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February 26, 2002 1 THE MACT PROCESS -- AND THE INDUSTRIAL BOILER & UTILITY INDUSTRY SECTORS Wisconsin Department of Natural Resources Mercury Citizens.

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Presentation on theme: "February 26, 2002 1 THE MACT PROCESS -- AND THE INDUSTRIAL BOILER & UTILITY INDUSTRY SECTORS Wisconsin Department of Natural Resources Mercury Citizens."— Presentation transcript:

1 February 26, 2002 1 THE MACT PROCESS -- AND THE INDUSTRIAL BOILER & UTILITY INDUSTRY SECTORS Wisconsin Department of Natural Resources Mercury Citizens Advisory Committee Madison, Wisconsin February 26, 2002

2 2 Presentation Outline zOverview of section 112 of the Clean Air Act zOutline the MACT development process zUtility MACT development and schedule zIndustrial Boiler MACT development and schedule zPossible mercury controls

3 February 26, 20023 Section 112 - General zContains list of 188 hazardous air pollutants (HAP) zRequires EPA to publish a list of major sources that emit HAP zRequires EPA to establish emission standards (NESHAP) for each category of major sources zAllows EPA to establish work practice requirements zMACT standards must include compliance date no later than 3 years after promulgation

4 February 26, 20024 Section 112 - MACT zMandates that EPA develop standards for HAP zStandards are based on the use of maximum achievable control technology (MACT) zSets minimum stringency criteria (MACT floor) zMACT may differ for new and existing sources zAllows for subcategorization

5 February 26, 20025 Format of Section 112 Rule zEmissions standard applicable to each source zTrading not allowed in any consideration of the level(s) of control at the floor yTrading among units at given facility allowed

6 February 26, 20026 Major Source z.. Any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants…

7 February 26, 20027 MACT Development Process zConduct an industry study zEstablish MACT floor/subcategories zDevelop control options zAssess impacts of options zPropose standards zReceive public comments zRespond to comments zPromulgate final standards

8 February 26, 20028 MACT Floor zFor existing sources yThe average emission limitation achieved by the best performing 12 percent of existing sources... zFor new sources yThe emission control achieved in practice by the best controlled similar source… zRecent court decisions will be examined for impact on how floors are established

9 February 26, 2002 9 Utility MACT

10 February 26, 200210 Background -- Mandate zSection 112(n)(1)(A) of Clean Air Act (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 zBased on the results of the study, Administrator must determine whether HAP regulations for such units are necessary and appropriate

11 February 26, 200211 Background -- Study zReport to Congress issued in February 1998 yHAP of greatest concern -- mercury from coal-fired units ySome concern from other HAP from coal-fired units and from oil-fired units

12 February 26, 200212 Background -- ICR zInformation collection request yIntended to inform electric utility regulatory determination along with health studies (e.g., National Academy of Sciences report), control option analyses, etc. yIntended to improve overall estimate of the amount and species of mercury being emitted from coal-fired utility units

13 February 26, 200213 Background -- ICR (conc.) yIdentified all coal-fired units meeting CAA definition and their control configuration yRequired all coal-fired units to analyze coal mercury content during calendar year 1999 yRequired ~85 coal-fired units to test for speciated mercury emissions

14 February 26, 200214 Background -- Determination zEPA announced finding on 12/14/2000 yRegulation necessary for oil- and coal-fired boilers yRegulation not necessary for gas-fired boilers yBased on xPublic health concerns xMercury emissions from power plants xInformation that mercury from power plants can be controlled

15 February 26, 200215 Section 112 Focus zMost of attention has been on mercury from coal-fired units zAlso concerned about yOther HAP from coal-fired units yNickel from oil-fired units zListing decision triggers section 112(g) case-by- case MACT determinations for new coal- and oil- fired sources

16 February 26, 200216 MACT Process zClean Air Act Advisory Committee Working Group yRepresentatives of industry, environmental groups, State/Local/Tribal organizations ySally Shaver, EPA, and John Paul, Dayton Regional Air Pollution Control Agency, Co-Chairs yBimonthly meetings for approximately 1 year xMeetings held August, November, December 2001; February 2002 xNext meeting -- March 4/5 in Washington, D.C. yInformation to be provided on website yOutreach and stakeholder communication

