Approach to Utility MATS August 22, 2012

Joel Millard

Environmental Regulatory Specialist KVB-Enertec Products Babcock & Wilcox Power Generation Group, Inc.

ARIPPA Annual Tech Convention

Harrisburg, PA

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Presentation Agenda

Utility MATS Overview PM Compliance Options and Cost Analysis HCL Compliance Options and Cost Analysis Hg Compliance Options Summary

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Mercury and Air Toxics Standards (MATS)

 40 CFR Part 63, Subpart UUUUU Steam Generating Units – National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility   Also known as the Utility MACT • • • • Final rule published in the Federal Register on February 16, 2012 Effective 60 days from publishing in FR (April 16, 2012) Affected sources have 3 years from this date to become compliant* Notifications of applicability were due August 14, 2012 Temporary stay of limits for new units in place. Stay in effect until November 2, 2012

*note: it appears that the EPA will grant a one year extension for sources that are showing an effort to achieve compliance

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Timeline for Compliance Mercury and Air Toxics Standard (MATS)

•

Covers Filterable Particulate Matter as a marker for heavy metals, HCl or SO 2 as a marker for acid gasses, and Mercury Nominal Compliance Deadline State Extensions Available Negotiated Enforcement Orders Possible Rule published in Federal Register Compliance Begins

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EGU Category Existing Units

Coal (Not Low) Coal (Low Rank) IGCC Liquid Oil-Cont.

Solid Oil (Coke)

NEW Units

Coal (Not Low) Coal (Low Rank) IGCC Liquid Oil-Cont.

Solid Oil (Coke)

UMATS – PM Limits

lbs/mmBTU

0.03

0.03

0.04

0.03

0.008

Lbs/MWh

0.007

0.007

0.07

0.07

0.02

PM mg/Scm

49.1

49.1

65.5

52.3

13.1

mg/Scm

1.1

1.1

11.1

NA 3.2

Total Non-Hg HAPS Metals lbs/mmBTU mg/Scm

0.00005

0.00005

0.00006

0.0008* 0.1

0.1

0.1

1.4

0.00004

Lbs/MWh

0.00006

0.00006

0.0004

0.0002* 0.0006

0.1

mg/Scm

0.01

0.01

0.06

0.03

0.10

* Includes Hg PM .5

EGU Category Existing Units

Coal (Not Low) Coal (Low Rank) IGCC Liquid Oil-Cont.

Solid Oil (Coke)

NEW Units

Coal (Not Low) Coal (Low Rank) IGCC Liquid Oil-Cont.

Solid Oil (Coke)

UMATS – HCl/SO2 Limits

lbs/mmBTU

0.002

0.002

0.0005

0.0002

0.005

Lbs/GWh

0.4

0.4

2 0.4

0.4

HCl ppm@ 3% O2

1.9

1.9

4.9

2.0

4.6

ppm@ 3% O2

0.04

0.04

0.2

0.04

0.04

lbs/mmBTU SO2 * ppm@ 3% O2

0.2

0.2

NA NA 105.5

105.5

NA NA 0.3

Lbs/GWh

0.4

0.4

0.4

NA 0.4

158.3

ppm@ 3% O2

20.5

20.5

20.5

NA 20.5

* SO2 Limit only for units with FGD .6

UMATS – Hg Limits

EGU Category Existing Units

Coal (Not Low) Coal (Low Rank) IGCC Liquid Oil-Cont.

Solid Oil (Coke)

NEW Units

Coal (Not Low) Coal (Low Rank) IGCC Liquid Oil-Cont.

Solid Oil (Coke)

Lbs/tBTU

1.2

4.0

2.5

0.05

0.2

Lbs/GWh

0.0002

0.04

0.003

0.0001

0.002

Hg ug/Scm

1.97

6.50

4.81

0.09

0.33

ug/Scm

0.03

6.30

0.56

0.02

0.32

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Presentation Agenda

Utility MATS Overview PM Compliance Options and Cost Analysis HCL Compliance Options and Cost Analysis Hg Compliance Options Summary

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What is PM ?

