.Research Triangle Park WC 27711
Technology Tf anffeE
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Manual

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                                            EPA/625/1-85/019
                                            October 1985
           FLUE  GAS DESULFURIZATION
     INSPECTION AND PERFORMANCE EVALUATION
                    HANUAL
                     I
                      by
             PEI Associates, Inc.
      11499 Chester Rbad, P.O. Box 46100
         Cincinnati, Ohio  45246-0100
                      or
Air and Energy Engineering Research Laboratory
      Office of Research and Development
     U.S. Environmental Protection Agency
      Research Triangle Park, NC  27711
                     and
Center for Environmental  Research Information
      Office of Research  and Development
     U.S. Environmental Protection Agency
            Cincinnati, OH  45268

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                            FOREWORD
     The 1970 Clean Air Act required the U.S. Environmental
Protection Agency  (EPA) to set air quality goals for a list of
priority pollutants.  In December 1971, under Section 111 of the
Clean Air Act, New Source Performance Standards  (NSPS) were
issued to limit emissions of sulfur dioxide  (SO2) , particulate
matter, and- nitrogen oxides  (NOv) from new, modified, and recon-
                               4&
structed fossil-fuel-fired steam generators used in electric
utility and large industrial facilities.  In 1977, amendments
made to the Clean Air Act directed the EPA to tighten emission
standards from new coal-fired utility and large industrial boil-
ers, which resulted in the revised NSPS of June 1979.  In addi-
tion to NSPS, air emissions from coal-fired utility boilers are
also governed by State Implementation Plans  (SIP's) and the
Prevention of Significant Deterioration  (PSD) program.
     As of 1985, flue gas desulfurization  (FGD) was the most
commercially developed means of ; controlling SO2 emissions from
coal-fired powerplants.  Currently, about 16 percent of the
domestic coal-fired generating capacity is controlled by FGD, and
this percentage is expected to double by 1991.  Of the 126 FGD
systems  (representing 53,189 MM of gross power-generating capaci-
ty in the United States) , only nine are dry systems, and these
represent only 3 percent of the! total controlled capacity.  In
contrast, more than 80 percent of the controlled capacity is
equipped with slurry  (wet) systems, which use either lime or
limestone as the SO2 scrubbing reagent.   (This trend is expected
to continue, as 70 percent of the FGD systems now under construc-
tion or for which  contracts have been awarded are of this type.)
                               XI

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     Lime/limestone slurry FGD, however, represents the most dif-
ficult application of scrubbing technology because of the process
design and operation and maintenance  (O&M) considerations re-
quired to withstand the inherent problems of erosion, corrosion,
scaling, arid plugging in such systems.  Inspectors from Federal
and State environmental regulatory agencies need to be familiar
with the problems that plague Ijime/limestone slurry FGD systems
to aid them in their inspections and performance evaluations of
these, systems with respect to compliance with emission standards.
For this reason, and to aid in the permitting process, this
manual was prepared and has bee
i approved for publication.
                              111

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                            ABSTRACT

     Flue gas desulfurization (FGD) is the most developed of the
commercial means of controlling sulfur dioxide (S02)  emissions
from coal-fired powerplants.  Of the 126 FGD systems currently in
service on domestic coal-fired utility boilers, only nine are dry
FGD systems  (representing only 3 percent of the total controlled
capacity).  Conversely, more than 80 percent of this capacity is
controlled by slurry (wet) systems in which either lime or lime-
stone is used as the SO2 scrubbing agent.  This preference is
attributed primarily to favorable costs, demonstrated commercial
operating experience, and simplicity of design and operation.
Because of this widespread usage of lime/limestone slurry FGD,
this manual is devoted exclusively to such systems.
     Despite these favorable aspects, however, lime/limestone
slurry FGD represents the-most difficult application of scrubbing
technology for the control of coal-fired boiler flue gas because
of the process design and operation and maintenance considera-
tions required to withstand the inherent problems of erosion,
corrosion, scaling, and plugging of such systems.
     The intent of this manual is to provide inspectors from Fed-
eral and state environmental agencies with information regarding
the problems that plague lime/limestone slurry FGD systems that
will aid them in their inspections and performance evaluations of
these systems with respect to compliance with the emission stan-
dards that have evolved since the passage of the 1970 Clean Air
Act.
     A unique feature of this manual is its structure as a
"tool," or working document, which will accompany the inspector
on each plant inspection.  Thus, the document is presented in
                                 xv

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"user friendly" fashion and tailored to provide practical infor-
mation for its intended use—to assist in the systematic inspec-
tion of an FGD system to determine present and future compliance
status.  This approach entails the use of nomographs, checklists,
matrices, simplified diagrams, cross-referencing, and indexing of
textual information, and the presentation of important guidelines
and recommendations in a readily discernible fashion.
     With regard to the intended!audience, for purposes of this
manual, the field inspector is defined as the individual who
periodically inspects powerplants to ensure their compliance with
emission standards.  The scope o£ the inspector's responsibility
is defined as ranging from confirmation of existing status re-
ports to anticipation of future compliance status  (i.e., avoid-
ance of potential noncompliance Episodes).
                                 v

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CONTENTS
Foreword
Abstract
Figures
Tables
Metric Conversions
Acknowledgment
1 . Introduction
1.1 Purpose
1.2 Approach
1 . 3 Scope and Content
1.4 Organization of the Manual
2. Lime /Lime stone FGD Technology
2.1 Environmental Regulations
2.1.1 Air Emission Standards
2.1.1.1 1971 NSPS
2.1.1.2 1979 NSPS
2.1.1.3 State Implementation Plans
2.1.1.4 Prevention of Significant
Deterioration
2.1.2 Water and Solid Waste Standards
2.1.2.1 Water Regulations
2.1.2.2 Resource Conservation and
Recovery Act
2.2 Coal Properties and Flue Gas Characteristics
2.3 Basic Principles of Lime /Lime stone Slurry
Processes
2.3.1 Process Description
2.3.2 Operational Factors
2.3.2.1 Stoichiometric Ratio
2.3.2.2 L/G Ratio
ii
iv
xii
XV
xvii
xviii
1
1
1
3
4
8
8
8
8
9
9
11
12
12
12
12
13
15
17
17
18
   VI

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                 CONTENTS I
                      continued)
            2.3.2.3  Slurrjj- pH
            2.3.2.4  Relative Saturation
            2.3.2.5  Oxidation
            2.3.2.6  Chemical Additives

2.4  FGD System Design Configurations
     2.4.1  Development of
                      Technology
            2.4.1.1  Historical Perspective
            2.4.1.2  Characteristics of Technology
                      Generation
     2.4.2  Existing Desigr
                       Configurations
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
•
«

•
•
•
•
•
•
•
•
•
*
•
•
4.
4.
4.
4.
4.
4.
4.
4.
4.
4.
4.
4.
4.
4.
4.
2.
2.
2.
2.
2.
2.
2.
2.
2.
2.
2.
2.
2.
2.
2.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Fans

Scrubby ers /Absorbers
Mist Eliminators
Reheatiers
Ductv/cjrk and Dampers
Reagent Conveyors and Storage
Ball kills
Slakers
Tanks
Thickeners
Vacuum Filters
Centra
Waste
Waste
Pumps
.fuges
Processing
Disposal
and Valves
     2.4.3  Operational Utility Lime and Limestone
             Slurry FGD Systems
2 . 5  FGD O&M Considerations;

     2.5.1  Failure Modes
            2.5.1.1  Coal Characteristics
            2.5.1.2  Boiler Characteristics
            2.5.1.3  Application Characteristics
            2.5.1.4  Desigrji and Operation
                      Considerations
2.5.2  System Layout,
        Design
                           Accessibility, and
19
19
20
20

21

21

21

25

28

30
32
38
39
42
46
50
52
54
55
55
57
60
61
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                          vxi

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                      CONTENTS (continued)
                 2.5
                 2.5
                 2.5.2.3
2.1
2.2
Gas Handling and Treatment
Reagent Preparation and Feed
Waste Solids Handling and
 Disposal
          2.5.3  O&M Practices

                 2.5.3.1  Standard Operations
                 2.5.3.2  Initial Operations
                 2.5.3.3  Startup, Shutdown, Standby,
                           and Outage
                 2.5.3.4  System Upsets
                 2.5.3.5  Operating Staff and Training
                 2.5.3.6  Preventive Maintenance Programs
                 2.5.3.7  Unscheduled Maintenance

3.    Performance Monitoring

     3.1  Key Operating Parameters and Their Measurement

          3.1.1  Gas Circuit Parameters
3.1.1.1
3.1.1.2
3.1.1.3
3.1.1.4
3.1.1.5
SO
NO
Opacity
°2
Gas Flo'
          3.1.2  Slurry Circuit Parameters
                 3.1.2.1
                 3.1.2.2
                 3.1.2.3

     3.2  Instrumentation
     pH
     Slurry Flow Rates
     Solids Content
          3.2.1  pH Instrumentation
          3.2.2  Slurry Flow Rates
          3.2.3  Solids Content

     3.3  Testing and Monitoring

          3.3.1  Manual Testing
          3.3.2  Alternative Methods
          3.3.3  Continuous Emissions Monitoring (CEM)
          3.3.4  Performance Specification Tests
Page

 85
 88

 89

 90

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 94
 95
 95
 97

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 99

100

100
100
100
100
101

102

102
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111
114
                               Vlll

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                  CONTENTS  (continued)
 3.4  Recordkeeping Practices  and  Procedures
 Inspection Methods and Procedures

 4.1  Guidelines for Overall Plant  Inspection
                           i
 4.2  Inspection Procedures

     4.2.1  Gas Handling aikd Treatment

            4.2.1.1  Fans
            4.2.1.2  Scrubbers /Absorbers
            4.2.1.3  Mist Eliminators
            4.2.1.4  Reheaters
            4.2.1.5  Ductwork and Dampers
     4.2.2  Reagent Preparation and Feed
            4.2.2.1  Reagent Conveyors and Storage
            4.2.2.2  Ball Mills
            4.2.2.3  Slakers
            4.2.2.4  Tanks
     4.2.3  Waste Solids Handling and Disposal

            4.2.3.1  Thickeners
            4.2.3.2
            4.2.3.3
            4.2.3.4
            4.2.3.5
            4.2.3.6
Vacuun
Centri
Waste
Waste
Pumps
 Filters
fuges
Processing
Disposal
and Valves
4.3  Summary
Performance Evaluation and Problem Diagnosis/
 Correction

5.1  Data Collection Methods

     5.1.1  Sources
     5.1.2  Forms of Data

5.2  Performance Evaluation

     5.2.1  Emissions
                          IX
 Page

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 142
 142
 142
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 148

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r
                                 CONTENTS (continued)
                            5.2.1.1
                            5.2.1.2
                            5.2.1.3

                     5.2.2  Process
                            5.2.2.1
                            5.2.2.2
                            5.2.2.3
                            5.2.2.4
                            5.2.2.5
                            5.2.2.6
                            5.2.2.7
                            5.2.2.8

                            5.2.2.9
S02
Particulate Matter
Opacity
Gas Flow
Gas-side Pressure Drop
Slurry pH
Slurry Flow
Slurry Solids
Reagent Consumption
Solid Waste Production
Makeup Water Source and
 Consumption
Energy Consumption
                     5.2.3  O&M
                     5.2.4  Observation

                            5.2.4.1  System Observation
                            5.2.4.2  Equipment Layout/Access
                            5.2.4.3  Consumed Equipment
                            5.2.4.4  General Housekeeping

                5.3  Problem Diagnosis and Corrective Measures

                     5.3.1  Problem Diagnosis

                            5.3.1.1  Gas Handling and Treatment
                            5.3.1.2  Reagent Preparation and Feed
                            5.3.1.3  Waste Solids Handling and
                                      Disposal

                     5.3.2  Corrective Actions
                            5.3.2.1
                            5.3.2.2
                            5.3.2.3
Gas Handling and Treatment
Reagent Preparation and Feed
Waste Solids Handling and
 Disposal
           6.    Model O&M Plan
                6.1  Management and Staff
156
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159

= 160
160
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                                           x

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6.1.1
6.1.2
            CONTENTS (continued)
                 Corporate Organization
                 Plant Organization and Training

     6.2  Operating Manuals      }
     6.3  Maintenance Manuals    I
     6.4  Troubleshooting Techniques
     6.5  Spare Parts
     6.6  Work Order Systems
     6.7  Computerized Tracking System

7.   Safety                      i

     7.1  Inhalation of Toxic Gases
     7f2  Skin Irritation and/or IChemical Burns
           to the Skin
     7.3  Exposure to Fugitive Dust
     7.4  Normal Industrial Safety Practices

References

Appendix A - Glossary of Terminology

Appendix B - Equations for Converting Pollutant
              Concentrations to tjfSPS Units

Appendix C - FGD System Inspection Checklist
                                                  Page
226
226

231
234
236
237
239
244

247

247

249
250
251

R-l

A-l


B-l

C-l
                      xi

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                             FIGURES
Number

1.3-1     Lime/Limestone FGD Capacity and Total
           FGD-Controlled Capacity Through 1992

2.1-1     S09 Emission Standards for Coal-Fired Units
           under 1979 NSPS.

2.3-1     Basic Lime/Limestone FGD Process Flow Diagram

2.4-1     Growth of Operational FGD Capacity for
           Utilities

2.4-2     Typical Fan Designs

2.4-3     Venturi Tower Configurations

2.4-4     Spray Tower Types

2.4-5     Tray Tower and Tray Types

2.4-6     Packed Tower and Packing Types

2.4-7     Baffle-type Impingement Mist Eliminators

2.4-8     FGD System Reheat Schematic Diagrams

2.4-9     -Simplified Flow Diagram Showing Damper
           Configurations        ;

2.4-10    Different Damper Designs

2.4-11    Barge-Based Limestone Handling and Storage
           System

2.4-12    Three Types of Conveying Equipment Used to
           Transport Lime

2.4-13    Two Types of Ball Mills Used in Limestone
           Slurry FGD Systems

2.4-14    Basic Types of Slakers;
                                                            Page
10

16


23

31

33

34

36

37

40

41


44

45


48


49


51

53
                                XII

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FIGURES  (continued)
Number
2.4-15
2.4-16
2.4-17
2.4-18
2.5-1
4.2-1
4.2-2
4.2-3
4.2-4
4.2-5
5.2-1
5.2-2
5.2-3
5.2-4
5.2-5
5.2-6
5.2-7
5.2-8
5.2-9
5.3-1
5.3-2

Diagram Showing Components of a Thickener
A Rotary-Drum Vacuum Filter
Components of a Settling Centrifuge
Examples of Pond Types 1 for Waste Disposal
Major Material Flows iih. FGD Systems
Isometric View of a Typical Centrifugal Fan
Typical Tray Tower Absorber
Typical Mist Eliminate]
-
Isometric View of a Tyj
Typical Slurry Recycle
Typical Specific Gravil
Recirculation Slurry :
FGD System
Reagent Requirement Ca.
Sludge (Waste) Product:
Fan Power Requirements
Recirculation Pump Pow«
: Section
>ical Thickener
Centrifugal Pump
:y of Absorber
for Lime /Lime stone
.culation
.on Calculation

>r Requirements
Example Operation Log Sheet
Example Operation Log Sheet
Example of a Handwritten Work Order Form
Example of a Computer-Generated Work Order Form
Gas Handling and Treatment Subsystem
Arrangements |
Reagent Preparation an<
Arrangements
x:
I Feed Subsystem
.ii
Page
56
58
59
62
75
125
128
130
143
150
165
167
168
175
176
177
178
180
181
187
198


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                       FIGURES (continued)
Number

5.3-3


6.1-1


6.2-1

6.3-1
Waste Solids Handling and Disposal Subsystem
 Arrangement

Organizational Diagram for Coordinated FGD
 System O&M Program

Outline for FGD Operating Manual

Outline for FGD Maintenance Manual
207


229

233

235
                                xxv

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Number

2.2-1

2.4-1



2.4-2

2.4-3a



2.4-3b



2.5-1

2.5-2


2.5-3


2.5-4

3.2-1

3.2-2


3.3-1



3.3-2

3.3-3

4.1-1
                             TABLES
Fuel Properties of Fou:: Representative Coals

Typical Characteristics of First, Second, -and
 Third Generation Lime/Limestone Slurry FGD
 Systems

FGD Subsystems Requiring Tanks

Design and Operating Data for Operational
 Utility Lime/Limeston^ Slurry FGD Systems
 in the U.S.  (General Data)

Design and Operating Data for Operational
 Utility Lime/Limestone Slurry FGD Systems
 in the U.S.  (Specific

Major Power Plant Cons

Summary Listing of the
 Major Equipment Area

Subsystem Outage Times
 Hours  (MEH)

Summary of Failure Mod

pH Instrumentation on

pH Instrumentation on
 FGD Systems
 Data)

Lderations

 FGD Subsystems by
 in Module Equivalent
e Analysis

Lime Slurry FGD Systems

Limestone Slurry
 Summary of Manual  Emissions Measurement
 Methods  for  an FGD  System on  a  Coal-
 Fired Utility Boiler

 Principles Used in Gaseous Emission  Monitors

 GEM System Components

 General Plant Data
Page

 14



 27

 54



 64



 68

 73


 76


 78

 84

 105


 106



 109

 112

 113

 122
                                xv«

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                       TABLES  (continued)
Number

4.2-1     Control Room Checklist

4.2-2     Fan Checklist         ,

4.2-3     Scrubber/Absorber Checklist

4.2-4     Mist Eliminator Checklist

4.2-5     Reheater Checklist

4.2-6     Ductwork/Damper Checklist

4.2-7     Reagent Conveyor Checklist

4.2-8     Ball Mill Checklist

4.2-9     Slaker Checklist

4.2-10    Tank Checklist        ;

4.2-11    Thickener Checklist

4.2-12    Vacuum Filter Checklist

4.2-13    Centrifuge Checklist

4.2-14    Waste Processing System Checklist

4.2-15    Waste Disposal System Checklist

4.2-16    Pump and Valve Checklist

5.2-1     Design Gas-Side Pressure Drops for Absorbers
           in Operational Lime/Limestone FGD Systems

5.2-2     Design Gas-Side Pressure Drops for Mist
           Eliminators in Operational Lime/Limestone
           FGD Systems

5.2-3     Makeup Water Consumption Rates for
           Operational Lime/Limestone FGD Systems

5.2-4     Energy Requirement Calculations

6.6-1     Work Order Priority System
124

126

129

132

133

135

137

139

140

141

144

145

146

147

149

151


161



162


•171

173

242
                               xvi

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                        METRIC CONVERSIONS
      This manual expresses measurements in English units  so  that

 information is clear to the intended audience in the United
               ' -     .,-,,''''!   I ..'I'.'.; i . :   t,       ,   ••- ,        .-
 States.   The following list prcjvides factors for conversion  to
 metric units.
 To convert from

 Btu
 Btu/lb
 cfm
 °F
 ft
 ft/h
 ft/s
 ft2
 ft3
 ft3
 gal
 gal/ft3
 gal/min
 gr
 gr/scf
 hp (mechanical)
 hp (boiler)
 in.
 in. H2O
 in.2
 in.3
 Ib
 Ib
 lb/106 Btu
 lb/ft3
 Ib/gal
 Ib/in.2
 Ib-mol
 Ib-mol/h
 Ib-mol/h per ft2
 Ib-mol/min
 scfm  (at 60°F)
ton
      I  To
 kWh
 kJ/kg
 m3/h
 °C
 m
 m/h
 m/s
 m2
 liters
 m3
 liter
 liter/[m3
 liter/Jmin
 g
 g/Nm3
 kw
 kw
 cm
 kPa
 m2
 m3
 g
 kg
 g/kj
 kg/m3
 kg/m3
 kPa
 g-mol
g-mol /ijnin
g-mol/min per m2
g-mol/s
Nm3/h (at 0°C)
kg
                               X
                                7X1
  Multiply by

   0.0002931
   2.326
   1.70
 (°F  - 32)/I. 8
   0.305
   0.305
   0.305
   0.0929
  28.32
   0.02832
   3.785
   0.134
   3.79
   0.0648
   2.29
   0.7457
   9.803
   2.54
   0.2488
   0.0006452
   0.00001639
453.6
   0.4536
429.9
 16.02
119.8
  6.8.95
453.6
  7.56
 81.4
  7.56
  1.61
907.2

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                         ACKNOWLEDGMENT

     This manual was prepared under the sponsorship of several
divisions of the U.S. Environmental Protection Agency.  Those who
provided guidance and coordination were Theodore G, Brna and
Julian W. Jones, Air and Energy Engineering Research Laboratory;
Norman Kulujian, Center for Environmental Research Information;
and Kirk Foster arid Sonya Stelmack, Stationary Source Compliance
Division, Technical Support feranch.  The PEI Project Director was
Bernard A. Laseke and the PEI Project Manager was E. Radha
Krishnan.  The PEI principal investigators were Messrs. Ronald S.
McKibben and Michael T. Melia.
                               xviii

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                             SEC
                                ION 1
                                  Desulfurization  Inspection and
                                 s to provide guidance to Federal
                          INTRODUCTION
1.1  PURPOSE
     The purpose of the Flue Ga
Performance Evaluation Manual i
and state environmental regulatory personnel involved in the
inspection and permitting of flue gas desulfurization  (FGD)
systems for electric utility cokl-fired steam generators  (boil-
ers) in the United States.
     The primary intended user of this manual is the field in-
spector directly involved in the inspection of operational,
FGD-equipped, coal-fired, utility boilers.  For the purposes of
the manual, the field inspector is defined as the individual who
periodically inspects power plants to ensure compliance with
emission standards.  The scope of the inspector's responsibility
is defined as ranging from confirmation of existing status re-
 ports to anticipation of future
 ance of potential noncompliance
 tal regulatory agency permitter,
 the permitter is defined as the
                                compliance status (i.e., avoid-
                                episodes).
      A secondary intended user of this manual is the environmen-
                                  For the purposes of the manual,
                                individual who reviews permit
 applications for new capacity in accordance with adherence to
 environmental regulations and eijiission standards.  Although the
 permitter is not specifically "targeted" in the manual, pertinent
 orientation material is presented on the design, operating, and
 performance characteristics of FGD systems.
 1.2  APPROACH
      The philosophy adopted for
                                the preparation of this manual is
 unique in comparison to other FGD technology manuals.   As stated,
SECTION 1-INTRODUCTION

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one of the intended user groups is environmental regulatory
personnel.  Other similar manuals generally define their intended
users as the owner/operator utility, architect-engineer, research
firm, and/or technology investigator.  This manual represents the
first of its kind in addressing solely the needs of environmental
regulatory agency personnel.
     Another unique feature of this manual is its intended use.
The manual is structured as a "tool", or working document,, which
will accompany the inspector on each plant inspection.  This
contrasts to the use of other similar manuals in that they are
often read and then filed away for possible future reference.  To
adequately serve as a working document, two major objectives must
be accomplished in the organization of the material.  First, the
document must provide practical information tailored to its
intended use, namely, the systematic inspection of an FGD system
to determine present and future compliance status.  This requires
that information on process theory be limited to a necessary
minimum.  Secondly, the information must be presented in a "user-
friendly" format in order to encpurage use.  This is accomplished
through the use of nomographs-, checklists, matrices, simplified
diagrams, cross-referencing and indexing of textual information,
and by presenting important guidelines and recommendations in a
conspicuous fashion.
     A final unique feature of the manual is its use for the
interpretation of sulfur dioxide1 (SO2) excess emission  reports.
If an FGD-equipped boiler represents a source of frequent SO2
excess emission reporting, the manual will provide guidelines to
determine the cause and to evaluate the remedial actions to be
taken by the plant operator.  If'an FGD-equipped boiler repre-
sents a source of infrequent SO»  excess emission reporting, the
                               £* ,
manual will provide guidelines to identify the  contributing
factors that are associated with! this situation.
SECTION 1-INTRODUCTION

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  1.3  SCOPE AND CONTENT
       The scope of the manual is Idevoted exclusively to lime/lime-
  stone slurry FGD processes.  Flue gas desulfurization systems
  are generally the last pieces of
 equipment used to handle the
  boiler flue gas before it reaches the stack.  In lime/limestone
  slurry processes, SO_ in the flus gas stream is removed with the
  aid of dilute limestone or lime slurries.  The treated flue gas
  is cooled and saturated with moisture in the process.  A more
  thorough description of the processes is presented in Section 2
  (Section 2.3, Basic Principles of Lime/Limestone Slurry
  Processes;  Section 2.4, FGD Syst
       The scope of FGD technology
  limited to  tail-end, "wet" lime/
  excluding:
       0   all tail-end processes
=m Design Configurations).
 addressed in this manual is
Limestone slurry processes  only,
 that do not use calcium-based
            (lime/limestone)  additives as the SO- reactant (e.g.,
            sodium/calcium [dual or double alkalx], sodium/thermal
            regeneration [Wellman-JLord] , magnesium oxide [Mag-Ox] ,
            and sodium [once-throu
            trona,  nahcolite]).
            all tail-end processes
            the flue gas during tr
jh soda ash,  sodium hydroxide,
 that do not completely saturate
2atment, known as "dry scrubbing"
            (spray drying,  dry sorpent injection).
       0    precombustion and in-sLtu (combustion)  SO,, control
            techniques which may involve the use of calcium alkali
            additives (e.g., limestone injection multistage burner
            [LIMB], lime furnace injection).
       The rationale for emphasizing lime/limestone slurry processes
  is based on their widespread use
 in the power industry because of
  their level of process development and economics.  Since the
  early application of FGD to control SO2 emissions from boiler
  flue gas,  there has been pronounced preference for lime/limestone
  slurry processes (see Section 2.J4.1.1; Historical Perspective).
  Presently, plants equipped with FGD systems using lime' or lime-
  stone slurry represent over 80 percent of the electric generating
  capacity with emissions controlled by FGD.  A perspective of the
  historical and projected future application of lime/limestone
SECTION 1-INTRODUCTION

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slurry processes is illustrated in Figure 1.3-1.  It shows the
installed capacity controlled by lime/limestone slurry processes
as a function of the capacity controlled by all processes.
     Detailed cost studies indicate that both the capital and the
annual costs are generally less than those of other FGD processes.
Additionally, the on-line experience of commercial systems at
utility plants'has generated a wealth of operational data which
are being used to enhance system reliability.  Advances in waste
disposal technology/ such as forced oxidation to produce more
easily dewatered calcium sulfate, have enabled utility operators
to reduce the volume of waste for,disposal as well as improving
its handling and disposal properties.  Advances in process chem-
istry, such as magnesium salts and organic acid additives, have
enabled operators to improve performance with respect to S02
removal, process chemistry, service time, and cost effectiveness.
With continuing technological advances and increasingly wider
utilization, lime/limestone slurry processes are considered the
major means of compliance with New Source Performance Standards
promulgated by the U.S. Environmental Protection Agency  (EPA) for
control of SO2 emissions from power plants  (see Section  2.1.1;
Air Emission Standards).
     The scope of the manual is the complete battery limits of
the entire FGD. process.  These boundaries are defined from the
inlet gas stream to the final waste disposal site.  All  opera-
tions in between are examined, including gas handling and treat-
ment, reagent preparation  and feed, and waste -solids handling and
disposal.  Moreover, operations and factors  that  influence the
FGD process  envelope are considered,  including  coal characteris-
tics and consumption, boiler design and operation, and particu-
late emissions  control  and operation.

1.4  ORGANIZATION  OF THE MANUAL   ;,  ,   .:•.•:••
     The manual is  structured  in  accordance  with  its  overall
purpose of providing a  constant  companion  to the  environmental

 SECTION 1-INTRODUCTION

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          0
           72  73  74  75  76  77  78  79' 80 8
           Figure 1,3-1.  Lime/1imestor
                        controlled cgpe
aTotals reflect  end of year values.
  82  83  84  8§  86  87  88  89 90 91 92

 YEAR
e F6D capacity  and total  F6D-
city through  ]992.a

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 regulatory agency inspector of FGD-equipped,  coal-fired,  utility
 boilers.   At the outset,  therefore, an overview of lime/limestone
 FGD technology is presented (see Section 2).    Next,  a review of
 the environmental regulations which govern utility coal-fired
 boilers and, in effect,  have driven the commercial application of
 FGD technology is provided.  A description of lime/limestone
 slurry processes including process theory and basic principles,
 system and equipment configurations,  and operation and mainten-
 ance considerations is also discussed.
      In succeeding sections, the practical guidelines associated
 with inspection and performance evaluation are presented.   Sec-
 tion 3 deals with FGD performance monitoring, starting with key
                                  I
 operating parameters and their measurement.   Particular attention
 is given to continuous emission monitoring procedures and manual
 test methods for determining compliance with  SO,, standards.  Sec-
 tion 4 is the focal point of the manual—inspection methods and
 procedures.  This information is provided in  a series of step-by-
 step detailed procedures.  Section 5  continues with guidelines on
 how to Use and interpret the. data observed and collected by the
 inspector with respect to performance evaluation,  problem diagno-
 sis, and correction.  Section 6 describes guidelines  for general
 operation and maintenance (O&M) practices based on acceptable
 "industry standards" that are necessary for high performance lev-
 els.  Operating practices and maintenance practices are described
 separately and in detail by component, equipment,  subsystem,
 sequence, roles, and activities.  The guidelines are  used to
 develop a model O&M plan summarizing  the important aspects of an
 adequate O&M program that should be practiced by the  owner/oper-
 ator utility in order to achieve satisfactory performance.
 Section 7 briefly addresses safety procedures and precautionary
 measures which should be adhered to during the course of a plant
 inspection.
      The appendices consist of supplementary  reference material,
 giving more specific details concerning the topics discussed in
SECTION 1-INTRODUCTION

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  Sections 2 through 7.   The append!
  of FGD terminology,  calculation
dices are devoted to definitions
sheets, and example- checklists
  which will be used by the inspector during a plant inspection.
  The  inspector may wish to reproduce and make several copies of
  the  checklists and keep them separate for the purpose of con-
  ducting an inspection.   As the inspector becomes more experienced
  and  relies less on the manual, he or she may be able to tour the
  facility without carrying the manual throughout the powerplant.
SECTION 1-INTRODUCTION

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                              SECTION 2
                   LIME/LIMESTONE FGD TECHNOLOGY
     This section presents a  discussion of  lime/limestone  slurry
FGD technology.  The overview includes a discussion of  1)  per-
tinent environmental regulations,  2) coal properties and flue gas
characteristics, 3) basic principles of lime/limestone  slurry
processes, 4) design configurations, and 5) operation and  main-
tenance considerations.  Appendix  A presents a glossary of FGD-
related terms used in this manual.

2.1  ENVIRONMENTAL REGULATIONS
2.1.1  Air Emission Standards
     The 1970 Clean Air Act required the U.S. EPA to set air
quality goals for a list of priority pollutants.  In December
1971, under Section 111 of the Clean Air Act, New Source Perfor-
mance Standards  (NSPS) were issued to limit emissions of SO-?
particulate matter; and nitrogen oxides (NO ) from new, modified,
                                           3C
and reconstructed fossil fuel-fired steam generators used  in
electric utility and large industrial facilities.  In 1977,
amendments were made to the Clean  Air Act, directing the EPA to
tighten emission standards for new coal-fired utility and  large
industrial boilers, resulting in the revised NSPS of June  1979.
In addition to the NSPS, air emissions from coal-fired  utility
boilers are also governed by the State Implementation Plans  (SIP)
and the Prevention of Significant  Deterioration  (PSD)  program.
2.1.1.1   1971 NSPS.  These standards apply to fossil fuel-fired
steam generating units capable of  firing more than 250 million
Btu/h heat input (to the boiler)  and upon which construction
commenced after August 17, 1971.
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                8

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          SO,  Standards.   Sulfur!  dioxide  emissions are limited to
          1.2  lb/10b  Btu  heat  irlput.
          Particulate  Standards.
          limited to 0.10  lb/106
                        Particulate emissions  are
                       Btu heat  input.
      0    NO  Standards.  Nitrog'en  oxide  emissions  are limited to
          0.70  lb/10b Btu heat  dlnput.

2.1.1.2   1979  NSPS.  These  standards  apply  to  electric utility
steam generating units capable  of firing  more than  250 million
Btu/h heat input of fossil  fuel
other fuels) and upon which construction  commenced  after  Septem-
ber 18, 1978.
          SO, Standards.  Sulfur
          a maximum of  1.2 lb/10
                       (alone or in combination with
                       dioxide emissions are limited to
                        Btu heat input.  In addition, a
          percentage reduction in SO2 emissions  (based  on  the
          sulfur content and heating value of the  fuel) must be
          achieved.  Figure  2.1-j
                                P£
                        depicts the allowable SO.
emissions under the NSPS for different sulfur levels
via a sliding percentage removal scale.  The percentage
reduction must be at least 70 percent under all condi-
tions, and the SO2 emission rate must not exceed 0.60
lb/106 Btu unless at least a 90 percent reduction is
achieved.  Compliance with these requirements is deter-
mined on the basis of la 30-day rolling average and is
determined with continuous emission monitors.
          Particulate Standards.
          limited to 0.03 lb/106
                        Particulate emissions are
                       Btu heat input.  The opacity
          standard limits the opacity of emissions to  20 percent
          (6-minute average).  Compliance with the particulate
          standards is determined through performance  tests.
          Continuous monitors are required to measure  and record
          the opacity of emissions.

     °    NO  Standards.  Nitrogbn oxide emissions are limited to
          O.BO lb/10b Btu heat input for bituminous coals, 0.50
          lb/106 Btu for subbituminous coals, and 0.60 lb/106 Btu
          for most lignites.  Continuous compliance is determined
          on the basis of a 30-dky rolling average.

2.1.1.3   State Implementation PJLans.  State and local standards

for SO2, particulates, and NO , kimed at achieving and maintain-
                             x1
ing national ambient air quality
gated under the SIP's required under the Clean Air Act.  Where
                       standards (NAAQS), are promul-
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY

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                                                                 CO

                                                                D
                                                                 O
                                                                   CSJ
                                                                 o
                                                                 co
                                                                 co
                                                                 
                                                     o -i-
                                                     o en

                                                     4-
                                                     o
                                                                            (LI
                                                                            O
                                                                            o
                                                                             rs
                                                                            CO
                                                                            *
                                                                                    00
                                                                                    O-
                                                                                    en
                                                                                    s-
                                                                                    OJ
                                                                                    •a
                                                                                     cu
                                                                                     s_
                                                                                     o
                                                                                     o
-a

 
-------
      state and local regulations are more stringent than Federal NSPS,
      they govern emission limits from coal-fired steam generating

      units.  A number of states have set the maximum S02 emission
      limit below 1.2 lb/106 Btu heat input for designated areas within
      the state (if not statewide).  Differences may also be encoun-
      tered in particulate and NO  standards.
      2.1.1.4   Prevention of Significant Deterioration.  The 1977
      Clean Air Act Amendments incorporate specific sections regarding
      PSD of ambient air quality in areas and regions where the air
      quality is better than standards!  The .PSD regulations are
      implemented by the individual states through the SIP's on a
      case-by-case basis.
           Under the PSD program, clean areas of the nation  (i.e.,
      those where pollutant levels are
      as Class I, II, or III, with each class representing a specific
      amount or increment of allowable
below  the NAAQS)  are  classified
 deterioration.   Class  I  incre-
      ments permit only minor air quality deterioration, Class II
      increments permit moderate deterioration consistent with normal
      growth, and Class III increments permit considerably more deteri-
      oration.  In no case, however, can the deterioration reduce the
      area's air quality below that permitted by the NAAQS.
           In addition to the increment concept and classification
      system, PSD regulations require  -hat each major new or modified
      source apply Best Available Control Technology  (BACT).  Best
      Available Control Technology is determined on a case-by-case ba-
      sis for each pollutant; it must represent an emission limitation
      based on the maximum achievable degree of reduction, taking into
      account energy, environmental, a
id economic impacts.   At a mini-
      mum, BACT must result in emissions not exceeding any applicable
      NSPS or National Emission Standards for Hazardous Air Pollutants
       (NESHAP).  The PSD regulations a
       for Class I or "pristine" areas
       values", such as visibility.
Lso provide further protection
Ln terms of "air quality related
       SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
_
                                       11

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2.1.2  Water and Solid Waste Standards
     Local, state, and Federal regulations relating to water
pollution or land use also affect the design of an FGD system.
2.1.2.1   Water Regulations.  The Clean Water Act of 1977 reg-
ulates the discharge of power plant effluents into any natural
water bodies. . Under the Federal Clean Water Act and similar
state laws, every discharge of pollutants into surface water must
be sanctioned by a permit, referred to as the National Pollutant
Discharge Elimination System  (NPDES) permit.
2.1.2.2   Resource Conservation and Recovery Act.  The Resource
Conservation and Recovery Act  (RCRA) of 1976 governs the develop-
ment of programs for environmentally safe solid waste disposal
including both hazardous and nonhazardous wastes, including
sludges as well as solids.  Flue gas emission control waste
generated from the combustion of coal or other fossil fuels falls
under the Act's definition of a solid waste.  However, it is
temporarily excluded from Subtitle C classification as a hazard-
ous waste under the 1980 amendment to RCRA, which requires EPA to
make a report to Congress on the environmental hazards, if any,
posed by the disposal of these wastes.  Subtitle D of RCRA con-
cerns the more general problems of waste disposal.  Such a status
is currently assigned to FGD waste.  Under Subtitle D provisions,
the management of nonhazardous solid waste remains essentially a
state and local function.  Subsequent to the submittal of :this
report,-the EPA administrator may make a determination whether
these wastes will be regulated under Subtitle C  or Subtitle D of
RCRA.

2.2  COAL PROPERTIES AND FLUE GAS' CHARACTERISTICS
     The properties of the coal fired in a utility boiler deter-
mine the flue gas characteristics, as well as the degree of SC>2
controls needed for the FGD system.  Typical fuel properties of
four widely used types of coal from prominent coal reserves in
the United States are listed  in Table 2.2-1.
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 12

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      The sulfur content and heating value of  the  coal  establish
 the amount of SO2 produced during combustion  as shown  in Figure
 2.1-1.  The amount of SO2 producid is typically the most impor-
 tant factor in determining the type and overall design considera-
 tion for the FGD system.  Other toal properties which  can affect
 FGD system design/operation include chlorine  and  ash content.
 The chlorine content of the coal
 struction and the ability of an FGD system to operate in a closed
 water loop.  Chlorine content is
 about 0.01 weight percent to mor<
                             affects the materials of con-
                             highly variable,  ranging from
                             : than 0.6 percent.   Ash content
 of coal ranges from less than 3.4 to more than 15 percent.  If
 large quantities of ash are collected in the FGD system (i.e.,
 they are not removed by upstream
 ment),  erosion and plugging of absorber internals and piping may
 occur.   In addition,  the extra ncnreactive solids may have an
 adverse impact on the waste solids disposal subsystem.  On the
 other hand,  the fly ash of western subbituminous and lignite
 coals contains sufficient alkalinity to provide some or all of
 the  S02 reagent requirements.   Ths principal alkaline species in
 coal ash which can be used are calcium, magnesium,  sodium,  and
 potassium  oxides.   Fly ash alkalinity has  been  used in numerous
 FGD  systems  for SO9 absorption.
2.3
                             particulate .collection equip-
BASIC PRINCIPLES OF LIME/LIMESTONE SLURRY PROCESSES
This section provides a brie:: discussion of the basic prin-
ciples of lime/limestone slurry process chemistry.  Principal
chemical reactions are identified
associated with process chemistry
                             and the operational factors
                             are defined.  The emphasis of
this discussion is on practical considerations of importance to
the agency inspector.  A more thorough description of process
design is provided in Section 2.4
tions) .
                             (FGD System Design Configura-
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                13

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                                s
                                                 r-. co •-; •*
                                             ,-t f> ,O O O O
                                                                  C«:«e«:«t«<:i«-a-a
                                                                  IZZZZZIZ—IZ
OO
o
o
     CSJ t-1 IO

SuJrH^O^

r-,»r r->  «3
                                                                      i 
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   2.3.1  Process Description
        The basic lime/limestone FGD  process  is  shown schematically
   in Figure  2.3-1.  Although there
 are  systems which produce  a
   salable byproduct  (i.e.,  gypsum  for wallboard construction), the
   vast majority use the  throwaway  process configuration  shown in
   Figure 2.3-1.   This type  of system is at present considered by
   the utility  industry to  be the 3
   among all of the commercially a\
east expensive to  own and operate
ailable systems.
        In the  lime/limestone FGD process shown  in Figure  2.3-1,
   flue gas,  from which fly ash has been removed in a particulate
   collection device such  as an electrostatic precipitator (ESP) or
   a  fabric filter, is brought into contact with the lime/limestone
   slurry in  the absorber,  where ScL  is removed.   The chemical reac-
   tion of lime/limestone  with SO?
   solids, which must be removed cc
   These waste  solids are  concentre
   dewatered  in a vacuum filter to
from  the flue gas  produces waste
ntinuously from  the slurry loop.
ted in  a thickener and then
produce a filter "cake" which is
  mixed with  fly ash.  The resulting stabilized mixture  is then
  transported to a landfill.   This  lime/limestone FGD system is
  called a "throwaway" process because it produces a waste byproduct
  for disposal rather than for processing to  recover salable gypsum.
        The principal chemical reactions for the lime/limestone FGD
  process are presented  below according to SO?  absorption, lime-
  stone dissolution, and lime dissolution.
         Limestone
      CaC03(s) + CaC03(aq)
  CaCO,(aq) + Ca++(aq) + C03~(aq)
   C03"(aq) + H+(aq) •»• HC03"(aq)
   S03=(aq) + H+(aq) -» HS03"(aq)
Ca++(aq) + S03=(aq) + if
Ca++(aq) + S04'(aq) + 2t
                 CaS04-2HgO(s)  HS03"(aq) + J02(aq
* g • gas phase; aq - aqueous phase; and s = solid phase
                                 Absorption *
                                S02(g) * M2(aq)
                              S02(aq) + H20 * H2S03(aq)
                              H2S03(aq) + HSO "(aq) + H^faq
                              HS03'(aq) - U, (aq) + H+(aq)
                             S03~(aq) + i02(aq) *_S04-(aq)
                                                              Lime
                   CaO(s) + H20 * Ca(OH)2(aq)
                 Ca(OH)2(aq) -> Ca+t(aq) + 20H"(aq)
                   OH'(aq) + H+(aq) -«• H£0
                  S03=(aq) + H+(aq) + HS03"(aq)
              Ca++(aq) + S0,=(aq)
               4.-I-.     J= _
S04= (aq) + H+(aq)  Ca++(aq) + S04"(aq)
                               CaS04'2H20(s)
   SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                      15

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                      CLEAN
                    FLUE GAS
  FLUE 6AS
      LIME/
    LIMESTONE
     SLURRY
TO DISPOSAL
                            VACUUM
                             FILTER
THICKENER
 OVERFLOW
   TANK
      Figure 2.3-1.   Basic lime/limestone FGD process flow diagram.
                                  16

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      Although not shown in the process flow diagram,  the major
 equipment  design difference between the two processes is reagent
 feed  preparation.   In the lime process, the reagent is slaked;
 limestone  is  ground in a ball mill.
 2.3.2   Operational Factors
     The  basic  operational fact
1
rs one should be acquainted with
when  inspecting lime/lime stone silurry. FGD systems are discussed
below.   Knowing these factors and how they are interrelated with
the process  chemistry of each system will provide an understanding
 of  how each process functions in
 guidelines  to be used during an
 2.3.2.1  Stoichiometric Ratio.
 defined as  the ratio of the actu!
  addition to providing a set of
 inspection.
  The Stoichiometric ratio  (SR) is
 al amount of SO0 reagent, calcium
 oxide  (CaO),  or calcium carbonate (CaCO_)  in the lime or lime-
 stone  feed to the absorber,  to the theoretical amount required to
 neutralize the SO2 and other acidic species absorbed from the
 flue gas.   Theoretically,  one mole of CaO or CaCO., is required
 per mole of SO2 removed (SR =1.0).   In practice, however, it is
 usually necessary to feed  more than the Stoichiometric amount of
 reagent in order to attain the degree of SO2 removal required.
 This is because of mass transfer  limitations which prevent com-
 plete  reaction of the absorbent.
     If a  high SO2 removal efficiency is required, the absorber
 may" not  be able to achieve such
 is  provided by feeding excess re
 removal unless extra alkalinity
 agent.  The amount of excess
 reagent  required depends upon the SO2 concentration in the inlet
 gas,  gas flow,  percent SO., removal required,  and absorber design.
                          ^
 For lime reagent, the SR employed in commercial FGD systems is
 1.05  for newer designs;  however,
 designs.   For limestone  reagent,
 designs;  however,  it may be as high as 1.4 in older designs.
  it ranges up to 1.2 for older
  a SR of 1.1 is used in newer
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 17

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      If the reagent feed is too much in excess,  the  results  are
 wasted reagent and increased sludge volume.  Excessive  over-
 feeding can also result in scaling in the  form of CaCO_  in the
                                   :                    *J
 upper part of the absorber for lime systems, and calcium sulfite
 (CaSOg'Jg H2°^ ' SOItietimes referred1 to as soft scale,  in  the lower
 part of the absorber for limestone systems.  Excess  reagent  can
 also be carried up into the mist  eliminator by entrainment,  where
 it can accumulate, react with SOy, and form a hard calcium
 sulfate (CaSO4«2H20) scale  (by sulfite oxidation).   This is
 particularly a problem with limestone systems.   Calcium  sulfate
 (or gypsum) scale is especially undesirable because  it  is very
 difficult to remove.  Once formed, the scale provides a  site for
 continued precipitation.  Calcium'sulfite  scale  can  generally be
 easily removed by reducing the operating slurry  pH  (see  Section
 2.3.2.3) or rinsing manually with water.
      Scale formation is usually more prominent in limestone
 systems than lime systems, particularly for high sulfur  coal
 applications.  Lime systems have  a greater sensitivity to pH
 control because lime is a more reactive reagent.  The change in
 pH across lime systems is.more pronounced than in limestone
 systems partly because limestone  dissolves more  slowly.
 2.3.2.2   L/G Ratio.  The ratio of slurry flow in the absorber to
 the quenched flue gas flow, usually expressed in units of gal/1000
 ft , is termed the liquid-to-gas  (L/G) ratio.  Normal L/G values
 are typically 30 to 50 gal/1000 ft3 for lime systems2 and 60 to
                3                       3
 100 gal/1000 ft  for limestone systems.   Lime systems require
 lower L/G ratios because of the higher reactivity of lime.   A
 high L/G ratio is an effective way to achieve high SO2 removal;
 this also tends to reduce the potential for scaling  since the
 spent slurry from the absorber is more dilute with respect to
 absorbed SO,,.  Increasing the L/G ratio can also increase system
 capital and operating costs because of greater capacity  require-
 ments of the reaction tank and associated hold tanks, dewatering
SECTION 2-L1ME/LIMESTONE FGD TECHNOLOGY
                                 18

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 equipment, greater pumping requirements, slurry preparation and
 storage requirements, and reagent and utility necessities.
 2.3.2.3   Slurry pH.  Commercial experience has shown that fresh
 slurry pH as it enters the absorber should be in the range of  8.0
                        4                                       1
 to 8.5 for lime systems  and 5.5 to 6.0 for limestone systems.
                               SO
In both FGD processes, as the SO9 is absorbed from the flue gas,
                                £*
the slurry becomes more acidic and the pH drops.  The pH of the
spent slurry as it leaves the absorber is in the range of  6.0 to
                                                           1
 6.5 for lime systems and 4.5 to
                                5.0 for limestone systems.   In
 the reaction tank of the absorber, the acidic species react with
 the reagent and the pH returns to its original fresh slurry
         Slurry pH is controlled by adjusting the feed stoichio-
         Operation of lime/limestone FGD systems at low pH levels,
value.
metry.
approaching 4.5, will improve reagent utilization but will also
 lower SO? removal efficiency and
 scale (gypsum) formation because
 pH levels (see Section 2.3.2.5).
 systems at high pH levels, above
 tend to improve SO- removal effi
 to maintain sensitive control of
 lowered SO2 removal efficiencies
 2.3.2.4   Relative Saturation.
 the term "relative saturation"  (RS) pertains to the degree of
 saturation (or approach to the s
                                 also increase the danger of hard
                                 of increased oxidation at lower
                                  Operation of lime/limestone FGD
                                 8.5 and 6.0 respectively, will
                                ciency but also increases the
 danger of soft scale  (calcium sulfite) formation.  Hence, control
 of slurry pH is essential to reliable operation.  The inability
                                 the slurry pH can lead to both
                                 and hard/soft scale formation.
                                In lime/limestone FGD processes,
                                 ilubility limit) of calcium
 sulfite and sulfate in the slurry? RS is important as an indica-
 tor of scaling potential, especially of hard scale, which can
 present severe maintenance problems.  Relative saturation is
 defined as the ratio of the .product of calcium and sulfate ion
 activities (measured in terms of
 product constant.  The solution
                                 concentrations) to the solubility
                                is subsaturated when RS is less
 than 1'. 0, saturated when RS equals 1.0, and supersaturated when
 RS is greater than 1.0.  Generally lime/limestone processes will
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 19

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 operate in a scale-free mode when the RS of calcium sulfate is
 maintained below a level of 1..4 and the RS of calcium sulfite is
                                               5
 maintained below a level of approximately 6.0.   Operation below
 these levels provides a margin of safety to ensure scale-free
 operation.  This is achieved through proper design and control of
 process variables  (e.g., L/G, pH).
 2.3.2.5   Oxidation.  An important chemical consideration in
 lime/limestone processes is the oxidation of sulfite to sulfate.
 Uncontrolled oxidation across the absorber leads to sulfate
 formation and resultant hard scaling problems on the absorber
 internals.  Sulfite oxidation can occur either naturally or it
 can be artificially promoted (i.e., forced oxidation).  Natural
 oxidation occurs when sulfite in the slurry reacts with dissolved
 oxygen (0~), which has been absorbed either from the flue gas or
 from the atmosphere'  (e.g., during agitation in the reaction
 tank).  With forced oxidation, air is bubbled into the absorber
 reaction tank to further promote oxidation.  This prevents the
 dissolved sulfite in the slurry f;rom returning to the absorber
 which minimizes the potential for the oxidation of the sulfite to
 sulfate in the absorber and resultant hard scaling problems.
 Forced oxidation has additional advantages of reducing the total
 volume of waste generated because of improved dewatering char-
 acteristics of the sulfate solids and improved characteristics of
 the final solid waste product.  Oxidation tends to increase with
 decreasing slurry pH.  For this reason, forced oxidation is
 normally employed only with limestone systems.
 2.3.2.6   Chemical Additives.  In recent years, inorganic and
 organic additives have been used to improve SO., removal effi-
                                               ^
 ciency, increase reagent utilization, decrease solid waste vol-
 ume, and decrease scaling potential of lime/limestone FGD sys-
 tems.  Magnesium oxide is the most widely used additive.
 Dicarboxylic acids, in the form of adipic acid or dibasic acids,
 are also used commercially.
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 20

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      Magnesium oxide additives permit a higher SO, removal rate
 per unit volume of slurry.  This| is because the salts formed by
 the reaction of magnesium-based additives with the acid species
 in the slurry liquor are more soluble with respect to those of
 the calcium-based salts.  This i
                                 i turn increases the available
                                 I
                Dibasic acids enhance SO- removal in a different
alkalinity of the scrubbing liquor, which promotes a higher SO
removal rate.
manner from magnesium additives.  Acting as buffers, they tend to
neutralize acid-generated hydrogen ions  (H+) which in turn
prevents the decrease of the system pH and SO, removal.  In lime-
                                             £
stone systems, because of their added ability to enhance utiliza-
 tion by improving dissolution, a
                                 lower stoichiometric ratio can
 be used which reduces limestone addition and .the resulting volume
 of solid waste.  In addition, high liquid phase calcium concentra-
 tions permitted by the dibasic acids leads to a reduced potential
 for scaling tendencies in the absorber.
 2.4  FGD SYSTEM DESIGN CONFIGURATIONS
      This section presents a briof discussion of the development
 of FGD technology including a historical perspective and a
 description of the characteristics of technology generation
 followed by a description of equipment used in existing design
 configurations.  A summary is also included of all operational
 utility lime/limestone slurry systems in the U.S. by design
 configuration elements.
 2.4.1
 2.4.1.1
          Development of Technology
                                i.
          Historical Perspective
                                   The rapid expansion in energy
demand that occurred starting aboulb 1950 greatly increased the
amount of all air pollutants resulting from fuel combustion —
particulates, SO», NO , carbon monoxide, organic compounds, and
                "    **          -|
trace metals.  Because of environmental concern over the increas-
ing concentration of pollutants xn the atmosphere in the U.S.,
the Air Quality Act of 1967 becarie law.  Its aim was to set
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 21

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 emission limitations on those pollutants for which adequate
 information was believed to be available, i.e., particulates,
 SO,
and NO .  Eventually new regulations came about in the form
            x
 of the Federal NSPS and state regulations under the individual
 SIP's.  As a result, in the early 1970's, important applications
 of FGD for SOp control were initiated in the U.S.
      The 1950's and 1960's were a time of laboratory and pilot
 plant investigations of new processes.  During the 1950"s, the
 Tennessee Valley Authority (TVA) experimented with lime/limestone
 slurry and dilute acid processes; in West Germany, the  first
 major carbon adsorption processes were developed.
      Lime/limestone processes were installed in 1964 on an iron
 ore sintering plant in the USSR and on a large sulfuric acid
 plant in Japan in 1966.
      In 1966, Combustion Engineering developed a process consis-
 ting of dry limestone injection into the boiler followed by wet
 scrubbing.  In the U.S., the first commercial system of this type
 was installed in 1968; there were five utility installations of
 this system by 1972.  Because of major problems associated with
 dry limestone furnace injection  (e.g., boiler tube fouling,
 scaling/plugging), these systems proved inadequate.  The five
 systems were either shutdown or converted to tail-end slurry
 processes.
      Significant commercial application of utility FGD  systems
 did not begin in the U.S. until the early 1970's.  Figure 2.4--1
 shows a yearly status of utility FGD capacity for the past decade
 and a half.
      There has been a continual evolution in the development of
                                  i
 FGD technology which is reflected in the improved design and
 performance.levels of these systems, even in an environment of
 increasingly more stringent emission limitations.  Many design
 configurations found in early systems have since been modified or
 abandoned.  A changing attitude of utilities toward FGD tech-
 nology has also improved FGD system performance in older systems
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 22

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72  73  74  75  76  ll  78  79  80  81  82  83  84
                         YEAR
  Figure 2.4-1.  Growt
\  of operational  FGD
           capacity  for  utilities.

