UPCOMING COMBUSTION MACT STANDARDS – Boilers, Engines and Turbines Technical Meeting and Annual Business Luncheon Indiana Chapter of the A&WMA April 16,

UPCOMING COMBUSTION MACT STANDARDS – Boilers,

Engines and Turbines

Technical Meeting and Annual Business Luncheon

Indiana Chapter of the A&WMA

April 16, 2002

Indianapolis, Indiana

Dr. Robert J. Wayland, LeaderCombustion Group

U.S. Environmental Protection AgencyOffice of Air Quality Planning and Standards

Research Triangle Park, North Carolina

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 unitsPM -- about 0.07 lb/million BtuHCl -- about 0.09 lb/million Btu (90 ppm)Hg -- about 4 lb/trillion Btu

• New large solid fuel-fired unitsPM -- about 0.01 lb/million BtuHCl -- about 0.02 lb/million Btu (20 ppm)CO -- 200 ppm @ 3% oxygenHg -- 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, %

Type of Coal b Add -On Controls Bituminous Subbituminous Lignite

PM Only

CS -ESP 36 3 0

HS -ESP 11 12 NT

CS -FF 89 73 NT

PM Scrubber 12 0 33

Dry FGD Scrubbers

SDA+ESP NT 50 NT

SDA+FF 98 23 2

Wet FGD Scrubbers

CS -ESP+Wet FGD 81 0 34

HS -ESP+Wet FGD 42 38 NT

CS-FF+Wet FGD 97 NT NT

a. Based on OH train data. NT= not tested b. Revised April 24

MERCURY CONTROL RETROFIT OPTIONS

ESP

Control options**

• Sorbent Injection (SI)

* Add CFBA + SI

• Add FF + SI

SDA

ESP (or FF)

APCD Configuration* No. of Units

** Selected control options--other options possible. Flue gas cooling and additional ducting may be used with sorbent injection (SI)

• SI or oxidization + SI

* ESP= electrostatic precipitator, FF=fabric filter, CFBA=circulating fluidized-bed absorber, SCR=selective catalytic reduction (6 units), SDA=Spray dry adsorber

Wet FGDScrubber

• SI

ESP (or FF)

Boilers (1140)

• PC fired- 979

• Cyclone- 87

• Fluid Bed- 42

• Stoker- 32

SCR

FF • SI

787

43

“Other” units -

143

88

Coals and Fuels

• Bituminous

• Subbituminous

• Lignite

• Mixtures

Boilers and Fuels

79

• Scrubber chem mods

• Add SCR + chem mods

• Add reagents, catalysts, or sorbent bed

ESTIMATED FEASIBLE LEVELS OF NEAR- AND LONG-TERM CONTROL*

PERCENT REDUCTION FROM INLET CONCENTRATON

Existing Current Near-Term

Technology Bitum. Subb. Bitum. Subb. ESP 36 3 70 45

FF 89 73 90 85

SDA + ESP 70 50 80 70SDA + FF 95 25 90 80ESP + wet FGD 80 0 90 50

FF + Wet FGD 90 75 90 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]