reporting 3 continuous emission monitoring system (cem… · emission minimization plan for...

1. OPERATING PHILOSOPHY ......................................................................................................................... 3 2. REPORTING ................................................................................................................................................... 3 3. CONTINUOUS EMISSION MONITORING SYSTEM (CEM) .................................................................... 4

3.1. Description ............................................................................................................................................... 4 3.2. Operation.................................................................................................................................................. 4 3.3. Critical Criteria ........................................................................................................................................ 5 3.4. Inspections ............................................................................................................................................... 7 3.5. Maintenance ............................................................................................................................................. 8 3.6. Spare Parts ............................................................................................................................................... 8 3.7. Abnormal conditions or malfunction: ...................................................................................................... 8 3.8. Abatement Measures ................................................................................................................................ 9 3.9. Time Frame for Abatement Measures ...................................................................................................... 9

4. ELECTROSTATIC PRECIPITATOR........................................................................................................... 10 4.1. Description ............................................................................................................................................. 10 4.2. ESP Interior Parts ................................................................................................................................... 10 4.3. ESP External Parts ................................................................................................................................. 11 4.4. Operation................................................................................................................................................ 11 4.5. Theory of Operation ............................................................................................................................... 11 4.6. ESP Operation ........................................................................................................................................ 12 4.7. Critical Criteria ...................................................................................................................................... 12 4.8. Inspection ............................................................................................................................................... 13 4.9. Maintenance ........................................................................................................................................... 14 4.10. Spare Parts ......................................................................................................................................... 14 4.11. Abnormal conditions or malfunctions ................................................................................................ 14 4.12. Abatement Measures .......................................................................................................................... 15

5. SELECTIVE NON-CALALYTIC REDUCTION SYSTEM (SNCR) .......................................................... 16 5.1. Description ............................................................................................................................................. 16 5.2. Operation................................................................................................................................................ 16 5.3. Critical Criteria ...................................................................................................................................... 17 5.4. Inspections ............................................................................................................................................. 18 5.5. Maintenance ........................................................................................................................................... 19 5.6. Spare Parts ............................................................................................................................................. 19 5.7. Abnormal conditions or malfunctions .................................................................................................... 19 5.8. Abatement Measures .............................................................................................................................. 19 5.9. Time Frame for Abatement Measures .................................................................................................... 20

6. MECHANICAL DUST COLLECTOR ......................................................................................................... 21 6.1. Description ............................................................................................................................................. 21 6.2. Operation................................................................................................................................................ 21 6.3. Critical Criteria ...................................................................................................................................... 21 6.4. Inspections ............................................................................................................................................. 22 6.5. Maintenance ........................................................................................................................................... 22 6.6. Spare parts .............................................................................................................................................. 22 6.7. Abnormal conditions and malfunctions ................................................................................................. 22 6.8. Abatement measures .............................................................................................................................. 23 6.9. Time Frame for Abatement Measures .................................................................................................... 23

7. BOILER ......................................................................................................................................................... 24 7.1. Description ............................................................................................................................................. 24 7.2. Operation................................................................................................................................................ 25 7.3. Critical Criteria ...................................................................................................................................... 25 7.4. Inspections ............................................................................................................................................. 26 7.5. Maintenance ........................................................................................................................................... 27 7.6. Spare Parts ............................................................................................................................................. 27 7.7. Abnormal conditions, malfunctions, and startup and shutdown ............................................................ 27 7.8. Abatement measures .............................................................................................................................. 28 7.9. Time Frame for Abatement Measures .................................................................................................... 29 8.1 Description ............................................................................................................................................. 30 8.2 Operation................................................................................................................................................ 30 8.3 Critical Criteria ...................................................................................................................................... 30

Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

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8.4 Inspections ............................................................................................................................................. 31 8.5 Maintenance ........................................................................................................................................... 31 8.6 Abatement Measures .............................................................................................................................. 31

9. MATERIAL HANDLING ............................................................................................................................. 31 9.1 Description ....................................................................................................................................................... 31 Attachments

1. Opacity Monitor

2. Nox Analyzer

3. CO Analyzer

4. O2 Analyzer

5. CEM system Drift Forms

6. CEM spare parts list

7. Boiler startup and natural gas light off

8. Boiler startup wood light off

9. Nox reduction system startup procedures

10. Spare parts for Nox system (SNCR)

11. Spare parts for Mechanical Dust Collector

12. Proximate and ultimate analysis on fuels burned

13. Operators rounds sheet

14. Spare parts list for boiler and auxiliaries

15. Spare parts list for Electrostatic Precipator system

16. Emergency and Special Instructions

17. Plant Shutdown Procedures


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Hillman Power Company L.L.C. Emission Minimization Plan for Startup, Shutdown, and

Malfunction Abatement Plan (MAP) October 17,

2014

1. OPERATING PHILOSOPHY

The operating philosophy implemented at the Hillman Power Company is to operate the plant

within the emission levels required by the Air Use Permit. To achieve these goals, the boiler will

be operated in the most efficient manner possible, which in turn, will conserve fuel and provide

for complete combustion. Hillman Power Company recognizes that exceedances of limits may

occur which are unavoidable under certain malfunction situations, as well as startup and shutdown

of the boiler and control equipment. The equipment will be operated and maintained in such a

manner to minimize the duration and magnitude of these incidents. The operation of the plant

will be performed utilizing properly trained and experienced operators.

In addition to proper operation, it is equally important to establish inspection and maintenance

procedures that will allow the plant to continue running in an optimum operating condition.

These procedures will include regular scheduled inspections. Properly trained and experienced

plant operators and maintenance personnel will perform the inspections. To ensure that

maintenance will be performed in a timely manner, it is intended to have an inventory of

appropriate spare parts available at the plant for normal scheduled maintenance. The quantity and

type of spare parts selected for inventory will be based on plant operating experience.

2. REPORTING

Operating reports consisting of the Hillman Power Company emission levels and plant operating

data will be submitted quarterly by written report to the Michigan DEQ-AQD district supervisor

within 30 days following the end of the calendar quarter. The quarterly report will include a

detailed analysis of all recording, reporting, and record keeping requirements in compliance with

40 CFR, part 60 and the current Air Use Permit. The quarterly reports will be in a format

exceptible to the department and contain the required information.

In addition to the quarterly reports, notifications will be provided to the DEQ-AQD district

supervisor of any abnormal conditions or malfunctions of process or control equipment that

results in emissions in violation of the Air Use Permit or Rule 912. This notice will be provided

not later than two business days after the startup, shutdown, or discovery of the abnormal

condition or malfunction. Also, within 10 days, a written detailed report including probable

causes, duration of violation, remedial action taken, and the steps which are being taken to prevent

a reoccurrence will be submitted to the DEQ-AQD district supervisor.

All monitoring data for the Hillman Power Company will be kept on file at the plant for a period

of fire years and made available to the DEQ-AQD district supervisor upon request.


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3. CONTINUOUS EMISSION MONITORING SYSTEM (CEM)

3.1. Description

A continuous emissions monitoring (CEM) system is used to monitor and record the emissions

from Hillman Power Company as required by the current Air Use Permit. The system is a

complete emissions monitoring and data gathering system used to demonstrate compliance with

state and federal air emissions regulations.