-------
  and,  in some cases,  improved design.   Of particular significance
  is  the  attention now directed toward  FGD system operating and
  maintenance  practices.
       The most noteworthy  site for  significant research and devel-
  opment  work  in FGD technology has  been the  EPA/TVA Shawnee Alkali
  Scrubbing Test Facility.   In June  1968,  the U.S.  EPA*,  through
  its Office of Research and Development,  initiated a program to
  construct and test prototype lime/limestone slurry systems for
  removing S02  and particulates  from flue  gases  generated in
  coal-fired boilers.  This  test program was  managed and  directed
 by EPA's Industrial Environmental  Research  Laboratoryt/Research
  Triangle Park (IERL/RTP).  A prototype test complex was inte-
 grated into the flue gas ductwork  of a coal-fired  boiler  (Unit
  10)  at TVA's Shawnee Power Station near  Paducah, Kentucky.
      At the outset, three major goals were  identified for  the
 test program:  (1) characterize as completely as possible  the
 effect of important process variables on S02 and particulate
 removal; (2)  develop mathematical models to allow economical
 scale-up of attractive operating configurations to full-size
 FGD  facilities;  and (3) perform long-term reliability testing.
 The  test facility was initially commissioned for service in March
 1972.  The  original  test  program was  conducted from March  1972 to
 May  1974.   During this  first  phase  of  testing,  efforts  were
 concentrated  on the characterization of process parameters as
 they affected SO2  removal  and FGD system reliability.
     A second phase of testing,  a four-year  advanced test  pro-
 gram,  was initiated in June 1974.   The  major objectives  accom-
 plished  during this phase  of  testing were achieving reliable
 operation of  the FGD  system,  improved performance,  and  lower
"*     ~"	            :
  National Air Pollution Control Association until  1970.
  Designated^ Control Systems Laboratory until 1975; redesig-
  1985  ^ Alr and Energy Engineering Research Laboratory  in  "
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                24

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costs.
          This was accomplished through investigations on chemical
  additives (see Section 2.3.2.6),
  forced oxidation (see Section 2.
       A third phase of testing,  v
  years,  from July 1978 to May 19f
  removal and improving the reliat
                                  system loop configurations,  and
                                 3.2.5).
                                rhich  lasted  approximately two
                                 0, was  devoted  to  enhancing SO~
                                 ility and  economics  of  lime/
  limestone  slurry processes through the use of organic acid
  additives  (see  Section  2.3.2.6).
       Shawnee provided a needed test site to assist in the develop-
  ment  and commercialization of  conventional and innovative FGD
  strategies.  Shawnee was instrumental  in the development of
                                   from  the level of a research arid
lime/limestone slurry technology
development "tool" to a level of
of the results from the various
                                   commercial  acceptability.   Many
                                  test programs  initiated or  re-
 fined commercial design strategies,  a  large  number  of which  are
 in commercial practice today:
           High utilization/low stoichiometric  limestone  chemistry
           and mist eliminator clteanliness
      0    Spray tower absorber djssign
      0    Two-loop scrubbing
      0    Magnesium additives
      0    Organic acid additives
      0    Forced oxidation and gypsum production
      0    Closed water-loop operation
'2.4.-1.2   Characteristics of Technology Generation.  Although the
 designation of "generation" is somewhat subjective, FGD  systems
 may be distinguished in accordance with the evolution of
 technology per the following guidelines:
 0     First generation:
                                 that remove SO2,  and possibly
                                  with gas contactors developed
Designs
for or ipased upon particulate matter
scrubbing concepts.  Included are
lime/linestone slurry processes which
                          use gas
                          packing-type internals.
                                 contactors  with venturi or
  SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 25

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    Second generation:
    Third generation:
                         Designs that remove SO2  primarily in gas
                         contactors developed specifically for
                         SO2 absorption which utilize features to
                         improve the chemical process through
                         chemical or physical means.   Included
                         are lime/limestone slurry processes
                         using additives or spray towers, combi-
                         nation towers, or special reactors.
                         Improved second generation designs that
                         encompass additional process refinements
                         and are currently under demonstration or
                         early commercial operation.   Included
                         are open spray tower designs with spare
                         absorbers, closed water-loop operations,
                         and gypsum production.
     Approximately 53 percent of the operational lime/limestone
slurry FGD systems on utility boilers in the U.S. can be classi-
fied as second generation systems.  First generation systems
account for 20 percent, while third generation systems account
for the remaining 27 percent of the total.  Often, a given FGD
system will have some characteristics of earlier and/or later
generation systems but will be assigned the generation status
which most closely represents its particular overall design.
Table 2.4-1 summarizes the basic characteristics of the systems
within the three generations.    ;
     First generation systems are  "early"  facilities based on
particulate scrubber designs modified  for  S02  control.  In  such
systems, particulates and SO2 are  collected  simultaneously by
venturi, marble bed, or other scrubber/absorber designs in  a
once-through  scrubbing operation having a  characteristically  high
stoichiometric ratio.  Spent  slurry is piped to a pond without
dewatering for final disposal.  Typically,  little or no water is
brought back  from the disposal  pond to the process for reuse.
Fresh makeup  water  is used  instead.   Few  existing FGD systems fit
this description completely.  As  FGD technology evolved,  more
effective measures  were  adopted and modifications were made to
earlier systems to  upgrade  performance.
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                26

-------
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                                           27

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     Second generation FGD systems were designed specifically for
SO7 control leaving all or most.particulate control to upstream
ESP's.  The SO0 absorbers usually contained gas contacting de-
vices to maximize SO2 collection efficiency and operate at a
moderate stoichiometric ratio chemistry.   Such systems included
primary solids dewatering, some form of solid waste treatment,
and on-site waste disposal.  Second generation systems character-
istically operate in a water loop which more closely  approaches
closed loop than first generation systems.
     Third generation systems are characterized by open spray
towers operating at relatively  low stoichiometric ratio chemis-
tries with additives for SO2 absorption enhancement and scale
control.  These systems also include liberal sparing  of key
components and incorporate design features which tend to decrease
interdependency of various subsystems.  This allows full load op-
eration of the system even when individual components are forced
out of service or are undergoing routine maintenance.  Third gen-
eration designs provide secondary dewatering-  (vacuum  filters or
centrifuges), solid waste treatment via chemical fixation or
forced oxidation, and landfill  disposal.   An integrated plant
                                 -        A
water inventory is generally included  in these closed loop sys-
tems, and liquor collected from the various dewatering devices is
recycled and blended with fresh makeup water.  The term "closed
loop" takes on a slightly different but significant meaning when
applied to third generation systems since  little water leaves the
system via the solid waste.  These systems must be designed to
withstand the corrosive effects and scaling potential of the
increasingly high concentrations of salts  that build  up in the
recycled water.  Second generation systems are less sensitive to
this problem because water is not recycled as extensively.
2.4.2  Existing Design Configurations
     This section describes briefly the important equipment items
one is likely to encounter when inspecting a conventional lime/
limestone FGD system.  Descriptions and diagrams are  provided for

SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY                   "
                                28

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 each of the equipment items disc-
 considerations for the equipment
 later in Section 2.5.
                       issed.   Operation  and maintenance
                       described here  are presented
      The equipment is organized by three major equipment areas:

      0    Gas handling and treatment
           1.   Fans              j
           2.   Scrubbers/absorbers
           3.   Mist eliminators  j
           4.   Reheaters
           5.   Ductwork and dampers
           Reagent preparation anc
                Reagent conveyors
1.
2.
3.
4.
                Ball mills
                Slakers
                Tanks
           Waste solids handling and disposal
           1.    Thickeners
           2.    Vacuum filters
           3.    Centrifuges
           4.    Waste processing
           5.    Waste disposal
           6.    Pumps and valves
             I
      It  is noted that there  is  sone overlap of the equipment
 items  in  all  three  areas,  althoug
 one equipment area  in  the  above  c
 reaction  tanks are  located in  the
 feed
and storage
                       i they may be listed only under
                       Lassification.   For example,
                        gas  handling and treatment
area; pumps and valves are  found  in  all  three  equipment  areas.
     Sections  2.4.2.1 through  2.412.5  address  equipment  used  in
gas handling and treatment, including:   fans,  scrubbers/absorbers,
mist eliminators, reheaters, and  ductwork and  dampers, respec-
tively.  Sections 2.4.2.6 through
in reagent preparation and feed, including:  reagent conveyors
and storage, ball mills, slakers,
                       2.4.2.9 address equipment used
                       and tanks, respectively.
Sections 2.4.2.10 through 2.4.2.15 address equipment used in
waste solids handling and disposal, including:  thickeners,
vacuum filters, centrifuges, wast^ processing, waste disposal
and pumps and valves, respectively.
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                29

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2.4.2.1   Fans.  The fan moves gas by creating a high or low
pressure by mechanical means.  Fans are used to draw or push flue

gas from the boiler furnace through the FGD system.  Fans used in

FGD systems may be classified in four basic ways:  function,

design, application, and service.1
     0    Function refers to service as either a unit fan or
          booster fan.  A unit fan is one that is designed_to
          create draft for the boiler, particulate collection
          system, and FGD system.  A booster fan accommodates
          only the FGD system.  Retrofit FGD systems usually
          include booster fans since existing unit fans are
          generally unable to accommodate the pressure drop of
          the add-on FGD system. '•. Booster fans are also often
          used for FGD systems that have flue gas bypass capabil-
          ity.  Booster fans may be used for individual modules
          on FGD systems to  give better control  of the gas
          passing through them.  Unit  fans  are generally used  for
          new FGD-equipped boilers, particularly installations
          where flue gas bypass does not exist.   Using unit  fans
          allows better balance of the draft throughout the
          entire unit.

      0    Fans used  for FGD  systems are either centrifugal  or
          axial  (Figure 2.4-2a  and b).  Most  fans used  in  FGD
          systems are  of the 'centrifugal variety.   Both  fan
          designs may  be equipped with variable-pitch vanes (or
          blades) which provide more  efficient  fan operation and
          better gas  flow  control.

      0    Fans are  classified as  either  induced  draft (ID)  or
           forced draft (FD).  Fans  that  are installed immediately
           following a module or system (downstream)  that draw gas
           through  the module or system are called ID fans (nega-
           tive pressure  operation).   Fans  that precede  a module
           or system (upstream)  that push gas through the module
           or system are  called FD fans (positive pressure opera-
           tion) .

      0    Fans may service either a wet or dry gas stream.  Fans
           that precede absorbers generally operate on hot dry
           flue gas and are classified as dry fans.  Fans that are
           installed downstream of the absorbers and are preceded
           by a reheater are also classified as dry fans.  Fans
           that are installed either between scrubber and absorber
           modules or downstream of absorbers but are not preceded
           by a reheater are classified as wet fans.  Most fans
           used in FGD systems are dry fans.
  SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 ,30

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                                                        TURNING BEND
                                                      WITH GUIDE VANES
Figure  2.4-2.  Typical  fan designs:   (a) centrifugal;  (b)  axial
                                   31

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2.4.2.2   Scrubbers/Absorbers.  Strictly speaking, the term
"scrubber" applies to first generation systems which remove both
particulate and SO2.  "Absorber" applies to the second and third
generation systems which remove SO2 only, although the term
"scrubber" is also used by some for this application.  The basic
scrubber/absorber types described herein identify the various
gas/slurry contacting devices used in the FGD systems.
     Figure 2.4-3 presents different venturi tower configurations
typically used in first generation systems.  In a fixed-throat
venturi, the venturi throat opening remains constant  (Figure
2.4-3a).  However, a number of variable-throat designs are used
to control the opening of the venturi throat to accommodate
varying gas flows  (Figures 2.4-3b .through h).  Venturi towers are
considered high energy devices because they typically operate in
a 10 to 30 in. H2O pressure drop range.  They are also limited
somewhat as contacting devices for gas absorption because of
limited gas/slurry contacting time in the tower.
     In spray towers, slurry is introduced into the gas  stream
from atomizing nozzles, resulting in .intimate contact for gas
absorption.  The pressure imparted to the slurry discharged from
the spray nozzles combined with the velocity of the incoming gas
stream produces liquid droplets from  50  to 4000 microns  in dia-
meter.  Low gas-side pressure drops  (typically  1 to 4 in. H2O)
are encountered because of the lack of tower internals.  The open
countercurrent spray tower is a simple configuration  in  which the
gas stream passes vertically upward through the tower with the
liquid droplets falling by gravity countercurrent to  the gas flow
 (Figure 2.4-4a).  Another spray tower design is the open cross-
current spray tower  (Figure  2.4-4b).  This design requires
somewhat  less pumping power because the  slurry  is pumped to a
lower height.  However, it requires more spatial area for the
absorber  than vertical designs.
     In tray towers, the gas  stream enters the  base of  the tower
and passes upward  through one or more trays containing  openings.
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 32

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    FIXED THROAT
     OPENING
           00.
                                                                     GAS
                                                              SCRUBBING  I—1
                                                              LIQUOR    < >
                                                               FEED,    V
                                                                       SUMP
                            (c)
 MOVABLE LIQUID /
 DISTRIBUTION DISC'
      SCRUBBING ~]
      LIQUOR -"-C,
       FEED
                                              SIDE-mVABLE
                                             PLATES OR BLADES
           Cd)
                            (f)
            GAS
           o
           (g)
(h)
Figure  2.4-3.   Venturi  tower configurations:   (a)  fixed-throat;  (b)  variable-
    throat top-entry  plumb bob;  (c)  variable-throat bottom-entry plumb bob;
   (d)  variable-throat  bottom-entry  li
throat  side-variable  plates or blades;
 quid distribution disc;  (e)  variable-
  (f) variable-throat  side-movable blocks;
   (g)  variable-throat  vertically-adjusted .rod decks;  (h) variable-throat
                                 adjustable-drum.
                                         33

-------
                    A   A  A
                    A   A
                                        MIST
                                      ELIMINATOR
                            SCRUBBING
                              LIQUOR
                               FEED
                                           GAS
                          (a)
                         SCRUBBING
                          LIQUOR
                           FEED
                           t   I   \
                               mr
                                    MIST
                                 ELIMINATOR
Figure 2.4-4.
            (b)

Spray  tower types:  (a) open countercurrent;
   (b) open crosscurrent.
                          34

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Slurry is introduced onto the top tray and  flows  across  it  and
down across each preceding tray
valve tray tower, the tray level
caps" with each bubble cap surmo
(Figure 2.4-5).  In a conven-
tional sieve tray tower, gas velocities are used  such that  the
gas passing up through the hole bubbles through the  liquid  on the
tray providing intimate gas/slur:ry contact  (Figure 2.4-5).   In a
t
consists of a bed of "bubble
nted by a constraining spider
cage  (Figure 2.4-5).  The gas flows upward through the caps and
the slurry flowing across the tray is kept in a state of constant
froth by the gas which exits each cap at venturi velocity.  This
design, however, is not very common in lime/limestone slurry FGD
systems.
     In packed towers, the gas enters the base of the tower and
passes up through the packing countercurrent to the slurry intro-
duced at the top of the tower (Figure 2.4-6).  The packing can be
of a variety of different shapes
 and configurations.  The purpose
of the packing is to provide a large surface area for intimate
gas/slurry contact.  Fixed bed consists of a rigid, stationary
packing such as a "honeycombed" material  (Figure 2.4-6a).  Static
bed consists of a largely immobile bed of packing, such as glass
spheres  (Figure 2-. 4-6b) .  Mobile
mobile bed of solid spheres whic
 bed packing consists of a highly
i is fluidized by the gas stream
 (Figure 2.4-6c).  Entrained bed packing consists of a mobile bed
of solid spheres which are entrained in the gas stream, passed
through the tower, and disengaged for recycling  (Figure 2.4-6d).
Rod decks and grids  (Figures 2.4J-6e and f) represent internals
which can be used instead of packing and still provide a suffi-
ciently large surface area for intimate gas/liquid contact.
     In combination towers, two or more separate tower design
features described in the foregoing are incorporated into one
tower for operation as an integral unit.  These combined- designs
provide flexibility because extreme operating conditions and/or
selective removal capabilities can be segregated into discrete
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                35

-------
      /•'":
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                   MIST
A  A  A
                   SCRUBBING
                    SLURRY
                PACKING
                 ZONE
                  A, DIRTY GAS
                 IV   INLET
   i      a
            OVERFLOW
           JL     A
           STATIC BED
               (b)
      FEED
     HEADERS
                             SCRUBBING
                             SOLUTION
                        CONTACT
                        SPHERES
GAS IN
        ENTRAINED BED
               (d)

            Figure 2.4-6.   Packed
                                                      "HONEYCOMB"
                                                      FIXED BED
                                                     (a)
                                                   OOoOOOOOOOOO
                                                   ooo 0000060
                                                   o o ooooo o
                                                   "-
                                                             SOLID
                                                             SPHERES
                                                MOBILE BED
                                                     (c)
                                                             RODS
                                                          (e)
                                                         GRIDS
                                                     (f)
                               bower and packing types,

                               37

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 areas of the tower,  thus permitting separate chemical and physi-
 cal conditions to be maintained.   Designs which have been devel-
 oped for commercial  application to date include a spray/packed
 tower and a venturi/spray tower.
 2.4.2.3    Mist Eliminators.   A mist eliminator removes entrain-
 ment introduced into the gas stream by the scrubbing slurry.
 Entrainment can take the form of  liquor droplets, slurry solids,
 and/or condensed mist.            ;
      There are two basic types of mist eliminators used in FGD
 systems:   the precollector and the primary collector.   A pre-
 collector precedes the  primary collector and is designed to
 remove the larger particle entrainment from the gas stream before
 it  passes through the primary collector.   A primary collector
 typically sees the heaviest  duty  with  respect to entrainment
 loading  and required removal efficiency.
      Precollectors are  of the bulk separation or knock-out type.
 Bulk  separation is effected  by baffle  slats,  perforated trays,  or
 a gas direction change  (90°  to 180°).   Bulk separation devices
 are characterized by a  low potential for  solids deposition, a low
 gas-side  pressure drop,  and  simplicity.   Knock-out type precollec-
 tors  are  either the  wash tray or  trap-out tray design.   Knock-out
 devices remove large solid and liquid  particles;  they  also pro-
 vide  a means  to recycle  the  mist  eliminator wash water.   By
 recirculating the relatively clean wash water,  the flow rate  of
 the wash  water to the mist eliminator  can be  significantly
 increased which allows greater flexibility in washing  operations,
wash water  treatment, and  the  addition  of scaling inhibitors.
Despite all these  advantages,  knock-out type  precollectors are
not used  at most  installations  primarily  because  of plugging,
high pressure • drop (>_3 in. H2O) ,  increased complexity,  and
operating problems.
     Impingement  (or inertial  impaction)  removes  mist by  collec-
tion on surfaces placed  in the  gas streams.   Entrained mist is
collected in  such devices by forcing the  gas  to make changes  in

SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY                   ~~   ~~	—
                                38

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flow direction as it passes through the slats.  The liquid drop-
lets thus collected coalesce and
scrubbing slurry.  Impingement t}
in lime/limestone slurry systems
Baffle-type mist eliminators include the conventional open-vane
(slat) and closed-vane chevron d<
 fall by gravity back into the
 pe mist eliminators used widely
 include baffle configurations.
 signs (Figure 2.4-7).  The
baffle design mist eliminators are most common and constitute the
simplest method of mist elimination.
2.4.2.4   Reheaters.  Reheaters daise the temperature of the
scrubbed gas stream in order to Prevent condensation of acidic
moisture and subsequent corrosion in the downstream equipment
(ducts, fans, and stack).  FGD systems that do not use reheaters
must be equipped with specially lined stacks and exit ductwork to
prevent corrosion.  Such liners require special attention, and
FGD systems using them must be equipped with emergency deluge
sprays in the event of a temperature excursion.
     The generic reheat strategies discussed in this section
include in-line, indirect hot air, and flue gas bypass  (Figure
2.4-8).  In-line reheat involves
the gas stream downstream of the
The heat exchanger is a set of t
t
the use of- a heat exchanger in
mist eliminator  (Figure 2.4-8a).
be bundles through which the
heating medium of steam or hot water is circulated.  When  steam
is used, the inlet steam temperatures and pressures range  from
350° to 720°F and 115 to 200 psia, respectively.  Saturated  steam
is preferred because the heat transfer coefficients of condensing
steam are much higher than those
water is used, inlet temperature
 of superheated steam.  When hot
 of the hot water typically
ranges from 250° to 350°F and the temperature drop  (water) over
the heat exchanger is 70° to 80°F.
     Indirect hot air reheat systems inject hot air  into the  gas
stream  (Figure 2.4-8b).  There a::e two types of indirect hot  air
reheaters:  the external heat exchanger and the boiler preheater
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 39

-------
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                                               TO CH1HHEV
                                 (a)
         (b)


Figure 2.4-8.
                                     (c)
FGD system reheat schematic diagrams:   (a)  in-line-
 (b) indirect hot air; (c) bypass.                 '

-------
design.  In the external heat exchanger design, reheat is
achieved by heating ambient air with an external heat exchanger
using steam at temperatures of 350° to 450°F.  The heating tubes
are usually arranged in two to three banks in the heat exchanger.
Hot air and flue gas may be mixed by use of a device such as a
set of nozzles or a manifold in the reheater mix chamber section.
In the boiler preheater design, reheat is achieved through the
use of the boiler combustion air preheater to provide hot air,,
In this case, part of the heat which would have been used to heat
the combustion air is used to reheat the stack gas.  As a conse-
quence, the temperature of the combustion air entering the boiler
is lowered, thus somewhat reducing boiler efficiency.
     In the bypass reheat system  (Figure 2.4-8c), a portion of
the hot flue gas from the boiler bypasses the absorber(s) and is
mixed with scrubbed flue gas.  Two variations of this method are
"hot-side" bypass, in which the flue gas is taken upstream of the
boiler air preheater and "cold-side" bypass, in which flue gas is
taken downstream of the boiler air preheater.  In the former, a
separate particulate removal device  (ESP or fabric filter) spe-
cifically for the bypass gas stream is required for fly ash
control when an upstream (i.e., hot-side) particulate collector
is not used.
2.4.2.5   Ductwork and Dampers.  Ductwork is used to channel the
flow of gas within the FGD system.  Ductwork in an FGD system is
usually made of carbon steel plates 3/16- or 1/4-inch thick,
welded in a circular or rectangular cross section.  It is sup-
ported by angle frames that are stiffened at uniform intervals.
The following design factors are ^considered for ductwork in
lime/limestone slurry systems:   '
     0    Pressure and temperature
     0    Velocity
     0    Configuration  (cylindrical or rectangular)
     0    Flow distribution
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 42

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           Variations in operating conditions
           Materials of construction
           Material thicknesses
           Pressure drop
 The  ductwork must be designed to
 temperatures that occur during n<
 that occur  during emergency cond:
 variety  of  conditions,  depending
withstand the pressures and
irmal operation and also those
tions.  Ductwork is subject to a
on location within the system.
 The  following  list  identifies  thd basic variants:

      0     Inlet  ductwork
      0     Bypass ductwork  (all 01  part of the flue gas)
      0     Outlet ductwork  (with Jeheat and without bypass)
      0     Outlet ductwork  (with reheat and with bypass for
           startup)
      0     Outlet ductwork  (without reheat and without bypass)
      0     Outlet ductwork  (withoujt reheat and with bypass
           for  startup)
     Dampers are used to regulate
 the flow of gas through the
system by control or isolation functions.   The  entire  system or
subsystems may be regulated by the use of dampers.   They  are
mainly used at the inlet duct to  the module, the outlet duct from
the module, and the bypass duct.
ally or in combinations.  A simplified overview diagram  showing
typical damper locations is prese
     A variety of damper designs
slurry systems, including louver,
blanking plates.  These designs are described below and depicted
in Figure 2.4-10.
          Louver or multi-blade d
 Dampers may be used individu-
ited in Figure 2.4-9.
are in use in lime/limestone
 guillotine,  butterfly, and
impers  may be of either opposed
          or parallel blade desighs  (Figures 2.4-10a).  Louver
          dampers are used to regjilate and isolate flue gas flow.
          For isolation, two dampers are used together and sealed
          by pressurizing the chaijnber formed by the ductwork
          between the dampers with a seal air fan.  A single
          damper may be used for gas flow regulation.
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                43

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     0     A guillotine damper may be of either top-entry or
          bottom-entry design and with or without seal air
          (Figure 2.4-10b).   Guillotine dampers for isolation may
          be equipped with seal air to pressurize the sealing
          space.                  i

     0     Butterfly dampers are often used for secondary duct
          runs such as bypass or reheat air ducts (Figure
          2.4-10c).  Butterfly dampers are mounted by a center
          shaft which crosses the duct and about which the damper
          plate rotates from a plane parallel to the gas flow
          (open)  to a plane perpendicular to the gas flow
          (closed).  Butterfly dampers are more often used for
          gas flow regulation than gas flow isolation.

     0     The most basic damper is the simple blank-off plate.
          Blanking plates are used to isolate absorbers for entry
          by operation and maintenance crews.  The blanking plate
          ensures complete isolation by "breaking" the duct and
          inserting the plate.  Blanking plates are typically
          used with positive ventilation air purge which adds an
          additional safety factor.  Blanking plates are similar
          to guillotine dampers in that they cut across the duct
          opening; however, the track for a blanking plate is
          designed only to guide the plate as it is put in place
          and bolted down.

2.4.2.6   Reagent Conveyors and Storage.  Conveying equipment
used to transport limestone, from'unloading to storage includes

dozing equipment, belt conveyors, and bucket elevators.  Lime-
stone is transported to feed bins by conveyors and bucket eleva-

tors.  Limestone can be stored in silos, piles, or a combination
of both.  Short-term storage feed bins are used with both systems

to feed limestone to the additive preparation system.  Storage
piles require more land to store a given quantity of limestone
than silos.  However,  silos are more expensive and can experience

flow problems such as  plugging and jamming.  Covered piles are
sometimes used for limestone storage.  The covers keep precipita-
tion off the limestone pile and prevent  freezing or  limestone mud

from developing.   The  primary design criterion of a  limestone
storage system is  capacity.  The: storage  facilities must  have
sufficient  capacity  so that the  storage  system does not  limit the
availability of  the  overall FGD  system.   There should be  enough
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 46

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 storage  capacity  to  account for
ping  schedule.   Figure  2.4-11  shjows  an example of a limestone
handling  and  storage  system.
      Conveying  equipment  used  td transport lime can be of three
basic  types,  as  shown in  Figure
 conveying  involves  simple  elevation of the lime from a storage
bin  into  a  smaller  feed bin.   A
 and with  less  power  consumption
Mechanical  conveying requires  careful arrangement of bins and
 equipment.  Alignment in  a  singl
 since  each  change  of  direction
disruptions in the normal ship-
2.4-12.  Most in-plant lime
simple combination of mechanical
 devices  can move  lime  from storage at less than the initial cost
than a pneumatic conveyor.
e straight row is preferable
sually requires another conveyor.
As  conveying  distances  or  elevations  increase,  or if conveyance
involves  several  changes of  direction or multiple points of
 delivery,  the  economic  advantage
 rapidly.   Unlike  the  basic  components  of a mechanical conveyor,
 those  of  a pneumatic  system are
 elevation.   They  differ  only in
 of pnuematic conveying increases
similar regardless of distance or
length of piping and size of the
 compressor  and motor.   Lime  is  blown up the' inclined pipe by the
 force  of  air  from the  compressor
 is  the vacuum or  negative-pressure  system.   It draws lime through
 the pipe by means of  a  vacuum exhauster  attached to the dust
 collector.  Another  arrangement,
 system, uses  air  circulated  froir
 and back.  A minimum amount  of  fjresh air  is  drawn in and the
 original charge  remains  dry.
     Minimum bulk  lime storage  capacity is generally considered
 to be  either 150 percent of  a plant's normal shipment size or
   The other basic conveyor type
 usually called a closed-loop
 the compressor to the conveyor
 capacity  for  7  days  of  operation
 at maximum rate.   Conservative
engineering practice,jgrovides  twice  this  volume,  since  lime is
often  transported  on a  less-dependable  schedule  than are  other
more expensive bulk  chemicals.
used for  lime is a steel  silo  with a cone bottom.   Concrete
storage bins have  been  used  in large facilities  and are often
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 47

-------
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                STORAGE BINS
   ROTARY
   FEEDER'

      OX
                                       ; BUCKET
                                       ELEVATOR
                     SCREW CONVEYOR
                  SLURRY STABILIZATION
                       TANK
                                                    VENT
                                                      DUST COLLECTOR
                                                         AND
                                                      COLLECTING BIN
   ROTARY
   FEEDER


CONVEYOR
 ADAPTER
                                                 SLURRY STABILIZATION
                                                      TANK
                                                      DUST COLLECTOR AND
                                                        COLLECTING BIN
Figure 2.4-12.   Three types
 transport lime:   (a) mechar
     conveyor;  (c)  positive-
 of  conveying  equipment  used  to
 ical  conveyor;  (fa)  closed-loop
pressure  pneumatic  conveyor.

 9

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less expensive than steel bins.  Lime storage bins must be weather-
proofed and airtight to prevent absorption of water  (moisture)
and carbon dioxide from the atmosphere.  Storage bins must be
fitted with a cone-shaped or hopper-shaped bottom to allow an
even flow of lime.  Steel is most often used for the hopper
section.  The number of storage bins and their relative size and
proportion are determined by construction economy.  A diameter of
12 ft is often the most economical, with a maximum height of 40
ft.  A bin of these dimensions will hold about 100 tons of lime.
     A lime storage bin may be connected directly to a lime
feeder that meters the flow of lime into the slaker.  Frequently,
however, lime is transferred from a storage bin into a smaller
feed bin at a higher elevation.  Lime feed bins are often de-
signed to hold enough lime to permit either 8 or 24 hours of
operation at maximum rate; thus, they can be routinely filled
once per shift or once per day.
2.4.2.7   Ball Mills.  Ball mills are used in limestone slurry
systems to grind the limestone to a fine size in order to improve
its reactivity.  There is very little basic information that
defines the most economical degree of grinding.  However, the
trend is toward finer grinding.   (A finer grind provides a smaller
particle which exposes more overall particle surface area and
therefore improves limestone reactivity.)  Specifications range
                                 1
from 70 percent passing through a 200-mesh screen to 95 percent
passing through a 325-mesh screen; most are in the range of 60 to
80 percent passing through 325 mesh.
     A ball mill consists of a rotating drum loaded with steel
balls that crush the,limestone by the action of the tumbling
balls as the cylindrical chamber rotates.  Ball mills used in FGD
systems fall'into two categories.  The long drum or tube mill va-
riety is a compartmented type  (Figure 2.4-13a), and the Hardinge
ball mill is noncompartmented and somewhat conical in shape
(Figure 2.4-13b).


SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY                  ~~  ~~    ~~
                                50

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                                 a)
Figure 2.4-13.   Two types of ball  mills used in limestone slurrv
FGD systems:  (a) compartmented
mill; (b) Hardinge ball mill

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2.4.2.8   Slakers.  A slaker is used in lime systems to convert

dry calcium oxide to calcium hydroxide  (see Section 2.3.1).  The

objective of lime slaking is to produce a smooth, creamy mixture

of water and very small particles of alkali.  Depending on the

type of slaker used, the slurry produced contains 20 to 50 per-

cent solids.  A lime slaker combines regulated streams of lime,

water under agitation, and temperature conditions needed to dis-

perse soft hydrated particles.  Dispersion must be rapid enough

to prevent localized overheating and rapid crystal growth of the

calcium hydroxide from occurring in the exothermic reaction.

However, the mixture must be held in the slaker long enough to

permit complete reaction.
     Three basic types of slakers are presently used in lime

slurry systems:  detention, paste, and batch.  A simplified

diagram of each type-is presented in Figure 2.4-14.  A brief

description of each is provided below.

     0    Quicklime and water are: fed to the detention slaker in
          specific proportions in order to produce a slurry
          containing 20 to 30 percent solids.  The mixture is
          agitated with a high-speed propeller mixer.  From the
          agitated chamber, slurry flows into a quiet section
          where grit settles out.  Degritted slurry is then
          diluted with additional water and flows to a stabiliza-
          tion tank.  Grit is continuously removed from the quiet
          section by means of a mechanical scraper.  This is
          rinsed with a small stream of water and discarded.  In
          a detention slaker, water is added to each chamber.
          Slurry is usually retained in a detention slaker 20 to
          30 min at a temperature of about 167°F.

     0    The paste slaker operates on the pug mill principle,
          kneading a thick mixture of lime and water.  Feed
          streams are proportioned to produce a putty-like
          mixture containing about 40 to 50 percent solids.  The
          mixture is blended in a narrow trough by paddles that
          rotate on horizontal shafts.  The thick,slurry
          continuously overflows the end of the trough into a
          dilution chamber where more water is added and grit is
          separated, rinsed, and discarded.  Slurry is retained
          in a paste slaker for only 5 to 10 min.  The slaking
          temperature is usually about 185 to 194°F.
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 52

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                                       AGITATOR DRIVE
                                           FEED INLET (LIQUID)
                                            LIME INLET
                                            SLAKING
                                   AGITATOR  COMPARTMENT
                     (a)  Detention  slaker
                    TORQUE-CPJITRPU.EO HATER VALVE
                           OUST SHIELD-,
                  WATER SPRAYv   I     /
quiCKiif*
       I
       1  SLAWS HATER  '   \ ^ ~
     lfJ/   pr--PADDLES IT**
     ™^fottitfa
        AQ;P/^a.%Cl
                    DISCHARGE PO IT'
                     CLASSIFIER
                                                        GRIT OISCHftRKE
                                                   HATER FOR GRIT HASHING
                                     GRIT ELEVATOR
                    (b) Pas-;e slaker
                                            I	DRY REAGENT
                                                 KATER
FRESH REAGENT
  SOLUTION
 JO PROCESS
                    (c) Batch slaker
       Figure 2.4-14.   Basic  types  of  slakers.
                               53

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      0    Batch slakers are  simple tanks equipped with agitators.
           Quicklime and water are•fed into the tank and the
           mixture is stirred briskly.  Although simple and
           relatively inexpensive, this type of device invariably
           produces a poor quality|slurry.   Even with high-energy
           agitation, slaking may riot be uniform.  Hard,
           crystaline lime particles are formed; slaking is
           usually incomplete;  and|part of the lime is lost as  a
           hard scale that forms  in the tank.  The slurry is
           usually very erosive and reacts slowly in the FGD
           system.  Batch slakers are seldom used on FGD systems
           today.


 2.4.2.9   Tanks.  Tanks are  used extensively in FGD systems to
 support the various equipment items in the slurry circuits.
 Tanks allow FGD systems to operate in a fluctuating continuous
 mode as demanded by the power plant while various components of
 the FGD system itself may operate in a discontinuous "batch"
 mode.  Tanks may be categorized  as reaction, surge, collection,

 mix, feed, storage, or combinations of these.  Table 2.4-2 shows
 a listing of typical subsystems  that require tanks.


               TABLE 2.4-2.  FGD SUBSYSTEMS REQUIRING TANKS

                            Component/area
         Reagent Slurry Product
         Presaturator/Quencher
         Scrubber/Absorber
         Mist Eliminator Wash
         Thickener Overflow
         Thickener Underflow
Waste Slurry Bleed
Vacuum Filter Filtrate
Centrifuge Centrate
Pond Return
Makeup Water
Solid Waste Additive
      Tanks may or may not be covered.   Covered tanks are pro-

 tected from contamination and sometimes may be pressurized as

 part of the gas circuit.  Tanks may  also be covered for safety

 reasons or to prevent the possibility  of debris falling into the

 tank (preventing subsequent damage to  agitators, pumps, piping,

 or  valves).  Protective liners are often applied to the internal

 surfaces of tanks; the types of liners used depend upon the

 service for which the particular tank  is intended and the tank

 construction materials.

SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY                     ~  ~~
                                  54

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 2.4.2.10  Thickeners.
 a clarifier) is to concentrate s
 in order to improve waste solids
                        The function of a thickener (also known as
                                ill
'lids in the slurry bleed stream
handling and disposal character-
      A typical gravity thickener
 large circular holding tank with
 istics  and  recover  clarified water.   The slurry bleed stream
 usually enters  a  thickener  at a  solids  level of about 5 to 15
 percent and exits at  a  concentration  of 25  to 40 percent solids.
 A thickener is  a  sedimentation device that  concentrates the
 slurry  by gravity.  There are two  basic types of thickeners:
 gravity and plate.  Only the graiity  type will be described here
 because plate thickeners are rarely used on utility  FGD systems.
                                  (Figure 2.4-15)  consists of a
                                 a central  vertical  shaft that is
 supported either  by internal structural design,  by a center
 column,  or  by a bridge.  Two long, radial rake arms  extend from
 the lower end of  the  vertical she.ft;  two short arms  may be added
                                 area.   Plow blades  are mounted
                                 •ith  a  clearance  of  1.5 to 3  in.
                                 y can  be arranged identically on
                                 so that the bottom  is  swept
                                 revolution.   The bottom of the
                                   8-degree  slope  from the center„
                                 t on the bottom  of  the thickener
                                 the  central discharge  outlet.
                                 ge trench  and move  the solid
deposits toward the underflow discharge  point.  The  rake  arms  and
pickets move the  settled solids to the  central discharge  point.
The reclaimed overflow  (i.e., clarified water) from  the thickener
is usually recycled and reused as i
2.4.2.11  Vacuum Filters.  Vacuuir
secondary dewatering devices because they can  be  operated suc-
cessfully at relatively high  turndown ratios over  a  broad range
of solids concentrations.  A vacuum filter  also provides  more
 when necessary to rake the inner
 on the arms at an oblique angle
 from the bottom of the tank.  The
 each arm or in an offset pattern
 either once or twice during each
 tank is usually graded at a 5- tc
 The settled sludge forms a blanke
 tank and is pushed gently toward
 Center scrapers clear the discha:
 operating flexibility than other
                                   makeup water.
                                   filters are widely used as
                                 types of dewatering devices
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 55

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 as well  as  producing a drier product.   Because a vacuum filter
 will  not yield  an acceptable fii.ter cake if the feed solids
 content  is  too  low,  it is  usually preceded by a thickener.   A
 vacuum filter produces filter cake of  45 to 75 percent solids
 from  feed slurries containing 25  to 40 percent solids.   The
 filtrate, typically  containing 0.5 to  1.5 percent solids,  is
 recycled to the thickener.      [
      Two types  of vacuum filters  are used in conventional  FGD
 system designs:   drum and  horizontal belt.   Each has-different
 characteristics and  applicability.   The drum type (Figure  2.4-16)
is the most widely applied.   In
slurry is fed to a tank  in whict
                                 a  rotary-drum vacuum filter,  the
                                 . the  solids  are  held uniformly in
suspension by an agitator.  As the  drum  rotates,  the  faces  of  the
sections pass successively through  the slurry.  The vacuum  in  the
sections draws filtrate through jthe filter medium, depositing  the
suspended solids on the filter drum as cake.  The cake  undergoes
dewatering by the simultaneous flow of air and  filtrate in  the
cake drying zone.  Drying is nee
                                 ligible when  the  air  is  at  room
                                is removed  in the discharge  zone
temperature.  Finally, the cake
by a scraper.
2.4.2.12  Centrifuges.  Centrifdges are used to a  lesser extent
than vacuum filters in solids ddwatering operations.  The centri-
fuge product is consistent and uniform and can be  easily handled.
Centrifuges effectively create high centrifugal forces, about
4000 times that of gravity.  The equipment is relatively small
and can separate bulk solids rapidly with a short  residence time.
     There are two types of centrifuges:  those that settle and
those that filter.  The settling centrifuge (Figure 2.4-17),
which is the only kind used in commercial lime/limestone slurry
FGD systems, uses centrifugal force to increase the settling rate
over that obtainable by gravity
of a settling centrifuge are the
                                settling.  The principal elements
                                 rotating bowl, which is the
settling vessel, and the conveyor, which discharges the settled
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY

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AIR FILTRATE LINE
                                   CLOTH  CAULKING
                                       STRIPS
                      AUTOMATIC VALVE
                                                             DRUM
                                                                FILTRATE PIPING
                                                                  CAKE SCRAPER
                                                           SLURRY AGITATOR

                                                             VAT
                  AIR BLOW-BACK LINE
                                         SLURRY FEED
                Figure 2.4-16.   A rotary-drum vacuum  filter.
                                       58

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solids.  The solid bowl is the only centrifuge design used com-
mercially in FGD systems.  Adjustable overflow weirs at the
larger end of the bowl discharge the clarified effluent, and
ports on the opposite end discharge the dewatered sludge cakes.
As the bowl rotates, centrifugal force causes the slurry to form
an annular pool, the depth of which is determined by adjustment
of the effluent weirs.  Feed enters through a stationary supply
pipe and passes through the conveyor hub into the bowl.  As the
solids settle to the outer edges of the bowl, they are picked up
by the conveyor scroll and continuously overflow the effluent
weirs.
2.4.2.13  Waste Processing.  Waste may be  processed as a treated
or untreated material prior to  final disposal in a pond or  land-
fill.  For untreated waste operation, the  waste is physically
processed only to  the point that it is thickened or dewatered
before disposal or "bleeding" to a pond.   The term  "processing",
then,  refers to the first phase in handling of the waste product
from an  FGD  system.
      Waste  from FGD systems may be chemically treated  by  forced
oxidation,  fixation,  or  stabilization.   These terms are  defined
as  follows:                      :
      o    Forced  oxidation.   Forced  oxidation  supplements  the
          natural oxidation  of  sulfite  to sulfate  by  forcing axr
          through the material.  The  advantages  of a  calcium
           sulfate (gypsum)-bearing material  include better set-
          tling  and filtering properties,  less  disposal space
           required, improved structural properties of the dis-
          posed  waste,  potential for utilization of the gypsum
           (e.g.,  wallboard production),  and minimal chemical
           oxygen demand of the disposed material.   Forced oxida-
           tion,  unlike fixation and stabilization, is not typ-
           ically a tail-end operation;  in many systems,  this
           operation often occurs;in the reaction tank.
      0    Fixation.  Fixation increases the stability of the_
           waste through chemical means.  This may be accomplished
           by the addition of alkali,  alkaline fly ash, or pro-
           prietary additives along with inert solids to produce a
  SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 60

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          chemically stable solid.  Examples of commercial proc-
          esses of this type are those marketed by Conversion
          Systems, Inc. (e.g. , Pozj-O-Tec) and Dravo Corporation
          (e.g., Calcilox).
          Stabilization.  Stabili:
                        ation is accomplished by the
addition of non-alkaline fly ash, soil, or other dry
additive.  The purpose of stabilization is to enable
the placement of the maximum quantity of material in a
given disposal area to improve shear strength and to
reduce permeability.  Disadvantages are that the
stabilized material is subject to erosion and rapid
      • •--• ----••'		-"".ual leachability potential.
                        .isposal refers to operations at
                        'llowing all handling and/or
                        ; basic FGD waste disposal site
                        stacking.  The most common
                        igure 2.4-18 shows examples of
          saturation and has resic
2.4.2.14  Waste Disposal.  Waste c
the disposal site for FGD waste f<
treatment stages.  There are thre<
types:  ponding, landfilling, and
waste disposal type is ponding.
four pond types.  Ponds are either lined or unlined;  lined ponds
used for conventional FGD processes are typically clay  lined.
Wastes that have been fixated or stabilized are usually (although
not always) landfilled.  Stacking
designed to produce gypsum.  Presently, only two planned  lime-
stone FGD systems are considering
                        is only used for FGD systems
                        producing gypsum.
2.4.2.15  Pumps and Valves.  Pumps are used in the  solids hand-
ling and disposal area for pond water return, thickener
underflow, waste Slurry transfer, etc.  Pumps are also used  in
othe_r areas of the FGD system, such as slurry transfer,  slurry
bleed, and slurry recirculation.
two generic groups:  displacement
                        Pumps may be classified  into
                        and nondisplacement.
     Displacement pumps include reciprocating,  rotary,  and  screw
designs.  Diaphragm-type reciprocating pumps  are  sometimes  used
in FGD systems for transferring thickener underflow.   Rotary
pumps are not designed to handle  liquid which contains  grit or
other abrasive materials and are  rarely used  in lime/limestone
slurry FGD systems.  Screw pumps  Differ from  rotary pumps in  that
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 61

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                              (a)
         (b)
(c)
                              (d)
Figure 2.4-18.   Examples of pond  types  for waste disposal
 (a) diked; (b)  incised; (c)  side hill;  (d)  cross valley.
                            62

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 the flow through the pump is axi
 like the rotary; they are often
   instead of circumferential
ased in utility FGD systems for
 transferring reagent feed as they can easily handle a concen-
 trated (30 to 40 percent) slurry
      The only nondisplacement pu:
 FGD systems is the centrifugal p
 widely used for water and slurry
 water slurry recirculation, fres
 fier overflow/underflow, and mis
 of lime or limestone.
up used in lime/limestone slurry
ump.  Centrifugal pumps are
 handling.  These include makeup
i slurry feed, thickener/clari-
t eliminator wash water.  Of
 these, the recirculation pumps are the largest with capacities
 ranging from 5,000 to 20,000 gpm.
      Valves are used throughout
 late the flow of fluids but also
the FGD system not only to regu-
 to isolate piping or equipment
 for maintenance/repair without interrupting other connected sys-
 tems.  This helps to provide for
      As of the beginning of 1985
 limestone slurry FGD systems in
 these systems is shown in Tables
 indication of the major subsyst
 Section 2.4.2.

