John Downs Environmental Manager, B&W PGG, KVB-Enertec Products. January 29, 2015

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John Downs Environmental Manager, B&W PGG, KVB-Enertec Products January 29, 2015

Introduction What is a CEMS? Regulatory Drivers for CEMS Quality Assurance of CEMS Summary & Question

A continuous emission monitoring system (CEMS) is the total equipment necessary for the determination of a gas or particulate matter concentration or emission rate using pollutant analyzer measurements and a conversion equation, graph, or computer program to produce results in units of the applicable emission limitation or standard. 1 1 http://www.epa.gov/ttnemc01/cem.html

What is a CEMS/DAHS? What is Emission Monitoring? Emissions Source Sample Extracted Data Flow CEMS Hardware Main Components Include: Stack Sample Probe Analyzers Flow meters Conditioning Equipment Programmable Logic Controller DAHS Software Emission Monitoring System Design Technology Software Technology Data Acquisition and Handling System (DAHS) Data Flow Data Recorded, Processed and EPA Report Generated Plant Monitoring Emissions for Site Performance Site Emission Report Electronically Delivered to Plant Manager

System Components Full Strength Extraction System Functions Sample Flow» Extraction» Conditioning» Analysis Calibration» Via Sample Lines» Direct to Analyzers Back Flush» Clears the Probe Filter» Clears the Stinger Modular Design Multi-analyzer Flexibility Simplified Maintenance Standardized Components Integrated DAHS Stack Probe Cal Gases Design Heated Sample Line Vent Moisture Sensor Ammonia Scrubber Sample Pump Sample Dryer Condensate Pump Sample Conditioner Drain Back Flush Air Turbine Controller I/O Valve Control Alarm Signals Prog. Logic Controller Calibration Panel O 2 Analyzer NO X Analyzer CO Analyzer Analyzer Rack Analyzer Output Instrument Air Supply CEMS Shelter Computer Monitor Printer DAHS Software Modem Serial I/O DAHS Equipment

System Components Dilution Extraction Design System Functions Sample Flow Stack» Dilution» Transport» Analysis Calibration» Via Sample Lines» Full System» Direct Inject Dilution Air Clean-up» Removes contaminants from dilution air» Reduces system maintenance Modular Design Multi-analyzer flexibility Simplified maintenance Standardized components Integrated DAHS Probe Freeze Protected Sample Line Cal Gases Vacuu m Gauge Dilution Control Panel Flow Control Panel Calibration Panel Dilution Air Supply Eductor Pump Air Supply Air Clean-up Panel CO2 Scrubber Charcoal Scrubber Prog. Logic Controller Prog. Logic Controller NO X Analyzer CO Analyzer CO2 Analyzer SO2 Analyzer Coalescing Filter Particulate Filter Instrument Air Supply Computer Monitor Printer DAHS Software Modem Shelter Serial I/O DAHS Equipment

Dilution CEMS Used when emissions are higher or sticky Extractive CEMS Regulatory & Process Control CFDS Coal Fired Detection Systems Opacity, particulates and stack flow monitoring Closed loop and remote emissions control DAHS USA Part 60, 63, & Part 75 (Data Acquisition and Reporting system/software) Predictive emissions monitoring systems Mercury CEMS; HCl CEMS, others

In-Situ CEMS Laser Fence-line Over time, CEMS have evolved to meet specific drivers TDL PM HG HCL

FTIR Extractive System 181 C Heated Sample Line Back Flush Air Teflon or Glass coated tubing Instrument Air Supply Stack Heated Sample Probe Probe Material: Hastelloy or Inconel Heated Sample Oven Calibration Gas Heated Sample Pump FTIR Analyzer Inferometer Gas Cell Computer: FTIR SW Exhaust Manifold Pressure Regulator Cal Gas Typical Hot/Wet Sample Conditioning System

Transmitter Flanges Receiver Detector Window Purge Cell Laser Calibration Cell Process Gas

Particulate Matter (PM) CEMS Analyzer Techniques and Suppliers Popular Techniques: Light Scattering (TML, Durag, Sick-Maihak, PCME) BETA Gauge (Durag, MSI) Other Technologies Optical Scintillation (PCME) (Commonly used for bag house leak detection) Electrification or Triboelectric (Codel, Auburn, PCME) Cannot be used for MATS Opacity monitors Optical Density (does not meet US EPA PS-11) Cannot monitor PM mass and low PM levels Opacity Monitors are adversely affected by changes in Particle size, shape, density changes