Gas emissions and opacity monitoring systems including monitoring, data collection, data storage

and reporting are in accordance with the requirements of the Environmental Protection Agency

(EPA) as stated in 40 CFR Part 60, “Standards of Performance for New Stationary Sources”.

The CEM System monitors opacity, O2, CO, and NOx in the stack at an approved location.

Provisions are made to accept inputs for steam flow and fuel feed rates into the data collection

system.

The monitoring equipment provided comprises a complete system designed to function as a unit.

The CEM system is a direct extractive monitoring system and includes the following items:

a. Probes, transducers, and duct mounted instruments

b. Sample conditioning and extraction equipment

c. Analyzers and monitors

d. Sample tubing and special cable

e. Signal conversion equipment

f. Calibration gases and interconnecting equipment

g. Data collection and storage software

3.2. Operation

The CEM System is operated at all times when the boiler is firing on wood, tire derived fuel

(TDF), other alternative fuels, and natural gas by properly trained experienced operators. The

equipment is operated in accordance with the manufacturer’s recommendations and plant

operating procedures. Monitoring of the CEM system is through the main plant computer (DCS)

Data Control System located in the plants control room. The DCS system is provided with

software to receive and process signals from the analyzers, signal conversions, calculate variables

from the database, signal alarms, and store and retrieve data.

The DCS system provides fault monitoring to detect equipment malfunction. Outputs are

provided to alarm system malfunctions as sensed by the fault monitors supplied as part of the

analyzers and the DCS system. The DCS system alarms and logs the following:

CO emissions high and low

Opacity emissions high and low


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O2 concentration high and low

NOx emissions high and low

SO2 emissions high and low

The DCS system is a redundant system, failure of one component will not result in the loss of any

previously stored data within 24 hours. The DCS system is designed to sustain memory in the

event of a power supply failure and is supplied with an internal clock to maintain correct time and

date during power failure.

Hourly and daily reports can be generated at the operator’s request. The dates and times are

included in the reports when the report is requested. The report uses the most up-to-date

information from the data base of emissions data stored in the computer.

Reports display hourly emissions averages, rolling averages, daily averages, status logs, steam

flow, fuel feed rate, 6 minute averages for opacity, and values of emission products as ppmd, #/hr,

and other data as required by the specified regulatory agencies.

Operator generated logs compiled from DCS trend logs are also kept on file. These logs

demonstrated compliance or noncompliance, give reason codes for noncompliance, and contain a

comment section for operation action taken.

3.3. Critical Criteria

The CEM System is operated in a manner that will provide accurate monitoring, recording, and

reporting of Hillman Power Company’s emissions limitation as specified in the plants current Air

Use Permit. The CEM System is operated to monitor the following critical criteria:

Opacity

a. The Opacity monitor is designed to accurately monitor and record the flue gas opacity.

Visible emissions from the boiler are not to exceed the specified limits set in the air

use permit.

b. The opacity monitor optical head and retro reflector alignment will be properly

aligned when the angle of projection from the optical head is within two degrees and

the angle of view from the retro reflector is within two degrees. Completed as needed.

c. The allowable angle of alignment drift will be within 0.5 degrees.

d. The optical head light source is a super wide band diode.

e. A blower is provided for the optical head and retro reflector for gas purging of the

assemblies. The blowers are designed to provide 60 inches water column of static

pressure and are fitted with an inlet filter and particulate bowl.

f. A copy of the calibration procedures are add as attachment #1.

g. A calibration check instrument is at the facility and is used whenever necessary to

verify accuracy, and calibrate the instrument. The calibration check instrument is also


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used for the Relative Accuracy Test Audit by the vendor contracted to perform the

testing.

h. The opacity monitor is automatically calibrated daily and a RATA is performed

annually.

NOx

a. The NOx analyzer is designed to accurately monitor and record the NOx emission

levels from the boiler. The NOx emission rate from the boiler will not exceed the

limits of the current air use permit.

b. The NOx calibration gas cylinder will contain gas of at least 80% to 100 % of the

instrument range.

c. The NOx analyzer sensitivity will be a 0.5-ppb.

d. The NOx analyzer range will be 0 - 500 ppm.

e. The NOx analyzer accuracy will be 2% of full scale.

f. The NOx analyzer calibration drift will be 1% in 24 hours.

g. The purge air supply for the NOx sample will be at 120 psi and at a flow rate of 6

liters per minute.

h. The calibration gas supply for the NOx sample will be at a flow rate of 8 liters per

minute.

i. A copy of the calibration procedures is supplied as attachment #2.

j. The NOx analyzer is run through, a daily calibration of the zero and span, a quarterly

Cylinder Gas Audit, and an annual RATA test.

SO2

a. The SO2 analyzer is designed to accurately monitor and record the SO2 emission

levels from the boiler. The SO2 emission rate from the boiler will not exceed the

limits of the current air use permit.

b. The SO2 calibration gas cylinder will contain gas of at least 80% to 100 % of the

instrument range.

c. The So2 analyzer sensitivity will be a 0.5-ppb.

d. The SO2 analyzer range will be 0 - 500 ppm.

e. The SO2 analyzer accuracy will be 2% of full scale.

f. The SO2 analyzer calibration drift will be 1% in 24 hours.

g. The purge air supply for the SO2 sample will be at 120 psi and at a flow rate of 6 liters

per minute.

h. The calibration gas supply for the SO2 sample will be at a flow rate of 8 liters per

minute.

i. A copy of the calibration procedures is supplied as attachment #2.

j. The SO2 analyzer is run through, a daily calibration of the zero and span, a quarterly



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Carbon Monoxide

a. The CO analyzer is designed to accurately monitor and record the CO emission levels

from the boiler. The CO emission rate from the boiler is not to exceed the plants

current air use permit based on a 24-hour daily average.

b. The calibration gas cylinder will contain CO gas at 80% to 100% of instrument range.

c. The CO analyzer sensitivity is 0.1 ppm.

d. The CO analyzer range is 0 to 1000 ppm.

e. The CO accuracy will be 2 % of full scale.

f. The CO analyzer calibration drift will be 3% in 24 hours.

g. The purge air supply for the CO sample will be 120 psi at 8 liters per minute.

h. The CO calibration gas supply for the CO sample will be at a flow rate of 3.5 liters per

minute.

i. A copy of the calibration procedures is added as attachment #3.

j. The CO analyzer is run through a daily calibration of the zero and span, a quarterly


Oxygen (O2)

a. The O2 analyzer is designed to accurately monitor and record the levels of O2 at the

stack gas sample point. The predicted levels of O2 are in the range of 5% to 6%.

b. The O2 calibration gas cylinders will contain O2 gas at 2% and 18% by volume.

c. The O2 analyzer sensitivity will be 0.1%.

d. The O2 analyzer range will be 0 - 25 %.

e. The O2 analyzer accuracy will be 0.1% of full scale.

f. The O2 analyzer calibration drift will be 2.5% in 24 hour.

g. The reference air supply for the O2 sample is 2 SCFH.

h. The O2 analyzer calibration gas supply for the O2 sample is at a flow rate of 10 liters

per minute.

i. A copy of the calibration procedure is added as attachment #4.