 2.5  FGD O&M CONSIDERATIONS
      This section provides a bri
 continuous operation and minimal
 downtime.  The generic classifications of valves are ball, but-
 terfly, check, gate, globe, pinch, and plug valves.  Among these,
 the check and globe values are generally not recommended for
 waste and slurry service.
 2.4.3  Operational Utility Lime and Limestone Slurry FGD Systems
  there were 91 operational lime/
the United States.  ,A listing of
 2.4-3a and b along with an
   and components described in
ems
ef introduction into the O&M
 practices associated with lime/limestone slurry:FGD processes as
 they relate to system reliability, identification of failure  •
 modes, system layout and accessibility, and required operating
 and maintenance procedures.  The purpose of this section is to
 introduce and define terminology
 that is used extensively in a
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 63

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                                 71

-------
 more thorough treatment of these topics in Section 4, Inspection
 Methods and Procedures; Section 5, Performance Evaluation and
 Problem Diagnosis/Correction;  and Section 6,  Model O&M Plan.
      The preceding section (2.4)  provides a description of the
 various types of design configurations used in lime/limestone
 slurry FGD  systems now in commercial service.   Technically, each
 PGD  system  represents  a unique application which varies according
 to plant, process, and historical considerations.
      Plant  considerations are  conditions which relate to the
 power plant and  its operation.   They involve  the power-generating
 unit's coal supply,  boiler design,  power demand, geographical
 site,  and applicable environmental regulations.   Table 2.5-1
 lists the major  power  plant considerations.
      Process  considerations relate to the FGD  vendor  which sup-
 plies the equipment, the architect-engineer  (A-E)  who designs the
 system,  and the  owner/operator  utility which operates the  system.
 Each  FGD supplier provides a process design with proprietary  or
 unique characteristics.   These  characteristics can vary in
 significance  from items as minor|as  spray nozzle design to items
 as major as absorber tower design.   The A-E is generally
 subordinate to the system supplier  in exerting influence on
 process  design;  however,  no two FGD  systems are  engineered alike.
 The owner/operator utility will also exert an  independent
 influence on  the  process  design generally in accordance with
 their  level of previous  FGD operating experience.
     Historical  considerations relate to  system  purchase and
 service  dates.   These  considerations  lock the  process  design
characteristics  into a particular generation of  technology  (first,
second,  or third).  A particular ^generation of technology will
define certain levels of performance  and  operating  expectations
as well  as flexibility  in  instituting modifications to  upgrade
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                72

-------
          •TABLE  2.5-1.   MAJOR  POWER  PLANT  CONSIDERATIONS
 Coal  Properties and Supplies
      Sulfur content
      Ash content
      Fly ash composition
      Chlorine content
      Moisture content
      Heating value
      Availability of coals
      Transportation considerations
      Flexibility for firing alternative coals

 Steam Generator Design

      Type of steam generator
      Size of steam generator
      Flue gas
       weight flow rate
       volume flow rate
       temperature
       dewpoint
       fly ash loading
      Additional control equipmer

 Power Generation Demand
      Base load
      Intermediate load
      Cycling load
      Peak load

Site Conditions
     Land availability
     Soil  permeability
     Disposal  facility
     Climatic  and geographic effiects
     Quality and availability of
Environmental  Regulations
     Air
       1971 NSPS
       1979 NSPS
       SIP
       PSD
     Water
       1977 CWA
     Solid Waste
       RCRA
reagent and makeup water
                               73

-------
performance  (see Section 2. 4.1. 2,; Characteristics of Technology
Generation).
     Even under the supposition that every lime/limestone slurry
FGD system is a unique application, there are also sufficient
similarities among the systems to permit a comparative evaluation
in terms of O&M considerations.  In Section 2.4.2  (Existing
Design Configurations)r lime/limestone slurry FGD processes were
described in terms of three major equipment areas:  gas handling
and treatment, reagent preparation and feed, and waste solids
handling and disposal.  These equipment areas can be further
subdivided into subareas, and the subareas further subdivided
into unique subsystems.  Figure 2.5-1 shows the organization and
relationship of the equipment areas in a typical FGD system.
Table 2.5-2 provides a summary listing of the FGD physical sub-
systems by major equipment area.
     The physical subsystems represent the basis by which all
lime/limestone slurry systems can be evaluated on a common basis.
This evaluation will be conducted in the balance of this section
in terms of the pertinent O&M considerations of lime/limestone
slurry FGD processes.  Section 2.5.1 identifies the failure modes
which plague FGD systems through an analysis of the subsystems
which are directly affected in terms of their impact on system
stream time and reliability.  The analysis is then extended into
facility considerations  (Section 2.5.2, System Layout, Accessi-
bility, and Design).  And finally, the various O&M practices
associated with lime/limestone slurry FGD processes are defined
(Section 2.5.3, O&M Practices).
2.5.1
Failure Modes
     Failure modes are defined as operating problems that may
lead to downtime  (outage) of a subsystem or system.  Failures may
lead to an outage isolated ,to the: subsystem affected, or to a
multiple subsystem outage, or to .a total system outage, or to a
multiple system outage.  A multiple system outage is possible
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY

-------


H. GAS HANDLING/
TREATMENT
PARTICULATE
REMOVAL
1
GAS
TRANSPORT
|^
COOLING
li
so2
ABSORPTION
||
REHEAT
IJ,
GAS
DISPERSION

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B. REAGENT PREPARATION/FEED
BULK
REAGENT
HANDLING

REA
PRE

^
f I
*— TwASHJ




-------
             TABLE 2.5-2.  SUMMARY LISTING OF THE FQD SUBSYSTEMS BY
                            MAJOR EQUIPMENT AREA
        Gas
 handlIng/treatment
       Reagent
   preparation/feed
     Waste solids
   handling/disposal
Fans

Scrubber

Absorber

Mist Eliminator

Reheater

Ductwork and Dampers

Stack
Reagent Receiving

Ball Mills and Slakers

Tanks
Thickeners

Vacuum Filters

Centrifuges

Waste Processing

Waste Disposal

Pumps, Pipes., and Valves
                                     76

-------
 only at a plant equipped with two
 boilers which' share subsystem (s)
 lent examples are common reagent :
 dewatering and treatment, and due
 have no effect on power productio:
 may  cause a total shutdown of the
 of a failure,  in addition to bein
 the  system or subsystem to the re
 or more separate FGD-equipped
affected by the outage.  Preva-
handling and preparation, solids
twork and stack.  A failure may
i,  may cause reduced load, or
 generating unit(s).  The effects
  a function of the relation of
st.of the plant, are also a
 function  of  the  restrictions  unde:r which the plant is operating
 (see  Section 2.1,  Environmental Regulations)  and the redundancy
 which is  built into  the  FGD system.
      Failure modes can be  described in terms of the downtime or
 outage time  that result  from  the ::ailure.   This can be considered
 a measure of unreliability.   For ~:he purposes of this manual, the
 results of a recently completed s-:udy in which PEI Associates,
 Inc.  (PEI) participated  in the  analysis of failure modes associ-
 ated  with lime/limestone slurry FGD systems were used.6  In this
 study, unreliability was quantified in terms of outage times as
 defined by "module equivalent hours"  in order to combine the
impacts of failures  into a  common
equivalent hours  (MEH)  is defined
basis  for  comparison.   Module
as  the product  of  the  number  of
scrubber/absorber modules affected by  a  given  type  of  failure,
the average duration of that type
of  failure  in  hours,  and the
number of times the failure occurs  in a given performance  period
 (year).  The overall results of the subsystem MEH  analysis are
presented, in Table 2.5-3.  The key  subsystems in order  of  highest
MEH are  (from top to bottom and left to right):
      0    Mist eliminators          °    Fans
      0    Ductwork                  °    Pipes and  valves
      0    Absorber                  °    Thickener
      0    Stack                     °    Dampers
     Key failure modes were identi fied for key subsystems  for
which major contributions to unreliability occur at the system
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                77

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   TABLE 2.5-3.   SUBSYSTEM OUTAGE TIMES  IN MODULE  EQUIVALENT  HOURS  (MEH)




Subsystem
Mist Eliminator
Ductwork
Absorber
Stack
Fans
Pipes and Valves
Thickener
Dampers
Reagent Preparation
Pumps
Tanks
Expansion Joints
Scrubber
Parti cul ate Matter Control
Reheater
Spray Nozzles
Reagent Receiving
Water System
Instrumentation
Waste Treatment
Disposal Site



Module
downtime/
year.
22,832
739
13,664
0
8,229
3,176
20
640
4,032
7,655
3,096
676
6,764
3,171
192
4,198
0
0
36
10
0
System
component
of
subsystem
MEH,
MEH/year
572
15,392
3,514
12,568
4,288
1,474
4,168
7,929
440
168
4,496
7,024
340
1,308
5,376
60
0
0
0
0
0
Plant
component
of
subsystem
MEH,
MEH/year
0
5,092
0
4,464
1,264
8,466
7,232
640
4,288
0
180
64
0
1,632
0
0
1,728
240

0
0



Total
Subsystem
MEH/year
23,404
21,223
21,178
17,032
13,781
13,116
11,420
9,209
8,760
7,823
7,772
7,764
7,104
6,111
5,568
4,258
1,728
240
oc
OD
10
0
*0ne hour of module downtime  is  equivalent  to  one MEH.
'The total  subsystem MEH/Year is the  sum  of the module,  system and  plant
 (station)  MEHrs.   The three  categories are mutually exclusive in that
 extensive MEH downtime for modular problems such as a complete mist
 eliminator failure due to a  boiler temperature excursion  forcing an entire
 FGD system out of service would appear under  system component rather than
 module downtime.   In this way the relative impact  of problems logged for a
 particular subsystem can be  gauged on a  modular, total  system, and plant
 (station) level as well as on an overall basis.
                                    78

-------
  and plant  levels.   For  a genera
  three boilers  equipped  with PGD
ing station  (power plant) having
systems each having two modules,
 one hour  of module  downtime  is  one MEH.   One hour of system or
 unit downtime  is  equivalent.to  two MEH (1 hour of system downtime
 x  2 modules/system).   One  hour  of plant  downtime is equivalent to
 six MEH  (1 hour of  plant downtime x 6  modules/plant).   The total
  subsystem MEH  is  the  sum of  the
MEH resulting from failures of a
 given  subsystem.   This  is  calculated by adding the MEH due to
 module,  system, and plant  downtimes.
      Ductwork,  stacks, pipes  and
 subsystems with a high percentag
 the system and  plant  levels.   Th
 valves, and thickeners are key
e of subsystem MEH manifested at
e most troub'lesome failure modes
 for the key  subsystems  are  highlighted below:
       0    Most duct  failures  occur  in  the  outlet duct.   The key
           ductwork failure  mode [is  corrosion of the outlet duct
           due to moisture carryover and residual SO  (SO0 and
           S03) .
                                                     x
           Stack  failures  are  almost  exclusively related to the
           lining.  The key  failure mode  is  acid attack of the
           stack  lining due  to moisture carryover and residual
           S0_ .
           Thickener  failures are
 primarily design related.
           Approximately  30 percent  of  the  design-related failures
           were to  supporting equipment rather  than the  thickeners
           themselves.  Joints,  lining,  and shaft failures are key
          , failure  modes  for thickeners.     |
       0    Fiber reinforced plastpLc  (FRP) pipe  failures  appear to
           cause more effective  dawntime (MEH)  than other pipe and
           valve failures.
       Stack lining  acid attack an3 outlet duct  corrosion were  key
 FGD system failure modes identified in this analysis.   Stack
 lining and outlet  duct failures are low frequency failures with
 high  penalties  (effects) associated with them  because they force
 the entire FGD system  (or system
 individual modules are available
 The MEH for these low frequency
3)  out of service, whether or not
,  usually for extended periods. >
failures are, prohibitive.   The
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                  79

-------
downtime they  cause may  be  catastrophic  in terms  of lost power
production.  There are seldom spares  provided for stacks and
outlet ductwork.
      In order  to  better  understand lime/limestone slurry FGD
system failure modes  and the  factors  associated with their
occurrence,  reported  failure  modes were  correlated with associated
system design  and operating characteristics.   The system design
and operating  characteristics investigated were as follows:
      0     Coal                    ;
      0     Boiler
      0     Application
      0     Design  and  operation
A brief description of this analysis  is  presented below.  A more
thorough treatment of this  topic is provided in Section 5, Per-
formance Evaluation and  Problem Diagnosis/Correction.
2.5.1.1    Coal Characteristics.   The  coal characteristics of
importance to  FGD systems are sulfur  and chlorine contents (see
Section 2.2).  These  characteristics  can be classified as low
 (less than 1 percent), medium (1 to 3 percent), and high (greater
than  3 percent) for sulfur; and low and  high (less/greater than
0.1 percent) for  chlorine.  The gas handling and  treatment sub-
systems of absorbers, ductwork,  and stack show a  strong correla-
tion  between high sulfur content and unreliability, and between
high  chlorine  content and unreliability.  The predominant problem
is corrosion attack in the  "wet" service areas.
2.5.1.2  Boiler Characteristics.  The boiler characteristics of
importance to  FGD systems are load: profile and age.  Load profile
represents the production output and schedule of  the generating
unit  (boiler). Four  basic  categories are defined:  base load
 (high production  level), intermediate load (moderate production
level), cycling  load  (low production level), and  peak load
 (intermittent  production level).  Boiler load profile shows a
correlation between unreliability and base load units, with
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 80'

-------
 downtime decreasing for cyclic load units and decreasing  still
 further for peak load units.  The overriding reason  for this
 trend appears to be the amount of
 scheduled downtime available
 for the unit and the greater opportunity to perform FGD main-
 tenance.  The results of unreliability as a function of age,
 where age is divided into one yeai: increments, are for the most
 part indeterminant and lack any correlation.  This may result
 from confounding the effects of depreciation and improved human
 skills.  If corrosion and wear were causative factors in equip-
 ment failure, the expected results would be increasing unreli-
 ability with age.  If a learning process was involved in improved
 equipment operation, a correlation between age and reliability
 should exist.
 2.5.1.3   Application Characteristics.  The application charac-
 teristics of importance are new versus retrofit, first versus
 second system, and size.  For new versus retrofit, fans and
 absorbers show a strong correlation between retrofit and
 unreliability.  For first versus second system, a number of
 utilities were examined which have more than one FGD system
 either within their power-generating system or at the same power
 plant.   A comparison of the first
versus the second FGD system at
 the same plant should give an ind:.cation of the effect of opera-
 ting experience on system reliability.   Comparisons for the most
 part do indicate slightly improved reliability for the second
 system.   For system size,  overall
 size per absorber module (MW/modu:.e) ,  were examined.  System size
 was  broken into two groups:   less
system size  (MW/unit), and the
or greater than 450 MW/unit.
 The  smaller units exhibited less c.owntime than the larger units.
 The  size of the unit appears to b^ a much more significant para-
 meter in terms of FGD system reliability than the size of the
 individual modules (MW/module)  in
 indicate  that smaller units do appear more desirable' in terms of
 reliability.
the FGD system.  The results
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 81

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 2.5.1.4   Design and Operation Considerations.  Section 2.4.3
 provides design data for operational FGD systems.  The design and
 operation considerations of importance are reagent type, water
 loop, solids dewatering, absorber parameters, reheat, reagent
 preparation, and fan location.  A brief summary for each consid-

 eration is provided.             ;

      0    Reagent type - the gas handling and treatment subsys-
           tems of absorber, ductwork, and stack show a strong
           correlation between lime systems and unreliability.
           This is probably because lime FGD systems are predomi-
           nantly used for higher sulfur coal applications.  Lime-
           stone shows a high correlation with unreliability in
           the slurry circuit  (limestone slurry is more abrasive
           than lime slurry).

      0    Water loop - the reliability of open and closed water
           loop FGD systems is another test for chloride (and
           other dissolved salts) 'as a failure mechanism.  Expec-
           tations are that closed water loops, high in chloride,
           will be associated with high unreliability.  Contrary
           to expectations, results indicated that unreliability
           was associated with open water loop systems.  One
           explanation for .this observation is that virtually all
           of the early generation commercial lime/limestone FGD
           systems were originally designed for closed water loop
           (no discharge)'operation.  However, due to a variety of
           problems  (e.g., buildup of dissolved salts), the water
           loop was eventually opened up as one of the first
           measures to relieve these problems.   (In other words,
           the water loop variable is an "effect" rather than a
           "cause".)

      0    Solids dewatering - results confirmed the expectation
           that FGD systems without dewatering were expected to be
           more reliable than  systems with dewatering because they
           have less equipment to cause downtime and lower concen-
           trations of dissolved salts that build up in the liquor
           loop.

      0    Absorber parameters - results indicated that towers
           with internals  (packed, tray) have a high correlation
           with unreliability.  The type of absorber exhibiting
           the highest unreliability is the packed tower.  Spray
           tower absorbers exhibited the highest reliability.
           However, mist eliminators showed a high correlation of
           unreliability with  spray tower absorbers.  This is to
           be expected when considering the open  structure of a
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                  82

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                                 L
spray tower, the high i/G ratio, and the upward  flow  of
the gas without impediment or a change  in direction.
Absorbers with internals have been associated with a
high degree of unreliability and are generally excluded
from new designs.  Another consideration in absorbers
is the use of "prescrubibers".  Prescrubbers include
upstream scrubbers, presaturators, and  quench towers.
A number of systems are equipped with one of these
devices to remove particulates, effect  initial SO2
absorption and/or condition the gas stream prior to the
absorber.  Systems with no prescrubbers appear to be
more reliable than systems with prescrubbers.  This is
an expected result becduse systems with prescrubbers
have an additional subsystem that may fail.  However,
the presence of a preso.rubber shows a high correlation
with reliability for SO2 absorbers in contrast to their
effect on the total sys|tem.  A possible explanation is
           that the combination o:
           ride, particulate, and
           in a prescrubber serves
           from failures.
           Reheat - the order of
           of reheat is no reheat,
           and indirect reheat.
                        flue gas quenching and chlo-
                       initial S02 removal that occurs
                        to protect the SO, absorber
                      decreasing reliability for type
                        bypass reheat, in-line reheat,
           Reagent_preparation - reagent preparation in a ball
           mill (limestone)  is associated with considerably higher
          .downtime for slurry circuit equipment (e.g., pipes,
           valves)  than is reagent preparation in a slaker (lime).

           Fan location - fan unreliability was affected by fan
           location between the scrubber and the absorber.  This
           location means that the fan operates completely wet—
           and the downtime results are as expected.  There was
           little  difference between downtime for fans located  .
           either  upstream (operating on hot, particulate-cleaned
           gas)  or downstream (operating oh reheated gas)  from the
           FGD system.
      A summary of the results  of
 FGD  characteristics  discussed  in
 Table 2.5-4.
                       the failure mode analysis by the
                       bhe foregoing is provided in
 2.5.2      System Layout,  Accessibility,  and Design
     An essential  feature  of  any
                       treatment of O&M practices is
 consideration of  FGD  system layoui:,  accessibility,  and design.
 Layout  and  accessibility  are face bs  of  FGD  design and operation
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY

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that go hand-in-hand.  System layout refers to the physical
arrangement of the equipment comprised by the FGD system.  System
accessibility refers to the approach and entry of the equipment
comprised by the FGD system.  System accessibility is a direct
function of system layout.  A physical arrangement of equipment
that is more open and less restrictive will improve approach and
entry to the equipment.  Conversely, a physical arrangement that
is close and constrictive will diminish approach and entry to the
equipment.  Obviously, the FGD system does not have a limitless
amount of space available to permit a physical arrangement of the
equipment in a completely open fashion to maximize accessibility
to all equipment.  Moreover, spatial necessities are assigned in
priority to the power-generating unit operations and peripherals.
Pollution control operations are generally assigned lowest
spatial priority at the plant.  Hence, within the given framework
of a low spatial priority, an FGD system layout must be defined
which minimizes spatial requirements while maximizing accessibil-
ity.
     This section will be devoted to layout, accessibility, and
design features that are suppor-ive of adequate O&M practices.
These features will be addressed in terms of the various physical
subsystems previously defined in Section 2.4.2. (Existing Design
Configurations).
2.5.2.1   Gas Handling and Treatment.  Typically, O&M necessities
are more rigorous for the "dynamic"  (moving) components than for
"static" (immobile) components.
dynamic components are fans and
 For this equipment area, the
dampers; the static components
are scrubbers, absorbers, mist eliminators, and reheaters.  With
respect to the dynamic components, fans represent a greater O&M
concern because of their constant high rate of motion.  System
layout, accessibility, and design considerations that enhance fan
O&M are as follows:
     0    Placement of the fan at grade level, a practice which
          is widely accepted because of sheer size and weight of
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                85

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          the equipment.  Some of the earlier  (and smaller)
          systems used elevated fan placements.  Accordingly,
          maintenance and repair activities were severely
          limited.

     0    Placement of the fan before  (upstream) the absorbers, a
          practice which is widely accepted and implies the
          existence of an upstream particulate collection device
          (typically ESP).  These fans are generally larger than
          those that follow  (downstream) the absorber because of
          higher volumetric flow rate  (operation at 300°F vs.
          175°F).  However, downstream fans require larger motors
          because of the additional mass added to the gas stream
          in the form of moisture.

     0    Upstream fans produce a positive pressure operating
          environment.  Therefore, any leaks in the downstream
          equipment will allow emission of flue gas into the
          local environment.  Any jleakage problem is further
          aggravated where the FGD system is located in an
          enclosure.  Special attention to leak-proof designs is
          a necessity.

     0    Fan capacity to overcome FGD system gas-side pressure
          drop can be provided by ;a separate booster fan or
          incorporated into the unit ID fan.  The latter practice
          is widely accepted because it is easier to operate one
          fan instead of operating and balancing two fans.
          However, a separate booster fan is easier to maintain
          and repair because of size.

     The function and duty of the various types of dampers pre-
sent in lime/limestone slurry FGD systems is described in Section
2.4.2.5.  Dampers are less dynamic than fans in that their opera-
tion is much slower and intermittent.  However, their O&M
necessities are equally demanding because of the cascading effect

their malfunction can have on downstream operations.  The in-

ability to properly control and isolate the flue gas stream can

either severely minimize or totally eliminate operating, mainten-
ance, and repair functions, or compromise worker safety necessi-
ties.  Layout considerations that enhance accessibility are site
and design specific; however, there are some significant overall
design considerations:

     0    The ductwork design should be able to accommodate the
          insertion of simple isolation blanking plates to

SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY                  '               ~~

                                86

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          isolate ducts for the protection of the maintenance
          crew during inspection and repair.  The plates and
          insertion point should be arranged such that the duct
          can be easily -"broken" and the plate quickly rolled
          into position.

     0    Guillotine dampers are the most widely used design
          because of superior seal-off capability.  However, they
          are more troublesome tojoperate, maintain, and repair
          than other designs.  Guillotine dampers are generally
          top-entry design.  This tends to limit observation and
          inspection opportunities.  Emergency operation is
          difficult in that manual operation (in the event of an
          operator or drive malfunction) is timely and labor
          intensive.  Dampers should be arranged to provide
          prompt access via conventional catwalk and handrails.

     0    Damper performance is a direct function of ductwork
          location.  A straight-run location is preferable to an
          elbow or bend because of gas channelling and uneven gas
          distribution; the longef the straight run, the better
          the performance.                                 <  ;

     The O&M necessities for static components in the gas handling
and treatment equipment area are typically less demanding than
dynamic components because of the
associated with the latter.  Accordingly, the layout, accessibil-
ity, and design considerations ar<
potentially higher wear rates
 correspondingly less crucial,
as noted in the considerations that follow:

     0    Cleanout doors should be| provided at various levels in
          the scrubber/absorber tower to:

               access the base of I the tower,

               access the upper level of the tower, generally
               in the spray zone,

          -'   access the mist eliminator, generally below or
               inbetween stages, depending on whether it is a
               single- or multiple-stage mist eliminator design,
               and

               access the reheat dhamber.
          Visual ports at various
          provided to permit visu<
levels in the tower should be
1 inspection during operation,
          especially for the absorber (or scrubber) at the inlet
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                87

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          gas/slurry, hot/dry interface area; gas/slurry contact
          zone; and mist eliminator.

     0    Manways should be provided at other levels in the tower
          which do not require rapid access and entry.

     0    A drainage system should be provided that allows for
          complete drainage of the towers for inspection and
          maintenance.

     0    Vertical tower versus horizontal tower arrangement is a
          major consideration.  The vertical arrangement predomi-
          nates because of spatial and cost factors.  The hori-
          zontal arrangement permits overall easier access
          because of equal accessibility at the same elevation to
          all portions of the vessel.  It also consumes less
          power because of lower gas-side pressure drop and lower
          slurry pumping height;

     0    Horizontal  (vertical gas flow) versus vertical  (hori-
          zontal gas flow) mist eliminator and reheater (in-line
          tube bundles) designs involve the same O&M advantages
          and disadvantages as vertical and horizontal towers-

2.5.2.2  Reagent Preparation and Feed.  Similar to gas handling

and treatment, reagent preparation and feed equipment can be

distinguished according to dynamic and static service.  Dynamic

components include conveyors, ball mills, slakers, and pumps;

static components include tanks, piping and valves, and storage

bins.  Again, the dynamic components are of more concern than the

static components.  The dynamic components operate in a slurry

service environment.  Slurry suspensions of 5 to 75 percent

solids are continuously or intermittently transferred or recycled

at low to high flow rates in the slurry circuit.  Access and

design considerations that enhance O&M are as follows:

     0    Placement of the slurry pumps in a central pump house
          at grade level.  Segregation of pumps with similar or
          identical service requirements or location of pumps in
          a sump area  (below grade or beneath the equipment, in
          slurry service) limits operating versatility, mainte-
          nance, and repair.
                                i
     0    Provision to accommodate flush-out and flush water
          necessities during shutdown and outages through fresh
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                88

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           (or clarified) water
          drains.
  supply and disposal sumps and
     The static components are
service environment as the dynam:
duty requirements are less severe
to move within this environment,
those described for the dynamic
considerations include:
  subjected to the same slurry
    c components.  Although their
     in that they are not required
    the same restrictions apply as
   components.  Additional design
          Provision of sufficient space to minimize elbows,
          bends, restrictions, reducers, and expansions  in the
          slurry piping.
          Provision of ample drainage to quickly accommodate
          planned and unscheduled outages.
          Provision of sufficient surge capacity within  the
          tankage network to accommodate extended peak load
          operation or to withstand the loss of a tank for a
          limited period of time.
2.5.2.3   Waste Solids Handling 5
the distinction of dynamic and st.atic components, dynamic com-
ponents include thickeners  (clarifiers), filters, centrifuges,
conveyors, and pumps.  Static components include tanks and stor-
    nd Disposal.  Continuing with
age bins.  Many of the same consi
preparation and feed also apply Y
peculiar to this area include:
    derations described for reagent
    ere.  Additional considerations
          Placement of all secondary solids dewatering equipment
          (filters and centrifuges and ancillaries) in a central
          dewatering house at the grade level.
          Minimization of the pipe run between primary dewatering
          (thickener) and the dewatering house, as well as the
          dewatering house and disposal area.
          Sufficient space to stockpile solid waste during
          emergency conditions (thickener outage, filter outage,
          pump failure, pipe failure).
          Access walkways to
          operation.
inspect thickeners and filter
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                89

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     0    Protective covers for tanks, thickeners, and other open
          vessels.
2.5.3  O&M Practices
     This section introduces the various types of operation and
maintenance  (O&M) practices for lime/limestone slurry FGD
processes, the conditions under which the practices are imple-
mented, and specific activities involved in each.  A more
thorough treatment of the subject can be found in Section 6
(Model O&M Plan).  This section introduces the O&M requirements
for these processes:  standard operating practices, routine
startup and shutdown, and operating modes for system upset condi-
tions.  The size, duties, and training needs of an operating crew
are reviewed.  Maintenance practices are described separately;
the requirements for maintenance personnel, in terms of numbers,
duties, experience level, and training are also reviewed.
2.5.3.1  Standard Operations.  With increasingly more stringent
requirements on plant emissions, the owner/operator utility must
make a strong commitment to FGD operation, including adequate
staffing.  Operators should be assigned specifically and solely
to the FGD system during each shift.  FGD system operation must
be coordinated with the unit's power generation schedule and even
into the purchasing of coal  (i.e.1, sulfur, ash, and chlorine
characteristics).  Some of the current difficulties with lime/
limestone FGD systems relate to poor operating practices, unnec-
essarily complex operating procedures, or both.  In some cases,
although the equipment has been correctly installed, it rapidly
deteriorates and breaks down because of improper O&M practices.
The operating characteristics of the FGD system can be estab-
lished during the initial startup period, which is also a time
for finalizing operating procedures and staff training.  Once
steady-state operating conditions are reached, the system must be
closely monitored and controlled to ensure proper performance.
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 90

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During periods of changing load or variation of any  system param-

eter, additional monitoring is required.  Some standard O&M
procedures are described below.

     °    Varying Inlet SO, and Boiler Load.  As boiler load is
          increased, additional modules are placed in service
          and, conversely, modules are removed from  service when
          i   -!_.. -,___-,          ,   with each change  in load, the
boiler load is reduced.
          operator must check the
          service modules are ope
                        system to verify that all in-
                        rating in a balanced condition.
          As the S02 concentratiojn in the inlet flue .gas changes,
          the FGD system should bfe able to accommodate and
          compensate for such changes.  Operator surveillance of
          system performance is needed, however, to verify proper
          system response (e.g., jslurry recirculation pumps dan
          be added and removed from service as the SO2
          tion increases or decreases).
                                             concentra-
          Verification of Flow Rates.  The easiest method of ver-
          ifying liquid flow ratefe is for an operator to deter-
          mine the discharge pressure in the slurry recirculation
          spray header with a hand-held pressure gauge (perma-
          nently mounted pressure)gauges frequently plug in slur-
          ry service).   Flow in slurry piping can be checked by
          touching the pipe.  If -;he piping is cold to the touch
          at the normal operating
          the line may be plugged

          Routine Surveillance of
                        temperature of 125° to 130°F,
                        Operation.   Visual inspection
          of the absorbers and reaction tanks can identify scal-
          ing,  corrosion,  or erosion before they seriously impact
          the operation of the system.   Visual observation can
          identify leaks,  accumulation of liquid or scale around
          process piping,  or discoloration on the ductwork sur-
          face  resulting from inadequate or deteriorated lining
          material.
          Mist Eliminators.   Many
                        techniques have been employed
          to improve mist collect:.on and minimize operational
          problems.   The mist eliminator can be washed with a
          spray of process makeup water or a mixture of makeup
          water and  thickener overflow water.  Successful,
          long-term  operation without mist eliminator plugging
          generally  requires  continuous operator surveillance,
          both  to check  the differential pressure across -the mist
          eliminator section  and to visually inspect the appear-
          ance  of blade  surface  during shut down periods.
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                91

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         Reheaters.   In-line reheaters are frequently subject to
         corrosion by chlorides ;and sulfates.  Plugging and
         deposition can also occur, but are more rare.  Usually,
         proper use of soot blowers prevents these problems.

         Reagent Preparation.  Operational procedures associated
         with handling and storage of reagent are similar to
         those of coal handling.  Operation of pumps, valves,
         and piping in the slurry preparation equipment is
         similar to that in other slurry service.

         Pumps, Pipes, and Valves.  Operating experience has
         shown that pumps, pipes, and valves can be significant
         sources of trouble in the abrasive and corrosive
         environments of a lime/limestone FGD system.  The flow
         streams of greatest concern are the reagent feed
         slurry, the slurry recirculation loop, and the slurry
         bleed streams.  When equipment is temporarily removed
         from slurry service, it must be thoroughly flushed.

         Thickeners.  Considerable operator surveillance is re-
         quired to minimize the suspended solids in the thick-
         ener overflow so that this liquid can be recycled to
         the system as supplementary pump seal water, mist
         eliminator wash water,(or slurry preparation water.
         For optimum performance, the operator must maintain
         surveillance of such parameters as underflow slurry
         density, flocculant feed rate, inlet slurry character-
         istics, and turbidity of the overflow.

         Waste Disposal.  For untreated waste slurry disposal,
         operation of both the discharge to the pond and the
         return water equipment requires attention of the oper-
         ating staff.  In addition to normal operations, the
         pond site must be monitored periodically for proper
         water level, embankment damage, and security for pro-
         tection of the public.  Landfill disposal involves the
         operation of secondary dewatering equipment.  Again,
         when any of the process equipment is temporarily re-
         moved from service, it must be flushed and cleaned to
         prevent deposition of waste solids.  For waste treat-
         ment  (stabilization or:fixation), personnel are re-
         quired to operate the equipment and to maintain proper
         process chemistry.

         Process Instrumentation and Controls.  Operation of the
         FGD system requires more of the operating staff than
         surveillance of automated control loops and attention
         to indicator readouts on a control panel.  Manual
         control and operator response to manual data indication
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY I
                                92

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           are often more reliable
           and are often needed to
than automatic control  systems
prevent failure of the  control
                 —	-— — •— %-v £*.A-'vv>vA.Li* a-(-*._i_jL«-4J_c- W -l_ I—lie ^ wil L..LU.L
           system.  Many problems.ian be prevented when an opera-
           tor can effectively integrate manual with automated
           control techniques.

 2-5.3.2   Initial Operations.  Very seldom does a system perform

 properly when it is first placed in service.  Even though string-

 ent  quality control may be exercised during the construction

                                   optimize the control functions
 and  to  correct minor problems.   Although the individual components

 may  be  completely checked out during construction tests, the
 integrated  system performance can
be evaluated only when the
 system  is placed  in  operation.   Cojmpliance testing is normally

 accomplished  immediately after  initial startup.   Tests conducted

 under the proposed normal operating procedures can verify the
 procedures and  familiarize the  station staff with the system.
 After the initial startup tests have established a norm for

 system  operation, additional  testing is conducted for two pur-

 poses:  to verify performance guarantees and to  demonstrate
 continuing compliance with regulations.

 2-5.3.3   Startup, Shutdown,  Standby,  and Outage.   Startup and
 shutdown are two nonsteady-state operating modes that occur
 frequently.  Furthermore,  two nonoberating conditions that

necessitate action .by the  operating staff are system standby  and
extended outage.  Each of  these  situations is of special  interest
to the FGD operating staff.

     °    Startup and Shutdown.  Before  flue  gas is  introduced
          into the system,  slurry is added as a  "lean"  stream
          (low slurry solids  content).   A prerequisite  to  start-
          ing slurry flow  is  the initiation of the limestone
          grinding or lime  slaking  to  ensure  the availability of
          slurry feed.  After integrated operation begins  and
          reaction product  solids are  permitted  to build up to a
          specified control level,  the staff  must be  ready to
          process the slurry bleed  stream (i.e.,  slurry purged
          for waste disposal)  .  Wh£n the  system  is placed  in
          service, the operating staff must be available to moni-
          tor system response as boiler  load  is  increased.  As
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                93

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          the  flue  gas  flow rate through the modules approaches
          the  maximum design value,  additional modules are
          systematically brought into service.  As boiler load is
          reduced in preparation for unit shutdown, the startup
          sequence  is executed in reverse.
     0     System Standby.  A module  that is ready to process flue
          gas  is said to be on standby.   The module may have been
          removed from  service because of a reduction in station
          load and  is now prepared for service because of an
          anticipated increase in load.   When a module is removed
          from service  because of a  load reduction, the slurry
          bleed stream  must be terminated and the bleed line
          flushed.   When a module is brought into service, the
          operator  must prepare the  bleed stream line to accept
          flow.
     o     Extended  Outage.  Additional attention is necessary
          when a module is removed from service for an extended
          period.  The  slurry recycle pumps and the recycle line
          should be drained and flushed.  During the outage, the
          operating staff should, conduct inspections of equipment
          that is normally inaccessible.
2.5.3.4   System Upsets.  Upsets are associated with the boiler,
particulate control system, the FGD system, or the waste disposal
system.  A boiler "trip"  (actuated shut-off of equipment item)
will terminate the flow of- flue gas through the FGD system.  Ex-
cept for the possible discharge of unreacted  slurry to the waste
processing equipment, there should be no adverse  impact on the
FGD system.  Transient conditions causing  an  increase  in  flue gas
flow may produce scaling  of the mist eliminator or excess liquid
carryover.  A  trip of the upstream particulate control device can
result in a system shutdown because  the FGD  system will generally
not be able to withstand the  impact  of  fly ash  (increase  in  sol-
ids loading)  for an  extended  period  of  time.   Inability of  the
FGD system to  process  flue  gas  can  lead to a boiler upset and
removal of the unit  from service.   Failure of a  single module can
lead to a reduction  of  unit/station output.   The  inability  to
process slurry bleed for waste  disposal could impair  FGD  opera-
tions  and station  output due  to waste  slurry buildup.   Since
 SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                 94

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waste processing systems usually
station output should only be reduced, at worst.
2.5.3.5  Operating Staff and Training.  The size, experience
                       incorporate some spare capacity,
level, responsibilities, and training of the operating staff are.
significant factors in FGD systein performance.  In staffing, the
absorber and waste disposal operations must be considered sep-
arately.  In addition to the normal complement of equipment
operators and supervisory personnel on the operating, crew of each
shift, certain specialists should always be available to assist
them.  Chemical engineers are essential for evaluating system
operating conditions.  Chemical
to analyze the process chemistry
2.5.3.6   Preventive Maintenance
                      laboratory technicians are needed
                       Programs.  Preventive mainte-
nance is the practice of maintaining system components in such a.
way as to prevent malfunctions during periods of operation and to
extend the life of the equipment.  The goal of preventive mainte-
nance is to increase availability of the FGD system by eliminat-
ing the need for emergency repair  ("reactive maintenance").
     The term preventive maintenance is synonymous with periodic
maintenance.  Such procedures majy be as simple as lubrication of
a pump or as complex as complete
          Absorbers.  Of primary
                       disassembly for inspection and
overhaul.  Some of the more impofrtant preventive maintenance pro-
cedures by subsystems are summarized in the following sections:
                       concern in the absorber module
          is the integrity of the structural materials.  Main-
          tenance personnel should enter and inspect the absorber
          module at least semi-annually.
          Mist Eliminators.  Scale deposits typically are the
          chief maintenance factbr with mist eliminators.  The
          mist eliminator may be subject to nonuniform flow or a
          faulty wash system.  Wash spray pressure should be
          monitored.  Mist eliminators should be inspected during
          forced or scheduled outages.
          Reheaters.  Both in-lipe and indirect reheaters are
                                             In addition to
subject to scaling and
corrosion.
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                95

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          visual inspection, pressure testing and measurement of
          heat transfer efficiency are useful in quantifying the
          magnitude of a reheater problem.  In an indirect reheat
          system, the mixing chamber and the air heating equip-
          ment must be checked routinely.

          Dampers, Fans, Ductwork, and Chimneys.  All points in
          the system must be checked for integrity of lining
          materials and for damage resulting from collection of
          condensation products in stagnant air spaces  (e.g.,
          duct elbows and corners).  Components located in the
          wet portion of the system are subject to scaling and
          corrosion.  Upstream fans and ductwork may be subjected
          to erosion.

          Reagent Preparation.  Reagent preparation subjects the
          ball mill or slaker to abrasive wear.  Because the
          equipment sees intermittent service, it should be
          inspected visually each time it is placed in service.
          Annual disassembly is also needed to check for exces-
          sive wear.              ;

          Reagent Feed.  Maintenance of the reagent slurry feed
          system is critical because failure of this equipment
          strongly impacts the FGD system operation.  The slurry
          storage tank should be checked daily for leakage and
          associated equipment inspected for proper operation.

          Pumps, Pipes, and Valves.  Slurry pumps are normally
          disassembled at least annually.  The purpose of the
          inspection is to verify lining integrity and to detect
          wear and corrosion or other signs of potential failure.
          Bearings and seals are checked but not necessarily re-
          placed.  Pipelines also must be periodically disassem-
          bled or tested in other ways (e.g., hand-held nuclear
          and ultrasonic devices) both for solids deposition and
          for wear.  Valves must be serviced routinely, especial-
          ly control valves.

          Thickeners.  Thickener coatings should be inspected
          periodically to prevent corrosion.  Drag rakes, torque
          arms, and support cables must also be inspected for
          wear.

          Waste Disposal Equipment.  Secondary dewatering devic-
          es , mixing components, and transport equipment must
          also have periodic maintenance to check for abrasive
          wear and solids deposition.  Vacuum filters, both drum
          and belt type, require periodic replacement of the
          filter media.  In a centrifuge, both the scroll coating
          and the bowl surfaces are subject to wear.
SECTION 2-LIME/L1MESTONE FGD TECHNOLOGY
                                96

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          Process Instruments and, Controls.  All electronic
          equipment  (pH, flow, prjessure, temperature, level,
          vibration, noise, and continuous monitors) must be
                                    Numerous installation and
                                 have proved beneficial in
calibrated periodically
maintenance techniques
          ensuring the reliability of sensors.  Ease of access to
          the sensors is very important.  The sensors should be
          cleaned and calibrated routinely.  Experience with
          process instrumention and controls in FGD systems has
          shown that a good preventive maintenance program begins
          with daily operating procedures.  Proper use of instru-
          ments will include daily flushing of most instrument
          lines in slurry service just before monitoring of
          process variables.  Roujtine comparison of the instru-
          ments in a process strejam with similar instruments in
          parallel streams can po'int out incipient failures.
          Operating data, especially from the startup test
          program, can also indicate potential problem areas.

2.5.3.7   Unscheduled Maintenance.  Even the most rigorous pre-
ventive maintenance program will not prevent random failures to
which the maintenance staff must
                       respond.  Most malfunctions are
correctable by unscheduled  (reactive) maintenance.  In some
situations, usually during initial system startup, design modifi-
cations may be required to bring
operating standards.  Each subsystem of the FGD system is subject
to malfunctions from a variety of
follows introduces these problems
                       the system into compliance with
                        causes.  The discussion that
                        and the probable responses.
          Absorbers.  Structural failure of absorber internals
          and recycle pump suction screens have occurred as a
          result of excessive vibration, uncorrected corrosion
          damage, or high pressure differentials.  These malfunc-
          tions must be repaired immediately before operation is
          resumed.

          Mist Eliminators.  Failure of the mist eliminator is
          typically due to scalin
                       3 and plugging.  The scale may
          be removed either by thorough washing or by mechanical
          methods, in which maintsnance personnel enter the
          absorber and manually chip away the scale deposits.
          Reheaters.  Reheater malfunctions include tube failures
          in in-line reheaters, damper problems in bypass reheat,
          or nonuniform flows in indirect reheaters.  Correction
          of these problems will probably necessitate changes in
          equipment design.
SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY

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r
                    Fans.   Fans can develop | vibrations resulting from
                    deposition of scale in wet service or from erosion of
                    blades in dry service.  The cause of the vibration must
                    be eliminated and the fan repaired and rebalanced.

                    Ductwork.  Most problems associated with ducts develop
                    over a long period.  Sudden or gross failures, such as
                    a major leak, call for immediate repair.  Temporary
                    repair or patching may suffice until the next scheduled
                    outage.  Acid condensation in a chimney can cause
                    lining deterioration and subsequent damage to the base
                    metal.  These problems are usually identified during
                    preventive maintenance inspections and require long-
                    term solutions.        :

                    Reagent Feed.  Malfunctioning components such as ball
                    mills or slakers must be repaired in accordance with
                    the manufacturer's instructions.  Some facilities have
                    experienced trouble with plugging of the lime or lime-
                    stone feeder due to intrusion of moisture.  Correction
                    of these problems will probably necessitate changes in
                    equipment design.

                    Pumps, Pipes, and Valves.  Excessive wear of the im--_
                    peller or separation of the lining from the pump casing
                    is a common problem.  Operation of slurry pipeline with
                    insufficient flow velocity can cause clogging.  High
                    flow velocity or extended service can cause erosion.
                    Malfunction and binding of a valve actuator are typi-
                    cally caused by wear-induced misalignment.

                    Thickeners.  The thickener underflow can become plugged
                    because of excessive  solids in the slurry or  failure of
                    the underflow pump.  A plugged underflow or rapidly
                    settling waste solids will produce a "heavy" blanket in
                    the bottom of the  thickener.  The rake must then be
                    raised so that the torque remains within acceptable
                    limits.  If the torque cannot be kept within  limits,
                    the thickener must be drained and the sludge blanket
                    removed manually.
           SECTION 2-LIME/LIMESTONE FGD TECHNOLOGY
                                           98

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                             SECTION 3
                      PERFORMANCE

       Performance monitoring is a
 MONITORING
major element  in  the O&M  activ-
  ities of every lime/limestone slurry FGD system.  Monitoring the
  FGD system is required to demonstrate compliance with applicable
  standards as well as to demonstrate that the system meets the
  vendor performance guarantees.  J Additionally, routine monitoring
  can identify potential operating
  cantly impact the performance of
problems before they signifi-
the system and/or the generating
  unit.   This section is devoted to lime/limestone slurry FGD
  system performance indicators and their measurement.  Addressed
  in this section are the instrumentation systems that measure
  process parameters, manual testirg and continuous emission moni-
  toring methods used for emission measurements, and recordkeeping
  practices of the operator utility.   This information is presentee
  from the perspective of the agency inspector.   Namely, what
  monitoring techniques will yield what kinds of data, how are
  these  data recorded and logged,  and how to interpret these data
  in terms of SO2 compliance status.
  3.1  KEY  OPERATING PARAMETERS  AND
      The  key  operating  parameters
  the  FGD circuits  identified  in Se
  tions)„   The  gas  circuit paramete
  opacity,  O2,  gas  volume, and pres
  parameters of importance are pH,
  measurement values  associated  wit
  assessed, give the  entire picture
  compliance status.
 THEIR MEASUREMENT
 can be described according to
ction 2.5 (FGD O&M Considera-
rs of importance are SO
                          NO
                             ,
                            X
sure.   The slurry circuit
solids, and slurry volume.   The
  these parameters, when
 of FGD system performance  and
SECTION 3 - PERFORMANCE MONITORING

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3.1.1  Gas Circuit Parameters
3.1.1.1   S0?.  Coal-fired boilers governed by the revised NSPS
of June 1979 are required to continuously monitor S02 emissions
to demonstrate compliance with standards.  In general, all FGD-
equipped, coal-fired, utility boilers are equipped with SO2
continuous emission monitors.  They generally take the form of
stack monitors.  In many cases, FGD inlet and outlet SO2 monitor;
are provided to continuously measure SO2 removal efficiency
across the system  (and/or the individual absorber modules).
Theoretically, these monitors can be instrumented into the proc-
ess control network through feedforward or feedback reagent feed
control loops.  To date, these control strategies have been
researched and developed and used intermittently in commercial
operations.  However, simple slurry pH control  (Section 3.1.2.1)
continues to provide adequate process control monitoring.
3.1.1.2   NO  .  A  continuous monitor is used in the stack to
            .X,                     !
comply with NSPS monitoring requirements.
3.1.1.3   Opacity.  To  satisfy the;NSPS continuous monitoring
regulations,  the opacity at the outlet of the FGD system  (stack
monitor) must be measured every 10 seconds.  The data must be
averaged and  recorded every  6 minutes, with a minimum of  24
equally spaced data points being used in the average.
          22.
An O- monitor is used to convert continuous mon-
3.1.1.4
itoring pollutant  (i.e., SO2 and NOx) concentration values to
NSPS units  (lb/106 Btu).  The 02 basically serves as a diluent
gas.  For existing sources, an O2 monitor is required only if
state law requires data for converting to the emissions standard.
The equations used for this conversion are shown in Appendix B.
The O~ monitor must be  located at a point where measurements can
be made that are representative of the pollutant gases sampled by
the S09/N0  monitors.   The O2 monitor sampling point location
conforms best with this requirement when it is at approximately
the same point in the duct as the SO2/NOx system.  The O2 gas
  SECTION 3 - PERFORMANCE MONITORING
                                  100

-------
 sample may be  extracted  from a  different duct location if the
 stack gas is honstratified  at both locations  and there is no
                                  een  the  two  sampling points.   If
                                  at a different location from  the
leakage of air into the duct betv
the €)„ monitor sampling point is
SO2/NOx sample point and stratification exists in the duct, a
multipoint extractive probe must be used for sampling.  This is
also true for the monitoring system when the O  and SO,, /NO
                                                           X
monitors are not of the same typ^  (i.e., one is extractive and
                      A CO2 monitor can also be used in place of
the other in-situ) .
the O  monitor.
3.1.1.5   Gas Flow Rate.  The FGfi  system must  continuously  re-
spond to variations in gas flow rate.   If multiple  absorbers  are
used, a dependable system to balance flow rates between parallel
modules must be provided.  Because the  boiler  and FGD  system  are
often designed as separate units
                                 and frequently have separate
control rooms, controller coordination is essential.
     The flue gas flow rate is a
                                 major operating variable and is
controlled in proportion to the generating unit load by adjusting
control dampers on the unit or FGD booster fans  (see Section
2.4.2.1).  The volumetric flow rate can be estimated from the
stack gas velocity or, alternate
                                 ely, from the fan performance
curves provided by the manufacturer.  The latter procedure should
be used only as a check to validate the data from the first
method.
     Gas pressure sensors are extremely important as a means of
gas flow rate indication, load-following control, and problem
indication.  The simplest method,
systems to equalize gas flow through the multiple modules, is the
use of pressure drop.  The total pressure drop through a module
is the sum of the losses through
absorber, mist eliminator, and reheater  (if present).  Each of
these losses is a function of the
                                  and the one used in most FGD
                                 the inlet and outlet ductwork,
                                  gas flow treated by the module.
Modules operating in parallel gensrally have equal pressure drops
because of identical modular designs.
SECTION 3 - PERFORMANCE MONITORING
                                101

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3.1.2  Slurry Circuit Parameters
3.1.2.1   pH.  Slurry pH is the most important control parameter
in lime/limestone slurry processes.  Measurement of pH in slurry
service is more difficult than pH measurements in many other
process applications.  The pH electrodes are fragile devices,
easily damaged by extreme weather conditions, floating debris,
and the slurry environment.  Slurry can also form a deposit on
the electrodes, acting as an electrical insulator and giving a
false value of the electrode potential.  For this reason, it is
essential that pH electrodes be kept clean.  However, despite
these limitations, slurry pH is universally accepted because of
its simplicity and widespread use.  The pH measurement location
is an important consideration.  There are three main choices:
(1) the spent slurry upstream of the reaction tank;  (2) the fresh
slurry feed to the absorber; and  (3) in the slurry reaction tank
itself.  The favored choice of the utility industry is the reac-
tion tank.
3.1.2.2   Slurry Flow Rates.  Measurement of slurry flow rates is
vital to the optimization of the process.  The flow rate of fresh
slurry is perhaps the most important control application; howev-
er, the flow rates of slurry recirculation and slurry bleed
streams are also vital control operations.  The slurry flow rates
are used to control the absorber L/G  (see Section 2.3.2.2) which
is a vital operational and performance factor.
3.1.2.3   Solids Content.  There are three areas where the solids
content of the slurry is controlled:   slurry feed, slurry recir-
culation, and thickener underflow.  Once the stoichiometric ratio
is properly maintained, the solids  level can vary without being
critical to the operation of the absorber.  A consistent slurry
solids level, along with proper stoichiometry,  can  reduce plugg-
ing and deposits in  the absorber, minimize erosion,  and reduce
the volume of solid waste.
 SECTION 3 - PERFORMANCE MONITORING
                                 102

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3.2  INSTRUMENTATION
     To date, the extent of instrumentation used on lime/lime-
stone FGD processes has been relatively limited.  Moreover, much
of the instrumentation used in existing systems has suffered
                       This section
reliability problems.
describes the different types
of instrumentation used for the measurement of some of the impor-
tant performance monitoring parameters addressed in Section 3.1.2,
Instrumentation described includes process control applications
for monitoring pH, slurry flow rates, and solids content.  SO»
monitors are addressed in Section
3.2.1  pH Instrumentation
     There are two types pf pH ser
             8
                                  3.3.
                                  sors;  immersion  (dip-type) and
flow-through.   The immersion sensor is merely inserted into a
tank and can be removed for maintenance and calibration.  A flow-
through sensor depends upon a continuous flow in the sample line.
Both have advantages and disadvantages.  The immersion sensor is
easier to operate and maintain.  Performance can also be improved
by locating the sensor in a specie.1 sampling tank, by using
redundant sensors, and by frequent, cleaning and calibration.  The
flow-through pH sensor is prone to wear and abrasion.  Mainte-
nance to ensure good performance of flow-through sensors is much
easier when  (1) the sample lines are short and relatively large
in diameter, (2) the sample taps are located at the top or side
of the slurry line, (3) back-flushing capability is provided, and
(4) a deflector bar is installed upstream from the sensor to
reduce erosion.  Redundant sensors
                                   are also desirable for the
flow-through type but are not as easy to provide.
     Practice has differed in regard to both the method and
frequency of cleaning the pH .sensors to remove scale.  Ultrasonic
self-cleaning devices have been used, but in numerous cases have
caused cell breakage.  The best method seems to be manual removal
and washing with acid on.a regular schedule.  Lime systems are
less susceptible to scale formation problems on sensor elements
SECTION 3 - PERFORMANCE MONITORING
                                103

