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EGU NESHAP allows for use of HAP Metal Continuous Monitoring Systems (CMS) as an Alternative to PM CEMS!


On May 7th the EPA published the Final Rule amendments for the NESHAP for EGUs. The amendments include lower limits (to 0.010 lb/MMBtu) for the filterable particulate matter (fPM) surrogate emission standard for non-mercury metal hazardous air pollutants (HAP) for coal-fired EGUs AND a requirement for sources to monitor continuously.  The final rule also lowered the limit for mercury emissions for lignite-fired EGUs and removed one of the start-up definitions that was rarely being utilized. You can find the Final Rule amendments here.  The start-up definition change won’t affect many. The lignite mercury limit will affect some.  But the requirement to monitor filterable PM continuously will be a challenge for most considering the limit is being decreased substantially and more than two-thirds of the industry does not have PM CEMS.

But, did you know that EPA left language in the final rule that allows for an alternative to this?

“Based on comments received during the public comment period, the EPA is not removing, but instead revising the alternative emission limits for the individual non-Hg HAP metals such as lead, arsenic, chromium, nickel, and cadmium and for the total non-Hg HAP metals proportional to the finalized fPM emission limit of 0.010 lb/MMBtu…Owners or operators may petition the Administrator to utilize an alternative test method that relies on continuous monitoring (e.g., multi-metal continuous monitoring system (CMS) under the provisions of 40 CFR 63.7(f).”

It’s time to seriously consider HAP Metal Sorbent Traps! A method very similar to Performance Specification 12B which many facilities use to continuously monitor for mercury.

We have been working on these HAP Metal sorbent traps for many years through the EPA SBIR Grant! To read up on the current method development, see this summary. Furthermore, EPA recently helped us to develop a Quality Control Program which outlined the performance specifications of this method for an incinerator customer.

The traps are ready to be tested at EGUs and this testing is imperative to give EGUs actionable insight on their choices for this monitoring requirement!

The amendments to this rule even created the language on how to approach continuous monitoring using HAP Metal CMS. In reality, the guidelines are very similar to PS 12B for continuous mercury monitoring. To read the language in the final rule on HAP Metal CMS, please see this article.

Please contact Alexandra if you are interested in performing testing using the HAP Metal sorbent traps. We are happy to supply traps for long-term evaluations with long-duration runs, perform analysis of these traps, and support side-by-side evaluations during your next Method 29 and/or PM test.

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