3.4. Inspections

a. Daily inspections are performed on the CEM equipment to ensure that the equipment

is

operating properly. Inspection form # 1 is used see attachment # 5

b. Quarterly cleaning is done on the equipment if there is enough monitor equipment

down

time left for the quarter. Work orders (log # 5) are used for the cleaning and

inspection

forms see attachment #5

c. Annual cleaning and inspection is done on our annual outage for maintenance and


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repair. Work orders (log # 5) are used for the cleaning and inspection forms see

attachment # 5

Daily, quarterly, and annual inspections are performed on the CEM equipment to ensure that the

equipment is operating properly and to observe various changes that may indicate a potential

malfunction. If the CEM system fails to pass any inspection immediate action is taken to correct

the malfunction or abnormal condition. Copies of the inspection forms are added as attachment

#5

3.5. Maintenance

Maintenance on the CEM equipment is performed in accordance with the manufacturer’s

recommendations. Normal maintenance is performed during the daily and quarterly inspections

with the replacement of worn parts that do not meet the manufacturer’s specification tolerances.

Other maintenance is performed to either replace or rebuild various pieces of equipment when a

malfunction occurs.

3.6. Spare Parts

Spare parts are purchased and stored in inventory based on plant operating experience. A copy of

the spare parts inventory is included as attachment #6.

3.7. Abnormal conditions or malfunction:

Abnormal conditions or malfunctions of the equipment include, but are not limited to, the

following equipment status which result in emissions or operations outside the permit

requirements:

a. CO analyzer failure

b. NOx analyzer failure

c. Opacity analyzer failure

d. O2 analyzer failure

e. Failure of extractive system

f. Failure of cabinet heater or air conditioner

g. Failure of electronic transmission system between analyzer’s and DCS system

h. Failure of DCS printer

i. Failure of purge air system


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3.8. Abatement Measures

In the event that a malfunction should occur to the CEM equipment that affects monitoring,

recording, or reporting of the plant emissions, specific action will be taken to correct the

equipment malfunction. Whenever needed the use of overtime, off-shift labor, outside consultants

or contractors, where reasonable to minimize the duration of the malfunction or excess emissions

will be used. This action in cooperation with the DEQ-AQD district supervisor will be taken and

one or more of the following steps:

a. Based on stable operation of the boiler and being in compliance with the required

emission levels at the time of the malfunction, continue to run the boiler at a stable

rate of operation and repair the CEM equipment as soon as possible.

b. Should it be determined that equipment replacement is required in lieu of repairs,

continue to run the boiler at a stable rate of operation and replace the equipment as

soon as possible.

c. Should it be determined that replacement of equipment is going to take an excessive

length of time, continue to run the boiler at a stable rate of operation and arrange for

rental of CEM equipment in the interim period.

d. Should it be determined that rental of CEM equipment is not possible, continue to run

the boiler in a manner where extensive operating experience has demonstrated that the

plant always complied with the permit emission levels.

e. Plant shutdown.

3.9. Time Frame for Abatement Measures

The time frame for repair of each of the malfunctions listed in the table below are estimates from

prior plant experience. All components of the plant systems are not identical and time frames for

repair will vary somewhat due to location in the plant, accessibility for repairs, and time when

malfunction occurs. Each time frame should be completed from time of initial malfunction or

abnormal condition.

3.7 Abnormal conditions or malfunctions 3.8 Abatement measures times in hours

a. b. c. d. e.

1. CO analyzer failure 48 72 96 240 720

2. NOx analyzer failure 48 72 96 240 720

3. Opacity analyzer failure 48 72 96 240 720

4. O2 analyzer failure 48 72 96 240 720

5. Failure of dilution extractive system 48 72 96 240 720

6. Failure of cabinet heater or air conditioner 48 72 96 240 720

7. Failure of electronic transmission system


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between analyzer’s and DCS system 48 72 96 240 720

8. Failure of DCS printer 48 72 96 240 720

9. Failure of purge air system 24 72 96 240 720

4. ELECTROSTATIC PRECIPITATOR

4.1. Description

The flue gas environmental control system is a Environmental Elements Corporation multi-field

electrostatic precipitator (ESP) designed to remove particulate from the flue gas flow and

maintain an emission rate as specified in the current Air Use Permit. The ESP is located down

stream from the induced draft fan to prevent air in leakage and possibility of fires. The ESP is

enclosed and insulated around the bottom for equipment protection from the weather and to

improve the ability of maintaining the equipment.

The main controls for the ESP are located in the equipment room adjacent to the main plant

control room for ease in startup and monitoring of performance.

The precipitator is comprised of one (1) chamber of three (3) mechanical / electrical fields, and

consists of a 3/16 mild steel casing containing the collecting panels and the high voltage discharge

electrodes, and associated suspension and alignment hardware.

The precipitator has one longitudinal trough hopper, which collects the ash from the collecting

plates and the high voltage electrodes, dislodged when the electromagnetic rappers are activated.

The rapping equipment is located at the roof level and the rapper control panel is located in the

boiler building.

The precipitator is equipped with inlet nozzles containing gas distribution plates and an outlet

nozzle. The roof of the precipitator has a complete checkerplate-walking surface for ease of

maintenance. Access is provided to the roof of the precipitator by a stairtower.

4.2. ESP Interior Parts

The interior parts of the ESP field consist of a system of grounded collecting surfaces and

independently hung high voltage elements.

Collecting surfaces are assemblies of panels, each panel being fabricated of light gauge steel plate,

stiffened by rolled edges and align bars. Collecting surfaces are held in vertical alignment and

parallel to one another to allow for uniform gas flow.


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High voltage discharge electrodes are a rigid mast type of rolled construction, hung from a

framework of channels and angles braced and tied to prevent horizontal movement. Each mast is

bolted in place at the upper end and lower end.

The masts are shrouded at the top and lower end to prevent electrical sparking. An alignment

frame at the lower end of the elements is designed to maintain the elements in proper vertical and

horizontal alignment.

The spaces between parallel collecting surfaces are called gas passages, and the high voltage

discharge electrodes are positioned in these spaces symmetrical with collecting surfaces.

The high voltage frame in each field is supported at four (4) points by insulators mounted on the

precipitator casing cover and housed in steel compartments. These support insulators provide

electrical insulation between the high voltage frame and the grounded structure.

4.3. ESP External Parts

The high voltage for the discharge systems is supplied by transformer-rectifier sets located on the

ESP roof. These units are connected to the high voltage elements through high voltage lines. The

high voltage lines and high voltage support insulators are enclosed in bus ducts above the ESP

roof level. Extremely accurate power regulation to each high voltage system is provided by

automatic control.

All ESP operating control and indicator panels, power distribution and automatic voltage control

units are located in the equipment room adjacent to the plants main control room.

The ESP also has a series of ash augers, rotary valve, and mixer system to handle the ash to the

ash bay for storage until it is removed from the site.

The ESP ash system is equipped with motion detection devices that will alarm the Operator Tech

in the plants main control room of any interruption in the system. The mixer system also uses

water for temperature and dust control.

4.4. Operation

Properly trained operators who operate the equipment in accordance with the manufacturer’s

recommendations and plant operating procedures operate the ESP.

4.5. Theory of Operation

Operation of the ESP depends upon creation of an electrostatic field to electrically charge dust

particles in the gas stream as it passes through the ESP.