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than' limestone.  In many existing systems, improper design limits
the access to the pH sensors, resulting in inadequate service.
Some utilities have reported the buildup of a film on the probes
of immersion sensors.  A properly designed electrode station
should have easy access for pH sensor maintenance.  If possible,
each pH sensor should have a maintenance station equipped with a
workbench, a cabinet to hold spare parts, small tools, and stand-
ardizing solutions.  Tables 3.2-1 and 3.2-2 summarize the pH
instrumentation used in a number of representative lime and
limestone slurry FGD systems.    i
3.2.2  Slurry Flow Rates
     Instrumentation measuring slurry flow falls into three broad
categories:  mechanical measurement of pressure differential,
electronic measurement, and measurement in open channels.  Each
category has its specific applications.
     Mechanical flowmeters are not suitable for abrasive slurry
environments.  The more acceptable meters for.this service are
electronic devices.  Electronic measurement of flow rate are
accomplished with Doppler-effeet ultrasonic meters and electro-
magnetic flowmeters.  The Doppler-effeet ultrasonic meter is a
fairly new development for slurry applications.  The principal
advantage of this device is that the electrodes are attached to
the outside of the pipe through which the slurry is flowing;
there is no penetration of the pipe.  The electromagnetic flow-
meter, or "magnetic meter," is the best proven instrument avail-
able for the measurement of pressurized slurries.  It consists of
a stainless steel pipe section lined with an electrically insu-
lated material.  The magnetic meter does not require installation
in straight piping.  It has no operating parts in contact with
the fluid, produces very little pressure drop, and is fairly
accurate.  The only disadvantage of the magnetic meter is its
high capital cost and the closer attention required for instrii-
ment calibration.
 SECTION 3 - PERFORMANCE MONITORING
                                104

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  3.2.3  Solids Content
       All lime/lime stone FGD systeirs include instrumentation for
  monitoring the solids level of fresh feed slurry, recycle slurry,
                                    Densinometers are used to moni-
and thickener underflow  streams.
tor and control the solids in slurry  streams  and  tanks.   Slurry
density can be measured  directly with special differential pres-
sure instruments, requiring a mininum liquid  depth of  6  ft to
measure a span of 0.1 specific gravity units.  Ultrasonic devices
directly measure the suspended solids.  Vibrating reed instru-
  ments  measure  the dampening effect
                                   of the slurry on vibrations
                                     Nuclear density meters which
from an electrically driven coil.
measure the degree of absorption oE gamma rays from a radioactive
source are the most popular because of ease of application.  The
meter can be strapped to a pipe without insertion into the pipe
  line.  The only problem with  these
  inaccuracy and  inconsistency.  At  several  facilities,  density
 measurements are often verified by
 laboratory analysis of grab  samples).
 3.3  TESTING AND MONITORING
      This section describes manual
 sions monitoring  (GEM) methods used
 data.
 3.3.1  Manual Testing
                                   meters has been their periodic
                                   manual measurements  (e.g.,
                                   testing and continuous emis-
                                    to collect FGD gas stream
      Manual sampling and analysis of the flue gas at the inlet
 and outlet of the FGD system are required periodically to evalu-
                                    I
 ate its performance.  Sampling ports must be incorporated during
 the design and construction of the FGD system to facilitate
 several sampling procedures which require a variety of probes and
 collection equipment.  Sampling operations for FGD systems are
 aimed primarily at characterizing the gas flow, particulate mass
 loading and size distribution, and
                                   gas  composition.   The gas flow
 at the sampling points must be stable to ensure collection of a
SECTION 3 - PERFORMANCE MONITORING
                                 107

-------
representative  sample and obtain accurate  information regarding
flow rate.  Bends and expansion and contraction  zones in the  flow
path can  induce secondary flow's such  as vortices,  rotation, and
large eddies.   Sufficiently  long runs of a straight uniform duct
are recommended at  the  sampling location before  and after  the
sampling  point.  Another factor;is the ease in the operation  of
the sampling  equipment.  Proper •• orientation of the sampling port
and availability of a clear  platform  area  near the port are other
necessary criteria  for  testing.
     Most interfaces for sampling  from ducts are designed  to  be
compatible with 3-inch  Schedule 40 pipe  nipples  used  as sampling
ports.  Occasionally, an experimental system has required  a  4- or
6-inch  opening. The size of the port necessary  to insert  a  probe
also depends  on the length  of the  port opening.   Other  considera-
tions  include availability  of diametrically opposite  ports so
                                                      9
that opacity  monitors may be installed,  if necessary.
     Table 3.3-1 presents  a list  of  gas  stream characteristics
and measurement methods for lime/limestone FGD systems.  Of
particular interest to  FGD  technology is the SO2 manual sampling
method.  EPA Method 6  is  the reference method for determining
emissions of  SO2 from all  stationary sources except sulfuric acid
plants.  In sampling for SO2, a gas sample is taken at a single
 sampling point located at the center of  the stack or no closer to
 the wall than 3.28 feet.   The sample must be extracted at a
 constant volumetric rate.   This requires adjustments of the
 extraction rate to compensate for any changes in  stack gas veloc-
 ity.   As the gas goes through the sampling apparatus, the sulfuric
 acid (H2S04)  mist and sulfur trioxide (SO3) are respectively
 removed using glass wool (borosilicate or quartz) and a solution
 of isopropanol; the SO2 is then removed by a chemical reaction
 with a hydrogen peroxide solution.   The sample gas volume is
 measured by a  dry gas meter.  Upon completion of  the run, the
 H2S04 mist and SO3 are discarded, and the  collected material
 containing the  S07 is recovered for  laboratory analysis.  The
SECTION 3 - PERFORMANCE MONITORING
                                 108

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concentration of SO2 in the sample is determined by a titration
method.
     For determination of the total mass emission rate of SC>2,
the moisture content and the volumetric flow rate of the exhaust
gas stream must be measured.  The minimum sampling time is 20
minutes per sample, and two separate samples constitute a run.
Three runs are required, resulting in six separate samples.  An
interval of 30 minutes is required between each sample.  Longer
sampling times may be required if a larger sample is needed.
     SO  concentrations of  50 to 10,000 parts per million  (ppm)
can be determined with this method.  Collaborative tests have
shown that an experienced test team using quality controls can
conduct a source test for SO2 within an accuracy range of  ±4
percent.
     Other sampling methods are Available which utilize different
chemical solutions, such as a  sodium hydroxide solution, to trap
the S00.  EPA Method  8 may  also be used as an alternative  method
                          Some  states specify a sampling method
                           and  SO2.   The analysis then gives total
     '2'
for stationary sources.
that collects H2SO4/ SO3,
sox.
3.3.2  Alternative Methods      :
     There is an alternative manual method to EPA Method 6.  This
is the proposed Method 6B.  In this method, intermittent samples
are drawn through a modified Method 6 sample train using a 24-
hour timer.  This method measures CO2 in addition to SO2.  The
samples collected in the train are recovered and analyzed on a
daily basis.  Collaborative testing to demonstrate this method is
now underway.  The high capital intensity of a conventional CEM
program could be replaced with a low cost but equally  O&M-inten-
sive Method  6B testing program.  Method  6B could also  be used as
a back-up to generate data during CEM outages, thus eliminating
the need for expensive parts inventory and highly trained techni-
cians.
  SECTION 3 - PERFORMANCE MONITORING
                                 110

-------
  3-3.3   Continuous  Emissions  Monitoring (CEM)
      There  are many  instruments  Available for monitoring gaseous
  emissions from stationary  sourceL   Gas monitoring systems  may be
  either  extractive, in-situ,  or rimote. The monitors utilize vari-
  ous physical or chemical properties  to detect and  quantify  compo-
  nents in the flue gas, as  shown  in Table  3.3-2.  The methods used
  may be  in-situ (the measurements are conducted on  the  flue  gas
  inside  the  stack) or extractive  (a sample  is  withdrawn  from the
  stack).  The basic problem commori to all CEM  systems is  that any
  sophisticated analytical technique will suffer when  exposed to a
 hostile flue gas environment  (e.g., heat,  humidity,  corrosive
 gases,  and fly ash).   The challenge in designing,  installing,  and
 operating a CEM system, therefore1, is to minimize  the harsh
 effects of the stack environment,
maximize the precision and
 accuracy of the effluent pollutant measurements, and accomplish
 both at a reasonable cost.   To mojnitor SO2, the CEM system must
 determine the concentration of the pollutant and also the
 concentration of a diluent  gas (OJ  or CO ) .
      Every CEM system can be divijded into three components, as
 shown 'in Table 3.3-3.   The  immediate drawback to the in-situ
 system  is the very fact that the  analyzer is mounted on the
 stack.   The optical alignment of  the light  source and the retro-
 reflector is critical.   This can  te a problem on composite stacks
 with  fiberglass  or stainless steel liners because these liners
 have  the  ability to flex.   A slotted pipe can be added across  the
 stack to  insure  the absolute alignment of the optical  components.
 Further,  in  in-situ systems,  the  optical  components  on either
 side of the  stack  are exposed to  ithe  corrosive stack gas.   An  air
 purging system is  provided  to keejl  the components clean but peri-
 odic maintenance will still  be required.
     Extractive CEM systems  depend  on  the reliable operation of
 the sample interface.  Many potential  problems exist in an
extractive sample  interface.  The probe is constantly  subjected
to a corrosive and erosive atmosphere.  Carryover of slurry from

 SECTION 3 - PERFORMANCE MONITORING

-------
        TABLE 3.3-2.  PRINCIPLES USED IN GASEOUS EMISSION MONITORS'
            Extractive systems

         Absorption spectroscopy
         Nondispersive infrared
         Differential absorption

         Luminescence methods
           Chemiluminescence  (NOX)
           Fluorescence (S02)
           Flame  photometry

         Electroanalytical methods
           Polarography
           Electrocatalysis  (OJ
           Amperometric analysts
           Conductivity
           Paramagnetism  (02)
    In-situ systems

Cross-stack
  Differential  absorption
  Gas-filter correlation

In-stack
  Second-derivative
   spectroscopy
  Electrocatalysis (02)
Methods followed by the gas (in parentheses) indicate that the technique is
 currently commercially applied only to that gas.
                                     112

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  the  FGD  process  can  be  a serious  problem.   Slurry  which deposits
  on the probe  will  scrub S02  out of  the  sampled gas.   The buildup
  of particulate and slurry solids  will plug the probe.   Shielding
  the  coarse  filter  with  a baffle will reduce the problem.  A
  periodic blowback  to purge the  probe  (air  or steam)  is  also
  common.
       The sample  pump is another point in the system that has
  potential problems because it is  subjected,to constant  wear.
  Preventive  maintenance  programs are necessary to keep the pumps
  operable.  The sample line and  probe must  be heated to  prevent
  condensation  prior to the moisture  removal system.  The large
  number of fittings needed to connect all of these  components
  contribute  to leaks  in  the extractive interface.  As a  result,
  this type of  system  will,require  constant  attention although this
  maintenance does not require special training.
       A comparison  of in-situ and  extractive systems reveals that
  neither  system is  superior overall. However, most stack moni-
  toring systems are extractive rather than  in-situ.  A single
  extractive  analyzer  can monitor one component in the gas stream
  at more  than  one source, 'whereas  a  single  in-situ  analyzer can
  monitor  more  than  one component but only at a single source.
  High levels (90  percent or greater) of  reliability have been
  reported for  at  least one of every  type of CEM system in use.
  The  extent  of trouble-free operation generally appears  to be
  directly proportional to the level  of management commitment to
  the  ongoing maintenance of the CEM  system.
  3.3.4 Performance Specification  Tests
       Continuous  monitoring instruments  must pass the Performance
  Specification Test requirements given  in Part 60,  Appendix B of
  the  Code of Federal  Regulations (CFR).   These tests evaluate the
  performance characteristics  of opacity, SO0, NO and O9 or C07
                                   I         
-------
      0    Performance  Specification Test 2 -  S09/NO  Systems
                                                &   J\.
      0    Performance  Specif icatiojn Test 3 -  O2 or CO2 Monitors

      A detailed  description of  thepe tests is presented in the
 "Continuous Air  Pollution  Source  Monitoring Systems Handbook"
 (EPA  625/6-79-005). 7
3.4  RECORDKEEPING PRACTICES AND  P
ROCEDURES
     The primary reasons  for FGD  rscordkeeping  are  cost  and  envi-
ronmental compliance accountability.  The  types of  records kept
may be in the form of strip charts, numerical data  printouts,
manual log books, or work order shket files.  The collection fre-
quency depends upon the data.  Maintenance records  may be updated
daily via log books or whenever wo::k order sheets are filed  upon
completion of a given task.  Most utilities collect SO0, NO  ,
                                   I                   ^    X
particulate, opacity, and O2 continually,  using continuous emis-
sion monitors in the form of strip
 charts or computer disk or
tape files.
                                   I
     The development of a GEM system extends' beyond the choice of
a set of analyzers.  The analyzers must measure emissions within
specified time periods.  The measurements, however, must then be
recorded in some manner.  After the data are recorded/ they must
be converted into units of the emissions standard,  (lbs/106 Btu).
Calculated emission values that are in excess of the standard
must then be reported on a quarterly basis to the EPA Adminis-
trator.  In addition, the guidelines stipulated in the Federal
Register (40 CFR, Part 60.7, Appendix B) require the reporting of
the following:
     0    Time and magnitude of excess emissions
          Nature and/or cause of ekcess emissions
          Corrective and/or preventative action taken to prevent
          their recurrence
          Zero/span calibration values
SECTION 3 - PERFORMANCE MONITORING
                                 115

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     0    Normal measurement data
                                 . i
     0    Log of inoperative periods
     0    Repair and maintenance logs
     0    Performance, test, calibration data
     For sources, subject to the June 1979 NSPS, calculated emis-
sions reports are required as 24-hour averages whether in excess
of the standard or not.  A complete emissions monitoring system,
therefore, requires some means of recording the analyzer data.
Strip-chart recorders have been used most often, but data loggers
and computer systems are beginning to become popular.  Data
processors have been developed specifically to reduce the time
necessary to evaluate and report excess emissions.
     A data reporting system may encompass anything from the
manual reduction of raw strip chart data and compilation of
associated data to the near fully automatic preparation of com-
plete excess emission reports, including most of the aforemen-
tioned data requirements.  The choice of the data reduction and
reporting system may be the most important factor in the overall
emission monitoring system, because it greatly affects the amount
of manual effort involved in meeting the NSPS requirements".
     The data generated by the monitoring instruments give much
more information than is actually required.  The actual data that
can be used to satisfy measuring requirements may be of three
types:
     0    Instantaneous values taken at the end of each time
          period
     0    Values obtained by integrating data over each time
          period
     0    Values obtained by averaging a number of data points
          over each time period
     The method used will often be determined by the type of
analyzers purchased and by the recording method employed.  The
 SECTION 3 - PERFORMANCE MONITORING
                                 116

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measuring requirements are tied  in with the recording require-
ments.  A consideration of both  will dictate the choice of  the
complete monitoring system.
     A monitor may produce a continuous trace on a  strip  chart
for a 6-minute or 1-hour period;
a larger amount of data may be
The regulation, however, speci-
obtained than is actually used.
fies only the minimum number of points that need to be averaged
and recorded.  It is often easier.to design systems that  inte-
grate the continuous data over the averaging periods.
     There are a variety of methods used to record data from
analytical devices.  The strip-chart recorder is encountered most
frequently in continuous source monitoring applications.  A
continuous analog record is obtained by using some type of chart
recorder.
     Because the recorder is a pe
system, the response time, drift,
rt of the continuous monitoring
 and accuracy requirements
established in the EPA performance specifications must be con-
sidered when choosing the recorde
chosen that has poor response tin
accuracy, the overall monitoring
many factors that contribute to the relative inaccuracy  (relative
to the EPA reference method) of c
ing system does not need to be ore of these factors if a proper
choice of the system is made initially.
     The analog chart recorders give a continuous record of the
r itself.  If a recorder is
e and limitations in recording
system will suffer.  There are
 monitoring system.  The record-
signal produced by an analyzer.
logger, however, selects some value  (either an instantaneous or
integrated value) after a given time period and records it.  For
this reason, a digital system may be characterized as recording
The digital recorder or data
data over intermittent periods.
tenth or hundredth of a second or less; but for such a short
period, the printed data produced
These periods may be short, a
 might be unmanageable.
     It should be noted that a data logger is not a computer or
microprocessor.  A computer can process data, convert it into
SECTION 3 - PERFORMANCE MONITORING
                                 117

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emission rates, and record it in specified formats.  Data loggers
merely record data at specified intervals.  There are two options
available on digital recorders that;extend their utility.  These
are an alarm-monitoring capability and the ability to print out
by exception.  A data logger, therefore, could be set to send off
an alarm or print out data once a specified value is reached.  It
could not, however, compute the emission rate by any specific
method and print it.  A microprocessor or computing system would
be necessary in this case.
     The difficulty of detecting trends has been overcome in some
systems by recording the digital data on floppy disk or cassette
tape.  The disk or tape can be read on a computer and the data
then can be graphed automatically with a plotter.  This method
provides a convenient means of storing the continuous monitoring
record.  Diskettes and cassette tapes are easily handled and
cataloged and detailed graphs need only be reproduced when de-
sired.
     The most convenient method of handling continuous monitoring
data is with a data processor.  Several firms involved in the
manufacture of stack monitors have seen the need for instrumen-
tation that will rapidly average and compute data in terms of the
emission standard.  There are two data processing methods that
generally are used in continuous monitoring systems:
     0    Analog-to-digital  (A/D) large general purpose computer
          or data processing system.
     0    Dedicated continuous monitor data acquisition system.
     The dedicated systems may save time and money in the long
run.  Many source operators will first purchase the gas analyzers
and rely on strip-chart output for the data-recording require-
ments.  If the monitoring system is working properly and the data
are reliable, consideration is given to a data processor in order
to reduce the amount of time spent analyzing what can amount to
volumes of data.  Many operators have found it convenient to keep
SECTION 3 - PERFORMANCE MONITORING
                                 118

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 the chart recorders to provide  an  easily  interpreted record of
 the trends occurring during  the so,urce  operation.   Cross  checks
 then can be made between the two systems;  if  either malfunctions,
                          ',•7
 the data may not be lost.
      The problem of monitoring  equipment  malfunctions is  a  matter
 of serious concern to the continuous monitoring program.  Obvious-
 ly, an improperly operating  continuous  monitor serves neither  the
 source operator nor the control agency.   In order  to keep aware
 of the instrumental problems that
 of instrument downtime, repair, or
 must be documented and explained i
inevitably develop, occasions
 significant readjustment also
i the quarterly report to EPA.
 Many agencies are now developing inspection programs  for  these
 systems in an effort to ensure thab reliable emissions data  can
 be obtained.               -  •       .   ,
      The operator, utility also musb maintain a  file of all of the
 continuous monitoring data, including records of the  Performance
 Specification Test, adjustments, repairs, and calibration checks.
 The file must be retained for at least 2 years  and is required to
 be maintained in such a condition  that it can be easily inspected
 by an agency field inspector.
SECTION 3 - PERFORMANCE MONITORING
                                  119

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                             SECTION 4
                 INSPECTION METHODS AND PROCEDURES
     This section presents detailed procedures and guidelines for
the inspection of lime/limestone;slurry FGD systems.  The objec-
tive of this section is to assist the agency inspector in his/her
duties of examining the FGD system, looking first for telltale
signs that might suggest misrepresentations of emissions such as
faulty monitors or leakage in or,out of ducts, and looking sec-
ondly for factors in addition to!SO2 removal efficiency that
suggest poor reliability of the FGD system.  If excess emissions
are reported, this section guides the inspector in collecting
information for the determination of causes of the problem and
the assessment of remedial action(s) taken by the utility.  When
no excess emissions are reported, procedures suggested herein
allow the inspector to assess the preventive actions taken by the
utility.  It is important that the inspector make specific obser-
vations and record pertinent data in order to make intelligent
decisions for resolving compliance problems or processing var-
iance requests.
     The information in this section is presented in a practical
fashion that facilitates comprehension by regional/state agency
personnel; theoretical principles underlying the inspection
procedures are not discussed.  The inspection procedures are
presented in a user-friendly format.
     The section begins with a brief discussion on inspection
procedures for the overall plant and is followed with detailed
inspection procedures addressed by equipment area and equipment
items in the order presented previously in Section 2.4.2  (Exist-
ing Design Configurations).  Inspection procedures for each
 SECTION 4-INSPECTION METHODS AND PROCEDURES                         "

                             ,   120

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 equipment item are comprised of
 illustration (where applicable)
 an  inspection  checklist,  an
 showing  the  relative  sizes  of  the
 associated components, and brief supporting text.  Performance
 parameters addressed in the equipment inspection checklists are
 classified under three categories (observation, process, and
 operation and maintenance) to facilitate the interpretation and
 evaluation of data obtained during inspections.  The various
 checklists presented in this sedtion are compiled together in
 Appendix C to assist the inspector during an inspection.
      The interpretation of the performance data observed and
 collected by the inspector is dd
scussed in the following section
 (Section 5,  Performance Evaluation and Problem Diagnosis/Correc-
 tion) .   The  checklists in this section include references to
 appropriate  locations in Section 5 which address the significance
 of  the  recommended inspection procedures.   Section 6 (Model O&M
 Plan) elaborates  on the O&M practices surveyed by the inspector
during  the  inspection  procedures
prudent safety procedures  to be
   Section 7 (Safety) outlines
followed during the inspection..
4.1  GUIDELINES FOR OVERALL PLAN!  INSPECTION
     Before actually performing kn PGD  system  inspection,  it is
advisable to collect general plakt data such as  information  on
coal characteristics, boiler datja, and  system  generation status
(see Sections 2.2, 2.5.1.1 and 2
this type of information include
Steam Electric Plant Factors11.
.5.1.2).   Published sources of
 the  Utility FGD Survey10 and the
 Nonpublished but available
sources include the Energy .Information Administration  (EIA)
General Utility Reference File  (GURF) data base and the utility
filed EIA Form 767  (formerly the
Federal  Power  Commission  [FPC]
Form 67).  Table 4.1-1 shows a checklist containing types of
information that should be obtained prior to the FGD system
inspection.
 SECTION 4-INSPECTION METHODS AND PROCEDURES
                               121

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                     TABLE 4.1-1  GENERAL PLANT DATA
Boiler Data
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
                                                  peak)
Type of firing (pulverized, cyclone)
Boiler service load (base, intermediate, cycling,
Date of commercial operation (month, year)
S09 emission limitation (lb/10  Btu)  g
Particulate emission limitation (lb/10  Btu)
Opacity limitations (%)
Fuel firing rate at maximum continuous rating (tons/hr)
Heat rate (Btu/net kWh)
Average capacity factor (%)
Gross generating capacity (MW)
Outlet flue gas flow (acfm)  !
Outlet flue gas temperature (°F)
Fuel Data
          Average heat content (Btu/lb)
          Average ash content (%)'
          Average moisture content (%)
          Average sulfur content (%)
          Average chlorine content (%)
General FGD System Data
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
     o
FGD process type (lime, limestone)
Generation type (first, second, or third)
Application (new/retrofit)
Initial startup date        ;
Commercial startup date
Total system design S0? removal efficiency
Percent flue gas bypassing FGD system (%)
Total system energy consumption (kWh)
Annual reagent consumption (tons/year)
Water loop type (open, closed)
Waste disposal type (landfill, pond)
Solid waste generation rate (dry) (tons/h)
Total system makeup water consumption (gpm)
Number of operators per shift
Number of maintenance personnel per shift
Maintenance philosophy (dedicated, rotated, pooled)
                                     122

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      In addition to general plant  data,  the  plant layout and
accessibility should also be  reviewed  as this  governs  the ap-
proach and entry to the equipment  (see Section 2.5.2).   The
inspector  should also review  the
the facility  (see  Section  3.4).
inquire about the  current  status
recordkeeping procedures used by
Finally, the inspector should
of operation of the FGD system
and recent  status preceding  the vjisit.
 4.2   INSPECTION PROCEDURES
      This  section presents detailed  inspection  procedures  for the
 different  equipment areas.  The  inspection  procedures  are  ordered
 sequentially by the FGD  system equipment  subsystems  in order of
 their appearance in Section 2.4.2.   In  the  field,  the  actual
inspection will most probably be
undertaken more according to
convenience rather than process  logic.   The  office  location of
the inspector's primary utility  contact  and  the  layout of the FGD
system usually dictate the most  convenient starting point for the
inspection.   Separate checklists
area  in light of this consideration.
     An  inspection of the  control
are outlined for each equipment
 room at the facility should,
however, be undertaken prior  to  tjhe  inspection  of  the  equipment.
The inspector  should also note tnat  not  all  plant  control  rooms
are centralized;  some plants  have  decentralized control  rooms
associated with specific operations  (boiler,  FGD,  waste  disposal,
etc.).  The inspector should  inquire about this.   A control room
usually includes  a process  schematic above the  main control panel
with warning or other indicator  lights as well  as  parameter read-
outs to .display general operating!  status and/or problems occur-
ring in specific  areas of the system.  The "live"  schematic is
supported by strip charts and meters fed by  sampling devices
either throughout the FGD sys'tem
areas.  Much of the process-relat
equipment checklists presented later in  this section can -usually
or through the more critical
ed information pertaining to thes
                                 I
SECTION 4 -INSPECTION METHODS AND PROCEDURES
                                123

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be obtained in  the control room(s).   Table 4.2-1  presents a
checklist to be follov.Ted when  inspecting the control room.

                    TABLE 4.2-1.   CONTROL ROOM CHECKLIST

     0   Ask the  operator to point  out the monitoring device  displays spe-
         cific to the FGD system.
     0   Note any monitoring device displays that are not in  operation.
     0   Ask the  operator or other  utility contact the reason the display
         device is out of service and;what action has been taken for correc-
         tion.
     0   Check for high/low readings  on S02, particulate, and opacity
         monitoring devices (as compared to the design values).
     0   If the facility has an integrated computerized control (ICC) system
         equipped with CRT displays,  ask to see sample readings for some
         subsystems.  Feel free to  ask for explanations interpreting the
         figures  and numbers displayed.

4.2.1  Gas Handling and Treatment
4.2.1.1   Fans.  Fans used in  FGD systems vary in size depending
on the number of fans used and their service classifications,
e.g., unit or booster (see Section 2.4.2.1).  Fans are generally
high-maintenance equipment items.   Figure 4.2-1  shows an iso-
metric view of  a typical centrifugal fan.  Table  4.2-2 presents  a
checklist for the  actual fan inspection.
4.2.1.2-   Scrubbers/Absorbers.   !The discussion in this section
focuses on absorbers because these are the most  popular in second
and third generation systems.  The SO? absorber  ranks third on
the list of equipment areas most likely to be the focus of a
forced system outage  (see Section 2.5.1).  Many  of the third
generation FGD  systems include spare absorber modules to minimize
the impact of a single module  forced outage.  Absorbers are con-
sidered to be very critical to FGD operation and  perhaps repre-
sent the most important area of  interest to field inspectors.
SECTION 4 - INSPECTION METHODS AND PROCEDURES
                                  124

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                    FAN INLET
                                          DOUBLE-WIDTH
                                              ROTOR
10 ft
                                                     MOTOR
                                                     FAN DISCHARGE
                                      BACKWARD  CURVED
                                          BLADES
   Figure 4.2-1.  Isometric \
lew of a typical  centrifugal  .sr:.
                           125

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                           TABLE 4.2-2.   FAN CHECKLIST
OBSERVATION
PROCESS
          Listen for excessive vibration.   If the fan is not operating or if
          it is not obvious whether the vibration is excessive or not,
          consult with the utility contact.  Ask if vibration/noise is moni-
          tored.  If so, what are. the correct readings?  Is there an alarm
          cutoff?

          Look for signs of unusually high levels of maintenance (e.g., worn
          rotors on site, debris on and around housing, unusually worn access
          doors).                    :

          Check for signs of corrosioh and note location.  Look for holes at
          intake/discharge and analyze duty (ID/FD) contribution.
          Note fan function, design application service, and location
          (refer to Section 2.4.2.1).!

               Unit/booster
               Centrifugal/axial
               ID/FD                 !
               Wet/dry               '

          What is the design/actual APa provided by each fan?  (See Section
          5.2.2.2 for significance.)

          What is the design/actual gas flow rate and temperature through
          each fan?  (See Section 5.2.2,1 for significance.)

          What is the design/actual energy consumption rate of each fan?
          (See Section 5.2.2.9 for significance.)
OPERATION AND MAINTENANCE
           Inquire about the incidence of bearing failure, fan blade erosion/
           corrosion, and rotor cracking.  What were the contributing causes
           of these problems?  What remedial actions were taken or planned?

           Inquire about routine maintenance procedures (balancing, cleaning,
           rotor/fan repair).  What is the frequency of inspection?
 aAP  refers to  pressure drop, typically measured in inches h^O for gas-side
  operation.
                                     126

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     The dimensions of absorbers vary widely depending on  the
type of absorber, the boiler gas flow, the number of  absorbers
included in the system design, the process type  (e.g., lime or
limestone), and the coal characteristics.  A utility  may choose
to install three 50 percent capacity absorbers  (including  one
spare), five 25 percent capacity absorbers  (including one  spare),
or as many as 12 absorbers  (including one spare) for  a given
facility.  Spray towers need to
towers for similar applications
be larger in height than packed
because spray towers require a
higher residence time for a given volume of flue gas to make up
for the lack of liquid/gas contacting area provided by packing
materials.  Lime systems should
for a given facility as compared
because lime is a more reactive
ratio and a lower residence time
typical absorber designed to accommodate 100 MW of boiler flue
have slightly smaller absorbers
 to those for a limestone process
reagent requiring a lower L/G
 of the gas in the tower.  A
gas capacity may be between 2 tc
 4 stories in height.  The
absorber may be rectangular or cylindrical in shape.  A
horizontal configuration  (see Figure 2.4-4b) may be adopted
instead of the more common vertical configuration  (see Figure
2.4-4a).
     Figure 4.2-2 shows the dime
absorber.  Because typical abso]
stories high, the inspector may
nsions of a typical tray tower
bers are likely to be several
not be able to collect all the
data for the absorber at one tiire.  It is often easier to inspect
all components found at each level of the tower before moving to
the next level.  Table 4.2-3 provides an inspection checklist for
absorbers.
4.2.1.3   Mist Eliminators.  Mist eliminators are the most trou-
blesome of all FGD system components  (see Section 2.5.1, Table
2.5-3).  They are prone to scaling, plugging, breakage, and
deformation from high temperature excursions.  Figure 4.2-3 is an
illustration of a typical mist eliminator section.  The sections
are replaceable so that only those sections that are permanently
SECTION 4-INSPECTION METHODS AND PROCEDURES
                                127

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   MIST ELIMINATOR
 TRAY MIST
PRECOLLECTOR
  INTERNAL SPRAY
HEADER AND NOZZLES
INLET GAS FLOW
                                                          OUTLET
                                                         GAS  FLOW
                                                                   40 ft
                                                       EXTERNAL
                                                     SPRAY HEADER
                                                     SIEVE
                                                     TRAYS
          SUMP
              J
      DRAIN TO REACTION TANK
                            20 ft
              Figure 4.2-2.  Typical tray tower absorber.
                                 128

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                 TABLE 4.2-3.  SCRUBBER/ABSORBER CHECKLIST
OBSERVATION
PROCESS
          Observe any tools, debris, of other materials that may suggest
          excessive maintenance problems:  scaling, plugging in spray nozzles
          and headers — look around for broken or eroded spray nozzles.
          (See Section 5.2.4.3 for significance).

          Look for signs of materials failure (e.g., corrosion, liner
          bubbling or peeling).  Note the location of the failure.

          Observe any signs of leaky piping due to erosion (e.g., corrosion,
          accumulation of liquid or scale around process piping).

          Look for signs of absorber sjlurry leakage due to erosion/corrosion
          (e.g., discoloration on the absorber outside walls).
          What are the design/actual absorber inlet particulate grain loading
          and S02 concentrations?  (See Section 5.3.1.1 for significance.)

          What are the design/actual absorber outlet particulate and S09
          emission levels?  (See Section 5.3.1.1 for significance.)    '*•

          What is the AP across the absorber?  (See Section 5.2.2.2 for
          significance.)  Note if AP is low or high (if not sure of the
          acceptable AP range, ask the

          What is the pH and slurry so'
          tank?  (See Sections 5.2.2.3
          if these values are high/low

          Inquire about the slurry and
operator or other utility contact).

ids content in the absorber reaction
and 5.2.2.5 for significance.)  Check
gas flow rates to determine the L/G
          ratio.  (See Sections 2.3.2.2 and 5.2.2.4 for significance.)

OPERATION AND MAINTENANCE
          Ask if absorbers have,been e:
periencing chronic problems of any
          kind.  If so, what remedial  actions were taken or planned?  Inspect;
          internals of any absorbers which may be shut down by looking
          through the access door with
          Are any instrumentation prob
          flow, gas flow)?
a flashlight.
          If absorbers are idle, ask wh|y (i.e.,  spare,  demand,  scheduled
          outage, forced outage).
ems evident (pH, AP, % solids, slurry
          Inquire about routine maintenance procedures.   Check  on  the
          frequency of plant inspection).
                                    129

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          CHEVRON VANES
                                                WASHER LANCE
                        BULK ENTRAPMENT SEPARATOR
Figure 4.2-3.  Typical mist eliminator section
        (baffle-type,  continuous vane).
                      130

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 damaged need  to be  changed  rather  than the  entire mist eliminator
                                  a  of  approximately 400 sq.  ft.
portion which could cover an are,
The mist eliminator is typically
                                   accessed through access doors
usually on the third or fourth level of the absorber.
4.2-4 presents a checklist for mist eliminators.
                                                         Table
4.2.1.4   Reheaters .
Indirect h
        ibl
                                  ot  ai
                                   air reheaters which operate on
 ambient  air  are  seldom responsible  for system shutdowns.   In-line
 reheaters, however,  are troublesome equipment items.   Although
 they  require less  energy to  elevate the flue gas  temperature
 above dew point  (typically  125°F) ,  they are subject to the haz-
 ards  associated  with the scrubbed gas  environment.   In-line
 reheaters are subject to corrosion  from acid attack and solids
 accumulation resulting from  carryover  from inefficient mist
 eliminators  and/or process chemistry problems.  The impact this
 has  on  the  reheater  is  a  loss  of
 materials  failure  (e.g.,  steam tube failure).   The impact on the
 FGD  system may be  an  increase  in
  reheat,  increased  energy  consumption,  or possibly, a complete unit
  shutdown.   Reheaters  are  usually
                                 heat exchange capacity and
                                 AP, a loss of effective flue gas
                                 located above the mist eliminator
  section  at  the  top  of  the  absorber or in the exit duct just
  downstream  of the absorber.   In-line reheat systems are located
  in  the ductwork at  or  near the  top of the absorber (see Figure
  2.4-8a), whereas indirect  hot air reheat systems are located
  anywhere along  the  exit duct downstream of the absorber (see
  Figure 2.4-8b).  Table 4.2-5 presents an inspection checklist for
  reheaters.
  4.2.1.5   Ductwork  and Dampers.   Ductwork and 'dampers also account
  for a large proportion of  FGD system outage hours (see Section
  2.5.1, Table 2.5-3).   The  duct  areas of greatest concern are at
  the scrubber/absorber  inlet .where the hot dry flue gas first
  encounters  the  slurry  sprays.   This area, called the wet/dry
  interface,  is typically found near the bottom of the absorber
  just above  the  reaction tank.   During the inspection, it would
  probably appear on  the second story of the FGD system.  The other
SECTION 4 -INSPECTION METHODS AND PROCEDURES
                                 131

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                      TABLE  4.2-4.   MIST  ELIMINATOR  CHECKLIST
 OBSERVATION
PROCESS
          Observe  any  discarded mist eliminator sections that may be nearby.
          Inspect  for  excessive plugging/scaling on vanes, breakage due to
          structural stress,  or deformation due to high temperature
          excursions.   (See Section 5.2.4.3 for significance.)

          If absorber  is shut down, inspect mist eliminator sections for
          signs of plugging/scaling, breakage, deformation, and erosion/cor-
          rosion.

          If possible,  inspect downstream equipment for signs of excessive
          mist eliminator carryover in the form of condensation packets and
          solids deposits;
          What is the design/actual AP?  (See Section 5.2.2.2 for signifi-
          cance.)  Note if it is low or high (if not sure of the acceptable
          AP range, ask operator or refer to Table 5.2-3).

          Ask if the absorber pH is operated above or below the design range.
          (See Section 5.2.2.3 for significance.)

          Inquire about the flue gas velocity.  (See Section 5.2.2.1 for
          significance.)  How does this compare with the design rate?
OPERATION.AND MAINTENANCE
          Ask about mist eliminator automatic and manual  washing techniques
          and practices.

          Check on wash water source (see Section 5.2.2.8 for significance.)
          Is it fresh makeup, process recycled water, or  a blend?  Does  the
          plant water loop type (i.e., open or closed) have any impact on
          washing practices?

          If problems have occurred, inquire about remedial  actions taken  or
          planned.

          Inquire about routine maintenance procedures.   How often  are the
          mist eliminators inspected?
                                     132

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                        TABLE 4.2-5.  REHEATER CHECKLIST
OBSERVATION
PROCESS
          If  FGD system  is shut dovn,  inspect indirect reheater mixing
          chamber and/or in-line tubes for excessive scaling/plugging.  Also
          check for  signs of corrosion and note location.

          If reheater is operational, inspect external  ductwork appearance
          upstream and downstream o|f reheater for signs of corrosion.

          Look for discarded or replacement tubes nearby (primarily for
          in-line reheater applications).  Ask why the  tubes were replaced.
          For in-line steam tube designs, note gas-side AP.  A high AP could
          indicate plugged reheater tubes.

          What is the energy consumption of the reheater?  (See Section
          5.2.2.9 for significance.!)

          What is the design/actual AT across the reheater?  Is the outlet
          temperature above the acijd dewpoint temperature to avoid corrosive
          attack?
OPERATION AND MAINTENANCE
          For in-line reheaters, inquire about- incidence of tube failure.
          What types of tubes are used (plate, shell-and-tube, finned tubes)?
          What are they made of?  Are they made of the same material  as the
          baffles to avoid galvanic corrosion?

          For in-line steam tube reheaters, ask about plugging problems.
          If problems have occurrec
          planned.
,  inquire about remedial  actions  taken  or
          Ask about reheater cleaning techniques and frequency (e.g., soot
          blowers).

          Inquire about routine maintenance procedures.   How often are the
          reheaters inspected?           .	^^
                                    133

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duct areas of importance are the absorber outlet ductwork leading
to the stack, particularly where the reheat gas encounters the
wet scrubbed flue gas.  Any wet gas ductwork requires special
attention.  All dampers need to be inspected, particularly the
isolation dampers before and after ,the absorber sections.  Again,
only dampers seeing wet gas require special attention.  As shown
previously in Figure 2.4-9 of Section 2.4.2.5, dampers may appear
in many places throughout the gas circuit.  Expansion joints will
also be found throughout the gas circuit ductwork.  Expansion
joint failures can result in leakage into or out of the FGD
system (depending on whether the system is an induced or forced
draft design).  This, however, does not usually result in forced
unit shutdowns.  Table 4.2-6 provides an inspection checklist for
ductwork/dampers.
                                   i
4.2.2  Reagent Preparation and Feed
     The inspection of the reagent preparation and feed equipment
can be considered secondary to the gas handling circuit.  The po-
tential for reagent preparation and feed equipment failure re-
sulting in downtime of FGD systems is not as great as compared to
equipment comprising the gas-handling circuit.  If, for example,
a slaker or ball mill should fail, the FGD system could still
operate for several hours drawing fresh slurry from the reagent
preparation tank fed by the faulty :component.  There may be
enough time to repair and put the faulty component back on line
before the last batch supply is exhausted.
4.2.2.1   Reagent Conveyors and Storage.  Reagent conveyors and
storage facilities may be associated with chronic minor problems
but they are seldom responsible for FGD system shutdowns.  The
operation of this equipment, however, has an impact on the FGD
system as a whole and the attention it receives by the operating
and maintenance staff will be somewhat representative of the
utility's attitude toward the FGD system in general.  Table 4.2-7
is an inspection checklist for reagent conveyors.

SECTION 4-INSPECTION METHODS AND PROCEDURES   '.                ——~~~~~
                                134

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                     TABLE 4.2-6.   DUCTWORK/DAMPER CHECKLIST
OBSERVATION
 PROCESS
          Check for signs of corrosion.   Note severity (e.g., discoloration,
          pitting, penetration) and size of area affected.   Note the gas flow
          location of the ductwork/damper with respect to other equipment
                *        .._.*.      .1   •      i    i   \
          areas (e.g., mist eliminator,
reheater, absorber).
          Observe duct expansion joints.  (See Section 5.2.4.1 for
          significance.)  Are there obvious ruptures where flue gas is
          leaking out (forced draft systems) or is ambient air being drawn
          into the duct (induced draft sjystems)?
          Observe any "new" ductwork.
          for their replacement.
sk the plant personnel the reasons
          Check for bypass ducting and verify if it is part of the original
          design (refer to Table 2.4-3a}.  If there is a contradiction, ask
          plant personnel the reasons for the change.

          Check to see if the duct runs(are insulated on the outside to
          reduce the possibility of condensation/corrosion.

          Note ductwork shape (cylindrical versus rectangular) and
          configuration (straight runs |ersus elbows).  (Stagnant/dead air
          spaces and sharp bends are vulnerable to erosion and the collection
          of condensation products.  Rectangular ducts are more prone to
          non-uniform gas flow distribution, channeling and associated
          problems.)
          Ask what process conditions troublesome ducts and dampers are
          subject to.  What is the gas flow and temperature?  Is the gas
          saturated?

          What materials  (if any) are used for duct lining?
           Is  there  a  slurry carryover p
^oblem through the mist eliminators?
 (continued)
                                      135

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TABLE 4.2-6 (continued)
OPERATION AND MAINTENANCE
          Inquire about problems with ductwork.

          Inquire about problems with dampers.   Do the dampers function
          properly - do isolation dampers effectively isolate a module so
          that workers can enter the module while other modules are in
          service?  Are there problems due to fly ash or other solids
          accumulation which hinder the opening/closing of the damper?  Are
          dampers equipped with seal air to aid isolation/operation?

          Inquire about integrity and installation of duct materials.   Ask
          where problems have occurred and what actions are being  taken to
          rectify problems.

          Are  there problems due to fly ash or  other  solid.s accumulation
          which hinder the opening/closing of the damper?
          Inquire  about  routine  maintenance  procedures.
          ductwork/damper's  inspected?
How often are the
                                    13:6

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                    TABLE 4.2-7.   REAGENT CONVEYOR CHECKLIST
OBSERVATION

     0    Check for belt misalignment,  tears,  or frayed  edges.(if  belt  con-
          veyor is used).

     0    If pneumatic, check for leaks near elbows or bends  due to  erosion
          caused by the reagent.

     0    If bucket elevator is used, look for discarded chain  sections
          and/or buckets, welding equipment, and signs of "jury rigging"
          Look for areas where track/chain jamming may have occurred.

     0    Inquire about the duty of the conveyors (i.e., separate  for  reagent
          and coal, or shared).  If shared, has this ever caused any contam-
          ination problems?


OPERATION AND MAINTENANCE

     0    Inquire about problems experienced with the conveying device.

     0    Are there problems reported with respect to lime/limestone quality
          (e.g., debris shipped to tie site in the reagent) or freeze  ups
          during the winter months?

          If problems have occurred,
          planned.
inquire about remedial  actions  taken  or
          Inquire about routine maintenance procedures.
                                     137

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  4.2.2.2   Ball Mills.   Ball mills  (see  Figure  2.4-13)  are  gener-
  ally  located  at  ground  level  along the  perimeter  of  the  FGD
  system building  adjacent  to the  limestone  conveying  equipment.
  Their size depends upon 1) the size of  the FGD system, 2)  the
  number of ball mills, 3)  the  design limestone  quality, and 4) the
  coal  sulfur content.  Ball mills are problem areas for utilities;
  however, the potential  for failure  resulting in downtime in the
  FGD system is not as great as compared  to  other equipment  areas.
  Ball mills require a good deal of operator and maintenance crew
  attention and repairs can be expensive.  Table 4.2-8 shows an
  inspection checklist for ball mills.
  4.2.2.3   Slakers.  Slakers (see Figure 2.4-14), like ball mills,
 are found at ground level along the perimeter of the FGD system
 main building or in a separate building nearby.  The size of a
 given slaker depends upon 1)  the size of the FGD system,  2) the
 number of slakers, 3)  the lime quality,  and 4)  the coal sulfur
 content.   Slakers are areas of concern for utilities but they are
 usually not  critical to  the continuous operation of the FGD
 systems.   Table  4.2-9 shows a  slaker inspection checklist.
 4.2.2.4   Tanks.   Tanks  are seldom responsible  for unit outages.
 They are,  however,  significant sources of module downtime.
 Problems  encountered with  tanks  depend upon the tank service.
 Tanks  handling slurry  are  prone  to  abrasion,  corrosion, plugging,
 agitator  failure, and  liner failures.  Table  4.2-10  is  a  tank
 inspection checklist.
 4-2.3  Waste Solids Handling and  Disposal
     The waste solids handling and  disposal area is  somewhat less
 critical to the operation  of the  FGD system than the  reagent
 preparation and feed circuit.  When  problems occur they can often
 be rectified without the need  for a  forced  outage, or at  least
 temporarily "bandaged" until the next scheduled plant outage.
 4.2.3.1   Thickeners.  With respect  to operation, thickeners can
be regarded as mechanically-aided settling  tanks.  When properly
 SECTION 4-INSPECTION METHODS AND PROCEDURES                            ~~
                                138

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                   TABLE 4.2-8.   BALL
MILL CHECKLIST
OBSERVATION
PROCESS
          Look for any discarded balls;.  Inquire about the reason for their
          replacement.  (New ball charges are expected requirements because
          the action of milling "consumes" the balls and eventually requires
          replacement to maintain desired particle size.)
          Inquire about problems that have resulted due to the quality of the
          delivered reagent (refer to "Reagent Preparation" in Section
          5.3.1.2 for significance).  Poor grade reagent (e.g., problems with
          purity, hardness, or chemical composition) can reduce the design
          output of a ball mill.  Was I the ball mill properly sized for the
          facility?

          Inquire about the source/quality of water used in the ball mill.
          (Water having high  levels of dissolved chemicals may inhibit
          dissolution.)
 OPERATION AND MAINTENANCE
           Inquire  about  problems  that
           rapid  ball  loss,  poor quali
           failure).
           Ask about routine maintena
 have occurred (e.g.,  liner failure,
ty product, motor failure,  bearing
      0    If any problems  have occurred,  inquire  about  remedial  actions  taken
           or planned.
ce procedures on mills.
                                     139

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                        TABLE 4.2-9.  SLAKER  CHECKLIST
OBSERVATION

          Observe whether the slaker is^operational.  If not, inquire why.

          Is the slaking equipment properly sized for the facility?  What is
          the dry reagent feed rate?  How does this compare with the design
          level and the current demands of the FGD system?

          Inquire about problems that have resulted due to poor quality of
          the delivered reagent.  (Poor grade reagent [e.g., problems with
          purity or chemical composition] can reduce the design output of the
          slaker.)

     0    Inquire about the source/quality of water used in the slaker.
          (Water having high levels of dissolved chemicals may inhibit
          reagent dissolution.)


OPERATION AND MAINTENANCE

     0    Ask about problems associated with slaking equipment.

          If any problems have occurred, inquire about remedial  actions  taken
          or planned.

          Ask about routine  maintenance procedures  on  the  slakers.
                                     140

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                          TABLE 4.2-10.
 TANK CHECKLIST
OBSERVATION
          Are there signs of tank repairs (e.g., patches welded on outside)?
          Inquire why the repairs were made.
          Note tank configuration (cylir
          tangular tanks are more prone
drical versus rectangular).   Rec-
to corrosion due to stagnant areas.
          Rectangular tanks are also more prone to insufficient mixing  and
          short circuiting; check placement of internal  baffles to  aid  in
          mixing.

          Inquire or note if tanks are qpen or closed.   If open, has it ever
          resulted fn any problem?
          Look for signs of slurry leakc
ge due to erosion/corrosion.
          Check for floating debris in cpen tanks (e.g.,  absorber packing,
          liners).  Inquire about the origin of the foreign material.   Are
          the tanks equipped with strairers and have they ever become  plugged?
OPERATION AND MAINTENANCE
          Ask about liner and baffle failures.   Have any tanks had to be
          taken out of service and drained in order to make repairs?  What
          caused the failure?
          Inquire about problems associe
          agitators, pumps, instrumentation).

          If problems have occurred, inquire about the remedial  actions  taken
          or planned.

          Inquire about routine maintenance procedures.
ted with support equipment (e.g.,

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 operated and maintained, thickeners generally perform well.
 However, if thickener problems occur, complete unit shutdowns may
 occur because there is no way to bypass the thickener.  Thickener
 failures are primarily design-related (e.g., shaft failures,
 lining failures).  Figure 4.2-4 shows an isometric view of a
 typical thickener.   Table 4.2-11 is an inspection checklist for
 the thickeners.                 ;
 4.2.3.2   Vacuum Filters.  Vacuum filters (see Figure 2.4-16) are
 generally located at ground level in the main FGD system building
 adjacent to the  holding area for the filter cake material.
 Vacuum filters are not generally responsible for unit shutdown
 because spares are usually provided.  Table 4.2-12 provides an
 inspection checklist.
 4.2.3.3   Centrifuges.  Centrifuges (see Figure 2.4-17)  seldom
 cause unit outage because of their batch-type operation and
 because spares are generally provided.  An FGD system usually has
 enough tank surge capacity to continue to operate for several
 hours, during which time repairs could be made.  If more time was
 required (and no spares were available), the boiler load could be
 cut back to slow the rate of waste slurry accumulation in the
                                i
 holding tank.  Table 4.2-13 provides a centrifuge inspection
 checklist.
 4.2.3.4   Waste  Processing.  Except for the forced oxidation
 waste processing alternative, this equipment area has little
 impact on the FGD system itself;   The waste processing system
 can, however, have an impact on the FGD system when failures
 cause back-ups beyond the storage capacity of the waste slurry
 holding tanks.  Table 4.2-14 provides a waste processing system
 checklist.                      ;
 4.2.3.5   Waste  Disposal.  The inspector should be aware of the
 area of waste disposal; however,  it has little effect on the FGD
 system itself.  Examples of typical pond types used for handling
 waste from a lime/limestone slurry FGD system were shown

SECTION 4 - INSPECTION METHODS AND PROCEDURES                         ~~
                                142

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DIAMETER: 100 ft
HEIGHT: 12 ft
EFFLUENT
LAUNDER
WALKWAY
                      TORQUE AND->
                       RAKE ARMS V
                                                                FEED
              HIGH-PRESSURE
              BACK-FLUSHING
                WATER LINE
                                                          UNDERFLOW
        Figure 4.2-4,  Isometric 4iew of a typical thickener.
                                 143

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                       TABLE 4.2-11.  THICKENER CHECKLIST
OBSERVATION
PROCESS
          Are there signs of repairs to the tank portion of the thickener
          (e.g.-, patches welded on the outside)?  Inquire why the repairs
          were made.