PM Measurement Methods Dust Back Scatter Extractive Back Scatter In-Situ Beta Gauge Extractive

Facilities that are subject to MATS are required to meet Hg emissions limits Methods for demonstrating compliance include: 1. Qualifying as a Low Emissions EGU 2. Installation of a Hg CEMS or 3. Install and certify Hg Sorbent trap monitoring system

Regulatory Database Stack Inertial Probe Eductor Air Air Cleanup Panel Instrument Air Supply NetDAHS Cal Gas Port (NIST traceable ) HgCl 2 Cal Gas Unit Dilution Module Sample Dilution Air Blowback Air (heated) (convert Hg +2 to Hg 0 ) Thermal Catalyst Heated Teflon Sample Extraction Line Elemental Mercury Calibration Line DI water injection DI water discharge Chiller PLC Cooling Air and Cal Gas Sample Dilution Air Bypass vent Carrier Gas Mercury Analyzer Elemental Mercury Calibration Unit (works on partial pressures of Hg) CEMS Flow Data Vent

Typical Sorbent Trap Monitoring System Paired trains required Two traps Two Sample paths

Monitored Emissions means Information Continuous Emissions Monitoring the Hardware System Design Stack Sample Probe Utilities, refineries, many other Industry Software Technology Sample Flow Signal Flow Information Flow Analyzers Flow meters Conditioning Equipment Programmable Logic Controller Data Recorded, Processed and EPA Report Generated Plant Monitoring Emissions for Site Performance Site Emission Report Electronically Delivered to Plant Manager

Introduction What is a CEMS? Regulatory Drivers for CEMS Quality Assurance of CEMS Summary & Question

Facilities install CEMS to satisfy: Permit Conditions NSPS requirements NESHAP requirements Acid Rain requirements Excess Emissions Annual Emissions Inventory requirements NBP, CAIR, CSAPR reporting Process Controls APC control

Introduction What is a CEMS? Regulatory Drivers for CEMS Quality Assurance of CEMS Summary & Question

Quality assurance (QA) is defined as an integrated system of management activities involving planning, training, quality control, assessment, data review, reporting, and quality improvement to ensure that a process, item or service is of the type and quality needed and expected by the user. QA is a management function that deals with setting policy and running an administrative system of controls to ensure the usability of the product (e.g., data).

Quality control (QC) is defined as a system of technical activities that measures the performance of a process, item, or service against a defined set of criteria or standards established by QA requirements. QC is a technical function that includes activities such as calibrations and analyses of check samples (performance evaluation samples, duplicates, spikes, blanks, etc.) to assess the bias and precision associated with sample results.

The objective of the QAP is to establish a series of QA and QC activities that will provide a high level of confidence in the data reported by the monitoring system. A QAP is typically implemented per the monitoring and reporting requirements for 40 CFR 75 and 40 CFR 60. A QAP my intentionally provide overlap and redundancy with the plant activities to ensure the highest quality data validity and availability. A QAP provides guidelines for implementing QA and QC activities.

QA plan is a contract Site owns the plan and is stating that this is how they (the site) will maintain and ensure that their CEMS data is valid. So what is in the plan? Descriptions of the QA requirements Document control Schedule of activities Procedures for conducting activities Manufactures maintenance schedules

40 CFR 60, Appendix B Each CEMS type has specifications that the system must be designed to meet and demonstrate that it meets the specifications: PS-1 Opacity PS-2 NOX and SO2 PS-3 O2 and CO2 PS-4, 4A, 4B CO PS-11 PM PS-12A & 12B Hg CEMS, Hg STS PS-18 HCL (?)

Part 60 and Part 75 specify QA requirements Limiting the QA plan to exactly what is stated in these two regulations may not result in an adequate QA Plan. Facilities must design their QA plan to meet the site conditions To meet the site regulatory drivers To ensure compliance with these drivers

Introduction What is a CEMS? Regulatory Drivers for CEMS Quality Assurance of CEMS Summary & Question

Thank you for your participation. If you have additional questions please email them directly to John Downs at jfdowns@babcock.com exclusive provider of KVB-Enertec Products & Services 2849 Sterling Drive Hatfield, PA 19440 215-996-9200 KVB-Enertec@babcock.com 2015 Babcock & Wilcox Power Generation Group, Inc. All rights reserved..28