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The electrostatic field is established by stepping up low voltage alternating current with a

transformer, and changing the resulting high voltage alternating current with a rectifier to high

voltage direct current. The rectified current is then delivered to a system of mast electrodes

uniformly spaced between collecting surfaces. The mast electrodes create the electrostatic field

within spaces between the collecting surfaces.

The dust particles in the gas stream are charged as they pass through the electrostatic field. Most

particles are charged negatively, or opposite in polarity to that of the collecting surfaces, and

therefore are attracted to these surfaces and adhere to them until removed. The remaining

particles are attracted to the mast electrodes. This collected material is periodically removed by a

system of rappers which strike the surfaces a sharp blow, breaking loose the collected material,

which then falls by gravity into the precipitator hoppers.

The polarity of the transformer-rectifier high voltage output is always negative at the voltage

necessary for highest ESP operating efficiency.

The precipitator may be operated either on automatic or manual voltage control. On automatic

control, the controller varies the voltage to the ESP as required to maintain optimum removal

efficiency under varying inlet gas and dust conditions. On manual control, proper ESP operating

voltage is obtained by adjusting voltage until only occasional sparking or shorting between high

tension electrodes and the collecting surfaces is reflected by the spark-rate meter.

4.6. ESP Operation

The main controls for the ESP are located in the plant equipment room and control room, they

will perform the following specific functions:

a. Automatic voltage regulation to each of the transformer/rectifiers associated with

the three (3) fields.

b. Control the operation of the Insulator Compartment Pressurization System, which

provides a positive pressure to prevent dust from entering the compartment.

c. Control the operation of the rappers system on the collecting surfaces, discharge

electrodes, and the ESP inlet distribution plates.

d. Monitor high ash level in the ESP ash hoppers.

e. Control power supply to the ESP through the key interlock system on the ESP

access doors.

f. Control ESP ash auger and mixing system.

g. Ash auger motion detection system.

h. Monitor the ESP ash hopper electric heating system.


The operational parameters for the critical criteria are not requirements of the air use permit but

are requirements for safe operating conditions. The operation of the ESP controls the final


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particulate emissions from the plant. The ESP operates in a manner to satisfy the following

critical criteria:

Particulate

a. Inlet dust loading to the ESP not to exceed 1.7 gr./DSCF. As design specifications.

b. Flue gas temperature entering the ESP not to exceed 360 degrees F. As design specifications.

c. Flue gas moisture content entering the ESP not to be greater than 29%. As design

specifications.

d. Particulate emissions from the ESP outlet shall not exceed the Air Use Permit limits.

Monitored and recorded by the CEM

e. Visible emissions from the ESP not to exceed the limitations of the Air Use Permit. Monitored

and recorded by the CEM

A copy of the plant startup procedures is added as attachment #8 which includes the

startup procedures for the ESP.

4.8. Inspection

Daily inspections are performed on the ESP in accordance with the manufacturer’s

recommendations and plant operating experience to ensure that the equipment is operating

properly and to observe various changes that may indicate potential malfunction. The inspections

performed each day are as follows: See attached plant log sheets section 13

a. Spark rate on each of the three fields average from 0 to 240 sparks per min. Log # 2

b. Voltage on each of the three fields maximum is 55 KV Log # 2

c. Amperage on each of the three fields. Log # 2

d. Transformer oil temperature on each field maximum is 550 C. Log # 3

e. Transformer oil Pressure on each field. Log # 3

f. Rappers operating properly. Monitored by the DCS and operators

g. Ash removal system operating properly. Log # 4

Weekly inspection items:

a. Remove dust and foreign matter from electrical equipment. Log #7

b. Check signal lights for proper operation. Log #7

c. Check rapper alignment. Log #7

d. Check rapper boots for cracks and wear. Log #7

e. Check tightness of belts on penthouse fan. Log #7

f. Grease penthouse blower fan and motor. Log #7

g. Check precipator rotary valve and lubricate. Log #7

h. Inspect and lubricate precipitator ash system bearings. Log #7

i. Check precipator auger gear boxes for unusual sounds, vibrations, and grease. Log #7


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Annual inspections items:

a. Clean insulators in the high voltage insulator compartment, as well as all other

insulators.

b. Thoroughly inspect the interior of the ESP and make necessary adjustments or repairs.

Give particular attention to the high voltage electrodes, each of which should be centered

between the collecting surfaces. Misalignment of even a single unit reduces the electrical

clearances between high voltage electrodes and collecting surfaces, resulting in a marked

reduction of collecting efficiency. Misaligned electrodes should be removed or replaced

as required.

c. Disassemble electric rappers and inspect the high voltage system rapper shaft ceramic

material for deterioration or cracking.

d. Test the insulating fluid in each transformer for dielectric strength according to the

appropriate American Society of Testing Materials Code. See plant work orders Log #5

section 13.

See plant work orders.

4.9. Maintenance

Maintenance on the ESP is performed in accordance with the manufacturer’s recommendations

and previous plant experience. Normal maintenance is performed during the annual inspection


Other maintenance is performed to either replace of rebuild various pieces of equipment should a

malfunction occur or force the shut down of the boiler.

4.10. Spare Parts

Spare parts will be purchased and stored in inventory based on the manufacturer’s

recommendations and plant operating experience. The expected spare parts list for the ESP is

added as attachment 15#.

4.11. Abnormal conditions or malfunctions



requirements:

a. ESP ash and mixer system

b. Penthouse pressurization system

c. Transformers/rectifier system


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d. ESP high voltage insulators

e. ESP rapper system

f. Startup and shutdown of plant

g. Rigitrode/plate collection system


In the event that a malfunction should occur to the ESP equipment that affects or controls the

plant emissions and causes the plant to exceed the permitted levels, specific action will be taken to

bring the plant back into compliance. Whenever needed the use of overtime, off-shift labor,

outside consultants or contractors, where reasonable to minimize the duration of the malfunction

or excess emissions will be used. This action, in cooperation with the DEQ-AQD district

supervisor will be taken and either one or more of the following steps:

a. Continue to run the malfunctioned ESP equipment at lower loads or fewer electrical

fields as long as the plant emissions are in compliance. This may or may not require

the boiler to run at reduced loads.

b. Correct the malfunctioned equipment by taking it out of service for repairs. It may be

possible to run the ESP and boiler at reduced loads and be in compliance with

emissions when the malfunctioned equipment is out of service for repairs.

c. Continue to run the boiler and repair the equipment, if the estimated repair would

create less total emission than a normal shutdown and startup. Emissions may exceed

the permit limits for certain periods of time during boiler startup and shutdown. This

situation may be unavoidable and is addressed in the emission minimization plan

during startup and shutdown (see Section 7).

d. Correct the malfunctioned equipment by shutting down the ESP and repair the

equipment. Shutting down the ESP will also require shutting down the boiler, which

in turn will cease all plant emissions.

Time Frame for Abatement Measures





abnormal condition.

4.11Abnormal conditions or malfunctions 4.12 Abatement measures times in hours


16

a b c d.

1. ESP ash and mixer system - - - 24

2. Penthouse pressurization system - - - 24

3. Transformers/rectifier system - - - 12

4. ESP high voltage insulators 24 - - 720

5. ESP rapper system - - - 24

6. Startup or shutdown of plant - - 48-

7.Rigitrode/plate collection system1. - - - 720

5. SELECTIVE NON-CALALYTIC REDUCTION SYSTEM (SNCR)

5.1. Description

A selective non-catalytic reduction (SNCR) urea based system is provided to control the NOx

emissions as required by the current Air Use Permit. This system includes a recirculating and

heater skid, a metering / mixing skid, and associated valves, fittings, and injectors. The urea

control fluid is mixed with water and injected into the boiler through water wall injectors.