          Look for signs of slurry leakage due to erosion/corrosion.

          Does the thickener have a protective covering (e.g., screen)?  If
          not, look for floating debris.
          How is water recycled back to the system (gpm) and how is it used?
          (See Section 5.2.2.8 for significance.)

          What is the actual/design percent solids the thickener produces at
          the underflow?  Overflow?  (See Section 5.2.2.5 for significance.)

          What is the thickener actual/design solid waste production rate?
          (See Section 5.2.2.7 for significance.)

          What is the approximate ratio of calcium sulfite to sulfate of the
          inlet waste to the thickener?  (See Sections 2.3.2.5 and 5.2.2.7
          for significance.)
OPERATION AND MAINTENANCE
          For equipment protection purposes, is the thickener rake drive
          shaft and motor equipped with a torque control/alarm system?   If
          not, how is it monitored?

          Have there been problems reported with rake binding or rake drive
          shaft/motor failure?

          Have there been sump pump failures?

          Have there been liner failures?

          If problems have occurred, inquire about remedial  actions  taken  or
          planned.

          Inquire about routine maintenance procedures.   How often inspected?
                                   144

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                     TABLE 4.2-12.   VACUUM FILTER CHECKLIST
OBSERVATION

     0    Inspect filter cloth for te
                    ars.
          Observe surroundings for spare or discarded filter cloths.
          Observe filter cake consistency.   Does the material  fall  from the
          filter cloth upon hitting the blade in dry cake-like chunks or do
          it stick and fall to the conveyor in a damp gum-like mass?
                                                       does
PROCESS
          What is the actual/design percent solids in the filter cake pro-
          duced by the vacuum filter?) (See Section 5.2.2.5 for signifi-
          cance.) Is the inlet solids
          filter cake formation?
          What are
          production
          significance.)
                     content high  enough  to  allow  adequate
s the design/actual  solid waste and wastewater effluent
ion rates of each vacuum filter?  (See  Section 5.2.2.7
for
          How much vacuum filter filtrate is recycled back to the system
          (gpm) and how is it used?

          What is the approximate rat
          filter cake?  (See Sections
                     See Section 5.2.2.8 for significance.)

                     o of calcium sulfite to sulfate  of the
                     2.3.2.5 and 5.2.2.7 for significance.)
OPERATION AND MAINTENANCE

     0    Have there been any filtrate or vacuum pump failures?

     0    Have there been problems wr:h filter cloth replacement?

     0    Have there been any problems due to filter cake conveyors?

     0    If any problems have occurred, inquire about remedial actions taken
          or planned.

     0    Inquire about routine maintenance procedures.
                                     145

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                       TABLE 4.2-13.  CENTRIFUGE CHECKLIST
OBSERVATION
PROCESS
          Are any centrifuges operational?  If not, is it the result of a
          forced outage or normal maintenance?

          Observe the filter cake consistency.  Does the material empty from
          the centrifuge in dry cake-like chunks or does it stick to the
          conveyor in a damp gum-like mass?
          What is the actual/design percent solids in the filter cake pro-
          duced by the centrifuge?  (See Section 5.2.2.5 for significance.)
          Does it yield a quality product consistently?  Is the inlet solids
          content high enough to allow adequate filter cake formation?

          What are the design/actual solid waste and wastewater effluent
          production rates of each centrifuge?  (See Section 5.2.2.7 for
          significance.)

          How much centrifuge filtrate is recycled back to the system (gpm)
          and how is it used?  (See Section 5.2.2.8 for significance.)

          What is the approximate ratio of calcium sulfite to sulfate in the
          end product?  (See Sections 2.3.2.5 and 5.2.2.7 for significance.)
OPERATION AND MAINTENANCE
          Ask the utility contact about problems associated with the centri-
          fuge and related equipment.

          If any problems have occurred, inquire about remedial  actions  taken
          or planned.

          Inquire about routine maintenance procedures.
                                     146

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                TABLE 4.2-14.   WASTE
      PROCESSING SYSTEM CHECKLIST
PROCESS
          What type of waste processi
          (See Section 2.4.2.13.)
      ng technique is used at this facility?
OPERATION AND MAINTENANCE
          Ask utility contact about
          area.
          If any problems have
          or planned.
               Forced oxidation

               Fixation

               Stabilization

               Untreated

          What is the energy consumption of the waste processing system?
     problems associated with this equipment
occurred, inquire about remedial  actions taken
          Inquire about routine maintenance procedures.
                                     L47

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 previously in Figure 2.4-18.  Table 4.2-15 provides a waste
 disposal system checklist.
 4.2.3.6   Pumps and Valves.  Figure 4.2-5 shows a typical slurry
 recycle centrifugal pump used in an FGD system.  Pumps of great-
 est concern with respect to operation and maintenance are slurry
 recycle pumps.   Valves are generally not major failure related
 items.   Table 4.2-16 provides a pump and valve checklist for the
 inspection.  Pumps are major areas of concern because of their
 very high maintenance requirements.   Most utilities accept
 impeller and liner failures as normal to operations.   Utilities
 track the expected life of each major pump,  and schedule complete
 overhauls around the time failures are projected.   In addition,
 particularly in newer systems, a good deal of pump redundancy is
 included in the overall FGD system design to minimize the impact
 of  failures.  It is important for the inspector to be aware of
 signs of excessive pump failure.   Excessive  failures  in this area
 could give clues to problems in other parts  of the FGD system.
 An  example of this might be corroded pump impellers due to
 lowered slurry  pH.

 4.3   SUMMARY
      To simplify the inspector's  data collection process,  the
 individual checklists presented earlier  have been  abbreviated and
 assembled into  a single  inspection worksheet titled "FGD  System
 Inspection Checklist", and  presented in  Appendix C.   Copies  of
 the inspection  worksheet should be made  prior to each plant
 inspection.
     As mentioned  in the beginning of  this section, the actual
 layout  of  the FGD  system may differ  greatly  from one  plant to the
next.   In  addition,  an inspector  is  likely to  encounter items
pertaining  to one area while inspecting  another, e.g., pallets  of
new mist eliminator  sections could be  stacked  outside  the FGD
system main building, near  the reagent handling  area,  or adjacent
to the waste processing  area*  Also, a typical FGD  system may be
  SECTION 4-INSPECTION METHODS AND PROCEDURES
                                148

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                 TABLE 4.2-15.   WASTE
      DISPOSAL SYSTEM CHECKLIST
PROCESS
          Is the FGD system water loop
          for significance.)

          What type of waste disposal
          Section 2.4.2.14.)

               Ponding

               Landfill ing
       open or closed?  (See Section 5.2.2.8


      system is used at this facility?  (See
               Stacking
          If a pond is used, is
          How much?  What are the
          chlorine content, other
          significance.)
wasteWater circulated back to the process?
  waste characteristics (solids content, pH,
  salts content)?  (See Section 5.2.2.8 for
OPERATION AND MAINTENANCE

     0    What problems have been reported with respect to this area?  If any
          problems have occurred, inquire about remedial actions taken or
          planned.
          Inquire about routine maintenance procedures.
                                      149

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                            DISCHARGE
SUCTION
                                                         SHAFT
            -7.5 ft-
          FRONT VIEW

/-SUCTION            | /-DISCHARGE
            SIDE VIEW
                                                         5 ft
                               Cb)


     Figure 4.2-5.   Typical  slurry.recycle centrifugal  pump:
        (a) isometric view;  (b) side and front viev\Twith
                     approximate dimensions.
                               150

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                     TABLE 4.2-16.   PUMP AND VALVE CHECKLIST
OBSERVATION
          Observe any discarded pump impellers or pump liners in the area
          around each pump.  (See Section 5.2.4.3 for significance.)  Inspect
          for excessive erosion/corrosion.

          Are there any leaks around the pump seals, pump bearings, or other
          areas?

          Check for excessive pump vihration (if it is questionable as to
          whether the vibration is norjmal or not, ask the operator or primary
          utility contact).
          Look for abrupt expansion,
          at the inlet/outlet of valvejs
          tion and valve malfunction.
                           contraction,  and bends in piping located
                              that could lead to solids accumula-
PROCESS
          Inquire about process
          are subject to.  How does
          case?
                          tM
conditions that failure-prone pumps/valves
       s compare to the design duty in each
          How does the actual energy consumption of the absorber recycle
          pumps compare with the design value?  (See Section 5.2.2.9 for
          significance.)
          Ask about pump redundancy p*
OPERATION AND MAINTENANCE
Ask the operator if there he
tion, or shaft, impeller or
curred, inquire about remed-
specific pumps in question

Inquire about the types of
occurred.  What remedial ac
                            •ovided.
                                      ve been problems with plugging, cavita-
                                      liner failure.  If problems have oc-
                                      al actions taken or planned.  Identify
                                      nd record details.

                                      •alves and location where failures have
                                      ;ion has the utility prescribed?
          Inquire about routine pump/valve maintenance procedures.
                                     151

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 several stories high.   It may be more  convenient for the inspec-
 tor to inspect equipment items  level by  level  rather than by
 equipment area.  In such a case, the inspector would look at the
 equipment observable at each level.
      As stated earlier  in Section  4.1, the  general plant data
 portion of the FGD system inspection checklist should be complet-
 ed prior to the inspection because it  can provide valuable input
 for evaluating the FGD  system performance,  diagnosing problems,
 and recommending corrective measures.
SECTION 4-INSPECTION METHODS AND PROCEDURES
                                 152

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                           SECTION 5
                  PERFORMANCE EVALUATION AND
                  PROBLEM DIAGNOSIS/CORRECTION
     This section describes guide]
ines that can be used by the
field inspector to interpret FGD system performance data with
respect to present and future compliance status.  The guidelines
presented are independent in that
they are designed to assist the
field inspector irrespective of performance interpretation or
biasing by the plant operator.  The guidelines presented are
designed to be used in both immediate and long-term performance
evaluations.  The latter considerction is important in that an
FGD system may yield performance c
the time of the inspection; howeve
the existence of problems which wi
status.
     This section represents a coritinuation of Section 3, wherein
we describe lime/limestone slurry
their measurement, and Section 4,
stone slurry FGD inspection methoc
ata indicating compliance at
r, process data may indicate
11 jeopardize future compliance
FGD performance indicators and
wherein we describe lime/lime-
s and procedures.  We describe
in this section both the sources of data available to the field
inspector as well as the form these sources of data take.  We
describe techniques that are available to aid the field inspector
in performance evaluation.  We identify cause-and-effeet problem
relationships and corrective measures through simplified sequence
diagrams.  We present followup prqcedures to verify the success
of the corrective measures taken.
     The information presented in
this section is organized in
accordance with the equipment aree.s and subsystems identified in
Section 2.4.2  (FGD System Design Configurations).

SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                 153

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 5.1  DATA  COLLECTION  METHODS      i
     The following  two  sections  give  a  brief description of
 sources of performance  data and  modes by which these data are
 available  to  the  field  inspector.
 5.1.1  Sources
     Sources  of information available to the field inspector
 during the plant  inspection include performance data,  process
 data, operation and maintenance  data, and observational  data.
     PGD system performance data includes any information con-
 cerning SO2 removal,  particulate removal,  and opacity  levels.   As
 mentioned  in  Section  3.4, most operator utilities  collect SO2,
 particulate,  and  opacity data continually using CEM's  in the form
 of strip charts,  computer disk,  arid/or  tape  files.   Other sources
 of performance data include stack test  results for compliance
 testing, acceptance testing, certification of the  CEM's,  and/or
 smoke stack readings  by a trained observer for opacity
 compliance.
     Process  data includes any information concerning  the various
 physical operating  parameters of the  FGD system.   These  param-
 eters include gas flow, gas-side pressure  drop,  slurry pH,  slurry
 flow, slurry  solids,  reagent consumption,  solid waste  production,
wastewater discharge, makeup water consumption,  and energy
 consumption (see  Section 5.2.2).  Most  operator utilities record
 this type  of data hourly on operation log  sheets.   If  not,  the
 field inspector,  with the aid of the  operator,  can obtain most  of
 these measurements  directly from the  control panel.  Certain
other parameters, such as slurry pH and slurry solids, are also
measured manually with grab samples to  check automatic
 instrumentation readings.  On request,  the field inspector should
also have  easy access to these recorded data.   However,  other
parameters such as  makeup water  consumption  and equipment energy
 consumption might not be measured directly;  they can be  obtained
directly from the operating staff.

 SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION   ~~™   ~~  ~~
                                 154

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     Operation and maintenance  data
is manually recorded  in  the  form of
 include any information which
 operation log books, mainte-
nance log books, work orders, maintenance  requests,  and equipment
purchase orders.  A detailed description of  these  types of data
is presented in Section  5.2.3.
     The last and most important  source of data  is observational
data and information obtained firsthand by the field inspector.
The field inspector should  try  to ask  questions  concerning system
O&M as well as take notes  (and/or photographs) on  equipment
layout, visual appearance of equipment, general  housekeeping,  and
any consumed equipment or parts  obi
erved during the inspection
 (see Section 5.2.4).   In  some  cases',  recorded  data will  not be
available and the field inspector will  have  to take readings
directly from the control panel(s)
or orally from the operating
staff.  All of these data and  information will  be  of  use  when the
field inspection is completed  and  the  inspector has returned to
the office for data assimilation anjd analysis.
5.1.2  Forms of Data
     The forms of data and  information available to the field
inspector are mentioned  in  Section
5.1.1.  These include computer
output, control room panels, O&M  records,  other written  documents,
and observational data and  information.  Most  GEM's  have a means
for viewing or printing on-line results of SO_, particulate,
opacity emission, and NO  measurements in  a variety  of units
           6
 (ppm, lb/10  Btu).  Regarding  control panels,  the  field  inspector
should be aware that FGD control  pajnels may be decentralized
 (i.e., at more than one location  in,  the plant) versus a  central
location such as the boiler control
and feed, gas handling and treatment,  and waste  solids  handling
and disposal instruments might be  located on  separate panels  at
different locations in the plant.
the field inspector include O&M  log
test reports, purchase orders,  lab
 room.  Reagent preparation
Written records available to
 books, work orders, stack
reports, and any other written
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                    5

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 documentation concerning the operation and performance of the EGD
 system.   The final and most important means for gathering data . , ,, .
 and  information is the recording by the field inspector during
 the  plant inspection.
 5.2   PERFORMANCE EVALUATION
      This  section provides the field inspector with independent
 guidelines on how to collect and interpret performance data
 during  a plant inspection.  These guidelines are organized accord-
 ing to  emissions (Section 5.2.1), process (Section 5.2.2), O&M
 (Section 5.2.3), and observation (Section 5.2.4).  These sections
 emphasize  collection techniques and performance interpretation.,
 To the  extent possible,  the interpretation guidelines exclude any
 discussion of problem diagnosis and corrective actions; these are
 taken up in Sections 5.3.1 and 5.3.2, respectively.
 5.2.1  Emissions
      The following discussion on emissions .addresses SO_, partic-
 ulate matter, and opacity.  The discussion on particulate matter
 and opacity is presented in terms of FGD performance.  Section
 3.1.1 introduces the gas stream measurement parameters and the
 associated monitoring techniques used by the operator utility to
 collect these data.                1
 5.2.1.1   SO,,.   Inlet SO,, concentration is largely dependent on
 the sulfur content of the coal fired in the boiler (see Section
 2.2,  Coal  Properties and Flue Gas ^Characteristics).  To estimate
 SO_ emissions (in units  of Ib SO»/10  Btu),  the field inspector
 should  refer to Figure 2.1-1 or use the following equation:
                                                           4
 SO- emission rate = (% sulfur in coal by weight)  x (2 x 10 )
                     x (fractional conversion of sulfur in coal
                     to SO2)/(heating value of coal in Btu/lb).
 EXAMPLE:
                                       4
 S02 emission rate = (3.5% S)  x (2 x 10 )  x (0.92 conversion)/
                      (ll,OOOBtu/lb)  = 5.85 Ib SO2/106 Btu.
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION           "
                                  156

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 (If  the  conversion of sulfur to Sol is unknown, use EPA AP-42
                                   £*
 emission factors  that assign SO2 cqinversion factors as follows:
 0.97  for bituminous  coal,  0.88 for
             12
 for lignite.  )
      Sulfur  is present in  the coal
pyritic  (primarily  FeS2),  and inorcanic sulfates.   The organic
sulfur  is  liberated when  the  coal a
subbituminous coal, and 0.75
in three forms:  organic,
s burned; however, not all the
inorganic  sulfates  and pyritic  sulfur is liberated during combus-
tion.  Some of  it is  converted  to tottom ash or fly ash.   The
coal should be  tested to  determine what fraction of the organic
and inorganic sulfur  is converted to SO9.   Typically,  95  percent
of the sulfur in coal is  converted
percent may be converted  to  sulfur
    2'
to SO2; about 0.5 to 1.0
trioxide (SO.,) ; and the re-
mainder is trapped  in  the bottom ash or fly ash.   The SO., is
converted to sulfuric  acid mist  during the  absorption process.
Due to the fineness of its particld  size, very little is removed
by the FGD system.
     An increase in inlet SO2  concentration due to a change in
coal sulfur content may lead to  several operating consequences
including increased reagent consumption, increased solid waste
production, and lowered slurry pH (li.e. , SO2 loading exceeds
design) with increased potential for gypsum scale formation and
corrosion in the absorber  (see Section 5.3.1.1,  Absorber).
5.2.1.2   Particulate  Matter.  Particulate  matter consists  pri-
marily of finely divided solid particles entrained in the flue
gas stream.  The particles can be either fly ash,  uncombusted
coal fines, or SO2  reactants/products.
     Increases in coal  fines and fly ash in the  flue gas can
contribute to plugging  in the  absorber.  Added levels of fly ash
and coal fines can  also  increase solid waste production.   If not
accounted for in the design of the FGD system,  the alkalinity of
the collected fly ash  from its available calcium  oxide (CaO)  and
magnesium oxide (MgO)   constituents can result in  high pH levels
and unreacted reagent.   This in  turn may increase  the potential

SECTION 5 - PERFORMANCE  EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                 is;

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for scale formation, plugging, and unnecessarily high solid waste
production.  If the fly ash has a low alkalinity value  (or,
conversely, high acidity value), it can have the opposite effect.
The fly ash (and coal fines) can dilute the slurry solids level
of the chemical reactants, thereby lowering the SO- removal effi-
ciency and pH of the system.  This in turn can promote gypsum
scale formation.  Increased amounts of fly ash and coal fines, in
addition to absorber-generated particulate matter, can also lead
to opacity problems.
     Decreases in particulate removal efficiencies can be attrib-
uted to a number of factors including mechanical problems, poor
maintenance, and changes in coal characteristics.  For example, a
change in coal sulfur content from 2.5 to 1.0 percent can reduce
the ESP particulate removal efficiency from 98 to 90 percent due
to changes in particle resistivity.  If the particulate matter
removal device is not working properly, the carryover of the
solids to the FGD system might lead to the adverse consequences
indicated in the foregoing paragraphs.
     Increased particulate matter loading due to higher ash
content in the coal can overload particulate matter removal
devices and subsequently increase opacity levels.  Ash content of
coal ranges from less than 3.5 to more than 15 percent.  A por-
tion of the ash leaves the boiler with the flue gas as fly ash,
and the remainder leaves the boiler as bottom ash.  The split of
fly ash to bottom ash depends on coal grade and characteristics
and boiler firing configuration.  For any application, an accu-
rate determination can only be made empirically.  However, for
field inspections, a number of quick-estimating techniques are
available.  For pulverized coal boilers, the split of fly ash to
bottom ash is 80:20.  For cyclone-fired boilers, the split is
30:70 (almost a complete reversal of pulverized coal).
5.2.1.3   Opacity.  Opacity is the degree to which particulate
emissions in the plume leaving the FGD stack reduce the transmis-
sion of light and obscure the vision of objects in the background.

SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION       ~~
                                158

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Increases in opacity levels are usually  the' result  of  decreased
particulate matter removal, an increase  in  particulate matter
loading  (i.e., higher ash content in coal),  or  the  generation  of
FGD particulate matter.
     A decrease in particulate matter control efficiency  can
easily contribute to higher opacity levels.  In some cases,
FGD-generated particulate matter contributes to the opacity
level.  There are several mechanisms which  account  for this.   For
example, prior to contacting the slurry, quenching  or  presatura-
tion may be used to reduce the flt.e gas  temperature.   The water
used in this spray may contain significant  quantities  of  sus-
pended solids or dissolved salts which can  form a solid aerosol
on evaporation.  If the aerosol is
penetrate the absorber and become
 small enough, it could then
part of the overall emissions
from the FGD system.  Another exarrple is the  slurry  from  the
absorber.  The mechanical equipmert required  to pump and  spray
the slurry also generates liquid and solid aerosols.   These
aerosols could be entrained by the
the mist eliminator to the stack.
such as sulfuric acid or volatile
vapors in the flue gas.  As the gas temperature  is reduced during
passage through the absorber, thes
small particle aerosols may pass through the absorber to the
stack.
5.2.2  Process
     The following discussion on process addresses the operating
parameters of gas flow and pressure drop; slurry pH, flow, and
solids; reagent, solid waste, and
wastewater effluent and energy con
 gas stream and pass through
 Additionally, certain species
elements may be present as
e species may condense.  The
makeup water consumption; and
sumption.  Section 3.1  (Key
Operating Parameters and their Measurement) provides background
information on these measurement parameters and monitoring tech-
niques.
  SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                 159

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5.2.2.1   Gas Flow.  The gas flow rate to the FGD  system  is
primarily a function of boiler load.  Variance  from design caused
by sudden changes in boiler load, .leaks  in ducts and expansion
joints, or the malfunction of the control dampers  can  lead to
several operating consequences.  Gas  flow rates above  the design
value can have several consequences,  including  the reduction of
SO0 removal.  Another result of high  gas flow rate is  the carry-
  £+
over of entrainment from the mist eliminator to the downstream
subsystem.  Higher-than-normal gas  flow  rates can  result  in in-
creased particulate loadings from upstream particulate collection
devices  (e.g., ESP's, scrubbers). !  The added particulate  matter
can also increase solid waste disposal.  Reduced gas flow may
decrease S0~ removal efficiency, depending on the  design  and
operating characteristics of the absorber.
5.2.2.2   Gas-side Pressure Drop.   Gas-side pressure drop con-
sists of losses  in the bends, contractions, and expansions in the
inlet and outlet ductwork, pre-scrubber  (if present),  absorber,
mist eliminator, reheater  (if present),  and stack. Emphasis is
placed here on the absorber and mist  eliminator because they con-
stitute the major portion of the total pressure drop.   The pres-
sure drop across the absorber and:mist eliminator  is a function
of flue gas velocity and design.  For reference, reported design
pressure drops for specific types of  absorbers  and mist elimina-
tors used in commercial lime/limestone slurry FGD  systems are
summarized in Tables 5.2-1 and 5.2-2, respectively.
     An increase in pressure drop across the absorber  and mist
eliminator can cause an increase in system energy  consumption due
to increased energy demand by the unit or booster  fans.  An
increase in pressure drop across the  absorber/mist eliminator is
commonly attributed to either plugging or scaling. Other con-
tributing factors include high gas  flow  rates and  high slurry
flow rates  (which compresses the gas  flow).
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

                                 160

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TABLE 5.2-1.   DESIGN GAS-SIDE PRESSURE DROPS FOR ABSORBERS  IN
           OPERATIONAL LIME/LIMESTONE FGD SYSTEMS
Absorber type
Venturi
Fixed-throat
Variable-throat/side movable blades
Variable-throat/top-entry plumb bob
Packed
Entrained
Grid
Mobile bed
Rod deck
Static bed
Tray
Sieve
Combination
Spray/packed
Spray
Open/countercurrerit spray
Open/crosscurrent spray


















Number
of
plants

2
1
1

3
1
5
3
1

7

8

24
4
Gas-side pressure
drop, in. H20
Range

6
8
8

3-6
2
2-9
8-12
11

2-14

1-6

1-8
2
Average

6
8
8

5
2
6
9
11

6

3

3
2
                             161

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TABLE 5.2-2.  DESIGN GAS-SIDE PRESSURE DROPS FOR MIST ELIMINATORS  IN
               OPERATIONAL LIME/LIMESTONE FGD SYSTEMS
Mist eliminator type
Primary collectors
Impingement '
!
Baffle/closed vane
Baffle/open vane ;
Centrifugal separation
Radial vane
Precollectors
Bulk separation
Perforated trays
Number
of
plants

56
2

1


2
Gas-side pressure
drop, in. HpO
Range

0.1-4.0
0.2-0.8

2.3


0.5
Average

1.0
0.5

2.3


0.5
                                 162

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     A decrease  in  pressure  drop
cause improper slurry  atomizatio
er.  A decrease  in  pressure  drop
packing,  low  slurry  flow rates,  or low gas flow rates.
5.2.2.3   Slurry pH.   Control  of
 ,  although not as common, can
 i  and distribution in the absorb-
 can be attributed to dislocated
  slurry pH is essential to reli-
able FGD  system performance.   Removal  of SO2 from the flue gas
takes place  in the  absorber,  and)neutralization and precipitation
reactions occur in  the  slurry recirculation and holdup tanks.
The pH of the recirculation  slur::y  entering the absorber should
be in the range of  8.0  to  8.5 for lime slurry and 5.5 to 6.0 for
limestone slurry.  The pH of  the
er should be in the range of  6.0
  spent slurry leaving the absorb-
  to 6.5 and 4.5 to 5.0 for lime
and limestone slurry, respectively.   Slurry pH is  controlled by
adjusting reagent  feed rate.  However,  slurry  pH can also be
t
affected indirectly by  slurry  feed  rate  and  the  quantity and
characteristics of flue gas being treated.   Operation at high pH
levels, which tends to  increase  SO9 removal  efficiency,  can lead
to soft scale formation,  lowered
  reagent utilization,  and in-
creased solid waste volume. Operation at  low pH  levels, which
tends to improve reagent utilization and  lower the  amount  of
solid waste production, will also  lower SO2 removal efficiency
and promote gypsum formation.
5.2.2.4   Slurry Flow.  The field  inspector should  obtain  read-
ings from all instruments used to  measure the flow  of  the  differ-
ent process streams  (see Section I 3.2.2).  Pump discharge pressure
is commonly used to determine slurry flow characteristics.  Flow
in noninsulated slurry piping can  be checked by  touching the  pipe
(warm and/or vibrating, the pipe is operational; cool  and/or
quiescent, the pipe is inoperative).  Deviations from  anticipated
values can indicate potential problems, either in the  absorber or
with the instrumentation.
     The rate of slurry flow (feed) to the .absorber is determined
primarily by the design L/G ratio.  An increase  in  slurry  flow
 SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                               163

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rate above the design L/G may improve SO2 removal; however, high
slurry flow rates mean high pumping costs, increased reagent
usage, lower reagent utilization,;and greater solid waste produc-
tion.  High flow rates also promote the erosion of piping, pumps
impellers, absorber linings, spray headers and nozzle orifices,
and valves.  High slurry flow rates can.also lead to slurry
carryover from the mist eliminators.  A decrease in slurry flow
below the design L/G is usually an indication of plugging, which
is detectable by either an increase in recycle pump discharge
pressure or absorber slurry recycle piping that is cold to the
touch  (normal operating temperatures are  125° to 130°F).  By
decreasing the recirculation slurry flow  rate, SO2 removal effi-
ciency will be lowered.   As slurry flow  is drastically reduced
or stopped, pump cavitation may occur.  Moreover, pump  liners can
be sucked into the path of impellers and  shreaded which may
become additional material to reduce flow rate by plugging down-
stream slurry handling equipment.
5.2.2.5   Slurry Solids.  Operation at a  consistent solids con-
tent in the various slurry process streams can improve  the relia-
bility of the absorber and slurry handling equipment and  improve
process control.  Specific gravity is a commonly used measure for
determining slurry solids content (see Section 3.2.3).  The
design specific gravity of the recirculating slurry for lime/
limestone FGD systems is usually  between  1.05 and  1.14  (approxi-
mately 7 to 20% solids).  A graphic representation of  specific
gravity as a function of the solids content of the slurry in
lime/limestone FGD systems is presented in Figure  5.2-1.
5.2.2.6   Reagent Consumption.  Reagent consumption is  set by
stoichiometry of the process.  As noted in Section 2.3.2.1,  it  is
necessary to feed more  than the stoichiometric amount  of  reagent
in order to attain the  degree of  SO2 removal required  (stoichio-
metric ratio).  However, excessive reagent can lead to  several
operating problems including wasted reagent, scale formation, and
  SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                 164

-------
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                      165

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erosion of slurry-handling equipment.  Figure 5.2-2 is a graphic
representation of reagent consumption as a function of the S02
emission limitation and boiler size  (i.e., equivalent FGD capaci-
ty in MW).  This figure can be used by the field inspector to
estimate reagent feed rates.
5.2.2.7   Solid Waste Production.  Solid waste  (sludge) produc-
tion will vary as a function of the  inlet flue  gas character-
istics and FGD system design and operating characteristics.  The
constituents usually include solid phase SO2 reaction products,
unreacted reagent, fly ash, and adherent liquor.
     Increases in solid waste  increase the burden on solids
handling and disposal.  This can mean higher energy consumption,
possible deviation from closed water loop operation due to exces-
sive amounts of wastewater  effluent, and reduced  land  area avail-
able for disposal.  Variations in  the quality  of  the slurry  bleed
stream to the thickener can either overload  (high or  "rich"  sol-
ids content) or under-utilize  (low or  "lean"  solids content)  the
primary  dewatering subsystem.  The ratio of  sulfite to sulfate
contained in the  spent  slurry  stream is  also  important because of
the size differences between gypsum  (1  to  100  microns  in  length)
and calcium sulfite crystals  (0.5  to 2.0 microns  in  length).
These  differences can  have  a  significant impact upon  the  dewater-
ability  of  the  solid waste  material.  Generally,  as  the ratio of
sulfite  to  .sulfate increases,  the  liquor content of  the dewatered
solid  waste also  increases.  Figure  5.2-3  provides a  nomograph to
convert  between dry and wet sludge production.
 5.2.2.8    Makeup Water Source and Consumption.  Water is lost
 from the FGD process  in the form of water vapor and small amounts
of entrained liquid in the saturated flue gas.  Water is also
 lost in the disposal of solid waste material or byproduct.
Makeup water is added in order to offset these losses.  Major
 addition points and/or uses of makeup water include reagent
 preparation and dilution, mist eliminator wash, pump seal water,
  SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                 166

-------
                                                           IT)


                                                           CM
                                                           OO
                                                                 C.
                                                                 o
                                                                  CM

                                                                 O
                                                                 00
                                                                          c
                                                                          o
                                                                          fO
                                                                           (O
                                                                           O
                                  §
                                                                           (1)
                                                                           
-------
Figure 5.2-3.   Sludqe (waste)  production  calculation.
                        168

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and recirculation tank level control.  Sources of makeup water
include fresh water, recycled water, and plant inventory water.
Fresh water may come from a river] lake, a municipal water sys-
tem, or an untreated well; recycled water is recovered from the
solid waste disposal system either in a settling pond or in a
settling or filtration step; and plant inventory water is cooling
tower blowdown.  The amount and type or quality of makeup water
used is important when considering its effect on closed water
loop operation, reagent preparation, and operability and clean-
liness.
     For closed water loop operation, makeup water addition
should not exceed losses in the flue gas and solid waste materi-
al.  High makeup water consumption could lead to discharges  (or
increased rates of existing discharge streams) to existing water-
ways.  Contributing factors to high makeup water consumption
include inefficient pump seals, excessive mist eliminator wash
rates, and inefficient water recovery in the FGD process.
     For reagent preparation and dilution, the importance of the
quality of makeup water used for limestone slurry is typically
not of critical concern and recycled  (recovered process) water is
used.  The quality of makeup water required for slaking lime is
very critical.  The use of fresh water  (of or near potable quali-
ty) is required.
     Concerning equipment performance, mist eliminator wash water
can be fresh, recycled, plant inventory, or a blend of the above.
Ideally, fresh water should be used; however, to attain closed
water loop operation, a blend is frequently used.  A number of
problems may be encountered due to the excess usage of recycled
or plant inventory water.  The high levels of dissolved salts in
recycled water can promote scale formation on mist eliminator
surfaces as well as mist eliminator wash lances.  With the use of
plant inventory water, the dissolved solids, suspended solids,
and residual chlorine contaminants can subsequently lead to the
scaling or erosion/corrosion of the mist eliminator wash lances,
 SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

                                 169

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absorber, piping, pumps, and other slurry handling equipment.
Another major use of makeup water is addition to the recircula-
tion tank for level control.  Water quality  is not a concern here
except that residual alkalinity is desirable. Typical makeup
water consumption rates and addition points  are summarized  in
Table 5.2-3 for several operational lime/limestone slurry FGD
systems.
5.2.2.9   Energy Consumption.  FGD energy consumption is attrib-
uted primarily to reheat, flue gas flow, slurry preparation, and
slurry recirculation.  Other energy consuming operations include
slurry transfer (pumping), tank agitation, solids dewatering
(thickeners, vacuum filters, centrifuges), steam tracing,
electrical instrumentation, and air supply.  An increase in
energy consumption in any of these areas usually indicates  a
problem.
     Reheating the saturated flue gas consumes more energy  than
any other part of the FGD system  (assuming reheat is used).
Reheat provides buoyancy to the flue gas and thus reduces the
nearby ground-level concentrations of pollutants.  Reheat also
prevents condensation of acidic, saturated gas from the absorber
in the ID fan, outlet ductwork, or stack.  Further, reheat  mini-
mizes the settling of mist droplets  (as localized fallout)  and
the formation of a heavy steam plume with resultant high opacity.
An increase in reheater energy consumption is generally indica-
tive of plugged or scaled in-line reheater tube bundles.  Energy
consumption is increased because the heat transfer efficiency of
the reheater tubes is lowered.  Table 5.2-4  provides a quick
approximation method to determine reheat energy consumption.
     Driving flue gas through the FGD system consumes energy.
Forced or induced draft fans use energy to overcome the gas-side
pressure drop of the FGD system.  An increase in fan energy
consumption usually indicates either a mechanical problem with
 SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                170

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           TABLE 5.2-4.   ENERGY REQ
                       UIREMENT CALCULATIONS
     P
     E
     Hs
     L/G
     o
     m
     AP
     Q
     AT
Specific heat, Btu/(lb)(°F)
Power required, kilowatts
Heat energy, Btu
Head, ft
Ratio of slurry flow to
outlet
flue gas rate, gal/1000 acf at the
Air flow rate at the inlet of reheat section, Ib/min
Pressure drop through FGD system, in. HJ3
Gas flow rate at the outlet of absorber, acfm
Degree of reheat, °F
     Slurry recirculation pumps (70% pump efficiency assumed)
          P = 0.000269 x H  x (L/G)
            = Hs (L/G) Q x (2.69 x
2.   Flue gas fans
          P = 0.0002617 x AP x Q (assuming 80% efficiency)

3.   Reheat of absorber flue gas
          E = 0.01757 ° C  AT
                                      1000
                                173

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the fan and/or an increase in pressure drop somewhere in the FGD
system.  Table 5.2-4 provides a quick approximation method to
determine FGD fan power requirements.  Figure 5.2-4 provides a
quick determination method if only plant size and gas-side pres-
sure drop are known.
     The grinding of limestone and the slaking of lime consume
relatively small amounts of energy as compared to other energy
consuming equipment.  Any increases are usually due to either
poor quality makeup water (see Section 5.2.2.8) or mechanical
problems with the slaker or ball mill.
     Energy is consumed to recirculate the slurry to the absorb-
er, to transfer water and slurry ;streams to various parts of the
FGD system, and to treat and dispose of the solid waste material.
Similar to fans, an increase in pumping energy consumption usu-
ally indicates either a mechanical problem or an increase in
slurry side pressure drop in the system.  Table 5.2-4 provides a
quick approximation method to determine recirculation pumping
requirements.  Figure 5.2-5 also provides a quick determination
for slurry recirculation pumping requirements if plant size and
L/G are known.
5.2.3  O&M
     Operation and maintenance data include recorded data in
operation log books, maintenance requests, maintenance log books,
work orders, and equipment purchase orders*
     Operation log books and the types of information recorded.
varies from plant to plant.  Example log sheets are shown in
Figures 5.2-6 and 5.2-7.  In Figure 5.2-6, the operation log
sheet simply records the status of equipment and the time of
operational changes.  In Figure 5.2-7, the operation log sheet
records only information on certain process parameters  (slurry
pH, slurry level, slurry density, etc.).
     With the increasing complexity of current FGD technology,
most utility operators employ computerized maintenance planning

 SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                 174

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    20,000
    15,000
O
    10,000
    5,000
                  —1	T
PLANT CAPACITY =f/1000 MW
                                                500 MW
                                                  60
                         AP, in
               , H00
          Figure  5.2-4.  Fan power  requirements.
                             175

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    4000 -
    3000 -
to

4->
ra
    2000 -
    1000 _
     I       I       I       I

PLANT CAPACITY =/1000 MW
                      20     30     40     50     60
                          L/G,  gal/1000 acf
     Figure 5.2-5.   Recirculation  pump power requirements,



                              176

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                    ABSORBER



(Indicate Status  of Equipment
OPERATION LOG



 and Time of Operational  Changes)
DATE























ABSORBER
MODULES IN























ABSORBER
MODULES OUT























OPE























BYPASS
^I-PARTIAL-CLOSED





































































REASONS FOR ABSORBER
BEING OFF OR BYPASSED























        Figure 5.2-6.  Example operation log sheet.
                            177

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                                        178

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systems.  Work orders are first written by operators during  shift
inspections.  In some cases, work
ging" in which the plant or shift
                                  orders are preceded by "tag-
                                  supervisor routinely inspects
the system and tags equipment apparently  in need of maintenance
or repair.  These work orders specify the equipment needing
repair, the estimated number of man-hours, possible causes of  the
.problem, and the urgency of completion  (i.e., date needed by).
The work order is then sent to the maintenance  department for
action.  The maintenance crew completes the maintenance  portion
of the work order form by noting
                                 the actual cause of the problem,
the work conducted, and the man-hours  needed  to  complete  the  job.
All of this information is then  computerized  for later  reference.
As this database expands, it becqmes a source for forecasting
equipment repairs which can be implemented during scheduled FGD
outages, unit outacres. or ceriods  of low demand.  For certain
         unit outages, or periods, of low demand.
recurring repairs, work orders can be generated automatically by
the computer versus being handwritten by an operator.  Figures
 5.2-8 and  5.2-9  are  examples  of,
                                 respectively, handwritten and
computer-generated work  order/maintenance forms.
     The  accounting  department ofl  the operator utility should
have records  on  equipment  purchase orders.   This  type of data can
be used to  spot  recurring  purchases which may indicate chronic
problem areas.
 5.2.4   Observation
     Sources  of observational dat
 FGD  system,  layout  of and access
                                 a include the operation of the
                                 to the equipment contained in
 the  FGD system,  equipment "consumed"  by the FGD system, and
 general housekeeping of the FGD system area.
 5.2.4.1  System Observation.  During  an inspection, the field
 inspector should look for signs Which indicate possible problem
 areas.   Several examples of thes4 include gas leakage; slurry
 leakage;  tower,  vessel,  and ductv
 of moving components.
                                 •ork appearance; and  the behavior
  SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                 :.79

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r
                                             WORK   ORDER
Priority/Laval
Station
Component

Requested By Group
Attach List: Work D
Work Description:

WORK ORDER NO.
Unit
Equipment No.
1 Unit Status
Raquantad Completion
Inspection LJ

90046041 9
Data Printed


Date
Settings LH



Special Instructions:

QRQUP
WORK
TYPE
CHQ/CWO/RWO
NUMBER
FERCK
OUTAGE INDICATOR
SUPERVISOR
PURCHASE ;
ORDER NO.
PLANNER
PLANNED WORK
EST.
CREW SIZE
Ciuca of Problem:







WORKFORCE MGT. CODE
9-Labor (Productive)
1 -Travel Time
2-lnclem Weather
3-Delay Time
4-Down Time
'Use code as last digit of
work order number on pay

SCHEDULED
COMPLETION
DATE ISSUED
EST. MANHOURS-ACT.










A
B
C
D
WELD.
MACH.
OPER.
CONTR.
OTHER
TOTAL
MH










CO

— 25
-rSO
— 75
— 100
%
MPLETE
                 Work Performed:.
                 D«1e t Tim* Tagged:

WORK
PERFORMED BY
ACTUAL
CREW SIZE
WORK PERFORMED
TYPE CODE
COMPLETED BY

DATE
COMPLETED
                        Figure 5.2-8.   Example of a handwritten work order form.



                                                      180

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PM03
            POUER MAIHTENWICE HtFORHATIOW SOURCE  RUN DATE: 2/12/«5
                                JOB ORDER-BOILER A
                                                         FREQUENCY:  0006!
1JOB  NO:  02585    BEPT:  3892    SCHIJD UEEK:  10/1965
IJOB  TITLE:       INSPECT, REPAIR, ADJUST S LUBRICATE
iUNIT:   1  SYSTEM:   SCR  EQUIP:  56/BAMPjER/OlOO/   A/C EQ.NO: AC-2892-2
[DESCRIPTION:   MODULE  "E" OUTLET ISOLATION DAMPER
iDESC CONT.:                             .
[MANUFACTURER:   AIRCLEAN     MODEL NO^  N/A
(LOCATION:  BL6. SCR NORTH-SOUTH E.O
 !CAPABILITY REDUCTION: 0000  PRIORITY:  05 CLEARANCE REQUIRED:   YES
 [ESTIMATED MANHOURS: 3: 0000.00 2: 0002.5 1: 0002.5 6t  0000.00  T:  5.00
                                    EAST-UEST  11.5 EL. 182.6
INSTRUCTION BOOK:
DRAWINGS:
LAST COMPLETED:  09/07/84
HAD TO CLIMB BEAMS TO PERFORM - COMPLETED - BERNIE AND RADHA
JOB STEPS:
   DAMPER CHAIN P.M. - ISOLATION DAHfERS
01 UORK SAFELY - CHECK ALL CLEARANCES.
02 CLEAN OIL AND DUCT ACCUMULATION FROM CHAIN UITH SOLVENT.
03 RELUBRICATE UITH SPECIFIED LUBRICANT.
04 CHECK CHAIN TENSION.  ADJUST AS NEEDED.
05 CLEAN UORK AREA.
PAGE 1 OF 1
AREA: 004 ACCT: 512.15 UORK ORD
ASSIGNED TO
COMPLETED BY
REMARKS



APPROVAL 	
:R:
DATE
DATE




FAILURE CODE
HOUR
HOUR





    Figure 5.2-9.  Example of a computer-generated work order form.
                                    181

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       Gas leakage usually occurs through expansion joints, damp-
  ers, or ductwork.  With positive pressure (forced draft) systems,
  flue gas can escape to the surrounding plant environment (which
  may be further complicated by an enclosed operation).  Such a
  problem will not be readily observable in negative pressure (in-
  duced draft)  systems in which air!is drawn into the FGD system.
  This air can promote corrosion, promote scaling due to uncon-
  trolled oxidation, and increase the amount of gas to be handled
  by the gas handling and treatment subsystems.
       Broken slurry lines and leaky pumps and valves can provide
  information concerning equipment maintenance, materials of  con-
  struction, and characteristics of the slurry.  Absorber tower
  appearance, inside and outside, also provides such information.
  Vibrating fans and pumps and pump;cavitation all provide clues
  regarding maintenance, materials of'construction, and system
  operation.  Dampers which are inoperative due to mechanical
  failure or absorber recirculation .lines which are cold to the
  touch because of plugging are examples of equipment items which
  also provide  information concerning system operation.
  5.2.4.2  Equipment Layout/Access.   Equipment layout and access
  can  influence performance (see Section 2.5.2,  System Layout and
  Accessibility).   For example,  layout of ductwork and piping is
  very important when considering system operation.   Excessive
  bending in ductwork can result in -added pressure drop,  increased
  erosion,  poor gas distribution,  and convenient host sites for
  collecting solids and moisture.   Excessive bending of  piping can
  result in high slurry pressure drop,  pump cavitation,  and host
  sites  for erosion and solids  buildup.   These types of  problems
  are  more  prevalent in retrofit FGD  systems (versus new systems)
  due  to spatial constraints.
      Access to equipment,  also a function of plant layout,  is
  important for maintenance  purposes.   Major and minor cleanout  is
  required  periodically.   Manholes should be present at  each  stage
  of the  absorber.   Similarly,  side doors should be  located in the

SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION        ~~~~~
                                  182

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reaction tank.  Tons of deposits may have to be removed each
maintenance period; doors should thus be large enough for easy
removal of such quantities of material/- To simplify repairs,
mist eliminator access should allbw for easy cleaning or replace-
ment of the components.  A walkway should be available for worker
safety and the prevention of damage to mist eliminator assemblies
and blades.  Mist eliminator sections should be light in weight
and come in small sections for easy removal by maintenance per-
sonnel to save man-hours.  Slurry recirculation pumps are often
located in a limited space with difficult access, especially  in
retrofit applications.  Because tiese pumps must be dismantled
periodically, sufficient access should be made available to
facilitate maintenance.  A winch-and-trolley system for moving
heavy parts, ample space for dismantled components, and good
lighting will simplify repairs.  Often the recirculation pump
                                of the FGD facility.  A constant
area is the most unsightly part
stream of seal water, slurry, an
                                d
 the FGD facility.
oil leaks from the pumps are
found even in well-maintained  systems.   Therefore,  the  pump area
should be designed  for  easy cleaning, with  such features  as
sloping  floors, wide  floor trenches, and a  good supply  of water.
Other equipment items such as  fans, agitators,  and  instrumenta-
tion  (pH meters,  density meters,
                                 etc.) should also have adequate
 spacing  for maintenance.   Equipment located in confined or inac-
cessible  spaces  tend to  see  less
                                 maintenance and prolonged main-
 tenance  repair  times.
 5.2.4.3   Consumed Equipment.   Used equipment can provide insights
 to  possible  operating problems.
 pump impellers  and liners,  spray
 and absorber internals.
      Erosion,  plugging,  and thermal stress are common reasons for
 spray nozzle replacement.   Eroded
                                 Commonly observed items include
                                 nozzles, mist eliminator blades,
                                  and plugged  spray nozzles may
 indicate a process chemistry problem or a mechanical problem due
 to slurry distribution or flue ga.s distribution in the. absorber.
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

                                 183

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      Mist eliminator packing is usually replaced because the
 packing is either damaged or plugged.  Mist eliminators con-
 structed of certain plastics can easily be damaged  (through ther-
 mal stress) at high temperatures.  Melted or brittle mist elimi-
 nators usually indicate a gas temperature control problem  (i.e.,
 high temperature excursion).  Mist eliminator replacement because
 of plugging is usually the result of gypsum scale formation.
      Displaced, plugged, or damaged absorber internals  (packing,
 supports, spray headers, nozzles) are also indicative of system
 reliability and performance.  Packing material can be commonly
 observed in the recirculation tank or thickener due to the high
 flue gas flow and/or high slurry flow.  Plugged packing is an in-
 dicator of gas slurry distribution or process chemistry problems.
      Pump impellers are usually replaced due to plugging, corro-
 sion, or loss of lining material.  Plugged impellers may indicate
 excessive solids in the slurry.  Corroded impellers indicate
 either problems with material of construction or process chemis-
 try.  Erosion or loss of pump liners may indicate improper lining
 materials, poor installation, high slurry solid levels, or pump
 cavitation due to low slurry flow.
      The above items and their possible reasons for replacement
 are just common examples of what the field inspector will come
 across during a plant inspection.
 5.2.4.4  General Housekeeping.   The overall cleanliness of the
 FGD facility provides insight to the following:  quality of main-
 tenance procedures,  size and type of maintenance staff, and the
 priority the operator utility gives to the FGD system in compari-
 son to other plant unit operations.  A clean and well-maintained
 facility will most likely be the result of a well-organized and
 managed staff who are probably using some sort of computer-based
 maintenance planning system.   Good  housekeeping is also an in-
 dication that the maintenance staff is well-manned and is more
 likely dedicated versus borrowed ifrom other service areas (boiler
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

                                 184

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staff, on-site contractors,  etc.)
facility, how well  the  FGD  system
indication of how the FGD system
utility.

5.3  PROBLEM DIAGNOSIS  AND  CORRECTIVE MEASURES
                              .idili
                                    When compared to the boiler
                                  is maintained gives a good
                                 is looked upon by the operator
     This section describes guid<
in diagnosing problems affecting
terns and in recommending potenti.
lines to aid the field inspector
lime/limestone slurry FGD sys-
.1 corrective measures to remedy
these problems.   This  section represents a continuation of Sec-
tion 5.2  in which guidelines  were described to interpret perform-
ance data with respect to compliance status.   We extend this
discussion by identifying the cause-and-effeet relationships of
the various problems which affect FGD systems (Section 5.3.1).
 These  relationships  are analyzed
                                 by the "triggering" event which
 initiates  the  problem sequence and the "terminating" symptom by
 which  the  problem is  manifested (see Section 2.5.1, Failure
Modes).   This  discussion is then
measures  instituted to rectify these problems (Section 5.3.2).
 This  division of material is pro
                                 extended to the corrective
                                 rided because the corrective
 measure  sequence is typically a more involved procedure than a
 simple reversal of the problem sequence.
 5.3.1  Problem Diagnosis
     - Diagnosing problems affecting lime/limestone slurry FGD
 systems  involves the identification of problem sequences (failure
 modes).   Problem sequences are' cause-and-effeet relationships
 consisting of a triggering event
                                 which initiates the problem  and
 a terminating event which manifests the problem.  These problem
 sequences are distinguished as either the simple variety (where
 the sequence of events are closely connected) or cascading vari-
 ety (where the sequence of events are connected through a series
 of intermediate events).   These sequences can be described in
 terms of simplified block diagrams representing the equipment
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

                                185

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areas and  subsystems  identified in Section 2.4.2 (FGD System
Design Configurations).
5.3.1.1    Gas Handling and  Treatment.   The gas handling and
treatment  equipment area  is comprised  of the  subsystems of fans,
scrubbers, absorbers,  mist  eliminators,  reheaters,  ductwork,
dampers, and stack  (Section 2.4;2).  These subsystems can be
arranged in a variety of  configurations  according to process,
application, and duty considerations.   The various  configurations
presently  used  in commercial lime/limestone slurry  FGD systems
are presented in Figure 5.3-1
     As indicated in  Figure 5.3-rl,  there are  ten configurations
now in commercial use in  lime/limestone  slurry processes.   These
configurations  are divided  according to  scrubber-absorber combi-
nations  (listed in the top  portion of  Figure  5.3-1)  and absorber
(only) configurations (listed in the lower portion  of Figure
5.3-1).  Of the configurations  listed, more pertain to scrubber-
absorber combinations than  to absorber combinations simply be-
cause of the additional variation  of fan placement  between the
scrubber-absorber train  (Gas Configurations III and IV).
     Each  configuration listed  includes  a set of "fixed"  subsys-
tems that  are common  to all the configurations listed;  namely—
inlet ductwork, absorber, mist  eliminator,  outlet ductwork, and
stack.  All the other subsystems  (fan,  scrubber,  and reheater)
can vary.according to presence  (scrubber and  reheater)  and posi-
tion  (fan  and reheater) in  the  configuration.   Of the gas  config-
urations listed (designated as  Gas Configurations I through X),
some are used far more extensively than  others.   The more  preva-
lent configurations are consistent with  the characteristics of
technology generation described,in Section 2.4.1.2  (Gas Configu-
ration IX  and X).  These  characteristics include placement of  the
fan upstream (forced  draft)  of  the absorber,  elimination of the
scrubber in favor of  segregated jparticulate control (upstream
ESP), use  of the absorber for segregated SO~  control,  and  the  use
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                               186

-------
                                                                      c -o
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of a reheater to maintain gas temperatures above dew point in the

discharge ductwork and stack.
     The cause-and-effect problem sequences which occur in the

gas handling and treatment area are described below in terms of

the triggering event causing the problem and the terminating

symptom manifesting the problem.

