demonstrating mats compliance...mats rule sets limits based on new or existing source and fuel type...

John Downs Environmental Manager, B&W PGG, KVB-Enertec Products

January 29, 2015

Introduction

MATS Notifications & Submittals

MATS Performance Tests

Boiler Tune-ups

40 CFR Part 63, Subpart UUUUU – National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units

Also known as MATS – Mercury and Air Toxics Standards

Published in the Federal Register on May 3, 2011

Finalized and published in FR on February 16, 2012◦ Effective Date: April 16, 2012

Affected sources have 3-years to comply – April 16, 2015◦ Potential for 1-year extension

Coal- and oil-fired power plants are covered by this rule

All hazardous air pollutants must have standards

EPA must set emission standards for existing sources in the category that are at least as stringent as the emission reductions achieved by the average of the top 12% best controlled sources for source categories with 30 or more sources

Mercury: numeric emission limit would prevent 91% of mercury in coal from being released to the air

Acid gases: HCl numeric emission limit as a surrogate, with an alternate surrogate of SO2

Non-mercury metallic toxic pollutants such as arsenic and chromium: numeric emission limit for total PM as a surrogate, with alternate surrogate of total metal air toxics

Organic air toxics (including dioxin): Work practice standards, instead of numeric standards, due to low-detected emission levels. Would ensure optimal combustion, preventing dioxin/furan emissions

MATS rule sets limits based on New or Existing source and

Fuel Type Category1. Coal–fired, not low rank virgin coal

2. Coal-fired, low rank virgin coal

3. IGCC unit

4. Liquid oil-fired, continental (excluding limited-use liquid oil-fired)

5. Liquid oil-fired, non-continental (excluding limited-use liquid oil-fired)

6. Solid oil-derived fuel-fired

MATS requires both initial and on-going demonstration of compliance.

Limits are exclusive – must demonstrate compliance with each limit◦ PM

◦ Hg

◦ HCl or SO2 as surrogate

How is compliance accompished?

MATS requires initial and on-going proof that you are in compliance.

HOW DO YOU DO THAT? Initial notifications

Notification of applicability

Notification of performance evaluations

CEMS / Sorbent Traps

Performance testing

LEE testing

Notification of Compliance Status

Data submissions….

Notification Type When How Submitted

Notification (of MATS Applicability)

8/14/2012 Hardcopy by mail

Notification of CMS Performance Test -Includes RATA for Hg ST and SO2 as surrogate for HCl on units using this, and/or PM CEMS for units using PM CEMS

60 calendar days prior start of performance test

Hardcopy by mail

Notification of Performance Test

60 calendar days prior start of performance test

Hardcopy by mail

Notification of Compliance Status

60 days after completion of each performance test

Electronically via CEDRI

Submittal Type When How Submitted

Site-Specific Test Plan (Performance Test Plan)

**** Hardcopy

Site-Specific Performance Evaluation Plan (for CMS)

60 days before test is scheduled to begin

Hardcopy by mail

Results of Performance Tests

60 days after completion of each performance test

Electronic via ERT/CEDRI

Hg CEMS, Hg STS, HCl CEMS, SO2 CEMS QA Results

30 days After Completion of Calendar Quarter

Electronic via ECMPS

Compliance Report 1/31/2016 Hard copy by mail OR electronically via CEDRI

Submittal Type When How Submitted

MATS Monitoring Plan 60 days before initial performance evaluation of CMS

If Requested –Hardcopy by mail

Electronic Monitoring Plan

21 days prior to compliance date –March 26, 2015

Via ECMPS

Subsequent Compliance Reports akaSemi-Annual Compliance Reports

7/31/2016 or May be coordinated with Title V permit Semi-Annual/ Annual Compliance Report

Hard copy by mail OR electronically via CEDRI

As with many regulations, MATS requires quite a large amount of recordkeeping:◦ Copies of all notifications that have been submitted

◦ Records of:

Performance Stack Tests

Fuel Analyses

Other compliance demonstrations and performance evaluations

◦ For CEMS and CPMS:

All times when CEMS/CPMS is out of control

All measurements needed to demonstrate compliance

CEMS (cont.)◦ All results of performance tests, CMS performance

evaluations, and opacity and visible emission observations

◦ All measurements as may be necessary to determine the conditions of performance tests and performance evaluations

◦ All CEMS calibration checks

◦ All Adjustments and maintenance to CEMS

◦ All, even superseded performance plans (test protocols)

CEMS (cont)◦ Requests for alternatives to RATAs

◦ Records of data and time each deviations started and stopped, and whether occurred during SUSD or malfunction.

