Utility MATS - Compliance with the Low Emitting EGU Compliance Option
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Eric Swisher of All4 Inc. explains "Compliance with the Low Emitting Electrical Generating Units(EGU) (LEE) Compliance Options". This presentation goes into both emission testing and monitoring for LEEs. Information included within this presentation explains: reduced emission testing, minimal monitoring requirements, quarterly emission testing, and monitoring (Continuous Emission Monitoring Systems (CEMS) and Parametric monitoring).
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Utility MATS - Compliance with the Low Emitting EGU Compliance Option
- 1. Utility MATS Compliance with the Low Emitting EGU Compliance Option Presented by All4 Inc. Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 117 April 8, 2013 www.all4inc.com Kimberton, PA | 610.933.5246 Columbus, GA | 706.221.7688
- 2. Utility MATS Compliance Strategies Low Emission Electrical Generating Unit (LEE) • Reduced Emission Testing • Minimal Monitoring Requirements Emission Testing • Quarterly Monitoring • CEMS • Parametric 2 Your environmental compliance is clearly our business.
- 3. Presentation Homework Hydrogen Chloride HCl • CEMS (SO2 Monitor) Particulate Matter (PM) • LEE Mercury (Hg) • LEE 3 Your environmental compliance is clearly our business.
- 4. Emission Testing Evaluate Various Emission Testing Firms • Negotiate Contracted Rates • Assess Resources Personnel Trucks/Trailers/Equipment Location(s) Reporting • Award Multiple Contracts • Start Testing Early 4 Your environmental compliance is clearly our business.
- 5. PM Testing U.S. EPA Reference Method 5 (Filterable) Initial Performance Test (LEE Qualification) • 3-Run Emission Test Program ~90-min Sampling Time Each Onsite analysis • Maximum Normal Operating Load Conditions 90 and 110% of unit design capacity • Quarterly Testing for 3 Consecutive Years Subsequent Performance Test (LEE Status) 5 Unit operating quarter (> 168 hours) 80 to 100 calendar days after the previous performance test Every 36 calendar months ~$12,000 per Test Program Your environmental compliance is clearly our business.
- 6. Hg Testing U.S. EPA Reference Method 30B Initial Performance Test (LEE Qualification) • 30-day Performance Test • Facility’s 40 CFR 75 Monitoring Systems Subsequent Performance Test (LEE Status) • Every 12 calendar months ~$44,000 per Test Program • Plant Personnel Training • Internet Access • Analysis (1 set of tubes per 5 days) 6 Your environmental compliance is clearly our business.
- 7. LEE Emission Testing Costs $800,000 LEE Emission Testing Cost $700,000 $600,000 LEE Status $55 - 70 K $500,000 $400,000 3-yr PM Testing $300,000 $117 K Annual Hg Testing $200,000 Annual Hg & Quarterly PM Testing $100,000 $0 0 10 20 30 40 Operating Quarter 7 Your environmental compliance is clearly our business.
- 8. Lose PM LEE Status Resume Quarterly PM Testing Monitoring Compliance Options • PM CEMS • PM CPMS 8 Your environmental compliance is clearly our business.
- 9. PM Compliance Option Cost Comparison $1,000,000 Operating Cost $800,000 $116 K $600,000 $400,000 $200,000 $0 0 5 10 15 20 25 30 35 40 Quarter PM CEMS 9 PM CPMS Emission Testing Your environmental compliance is clearly our business.
- 10. Lose Hg LEE Status 10 Resume Quarterly Hg Testing Install and certify Hg CEMS within 6 months Your environmental compliance is clearly our business.
- 11. Hg Compliance Option Cost Comparison $1,000,000 Operating Cost $800,000 $600,000 $400,000 $200,000 $0 0 5 10 15 Hg CEMS 11 20 Quarter 25 30 35 40 Hg Sorbent Trap Your environmental compliance is clearly our business.
- 12. Questions ? Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 117 www.all4inc.com Kimberton, PA | 610.933.5246 Columbus, GA | 706.221.7688
Editor's Notes
- Fuel switching to a “cleaner fuel” to qualify as a LEE most likely will require permitting.§63.9991(c) - Alternate SO2 limit in Tables 1 and 2 to this subpart are an option if your EGU:Has a system using wet or dry flue gas desulfurization technology (this includes limestone injection into a fluidized bed combustion unit) and SO2 continuous emissions monitoring system (CEMS) installed on the unit; and(2) At all times, you operate the wet or dry flue gas desulfurization technology installed on the unit consistent with § 63.10000(b).Dry flue gas desulfurization technology, or dry FGD, or spray dryer absorber (SDA), or spray dryer, or dry scrubber means an add-on air pollution control system located downstream of the steam generating unit that injects a dry alkaline sorbent (dry sorbent injection) or sprays an alkaline sorbent slurry (spray dryer) to react with and neutralize acid gases such as SO2 and HCl in the exhaust stream forming a dry powder material. Alkaline sorbent injection systems in fluidized bed combustors (FBC) or circulating fluidized bed (CFB) boilers are included in this definition.
- Start Testing Early - §63.10005(b) – Test results from up to 12-months prior to the compliance date (April 16, 2015) can be used.
- §63.10005(h)(2)(i) - When conducting emissions testing to demonstrate LEE status, you must increase the minimum sample volume specified in Table 1 or 2 nominally by a factor of two.PM = 2 dscm for LEE (i.e., 3 x 90-min test runs)1. The unit must be operated at maximum normal operating load conditions during each periodic performance test [40 CFR §63.10007(a)(2)].Maximum normal operating load will be generally between 90 and 110% of design capacity but should be representative of site specific normal operations during each test run [40 CFR §63.10007(a)(2)].PM performance testing must be conducted every calendar quarter which the unit operates greater than 168 hours. PM emission testing must be conducted at least once every calendar year regardless of the unit operational status [40 CFR §63.10021(d)(1)]. Performance testing required at least quarterly must be completed within 80 to 100 calendar days after the previous performance test [40 CFR §63.10006(f)