Transcript THE UPCOMING INDUSTRIAL BOILER & PROCESS HEATER …

UPCOMING COMBUSTION
MACT STANDARDS – Boilers,
Engines and Turbines
Dr. Robert J. Wayland, Leader
Combustion Group
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
Technical Meeting and Annual Business Luncheon
Indiana Chapter of the A&WMA
April 16, 2002
Indianapolis, Indiana
Presentation Outline
• Summarize the status of the:
– Industrial Boiler and Process Heater MACT
– Reciprocating Internal Combustion Engine MACT
– Stationary Combustion Turbine MACT
– Steam Electric Utility Generating Unit MACT
– 112(j) “MACT Hammer” Issue
Status of Industrial Boiler MACT
• Source categories included:
– Industrial Boilers
– Institutional/Commercial Boilers
– Process Heaters
• Major source MACT only
• Subcategorizing by fuel type, size, and use
Industrial Boilers plus Process Heaters ?
• Boilers and “indirect-fired” process heaters
are similar combustion devices
– Combust similar fuels to heat water (steam) or
other materials
– Both transfer heat indirectly
– Fuel-related emissions are the same
– Organic HAPs are similar
Emission Controls
• Various controls and combination are used
– Metals and particulate matter
• Fabric filters, ESP, scrubbers
– Acid gases (HCl)
• Scrubbers (Wet and Dry)
– Mercury
• Fabric filters
– Organic HAPs (Dioxins, Formaldehyde)
• CO monitoring and limit
Preliminary Subcategories
• Three main subcategories selected based on fuel type:
– Solid fuel-fired units
– Liquid fuel-fired units
– Gaseous fuel-fired units
• Additional subcategories to analyze impacts on small
businesses
– Subcategories based on size
• Greater than 10 million Btu/hr heat input
• Less than 10 million Btu/hr heat input
– Subcategories based on use
• Limited-use (less than 10% capacity factor)
• Total of 9 subcategories
MACT Floor Results
• Preliminary MACT floors based on control
technologies for existing sources
– For solid fuel boilers
• Large units -- Baghouse (metals)/ scrubber (HCl)
• Small units -- No Floor
• Limited-use Units -- ESP
– For liquid fuel units -- No Floor
– For gaseous fuel units -- No Floor
• MACT floors are actually emissions levels
MACT Floor - New Units
• Based on control technologies, state regulations,
and new source performance standard (NSPS)
• Solid and Liquid fuel units
• Large units -- Baghouse/scrubber/CO limit
• Small units -- Baghouse/scrubber
• Limited-use Units -- Baghouse/scrubber/CO limit
• Gaseous fuel units
• Large/limited use units -- CO limit
• Small units -- No Floor
• MACT floors are actually emissions levels
Preliminary MACT Floor Levels
• Based on review of emission database
• Existing large solid fuel-fired units
PM -- about 0.07 lb/million Btu
HCl -- about 0.09 lb/million Btu (90 ppm)
Hg -- about 4 lb/trillion Btu
• New large solid fuel-fired units
PM -- about 0.01 lb/million Btu
HCl -- about 0.02 lb/million Btu (20 ppm)
CO -- 200 ppm @ 3% oxygen
Hg -- about 1 lb/trillion Btu
INFORMATION AND CONTACT
• Information on the MACT rulemaking for industrial,
commercial, and institutional boilers and process
heaters is available on EPA’s web site at:
– www.epa.gov/ttn/atw/combust/boiler/boilerpg.html
• Contact: Jim Eddinger
919-541-5426 (phone)
919-541-5450 (fax)
[email protected]
Stationary Combustion Turbine (CT)
and Reciprocating Internal
Combustion Engine (RICE) MACT
RICE-Subcategories
• Emergency power/limited use
• Landfill gas or digester gas combusted as primary
fuel
• Manufacturer’s nameplate rating of  500 brake
horsepower
• Other:
– Two stroke lean burn (2SLB)
– Four stroke lean burn (4SLB)
– Four stroke rich burn (4SRB)
– Compression Ignition (CI).