Compressed air is utilized for atomization and proper distribution into the boiler’s flue gas path.

NALCO Fueltech furnishes the SNCR system.

5.2. Operation

The SNCR system is operated at all times when the boiler is firing on wood fuel, or a combination

of wood fuel and tire derived fuel by properly trained operators. The equipment is operated in

accordance with the manufacturer’s recommendations and plant operating procedures. A copy of

the plant operating and startup procedures for the SNCR system are attachment #9. Control of the

SNCR System is directed by a single loop controller. The alarm system is directed by the main

DCS system. The Operator Tech on shift monitors all plant systems and makes all necessary

adjustments to maintain a safe operation, and be in compliance with state and federal regulations.

Specific functions of the SNCR controls are as follows:

a. Control urea chemical temperature in the chemical storage tank. The tank is supplied

with insulation to minimize heat loss. The method for heating the urea is by a heating

element and a recirculating pump. The recirculation skid serves the SNCR Process in

a dual role. It has one purpose of keeping the urea reagent at a temperature above 85

degrees F. and its second purpose is to supply the urea to the Metering/Mixing Skid.


17

The skid consists of dual redundant centrifugal pumps, one electric in-line heater, one

self-contained control panel, and all associated stainless steel piping and valving.

b. The metering mixing skid is used to supply urea to the (3) injector wands mounted

on the upper boiler walls. The unit includes two sets of full flow duplex metering

pumps and gear pumps for water/chemical mixing and pressure boost, respectively.

The skid contains a pressure control loop consisting of a pneumatic valve and a

pressure transmitter system wired into the single loop controller for discharge pressure

control. In addition the module contains all necessary motor operated ball valves,

manual ball valves, check valves, pressure switches, flow switches, and stainless steel

piping to make it a self-contained pumping system.

c. The SNCR also contains an air pressure regulator system which is used to control the

atomizing air pressure at the injectors.

d. The injectors consist of an atomizing chamber in which the air and urea first meet.

Air is required for atomizing the urea and cooling when the injectors are off-line and

not retracted from the boiler.


The SNCR System is operated in a manner that will control the plant’s NOx emissions in

compliance with the current Air Use Permit. The SNCR System is operated to maintain the

following critical criteria

NOx

a. The SNCR System provides the proper urea and water mixture to the injectors to

maintain plant NOx emissions at the current air use permit limits. This level of NOx

emissions represents a reduction of approximately 20 percent of the NOx level

received from the boiler.

b. In order to achieve the above reduction in NOx emissions the urea is injected and

atomized through injectors installed in the boiler walls in a location where the furnace

temperature averages 1800 degrees F.

c. Proper flow and mixing of the urea chemical is best controlled when the chemical

temperature is maintained at greater than 70 degrees F. log #4 section 13

d. Compressed air at a pressure of 80 psig is provided for atomization of the urea

chemical into the boiler. Log #3 section 13


18

e. Service water for urea dilution is provided at a pressure of 60 psig to the metering

mixing skid. Log #3 section 13

f. The NOx emissions are monitored by the CEM equipment and recorded by the plants

DCS system as required by the current Air Use Permit.

CO

a. The SNCR System by injecting urea chemical for NOx reduction will contribute to the

level of CO emissions. However the SNCR System is designed to be in compliance

with the Air Use Permit.

5.4. Inspections

Inspections are performed on the SNCR system every four hours to insure that the equipment is

operating properly and to observe any changes that may indicate potential malfunction of the

equipment. The inspections performed are as follows: see log sheets section 13

a. Observe the level in the urea-mixing tank, operating range is from 200 to 750 gallons.

. Log #3

b. Observe the recirculation skid, heater, pump, and discharge pressure. The discharge

pressure during normal operation averages 20 psig. Log #4

c. Observe the metering/mixing skid, pumps, and pressure control system. Log #3

d. Observe the air pressure to the injectors for proper atomization and cooling.

Atomization air pressure during normal operations averages 35 psig. Log #3

e. Observe the service water supply to the metering/mixing skid for proper water

pressure. City water pressure averages 60 psig. Log #3

Through the process of normal operation other operating parameters are continuously observed in

the control room including NOx emission levels. Maintaining the plant emissions at proper levels

provides an additional means of inspection that assures the plant operators that the SNCR system

is operating properly.

Annual inspections are performed on the SNCR equipment to ensure that the equipment is in

proper operating condition. This inspection includes the shutting down of the equipment during a

scheduled plant shutdown and removal of various parts for close inspections. Annual inspections

and tear down may include the following equipment: See plant work orders Log #5 section 13.

a. Piping Injectors

b. Pumps


19

c. Heater system

d. Check valves

5.5. Maintenance

Maintenance on the SNCR System is performed in accordance with the manufacturer’s

recommendations and previous plant experience. Normal maintenance is performed during the

annual inspection with the replacement of worn parts that do not meet the manufacturer’s

specification tolerances. Other maintenance is performed to either replace or rebuild various

pieces of equipment should a malfunction occur and force the shutdown of individual pieces of

equipment. Due to the redundancy of many pieces of equipment, a malfunction of rotating

equipment will not shut the SNCR System down.

5.6. Spare Parts

Spare parts are purchased and stored in inventory based on manufacturer’s recommendations and

plant operating experience. The spare parts for the SNCR equipment is added as attachment #10.

5.7. Abnormal conditions or malfunctions



requirements:

a. Heater system failure

b. Pressure control system failure

c. Single loop controller failure

d. Injector failure

e. Failure of air supply for atomization and cooling

f. Loss of dilution water supply

g. System temperature control of solubility of solution

h. Flue gas temperature control

i. Nitrogen content in alternative fuels

j. Failure of motor operated control valves

k. Failure of pumps, piping, or check valves


In the event that a malfunction should occur to the SNCR equipment that affects or controls the

plant emissions, specific action will be taken to correct the equipment malfunction.

Whenever needed the use of overtime, off-shift labor, outside consultants or contractors, where

reasonable to minimize the duration of the malfunction or excess emissions will be used. This

action in cooperation with the DEQ-AQD district supervisor will be taken, and one or more of the

following steps:


20

a. Continue to run the malfunctioned equipment as long as the plant emissions are in

compliance. This may or may not require the boiler to run at reduced loads.

b. Correct the malfunctioned equipment by taking it out of service for repairs. In some

cases, it will be possible to run the boiler at either full load or reduced load and be in

compliance with emissions when the malfunctioned SNCR equipment is out or service

for repairs.

c. Continue to run the boiler and repair the equipment, if the repair takes less time than

the time required for a normal boiler shutdown and startup. Emissions may exceed the

permit limits for certain periods of time during boiler startup and shutdown. This


during startup and shutdown (see Section 7)

.

d. Correct the malfunctioned equipment by shutting down the SNCR system and

boiler to repair the equipment. Shutting down the boiler will cease all plant

emissions.






abnormal condition.