Particles exist in both solid and liquid Filterable and Condensable Particle sizes and shapes vary PM characteristics will vary with fuel and controls technologies Temperature and Pressure of sample also affect PM

Organic Hydrocarbons Salts Carbon Metals

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Why Measure PM?

Opacity correlates poorly to PM emissions  All States require opacity monitoring  PM CEMs can measure PM mass and low PM concentrations, which opacity monitors cannot Consent Decrees Technology now available to measure PM emissions and new EPA test standards available .10

PM Compliance Options

1. Measure using PM CEMS 2. Measure using a Continuous Parametric Monitoring System (CPMS) and perform annual compliance testing 3. Quarterly testing for PM/Non-Hg Hap Metals  PM filterable – Method 5 test - $14K  Total HAP Metals – Method 29 train - $15K/quarter  Individual HAP Metals (10) - More $$ than Method 29 test

NOTE:

Annual Compliance test not required for Option 3 .11

PM CEMS Permissible Monitor Types for MATS Compliance

    Light Scatter Scintillation Beta Attenuation Mass Accumulation

Beta Gauge Extractive Back Scatter Extractive Back Scatter In-Situ

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PM CEMS Certification

PM CEMS must initially be certified in accordance with 40 CFR Part 60, Appendix B, Performance Specification 11 (PS-11)  Test to generate a correlation curve between the particulate concentration and the unit load  Requires at least 15 Paired samples 3 loads, 5 runs per loading level  Tests are time consuming and expensive (35k-50k), and can cause problems with the state regulatory agency .13

Ongoing QA/QC procedures

Outlined in 40 CFR 60, Appendix F, Procedure 2  Absolute Correlation Audit (ACA) – Challenge the analyzer with three filters (quarterly)  Relative Response Audit (RRA) – 3 particulate tests, normal load (annual)  Response Correlation Audit (RCA) - Basically 12 run PS -11 (every 3 years) .14

PM CEMS vs. CPMS

UMATS allows for EITHER PM CEMS OR CPMS Both technologies must use Light Scatter, Scintillation, Beta Attenuation, or Mass Accumulation What is the Difference ?

CPMS – Not a certified PM CEMS – Similar technology  Parametric limit is determined from annual testing PM CEMS – Initial capital cost & testing is more $$ PM CEMS – Exempt from Opacity monitoring (Pending state approval) .15

300 250 200 150 100 50 0

PM (Dry Stack) Monitoring Options - Costs

Dry Stack - PM Monitoring Cost Comparison

Quart. Testing PM CPMS PM CEMS 1 2 3

Year

4 5 .16

400 350 300 250 200 150 100 50 0

PM (Wet Stack) Monitoring Options - Costs

Wet Stack - PM Monioring Costs

Quart. Testing PM CPMS PM CEMS 1 2 3

Year

4 5 .17

Presentation Agenda

Utility MATS Overview PM Compliance Options and Cost Analysis HCL Compliance Options and Cost Analysis Hg Compliance Options Summary

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Compliance Options

Continuously monitor HCL concentrations Continuously monitor SO 2  concentrations Coal fired sources already have SO 2  analyzers installed Requires that the source has a wet or dry FGD  Once a plant opts in to using SO 2 as a surrogate, the 0.20 lb/MMBtu limit becomes federally enforceable • some clients choosing not to use this option, due to the reduction of fuel flexibility .19

HCL

Limit is 0.002 lbs/mmBTU (~1.9 ppm) – Coal fired units Initial and Annual testing – Method 26 or 26A Initial CEMS requirements being developed - PS-18 Annual compliance tests are $14K – 3 – 1 hour runs HCl CEMS types:  FTIR – Hot, wet extractive  TDL – In-situ, cross stack/duct  Gas Filter Correlation Infra-red (GFC) – Hot, wet extractive New probes/ports required for most applications HCl CEMS have been in use for many years on waste incinerator applications .20

HCl Monitoring - Cost Comparison

$K

Capital Installation 1 st year O&M Total

FTIR CEMS

100 50 20 170

TDL

45 15 8 68

Notes:

1. Certification costs are equivalent: ~$14K 2. FTIR cost assumes 200 ft. Sample Line 3. Cost of power is excluded TDL – No sample lines required, only measures HCl TDL – Lower cost option for “ADD-ON” measurement FTIR – Capable of measuring multiple components (more flexible)

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HCl Monitoring Options - Costs

HCl Monitoring Costs

350 300 250 200 150 100 50 0 1 2 3

Year

4 5 Quart. Testing HCl CEMS .22

600 500 400 300 200 100 0 PM&HCl (Dry Stack) Monitoring Options - Costs

Dry Stack - PM&HCl Combined Costs

Quart. Testing PM CPMS&HCl CEMS PM CEMS&HCl CEMS 1 2 3

Year

4 5 .23

Presentation Agenda

Utility MATS Overview PM Compliance Options and Cost Analysis HCL Compliance Options and Cost Analysis Hg Compliance Options Summary

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Hg Compliance Options

Continuous Monitors must be installed  Two technologies currently available • Hg analyzer • Continuous Sorbent Trap Monitoring System Sorbent Trap System .25

Hg Monitoring – Technology Comparison

 Both Hg CEMS and Sorbent trap are certified using Method 30B  Hg CEMS have continuous data – Sorbent trap gives weekly updates (5 7 days, no longer than 14 days)  Sorbent trap is lower capital cost  O&M costs for each similar – Hg CEMS may be higher maintenance for some applications  Control Device for Hg is a factor in deciding continuous vs. sorbent trap .26

Hg Monitoring - Cost Comparison

$K

Capital Installation 1 st year O&M Total

Hg CEMS

220 100 30 350

Hg Sorbent Trap

90 49 37 177 Notes: 1.

2.

Certification costs are equivalent Annual certification test costs are similar 3.

4.

5.

Sample Line costs are excluded Cost of air compressor for Hg CEMS should also be considered Sorbent trap need easy access to probe location .27

Hg CEMS

Typical design is a dilution extractive system Analyzer measures elemental Hg Measurement levels are extremely low Ionic Hg is converted to elemental Hg Hg CEMS are more complex than conventional CEMS Capital, installation, and O&M costs are higher Alternative to Hg CEMS is Sorbent Trap System (non-continuous) .28

Hg Sorbent traps

 Can be used instead of CEMS measurement & also for ref. method stack tester  Uses dual train carbon traps mounted in tip of probe in stack  Hg is collected on carbon traps and sent to lab for Hg analysis (in most cases every 5-7 days)  Must measure sample flow, stack flow, and stack conditions  Issues: Loose 5-7 days of data if traps fail QA tests  Hg reading are batch sample – I.e. Non-Continuous .29

Presentation Agenda

Utility MATS Overview PM Compliance Options and Cost Analysis HCL Compliance Options and Cost Analysis Hg Compliance Options Summary

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Summary

Particulate Matter  PM CEMS   CPMS and Annual Testing Quarterly testing for PM or Non-Hg HAP Metals Hydrogen Chloride  FTIR - More accurate but more expensive  TDL- Lower cost and easier to integrate, may have some issues with data accuracy Mercury  Mercury CEMS - Costlier method, however real time data is available  Sorbent Trap System – Lower cost method, however data is not available and it is more labor intensive for the plant personnel .31

UMATS - PM & HCl Cost Comparisons If PM only is considered – PM CPMS may be the lower cost option If SO2 Limit/SO2 CEMS is not an option and HCl must be measured

 Combining Method 5 and Method 26A quarterly testing may be the lower cost option for HCl & PM  If HCl only is considered – Then HCl CEMS may be the lower cost option

Assumes a 3-4 year payback – Capital + O&M

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       

Basis of Cost Analysis

Lowest cost analyzer capital cost TDL technology utilized for HCl-CEMS Installation costs included, assuming steel stack and no platform work Includes certification, quarterly testing, and recertification every 3 years for PM-CEMS Includes initial certification and annual testing for CPMS Potential elimination of opacity O&M costs with PM-CEMS not included Estimates based on today’s dollar non-escalated Based on single stack

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Thank you!

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