17 February 26, 200217 MACT Activities zContinuing ICR data analyses for the purpose of establishing section 112 MACT standards yPotential subcategories xBoiler type xCoal type xControl device type xOther -? yFloor determination yBest performing technology (new source MACT) yAdequacy of data

18 February 26, 200218 Coordination Activities zCoordination with ORD, DOE, EPRI, UNDEERC, etc. on current mercury control research yMore testing on existing control devices and enhancements yMore testing on SCR/SNCR installations yCoal combustion residue issues yControl device cost analyses yHg CEM activities xLong-term demonstrations on 1-2 units xShort-term demonstrations on multiple units

19 February 26, 200219 zDOE field test program yPowerSpan - multi-pollutant removal system yADA - ESP retrofit (4 sites) xAlabama Power E.C. Gaston - completed xWisconsin Electric Pleasant Prairie - completed yB&W - wet scrubber reagent (Endicott, Zimmer) yUNDEERC - hybrid electrified FF w/activated carbon yApogee - ESP tests w/sorbent injection (2-3 sites) yCONSOL - cooling system w/calcium sorbents ySouthern Co. - multipollutant sorbents yUSR Radian - oxidation catalysts zAlso research on impact of SCR/SNCR Ongoing Research Areas

20 February 26, 200220 DOE Program Information Further information on the DOE program may be found on the following websites shtml zAdditional information, including technical papers, are available on the linked company webpages

21 February 26, 200221 Additional Activities zMore sophisticated deposition analyses using REMSAD and new mercury emissions data zAnalyses using IPM looking at the costs and market impacts of a variety of potential levels of mercury control

22 February 26, 200222 Timing zSettlement agreement provides for yProposal of section 112 regulations by 12/15/2003 yPromulgation of section 112 regulations by 12/15/2004 zCompliance date of 12/15/2007

23 February 26, 200223 Website Utility MACT information located at: xAnnouncements of new postings, upcoming activities xBackground material xCoal data for 1999 xList of plants xSpeciated mercury emission test reports xSummary analyses of speciated emission data

24 February 26, 200224 Utility MACT Contact William Maxwell, U.S. EPA OAQPS/ESD/CG C439-01 Research Triangle Park, NC 27711 Phone: 919-541-5430 Fax: 919-541-5450

25 February 26, 2002 25 Industrial Boiler MACT

26 February 26, 200226 Status of Industrial Boiler MACT zSource categories included: yIndustrial boilers yInstitutional/commercial boilers yProcess heaters zMajor source MACT only zSubcategorizing by fuel type, size, and use

27 February 26, 200227 What is a Process Heater? zAn enclosed device using controlled flame and the units primary purpose is to transfer heat indirectly to a process material, instead of generating steam zProcess heaters are devices in which the combustion gases do not directly come into contact with process gases in the combustion chamber

28 February 26, 200228 Industrial Boilers Plus Process Heaters? zBoilers and indirect-fired process heaters are similar combustion devices yCombust similar fuels to heat water (steam) or other materials yBoth transfer heat indirectly yFuel-related emissions are the same

29 February 26, 200229 Potential Affected Existing Sources zTotal: 57,000 units (42,000 boilers, 15,000 process heaters) y2,500 coal-fired units y46,800 gas-fired units y700 wood-fired units y6,000 oil-fired units y1,200 mixed fuel-fired units zBased on size or co-location

30 February 26, 200230 Projected Affected New Sources zBased on DOE fuel consumption forecasts zBased on existing population data zTotal: 4,500 boilers (fifth year) y250 coal-fired boilers y100 wood-fired boilers y260 oil-fired boilers y3,900 gas-fired boilers

31 February 26, 200231 Emission Controls zVarious controls and combination are used zMetals and particulate matter yFabric filters, ESP, scrubbers zAcid gases (HCl) yScrubbers (wet or dry) zMercury yFabric filters zOrganic HAP (dioxins, formaldehyde) yCO monitoring and limit