Monthly Fuel use, including type and amount used◦ Including clean fuels used during startup

Records of each startup and shutdown◦ Records of the determination of the maximum clean

fuel capacity

Added as result of petitions to reconsider definition of Start up:◦ Basic items:

Date and time of clean fuel use for start up

Quantity of and HI of clean fuel used

Electric load for each hour of start up

Date and time that non-Clean fuel begins

◦ Facilities that do not use PM CEMS or PM CPMS must also: Record temperature and flow rate of post-combustion

exhaust and amperage of forced draft fans upstream of PM APCD

Record temperature and flow rate of exhaust gas and amperage of induced draft fan(s) downstream of each filterable control device during each hour of startup

ESP: Record the number of fields in service, each field's secondary voltage and secondary current

FF: Number of compartments in service, DP across the baghouse during startup

Wet Scrubber: Record scrubber liquid to fuel ratio and DP of liquid

Introduction



Boiler Tune-ups

MATS affected units must be in compliance by April 16, 2015*

63.9984(f) allows subject facilities 180 days after applicable date to demonstrate compliance.

How is this done?

You must conduct initial performance tests and one or more of the following:◦ Fuel analysis, for each type of fuel

◦ CMS (i.e. CEMS or CPMS) performance evaluations where applicable

◦ Sorbent Trap monitoring system performance evaluations where applicable

You must establish a site specific operating limit

For fuel analysis, you must determine the maximum chlorine, Hg, non-Hg HAP, and fluorine for each applicable limit the fuel mix that provides the highest concentration of tested parameter

Coal/solid fuel: Initial performance testing must be done for all pollutants covered by this rule-63.10000(c)(1)

Liquid Oil fuel: Initial performance testing must be done for HCl, HF and total HAP metals covered by this rule- 63.10000(c)(2)

For non-Hg HAP metals:

◦ Use PM CEMS for initial compliance

◦ Compliance determined by establishing an operational limit for filterable PM – obtained during total PM testing

Alternative to PM CEMS:

◦ Conduct total HAP testing or

◦ Individual non-Hg Metal testing

For Mercury (Hg) :

◦ Initial compliance and continuous compliance requires Hg CEMS or

◦ Sorbent Trap System

◦ Unless unit qualifies as Low Emitting EGU (LEE) 63.10005(k)

LEE is defined for Hg as unit that emits:

Less than 10% of Hg emissions limit or

Less than 29.0 lbs of Hg per year

For HCl:

HCl is used as a surrogate for Acid Gases

◦ Initial compliance is demonstrated through use of an HCl CEMS

◦ Alternatively, you may demonstrate compliance by conducting performance tests

Or

◦ Use of SO2 CEMS, but only if EGU has a wet or dry FGD

For all pollutants tested, must follow 63.7

(c) Quality Assurance Program

◦ Develop and Submit a site specific test plan

◦ Use of AASP (Accredited Audit Sample Provider)

◦ See Table 5 and/or http://www.epa.gov/ttn/emc for test methods and Performance Specifications

(d) Testing facilities

(f) Request with documentation permission to use alternate testing methods

(h) Must receive written waiver approval granting permission to not perform any required PT

http://www.epa.gov/ttn/emc

Compliance by use of a CMS (includes CPMS and CEMS or Sorbent Trap System) requires◦ Development of Site specific Monitoring Plan completed

at least 60 days prior to initial performance testing◦ Submit plan to Agency, if requested ◦ Site specific monplan does not apply to sources that

have existing monitoring plan under Part 60 or Part 75*

◦ Monplan specifics found under 63.10000(d)(7)(1) (7)

CEMS demonstration is first 30 days of operation after certification testing

*Rule only appears to address SO2 monitoring requirements, but should apply to PM CEMS, Hg CEMS, Sorbent Trap Systems, HCl CEMS etc.

On going compliance proof requires installation of CEMS and combination of fuel analysis and stack testing

There are different requirements depending on how you demonstrate initial compliance

You must monitor and follow your site specific monitoring plan.