RICE-Applicability
• Applies to each stationary RICE located at a major
source of HAP
• Stationary RICE meeting any of the following criteria
have no requirements except for an initial notification
requirement:
– Emergency power/limited use units
– Units that combust digester or landfill gas as
primary fuel
• Stationary RICE meeting any of the following criteria
have no requirements:
– Existing 2SLB, existing 4SLB, and existing CI
– Manufacturer’s nameplate rating  500 brake
horsepower
RICE-Emission Limitations
• Existing, New, or Reconstructed 4SRB
Stationary RICE
– Reduce formaldehyde emissions by 75% or more,
if you use NSCR, or
– Limit formaldehyde in RICE exhaust to 350 ppbvd
or less if you do not use NSCR
• New or Reconstructed 2SLB Stationary RICE
– Reduce CO emissions by 60% or more if you use
an oxidation catalyst, or
– Limit formaldehyde in RICE exhaust to 17 ppmvd
or less if you do not use an oxidation catalyst
RICE-Emission Limitations (cont.)
• New or Reconstructed 4SLB Stationary RICE
– Reduce CO emissions by 93% or more if you use
an oxidation catalyst, or
– Limit formaldehyde in RICE exhaust to 14 ppmvd
or less if you do not use an oxidation catalyst
• New or Reconstructed CI Stationary RICE
– Reduce CO emissions by 70% or more if you use
an oxidation catalyst, or
– Limit formaldehyde in RICE exhaust to 580 ppbvd
or less if you do not use an oxidation catalyst
RICE-Operating Limitations
• 4SRB stationary RICE complying with the
formaldehyde percent reduction limitation
using NSCR
– Operating limitations for catalyst pressure drop,
temperature rise across catalyst, and engine
exhaust temperature
• 4SRB stationary RICE complying with the
formaldehyde concentration limitation
– Operating limitation for operating load or fuel flow
rate
RICE-Operating Limitations (cont.)
• 2SLB, 4SLB, CI; <5000 HP; complying with
CO reduction requirement:
– Operating limitation for catalyst pressure drop and
engine exhaust temperature
– 2SLB, 4SLB, CI; complying with formaldehyde
emission limitation:
– Operating limitation for operating load or fuel flow
rate
RICE-Testing/Monitoring
• 2SLB, 4SLB, CI; <5000 HP; complying with CO
reduction requirement:
– Continuous Parameter Monitoring System (CPMS) to
monitor pressure drop and inlet temperature for
catalyst; continuously monitor and record these values
– Initial and quarterly performance tests to demonstrate
CO reduction
• 2SLB, 4SLB, CI; 5000 HP; complying with CO
reduction requirement:
– CEMS
– Initial performance evaluation and demonstration of CO
reduction
– Yearly RATA
RICE-Testing/Monitoring (cont.)
• 4SRB stationary RICE complying with the
formaldehyde percent reduction limitation
using NSCR:
– CPMS to monitor pressure drop, inlet temperature,
and temperature rise for catalyst; continuously
monitor and record these values
– Initial performance test to demonstrate
formaldehyde reduction
– If 5000 HP, semiannual performance tests for
formaldehyde; frequency may be reduced to
annually
RICE-Testing/Monitoring (cont.)
• Stationary RICE complying with the
formaldehyde concentration limitation:
– Initial performance test to demonstrate you are
meeting emission limit
– CPMS to monitor operating load or fuel flow rate;
continuously monitor and record these values
– Semiannual performance tests; frequency may be
reduced to annually
Stationary Combustion Turbine
Combustion Turbine -Applicability
• The rule will apply to each stationary
combustion turbine with a rated peak power
output greater than 1.0 MW located at major
sources, which is not:
– An emergency stationary combustion turbine
– A stationary combustion turbine burning landfill
gas or digester gas as its primary fuel
– A limited use stationary combustion turbine
(operated  50 hours per year)
– An existing diffusion flame stationary combustion
turbine
CT-Emission Limitations
• You must meet one of the following
emission limitations:
– Reduce CO emissions in the turbine exhaust by
95%, if you are using an oxidation catalyst
emission control device, or
– Reduce the concentration of formaldehyde in
the turbine exhaust to 25 ppbvd or less, if you
use means other than an oxidation catalyst
emission control device
CT-Operating Limitations
• If you comply with the emission limitation for
CO reduction, or if you comply with the
emission limitation for formaldehyde and your
turbine is lean premix or diffusion flame:
– No operating limitations
• If you comply with the formaldehyde emission
limitation and your turbine is not lean premix
or diffusion flame:
– Petition Administrator for approval of (no)
operating limitations
CT-Testing/Monitoring
• New/reconstructed turbines complying
with the emission limitation for CO
reduction:
– Install CEMS
– Initial performance evaluation
– Initial demonstration of 95% CO reduction
– Yearly RATA
CT-Testing/Monitoring (cont.)