5.7Abnormal conditions or malfunctions 5.8 Abatement measures times in hours

a. b c d

1. Heater system failure - - - 120

2. Pressure control system failure - - - 120

3. Single loop controller failure - - -

120

4. Injector failure - - - 120

5. Failure of air supply for atomization and cooling - - - 72

6. Loss of dilution water supply - - - 120

8. Flue gas temperature control - - - 240

9. Nitrogen content in alternative fuels - - -

240

10. Failure of motor operated control valves - - 48 240

11. Failure of pumps, piping, or check valves - - 48 240


21

6. MECHANICAL DUST COLLECTOR

6.1. Description

A Joy Manufacturing multi-clone mechanical dust collector is provided in the flue gas ductwork

exiting the boiler. The multi-clone mechanical dust collector will remove the heavier particles of

fly ash from the flue gas steam prior to the flue gas passing through the induced draft fan and to

the electrostatic precipitator. The mechanical dust collector is furnished by Joy Manufacturing

Corporation.

The mechanical dust collector does not have moving parts and is fitted with the following fixed

devices for removal of dust particles, char, and sand.

A series of collector tubes consisting of inlet and outlet tubes.

The collector tubes are contained within a dust collector housing where the flue gas enters and

exits the mechanical dust collector. Two ash hoppers are attached to the housing to collect the ash

removed from the gas stream by the collector tubes.

6.2. Operation

The mechanical dust collector is operated at all times when the boiler is operating. In as much as

the mechanical dust collector has no moving parts, it relies on centrifugal force created by the

collector tubes for removal of dust particles, char and sand from the flue gas stream. This

material is then collected in the ash hoppers below the collector tube housing and removed by

means of the ash handling system.

Controls for the mechanical dust collector operate rotary valves and an ash removal system on the

outlets of the ash hoppers. This equipment handles the material removed by the multi-clone

collector tubes.


The operation of the mechanical dust collector assist in controlling the plant’s particulate

emissions. The mechanical dust collector is operated in a manner to satisfy the following critical

criteria.

Particulate


22

Inlet dust loading to the collectors per cubic feet of flue gas flow.

Flue gas temperature of approximately 350 degrees F. at collectors.

6.4. Inspections

Daily inspections are performed on the mechanical dust collector to ensure that the equipment is

operating properly and to observe various changes that may indicate potential malfunction. The

inspections to be performed each day are as follows: see log sheets section 13

a. Observe the operation of the system. Log #4

b. Observe that the ash removal system is operating properly. Log #4

c. Operator Tech from the DCS system monitor the drafts and temperature on the

system continuously. Under normal conditions the dust collector draft averages -9 inches

of water and operates at an average temperature of 340o F.

Annual inspections are performed on the mechanical dust collector to ensure that the equipment is

in proper operating condition. This inspection includes the shutting down of the boiler and

internal inspection of the multi-clone collector tubes. Log #5

Due to the abrasive nature of the sand and unburned char being collected in the mechanical dust

collector, the multi-clone collector tubes will erode away and need to be replaced periodically.

The rotary air lock valves and external ash removal system are to be inspected during the annual

outage.

6.5. Maintenance

Maintenance on the mechanical dust collector is performed in accordance with the manufacture’s

recommendations and plant operating experience. Normal maintenance is performed during the


specification tolerances. Other maintenance will be performed to either replace or rebuild

various pieces of equipment should a malfunction occur and force the shut down of the boiler.

6.6. Spare parts

Spare parts are purchased and stored in inventory based on manufacturer’s recommendations and

plant operating experience. The spare parts list for the mechanical dust collector is included as

attachment #11.

6.7. Abnormal conditions and malfunctions



requirements:


23

a. Rotary air lock valve failure

b. Ash removal system failure

c. Ash reinjection system failure

d. Centrifugal turning vanes or separator tube failure.

e. Tube sheet failure.

6.8. Abatement measures

In the event that a malfunction should occur to mechanical dust collector equipment that affects

the control of the plant emissions and causes the plant to exceed the permitted levels, specific

action will be taken to bring the plant back into compliance. Whenever needed the use of

overtime, off-shift labor, outside consultants or contractors, where reasonable to minimize the

duration of the malfunction or excess emissions will be used. This action in cooperation with the

DEQ-AQD district supervisor will be taken and either one or more of the following steps:

a. Continue to run the malfunctioned equipment at lower loads as long as the plant

emissions are in compliance. This may or may not require the boiler to run at reduced

loads.

b. Continue to run the boiler and repair the equipment, if the estimated repair would

create less total emission than a normal shutdown and startup. Emissions may

exceed the permit limits for certain periods of time during boiler startup and

shutdown. This situation may be unavoidable and is addressed in the emission

minimization plan during startup and shutdown (see Section 7).

c. Correct the malfunctioned equipment by shutting down the boiler and repair the

equipment. Shutting down the boiler will cease all plant operations.






abnormal condition.

Abnormal conditions or malfunctions 6.8 Abatement measures times in hours

a b c


24

1. Rotary air lock valve failure 24 48 120 2. Ash removal system failure 24 48 120 3. Ash reinjection system failure 24 48 120 4. Centrifugal turning vanes or separator tube failure. - - 720 5. Tube sheet failure. - - 720

7. BOILER

7.1. Description

Hillman Power Company uses wood fuel, tire derived fuel, and natural gas to fire a cross flow

boiler with a double-pass superheater to generate steam at 850 psig and 900 degrees F. This

boiler is of the latest design technology utilizing water panels open to the combustion space walls

and floor to gain maximum heat transfer. A natural gas system is used for boiler startup and also

for flame stabilization of the wood and TDF fuel supply.

The method of combustion is by the use of a shaker grate system. The fuel is uniformly

distributed over the stoker grate by means of air swept spout feeders. Combustion air is provided

to the stokers grate system by forced draft and overfire air fans and flue gas drawn from the

combustor by an induced draft fan. The steam generator portion consists of both radiant and

convection pass tubes and superheater above the shaker grate system.

An ash reinjection system is included to collect unburned carbon from the ductwork hoppers and

the multi-clone mechanical dust collectors. The unburned carbon is reinjected into the boiler.

The ash reinjection system will reduce the ash that would normally be collected in the ash

handling system and enhance the combustion efficiency.

The boiler ash system consist of a series of augers conveying ash from the ESP, air heater ash

system, mechanical dust collector, and bottom ash to the ash storage area. From the storage area

the ash is transported by truck to the local landfill.

Fuel system consist of a reclaimer, disc screen, three feeders, and a series of belt conveyors that

size and convey the wood and tire derived fuel to the boiler grate area.

7.2. Operation

The boiler is operated by properly trained boiler operators who will operate the equipment in

accordance with the manufacturer’s recommendations and plant operating procedures.

Combustion control of the boiler, monitoring of boiler parameters and alarms for the boiler are

directed by the main plant Distributed Control System (DCS) located in the main control room.

Specific functions of the boiler controls are as follows:

a. Control steam flow, pressure, and temperature from the superheater to the steam

turbine generator.

b. Control fuel feed rate to the boiler for proper heat input to satisfy the required steam

generation rate.

c. Control fuel air ratio through the forced draft, overfire air, and induced draft fans.

d. Control grate shaker sequence for proper and complete combustion for the fuel.

e. Control steam drum water level and pressure to ensure proper boiler circulation and

steam flow.

f. Monitor and record boiler operating parameters and auxiliary equipment.

g. Monitor all motion detection devices.