Reconsideration (11/19/2014) sets separate WPS depending on which startup option facility elects to follow:

Option 1leaves SU definition as stated in original rule

Option 2 allows for a 4-hour exclusion, but sets restrictions that some APCD cannot meet within the strict definition of this option

• Not all data is reported

• Records must be kept –• On site for at least two years• Must be kept for 5 years – but can be moved off site

after 2

• Copies of each Notification and Report submitted• Including supporting documentation

• CEMS information:• Previous or superseded Performance Evaluation Plans• Records and date of each deviation • All items in Table 7 of MATS

Introduction



Boiler Tune-ups

All EGUs must have a performance tune-up performed:

◦ Burner Inspections

◦ Inspect Flame Patterns to ensure optimization

◦ Air-to-fuel ratio inspection

◦ Optimize total CO and NOx emissions

EGU performance tune-up continued:

◦ Measurements of both CO and NOx before and after adjustments required

◦ Description of adjustments

◦ Records of fuel combusted for 12 months prior to adjustment

◦ Submit notification to Delegated Authority of completion of tune-up and adjustments

When is the Performance Tune-up required?:◦ It is required to be done as part of your initial

compliance demonstration, but◦ The burner inspection may be delayed until the next

unit outage provide requirements in 63.10005 are met.*

When must you perform subsequent tune-ups and inspections?:◦ You must perform burner inspection at least once

every 36 months unless◦ You utilize a neural network combustion optimization

system in which case you must perform the burner inspection at least once every 48 months

What does the inspection/tune-up involve:◦ Inspect the burner and combustion controls, as

applicable,◦ Clean or replace any components of the burner or

combustion controls as part of your work-practice program and at least once every inspection period

If the inspection indicates that repairs or parts need to be replaced, what then?◦ If component parts affect the ability to optimize NOX

and CO, the parts must be replaced within 3 months of the inspection

If component parts do not affect the ability to optimize NOX and CO emissions, parts may be replaced on a schedule that you (the Operator) determines

The Inspection must include (as applicable) the following items and may require these actions:◦ Flame Pattern

Make adjustments to the burner or combustion controls to optimize the flame pattern Follow burner manufacturers specifications or Make adjustments in accordance with best combustion engineering

practice for the burner type

◦ Observe Damper operations Do this as a function of:

Mill and or cyclone loadings, Cyclone and pulverizer coal feeder loadings, Or other pulverizer and coal mill performance parameters

Make adjustments/repairs, as applicable, to: Dampers, Controls, Mills, Pulverizers, Cyclones, and/or Sensors

◦ Evaluate Windbox pressures and air proportions Make adjustments/Repairs as appropriate to:

Dampers, Actuators, Controls, and/or Sensors

◦ Inspect system controlling the air-to-fuel ratio Ensure that it is correctly calibrated and functioning properly Inspection may include calibration of excess O2

probes/sensors Inspection may include adjusting overfire air system Inspection may include changing software parameters Inspection may include calibrating actuators and/or dampers

to ensure that system operates as designed Note that any component found to be out of calibration, in

or near failure, or in a state that is likely to negate combustion optimization efforts prior to the next tune-up should be corrected or repaired at this time.

NOX/CO Optimization – optimize combustion to minimize generation of CO and NOX◦ Optimization should be consistent with manufacturers

specs. NOX Optimization includes:

Burners Overfire air controls Concentric firing system improvements Neural network or control efficiency software Control system calibrations Adjusting combustion zone temperature profiles Add on controls such as SCR and SNCR

CO Optimization includes: Burners Overfire air controls Concentric firing system improvements Neural network or control efficiency software Control system calibrations Adjusting combustion zone temperature profiles

◦ Measure NOX and CO, in ppm by volume, while operating at full load or at the predominantly operated load before the tune-up adjustments, and

◦ Measure NOX and CO, in ppm by volume, while operating at full load or at the predominantly operated load after the tune-up adjustments.

Before and after measurements must be made on a consistent basis, either wet or dry

Portable CO, NOX and O2 monitors may be used

Values need to be recorded before and after each adjustment throughout the optimization process.

If you use a neural network, you need only to proved a pre- and post- tune-up value rather than values for each adjustment made throughout the process

What do I do with results:◦ Create a report that contains the results of all task listed above (See

63.10021(e)(8)) that contains: CO and NOX concentrations in PPM and O2 percent measured

before and after each adjustment to combustion systems Description of any corrective actions take as part of combustion

adjustment Types and amounts of fuel used of the 12 calendar months prior to

an adjustment, BUT ONLY IF the unit was physically AND legally capable of using more than one type of fuel during the period.

◦ Maintain a copy on site and ◦ Submit a copy to the delegated authority (this will be either through

CEDRI, through ECMPS as PDF attachment, or by hardcopy to the state) If first tune-up is part of initial compliance demonstration, submit

as part of your Notification of Compliance package in both Hardcopy format and

Electronically as part of the initial Notification of Compliance package submission and should include: The date of the most recent tune-up and

The date of the most recent burner inspection if it was not done annually and was delayed until the next unit outage (scheduled unit shutdown)

Introduction



Boiler Tune-ups

Questions??

demonstrating mats compliance...mats rule sets limits based on new or existing source and fuel type...

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