-fired Power Plant
Steve Gibbons, Business Development Manager, ABB Inc.
Regulations recently promulgated by the Environmental Protection Agency (EPA) require qualifying
Power and Cement plants to control and monitor Hydrogen Chloride (HCl) emissions. HCl must be
measured at very low concentrations (often below 1ppm), is highly soluble in water and suffers from
adsorption and desorption effects with certain materials (e.g. PTFE). NH3 in the flue gas can form several
salts. In the case of an extractive system, if the temperature of the sample drops below the sublimation
point of these salts (e.g. ABS 297°F), build-ups can occur. These salts can cause hang-up effects to HCl
and other flue gas components. The use of dilution-extractive systems, commonly employed for CEMS
in the Coal- and Oil-fired power industry and for most Mercury (Hg) CEMS as well, alleviates many of
these challenges by lowering the dew point of the sample. However, a dilution system depends on
the availability of an analyzer with the required sensitivity. Cavity Enhanced Absorption Spectroscopy
(CEAS) combines the benefits of coherent light sources (i.e. lasers) with a very long optical path
length (~12 miles) achieving detection limits below 1ppb for HCl and a range of other components.
A particularly effective variant of this scheme is Off-Axis Integrated Cavity Output Spectroscopy (Off-
Axis ICOS) technology from Los Gatos Research, acquired by ABB in 2013. Recent trials at Coal-fired
power plants demonstrate that the LGR Off-Axis ICOS HCl analyzer is a viable alternative to more
conventional techniques (e.g. FTIR, TDL), offers higher relative accuracy for HCl measurements below
1ppm and is suitable for retrofit to existing dilution-extractive systems with various dilution ratios and
sample line lengths. Results from these trials will be presented in detail for discussion.
B3.2 Tunable Diode Laser (TDL) Based HCl CEMS Development Challenges & Monitoring Technologies to Meet Performance Specification 18
Gary Cacciatore, Business Develpoment Manager, Cemtek Environmental
Cemtek has been involved with the EPA’s stakeholders group to develop the performance specification
for HCl monitoring systems to comply with the Portland Cement MACT rule as well as Utility MATS.
This presentation will exhibit results of multiple demonstration tests & the challenges of developing
a continuous emissions monitoring system (CEMS) for HCl for utility coal fired boilers & cement kiln
applications. Data from a continuous demonstration trials in which a tunable diode laser (TDL) system
was operating on a utility coal boiler & a cement kiln will be presented, including initial certification
testing requirements & RATA results.
B3.4 Hydrogen Chloride Monitoring by FTIR
Kevin Ramazan, VP of FTIR Operations, California Analytical Instruments
With the introduction of the Portland Cement MACT & Utility Boiler MACT, the measurement of acid
gases such as HCl & HF have been brought to the forefront as a surrogate measurement for various
Hazardous Air Pollutants (HAPS). FTIR is an excellent tool to measure HCl on a continuous basis as
required by these new rules. This presentation will examine data generated from a cement kiln(s)
& municipal waste incinerator & what lessons we can take forward into the utility industry for the
measurement of HCl & other acid gases.
B3.5 Continuous Emissions Monitoring of HCl: Sampling System Design and Operation Considerations
Roberto Bosco, Principal Applications Engineer, MKS Instruments; Barbara Marshik
Recent EPA regulations call for extremely stringent limits for HCl emissions from Portland cement and
Electric Generating Units (EGUs). The new regulations impose 3 ppmv and 1 ppmv limits for cement
plants and EGUs respectively (dry at 7% O2) and continuous monitoring is required. Measurement of
HCl for these applications requires not only a sensitive analyzer but one that has a high dynamic range
to cover gas excursions. The MKS Instruments line of FTIR analyzers exceed these requirements with
both the MultiGas 2030 CEM and 2030 CEM HiSens analyzers, the latter achieving detection limits as
low as 30 ppbv for HCl. Thorough sampling system design and operational procedures are equally as
significant as having a sensitive analyzer. Since HCl is a water soluble and adsorbent gas, substantial
losses of HCl can be associated with dissolution into water and adsorption on wetted surfaces. For
extractive gas analyzers, the materials used in the calibration lines and sample lines play an extremely
important role in the ability to transfer the HCl gas (wet or dry) while still maintaining acceptable system
response times. Typical materials used for continuous emissions monitoring systems (CEMS) such as
stainless steel, fluoropolymers, and plastics are explored to determine the best choice when sampling
for HCl. Humidification of HCl calibration gas as allowed by the proposed Performance Specification 18
(PS18) is also explored to determine its effect on system response time during calibration.
B4.1 A Dilution Calibrator Designed To Minimize Source Testing Gas Cylinder Costs While Improving On-Site Flexibility
Doug Haugen, Product Manager, Teledyne API; Ray Jalisi
A gas dilution system has been developed that allows gas blending from multiple cylinders, builds
known low-level calibration gases from high-level calibration gases with a degree of confidence similar
to that for Protocol gases, & produces NO2 via GPT (Gas Phase Titration) using NO cylinder gas for
converter efficiency tests at any points up to 100 ppm. The Teledyne API Model T700H may be used
for compliance tests in lieu of multiple calibration gases when the system is demonstrated to meet
the requirements of Method 205. The T700H allows stack testers to inventory & transport a drastically
reduced number of stock cylinders to the job site, creating virtually unlimited concentrations as
needed, including custom blends. Using Gas Phase Titration to “build” NO2 on site provides increased
accuracy & flexibility vs. bottled NO2 for converter efficiency testing.
