Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company
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
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
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.
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
· 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 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 Cylinder Gas Audit, and an annual RATA test.
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 Cylinder Gas Audit, and an annual RATA test.
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