     0    Fan.  Forced draft fans  (upstream of the scrubber/ab-
          sorber) , as depicted iti Gas Configurations I, II, IX,
          and X of Figure 5.3-1, depend on the operation of the
          upstream particulate matter collection device  (typical-
          ly ESP).  Variations or degradation of performance in
          the particulate matter collector can lead to solids
          deposition or erosion of the rotor, inlet box, housing,
          and discharge duct  (see Section 2.4.2.1, Fans).  The
          following simple and cascading problem sequences can
          result:

               Accelerated wear and holes in fan housing

               Erosion  ("sandblasting") of rotor, causing loss of
               draft across system  (inability to overcome gas-
               side pressure drop) which can lead to loss of
               absorber SO2 removal efficiency, loss of duct
               velocity and settling out of gas-entrained solids
               in the duct, or premature motor failure  (motor
               compensates for mechanical failures).

               Leakage of air into fan  (through inlet ductwork or
               fan intake), causing gas temperature drop and dew
               point corrosion attack in fan and inlet duct;
               greater volume of gas into system, causing in-
               crease in pressure drop, loss of absorber S02
               removal efficiency, premature motor failure;
               greater amount of:oxygen in system, causing uncon-
               trolled oxidation and process chemistry problems
               of gypsum scaling in absorber tower.

          Induced draft fans  (downstream of the scrubber/absorb-
          er) , as depicted in Gas Configurations V through VIII,
          have a less cascading influence on FGD operation due to
          the minimization of downstream equipment.  Any impacts
          on downstream equipment will be similar to those de-
          scribed above for FD fans.  However, ID fans are more
          influenced by the operation of upstream subsystems than
          FD fans.  Accordingly, they can be involved in a great-
          er number of cascading problem sequences associated
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         with the scrubber, absorber, mist eliminator,
         heater.
                                         or re-
         These sequences are described below as these particular
         subsystems are discussed.

         Scrubber.  Scrubbers, as depicted in Gas Configurations
         I through VI of Figure 5.3-1, provide supplemental or
         primary particulate removal and supplemental SO2 remov-
         al.  The scrubber subsystem also includes presaturator
         and quench towers that condition the gas stream prior
         to SO2 absorption (see Sefation 2.4.2.2, Scrubbers/Ab-
         sorbers) .  A scrubber that is part of an SO2 scrubber-
         absorber train is generally of the venturi  (particulate
         scrubber) or spray tower  (presaturator or quench) de-
         sign.  These represent "open"  (i.e., lacking internals)
         designs that are generally not subject to plugging or
         scaling.  Variations or degradation in scrubber per-
         formance can result in a number of simple and cascading
         problem sequences.

              If the scrubber is preceded by an ESP, degradation
              in the performance oJE the ESP can lead to in-
              creased particulate {Loading to the scrubber and a
              subsequent degradation in scrubber performance.
              This can be evidenced either by increased scrubber
              pressure drop to maintain performance levels  (and
              therefore greater syjstem power consumption by the
              fans) or erosion of jscrubber internals due to the
              increased loading.

              If the fans are forced draft with respect to the
              scrubber, degradation in their performance can
              cause variations in bas volume and draft, result-
              ing in degradation oif particulate capture and SO2
              removal across the scrubber.
              Venturi scrubbers typically operate at a  turndown
              ratio of 2 to 2.5:1.  At high and  low gas volumes,
              the scrubber has a difficult time  maintaining
              performance level  (i
              cated by limitations
              scrubber to control
                    .e., load-following is compli-
                     in mechanical ability of
                     pressure drop across throat).
Subsequent degradation in particulate matter
capture and SO2 removal are experienced at these
conditions.

Degradation in scrubber performance can affect ab-
sorber performance by increased particulate matter
loading or SO2 loadibg.  Particulate loading can
result in erosion ofj internals.  This can cascade
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                                18S

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                to the mist eliminator  (resulting in plugging) and
                on to the in-line reheater  (resulting in decline
                of heat transfer efficiency); this in turn can re-
                sult in dew point corrosion to downstream subsys-
                tems of ID fans, outlet ductwork, and stack.  SO2
                loading can result in degradation of SO2 removal
                efficiency because of greater-than-design SO2
                loading entering the absorber tower.

           -    If the scrubber also provides physical condition-
                ing of the gas  (quenching or saturation to reduce
                temperature and volume), degradation in perform-
                ance can result in thermal stress damage to ab-
                sorber internals.

           -    Solids buildup at the wet/dry interface area where
                scrubber slurry contacts the gas can result in gas
                stream channeling or buildup in pressure drop,
                which can lead to degradation of scrubber tower
                performance and subsequent cascading results as
                noted above.

           Absorber.  Absorbers are depicted in every configura-
           tion shown in Figure 5.3-1  (fixed subsystem).  The
           absorber can be part of a scrubber-absorber train  (Gas
           Configurations I through VI) or as the absorber only
           (Gas Configurations VII through X).  The absorber rep-
           resents the heart of the FGD system in that the primary
           role of the FGD system is fulfilled there—the removal
           of S02 from the' flue gas.  As the focal point of the
           FGD system, the absorber is also the focal point of
           problem sequences—either as the initiating or termi-
           nating event in both simple.and cascading relation-
           ships.  A number of absorber impacts from the upstream
           subsystems of fans and scrubbers are described in the
           preceding sections.  Other significant problem sequenc-
           es are described below.

           -    Degradation in the performance of the absorber can
                lead to loss of SO2 removal efficiency and result
                in non-compliance.

           -    Degradation of absorber performance can occur due
                to a variety of contributing factors in the up--
                stream gas circuit.  They include variations in
                gas flow, resulting in tower overloading or "flood-
                ing" (high gas flow) or tower "weeping" (low gas
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               flow)*; variation!in gas  (SO2) composition,  re-
               sulting in reduce^ SO2 removal  (high S02) or
               chemistry upsets  such as high pH or soft  scale
               formation  (low SoL); degradation in upstream par-
               ticulate collection devices  (ESP and/or scrubber)
               described above;  degradation in upstream  fan
               performance described above; and degradation in
               upstream scrubber
 performance described above.
               Degradation in ab sorber performance can occur  due
               to a number of cohtributing factors in the  slurry
               feed circuit  (see Section 5.3.1.2, Reagent  Prep-
               aration and Feed) j.  Insufficient  slurry feed,  low
               slurry pH, and hijjh slurry pH can result  in low
               S02 removal,  solids accumulation  and pressure  drop
               buildup across thjs tower, solids  entrainment in
               absorber discharge gas stream, and corrosion/ero-
               sion of internalsL
               Degradation in absorber performance  (due  to  gas-
               side or slurry-sijle factors) can  affect downstream
               subsystems through a series of  simple or  cascading
               sequences.  Solids deposition on  the mist elimi-
               nator can occur through scaling or plugging.   Mist
               eliminator pressure drop buildup  can take the
               absorber out of service.   Inefficient mist elimi-
               nator performance can contribute  to carryover  of
               entrainment to thfe downstream damper(s),  reheater
               (if present), ID fans, duct, or stack.  Subsequent
               solids buildup and corrosion/erosion can  take
               these subsystems put of service.  If an in-line
               reheater exists, solids can buildup on the tubes,
               cutting down heat transfer efficiency.  Reduced
               reheater efficiency can result  in dew point  corro-
               sion to downstream ID fans, ductwork, dampers, and
               stack.
          Mist Eliminator.  Mist
          separate subsystem in
          5.3-1  (fixed subsystem)
 eliminators are shown as a
svery gas configuration in Figure
    Before proceeding, however, a
*Flooding is a condition which occurs  in a packed  tower where  gas
 flow is increased at a giveri slurry flow rate  and slurry  is
 suspended at the top of the. packing and entrained in  the  dis-
 charge gas stream.  Weeping is ja condition which  occurs in a
 tray tower wherfe gas flow is insufficient to maintain a slurry
 suspension on the trays and the slurry flows unimpeded downward
 through the tower.
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         clarification of the mist eliminator subsystem is in
         order (see Section 2.4..2.3, Mist Eliminator).  First,
         although the mist eliminator is shown as a separate
         subsystem downstream of the absorber, it is typically
         contained within the absorber tower in the proximity
         (downstream) of the slurry spray zone.  Therefore, it
         is not a separate physical entity.  Secondly, both
         scrubbers and absorbers are typically equipped with
         mist .eliminators.  In FGD systems, however, the absorb-
         er mist eliminator is of overriding importance.  Since
         the mist eliminator is, in effect, a specialized opera-
         tion within the absorber, many of the same considera-
         tions that apply to the absorber apply to the mist
         eliminator as well.  In effect, the mist eliminator is
         extremely sensitive to the mechanical and chemical
         operating aspects of the absorber.  Any upset in the
         absorber will most of the time also manifest itself in
         the mist eliminator.  Any mist eliminator outage will
         also require the absorber to be taken out of service.
         Other problem sequences peculiar to the mist eliminator
         are described below.

         -    Mist eliminator self-cleaning occurs through an
              automatic water wash system which systematically
              cleans the mist eliminator assembly.  The wash
              water is delivered through high pressure spray
              nozzles and piping.  Mechanical failure in this
              system can result in localized or generalized
              solids buildup, resulting in gas channeling and
              carryover of entrainment and/or pressure drop
              buildup across the mist eliminator.

         -    The mist eliminator wash water may typically con-
              sist of some portion of clarified liquor recovered
              from primary solids dewatering, secondary solids
              dewatering, or the 'disposal site (see Section
              5.3.1.3, Waste Solids Handling and Disposal).
              This liquor can contain high levels of dissolved
              salts which represent S02 reactants or products
              (calcium sulfite, sulfate, carbonate, chlorides,
              etc.).  Depending on concentration levels, these
              salts can precipitate and accumulate on the mist
              eliminator through physical or chemical means
              (i.e., the alkaline salts react with the residual
              SO 2 in the gas stream from the absorber, forming
              sulfite/sulfate reaction products).

              With few exceptions, the mist eliminators are
              constructed of plastic  (with or without fiberglass
              reinforcement).  These materials are subject to
              thermal stress.   (N.B. Many mist eliminators are


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               now constructed of
               high temperatures
               als are designed  [
                        materials designed to withstand
                        [400°F].  However, these materi-
                        1 guaranteed"] to withstand lim-
               ited exposures to high temperatures.  As exposure
               time accumulates, the effects of thermal stress
               begin to take place.)  In the event of a sudden
               loss of slurry or liquor feed to the absorber or
               preceding scrubber  (including quencher or presatu-
               rator), the hot gas  (300°F) may melt or disfigure
               the mist eliminator vanes.

          Reheater.  Reheaters represent an optional subsystem
          that always follows the absorber and mist eliminator
          and precede the ID fan and/or discharge ductwork and
          stack.  (Gas Configurations I, III, V, VIII, and X of
          Figure 5.3-1.)  As described in Section 2.4.2.4, three
          generic reheat strategies are used:  in-line, indirect
          hot air, and flue gas bypass.  Of these, in-line reheat
          is the most sensitive to problems because of its pres-
          ence in the gas stream,
          in upstream operations.
                        making it vulnerable to upsets
                         Upstream operations of impor-
tance are the scrubber/absorber and mist eliminator.  A
number of problem sequences involving these subsystems
affecting the reheater were described earlier.  Problem
sequences that are peculiar to the reheater alone are
described below.

     Reheater self-cleaning occurs through an automatic
     soot blowing system which systematically cleans
     the tube bundles with either steam or air.  The
     steam or air is delivered through retractable high
     pressure lances whjich rotate axially through 360
     degrees for maximum coverage.  Mechanical failure
     in this system can' result in localized or general-
     ized solids buildup, which can result in reduced
     heat transfer, downstream dew point corrosion, and
     ultimately, tube bundle failures.

     Reheater tube failures typically occur at the weld
     in the tube bend facing the discharge gas stream
     from the mist eliminator  (absorber).  A tube
     failure obviously causes a decline in the heat
     transfer to the gas, resulting in insufficient
     temperature boost (and the danger of downstream dew
     point corrosion  (ejspecially in the upper portions
     of the stack because a partial failure will show
     up at the point of maximum radiative heat loss).
     A tube failure, id not attended to immediately,
     will trigger othed tube failures in the immediate
     vicinity due to thje corrosive/erosive action of
     the heating medium) and flue gas environment.
                              .iuirj
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         -    Flue gas bypass reheat is extremely dependent on
              proper design and operation of control dampers
              regulating the flow of gas into the absorber and
              bypass duct.  Improper operation in the  form of a
              partial or a complete failure  (inability to go to
              a fully opened or closed position) can allow
              either too much or too little gas flow into the
              bypass duct  (meaning'low or high gas flows into
              the absorber, respectively).  This can cause low
              SO2 removal in the absorber  (noncompliance);
              thermal stress in the outlet ductwork and stack;
              dew point corrosion attack in the outlet ductwork
              and stack; and carryover of entrainment  to the
              outlet ductwork and stack  (scrubber-generated
              particulate matter, opacity violation, stack
              rainout).

         -    Indirect hot air reheat is extremely dependent on
              the proper flow and distribution of hot  air in-
              jected into the scrubbed gas stream to achieve the
              desired level of reheat.  This is more of a design
              consideration than an operating consideration.
              Insufficient residence time and/or mixing can
              cause an uneven (stratified) gas temperature
              profile, resulting in localized dew point corro-
              sion attack and/or localized thermal stress damage
              in the downstream ID fan  (optional), ductwork, or
              stack.

         Ductwork.  Inlet"and outlet ductwork are fixed subsys-
         tems of every configuration depicted in Figure 5.3-1.
         Many of the simple and cascading problem sequences
         associated with the ductwork .have been described in the
         preceding discussion.  A number of additional problem
         sequences associated with the ductwork subsystem are
         discussed below.  These sequences are associated more
         with design considerations than operating considera-
         tions.  A problem specifically inherent to ductwork is
         an inability to obtain a representative gas sample or
         gas flow measurement.  This could bias any manual or
         continuous monitoring performance or guarantee measure-
         ments .

         -    Insufficient or excessive cross-sectional area of
              the ductwork's inner :diameter will result in
              excessive or insufficient gas velocities, respec-
              tively, causing carryover of entrainment, settling
              out in the ducts, and ultimately, erosion or
              corrosion attack.
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              Rectangular ductwojrk  (typically observed in gas
              distribution manifplds and breeching for some
              systems) is subject more to nonuniform gas distri-
              bution than circular ductwork, causing associated
              variations in perfprmance and attendant problems
              as described in this preceding sections.  The use
              of turning vanes (jgas flow distribution baffles)
              in rectangular ductwork is beneficial, though not
              always a complete solution.
              Bends, expansions,
              also contribute to
              dant variations in
              problems.
                        and contractions in duct runs
                        nonuniform gas flow and atten-
                        performance and subsequent
         Stack.  Similar to the ductwork, the stack is also a
         fixed subsystem of every configuration depicted in
         Figure 5.3-1.  Moreover', because the stack occupies the
         tail-end of the gas handling and treatment equipment
         area, it is always the subsystem affected by a simple
         or cascading problem sequence rather than .the trigger-
                                   Much of the foregoing discus-
ing or initiating event
sion on outlet ductwork
consideration unique to
                                 also applies to the stack.  A
                                 the stack is due to its dimen-
         sions and position in the gas circuiti  Typically,
         stacks rise very high above grade.  Heights vary from
         200 ft to 1200 ft.  Present-day stack height has been
         somewhat standardized by the "Good -Engineering Prac-
         tice" of the June 1979
         specifying credit for 2
         adjacent structure (i.e
                       ISTSPS  (see Section 2.1.1.2)
                       .5 times the source or tallest
                          roughly equivalent to 500 to
600 ft above grade).  Added to this consideration is
the stack's tail-end pojsition in the gas circuit.
Unique problems associated with these considerations
are radiative heat loss in the discharge ductwork and
stack base which can caase downstream dew point corro-
         sion to the top portion
         quired degree of reheat
                        of the stack, even if the re-
                        is being achieved.  Concurrent
         considerations associated with this concern are plume
         visibility, plume rise, and pollutant dispersion.  Dew
         point corrosion to the pop portion of the stack is com-
         pounded by the inability to inspect it during routine
         operation, maintenance, or scheduled maintenance.

         Damper.  As indicated i.i Figure 5.3-1, dampers are not
         shown as a separate subsystem.  Instead, they ar"e
         associated with the operation of the subsystems of
         ductwork, fans, scrubbejrs/absorbers, and reheaters.
         Dampers are used to regiulate the flow of flue gas
         through these subsystemjs through control and isolation
         functions.  These functions are critical to the proper
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                                195

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           operation and performance of these subsystems.   Damper
           malfunctions can be either a triggering or terminating
           event in a simple or cascading problem sequence.  Damp-
           ers in the inlet or outlet ductwork are sensitive to
           the performance of upstream particulate controls or S02
           absorbers.  Degradation in performance can result in
           accumulation of solids (fly ash,  SO2 reactants  and
           products)  on damper drives and seals, causing damper
           regulation problems with associated gas control and
           leakage problems.   Gas control problems include regula-
           tion of the fan,  scrubber/absorber, and bypass  and hot
           air injection reheaters.   Leakage problems include gas
           bypass for scrubbers/absorbers during low load  or main-
           tenance situations.   Gas flow regulation problems can
           cascade into performance'degradation for the subsystems
           being served through low and high gas flows, as de-
           scribed in the preceding;sections on the various sub-
           systems in the gas handling and treatment equipment
           area.   Isolation  problems can prevent timely inspection
           and preventative  maintenance, which can ultimately
           manifest itself in major,unscheduled maintenance.
           Dampers in the absorber discharge are subject to the
           harshest operating environment.   Corrosion attack
           commonly occurs through entrainment carryover of solids
           and the collection of corrosive condensate (the solids
           carryover deposit,  forming convenient host sites for
           the collection and buildup of corrosive condensate,
           leading to pitting corrosion of the surface material).
           Entrainment carryover generally occurs as a result of
           poor mist eliminator performance,  which can be  caused
           by  poor absorber performance,  which in turn can be
           caused by poor scrubber performance.

5.3.1.2    Reagent Preparation  and Feed

     The reagent preparation and feed equipment area is described
in Section 2.4.2 (Existing Design Configurations).   As is the
case for the  gas handling and  treatment equipment area discussed

in the preceding section, the  subsystems  contained in the reagent
preparation and  feed area can  be arranged in a  variety of config-

urations.  However,  unlike the gas:handling  and treatment equip-
ment area, the number of permutations  are limited.   This  is  a
result of  process  considerations, Which represent the primary
determinants  in  the  selection  of a;subsystem configuration.   In

effect, there are  two basic configurations now  in use—one  for
lime slurry processes and one  for limestone  slurry  processes.
 SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

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These configurations differ becajuse in the former, a more  reac-

tive and pre-prepared  (calcined)) chemical additive—lime—is

used, requiring special handling! and preparation considerations.

In the latter, a less reactive chemical additive—limestone—is

used, requiring less sophisticated handling and preparation

techniques.  A simplified block diagram of these configurations

is presented in Figure 5.3-2.   |

     Figure 5.3-2 defines two basic configurations comprised of

the subsystems of receiving, conveying, bulk storage,  slurry

preparation (milling and slaking1) , and slurry distribution (prod-

uct slurry storage, product slurry feed, and slurry recircula-

tion).  Of these subsystems, only conveying, bulk storage, and

slurry preparation show a variance.

     The cause-and-effeet problem sequences which occur in the

reagent preparation and feed equipment area are described  below

by subsystem in terms of the triggering event and the  terminating

event for both simple and cascading varieties.

     0    Receiving.  Receiving and off-loading of reagent sup-
          plies to the plant car occur by river barge, rail car,
          and/or road truck.  Mojst modern-day plants incorporates
          the flexibility of receiving supplies through more than
          one mode of transportation  (in many cases, all three) .,
          Factors which govern this selection include  geographi-
          cal location, existing infrastructure, source of sup-
          ply, and mode of coal (transportation.  Although  receiv-
          ing and off-loading arje not considered sophisticated or
          specialized functions of the FGD process, a  number of
          simple problem sequences can occur.

               Weather conditions can interrupt the supply of
               reagent to the plant, especially river  barge
               deliveries during severe winter weather (freezing
               conditions).  Expended interruptions can eventu-
               ally affect FGD s|ervice time, especially if plant
               supplies are low.!  This is more of a concern for
               lime than limesto'ne because on-site bulk storage
               is limited to sto'rage silos and bins whereas
               limestone bulk storage can be accommodated  through
               large, unprotected storage piles  (typical lime-
               stone storage pile supplies 30 days of  operation).
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

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                              198

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               Weather conditions also can hamper or interrupt
               unloading operations because of frozen shipments,
               especially on ra
          Conveying.
          conveyors,
 Conveying
screw conv
           1 cars.
equipment includes covered belt
yors, and pneumatic conveyors.
the "simple" mechanical variety;
          The former two are of
          the latter uses compressed air.   Limestone is normally
          conveyed to storage by mechanical means;  lime by pneu-
          matic means.   Interruption of conveying from receiving
          to bulk storage or from bulk storage to slurry prepara-
          tion can obviously interrupt FGD operation.  However, a
          more subtle problem occurs where conveying equipment is
          shared (in order to save on capital costs).  This situ-
          ation exists at a number of coal-fired plants which use
          limestone slurry FGD.I  The coal  and limestone supplies
          share a considerable portion of  the belt conveying
          equipment.  Contamination of supplies invariably oc-
          curs.  Contamination of the limestone supply by coal
          fines may plug or erode feed equipment in the slurry
          circuit.   As a consequence, there is added potential
          for absorber plugging)or scaling.
                               j
          Bulk Storage.  Open storage piles are used for bulk
          limestone storage and}storage silos and bins are used
          for bulk lime storage]   Open storage piles are subject
          to problems of ambient environmental conditions in the
          form of freezing and precipitation (dissolution of
          reagent by water).  Silos and bins are a more expensive
          means of storage.  They can periodically experience
          flow problems such as jamming or plugging.  Lime stor-
          age bins must be weatlixerproofed  and airtight to prevent
          absorption of water and carbon dioxide from the atmo-
          sphere.  Lime storage]is much more limited in supply
          capacity than limestone (typically 100 tons per storage
          bin).  Lime storage also is generally served by more
          complex conveying equipment than limestone.  These two
          factors make lime storage a more difficult proposition
          than limestone.  Supply interruptions or conveyor
          failures can impact FGD operation relatively quickly,
          possibly causing a curtailment or interruption of oper-
          ation.  Conveyor failures can occur through the loss of
          a compressor, screw conveyor, or bucket elevator.
          Feed Bins.   Feed bins
           receive the reagent from storage
          (piles or silos)  and transfer the material to slurry
          preparation.   Feed bins are similar to storage bins and
          therefore are subject I to the same types of problems.  A
          feed bin is a somewhai more complex operation, however,
          due to the presence of dust collecting equipment, air
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          locks, and feeder.  The feeder feeds and meters the
          flow of reagent into the ball mill or slaker.  Failure
          of the bin or ancillary equipment can cause slurry
          interruption and curtailment of FGD operation.  Improp-
          er operation can impact the operation of reagent prep-
          aration equipment, causing variations in slurry product
          quality and subsequent,degradation in SO2 removal and
          absorber reliability (plugging, scaling of internals).

          Reagent Preparation.  Limestone slurry is typically
          prepared by a ball mill (Section 2.4.2.7) and lime
          slurry is typically prepared by a slaker (Section
          2.4.7.8).  A limited number of lime slurry FGD systems
          use ball mill slakers to improve slurry product quality
          (slurry particle size).  Where the absorber is con-
          sidered the central operation of the gas handling and
          treatment equipment area,  so the ball mill or slaker is
          considered the central operation of the reagent prepa-
          ration and feed equipment area.  The ball mill produces
          a  product quality of typically 90 percent minus 200
          mesh (design specifications can range from as low as 70
          percent minus 200 mesh 'to as high as 95 percent minus
          325 mesh).   The slaker produces a product quality of
          all hydrated particles of one micron or less in size.
          A  number of problem sequences associated with these
          subsystems  are noted below.

              Variations in specified chemical and physical
              properties of the  bulk reagent delivered to the
              plant  can cause degradation in ball mill or slaker
              performance.   Physical  characteristics of lime-
              stone  grindability and  lime porosity may limit
              desired  particle  size,  available particle surface
              area,  and reactivity  of final slurry product,
              which  in turn can  affect absorber SO2  removal and
              reliability (plugging,  scaling).   Chemical charac-
              teristics of  active alkali components  (CaCO3,  CaO,
              MgCO3, MgO)  and impurities (silica)  will  affect
              SO2  removal and mechanical reliability.   With
              respect  to  the  former,  insufficient active alkali
              can  limit the amount  of alkalinity  available  in
              the  slurry  liquor  to  absorb  SO2.  With respect to
              the  latter,  impurities  in  the  form  of  silica,
              dirt,  and flint can result in  an  extremely abra-
              sive slurry product which  can  erode  absorber'
              internals,  slurry  spray nozzles,  and slurry stor-
              age and  feed  equipment.  Degradation in reagent
              quality will  also  increase the quantity of bulk
              material  consumed,; resulting in a more costly  and
              more solid waste-producing operation.
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               Ball mill performance is a direct function of the
               quality of the milling surface.  The initial
               charge of balls in the mill is eroded away over
               time with use.  Degradation in slurry product
               quality will result.  Periodic recharging is
               required.  Degradation in bulk limestone quality
               (impurities) may klso accelerate mill surface wear
               and subsequent prbduct slurry quality.

               Slaker performance is a direct function of resi-
               dence time and temperature of the slaking opera-
               tion.  The mechanism by which hydration reactions
               are carried to completion require the heat of
               reaction to convert water into steam at the sur-
               face of the lime pebble.  Steam expansion plus
               slurry agitation causes reaction products to be
               carried away fromi the surface of the pebbles as
               they form, thereby exposing fresh surfaces for
               further reaction and improving reagent utiliza-
               tion.  Depending on slaker type (Section 2.4.2.8),
               retention time and temperatures range from 5 to 30
               minutes and 167 to 194°F, respectively.  Insuffi-
               cient residence time and temperatures cause inef-
               ficient particle dispersion, rapid crystal growth,
               "blinding", localized overheating, and lime loss
               through hard scale formation in the tank.  These
               effects in turn result in a poor quality slurry
               product, resulting in possible degradation of S02
               removal across th(J2 absorber, increased lime con-
               sumption, and scaling and plugging within the
               absorber tower.

               The quality of the lime slurry product is highly
               dependent on the quality of the slaking water
               used.  High concentrations of S02  products_and
               reactants and anions such as carbonate (CO^), and
               bicarbonate (HCO~j  will precipitate in the pres-
               ence of calcium aijid cause scaling.  Similarly,
               high concentrations of metal cations that will
               precipitate as hydroxide salts are objectionable.
               High chloride concentrations do not appear to be
               detrimental to the slaking process;  however,  high
               concentrations of
chlorides may increase the
               degree of chloride corrosion.   The result of using
               a poor quality slaking water is a reduction in the
               slaking rate and the production of large, dense
               particles of partially hydrated lime.   The slurry
               is more abrasive,
               attack.
thereby accelerating erosion
SECTION 5 - PERFORMANCE EVALUATION AND PRJOBLEM DIAGNOSIS/CORRECTION

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          -     The  quality  of  lime  slurry dilution water is not
               as critical  as  slaking water,  provided that com-
               plete  slaking of  the lime  slurry is accomplished
               using  high quality' fresh water.   Dilution with
               recycled water  should be satisfactory and only
               minimal use  of  fresh water as  a  blend should be
               required.  If recycled water is  used for slaking,
               recycled water  for! dilution will react with dis-
               solved anionic  species and the resulting compounds
               will precipitate  on  the suspended lime particles,
               preventing dissolution and reaction ("blinding").
               This in turn will result in a  degradation of
               performance  as  noted above.  This problem arises
               because the  pH  of slaked lime  slurry is very high
               (in  the range of  11  to 12).

               The  quality  of  the limestone slurry product is
               largely independent  of the quality of milling and
               dilution water  used.   Limestone  differs from lime
               in this regard  in that it  is much less reactive
               (i.e., much  lower pH)  and,  therefore,  dissolves
               less readily in water.   Thus,  in order to get
               sufficient alkalinity into the slurry liquor,  a
               ball mill is needed  to pulverize the limestone to
               finely ground particles and expose sufficient
               surface area to generate reactivity.   The pulver-
               ization operation supercedes any effect the quali-
               ty of  water  may have  on dissolution.   Recycled
               water, cooling  tower  blowdown, and waste water
               from other operations can  substitute for fresh
               water  without significant  impact on limestone
               slurry product  quality,  absorber performance,  and
               the  performance of other subsystems.

         Slurry Distribution.   The  slurry distribution subsystem
         includes  slurry product storage, slurry feed to the
         absorber, and slurry recirculation  within the absorber
         loop.  The  slurry distribution  network is where the
         reagent preparation  arid feed equipment area interfaces
         with  the  gas handling  and  treatment equipment area,.   As
         such, any problem sequences  which originate or cascade
         in the slurry distribution subsystem  are eventually
         manifested  in the performance of the  gas handling and
         treatment equipment  area.  A number of these problem
         sequences have been  described in the  preceding sections
         for the upstream  subsystems  in  the  reagent  preparation
         and feed  equipment area.   A  number  of additional se-
         quences peculiar  to  the slurry  distribution subsystem
         are identified below.
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

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             Lime slurry product!  storage  not  only provides
             surge volume between the  slaker  and absorber, but
             also allows time  fojr the  slurry  to "stabilize".
             Addition of dilution water to  a  concentrated slur-
             ry causes a  series
                                 of  chemical  reactions between
             the  lime and dissolved  minerals  in the water such
             as the alkaline  eau+th salts  (Group IIA metal ox-
             ides) , chlorides,  sjulfates,  and  phosphates.   These
             reactions, which are  typically completed in  less
             than 15 minutes, cg.use  the formation of hard,
             insoluble, crystalline  solids.  The primary  func-
             tion of slurry storage  is to hold freshly diluted
             slurry until these1 scale-forming reactions are
             completed.  Once completed,  the  trapped suspended
             solids are allowed(to settle out of the slurry
             before being introduced along with the slurry to
             the  FGD system.  Iii a well-designed system,  a
             large storage tank is used so that most of the
             scale compounds  ar4 present  as a suspension.  As
             additional scale compounds are formed, they  adhere
             to the suspended crystals, which increase in size
             and  eventually settle to the bottom of the tank.
             The  slurry is thenjsaid to be stabilized.  If no
             more water is adde4 and the  slurry does not  absorb
             significant quantities  of CO2 from the air,  no
             further scale reactions occur.  If insufficient
             residence time is  provided in the lime slurry
             product tank, or the  addition of dilution water is
             uncontrolled, or too  much residence time in  the
             lime slurry product tank is  provided  (increasing  .
             CO9  uptake from  the air), or if  the suspended sol-
             ids  are not allowed to  settle, the "unstabilized"
             slurry contributesjto the erosion of downstream
             transfer pumps andjpiping, decreased SO2 removal
             in the absorber, plugging and scale formation in
             the  absorber, and  possible downstream effects to
             the  mist eliminator,  reheater, ID fans, ductwork,
             and  stack.

             Limestone  slurry product storage provides surge
             capacity within  th& slurry  distribution subsystem
             in order to permit!disruptions in the operation of
             the  grinding  systeijn without  affecting the opera-
             tion of  the absorber.  Limestone slurry product
              storage  also  provides residence  time for disso-
              lution and generation of sufficient slurry, liquor
             alkalinity.   Unlike lime, limestone exhibits a
             much less  reactive!and more  buffered process
              chemistry.  Accounting for  process surge capacity
             and  limestone dissolution,  limestone slurry  stpr^-
              age  tanks  provide  a residence time of a minimum of

SECTION 5 - PERFORMANCE EVALUATION AND PFJOBLEM DIAGNOSIS/CORRECTION
                                i
                               203

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                8^hours to a maximum of 40 hours.   If residence
                time is below the minimum, or if the fresh lime-
                stone slurry "short-circuits"* the product slurry
                storage tank, the limestone slurry feed to the
                absorber may be insufficient in slurry liquor
                alkalinity,  causing degradation of SO2 removal
                across the absorber, increased limestone consump-
                tion, plugging and scaling in the  absorber, and
                cascading downstream effects in the mist elimina-
                tor,  reheater, ID fan,  ductwork, and stack.

                All  slurry distribution tanks must be sufficiently
                agitated to  keep the solids in suspension.   In the
                event of insufficient agitation or agitator fail-
                ure,  solids  will settle out and plug up discharge
                lines,  pump  intakes, and valves.

                Slurry recirculation tanks receive product slurry
                from the reagent preparation subsystem, spent
                slurry from  the absorber ("downcomer"), and,  in
                some  cases,  makeup water (process  recycle or
                fresh)'.   The slurry recirculation  tank fulfills a
                number of mechanical and chemical  functions in the
                process.   In the way of mechanical functions,  the
                recirculation tank provides surge  capacity within
                the  system to balance the operation of the  reagent
                preparation  and feed, gas handling and treatment,
                and waste solids handling and disposal equipment
                areas.   As the nexus of these equipment areas,  the
                recirculation tank represents the  logical point to
                monitor and  control process chemistry.   The
                process  chemistry parameters monitored include
                slurry  pH and percent solids.   The process  chemis-
                try variables of importance include solid phase
                residence time,  liquor  phase residence  time,  lime/
                limestone dissolution,  crystal precipitation,
                particle  size,  relative saturation,  percent oxida-
                tion,  individual cation and anionic concentra-
                tions,  and liquid phase alkalinity.   Thus,  the
                complexity of the functions of the recirculation
                tanks make it both extremely important  and  ex-
                tremely  sensitive to problem sequences  within  the
                entire process.   A number of considerations pecu-
                liar  to the  recirculation tank are enumerated
                below.
*Short circuiting is the inability of the slurry to use the
 entire residence time provided by the tank due to the position-
 ing of the inlet and outlet feed streams or insufficient back-
 mixing.                         :


SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION          ~

                                204

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              (1)
              (2)
               (3)
               (4)
               (5)
Slurry residence times of 8 to 15 minutes are
typical for lijme/limestone systems.  All
other factors being equal, the lower range
suffices for llime slurry and the higher range
suffices for Ijimestone  (due to chemical
reactivity considerations).  An undersized
recirculation tank can impair the mechanical
and chemical ajspects of process operation.
Namely, the inability to "surge", insuffi-
cient slurry alkalinity to remove SO2 in the
absorber, towqr scaling and plugging, high
reagent consumption and increased solid waste
volumes.
Improper mixinjg in the recirculation tank  can
short circuit {the available residence  time
and affect the process chemistry which in
turn can cause; reduced SO2 removal across  the
absorber, scaling and plugging  in the  absorb-
er, increased jreagent consumption, and in-
creased solid jwaste production.  Improper
mixing can occur through insufficient  resi-
dence time, tank geometry, arrangement of  .
reed and discharge streams, insufficient
agitation, and^ position of afitators  (top
entry preferred to side entry).
Open externaljtanks are  subject  to  debris
falling into the tank, which  can clog  up pump
intakes, feed {lines, and spray nozzles, and
cause inefficiency of operation  and/or com-
ponent malfunctions.  Open  tanks also  emit
slight corrosive vapors  which can eventually
rust or corrode the undersides of equipment
directly above, most notably  absorbers.

Internal tanks provide limited access  for
inspection, operation, and.  maintenance.  This
can result injthe lack of proper attention or
early detection of minor operating  problems
which can compound into  major problems (noted
above).  Noteable examples  are agitator
operation  (moior, shaft, and  blade  assembly
integrity and{lubrication), proper  liquid
level, and corrosion of  internals and  under-
sides of equipment directly above.

Cylindrical tanks contain superior  mixing
characteristics to rectangular tanks which
                   have  a higher
                   and localized
               potential for short.circuiting
               poor  mixing.   The impacts of
SECTION 5 - PERFORMANCE EVALUATION AND
                EM DIAGNOSIS/CORRECTION
                                205

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                     this  condition on process  performance are
                     noted above.
 5.3.1.3   Waste  Solids  Handling and Disposal.   The  waste solids
 handling  and  disposal equipment area is  described in Section
 2.4.2  (Existing  Design  Configurations).   Similar to the discus-
 sion for  the  previous two equipment areas,  the subsystems con-
 tained in the solids handling  and  disposal  equipment area can be
 arranged  in a variety of  configurations.  For  this  particular
 equipment area,  a  large number of  permutations are  possible.
 Figure 5.3-3  presents a summary of the various configurations
 used in commercial lime/limestone  slurry FGD systems.   Figure
 5.3-3 is  organized according to the solid waste treatment method
 used.  As indicated, three major .types of treatment methods  are
 possible—untreated, physical  treatment,  and chemical  treatment.
 Untreated is  self-explanatory.   The recirculation slurry bleed is
 handled and disposed of without the benefit of an external treat-
 ment step.  Physical treatment involves  the use of  forced oxida-
 tion to treat the  waste product.   Physical  treatment is somewhat
 of a misnomer in this context  because forced oxidation involves
 the conversion of  the unoxidized sulfite  to sulfate,  generating a
 gypsum-bearing waste product.   Chemical  treatment involves the
 use of chemical  additives  to treat the waste product.   One form
 of chemical treatment is  stabilization, which  involves the addi-
 tion of chemically non-reactive materials;  the other is fixation,
which involves the addition of chemically reactive  materials.
All the subsystem  configurations described  in  Figure 5.3-3 are
 applicable irrespective of process,  application,  and duty con-
 siderations .
     .The  cause-and-effeet  problem  sequences which occur in the
waste solids  handling and  disposal  equipment area are  described
below by  subsystem in terms of  the  triggering  and terminating
events for both  simple  and cascading  varieties.
     °    Slurry bleed.  Purging spent slurry  from  the  absorber
          slurry recirculation  loop can be  accomplished by bleed-
          ing  directly  from the slurry recirculation line or the
 SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION      ———
                                206

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 CHEMICAL
 TREATMENT
                                                                Landfill


                                                                Landfill



                                                                Landfill
Figure  5.3-3.  Waste solids handling and disposal subsystem arrangement.
                                       207

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         slurry recirculation tank.  In the former, the bleed
         line extends directly off the recirculation line on the
         discharge side of the recirculation pump(s) feeding the
         absorber.  This operation is actuated by a control
         valve.  In the latter, spent slurry is taken directly
         out of the bottom of the slurry recirculation tank
         through the use of a separate pump and discharge line.
         Both operations are controlled by monitoring physical
         and chemical parameters in the recirculation tank,
         namely—slurry liquid level, slurry pH, and slurry per-
         cent solids.  The bleed stream method is more prevalent
         due to favorable costs? however, bleeding from the tank
         offers superior process control and reliability.  A
         number of simple and cascading problem sequences are
         identified below:

              Bleeding spent slurry is controlled primarily by
              monitoring the solids content of the slurry in the
              recirculation tank to a specified level.  The
              solids control level is typically 10 percent,
              although levels as low as 5 percent and as high as
              15 percent are practiced.  In an unsteady-state
              situation, if the solids level is allowed to fall
              below the set point  (i.e., the solids level of the
              recirculation slurry is maintained below design),
              absorber process chemistry may be upset and down-
              stream solids dewatering operations may be over-
              loaded.  Absorber process chemistry upsets can
              occur through depletion of slurry alkalinity or
              depletion of slurry seed crystals.  In the former,
              SO2 removal declines? in the latter, the precipi-
              tation of SO2 reaction products declines and
              uncontrolled scaling occurs in the absorber.
              Downstream dewatering operations are sized accord-
              ing to the mass inlet loading of solids.  Continua-
              tion of unsteady-state operations above this
              design value can result in insufficient clarifica-
              tion of recovered water or subsequent overloading
              of downstream secondary dewatering equipment.  On
              the other hand, if the solids level is allowed to
              rise above the set point  (i.e., the solids level
              of the recirculation slurry is maintained above
              design), absorber operation can be affected
              through erosion of :slurry pumps, valves, and pip-
              ing and plugging and scaling of tower internals.
              Downstream operations are also affected in that
              insufficient solids loading may create too much
              water in the solid waste product for proper
              processing or dewatering.
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               Bleeding spent slurry off the recirculation line
               limits the amounij. of redundancy available to
               overcome component failure.   (Generally, the
               absorber is servejd by one main slurry recircula-
               tion line which njtanifolds into several recircula-
               tion pumps.)   A failure in the control valve can
               affect absorber performance  (as noted above) and
               upset downstream
operations  (as noted above).
               Bleeding spent slurry directly out of the recircu-
               lation tank offers more flexibility in the event
               of a component failure.  Redundancy can be provid-
               ed through spare pumps and valves, which can be
               placed quickly into operation without affecting
               absorber and downstream dewatering equipment
               performance.   In
               or no short-term
               tion feed because
               tank versus bleec
addition, a failure here  (i.e.,
               recirculation tank bleed line) would have little
effect to an absorber recircula-
 of greater surge capability of
 line.
          Forced Oxidation.  Forced oxidation involves the con-
          version of sulfite to sulfate to produce a gypsum-
          bearing waste product.'  Typically, forced oxidation is
          grouped with the chemical methods of fixation and
          stabilization.  However, forced oxidation is treated
          separately here because of its position in the process
          flow sheet.   (Forced oxidation is accomplished in the
          slurry recirculation tank before dewatering, whereas
          stabilization and fixation are accomplished after
          dewatering.)   Forced [oxidation is used in selective
          applications — exclusively limestone slurry processes
          and primarily low sulfur coal applications  (due to the*
          high degree of natural] oxidation which occurs in these
          systems).   Forced oxidation is accomplished by an air
          compressor and sparger pipe or ring situated in the
          base of the slurry redirculation tank.  A number of
          problem sequences are
noted below:
               Process chemistry upsets can reduce the efficiency
               of converting suljfite to sulfate and therefore the
               amount of gypsum 'produced.   One key variable is
               slurry pH.  Oxidajtion efficiency increases as
               slurry pH is rediiced (i.e. , becomes more acidic) .
               In the limestone slurry process, this means any pH
               approaching 5 or (below.  At high pH levels (any pH
               approaching 6 or labove), more dissolved sulfite
               precipitates out jas a solid phase salt and sulfite
               oxidation efficiency drops  correspondingly (i.e.,
               sulfite oxidation occurs in the aqueous phase
               only;  oxidation o|f the solid sulfite is extremely
SECTION 5 - PERFORMANCE EVALUATION AND PftOBLEM DIAGNOSIS/CORRECTION

                                209

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              limited).  This can have a number of ramifications
              on process operation.  Solids dewatering becomes
              increasingly more difficult  (calcium sulfite
              crystals are more difficult to dewater because of
              crystalline properties).  Solid waste disposal
              increases in volume and solid waste quality de-
              clines.  Desupersaturating the process liquor of
              SO2 reaction products declines, increasing the
              likelihood of scalihg in the absorber.
              Another key process chemistry variable is  slurry
              solids.  If an insufficient amount of seed crys-
              tals is not maintained in the slurry recirculation
              loop, gypsum desupersaturation becomes impaired,
              contributing to the likelihood of scaling  in  the
              absorber.

         -    A compressor failure or insufficient agitation  in
              the slurry recirculation tank can impair sulfite
              oxidation conversion efficiency, with consequences
              noted above.

              Solids buildup on the forced oxidation sparger
              holes at wet/dry interface can impair oxidation
              efficiency, with consequences noted above.

         Primary Dewatering..  Primary dewatering is accomplished
         by a thickener or interim pond.  Current use emphasizes
         the former.  Interim ponds, which were used extensively
         in early FGD systems, have been largely abandoned  due
         to inefficiency of clarification of process liquor
         coupled with a greater emphasis on closed water loop
         operation  (most of these: applications were solar evap-
         oration ponds  [located in arid regions of the south-
         west] used in once-through, open water loop systems).
         The thickener is an extremely problem-sensitive opera-
         tion because of its central role in balancing the
         chemistry and flow of the FGD process.  A number of
         notable problem sequences are identified below:

         -    Process chemistry upsets can alter the flow and
              composition of the  spent slurry  stream, affecting
              solids dewatering  (solids content of underflow)
              and clarification  (residual solids content in
              overflow).  Subsequent impacts  include mist elimi-
              nator cleanliness,  increased makeup water  consump-
              tion  (pump seals, mist eliminator wash,  slurry
              precipitation, slurry dilution),  increased solid
              waste production, ineffectual  secondary  solids
              dewatering, inefficient chemical treatment, and
              final disposal difficulties.
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

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             Inefficient thickening due to insufficient resi-
             dence time for settling out SO2 reaction products
             can contribute to j:he consequences noted above.
             Key design factors
             ener diameter) and
are liquid surface area  (thick-
liquid level (thickener height)
             Inefficient secondary dewatering resulting  in high
             residual solids in filtrate or centrate recycled
             back to the thickener can overload thickener
             operation.

             Inefficient thickening due to an insufficiently
             sloped bottom cone! can impair sludge blanket
             formation and solids content of underflow.

             Rake drive speed variations  (or failure)  on the
             low or high side can cause clogging of solids
             underflow stream or high turbulence in thickener
             with insufficient Clarification of overflow stream.

        Secondary Dewatering.  Secondary dewatering is accom-
        plished by vacuum filter or centrifuge.  Current use
        emphasizes the former. | The problem sequences  identi-
        fied in the foregoing for the thickener also apply to
        secondary dewatering.  {& number of special considera-
        tions which differentiate secondary and primary  de-
        watering are worth notilng.  First, the vacuum  filter
         (or centrifuge) is mechanically a more complex opera-
        tion.  Therefore, there! is a greater risk of failure or
        improper operation.- Second, however,  size and cost
        factors permit the use of spare vacuum filters which
        compensate for the higher degree of risk.

        Physical/Chemical Treatment.  Physical/chemical  treat-
        ment involves the use olf additives to  stabilize  or
        "fixate" the solid wastes prior to final  disposal.
        Stabilization involves jno significant  chemical
        reactions between the wastes and  the additive; the
        additives provide physical  stability primarily by
        increasing the solids content of  the wastes.   Fixation
        involves pozzolanic  (cejmentitious) chemical  reactions
        between the wastes and I the  additives  (e.g.,  lime,  fly
        ash) .  Some western  coa1! ashes  are  so  alkaline that
        addition of  lime  is  noii necessary for  fixation.   Fix-
        ated material  is  more often subsequently used  for
        off-site landfill where product quality  and secondary
        environmental,  impacts sire of  primary  concern.   The
        problem  sequences  in the upstream subsystems that can
         cascade  to the physical/chemical  treatment subsystem
         are noted  above.   Other notable problem sequences
         include:
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

                                211

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               Insufficient  curing time  prior  to  disposal  will
               inhibit the material's  ability  to  set up  properly
               in the disposal  site, resulting in variations  in
               landfill quality and increased  tendency for second-
               ary environmental affects associated with permea-
               tion or runoff of dissolved  chemical components.

          -    Excessive  curing time prior  to  disposal inhibits
               the handling  and transportation of the material to
               the final  disposal site.   The material can  set up
               in the curing pile or the pipe  line delivering the
               material to the  disposal  site.

          -    Variations in monitoring  of  additive chemicals or
               quality control  (such as  often  exhibited  in the
               transition from  startup to sustained operation)
               can result in stratified  variations of final dis-
               posal material.   This can limit the end use of the
               disposal site, especially in a  structural fill.

     0    Final Disposal.  Three major types of final disposal
          are available:  pond,  landfill, and  stacking.  Stacking
          (i.e., systematic  piling of  waste material above ground
          level) is applicable  only for  forced oxidation,  second-
          ary dewatering, and gypsum waste-producing systems.  To
          date, no such systems  are in commercial operation.  Of
          the pond and landfill  methods  available,  a variety  of
          types are used  in  accordance with the considerations of
          off-site/on-site,  surface/subterranean,  and minefill/
          structural fill.   A number of  problem sequences  associ-
          ated with the final disposal operation  are identified
          above.  A problem  commonly encountered  with lime/lime-
          stone slurry systems  is insufficient capacity  of the
          final disposal  site.   Conditions  which  contribute to
          this (in descending order of importance)  include open
          water loop (purging)  operation (affecting pond capaci-
          ty) , inefficient dewatering, high reagent consumption,
          high SO2 loadings  (versus design), and  underdesign  of
          disposal capacity  requirements.

5.3.2  Corrective Actions

     Following problem identification  and problem diagnosis,
corrective measures are then taken to  rectify  the problem  and
restore the FGD process to steady-state  operating conditions.  As
noted previously in this  section,  the  corrective  action  sequence
is, in many cases, a more involved procedure than a simple rever-
sal of the problem sequence.  The corrective action sequence
 SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

                                212

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                                j
generally begins by correcting the initiating or triggering
event.  The subsystems affected Jin the simple or cascading se-
quence are restored to previous operating status.  The  subsystem
manifesting the symptom or terminating event is then monitored  to
verify resumption of steady-state operation.
     Corrective sequences are described in the following  sections
for the problem sequences described in Section 5.3.1  (Problem
Diagnosis).  The approach adopted for the presentation  of this
material is to describe remedial actions for those subsystems
that are vital and unique to the operation of lime/limestone  FGD
systems.  This information is organized according to the  equip-
ment areas and subsystems described in Section 5.3.1 and  defined
in Section 2.4.2 (Existing Design Configurations).
                               i
5.3.2.1  Gas Handling and Treatment.  All of the subsystems
contained in the gas handling and treatment area are considered
both vital and unique to the operation of lime/limestone FGD
systems.  Accordingly, corrective actions are described below  for
each.
     0    Fan.  Forced draft fans tend to have a more pronounced
          cascading influence on FGD operation than ID fans due
          to their position in iihe process flow.  The triggering
          event in fan-related p!roblems is loss of upstream
          particulate collection efficiency.  Accordingly, the
          following corrective sequence is instituted:
           (1)

           (2)
           (3)

           (4)

           (5)
               Take fan out of service  (which usually  involves
               taking the absorb'er module out of  service also) .
               Remove deposits from internals and rotor.
               Repair  (weld or
               ponents.
atch) or replace failed corn-
               Rebalance fan rotor, inspect and  lubricate bear-
               ings and motor.
               Determine particulate collection  efficiency of
               upstream device via inlet/outlet  measurements  (EPA
               Method 5) to determine particle loading, particle
               size distribution, and particle resistivity.
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                213

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           (6)  Correct particulate collection device through
               mechanical modifications, flue gas conditioning,
               or possibly modifying characteristics of coal
               fired in boiler  (last resort).