• New/reconstructed turbines complying
with the emission limitation for
formaldehyde:
– Initial performance test using Method 320,
CARB 430, SW-846, or proposed Method
323
– Meet low NOx emission levels required by
federally enforceable permit (or guaranteed
by turbine manufacturer if no permit level)
CT-Testing/Monitoring (cont.)
• Existing lean premix turbines:
– No initial compliance requirements
– Meet low NOx emission levels required by
federally enforceable permit (or guaranteed by
turbine manufacturer if there is no permit level)
• Turbines complying with formaldehyde
emission limitation that are not lean premix or
diffusion flame:
– Petition Administrator for approval of (no)
operating limitations
Information and Contact
• Information on the MACT rulemaking for
Reciprocating Internal Combustion Engines (RICE) and
Stationary Combustion Gas Turbines is available on
EPA’s web site at:
– www.epa.gov/ttn/atw/combust/turbine/turbpg.html
– www.epa.gov/ttn/atw/combust/engine/ricepg.html
• Contact: Sims Roy
919-541-5263 (phone)
919-541-5450 (fax)
[email protected]
Utility Boiler MACT
Background -- Mandate
• Section 112(n)(1)(A) of CAA: EPA must
perform study of, and report to Congress on,
the hazards to the public health of HAP
emissions from fossil fuel-fired electric utility
steam generating units
• Based on the results of the study,
Administrator must determine whether HAP
regulations for such units are necessary and
appropriate
Background -- Determination
• EPA announced finding on 12/14/2000
– Regulation necessary for oil- and coal-fired boilers
– Regulation not necessary for gas-fired boilers
– Based on
• Public health concerns
• Mercury emissions from power plants
• Information that mercury from power plants can be
controlled
Section 112 Focus
• Most of attention has been on mercury
from coal-fired units
• Also concerned about
– Other HAP from coal-fired units
– Nickel from oil-fired units
Timing
• Settlement agreement provides for
– Proposal of section 112 regulations by
12/15/2003
– Promulgation of section 112 regulations by
12/15/2004
• Compliance date of 12/15/2007
Mercury Capture
• Hg(p) easily captured by ESPs and FFs
• Hg2+ exhibits high to low solubility and can generally be
captured in scrubbers
• Hg° is insoluble; must be adsorbed on to solids or
converted to Hg2+ for capture by scrubbing
• Hg2+ is generally easier to adsorb than Hg°
• Adsorption highly dependent on flue gas composition and
temperature
• Typical Hg2+:Hg° in flue gas: bituminous coal >
subbituminous coal > lignite
Major Conclusions of Determination Studies
• 48 tons of Hg emitted from coal-fired units in 1999
• Capture by existing equipment ranges from 0 to >90%
• Moderate to good capture for bituminous
• Poor capture for subbituminous and lignite
• Best capture for dry and wet FGD scrubbers
• Capture associated with PM controls:
FF > ESPs > PM scrubbers & mechanical collectors
• NOx controls may enhance ability to capture Hg
MEAN MERCURY EMISSION REDUCTIONS FOR
EXISTING PC-FIRED UNITSa, %
Add -On Controls
Bituminous
Type of Coal b
Subbituminous
Lignite
PM Only
CS -ESP
36
3
0
HS -ESP
11
12
NT
CS -FF
89
73
NT
PM Scrubber
12
0
33
SDA+ESP
NT
50
NT
SDA+FF
98
23
2
CS -ESP+Wet FGD
81
0
34
HS -ESP+Wet FGD
42
38
NT
CS -FF+Wet FGD
97
NT
NT
Dry FGD Scrubbers
Wet FGD Scrubbers
a. Based on OH train data. NT= not tested
b. Revised April 24
MERCURY CONTROL RETROFIT OPTIONS
Boilers and Fuels
APCD Configuration*
No. of Units
787
ESP
Boilers (1140)
Control options**
•
Sorbent Injection (SI)
* Add CFBA + SI
• PC fired- 979
• Add FF + SI
• Cyclone- 87
79
FF
• Fluid Bed- 42
•
SI
•
SI or oxidization + SI
• Stoker- 32
43
ESP
(or FF)
SDA
Coals and Fuels
• Bituminous
• SI
• Subbituminous
• Lignite
SCR
ESP
(or FF)
Wet FGD
Scrubber
143
• Add SCR + chem mods
• Mixtures
“Other” units -
• Scrubber chem mods
88
• Add reagents, catalysts,
or sorbent bed
ESP= electrostatic precipitator, FF=fabric filter, CFBA=circulating fluidized-bed absorber,
SCR=selective catalytic reduction (6 units), SDA=Spray dry adsorber
** Selected control options--other options possible. Flue gas cooling and additional ducting may be
used with sorbent injection (SI)
*
ESTIMATED FEASIBLE LEVELS OF NEAR- AND LONG-TERM
CONTROL*
PERCENT REDUCTION FROM INLET
CONCENTRATON
Existing
Technology
Current
Bitum. Subb.