B4.2 Cost Effective Remote Sensing of the Upper Altitude Wind Field & Inversion Heights
Kenneth Underwood, President, Atmospheric Systems Corporation
Atmospheric Systems Corporation has deployed several SoDAR systems for the purpose of measuring
upper leave wind fields. The data obtained from these systems is extremely useful for the prediction
& monitoring of surface based concentration of particulates & pollution. & the understand of the
processes that lead to the elevated concentrations. These SoDAR units have been coupled with the
surface based PAM unit for some of these studies. Dr. Underwood will present a full description of
these systems, detail the performance of these systems & describe the value added to surface based
B4.3 Top Ten To-Do Items for a Successful Emission Test or RATA, & the Bottom Ten Not-To- Do, for Mercury, HCl, PM, NOX & Other Monitors or Emission Limits
Kevin Crosby, VP, Technical, Montrose Environmental Group, Inc.; Judith Aasland
Emissions must be tested, measured or monitored. Time and cost must be saved, yet the unit must
pass the test or the RATA or trouble will ensue. This presentation will provide managers, engineers and
operators with practical information on how to specify the right tests, qualify proposals and test plans,
prepare your site, CEMS and personnel for the testing program, complete a successful test and get
a worry-free test report. Example data and results will be used to illustrate what can go wrong, what
should be right, and how to tell the difference.
B4.4 How Much Uncertainty is there in an Stationary Source Test?
Robert Davis, Project Director, TRC Solutions
In this paper we will be demonstrating the basic tools (gases, sample lines, probes) and personnel
(stack testers, and their credentials) behind an average emissions source test, and the uncertainty
behind each part of the test. This will prepare the end user to understand how much uncertainty
each tool and person responsible for the test adds to the certainty of the results of the test. In the
end the audience will be able to develop a check list to reduce uncertainty and provide a better
understanding of what they can do to control the quality of the test and the ability to set up their next
required emissions test to assure compliance and much more accurate results with assurance of a
better test. This will also provide the state observers with a better understanding of the industry and
where to find actions and tools that could provide less accurate results.
B4.5 EPA Alternative Method 082 Digital Opacity
Shawn Dolan, President, Virtual Technology LLC
The presentation will provide a status update to EPA Alternative Method 082 (ALT 082) & its use in
the evaluation of visible emissions throughout the electric utility industry. The presentation will explain
the history of ALT 082 as well as case studies explaining the cost effectiveness of the method when
compared to Continuous Emission Monitors & EPA Method 9. The presentation will detail two cases
were ALT 082 was used in lieu of CEM’s & Method 9 to satisfy visible emission monitoring requirements.
The presentation will conclude with examples of remote monitoring performed around the globe from
Arizona using ALT 082, in a cost effective, accurate & defendable manor.
B5.1 The latest Tips & Tricks for Getting the Best Mercury Results Using Sorbent Traps
Philip Dufresne, President, ALL BLUE
Even after almost a decade of analyzing sorbent traps for mercury, new challenges arise & solutions
become clear that I should have thought of years ago. I will share the latest tips & tricks for analyzing
sorbent traps for mercury that will help you obtain accurate & precise measurements & also make the
job easier. Additionally, I’ll throw in some common pitfalls to avoid.
B5.2 Sorbent Trap Innovations: SO3, NH3, HCl
Andrew Mertz, Lead R&D Chemist, Ohio Lumex; Joseph Siperstein & Anthony Schneider
Over the last two years, Ohio Lumex has developed several new analytical and sampling techniques
which utilize sorbent traps to effectively sample gaseous components from stationary sources. All of the
novel methods which measure sulfur trioxide, ammonia, and hydrogen chloride conveniently utilize ion
chromatography for the analysis. These recent developments, when added to existing sorbent trap
methods for both total and oxidized mercury, provide the coal-fired utility industry with valuable, yet
economical tools for understanding flue gas chemistry as it applies to pollution control technologies.
More specifically, the traps can be used to monitor and fine-tune control technology performance,
spot check continuous emissions monitors, as well as to indicate compliance. Supporting data from
recent field trials will be presented.
B5.3 Gas Turbine Regulatory Regulations with a Focus on CEMS & Part 75 Update
Ben Sehgal, Senior Air Resource Engineer, California Air Resource Board
Gas turbine regulatory regulations with a focus on Continuous Emissions Monitoring and 40 CFR Part 75
updates from EPA. More details can be provided later.
B5.4 Forum on low level emissins testing with CARB
Robert Davis, Project Director, TRC; Ben Sehgal, CARBl; Bernadette Shain,CAI; Bob Finken, Montrose
In this paper I will add to the discussions of the other presenters considering the gas requirements and
best practices to use when selecting and using EPA protocol gases that now are required to have a
PGVP number. There are many requirements for gases as well there are potential issues when using
them that could create problems. I will discuss in my part of the forum about the gases.
B5.5 FORUM ON LOW LEVEL EMISSIONS TESTING WITH CARB
Bernadette Shahin, National Applications Manager, M&C TechGroup; Ben Sehgal CARB; Bob Davis
TRC; Bob Finken, Montrose
NOx Analyzer and Sampling Uncertainty at sub 2 ppm Levels. Uncertainty at the sub 2ppm NOx
measurement level with has become more of an issue as permits are being written at lower levels.
The NOx gas that is sampled, delivered, conditioned, analyzed, and calibrated present uncertainty in
the final reported results when measuring at these low levels. This presentation/discussion will provide
insight into analyzer limitations, gas interferences, proper sampling at the probe, delivery, conditioning,
calibration and RATA testing and how each becomes more critical when measuring at these lower