           (7)  Startup fan and monitor performance via differen-
               tial pressure readings across the fan in accord-
               ance with fan performance curves provided by the
               manufacturer.      ,

          Scrubber.  Scrubbers include Venturis for particu-
          late/SO2 control and pregaturators and quenchers for
          physical conditioning of the gas stream prior to ab-
          sorption.  Venturi scrubbers may achieve insufficient
          particulate and SO2 removal.  The  following corrective
          measures may be instituted:

           (1)  Increase gas-side pressure drop across the
               scrubber through the variable-throat adjustment
               (obviously, this first step is not possible for
               fixed-throat designs).

           (2)  Increase scrubber L/G ratio by increasing slurry
               flow rate through increased pumping (increase
               output of variable-drive pumps or bring installed
               spare pumps into service).

           (3)  Measure particulate and/or SO2 removal across
               scrubber before and after throat and/or L/G ad-
               justments (EPA Method 5).

           (4)  If adjustments are insufficient, take scrubber out
               of service.

           (5)  Remove deposits from wet/dry interface areas.

           (6)  Remove deposits from slurry spray nozzles.

           (7)  Check/replace slurry spray nozzles.

           (8)  Modify slurry spray pattern through nozzle and
               piping modifications (optional, if problem per-
               sists) .

           (9)  Return scrubber to service and monitor performance
               by SO2,  particulate> temperature, pressure, and
               flow differentials across tower.

          Absorber.  Absorbers may encounter solids deposition in
          the form of plugging or scaling of internals.  Although
          plugging and scaling represent different chemical
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         phenomena, they cannot be readily distinguished by
         conventional performance monitoring.  Even visual
         inspection cannot distinguish one from the other.
         Chemical analyses of tile deposits  (and slurry  liquor)
         are generally needed.  Solids deposition is also a
         problem for open spray
         less debilitating), as
tower designs (although somewhat
solids can build up at wet/dry
         interface areas, slurry spray headers, slurry  spray
         nozzles, and various internal supports.  Solids depo-
         sition is generally remedied through the following
         corrective sequence:
         (1)  Reduce slurry pH
acidify) by small incremental
              amounts  (0.1 pH units).

         (2)  Monitor gas-side pressure drop and SO2  removal
              while reducing slurry pH.   (The time  frame  over
              which this action I is taken will vary  according to
              the system and the situation.  However, we  recom-
              mend that severalj days of continuous  steady-state
              operation be giverji to this activity.  A reduction
              in pressure drop denotes solids deposition  due to
              soft scale caused)by calcium  sulfite/calcium
              carbonate.  Lowering the pH causes the  solids to
              dissolve into the!slurry liquor.  If  pressure drop
              is not alleviated|and SO2 removal drops signifi-
              cantly during pH reduction, solids deposits may
              form consisting most likely of gypsum and possibly
              fly ash.
          (3)  Take absorber out
of service  (if pressure drop or
              SO2 removal problems persist).

          (4)  Remove solids from absorber  internals  (including
              wet/dry interface} spray headers,  spray  nozzles,
              supports)         I

          (5)  Check/replace slurry spray nozzles.

          (6)  Check/replace slurry spray headers.

          (7)  Modify slurry spray pattern  through  nozzle  and
              piping modifications  (optional,  if problem  per-
              sists) .

          (8)  Return absorber to service and monitor performance
              by measuring SO2  Removal and pressure  drop  across
              the tower ^
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         Mist Eliminator.  Mist eliminators are prone to solids
         deposition on the blades and vanes.  Solid deposits can
         occur due to plugging or scaling  ("fouling").  As noted
         previously, the mist eliminator is a specialized opera-
         tion within the absorber.  Therefore, the mist elimi-
         nator is extremely sensitive to the mechanical and
         chemical operating aspects of the absorber.  Mist^,
         eliminator fouling is generally remedied by the follow-
         ing corrective sequence:

         (1)  Measure dissolved salts in mist eliminator wash
              water.  If high in S02 products/reactants, in-
              crease amount of fresh makeup in wash.

         (2)  Increase mist eliminator wash by increasing wash
              duration  (preferred method), wash frequency  (sec-
              ondary preference), and wash rate  (final prefer-
              ence) .  Changes in the mist eliminator wash rate
              should be carefully balanced against makeup water
              consumption and closed water loop operating re~
              quirements.

         (3)  If mist eliminator pressure drop, is not reduced,
              reduce absorber recirculation slurry pH incremen-
              tally, monitoring pressure drop and S02 removal
              (see preceding discussion on absorber).

         (4)  If mist eliminator pressure drop is not reduced,
              take absorber out of service.

         (5)  Remove deposits and conduct chemical analyses.

         (6)  Inspect wash system nozzles, piping, and pump(s).
              Repair and replace where necessary.

         (7)  Measure relative saturation  (RS) of slurry.   If RS
              is in critical range, adjust process chemistry.

         (8)  Inspect mist eliminator blades for thermal stress
              and melting.

         (9)  If accessible, inspect downstream components  for
              solids carryover, qondensate collection, and  dew
              point and pitting corrosion.

         (10)  Return.absorber to service.  Monitor gas-side
              pressure drop, gas flow rate, and wash water  flow
              rate.

         Reheaters.  Inline reheaters represent the.lowest  cost,
         most efficient, but most problem prone  form of gas
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

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         reheat.  For this reason, only corrective  actions  for
         this type of reheater are discussed here.  Frequency of
         problems is due to the reheater's presence in  the  gas
         stream and its dependency on the performance of up-
         stream subsystems.  Major problems are  solids  deposi-
         tion on the tube surfaces with subsequent  corrosion/
         erosion attack to tube)bundles.  Reheater  fouling  is
         remedied by the following corrective  actions.
          (1)
          (2)
          (3)
          (4)
Monitor temperature differential of gas stream
across reheater. I If temperature differential is
less than design pr declining, check .flow and
temperature of hekting medium.  If below design,
correct and monitor gas stream temperature
differential.

If temperature differential problem persists,
investigate performance of soot blowers.  Verify
supply of soot blowing medium '(steam or air) and
              delivery  (lances)
                    If failures are observed,
correct and monitor temperature differential.

If no soot blower problems are observed, monitor
gas stream pressure drop across reheater.   If
pressure drop is breater than design, increase
soot blowing frequency.

If problem persists, remove reheater  (including
absorber) from service.
          (5)  Inspect reheater
              manually.
                 tubes for deposits.  Remove
          (6)  Inspect reheater  tubes  for  failures  (steam leaks),
              especially at welds and tube bends.   Repair
              through spot welding.   Replace  tube  bundles if
              leaks are extensive.

          (7)  Inspect tube bundles in immediate  vicinity of
              failure to determine if other failures  were trig-
              gered by initial  [failure.   Spot weld or replace,
              if necessary.

          (8)  Inspect downstream subsystems for  dew point cor-
              rosion attack.  Repair  and  replace where neces-
              sary.

          (9)  Return reheater to service.  Monitor gas-side
              temperature differential and pressure drop and
              heating medium flow and temperature.
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         Ductwork.  The outlet ductwork  (on the discharge side
         of the absorber) is the most problem-prone portion of
         ductwork in the FGD system.  This is due to service in
         saturated conditions and dependency on the performance
         of upstream subsystems.  The most prevalent problem is
         corrosion.  Corrective measures can be instituted in
         the following fashion:

         (1)  Inspect the ductwork shell for pits and cracks.

         (2)  Inspect internal liner or shell for corrosion
              attack (general or pitting) during outage oppor-
              tunities .

         (3)  Monitor emissions  (stack) for SO2, opacity, and
              acid rainout.  If SO2 measurements vary signifi-
              cantly below expectations or SO2 measurements ob-
              tained upstream, air leakage into the ductwork and
              subsequent dilution may be occurring.  If opacity
              increases or exceeds expectations or stack rainout
              is observed  (low pH condensate.in the vicinity of
              the stack), entrainment carryover may be occurring
              due to high flow rates and correspondingly high
              duct velocities.

         (4)  If these problems persist, remove duct from ser-
              vice .

         (5)  Inspect ductwork for pockets of condensate and any
              significant solids deposition.  If observed,
              sample and analyze.

         (6)  Inspect duct liner and .shell.  Patch repair where
              possible, replace sections where necessary.

         (7)  Inspect upstream reheater  (in-line tube bundles or
              mixing chamber) for failures and cleanliness of
              heat exchanger surfaces.  Maintain and repair,
              where necessary.

         (8)  If solids deposition or carryover to reheater are
              observed, inspect upstream mist eliminator for
              cleanliness and operability.  Maintain and repair,
              where necessary.

         (9)  If mist eliminator' performance is suspect, eval-
              uate operability  (mist eliminator blade assembly,
              wash system) and inspect absorber for operability
              and performance.
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        (10)   Return ductwork (and any upstream subsystems)  to
              service.   Monitor jstack emissions and measure gas
              velocities at various load levels and operating
              conditions.

         Stack.   The stack is very similar to outlet ductwork in
         terms of major problems and corrective actions.  As
         noted previously, the stack requires special considera-
         tion  because of its dimensions and location in the gas
         circuit.  If a problem is suspected, a major unit
         outage  is required to inspect the stack and stack flue,
         identify damage,  and institute corrective measures.
         Moreover, if the stack fflue liner is damaged, special
         application techniques and skills are needed for re-
         pairs.   This is a very time consuming operation.  In
         the event of a stack flue liner failure due to dew
         point corrosion attack, the following corrective action.
         sequence is instituted:

         (1)   If dew point corrosion attack in the outlet duct-
              work is observed, [similar damage to the flue liner
              is likely.
         (2)   Inspect flue liner
              outage.
                   during next scheduled unit
         (3)   If flue liner is failing or has failed, schedule
              repairs during extended unit .outage.  If failure
              is severe,  an immediate forced unit outage may be
              necessary.

         (4)   During outage, inspect upstream subsystems for
              proper operation and performance (see preceding
              discussion  on absorber, mist eliminator, and
              reheater).
         (5)
During outage, conduct engineering analysis of
liner failure determining  (at a minimum):  gas
velocities and temperature profiles, radiative
heat losses, necessity and amount of reheat,
corrosivity, and acid dew point.
         (6)   Incorporate any dejsign and operating changes in
              accordance with inspection and engineering analy-
              sis.
         (7)   Return unit to service.
         Damper.   The inability
                   >f isolation dampers to effec-
         tively seal off the absorber tower during flue gas
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

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          bypass represents the major damper operating problem.
          Solids accumulation and corrosion are typically en-
          countered.  On the inlet side of the absorber, fly ash
          is generally the cause.  On the discharge  side of the
          absorber, entrainment carryover is generally the cause.
          As described in the preceding sections, upstream sub-
          system operation must be improved.  Maintenance and
          repair to the damper itself involves cleaning and
          readjustment during a unit outage.
5.3.2.2  Reagent Preparation and Feed
     The reagent preparation and :feed equipment area contains two
subsystems that are of vital concern to overall FGD  system opera-
tion and performance.  They are the reagent preparation and
slurry distribution subsystems.  These subsystems involve the
operations of the ball mill for limestone and the slaker for lime
as well as product slurry storage, product slurry feed, and
slurry recirculation in the absorber.  Although mechanical prob-
lems associated with the preparation and transfer of the product
slurry to the absorber loop are frequently encountered, the
problem of overriding concern is the reactivity of the product
slurry.  Insufficient reactivity will affect the operation of all
downstream subsystems as well as carrying over into  the gas han-
dling and treatment equipment area and waste solids  handling and
disposal equipment area.  These effects will include insufficient
S02 removal in the absorber; scaling and plugging in the absorb-
er; erosion of pumps, piping, valves, and tanks in the slurry
distribution network; increased reagent consumption; and in-
creased solid waste production.  Using the quality of the product
slurry as a gauge, corrective measures can be instituted to
ensure adequate performance.  These measures can be  implemented
for both the reagent preparation and slurry distribution subsys-
tems per the following:
     (1)  Sample and measure the slurry at each stage in the
          preparation and distribution process.  The slurry will
          be analyzed for reactivity per the following measure-
          ments:  liquor pH, slurry solids, particle size, alka-
          linity, reaction products, dissolved salts, and inerts.

SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION      ~~
                                220

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    (2)
    (3)
    (4)
   . (5)


    (6)


    (7)


    (8)


    (9)



   (10)
If slurry reactivity is [inadequate, determine quality
of -bulk reagent with reSpect to specified chemical and
physical characteristics.  If the quality of the cur-
rent supply is determined to be inadequate, change
supply.

If bulk reagent supply is determined to be adequate,
determine quality of preparation and dilution water per
the .following measurements:  pH, carbonate, bicarbo-
nate, sulfite, sulfate, jchloride, and metal cations.
If current supply is determined to be inadequate,
change water supply by adding more fresh makeup or a
filtering step.

If water supply characteristics are determined to be
adequate, inspect the ball mill or slaker.  Typically,
ball mills and slakers operate on a batch basis  (e.g.,
8 hours for every 24-hour operating day).  Hence, there
is sufficient opportunity to empty and inspect these
         subsystems without takir
         system out of service.
                        g either them or the entire FGD
If ball mill milling surfaces are worn, take ball mill
                       1
out of service and recharge balls

If slaker "surfaces"  (paddles, agitators, rakes) are
worn, take slaker out of service and replace.

Return ball mill or slaker to service and monitor
product quality  (chemical reactivity).

If slurry reactivity is still inadequate, determine
residence times in each holdup tank.
If residence times are inadequate, vary liquid levels
(height), pumping- rates ,| and/or operating schedules to
increase residence times.

If reactivity is still inadequate, determine  sufficien-
cy of backmixing and the possibility of short circuit-
ing in the tanks.  Determine adequacy of agitation and
identify flow patterns in each tank.  If insufficient,
modify or change agitators and modify inlet/outlet feed
stream configurations.   (Product slurry and feed tanks
may not require forced outage to complete modifica-
tions; however, slurry recirculation tank will because
of its continuous mode 4f operation.)  If required,
"baffle" the tanks to improve agitation and backmixing.
         Baffles, which break up
                        the circular motion of the
         slurry, should not be attached directly to the sides
SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION

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          and bottom of the tank because solid deposits will form
          behind them, decreasing the effective volume of the
          tank and hampering slurry agitation.
    (11)  Return tanks to service^ and monitor product quality
          (chemical reactivity).
5.3.2.3  Waste Solids Handling and Disposal
     The waste solids handling and disposal equipment area con-
tains one subsystem that'is vital to overall FGD system operation
and performance—primary dewaterihg.  As noted in Section
5.3.1.3, primary solids dewatering typically is accomplished by a
thickener.  The thickener is an extremely problem-sensitive oper-
ation because of its central role in balancing the .chemistry and
flow of the FGD process.  An index of the overall performance
level of the thickener is the quality of the clarified water
(overflow) recovered by the thickener and returned to the pro-
cess.  An overflow high in suspended solids or dissolved salts
can have detrimental impacts on mist eliminator cleanliness,
product slurry quality, and absorber SO2 removal and reliability.
Concurrently, an overflow of poor quality also indicates a poor
quality underflow stream, which can cascade and affect the down-
stream subsystems of secondary dewatering, physical/chemical
treatment, and final disposal.  Accordingly, the following cor-
rective actions can be taken to resolve problems or improve
performance.
      (1)  Monitor the quality of the thickener overflow stream
          with respect to suspended solids  (typically 50 to 100
          ppm), dissolved salts  (total weight), pH, and ionic
          concentrations of calcium, magnesium, sulfite, sulfate,
          carbonate, hydroxide, and chloride.
      (2)  If thickener overflow quality exceeds specifications,
          monitor inlet  (feed) and underflow characteristics with
          respect to flow rate and solids content.
      (3)  If inlet feed stream exceeds design  flow rate or solids
          content, the thickener may be "overloaded"  (mass load-
          ing of solids exceeds design), resulting in insuffi-
          cient clarification.  Consequently,  increase thickener

  SECTION 5 - PERFORMANCE EVALUATION AND PROBLEM DIAGNOSIS/CORRECTION
                                 222

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         underflow pumping rate to increase  solids discharge
         rate and restore steady-state operation.

     (4)  If increasing thickener underflow pumping rate does not
         resolve problem or is not possible, add a flocculant  to
         improve settling characteristics  (or increase rate of
         addition if a flocculknt is already added).  Flocculant
         addition should not exceed recommended concentration
         levels  (typically 5 to 7 ppm).
     (5)  If thickener overflow
    (6)
                      quality is still determined to be
inadequate, analyze chemistry of suspended solids and
dissolved species.  Determine level of excess  (unreact-
ed) reagent, sulfite/sulfate ratio, and fly ash.  If
reagent exceeds design excess, reduce stoichiometric
ratio in absorber recirculation slurry.  If sulfite/
sulfate ratio exceeds design, investigate forced oxida-
tion system (if present) and absorber slurry recircu-
lation. loop (slurry pH, recirculation tank residence
time).  If fly ash presence exceeds expectations,
investigate the performance of the particulate collec-
tion device.

If thickener underflow stream exceeds design flow rate
or solids content (thickener overload), monitor per-
formance of downstream secondary dewatering subsystem
(if present).   Secondary dewatering may in turn be
overloaded, resulting in a poor quality filtrate or
centrate returned to the thickener.  This may in turn.
aggravate thickener problems.  Increase secondary
solids dewatering by activating installed spare  (if
present) as a temporary measure.
    (7)  If the solids content
         below design, recycle
                      of the thickener underflow is
                      underflow stream back to thick-
         ener to buildup solids inventory to proper level.  If
         this measure proves inadequate, monitor chemistry of
         thickener feed stream to determine excess reagent
         level, sulfite/sulfate ratio, arid fly ash.  If neces-
         sary, adjust as described above.

    (8)  If thickener performance is still inadequate, take
         thickener out of service.  Due to large liquid inven-
         tory, this will be a ^ime-consuming process.  Forced
         outage of FGD system may be avoided by temporarily
         bypassing thickener and going to an emergency pond or
         directly to disposal (if an on-site pond).  Inspect and
         repair and replace any components (where needed).
         Attend closely to rake drive assembly, underflow line,
         and motor drive and gear assembly.
SECTION 5 - PERFORMANCE EVALUATION AND
                      PROBLEM DIAGNOSIS/CORRECTION

                      223

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     (9)   During episodes of poor thickener performance, closely
          monitor gas-side pressure drop across the mist elimi-
          nator (solids deposition), product slurry reactivity,
          pump seals,  secondary solids dewatering, chemical
          treatment,  and final disposal.

    (10)   The physical/chemical treatment subsystem must be able
          to control  additive feed, rates in accordance with solid
          waste feed  stream characteristics.  This operation
          should be closely monitored during thickener upsets.
          This monitoring should be extended to the final dis-
          posal material to ensure1 proper curing and characteris-
          tics (permeability, compressive strength).  This can be
          accomplished through periodic core sampling and analy-
          sis.
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                            SECTION 6
                         MODEL O&M PLAN
                                • i
     This section highlights a model O&M plan  for  lime/limestone
slurry FGD systems.  The purpose of this section is  to  introduce
the field inspector to the elements of an idealized  O&M plan
which the field inspector can us
evaluate actual FGD systems.
  e as a benchmark from which to
idealized, in this context, refers
to practices that are determined
their successful application in
   to be "preferable" based upon
  specific systems throughout the
  one plan is currently in use that
industry.  To our knowledge, no
contains all of the elements discussed in this plan.
     This section is a continuation of the material introduced in
Section 2.5.3  (FGD O&M Practiced) and Section 5.2.3  (O&M).  This
section addresses the operator utility's management and staff
 (Section 6.1) at both the corporate and plant levels.  Operating
and maintenance manuals are desdribed  (Section 6.2 and 6.3,
respectively) complete with suggested outlines.  Troubleshooting
techniques  (Section . 6.4) are described in terms of an organized
multiphase program.  Spare parts requirements are described for
inventories of shelf spares  (Section 6.5).  The work order system
is described in terms of its importance for monitoring O&M re-
sponse  (Section 6.6).  Computerized tracking is discussed as a
necessary function to store, retrieve, and analyze the current
and projected status of FGD performance  (Section 6.7).
6.1  MANAGEMENT AND STAFF
     The field inspector should
management structure and staff
  be acquainted with two levels of
 organization that are prominent
SECTION 6 - MODEL O&M PLAN
                                225

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elements of an operator utility's O&M plan for an FGD-equipped
coal-fired unit.  They are corporate level and plant level.
Corporate level represents the upper management attention pro-
vided by the operator utility.  Plant level represents the O&M
attention provided by the operator utility.  These levels are
described below for the idealized O&M plan.
6.1.1  Corporate Organization
     The environmental manager at the corporate level is gener-
ally responsible for all pollution control activities and issues
for the plants within the operator utility's generating system.
Typically, the environmental manager can occupy one of three po-
sitions at the corporate level:  vice-president of environmental
affairs, manager of environmental affairs, or principal engineer
of environmental affairs.  Generally, the higher the ranking of
the environmental manager, the greater the operator utility's
commitment to FGD O&M.  Moreover, assigning this responsibility
at the vice-presidential level can free up positions at the
manager and principal engineer levels to concentrate on more
specific pollution control-related matters, with FGD representing
one specialty function.           ;
6.1.2  Plant Organization and Training
     The management structure and staff organization at the plant
level is organized in a fashion parallel to the corporate manage-
ment and structure level.  The highest position at the plant
level is the plant superintendent.  Other positions in descending
order are designated as assistant superintendent, operations man-
ager, shift supervisor, shift engineer, foreman, technician, and
support personnel.  Similar to the corporate structure and organ-
ization, the higher the ranking of the air quality control system
(AQCS) manager, the higher priority the operator utility assigns
to FGD O&M.  Moreover, assigning this level of responsibility at
the superintendent level can free;up positions at lower levels to
 SECTION 6 - MODEL O&M PLAN
                                226

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concentrate on FGD O&M.  One approach being adopted by many oper-
ator utilities is to establish aj completely separate AQCS  staff
that is organized and managed parallel to the  "power-side" staff.
This approach involves maintaining a separate  AQCS O&M staff with
its own separate job titles, functions, incentives, and promo-
tional structure.  FGD O&M can be assigned a separate function
within this structure or embody
itself.  Some of the functional
the entire FGD responsibility in
concerns associated with these
strategies are described below.
     Personnel operating and servicing the FGD system must be
familiar with the components of (the FGD system, process theory,
equipment limitations, and proper procedures for maintenance and.
repair.
     For optimum performance, ons person  (the AQCS manager)
should be responsible for the entire FGD  system O&M program.  All
requests for major repair and/or investigation of abnormal opera-
tion should go through this individual for coordination of ef-
forts.  When repairs are completad, final reports also should be
transmitted to the originating sjtaff through the AQCS manager.
Thus, .the AQCS manager will be aware of all maintenance that has
been performed, chronic or acute
 operating problems,  and any work
that is in progress.  The manager, in consultation with the oper-
ation supervisors, also can arrange for and schedule all required
maintenance.  He/she can assign priority to repairs and order the
necessary repair components, which sometimes can be received and
checked out prior to installation.  Such coordination does not
eliminate the need for certain f
cation of effort and helps to en
     The size, experience level,
of the O&M staff are significant
inctions but it does avoid dupli-
3ure an efficient operation.
 responsibilities, and training
 factors in FGD system perform-
ance.  The number of .support staff required for proper O&M of a
FGD system is a function of unit
history.  Staff requirements mus-; be assessed periodically to
 size,  design,  and operating
 SECTION 6 - MODEL O&M PLAN
                                227

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 ensure  that  the  right personnel  are  available  for  normal  levels
 of maintenance.  Additional  staff  will  generally be  needed  for
 such  activities  as  a  major refurbishing of  the FGD system.   This
 additional staff may  include plant personnel,  outside  (contract)
 hourly  laborers, or contracted personnel from  service  companies
 or PGD  equipment suppliers.   In  all  cases,  outside personnel
 should  be supervised  by experienced  plant personnel.   The servic-
 es of purchasing personnel and computer analysts may also be
 needed.  The coordinator  should  be responsible for final  accept-
 ance  and approval of  all  repairs.  Figure 6.1-1 presents  the
 general concept  and staff organizational diagram fc-r a coordi-
 nated FGD system O&M  program.
      The supervisors  and  staffing  of the absorber  (including
 reagent preparation and storage) and waste  solids  disposal  opera-
 tions should be  considered separately.   The permanent  assignment
 of key  personnel to specific work  areas will allow them to  become
 completely familiar with  the process equipment and its chemistry.
 As the  operating personnel gain  understanding  of the system, they
 will  be able to  anticipate problems  before FGD system  operations
 become  impaired.  In  addition to the normal complement of shift
 supervisors  and  equipment operators  on  the operating crew of each
 shift,  certain specialists should  be available to  assist them.
 For example,  a chemical engineer is  a valuable resource during
 atypical operating  conditions.   A  chemical laboratory  technician
 should  also  be available  to  analyze  the process chemistry in the
 event of suspected  trouble.  During  normal operations, this tech-
nician  can monitor  routine system  performance  through  sampling
 and testing  and  need not  be  dedicated full time to the FGD  sys-
tem.
     The maintenance supervisors and staff for the FGD system
must include personnel from  a number of  disciplines.   Mechanics
are needed for component  repairs.  Electricians are also needed,
as well as instrument technicians  familiar with the system.
SECTION 6 - MODEL O&M PLAN
                               228

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PURCHASING
PERSONNEL
AQCS FGD MANAGER
                                                 PLANT
                                             SUPERINTENDENT
1


1

ABSORBER/WASTE
SOLIDS DISPOSAL
OPERATIONS SUPERVISORS


\f
SHIFT (ENGINEERS)/
EQUIPMENT OPERATORS

t
LABORATORY
TECHNICIANS







T
)
'
CHEMICAL
ENGINEERS
i
f
SUPPORT





4
J

MAINTENANCE
SUPERVISORS
^

ELECTRICAL
FOREMAN
\

ELECTRICIANS
\t

SUPPORT

*

MECHANICAL
FOREMAN
V

MECHANICS
\<
SUPP

ORT
Figure 6.1-1.   Organizational  diagram for coordinated  FGD
                   system O&M  program.
                          229

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These specialists can be supported by laborers from the operating
staff.  Assignment of maintenance personnel to shift coverage
will vary with individual facilities.  Where maintenance on the
back shift is performed by "on-call" personnel, the standard
day-shift maintenance requirements, such as instrument flushing,
can be reduced.  The potential number of unscheduled maintenance
activities  (i.e., related to equipment malfunctions) must also be
considered in determining the size of the maintenance staff.
     Many plants have a relatively high rate of personnel turn-
over and, therefore, new employees are assigned to work on the
FGD system who may have had no previous contact with air pollu-
tion control equipment.  To provide the necessary technical
expertise, the operator utility must establish a formal training
program for each new employee assigned to FGD system O&M.  The
training program should include the supervisors, shift managers,
foremen, and support staff.  The time period following initial
startup and operation of the FGD system presents an excellent
opportunity for training the O&M staff.  When the FGD system is
first placed in operation, system supplier personnel are usually
available on site to ensure that the equipment is operating
properly.  During this period, all equipment should be operated
and maintained by the operator utility staff personnel under
guidance of the system supplier.  Whenever possible, written
procedures should be followed so that any error can be identified
and corrected.
     Safety is an important aspect of any training program  (see
Section 7.0).  Each person associated with the system should have
complete instructions regarding confined-area entry, first aid,
and lock-out/tag-out procedures.
     The O&M training program should also emphasize optimum and
continuous performance of the FGD system.  The staff should never
be given the impression that less-than-optimum FGD performance is
acceptable.  Redundancy is established in the system solely to
provide a margin of safety for achieving compliance during
 SECTION 6 - MODEL O&M PLAN
                                230

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emergency situations.  Once a patiern is established that allows
a nonoptimal condition to exist (i.e., reliance on built-in
redundancy), this condition then becomes the norm and the margin
of safety begins to erode.
     To reinforce the training program, follow-up written materi-
al should be prepared.  Each plan^; should prepare and continually
update an operating manual (see Section 6.2) -and a maintenance
manual (see Section 6.3) for each
FGD system.  A generic manual
usually is insufficient because each system supplier's design
philosophy varies.  The use of actual photographs, slides, and
drawings aids in the overall understanding of the system and
reduces lost time during repair work.
     Training material and courses available from the system sup-
plier should be reviewed and presented as appropriate.  Further,
responsible staff should attend workshops, seminars, and training
courses presented by the Electric Power Research Institute
(EPRI), EPA, and other organizations to increase their scope of
knowledge and keep current with the evolving technology.  A
typical FGD training program should include safety, theory of
operation, physical descriptions of equipment, review of subsys^-
tems, normal operation  (indicators), abnormal operations  (common
failure mechanisms), troubleshooting procedures, preventive and
reactive maintenance, and recordk^eping.

6.2  OPERATING MANUALS-
     Operating manuals for FGD systems should contain the follow-
ing types of information:  the operating norm or baseline of the
FGD equipment, the particular operating variables which affect
their operation, abnormal operating characteristics, safety
precautions, and step-by-step startup/shutdown instructions.  The
operating manual should also parallel the maintenance manual  (see
Section 6.3) in terms of introductory material so that the opera-
tors and maintenance staff have the same basic understanding of
 SECTION 6 - MODEL O&M PLAN
                                  31

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all the FGD equipment and their function and of the overall oper-
ating theory.  Figure 6.2-1 presents a suggested outline for a
typical operating manual.  The.introductory material of the
manual would begin with a basic description of the FGD system and
outline the major equipment areas and their associated compo-
nents.  The manual should continue with separate sections on each
of the equipment items presented in the introduction.  In these
sections, the material outlined above would then be addressed.
     The operating norm or baseline information for FGD equipment
basically describes the mechanical parameter(s) used for gauging
whether the equipment is functioning properly.  An example of
this would be electrical usage (i.e., amperage readings) for
motor driven equipment  (e.g., pumps, fans, ball mills).  The
material should also discuss the particular operating variables
which affect the equipment operation.  Each parameter should be
defined, its set point or range given, and information provided
on how that parameter is controlled.  This type of information is
helpful in identifying present or predicting future equipment
malfunctions or failures.  The manual should also list the normal
operating characteristics for each piece of FGD equipment.  These
internal/external visual aids are extremely critical for deter-
mining proper equipment performance.  With the use of these aids,
operators can possibly alleviate the problem in its earlier stag-
es before it actually manifests itself as a more serious problem
(i.e., equipment malfunction or failure).  The sections on equip-
ment should also provide step-by-step shutdown procedures and
safety precautions for each piece of FGD equipment to ensure
sequential outage of FGD equipment arid/or boilers, to aid mainte-
nance activities, to eliminate startup problems, and to ensure
worker safety.  Unless these proper startup/shutdown procedures
are followed, operation or maintenance actions could result in
either further damage to the equipment, increased emissions,
repeated failure, or in the worst case, a worker accident.
 SECTION 6 - MODEL O&M PLAN
                                232

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 I.
 II.
III.
IV.
V.
 Introduction
 A.  FGD System Description
 B.  Major Equipment Areas
 Gas Handling and Treatment Components
 A.  Fans
         Operating norm or baseline9
         Major operating variables
         Abnormal operating characteristics'
         Startup/shutdown procedures
         Safety precautions
          1.
          2.
          3.
          4.
          5.
 B.  Scrubbers/Absorbers
 C.  Mist Eliminators
 D.  Reheaters
 E.  Ductwork and Dampers

 Reagent Preparation

 A.  Reagent Conveyors and Storage
 B.  Ball Mills
 C.  Slakers
 D.  Tanks

 Waste Solids Handling and Disposal
 A.  Thickeners
 B.  Vacuum Filters
 C.  Centrifuges
 D.  Waste Processing
 E.  Waste Disposal
 F.  Pumps and Valves

 Emissions Monitoring and Process Control
 A.  Gas
     1.   Pressure (differential)
     2.   Temperature (differential)
     3.   Flow
     4.   Continuous  Emissions  Monitoring
         a.   S02
         b.   Particulate  matter
         c.   NOX
J.    Slurry
     1.   pH
     2.   Density (solids)
     3.   Flow

     Solids
     1.   Density (solids)
     2.   pH
     3.   Flow
     C.
 These  considerations  apply  to  all  items  in  Section  II,  III,  IV,  and  V.

              Figure 6.2-1.   Outline  fior  FGD Operating Manual,

-------
     The remainder of the operating manual should discuss the
operation of the continuous emissions monitoring and process
control systems.  This section would address the same factors
described above for the components comprising the two systems.

6.3  MAINTENANCE MANUALS
     Specific maintenance manuals should be developed for each
FGD system of the operator utility.  The basic elements of design
and overall operation should be specific to each FGD system and
incorporate the manufacturer's documentation and in-house expe-
rience for that particular system design.  Equipment descriptions
(vendor documentation) should be brief and to the point; long
narratives without direct application should be avoided.
     Figure 6.3-1 presents a suggested outline .for a typical man-
ual.  The manual should begin with a basic description of the FGD
system and outline the major equipment areas and their associated
components.  The manuals should continue with separate sections
on each of the equipment items presented in the introduction.  In
these sections, the following material would be presented:
     0    Detailed description of the equipment item and its
          components
     0    Equipment layout and schematics
     0    Internal/external inspection and maintenance procedures
           (i.e., inspection and maintenance checklists)
     0    Startup/shutdown procedures
     0    Safety precautions particular to that equipment item
     The equipment descriptions should show the component parts
of the equipment item.  In addition, detailed drawings and an
explanation of the function of each component and its normal
conditions should be presented.
     The material should discuss the internal/external inspection
and maintenance procedures of the equipment and components, both
 SECTION 6 - MODEL O&M PLAN
                                234

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I.    Introduction

      A.  FGD System Description
      B.  Major Equipment Areas

II.   Gas Handling and Treatment Components
III.
IV.
V.
      B.
      C.
      D.
      E.
    Fans
    1.
    2.
    3.

    4.
    5.

    Scrubbers/Absorbers
    Mist Eliminators
    Reheaters
    Ductwork and Dampers
              Component descriptions0
              Layout and schematics
              Internal/external inspection and reactive and preventative
               maintenance procedures j
              Startup/shutdown procedures
              Safety precautions
Reagent Preparation
A.  Reagent Conveyors and Storage
B.  Ball Mills
C.  Slakers
D.  Tanks

Waste Solids Handling and Disposal

A.  Thickeners
B.  Vacuum Filters
C.  Centrifuges
D.  Waste Processing
E.  Waste Disposal
F.  Pumps and Valves

Emissions Monitoring and Process, Control

A.  Gas
      C.
    1.  Pressure  (differential)
    2.  Temperature  (differentia
    3.  Flow
    4.  Continuous Emissions Mor
        a.  S02
        b.  Particulate matter
        c.  NOX
    Slurry
    1.  pH
    2.  Density  (solids)
    3.  Flow
    Solids
    1.  Density  (solids)
    2.  pH
    3.  Flow
                                       D

                                       i tori ng
 JThese considerations apply to all it
-------
 of which are extremely critical in maintaining equipment perform-
 ance.   Periodic external checks'of all equipment are required in
 order  to spot symptoms or clues which may indicate probable
 equipment/process deterioration or failure (e.g., failed expan-
 sion joint,  leaky pump).  More importantly,  however, most FGD
 equipment (e.g., absorbers,  pumps, fans)  have internal parts
 which  must be inspected and  overhauled periodically in order to
 assure that  these items continue to function properly.
     The remainder of the section on the  equipment should focus
 on startup/shutdown procedures and safety precautions particular
 to the equipment in order that it can be  inspected,  repaired,  and
 brought back on-line without harm to either  the maintenance crew
 or the equipment itself.
     The remainder of the maintenance manual should discuss the
 maintenance  and inspection of the continuous emissions  monitoring
 and process  control systems.   An additional  section  describing
 the correct  procedures for completing and processing work orders
 (see Section 6.6)  is also recommended.

 6.4 TROUBLESHOOTING TECHNIQUES
     Troubleshooting a lime/limestone FGD system requires  a
multiphase program that  should be organized  along the following
 lines.
     Phase 1;   Problem Identification.  This phase begins  with a
detailed  inspection  of the system utilizing  the  procedures de-
 scribed in Section  4.  All observations (positive and negative)
are  listed,  interpretations are developed (why things were the
way  they were),  and  finally, methods  and  items that will improve
performance  are  recommended.   Recommendations may call  for design
modifications, replacement of  components  or accessories, or the
fabrication of new equipment.
     Phase 2;  Implementation.  After thorough analysis, the
Phase 1 recommendations should be  implemented by repair and by
 SECTION 6 - MODEL O&M PLAN
                                236

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replacement with procured and fabricated components.  The system
is then started up and debugged.
     Phase 3;  Testing and Sampling.  A performance test must be
                                  of the work on system operation
conducted to evaluate the effects
 (see Section 3.3).  Testing may b = done by stack sampling and/or
measurements with the system in continuous operation.
     Phase 4;  Operational Troubleshooting.  Certain symptoms are
attributable to more than one cause.  Section 5.3  (Problem Diag-
nosis and Corrective Measures) gives typical symptoms, probable
causes, and suggested remedies.  The information presented in
this section should not be regarded as exhaustive of all possi-
bilities; no report, maintenance protocol, or operator instruc-
tion manual can take the place of
staff familiar with the equipment
6.5- SPARE PARTS
                                  a well-trained maintenance
                                  and its operating history.
     Two separate categories of spare parts can be identified—
installed spares and shelf spares.  Installed spares are redun-
dant components that are built in-:o the system.  These components
can be activated and placed into service expeditiously in the
event of a forced or scheduled outage.  .Shelf spares are compo-
nents that are stored for replacement of in-service components.
Shelf spares are considered true spare components in that they
are required to replace components that fail in service.  Accord-
ingly, the balance of this section will be devoted to a discus-
sion of shelf spares.
     An inventory of spare parts should be maintained on-site to
support the required maintenance activities.  Because all compo-
nents or subassemblies cannot be stocked, a rational system must
be developed that establishes a reasonable inventory of spare
parts.  Decisions regarding which
spare parts inventory should be based on the following considera-
tions:
                                  components to include in the
 SECTION 6 - MODEL O&M PLAN
                                237

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     1.   Probability of failure
     2.   Cost                  :
     3,
     4,

     5,
     6,
Impact on system/unit operation
Availability  (specialty or custom-fabrication item vs.
stock item)
Replacement time  (installation)
Whether the part can be stored as a component or sub-
assembly (i.e., conveyor belt assembly vs. individual
components)
     8,
Repair center  (i.e.,
capabilities)
Spatial constraints
                               in-house technical repair
     The probability of failure can be developed from outside
studies,  supplier recommendations, and past histories of the
system components.  It is reasonable to assume that components
subject to environments of erosion, scaling/plugging, corrosion,
weather, extreme and sudden temperature differentials, or wear
are the most likely to fail.  Components of this type are no
different from those in the entire FGD process, and reasonable
judgment must be used in deciding what to stock.  Maintenance
staff members should be consulted for recommendations concerning
some items that should be stocked and the number required.
Adjustments to the initial spare parts inventory can be made as
operating experience is gained and decisions are made regarding
the degree of redundancy  (installed spares) in the system.
     Another factor in defining a spare parts inventory is the
cost of individual components.  Although stocking slaker agita-
tors, 'rakes, and other slaker components may not be costly,
stocking a spare compressor for the reagent conveying system
could be quite costly.  Maintaining an extensive inventory of
high-cost items that have low probability of failure is not
justified.
 SECTION 6 - MODEL O&M PLAN
                                238

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     The impact that a failed component has on system/unit opera-
tion should strongly influence whether an item should be spared.
These components represent items which are essential to main-gain-
    FGD system/unit operation.
nents would impact FGD operation relatively quickly, possibly
causing a curtailment or total
that fall into this category in
 Non-replacement of these compo™
system/unit outage.  Components
elude spare parts of major items
comprising the reagent preparation and feed equipment area.
     The availability of the component (i.e., specialty items
versus stock items) and the time required to replace the compo-
nent are additional factors which must be considered.  If the
lead time to order a part from (the supplier is a matter of weeks
or months because, it must be specially fabricated instead of
taken directly from stock, or ijf the repair is a time-consuming
procedure, stocking such items is advantageous.
     Many operator utilities have implemented electrical and
mechanical shops (i.e., repair centers) where trained staff can
coordinate the repair or rebuilding of components to meet origi-
nal design specifications.  The establishment of such a service
                                "!            '        '
facility can greatly reduce the need to maintain component parts
or subassemblies.  In these cases, one replacement part can be
stocked for installation during
made.
retrofit applications, spatial
The number, type, and size of ;
 the period when repairs are being
     If the plant has very limited space, as is the case for most
constraints may come into play.
'pare parts .may have to be reduced
to fit the available space allcjtted for plant inventory.

6.6  WORK ORDER SYSTEMS
     A work order system is a valuable tool that allows the AQCS
manager to track FGD system performance over a period of time.
Work order and computer tracking systems  (see Section 6.7) are
 SECTION 6 - MODEL O&M PLAN
                               239

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generally designed to ensure that ;the work has been completed and
that charges for labor and parts 'are correctly assigned for
accounting and planning purposes.  With minor changes in the work
order form and in the computer programs, the work order also can
permit continuous updating of failure-frequency records and can
indicate whether the maintenance performed has been effective in
preventing repeated failures.  In igeneral, the work order serves
three basic functions:
     1.   It authorizes and defines the work to be performed.
     2.   It verifies that maintenance has been performed.
     3.   It permits the direct impact of cost and components
          data to be entered into a computerized data handling
          system.
To perform these functions effectively, the work order form must
be specific, and the data fields must be large enough to handle
detailed requests and to provide specific responses.  In many
computerized systems, the data entry cannot accommodate a narra-
tive request and specific details are lost.
     Most systems can accommodate simple repair jobs because they
do not involve multiple repairs, staff requirements, or parts de-
lays.  Major repairs, however, become lost in the system as major
events because they are subdivided into smaller jobs that the
system can handle.  Because of this constraint, a large repair
project with many components that may have a common cause appears
to be a number of unrelated events in the tracking system.
     For diagnostic purposes, a subroutine in the work order
system is necessary that links repairs, parts, and location of
failure in an event-time profile.  Further, the exact location of
component failures must be clearly defined.  In effect, it is
more important to know the pattern of failure than the cost of
the failure.
SECTION 6 - MODEL O&M PLAN
                                240

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     The goal of the work order
following items:
     0    To provide systematic
          requested work.
system can be summarized in the
screening and authorization of
          To provide the necessary information for planning and
          coordination of future work.
          To provide cost information for future planning.
          To instruct management
          of repair work.
          To estimate manpower,
          ing the repair.
 and craftsmen in the performance
time, and materials for complet-
     0    To define the equipment that may need replacement,
          repair, or redesign (work order request for analysis of
          performance of components, special study, or consulta-
          tion, etc.) .
     Repairs to the PGD system nay be superficial or cosmetic in
nature or they may be of an urgent nature and require emergency
response to prevent damage or failure.  For a typical utility PGD
system, numerous work order requests may be submitted as a result
of daily inspections or operator analysis.  Completing the jobs
in a reasonable time requires scheduling the maintenance staff
and ordering and receiving parts in an organized manner.
     For effective implementation of the work order system, the
request must be assigned a level of priority as to completion
time.. These priority assignments must take into consideration
plant and personnel safety, the
potential damage to the equipment, maintenance personnel avail-
ability, parts availability, anc
Obviously, all jobs cannot be as
potential effect on emissions,
 boiler or process availability.
signed the highest priority.
     Careful assignment of priority is the most critical part of
the work order system, and the assignment must be made as quickly
as possible after requests are received.  Ah example of a five-
level priority system is shown below in Table 6.6-1.
 SECTION 6 - MODEL O&M PLAN
                                241

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                TABLE 6.6-1.  WORK ORDER ..PRIORITY SYSTEM
Priority
                   Action
   1
   2
  3,4
Emergency Repair
Urgent repair to be completed during the day
Work which may be delayed and completed in the future
(during periods of low demand)
Work which may be delayed until a scheduled outage
     If a work order  request is too detailed, it will require
extensive time to  complete.   Also, a very complex form leads to
superficial entries and erroneous data.  The form should concen-
trate on the key elements  required to document the need for
repair, the response  to the  need (e.g., repairs completed), parts
used, and manpower expended  (see Figure 5.2-8).  Although  a
multipage form is  not recommended, such a form may be used for
certain purposes.  For example, the first page can be a narrative
describing the nature of the problem or repair required and the
response to the need.   It  is very important that the.maintenance
staff indicate the cause of  the failure and possible changes that
would prevent recurrence.  - It is not adequate simply to make a
repair and respond that "the repairs have been made."  Unless a.
detailed analysis  is  made  of the reason for the failure, the
event may be repeated several times.  Treating the symptom (mak-
ing the repair; replacing  spray nozzles, pump impellers, etc.) is
not sufficient; the cause  of the failure must be treated.
     In summary, the  following is a list of how the key areas of
a work order request  are addressed:
     1.   Date - The  date  is the day the problem was identified
          or the job  was assigned if it originated in the  plan-
          ning, environmental, or engineering sections,
     2.   Approved by - This indicates who authorized the  work to
          be completed, that the request has been entered  into
          the system, and  that it has been assigned a priority
          and schedule for response.  The maintenance supervisor
          or AQCS  manager  may approve the request, depending on
 SECTION 6 - MODEL O&M PLAN
                                 242

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   3.


   4.



   5.
        the staff and the size' q'f' the system.  When emergency
        repairs are required, tlhe work order may be completed
        after the fact, and approval is not required.
Priority - Priority is
assigned according to job urgen-
cy on a scale of 1 to 5.

Work order number - The work order request number is
the tracking control number necessary to retrieve the
information from the computer data system.

Continuing or related Work order numbers - If the job
request is a continuation of previous requests or
represents a continuing problem area, the related
number should be entered.
   6.   Equipment number - All
                       major FGD equipment should be
        assigned an identifying number that associates the
        repair with the equipment.  The numbering system can
        include major equipment area, subsystem, module, and
        component.  This numeric identification  (ID) can be
        established by using aifield of grouped numbers.  The
        purpose of the ID system is to enable analysis of the
        number of events and cost of repair in preselected
        areas of the FGD system.  The fineness or detail of the
        equipment identification system will specify the detail
        available in later analyses.

        Description of work -  The request  for repair is usually
        a narrative describing!the nature  of the  failure, the
        part to be replaced, or the work to be completed.  The
        description must be dejtailed but brief because the
        number of characters that can be entered  into the
        computerized data system is limited.  Additional pages
        of  lengthy instruction regarding procedures may be
        attached to the request  (not for computer storage).
         Estimated labor - Assignment of personnel and sched-
         uling of outages of cejrtain equipment require the
         inclusion of an estimate of man-hours, the number of
         in-house staff needed,) and whether outside.. (contract)
         labor is needed.  The more complex jobs may be broken
         down into steps, with different personnel and crafts
         assigned specific responsibilities.  Manpower and
         procedures in the request should be consistent with
         procedures and policies established in the O&M manual.

         Material requirements - In many jobs, maintenance crews
         will remove components before a detailed analysis of
         the needed materials can be completed; this can-extend
SECTION 6 - MODEL O&M PLAN
                               243

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           an outage while components  or parts are ordered and re-
           ceived from suppliers or retrieved from the spare  parts
           inventory.   Generally,  the  cause  of the failure should
           be identified at the time the work order request is
           filled,  and specific materials needs should be  identi-
           fied  before any removal effort begins.   If the  mainte-
           nance supervisor knows  in advance what  materials are to
           be replaced,  expended,  or removed, efficiency is in-
           creas'ed  and outage  time reduced.   Also,  if parts are
           not available,  orders may be  placed and the parts
           received prior to the outage.   Material requirements
           are not  limited to  parts; they also include tools,
           safety equipment, etc.

     10.    Action taken - This section of the request is the  most
           important part of the computerized tracking system.   A
           narrative description of the  repair conducted should be
           provided in response to the work  order  request.  The
           data  must be accurate and clearly respond to the work
           order request.

     11.    Materials replaced  - An itemized  list of components
           replaced should be  provided for tracking purposes.   If
           the component has a preselected ID number (spare parts
           inventory number),  this number should be included.

     Actual  man-hours expended in the repair can  be indicated  by
work order number  on  separate time cards and/or job control  cards
by craft and personnel  number.

     Copies  of  work orders for the FGD  system should be retained
for  future reference.   The AQCS manager  should review these work

orders routinely and  make design  changes or equipment changes  as
required to  reduce failure or downtime.   An equipment log  also

should be  maintained  and  the  work should be summarized and dated
to provide a history  of maintenance on the  system.