32 February 26, 200232 Databases zInventory database (fossil fuel) zSurvey database (nonfossil fuel) zEmission database zCan be downloaded from EPAs website at: l yMicrosoft ACCESS is the database software

33 February 26, 200233 What Units Will the MACT Cover? zAll industrial boilers located at major sources zAll commercial and institutional boilers located at major sources zAll process heaters located at major sources

34 February 26, 200234 What Units Will the MACT Not Cover? zFossil fuel-fired electric utility boilers zBoilers burning municipal waste zBoilers burning hazardous waste zBoilers burning medical waste zBlack liquor recovery boilers zHot water heaters zWaste heat boilers

35 February 26, 200235 Preliminary Baseline Emissions zHCl = 66,000 tpy zLead = 175 tpy zChromium = 200 tpy zPAH = 580 tpy zFormaldehyde = 3,850 tpy zMercury = 14 tpy zParticulate Matter = 1,000,000 tpy

36 February 26, 200236 Preliminary Subcategories zMain subcategories selected based on fuel type ySolid, liquid, gaseous fuel-fired units zSubcategories to analyze impacts on small businesses ySubcategories based on size xLarge (greater than 10 MMBtu/hr heat input) xSmall (less than 10 MMBtu/hr heat input) ySubcategories based on use xLimited-use (less than 10% capacity factor) zTotal of 9 subcategories

37 February 26, 200237 MACT Floor - Existing Units zPreliminary MACT floors based on control technologies for existing sources yFor solid fuel boilers xLarge units -- Baghouse (metals)/scrubber (HCl) xSmall units -- No demonstrated emission reduction xLimited-use units -- ESP yFor liquid fuel units -- No demonstrated emission reduction yFor gaseous fuel units -- No demonstrated emission reduction zMACT floors are actually emissions levels

38 February 26, 200238 MACT Floor - New Units zBased on control technologies, State regulations, and new source performance standards (NSPS) zSolid fuel units yLarge units -- Baghouse/scrubber/CO limit ySmall units -- Baghouse/scrubber yLimited-use Units -- Baghouse/scrubber/CO limit

39 February 26, 200239 MACT Floor - New Units (more) zLiquid fuel units yLarge units -- Baghouse/scrubber/CO limit ySmall units -- Baghouse/scrubber yLimited-use units -- Baghouse/scrubber/CO limit zGaseous fuel units yLarge/limited use units -- CO limit ySmall units -- No demonstrated emission reduction zMACT floors are actually emissions levels

40 February 26, 200240 Preliminary MACT Floor Levels zBased on review of emission database zExisting large solid fuel-fired units yPM -- about 0.065 lb/MMBtu yHCl -- about 0.048 lb/MMBtu (45 to 50 ppm) yHg -- ? zNew large solid fuel-fired units yPM -- about 0.04 lb/MMBtu yHCl -- about 0.016 lb/MMBtu (15 to 20 ppm) yCO -- 200 ppm @ 3% oxygen yHg -- ?

41 February 26, 200241 Beyond the Floor Control Options zFor solid fuel boilers -- fuel switching (Hg)/CO limit zFor liquid fuel boilers -- ESP (metals)/CO zFor gaseous fuel boilers -- CO limit

42 February 26, 200242 Provisions Being Considered zAlternate metal standard yMinimize impacts on small businesses ySensitive to sources burning fuel with little metals, but emitting PM which would require control ySum of 8 selected metals: arsenic, beryllium, cadmium, chromium, lead, manganese, nickel, and selenium yWill be based on review of emission database xAbout 0.001 lb/MMBtu

43 February 26, 200243 Issues zCourt opinion from National Lime Association litigation on the Cement Kiln MACT yOpinion was that material substitution (pollution prevention [i.e., fuel switching]) should be considered in the MACT floor analysis yFuel switching is not considered an appropriate MACT floor technology for industrial boilers because xUncertain benefits Decrease in some HAP (metals, HCl) Increase in some HAP (organic HAP) xPotentially lower efficiency xFuel availability concerns

44 February 26, 200244 Schedule zProposal Summer 2002 zPromulgation Summer 2003 zCompliance date Summer 2007

45 February 26, 200245 Information zInformation on the MACT rulemaking for industrial, commercial, and institutional boilers and process heaters is available at:

46 February 26, 200246 Industrial Boiler MACT Contact Jim Eddinger, U.S. EPA OAQPS/ESD/CG C439-01 Research Triangle Park, NC 27711 Phone: 919-541-5426 Fax: 919-541-5450

47 February 26, 2002 47 Possible Mercury Controls

48 February 26, 200248 Mercury Capture zHg(p) easily captured by ESP and FF units zHg 2+ exhibits high to low solubility and can generally be captured in scrubbers zHg° is insoluble; must be adsorbed on to solids or converted to Hg 2+ for capture by scrubbing zHg 2+ is generally easier to adsorb than Hg° zAdsorption highly dependent on flue gas composition and temperature zTypical Hg 2+ :Hg° in flue gas: bituminous coal > subbituminous coal > lignite

49 February 26, 200249 Major Conclusions of Determination Studies z 48 tons of Hg emitted from coal-fired units in 1999 z Capture by existing equipment ranges from 0 to >90% z Moderate to good capture for bituminous z Poor capture for subbituminous and lignite z Best capture for dry and wet FGD scrubbers z Capture associated with PM controls: FF > ESPs > PM scrubbers & mechanical collectors z NOx controls (particularly SCR/SNCR) may enhance ability to capture Hg

50 February 26, 200250 Mean Mercury Emission Reductions for Existing PC-Fired Units a, %

51 February 26, 200251 Mercury Control Retrofit Options

52 February 26, 200252 Estimated Feasible Levels of Near- and Long-Term Control* PERCENT REDUCTION FROM INLET CONCENTRATION Existing Current Near-Term Technology Bit SubBit Sub ESP29 37045 FF89739085 SDA + ESP458070 SDA + FF93239080 ESP + wet FGD78 09050 FF + Wet FGD979085 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 based on use of PAC.

53 February 26, 200253 The Future -- Activated Carbon zExisting DOE program yielding results on what may be possible in the near- to long-term yActivated carbon injection tests conducted on two facilities to date xAlabama Power E.C. Gaston - low sulfur bituminous coal w/hot-side ESP and COHPAC unit xWisconsin Electric Pleasant Prairie - subbituminous coal w/cold-side ESP yTwo additional facilities to be tested xPG&E NEG Salem Harbor - low sulfur bituminous coal w/cold-side ESP and SNCR xPG&E NEG Brayton Point - low sulfur bituminous coal w/cold-side ESP and carbon/ash separation

54 February 26, 200254 The Future -- SCR/SNCR zTests conducted at seven units yFour with SCR xOne subbituminous coal-fired xThree bituminous coal-fired yOne with SNCR xBituminous coal-fired yTwo with ammonia injection xOne subbituminous coal-fired xOne bituminous-subbituminous coal blend

55 February 26, 200255 The Results -- Activated Carbon zE.C. Gaston tests indicated that mercury removals as high as 90% were achieved on the bituminous coal zPleasant Prairie tests indicated that mercury removals as high as 70% were achieved on the subbituminous coal but at a higher cost than was observed for 40-60% mercury removal yImpacts on potential to sell fly ash yHigher mercury removals greatly increased use of activated carbon and cost

56 February 26, 200256 The Results -- SCR/SNCR zPreliminary results yOxidation of mercury enhanced with SCR use on two of the bituminous coals yNo significant mercury oxidation enhancement with SCR use on one bituminous coal or the subbituminous coal yAmmonia injection and SNCR did not appear to enhance mercury oxidation

57 February 26, 200257 What More Could be Done? zFurther tests are yet to be conducted that will address some of the issues zModifications that could be considered to lower costs, preserve fly ash value, etc. yUse of COHPAC unit for activated carbon injection as done at E.C. Gaston - preserves fly ash in ESP yUse of ash/carbon separation techniques as will be investigated at Brayton Point - preserves both yActivated carbon modifications to make it more mercury friendly - more reactive sorbent

58 February 26, 200258 And... zMore work yet to be done yDifferent coal types yDifferent control configurations yApplications to other processes (e.g., industrial boilers) yDifferent catalysts and catalyst system designs zThere are some promising signs

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