Near-Term
Bitum. Subb.
ESP
FF
36
89
3
73
70
90
45
85
SDA + ESP
SDA + FF
70
95
50
25
80
90
70
80
ESP + wet FGD
FF + Wet FGD
80
90
0
75
90
90
50
85
Long-term control ranges from 85 to 95 % depending on coal and
control technologies
* Mercury control for pulverized coal-fired boilers and units with cold-side ESPs or FFs. Current
control from ICR data; Near-term control (2007-2008) is base on use of PAC; Long term
control for technologies available in 2012-2015
Information and Content
• Information on the MACT rulemaking for steam
electric utility generating units is available on EPA’s
web site at:
– www.epa.gov/ttn/atw/combust/utiltox/utoxpg.html
• Contact: Bill Maxwell
919-541-5430 (phone)
919-541-5450 (fax)
[email protected]
112(j) – The “MACT Hammer”
112(j) Basic Requirements
• If MACT standards are not issued within 18
months after scheduled date, sources must
submit a Title V permit application
• Permitting authority (i.e., State) determines
equivalent case-by-case MACT
• “Hammer Date” for 10-year MACT rules is
May 15, 2002
112(j) Rule Amendments
• Final amendments signed March 5, 2002
• 2-part application process created:
– Source must submit Part 1 (notification) on May 15,
2002, or 30 days after permitting authority notification
– Part 2 due 24 months later (in most cases, May 15,
2004)
• Permitting authority determines case-by-case
MACT equivalent to what EPA would have
established for new and existing sources
• Permitting authority issues a Title V Permit within
18 months after receiving a complete Part 2
application
Part 1 Application Content
•
•
•
•
Name and address of major source
Brief description of major source
Identification of relevant source
Identification of types of affected sources in
the relevant source category
• Identification of any 112(g) determinations
for affected sources
Part 2 Application Content
• Required
– Anticipated date of startup for new affected source
– HAP emitted by the affected source and total controlled
and uncontrolled HAP emission rates
– Applicable existing requirements for the affected source
– Control technology currently in place
– Information relevant to establishing the MACT floor
– Any other information reasonably needed/required by
the permitting authority
Part 2 Application Content (cont.)
• Optional
– Recommended MACT floor
– Recommended MACT limitations
– Description of control technologies to be
applied to meet the MACT requirements
– Information on monitoring to demonstrate
continuous compliance
Where Are We Now?
• Negotiating with EarthJustice (Sierra Club) to
establish a schedule for remaining 10-year
MACTs
• Approximately 9 of remaining 10-year MACTs
expected to be promulgated by May 15, 2002
• Most 10-year MACTs will be proposed by May
15, 2002; remaining ones by November 2002
• “Hammer” is expected to fall on approximately 31
standards, covering roughly 59 source categories
• All 10-year MACT standards expected to be
promulgated by May 15, 2004
Information and Contact
• Information on the 112(j) rulemaking is
available on EPA’s web site at:
– http://www.epa.gov/ttn/atw/112j/info/112(j)table2.html
• Contact: Rick Colyer
919-541-5262 (phone)
919-541-5600 (fax)
[email protected]