Above items are monitored 24 hours a day by the plant operator and DCS system.


Proper control and efficient operation of the boiler also ensures that complete combustion is

achieved and emissions minimized. In order for the overall plant emissions to be in compliance

with the current Air Use Permit, the boiler is operated to maintain the following critical criteria:

Particulate

a. Wood and tire derived fuel consisting of chips sized at minus 2.5” x 2.5”, saw dust and

planer mill fines are burned in the boiler. The specification for the wood fuel and tire

derived fuel is as described in the Fuel Analysis added as attachment #12.

b. Efficient operation of the boiler will also ensure that complete combustion is taking

place and that the amount of particulate consisting of fly ash is minimized. The

predicted efficiency of the boiler is 68 %. The efficiency of the boiler is directly

related to maintaining the fuel to air ratio, which will provide an excess air leaving the

furnace a approximately 5 % O2 while burning approximately 28 ton per hour of fuel.

NOx

a. Efficient operation of the boiler also influences the generation of NOx . The

boiler is designed to maintain proper combustion temperatures to minimize the

generation of NOx through control of the fuel air ratio. The predicted NOx

levels before reduction by the SNCR system is approximately 0.30 #/mbtu

heat


26

input. Again this is demonstrated by maintaining the excess air leaving the

furnace at 5% oxygen. The excess air is being monitored and recorded by the

CEM equipment as required by the Air Use Permit.

b. Efficient operation of the boiler also controls the flue gas temperature in the

furnace in the region where the urea chemical is to be injected from the SNCR

system. In this area of the furnace the flue gas temperature will range from

1700 to 2000 degrees.

CO

a. Efficient operation of the boiler also influences the generation or CO. In as

much as the generation of CO is somewhat related to the level of NOx , as long as

the NOx is being maintained at 0.30 #/mbtu heat input before reduction, CO

should also be controlled. One distinct exception is the moisture content in the

fuel.

Opacity

a. Wood fuel and tire derived fuel consisting of chips sized at minus 2.5” x 2.5”,

sawdust and planer mill fines are burned in the boiler. The specification for the

fuels in the Fuel Analysis is included in the attachments.

b. Efficient operation of the boiler will also ensure that complete combustion is

taking place and that the opacity will be minimized.

VOC

a. Efficient operation of the boiler influences the generation of VOC emissions.

7.4. Inspections

Inspections are performed every four hours on the boiler to ensure that the equipment is operating

properly and to observe various changes that may indicate potential malfunction. The complete

plant is monitored continuously by the plant DCS System which alarms the Operator Tech as to

any function that varies from the average operation by a few percentage points. The inspections

to be performed each round are as follows: see logs in section 13

a. Observe the stoker distribution and grate area. Log #4

b. Observe the grate shakers are working properly. Log #4

c. Record bearing temperature and condition of forced draft fan. Log #4

d. Record bearing temperature and condition of overfire air fan. Log #4

e. Record bearing temperature and condition of induced draft fan. Log #4

f. Observe the complete ash system. Log #4


27

g. Observe the complete fuel system. Log #6

Through the process of normal operation other operating parameter are continuously observed in

the control room including boiler pressures, temperature, functions of controls, and performance

of the systems. A copy of the daily inspection round logs are added as attachment #13.

Annual inspections will be performed on the boiler to ensure that the equipment is in proper

operating condition. The annual inspection also will include a boiler inspection by the insurance

carrier. Annual inspections will include the following equipment: see work orders log #5 section

13. See also boiler license in control room.

a. All pumps pertaining to boilerwater, feedwater, and condensate.

b. All boiler air fans.

c. Internal inspection of the stoker grate, boiler water walls, superheater, economizer,

air heater, refractory, sidewalls and seals.

d. Fuel system

e. Ash system

7.5. Maintenance

Maintenance on the boiler is performed in accordance with the manufacturer’s recommendations

and plant operating experience. Normal maintenance is performed during the annual inspection


Other maintenance will be performed to either replace or rebuild various pieces of equipment

should a malfunction occur and force the shut down of the boiler.

7.6. Spare Parts

Spare parts are purchased and stored in inventory based on plant operating experience. The

expected spare parts list is added as attachment # 13.

7.7. Abnormal conditions, malfunctions, and startup and shutdown

a. Loss of fuel feeders

b. Rotary air damper failure

c. Hydrograte failure

d. Bottom ash conveyor failure

e. Boiler air fan system and controls

f. High moisture content in incoming fuel

g. High flue gas temp

h. Loss of incoming fuel

i. Ash system failure

j. Loss of boiler refractory

k. Plant air supply system failure


28

l. Nitrogen content in alternative fuels

m. Clinkers and slagging on the Hydrograte system

n. Incoming line voltage surges

o. Safety valve failure

p. Scheduled maintenance

q. Distributed Control system failure (DCS)

r. Turbine/generator system failure

s. Transfer trip failure (Consumers Power emergency trip system)

t. Condenser tube failure

u. Loss of feedwater control

v. Electrical equipment and or control failure

w. Substation equipment and or control failure

x. Cooling water system failure

y. Boiler tube failure

z. Act of God (For example Electrical storm hit by lightning)

7.8. Abatement measures

In the event that a malfunction should occur to the boiler or related equipment that affects the

control of the plants emissions and causes the plant to exceed the permitted levels, specific action

will b taken to bring the plant back into compliance.

Whenever needed the use of overtime, off-shift labor, outside consultants or contractors, where

reasonable to minimize the duration of the malfunction or excess emissions will be used. This

action in cooperation with the DEQ-AQD district supervisor will be taken and either one or more

of the following steps:

a. Continue to run the malfunctioned equipment at lower loads as long as the plant

emissions are in compliance.. This may or may not require the boiler to run at reduced

loads.

b. Correct the malfunctioned equipment by taking it out of service for repairs. It may

be necessary to run the boiler at reduced loads to be in compliance with emissions

when the malfunctioned equipment is out of service for repairs.

c. Continue to run the boiler and repair the equipment, if the repair takes less time than

the time required for a normal boiler shutdown and startup. Emissions may exceed

the permit limits for certain periods of time during boiler startup and shutdown. This


during startup and shutdown (see Section 7).

d. Correct the malfunctioned equipment by shutting down the boiler and repair the

equipment. Shutting down the boiler will cease all plant emissions.


29






abnormal condition.

7.7 Abnormal conditions or malfunctions 7.8 Abatement measures times in hours

a b c d

a. Loss of fuel feeders 24 48 72 -

b. Hydrograte failure - - - 24

c. Bottom ash conveyor failure - - -

24

d. Boiler air fan system and controls - - - 24

e. High moisture content in incoming fuel - - - 120

f. High flue gas temp - - - 120

g. Loss of incoming fuel - - - 120

h. Ash system failure 24 - 48 120

i. Loss of boiler refractory - - - 720

j. Plant air supply system failure - - - 24

k. Nitrogen content in alternative fuels - - -

240

l. Clinkers and slagging on the Hydrograte system - - - 24

m. Incoming line voltage surges - - 24

n. Safety valve failure - - - 48

o. Distributed Control system failure (DCS) - - - 24

p. Turbine/generator system failure - - - 24

q. Transfer trip failure - - - 24

(Consumers Power emergency trip system)

r. Condenser tube failure - - - 48

s. Loss of feedwater control - - - 24

t. Electrical equipment and or control failure - - - 24

u. Substation equipment and or control failure - - - 24

v. Cooling water system failure - - - 24

w. Boiler tube failure - - - 48

x. Act of God (For example Electrical storm hit by lightning) - - 48

Startup and Shutdown


30

8.1 Description

Plant startup will begin when fuel is introduced to the boiler at 20.9 percent oxygen and will

end when the one hour average for oxygen in the boiler reaches 5 percent. Plant shutdown

will begin when the one hour average for oxygen in the boiler exceeds 5 percent until fuel

stops entering the boiler and combustion ceases a 20.9 percent oxygen.

8.2 Operation

During plant startup and shutdown the plant is operated by properly trained personnel who

will operate the facility in accordance with the manufacturers recommendations and plant

operating procedures. During a normal plant startup two operating crews are generally on

duty to provide constant monitoring of plant equipment and to complete the startup

procedures of the individual pieces of equipment required to operate the facility. A copy of

the startup procedure is added as attachment # 7 & 8

8.3 Critical Criteria

Proper control and efficient operation of the plant during startup and shutdown provides for

personnel safety, minimizes wear or damage to the equipment, and minimizes the amount of

and duration of emissions emitted by the facility. Plant emissions may exceed the permit

limits for certain periods of time during boiler startup and shutdown. This situation may be

unavoidable due to the limitations and conditions of the manufacturers recommended startup

and shutdown procedures. The facility is operated to maintain the following critical criteria:

a. Proper valve arrangement for the process operation per plant startup or shutdown

procedures.

b. Boiler water drum level 5” from normal operating level.

c. Drum pressure not to exceed 950#

d. Main steam pressure not to exceed 900#.

e. Main steam temperature not to exceed 9500 F.

f. Furnace draft to operate from -0.2” to -1.5” of water.

g. Furnace temperature not to exceed 7500 F at secondary superheater inlet.

h. Not to exceed Boiler Heating Curve attached in startup procedure #7.

i. Maintain cooling tower level 80% to 95% .

j. Cooling tower water inlet temperature not to exceed 850 F.

k. Condenser vacuum to maintain at least 20” of hg.

l. Hotwell level not to exceed 10 inches from normal operating level.

m. Turbine hood temperature not to exceed 2000 F.

n. DA tank level not to exceed 10% of normal operating level.

o. DA tank temperature not to exceed 2400 F.


31

p. Reduce oxygen level in the boiler to below 8% as soon as operating condition

allow.

q. Maintain feed water pump pressure less than 1300#.

r. Lube oil temperature not to be less than 900 F, or greater than 140

0 F.

s. Maintain boiler water chemistry as per manufacturers recommendations.

t. Maintain hydrogen purity in the generator above 90%.

u. Transformer Rectifier spark rate not to exceed 240 sparks per minute.

v. Account for all personnel on sight at all times.

8.4 Inspections

Inspections are performed on a continuous basic during startup to ensure that the equipment is

operating properly and to observe various changes that may indicate potential malfunction.

The inspections include all previous inspection items listed in this program as well as many

others that pertain to the complete operation of the facility.

8.5 Maintenance

Maintenance is performed to either replace or rebuild various pieces of equipment should a

malfunction occur. Maintenance during startup and shutdown is performed as needed to

ensure a successful operation, and to minimize the amount and duration of excess emissions.

8.6 Abatement Measures

In the event that a malfunction or an abnormal condition should occur during startup or shutdown

the abatement measures listed in the previous sections of this program will be complied with.

9. MATERIAL HANDLING

9.1 Description

FGMATLHANDLING consists of fuel and ash handling for the plant. The major fuel handling

operations includes fuel unloading from trucks, storage piles and storage pile management (i.e.,

loader and dozer moving fuel around), reclaimer, screen, and conveyors. The ash handling

includes removing bottom ash, sand ash and flyash from the boiler and air pollution control

systems, storage, and loading ash into trucks for removal from the site.

9.2 Operation

The material handling systems are continuous operating systems while the boiler is operating.

Fuel is continuously fed to the boiler in an amount greater than needed to operate the plant to


32

ensure continuous flow of fuel to the boiler. The excess material leaves the plant and is piled in

an overfeed area. This material is then reintroduced into the fuel feed system through the reclaim

area.

Bottom ash is removed from the bottom of the boiler in a water bath and stored in an ash bay

located inside the ash building. Sand ash exits from the air heater system and is stored in a

different ash bay in the ash building. The sand ash from the multiclones as well as the flyash from

the ESP is removed and augered in an enclosed system. The ash from the multiclones and

precipitator are mixed together with water in the enclosed system before dropping into a pile in a

separate bay in the ash building. All ash is loaded onto truck to be removed from the site.

9.3 Critical Criteria

The operation of the material handling system is critical in controlling the particulate emissions

from the boiler, as well as dust emissions from the material handling sources. Disruptions in fuel

supply or ash removal can put the plant into an upset condition causing the plant to be less

efficient causing the precipitator to work harder.

9.4 Inspections

Daily inspections are performed on the material handling system to ensure that the equipment is

operating properly and to observe various changes that may indicate potential malfunction. The

inspections to be performed each day are as follows:

a. Fuel operators observe the operation of the fuel system.

b. Plant operators observe the operation of the ash removal system.

Additional inspections are performed on the material handling system weekly by maintenance

personal to ensure that the equipment is in proper operating condition.

Due to the abrasive nature of the fuel and ash materials, packing material in the auger system and

skirting material around the conveyors can erode away and need to be replaced periodically.

9.5 Maintenance

Maintenance on the material handling system is performed in accordance with the manufacture’s

recommendations and plant operating experience. Normal maintenance is performed during the


specification tolerances. Other maintenance will be performed to either replace or rebuild

various pieces of equipment should a malfunction occur and force the shutdown of the boiler

9.6 Spare parts


33

Spare parts are purchased and stored in inventory (packing for ash auger system and skirting for

fuel handling systems).

9.7 Abnormal conditions and malfunctions

The following is a list of specific equipment that is observed and inspected for emissions or

operations outside the permit requirements (i.e., visible emissions):

a. Reclaimer

b. Reclaimer to screen conveyor

c. Screen

d. Screen to boiler conveyor.

e. Feeder distribution conveyor

f. Overfeed conveyor

g. Ash auger 396

h. Rotary air lock 517

I. Ash auger 505

J. Ash auger 506

9.8 Abatement measures

Malfunctions that occur to material handling systems that affect the control of the boiler emissions

are addressed in Section 7.

Malfunctions that occur to material handling systems that result in visible emissions noted in a

daily inspection results in the generation of a work order in the maintenance management system

for repair of skirting for the fuel handling system or packing in the ash handling auger system.

This work order is marked environmental. Any work order marked safety or environmental get

top priority and the cited situation is corrected within 24 hours.

9.9 Time Frame for Abatement Measures

The timeframe for repair of each of the malfunctions listed in table 7.9 are estimates from prior

plant experience. All components of the plant systems are not identical and time frames for repair

will vary somewhat due to location in the plant, accessibility for repairs, and time when


abnormal condition.

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