6.7  COMPUTERIZED  TRACKING SYSTEM

     Again,  it  should be  emphasized that the purpose of the com-
puterized  tracking system is  not  to satisfy the needs  of the ac-
countants  or to  state that the  plant  has such a system.  Rather,
the purpose  of  a computerized tracking system is to  provide the
necessary  information to  analyze  FGD  O&M practices  and to  reduce
SECTION 6 - MODEL O&M PLAN
                                244

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equipment failures, system/unit outages, and emission excursions.
The O&M staff and AQCS manager iriust clearly define the kinds of
data to be collected, the level of detail, and the type of anal-
ysis required prior to the purchase/lease of any computer equip-
ment and the preparation of the
software.
data-handling and report-writing
     The operator utility has many options regarding the physical
location of its computerized tracking system.  The system could
range anywhere from an in-house
personal computer  (PC) to a time-
share system by which data are input and accessed interactively
via remote terminals on either a mainframe or minicomputer.  The
operator utility may even choose^ to purchase and operate its own
computer and time-share versus leasing computer space.  The
operator utility must weigh many factors before choosing any of
the above alternatives.  The ke4- factors are the complexity of
the tracking system, number of FGD systems, computer  staff,
available software, number of users, input/output features,
available storage  space, and computer costs.
     The data base for the computerized tracking system should
contain the following type of information:  work orders, prevent-
ative maintenance  man-hours, operating parameters,  and service
hours.
      If the work completed and parts used  are  documented on the
work  orders  (see Section  5.2.3 -md  6.6) and entered into the
computerized tracking  system wi;h sufficient detail,  maintenance
and management  personnel  can easily evaluate the effectiveness  of
FGD  system maintenance.
      Preventive maintenance  (ses  Section  2.5.3.6) man-hours
versus  reactive maintenance manphours  can be compared to evaluate
the  effectiveness  of  the  current  preventive maintenance (PM)
program.  The  level of detail mLy allow tracking of the impact of
PM on particular  components  as  changes are made in  PM procedures.
The  effectiveness  of  the  PM program may be further  evaluated by
  SECTION 6 - MODEL O&M PLAN
                                245

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the required number of emergency repairs versus scheduled repairs
over a period of time  (i.e., priority 2 versus priority 5, etc.).
     In addition to tracking work orders and PM man-hours, the
computer can be used to develop correlations between unit/FGD
operating parameters and observed equipment malfunctions/fail-
ures.  Depending on the parameter type and cycles expected in
unit operation, the data may be continuously entered into the
tracking system or it may be entered from operating logs or daily
inspection reports once or twice per week.  The key parameters
for tracking FGD equipment performance should include boiler
load, coal properties  (see Section 2.2), gas flow (see Sections
3.1.1.5 and 5.2.2.1), slurry flow rates  (see sections 3.1.2.2 and
5.2.2.4), reagent consumption  (see Sections 2.3.2.1 and 5.2.2.6),
waste solids production  (see Section 5.2.2.7), and makeup water
consumption (see Section 5.2.2.8).
     Finally, equipment service time is another data item that
should be tracked so that it can be analyzed/correlated along
with the other data items.  This type of data can also be uti-
lized to evaluate overall FGD system operation through the devel-
opment of dependability factors such as FGD system availability
and reliability.
 SECTION 6 - MODEL O&M PLAN
                                246

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                              SAFETY
     The safety of agency personnel during field inspections is
of primary importance.  The fiel
3. inspector should take adequate
precautions to guard against inhalation of toxic gases, skin
irritation or chemical burns, and exposure to fugitive dust.  In
addition, normal industrial safety practices should be followed,
such as attention to electrical power lines and connections,
attention to steam lines and connections, attention to rotating
equipment, and protection againsb falling objects.  During an FGD
inspection, many of these conceris are simultaneous and can re-
sult in potentially serious injuries to the inspection personnel.
Familiarization with safety procedures and use of necessary
safety equipment can result in inspections being performed safely
without risk of injury.
     This section discusses many
dresses proper safety procedures
 of the potential hazards and ad-
   Further information concerning
safety precautions/considerations can be found in specific vendor
equipment O&M manuals for the FGD systems and subsystems, Occupa-
tional Safety and Health Administration  (OSHA) publications, and
National Institute for Occupational Safety' and Health  (NIOSH)
publications.
7.1  INHALATION OF TOXIC GASES
     There are two major classes
present in and around areas.of t
asphyxiants.
     Irritants are gases, which
mildly irritating to the eyes, t
 of toxic gases which can be
lie FGD systems:  irritants and

at very low concentrations are
tiroat, upper respiratory system,
  SECTION 7 - SAFETY
                                2j47

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and nervous system.  At higher levels, they can even cause death.
Sulfur dioxide and hydrogen  sulfide  (E^S) are both irritants
which are present in boiler  flue gas.  Sulfur dioxide is present
in much greater concentration than H-S.
     Inhalation of SO« at concentrations of 8 to  12 ppm causes
throat irritation, coughing, constriction of the  chest, and
tearing of the eyes.  A concentration of 150 ppm  is extremely
irritating and can be endured only for a few minutes.  A con-
centration of 500 ppm is acutely;irritating to the upper res-
piratory tract and causes a  sense of suffocation, even with the
first breath.  While SO? is  extremely irritating  to the eyes and
mucous membranes of the upper respiratory tract,  it has excep-
tionally good warning powers.  The normal person  can detect 3 to
5 ppm in the air.  The Threshold Limit Value  (TLV) established by
the American Conference of Governmental Industrial Hygienists
(ACGIH) establishes the airborne concentration of substances to
which persons may be exposed without adverse health effects.  The
TLV for SO2 is 5.0 ppm  (0.0005 percent by volume).
     Hydrogen sulfide is another toxic irritant which could be
present in very low concentrations in the flue gas.  Concentra-
tions of H2S as little as 100 ppm  (0.01 percent by volume) may
cause death if exposure occurs for more than a few hours.  In
lower concentrations, it is  classified as an irritant because it
inflames the mucous membranes and results in the  lungs filling
with fluid.  This colorless  gas has a characteristic rotten egg
odor.  Because the gas renders the olfactory nerve ineffective,
an inspector may be lulled into a false sense of  security not
realizing that a toxic concentration of the gas may be present.
The TLV for H-S is 10 ppm (0.001 percent by volume).
     Substances which render the body incapable of utilizing an
adequate oxygen supply are referred to as chemical asphyxiants.
Carbon monoxide  (CO) is a chemical asphyxiant which is present in
boiler flue gas.  It is formed by incomplete combustion of the
SECTION 7 - SAFETY
                               248

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coal.  Exposure to high levels-df CO can, over prolonged periods,
lead to death.  The TLV for CO is 50 ppm (0.005 percent by vol-
ume) .
     The aforementioned toxic gases can be present in potentially
dangerous concentrations in confined nonventilated areas such as
the interiors of scrubber/absorber towers and ductwork.  Although
these equipment areas may be out of service for maintenance and
appear safe for entrance, precautions should be taken prior to
internal inspection.  Isolation
closed or pressurized with adegv
dampers may not be properly
ate amounts of seal air to elimi-
nate the possibility of boiler flue gases from leaking into these
equipment areas.  Entrance should only be made upon clearance
from plant personnel who have first taken the precaution of
ventilating and monitoring the caseous concentrations within the
equipment area.

7.2  SKIN IRRITATION AND/OR CHEMICAL BURNS TO THE SKIN
                                i
     Irritation and chemical burns to the skin can result from
inadvertent contact with either
alkaline slurry or acid condensa-
tion.  Areas where possible contact with slurries can easily oc-
cur include slurry preparation equipment, slurry pipe lines and
valves, scrubber/absorber towers, and equipment used for solid
waste handling and treatment.  The inspector should be especially
aware of airborne slurry from sources located overhead.  Acid
condensation from the flue gas usually occurs.in certain internal
wet areas of the scrubber, absorber, ductwork, and stack.  Skin
contact with acidic condensation  in these areas could cause se-
vere burns.  To prevent possible  irritation or burns to the body
areas, gloves and protective clothing should be worn at all times
when entering or  inspecting  the
equipment areas noted above.  If
exposure does occur,  the affected  areas  should be washed with
water  thoroughly.
     Skin  irritation  or burns may  also result from  contact with
dust particles  depending on  their  acidic,  alkaline,  hygroscopic,
SECTION 7 - SAFETY
                               249

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 or abrasive nature.   Section 7.3 discusses potential locations of
 these dust sources in the FGD system.   Inspection personnel can
 limit skin contact area and thus prevent potential irritation by
 wearing long-sleeved shirts and gloves during internal inspec-
 tions of equipment.

 7.3  EXPOSURE TO FUGITIVE DUST
      Sources of fugitive dust include ground surfaces, surfaces
 of access scaffolds, ladders and handrails, equipment surfaces,
 and stagnant areas found within equipment.  This material can
 easily be dislodged and suspended by wind, drafts, moving equip-
 ment, or by plant and agency personnel.  Fugitive dust around the
 FGD system may consist of any or all of the following materials:
 coal dust, reagent  (lime/limestone)  particles, fly ash, gypsum
 particles, dirt, and solid waste material.  Fugitive dust is an
 irritant because of its abrasive nature (i.e., sharp-edged or
 crystalline form).  However, fugitive dust can also subject the
 eyes and lungs to chemical- damage depending on the chemical
 composition of the dust.  Of special concern are sulfuric acid
 and alkaline slurry agents.  The heaviest concentrations of coal
 dust and reagent particles exist in and around coal and reagent
 stockpiles, conveyors, storage silos; coal pulverizers, and
 reagent preparation equipment such as ball mills and slakers.
 Fly ash is normally only encountered within equipment items
 (e.g., particulate scrubbers, dampers, ductwork, fans).  However,
 fly ash may also be encountered in and around the solid waste
 disposal system  (e.g., fly ash silo, pug mill), if utilized to
 fixate or stabilize the solid waste material.  Dust consisting of
 dirt, gypsum, and dried solid waste material may be encountered
 in high concentrations in and around the waste disposal handling
 conveyors and disposal area  (e.g., stockpiles, landfill area).
 To prevent irritation, goggles and dust masks should be worn,
 especially on windy days or when inspecting equipment internals.
SECTKDN 7 - SAFETY
                                250

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7.4  NORMAL INDUSTRIAL SAFETY PRACTICES
     This section discusses normal industrial safety practices
which should be followed during plant inspections.  The field
inspector should take to the plant or obtain from plant personnel
the necessary personal protectiv4 equipment needed for conducting
the plant inspection.  This consists of safety glasses with side
shields, a hard hat, gloves, protective clothing, steel-toe shoes
with nonslip soles, and a dust mask.  As discussed previously,
some of the protective equipment
will be required only in certain
areas of the plant.  It is also advisable to remove any jewelry,
neck ties, and other loose objects prior to the inspection in
order to safeguard against moving machinery or other catch/snare
points  (i.e., jagged edges on ladders, handrails, access doors).
While conducting the inspection,
the inspector should obey plant
safety rules, not smoke, walk slowly, observe any interlock
procedures, avoid opening equipment access doors, avoid touching
or entering operating equipment,1 avoid manipulating valves or
controls, ensure that foreign objects  (e.g., hard hats) do not
fall into open tanks or thickeners, and should not try in any way
to physically change the operating characteristics of the plant
equipment.   In addition, the  field inspector  should use handrails
when using  scaffolds and steps and have both  hands free for
climbing  ladders.   Inspectors should  avoid  ladders which are
either not  equipped with safety  (pages or are  too  strenuous to
climb.  Use of a  flashlight is recommended  when inspecting inte-
riors of  different  equipment.  The field inspector should try  to
avoid poor  footing  areas;  these  include slippery  surfaces  (e.g.,
wet slurry, ice,  snow), tripping hazards  (e.g., unguarded open-
ings, hoses, tools, equipment items), and damaged or worn surfac-
es.  Finally, the field inspector should be wary  of overhead
 hazards  such as  falling objects
 head clearance areas  (e.g.,  piping,  steel supports).
(e.g.,  tools,  slurry)  and low
SECTION 7 - SAFETY
                                251

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7.
8.
                          REFERENCES
1.  Jones, D. G., et al.  Lime/Limestone Scrubber Operation  and
    Control Study.  Research Project  630-2.  Prepared  for
    Electric Power Research Institute, Palo Alto, California.
    1978.                       I
                                I
2.  Smith, E. O., et al.  Lime  FGD Systems Data Book - Second
    Edition.  CS-2781.  Research Project 982-23.  Prepared for
    Electric Power Research Institute, Palo Alto, California.
    January 1983.

3.  Smith, E. O., et al.  Limestone FGD Systems Data Book.
    CS-2949.  Research Project  1857-1.  Prepared for Electric
    Power Research Institute, Palo Alto, California.   March
    1983.

4.  Rosenberg, H., et al.  Lime FGD Systems Data Book.   FP-1030.
    Research Project 982-1.  Prepared for Electric  Power Re-
    search Institute, Palo Altol California.- May 1979.

5.  Henzel, D. S., et al.  Limestone  FGD Scrubbers  Users Hand-
    book.  Prepared for U.S. Environmental Protection  Agency,
    Industrial Environmental Research Laboratory, Research
    Triangle Park, North Carolina.  April 1981.
                                !
                             ilu
Kenney, S. M., et al.  Failure Mode Analysis for Lime/
Limestone FGD Systems.  Voliitne I - Description of Study and
Analysis of Results.  Prepared for U.S. Department of Energy,
Morgantown Energy Technology Center, Morgantown, West
Virginia.  DOE/METC/84-26  (DE84011958).  August 1984.

Jahnke, J. A., and G. J. Aldina.  Continuous Air Pollution
Source Monitoring Systems.  Prepared for U.S. Environmental
Protection Agency, Environmental Research Information
Center, Research Triangle Park, North Carolina.  EPA-625/6-
79-005.  June 1979.

Delleney, R. D., and P. K. Beekley.  Process Instrumentation
and Control in SO, Scrubbers.  CS-3565.  Research Project
2249-1.  Prepared for Electric Power Research Institute,
Palo Alto, California.  June 1984.
REFERENCES
                               R-l

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                     REFERENCES (continued)
10.
11,
12,
13,
Kashdan, E. R., and M. B. Ranade.  Design Guidelines for an
Optimum Scrubber System.  Prepared for U.S. Environmental
Protection Agency, Environmental Research Information
Center, Research Triangle Park, North Carolina.  EPA-600/7-
79-018.  January 1979.

Melia, M. T., et al.  Utility FGD Survey, July 1982 - March
1983.  Volume 2:  Design and Performance Data for Operational
FGD Systems.  CS-3369.  Research Project 982-32.  Prepared
for Electric Power Research Institute, Palo Alto, California
and U.S. Environmental Protection Agency, Industrial
Environmental Research Laboratory, Research Triangle Park,
North Carolina.  April 1984.
Steam Electric Plant Factors.
Washington, D.C.  1983.
National Coal Association,
U.S. Environmental Protection Agency.  Compilation of the
Air Pollutant Emission Factors.  3rd ed.  (including Supple-
ments 1-13).  AP-42.  Research Triangle Park, North
Carolina.  1977.

Vuchetich, M. A., and R. J. Savoi.  Electrostatic Precipita-
tor Training Program and Operation and Maintenance Manual
Development at Consumers Power Company.   In:  Proceedings
Conference on Electrostatic Precipitator  Technology for
Coal-Fired Power Plants.  EPRI CS-2908.   April  1983.
 REFERENCES
                               R-2

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                            APPENDIX A
                     GLOSSARY OF TERMINOLOGY
APPENDIX A - GLOSSARY OF TERMINOLOGY
                                A-l

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                           GLOSSARY OF TERMINOLOGY
acfm (actual cubic feet per minute) - A gas flow rate expressed with respect
to operating conditions (temperature and pressure).
Absolute humidity  - The weight (or mass) of water vapor in a gas water-
vapor mixture per unit volume of space occupied.
Absorber - General term for those gas/liquid contacting devices designed
primarily for the removal of SO  pollutants.
                               X
Absorption - The process by which gas molecules are transferred to a liquid
phase during scrubbing.
Additive reagent - That particular chemical compound or element which is
added to the FGD process as an additional reagent to promote improved process
operation (see process additives).
Agitator/mixer - A slowly rotating rake, or set of blades or paddles fastened
to a shaft and motor, used in tanks and thickeners to promote completion of
chemical reaction, maintain underflow solids in a fluid state, maintain a
homogenous slurry, or rake underflow solids to a center discharge sump.
Alkaline fly ash scrubbing - An FGD process that uses the alkaline constit-
uents of fly ash collected from the burning of western coals as the primary
absorbent.
Alkalinity - Represents the amount of carbonates, bicarbonates, hydroxides,
or phosphates contained in the water, scrubber liquor, or wastes.
Ambient - Pertaining to the conditions (pressure, air quality, temperature,
etc.) of the surrounding environment of ;a plant or scrubbing system.
Annual outage - A scheduled period of time (generally four to six weeks) set
aside by the utility once per year to shut down the boiler and/or FGD system
for inspection and maintenance.
Atomizer - A device used to disperse a liquid (water/slurry) into a gas
stream by reducing the liquid into a fine spray.
Axial flow fan - A mechanical air mover that consists of propeller-like
blades rotating in a plane perpendicular to the gas stream about a shaft
resting in a plane parallel to the gas stream.
                                     A-2

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Ball mill - A rotating drum loaded wi
slurry materials, such as limestone,
cient chemical reactivity.
 th steel balls that is used to crush and
 to. a particle size suitable for effi-
Base load - A generating station whicjh is normally operated to take all or
part of the normal load of a system and which, consequently, operates at a
constant output.

Blanketing plate -.The simplest of dahipers consisting of a steel plate which
is bolted into place to close off and! isolate ducts and/or scrubbers.

Blinding (reagent) - A phenomenon where chemical reaction of a reagent par-
ticle in a scrubbing slurry is primarjily limited to the surface of that
particle so that less than 100 percent of the reagent molecules within the
particle are exposed to the gas moleclules that are to be collected.
Bottom ash - Heavy solid particles of
bottom of the boiler.
  noncombustible ash that fall to the
British thermal unit (Btu) - The amoupt of heat required to raise the tem-
perature of one pound of water one degree Fahrenheit, averaged from 32° to
212°F.

Butterfly damper - A damper consisting of a simple plate that opens or closes
by turning the plate parallel or perpendicular to the gas flow.
Bypass reheat - A system which boosts
  the temperature of the saturated flue
gas leaving an F6D system above dew pbint by ducting a slip stream of parti-
cle-cleaned flue gas from the ESP exit duct past the F6D system to the ab-
sorber outlet duct or directly to the
acid rainout.
Byproduct (recoverable byproduct) -
regenerable-type FGD systems.
  stack, preventing stack damage from
Saleable materials produced by various
Capacity factor - The ratio of the average load on a boiler for the period of
time considered to the capacity rating of the boiler (actual kWh produced/
theoretical kWh produced x 100).     I

Carryover - Entrained solids, slurry droplets, and/or mist that leaves with
the flue gas stream exiting a particular stage of a scrubber or absorber.

Centrifugal fan - An air mover consisting of a drum of blades or slat-type
vanes aligned parallel to the entering gas stream that rotates rapidly about
an axis also parallel to the entering]gas stream, casting the gas outward
into the housing and through an exiting duct connected tangentially to the
housing.
                                     A-3

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Centrifuge - A drum and worm gear type machine that separates solids from the
entering slurry stream by centrifugal force as the drum and gear rotate at
slightly different speeds.

Chloride - A compound of chlorine with another element or radical.

Closed water loop - The water loop of an F6D system is closed when the fresh
makeup water added exactly equals the evaporative water loss leaving via the
stack and the water chemically or physically bonded to the sludge product.

Cpcurrent flow - The process in which absorbent liquor or slurry enters the
absorber from the same direction as the gas stream so that S02 collection
occurs as the gas and liquid pass simultaneously through the lower absorber.

Cold-side ESP - An ESP located downstream of the boiler air preheater.

Combination tower - An absorber that consists of a combination of two or more
types of absorbers within the same tower such as a level of sprays followed
by a level of absorber packing material (spray/packed type combination tower).
                                       ',
Configuration (horizontal/vertical mist eliminator) - A horizontal configura-
tion is one in which the mist eliminator lays across the vertical duct or
absorber tower with the wet gas rising up through the mist eliminator.  A
vertical configuration is one in which the mist eliminator is fastened ver-
tically in a horizontal duct run downstream of the absorber tower.
Continuous analyzer - Gas or liquid monitoring devices which automatically
take readings or measuremen'
continuous stack monitors).
take readings or measurements on a continual basis (e.g., SO , NO , 02, etc.
   . •       _».  i     • .•_   \                                  /\/\
Cooling tower blowdown - The wastewater characterized by high concentrations
of soluble salts periodically purged from the boiler cooling tower and some-
times used as makeup for the FGD system.

Corrosion - The deterioration of a metallic material by electrochemical
attack.

Countercurrent flow - The process in which abs-orbent liquor or slurry enters
the absorber tower from the opposite direction of the gas stream so that S02
collection occurs as the gas and liquid collide in the tower.

Crosscurrent flow - The process in which absorbent liquor or slurry enters
the absorber perpendicular to the gas stream flow so that S02 collection
occurs as the gas and liquid paths intersect.

Cycling load - A generating station which is operated continuously but fluc-
tuates its load throughout a given day based on electrical demand.

Cyclone - A piece of air pollution hardware used for particle removal that
uses centrifugal separation to effect particle collection.
                                     A-4

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Damper - A plate or set of plates or |1 Olivers  in a duct used to stop or  regu-
late gas flow.                       i
Density meter - Electronic device used to measure fixed density  (mass per
unit volume).

Dewpoint - The temperature at which Vapor contained in saturated flue gas
begins to condense.
Direct combustion reheat - A flue gas
                                 reheat system that boosts the tempera-
ture of the saturated gas from the absorber above dewpoint; this is
accomplished by injection of the hot
non-saleable waste from an FGD system
mine filling, etc.
                                combustion products generated by oil or
gas reheater burners into the gas stream.

Disposal (also referred to as waste disposal) - Removal of and discarding of
                                 in the form of ponding, landfill ing,
Dolomite (dolomitic lime or limestone) - A crystallized mineral consisting of
calcium magnesium carbonate (CaMg(C03i)2).
Efficiency - Ratio of the amount of a
                                 pollutant removed to the total amount
introduced to the normal operation.

End product:

     Salable - The S0§ removed from tjhe flue gas is recovered in a usable or
Salable - The SO, removed from td
marketable form (e.g., gypsum).
     Throwaway - The S02 removed from' the flue gas is not recovered in a
     usable or marketable form, and tjhe resulting sulfur-bearing waste prod-
     ucts must be disposed of in an environmentally acceptable fashion.

Entrainment - The suspension of solids, liquid droplets, or mist in a gas
stream.
Equivalent scrubbed capacity (ESC) -
equivalent MW based on the percent of
                                The effective scrubbed flue gas in
Erosion - The action or process of wearing away of a material by physical
means (friction).
ESP (electrostatic precipitator) - An
particles from an exhaust stream by i
and then collecting them on opposite!,

Excess air (percent) - The percentage
excess of that theoretically required
                                 air pollution device used to remove
                                m'tially charging them with electrodes
                                y charged plates.

                                 of air supplied for combustion in
                                 for complete oxidation.
                                 flue gas scrubbed by the FGD system.
                                     A-5

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Expansion joint - A small section of ductwork or piping that is designed to
passively expand or contract as required by the flexing of more rigid duct
runs, piping, or pieces of equipment as such components are exposed to vary-
ing external and internal temperatures.

Fan - A piece of equipment designed to move air by creating a high or low
pressure through mechanical means.

FD (forced draft) - A fan or blower used to produce motion in an enclosed
stream of gases by creating a positive pressure in the stream, effectively
pushing it through the system.

Feedback control - An automatic control system in which information about the
controlled variable (S02, temperature, pH, etc.) is fed back after scrubbing
has taken place and is used as the basis for control of the process variable
(reagent feed, steam, etc.).

Feedforward control - An automatic control system which measures an upstream
process variable (gas flow rate, temperature, slurry flow rate, and/or pH,
etc.) and compensates immediately without waiting for a change in the con-
trolled variable (S02, temperature, pH, etc.) downstream to indicate a change
has occurred.

FGD (flue gas desulfurization) -  The process by which sulfur is removed from
the combustion exhaust gas.

FGD battery limits - An  imaginary boundary that encompasses all equipment,
ponds, special liners, etc. that would not otherwise be installed if an FGD
system was not required.

Fixation - Increasing the chemical stability of FGD waste through chemical
means such as addition of alkali, alkaline fly ash, etc. usually in conjunc-
tion with dewatering and blending of inert solids; or through the use of
commercial processes (e.g., POZ-0-TEC, Calcilox, etc.) to produce a chemi-
cally stable solid.

Fly ash - Fine solid particles of noncombustible ash carried out of the
boiler by the exiting flue gas.

Forced outage - The FGD  system is taken out or forced out of service to make
necessary repairs or modifications regardless of boiler availability such
that the system is unavailable for service.

Forced oxidation - A process  in which sulfite-containing compounds are fur-
ther oxidized to sulfate compounds by aeration with air or pure oxygen to
promote dewatering, ease of handling, and/or stability in the waste product.

Gas contacting device.-  Grids, balls, marbles, trays, rods, or other obsta-
cles in the gas path within a scrubber/absorber intended to effect intimate
mixing and promote the gas-liquid transfer of S02 to the scrubbing liquor or
slurry.
                                     A-6

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 Gas/liquid distribution (in absorber scrubber) - The presence of random
 mixing of flue gas with scrubber liquor throughout a wet scrubbing device
 without the occurrence of static pockets or streams of uncontacted gas and
 liquor.                            |

 Guillotine damper - A damper whose bperation is characterized by a vertical
 or horizontal sliding gate or plate resembling a guillotine as it is moved
 into and out of the gas path.

 Heat exchanger - Device used to transfer sensible and/or latent heat from one
 stream of material to another to raise or lower the temperature of one of the
 materials.
 Heat rate - A measure of generating
                                    station thermal efficiency, generally
 expressed in Btu per net kilowatt-hour.   It is computed by dividing the total
 Btu content of fuel  burned for electric  generation by the resulting net
 kilowatt-hour generation.
 Hot-side ESP  -  An  ESP located immedi
 heater.
                                    ately upstream of the boiler air pre-
 ID  (induced  draft),-  A fan  used  to  move  an  enclosed  stream of gases  by creat-
 ing a  negative  relative pressure in the  stream to  pffprtiviaiv Hraw tho nac
ing a negative relative pressure in
through the system.
the stream to effectively draw the gas
 Indirect  hot  air  - A  flue  gas  reheat  system  in which  reheat  is  achieved  by
 heating ambient air with an external!  heat  exchanger using  steam at  tempera-
 tures of  350°  to  450°F.             '
 In-line  reheater  - A heat exchanger
                                    installed in the wet flue gas duct down-
              _ ____       	~  —-.„. . w . . ^ v .  • • • w WM • i X-w  ill  IfllV* TV V_ I*  I IUG MUW UU\*> l« VlwWIl
stream of the mist eliminator, usually consisting of hot water or steam coils
used to boost the wet  flue gas tempejrature above dewpoint.

Knock-out tray - A wash-tray  type prje-mist eliminator using valve or bubble-
cap type mechanisms to capture the b'ulk of the entrained solids, droplets,
and mist carrying over from the scrubber/absorber of an FGD system.

Landfi11 - A method of waste  disposal in which the dried FGD byproduct wastes
are dumped and packed, or buried betjween layers of earth near ground level or
below ground level.                 i

L/G ratio (liquid-to-gas ratio) - The ratio of the total liquid exposed to
the gas stream in an FGD system (in 'gallons) to the inlet gas flow rate (in
increments of 1000 acf).

Liner - A metal, organic, or  inorganic type material applied to a shell of an
FGD system component which is intended to protect the shell from abrasion,
heat, and/or corrosion.

Load factor - The ratio of the averaje load in kilowatts supplied during a
designated period to the peak or maximum load in kilowatts occurring in that
period.
                                     A-7

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 Louver  damper  - A  damper  consisting  of  several blades each pivoted about its
 center  and  linked  together  for  simultaneous operation.

 Makeup  water - Water added  to an  FGD system to maintain a certain slurry
 solids  level by making up for water  losses resulting from evaporation and
 exiting waste  streams.

 Mechanical  dewatering equipment - Devices used to decrease the moisture level
 of  FGD  waste to the point where the  material can be handled more easily and
 disposed of as a stable solid suitable  for landfill (e.g., vacuum filter,
 centrifuge, hydrocyclone, etc.).

 Mist  -  Dispersion  of relatively large liquid particles in a gas stream,
 carryover from a gas-liquid contact  operation.

 Mist  eliminator -  A piece or section of pollution hardware used to remove a
 dispersion  of  liquid particles  from  a gas stream.

      Precollector  - A mist  eliminator that directly follows the scrubber/
      absorber  and  is intended to  remove the bulk of the entrained solids,
      water  droplets, and  mist from the  flue gas stream.

      Primary collector -  A  mist eliminator that removes entrained solids,
      water  droplets, and  mist not collected by the precollector.

 Mist  eliminator passes/stage -  The number of direction changes the gas stream
 must  make before it exits the mist eliminator stage.

 Hist  eliminator stages -  The number  of  individual mist eliminators (e.g., 2-
 stage mist  eliminator - bulk separator  followed by an impingement collector).

 Mist  eliminator vane angle  - The  angle  measured between the intersection or
 vertex  of any  two  interconnecting vanes.

 MW  (megawatt)  - Unit used to describe gross or net power generation of a
 particular  facility.  One watt  equals one joule per second.  One megawatt
 equals  106 watts.                       \

 New (as opposed to retrofit for FGD  systems) - FGD unit and boiler were
 designed at the same time,  or space  for addition of an FGD unit was reserved
 when  the boiler was constructed.

 NO  - A symbol meaning oxides of  nitrogen (e.g., NO and N02).
^™"™""V\                                     ^

 NSPS  (New Source Performance Standards) - Environmental  regulations that
 apply to a new installation, referring  primarily to the Federal NSPS that
 applies to  installations beginning construction on or after August 17, 1971.

 Opacity - The  degree to which emissions reduce the transmission of light and
 obscure the view of an object in  the background.
                                     A-8

-------
Open water loop - The water loop of an FGD system is open when the fresh
makeup water added exceeds the evaporative water loss leaving via the stack
and the water chemically or physicall^ bonded to the sludge product.
                                      \
Outage - That period of time when thejboiler and/or FGD system is shut down
for inspection and maintenance.  Outages may be either forced or scheduled.
                                      !

Overflow (also supernatant) - The cle^r liquor that is drawn from the top of
settling tanks (e.g., thickener) or settling ponds.

Oxidation - A chemical reaction in which oxygen unites or combines with other
elements or compounds in an FGD system (primarily with respect to the sulfite-
sulfate reaction).

Packed-bed absorber - A piece of pollution equipment using small plastic or
ceramic pieces, with high surface are4-to-volume ratios, for intimate contact
between liquid and gas for mass transfer of a pollutant.

Particulate matter - Finely divided solid particles entrained in the gas
stream (fly ash, coal fines, dried reaction byproducts, etc.)
Peak load - A boiler that is normally
mum load periods.
 operated to provide power during maxi-
Perforated tray absorber - Pollution dontrol equipment that passes the un-
treated gas through holes in a series(of plates on which liquid flows, caus-
ing an intimate contact between phases by breaking the gas flow up into
bubbles.

pti - The hydrogen ion concentration of a water or slurry to denote acidity or
alkalinity.

pH meter - Electronic instruments which measure the potential difference
between a reference half-cell electrode and an indicator electrode sensitive
to hydrogen ions.

Plume (stack plume) - The visible emission from a flue (stack).
T
ppm (parts per million) - Units of concentration that in wastewater applica-
tions is equal to milligrams per liter and in air pollution applications is
equal to moles of pollutant to million moles dilutent.

Preheater - Heat transfer apparatus through which ambient air is passed and
heated by higher temperature boiler f
 ue exhaust gases for boiler combustion.
Presaturator - An external vessel or section of incoming flue gas ductwork
prior to the main scrubbing vessel where hot flue gas is presaturated.

Pressure drop - The difference in force per unit area between two points in a
fluid stream, due to resistive losses in the stream.
                                      -9

-------
 Process  additives  - A chemical  compound or element which  is added to the
 process  or  normally found with  the main process  reagent in small quantities
 (e.g., Mg,  adipic  acid) to promote improved process operation  (e.g., scale
 reduction,  increased S02 removal efficiency).

 Process  type - The generic name for the FGD process based on the absorbent
 used  (e.g., lime,  limestone) except for a few specialized processes which are
 referred to by patented titles.

 Pug mill - A mechanical device  used for blending ash and/or other dry solid
 materials with FGD waste to enhance its handling characteristics for disposal
 purposes.

 Quencher - The inlet portion of the main scrubbing vessel where hot flue gas
 is cooled and saturated.

 Reagent  - The substance which contains or produces the desired reactant
 reagent  material utilized by an FGD process for pollutant removal (e.g.,
 lime, limestone).

 Reagent  preparation equipment - Equipment and/or mechanical devices involved
 in the handling and preparation of the scrubber reagent (slakers, wet ball
mills, pug mills,  etc.).

Reagent  utilization (also utilization) - That fraction of reagent material
 (e.g., lime, limestone) fed to  the FGD system which is consumed (utilized)
and chemically converted into product material (e.g., CaS03, CaSO^, etc.).

Reheater - Device  used to raise the temperature of the scrubbed gas stream to
prevent  condensation and corrosion of downstream equipment, avoid visible
plume, and/or enhance plume rise and dispersion.

Relative humidity  (also relative saturation) - The ratio of the weight (or
mass) of water vapor present in a unit volume of gas to the maximum possible
weight (or mass) of water vapor in unit volume of the same gas at the same
temperature and pressure.   The term "saturation" refers to any gas-vapor
combination, while "humidity" refers specifically to an air-water system.

Removal  efficiency:

     Particulate matter - The actual  percentage of particulate matter removed
     by the emission control  system (mechanical  collectors,  ESP, or fabric
     filter and FGD) from the untreated flue gas.
     SO, - The actual percentage of SO,
     system.
removed from the flue gas by the FGD
                                     A-10

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      Total  unit design  - The designed  percentage  of mass  of S02  or  particu-
      late matter entering the stack to. the  mass of the  material  in  the  flue
      gas  exiting the  boiler regardless of the  removal efficiency of an  indi-
      vidual  component or the percentage of  the exiting  flue gas  actually
      being  scrubbed.
 Residence  time  -  The  amount  of time
 a  pollution  control device.
                                      unit volume of gas or liquid spends in
 Retrofit  -  The  FGD  unit will  be/was  added  to  an  existing  boiler  not  specif-
 ically  designed to  accommodate  an  FGD  system.

 Rod  deck  absorber - Gas/liquid  contacting  device used for pollutant  removal.
 Untreated flue  gas  is  contacted counllercurrently with slurry with mixing
 being aided by  decks of cylindrical  rods positioned perpendicular to the gas
 and  liquor  flows.

 scfm (standard  cubic feet per minute)  - Units of gas flow rate at 60°F and 1
 atmospheric pressure.
Saleable end product - Any material Produced from the byproducts or inlet
materials of an FGD process, the original purpose of which is pollutant
removal, which can be resold (e.g., gypsum).
Saturated - The situation when a gas
                    No additional amount
certain substance.
under the given conditions.
or liquid is filled to capacity with a
    of the same substance can be added
Saturation tempera t u re - The temperature to which flue gas drops when it is
saturated by scrubbing in a wet FGD system.

Scale - Deposits of slurry solids (calcium sulfite or calcium sulfate) that
adhere to the surfaces of FGD equipment^particularly absorber/scrubber
internals and mist eliminator surfaces!
Scheduled outage - A planned period of time set aside periodically for in-
spection and maintenance of the boiler and/or FGD system.
Scrubber - A device that promotes the
                                      removal  of pollutant particles  and/or
gases from exhaust streams of combustion or industrial processes by the
injection of an aqueous solution or slurry into the gas stream.

Settling pond - Waste dewatering ponds which generally are not preceded by
dewatering equipment.  Absorber bleed
the pond and supernatant drawn off at
absorber reuse.  Settling ponds may o

Slaker - Mechanical devices which sla
oxide into calcium or magnesium hydroxide alkali.
                                      is  normally  introduced  at  one  end of
                                      the other  end  and  recycled back  for
                                      may not be  final  disposal  areas.

                                     
-------
Sludge - The material containing high concentrations of precipitated reaction
byproducts and -solid matter collected and/or formed by the F6D process (com-
posed primarily of calcium-based reaction byproducts, excess scrubbing reagent,
flyash, and scrubber liquor).

Sludge disposal (also waste disposal) - Removal of and discarding of non-
saleable waste from an F6D system in the form of ponding, landfill ing, mine
filling, etc.

Sludge pond - Sludge dewatering ponds which generally are preceded by either
dewatering equipment and/or settling ponds.  The sludge pond is usually the
final disposal area.

Slurry - A watery mixture of insoluble matter (usually lime or limestone).

SOV - A symbol meaning oxides of sulfur (e.g., S02 and S03).
""""'X
Spray tower - Gas/liquid contacting device used for pollutant removal.
Untreated gas is contacted countercurrehtly, crosscurrently, or cocurrently
with scrubber liquor via spray nozzles in a horizontal or vertical chamber.

Stabilization - Physical stabilization is accomplished by reducing the
moisture content of the sludge by addition of non-alkaline flyash and/or
using a vacuum filter or centrifuge to the point that structural properties
are optimized when the material is disposed of in a landfill.

Stabilization pond - Sludge ponds containing stabilized sludge.

Stack flue - The inner duct or channel in a stack through which the flue gas
is conveyed.

Stack gas velocity - The exiting velocity of the flue gas out the top of the
stack.

Standard conditions - A set of physical constants for the comparison of
d i fferent gas violume flow rates (60°F, 1 atmosphere pressure).

Stoichiometric ratio - A molar ratio of reactants in a chemical process;
indicates to what extent lime (or other reagent) is added to the reaction in
excess of the theoretical amount required.

Superficial gas velocity - The average flue gas velocity through a mist
eliminator or other component of an F6D system.

Supernatant (also overflow) - The clear liquor that is drawn from the top of
settling tanks (e.g., thickener) or settling ponds.

System supplier - A firm that fabricates and supplies flue gas desulfuriza-
tion systems.

Temperature, dry-bulb - The temperature of a gas or mixture of gases indi-
cated by an accurate thermometer after correction for radiation.
                                     A-12

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Temperature, wet-bulb - A measure of tpe moisture content of air (gas) indi-
cated by a wet bulb psychometer.
Theoretical kWh production - Period ho
capacity in kilowatts.

Thickener - A continuous settling basi
from influent to underflow.
                                      jrs multiplied by gross unit operating
                                      i used to increase solids concentration
Throwaway end product - Those byproduct materials formed by F6D systems which
have no resale value with or without additional processing.
Total controlled capacity (TCC) - The gross rating (MW) of a unit brought
into complian
the facility.
	capa<	
into compliance with FGD, regardless of the percent of flue gas treated at
Tray tower - Gas/liquid contacting dev
                                       ce used for pollutant removal.  Un-
treated gas enters the base of the tower and passes upward through trays
containing openings countercurrent to {downward cascading scrubber liquor
introduced from above each tray.

Treatment - The specific type of dewatsring preparation used on FGD waste
material (sludge) to prepare it for final disposal (e.g., fixation, stabili-
zation, vacuum filters, thickeners, etc.).

Turnaround - Common term referring to an annual scheduled outage period.

Turndown ratio - The ratio of maximum gas flow capacity of a absorber to the
minimum it can handle without reducing! S02 removal or causing unstable opera-
tion.
Underflow - Concentrated solids flow f
ener.

Unit rating:
                                      rom the bottom of an absorber or thick-
     Gross - Maximum continuous generating capacity in MW.
     Net - Gross unit rating less the (energy required to operate ancillary
     station equipment, inclusive of enission control systems.

Utilization (also reagent utilization) - That fraction of reagent material
(e.g., lime, limestone, etc.) fed to the FGD system which is consumed (uti-
lized) and chemically converted into p
Vacuum filter - A drum and belt-type machine that separates solids from
slurry by use of vacuum pressure.

Wash water type - The nature of wash water spray utilized for mist elimin-
ators (e.g., continuous, periodic).
                                       oduct material (e.g., CaS03, CaSOiJ.
                                      -.1.3

-------
Water loop - All aqueous mass flows from inlet (e.g., seal  water, quench
water, scrubber liquor) to outlet of an F6D system (e.g., evaporation via
stack, pond evaporation, waste disposal).

Water losses - Water leaving the F6D system via the stack (evaporation),
pond, and thickener or that is chemically or physically bonded to the waste
disposal product.

Het stack - Stacks equipped with special liners for handling the continual
condensation of moisture contained in the exiting scrubbed flue gas.

Zero discharge - A pollution regulation requiring that no effluent waste
stream be discharged back into the environment, with the exception of evapo-
ration via ponds and stacks (e.g., pond runoff or direct piping of spent
slurry or waste into nearby waterways or tributaries would be prohibited).
                                     A-14

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                             APPENDIX B
                      EQUATIONS FOR CONVERTING
                   POLLUTANT CONCENTRATIONS TO
                             NSPS
UNITS
APPENDIX B - EQUATIONS FOR CONVERTING POLLUTANT CONCENTRATIONS TO NSPS UNITS
                                B-l

-------
              EQUATIONS FOR CONVERTING POLLUTANT CONCENTRATIONS

                    (lb/ft3) TO NSPS UNITS (lb/106 Btu)*




     106 C5.56(XH)+1.53(XC)+0.57(aSS)+0.14(%N)-0.46(XOi,)+0.21(%HgO)]
             •  in-   i   in— i      *"     *"    '     •  "
 w
                                   GCT
                     20.9
   "  wsw   20.9 (1 - Bwa) - % 02w



Where:


F  = Coal analysis factor on a wet basis, std. ft3/106 Btu
 W

6CV (Gross Caloric Value) = High heating value of coal, Btu/lb


E = Pollutant emission rate, lb/106 Btu


C   = Pollutant concentration given as a wet basis, lb/ft3
 ws

B   = Ambient air moisture fraction
 wa

02  = Percent oxygen in flue gas on a wet basis


Note:  Standard FW factors for coal:


       Bituminous - 10,680-


       Subbituminous - 11*500


       Lignite - 12,000
  Refer to  Section  3.1.1.4.
                                      B-2

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                            APPENDIX C
                                I            ....  ....

                  FGD SYSTEM INSPECTION CHECKLIST
APPENDIX C - FGD SYSTEM INSPECTION CHECKLIST
                                C-l

-------
         FGD SYSTEM INSPECTION  CHECKLIST
GENERAL INFORMATION
Utility/Plant Name
Plant Address
Plant Representative
Plant Manager
Inspector Agency Name
Inspector Name
      Date
      Phone No.
      Phone No.

      Phone No.
                        PLANT DATA (Table 4.1-1)
Boiler Data
         Type of firing (pulverized, cyclone)
         Boiler service load (base, intermediate,
          cyclic, peak)
         Date of commercial operation (month, year)
         S00 emission limitation, lb/10  Btu
                         '                   6
         Participate emission limitation, lb/10  Btu
         Opacity limitations, %
         Fuel firing rate at maximum continuous rating,
          tons/hr
         Heat rate, Btu/net kWh
         Average capacity factor, %
         Gross generating capacity, MW
         Outlet flue gas flow, acfm
         Outlet flue gas temperature, °F
Fuel  Data
Design
         Average heat content,  Btu/lb
         Average ash content, %
Actual
                                  C-2

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Fuel  Data (continued)
           Design
Actual
     0    Average moisture content, %
     °    Average sulfur content, %
     0    Average chlorine content, %
General FGD System Data
     0    FGD process type (lime, limestone)
     0    Generation type (first, secpnd, or third)
     0    Application (new/retrofit)
     0    Initial startup date
     0    Commercial startup date
     0    Total system design S02 removal efficiency,
          Percent flue gas bypassing
rGD system,  %
          Total system energy consumption, kWh
          Annual reagent consumption,
 tons/year
          Water loop type (open, closed)
          Waste disposal type (landfi
          Solid waste generation rate
11,  pond)
 (dry), tons/hr
          Total system makeup water consumption, gpm
          Number of operators per shirt
          Number of maintenance personnel per shift
          Maintenance philosophy (dedicated, rotated,
           pooled)
                         CONTROL ROOM
Observation
 (Table 4.2-1)
          Operator indicated location; of FGD monitors?
          All monitors operational?
Operation and Maintenance
     0    Reason/corrective action regarding non-operational FGD monitors.
                           Yes
                           Yes
         No
         No
                                     C-3

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Operation and Maintenance (continued)
     0    Emission  Readings
               S02, ppm
          0    Particulate, gr/scf
          0    Opacity, %
Design
Actual
          Facility  has computerized control
           with  CRT displays,
          CRT Readings
               Yes
         No
GAS HANDLING AND TREATMENT
                             FAN (Table  4.2-2)
Observation
          Excessive fan vibrations [ ]  Yes   [ ] No.  If yes,  note  readings
          and inquire why.
          Signs  of debris/maintenance.
          Signs  of corrosion/location.
                                    C-4

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Process
          Fan function, design application service, and location
          Unit/booster
          ID/FD
                                        Centrifugal/axial
                                        Wet/dry

                                                Design
               Fan AP, in.
                            «-        |
          0    Fan gas flow rate, acfm
          0    Fan gas temperature, °F
          0    Fan energy consumption!
                rate, kW
Operation and Maintenance
     0    Fan failure incidences/causes/remedial actions.
                                                                 Actual

          Routine maintenance procedures/inspection schedules.
                                     Us/
Observation

>n
Signs
SCRUBBER/ ABSOR
of debris/maintenance


5ER (Table 4.2-3)

                                     C-5

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Observation (continued)
     0    Signs of materials failure/location.
Process
          Signs of leaky piping.
          Signs of leaks on absorber vessel  walls.
Design
Actual
          Inlet particulate grain
           loading, gr/scf
          Outlet particulate grain
           loading, gr/scf
          Inlet S02 concentration, ppm
          Outlet S02 concentration, ppm
          Absorber L/6, gal/1000 acfm
          Absorber AP, in. H20
          Slurry solids content in
           absorber reaction tank, %
          Slurry pH in absorber reaction
           tank
Operation and Maintenance
     °    Absorber failure incidences/causes/remedial  actions.
                                     C-6

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Operation and Maintenance (continued)j
     0    If idle, inquire why and inspect internals (if possible).
     0    Absorber instrumentation problems/causes/remedial  actions.
          Routine maintenance procedures/inspection schedules
                        MIST ELIMINATOR (Table 4.2-4)
Observation
          Discarded sections/causes of failure.
          If idle, inspect installed mist eliminator section  for:
                                          Yes       No
               Plugging/scaling
               Breakage
               Deformation
               Erosion/corrosion
          Signs of mist eliminator carryover in  downstream  equipment.
                                     0-7

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Process
Design
                                                                 Actual
     0    Mist eliminator AP, in.  H20
     0    Absorber pH
     0    Mist eliminator flue gas velocity,
           ft/s
Operation and Maintenance

     0    Washing techniques utilized [ ] Automatic  [ ] Manual.
          Wash water source/water loop type/problems.
          Mist eliminator failure incidences/causes/remedial actions.
          Routine maintenance procedures/inspection schedules.
                           REHEATER  (Table 4.2-5)
Observation
      0     If  idle, check for excessive scaling/plugging (if possible),
                                     C-8

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Observation (continued)
     0    Discarded reheater tubes/causes of failure.
          If operational, check nearby ductwork for corrosion caused by
          reheater malfunctions.
Process                              ,
     0    In-line reheater AP, in. H9()
           Design
Actual
          Reheater energy consumption
           rate, kW
          Reheater inlet temperature,
          Reheater outlet temperature
          Is reheater outlet temperat
,  °F
Operation and Maintenance
          In-line tube failure incide
jre above acid dew point? [ ]  Yes [ ]  No.
ices/causes/remedial  actions.



Tube type/baffle and materi



ils of construction.
           Plugging problems encountered with  in-line  reheaters.
                                     C-9

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Operation and Maintenance (continued)
     0    Reheater failure incidences/causes/remedial  actions.
          Cleaning techniques utilized [ ] Automatic  [ ] Manual
     0    Routine maintenance procedures/inspection schedules.
                        DUCTWORK/DAMPER (Table 4.2-6)
Observation
          Signs of ductwork/damper corrosion/severity and location.
          Check for ruptured expansion joints/location.
          Newly installed ductwork/reasons for replacement.
                                     C-10

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Observation (continued)
     0    Does actual bypass ducting
          [ ] Yes   [ ] No.  If no, i
                                agree with original  system design?
                               inquire why.
          Is ductwork insulated? [ ] |Yes  [ ] No.
          Note ductwork shape and configuration/associated problems.
Process
          Process conditions (e.g., gas flow, gas temperature)  to which
          troublesome ductwork/dampens are subject to.
0    Is ductwork lined? [ ] Yes
     construction are used?
                                      [ ] No.   If yes,  what materials of
          Ductwork/damper problems due to mist eliminator carryover/causes/
          remedial  actions.
                                    Q-ll

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Operation and Maintenance (continued)

     0    Ductwork failure incidences/causes/remedial actions.
          Damper failure incidences/causes/remedial actions.
          Ductwork/damper problems due to improper installation and/or
          materials of construction/remedial actions.
          Are dampers equipped with seal air?  [ ] Yes  [ ] No.  If no, note
          any isolation problems.
          Damper problems due to fly ash or solids accumulation.
          Routine maintenance procedures/inspection schedules.
                                     C-12

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REAGENT HANDLING AND FEED
REAGENT CONVEY*
Observation
0 Signs of belt misalignment,



0 Signs of leaks on pneumatic



0 Signs of bucket elevator de



0 Conveyor duties/problems.



Operation and Maintenance
0 Conveyor failure incidences,




)R (Table 4.2-7)
tears, or frayed edges.



conveyor lines.



>r is/ jamming/maintenance.
- . ,






'causes/remedial actions.



;-13

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Operation and Maintenance (continued)
     0    Conveyor failures caused by reagent quality/weather.
          Routine maintenance procedures/inspection schedules.
                           BALL MILL (Table 4.2-8)
Observation
          Signs of discarded balls/maintenance.
Process
     0    Failures caused by poor reagent quality/undersizing.
          Water source/problems.
                                     C-14

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Operation and Maintenance             i
     0    Ball mill failure incidences'/causes/remedial actions.
          Routine maintenance procedures/inspection schedules.
res/ii
                            SLAKER (Table 4.2-9)
Observation
          Is slaker operational?  [ ]
 Yes  [ ] No.  If no, inquire why.
Process



Dry reagent feed rate of si a
Slaker capacity problems/cat



ker, tons/hr. [ ] Actual [ ] Design.
ses.
           Failure caused by poor reagent quality.
                                      G-15

-------
 Process  (continued)
      0    Water source/problems.
Operation and Maintenance
     0    Problems associated with slaker support equipment.
          Slaker failure incidences/causes/remedial actions.
          Routine maintenance procedures/inspection schedules.
                            TANKS (Table 4.2-10)
Observation
          Signs of tank repairs/maintenance.
                                     C-16

-------
Observation (continued)
     0    Note tank configuration/associated failures.
     0    Note if tanks are covered or open.
          If open, check for floating
debris/associated failures.
          Signs of slurry leakage.
Operation and Maintenance
          Tank(s) drained to repair 1
iners/bafflers.
      0     Problems  associated with taik support equipment.
                                      C-17

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Operation and Maintenance  (continued)
     0    Tank failure incidences/causes/remedial  actions.
          Routine maintenance procedures/inspection schedules.
WASTE SOLIDS HANDLING AND DISPOSAL

                         THICKENER (Table 4.2-11)
Observation
          Signs of thickener repairs/reason for repairs.
          Signs of slurry leakage.
         Are thickeners covered?   [ ] Yes   [ ] No.
         If not covered, check  for debr,is/ass.ociated failures.
                                   C-18

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Process
Design
Actual
          Overflow rate, gpm
          Underflow rate, gpm
          Solids content in underflow,  %
          Sulfite/sulfate ratio of inlet
           slurry
          How is thickener overflow used?/rate (gpm).




and Maintenance
Is thickener rake drive sli
control alarm system? [ ]
Problems with rake binding







lift and motor equipped with a torque
Yes [ ] No.
or rake drive shaft/motor failure.



          Problems with sump failures.
     0    Problems with liner failun
     0    Thickener failure incidences/causes/remedial actions.
                                     C-19

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Operation and Maintenance  (continued)

      0    Routine maintenance procedures/inspection schedules.
                        VACUUM FILTER (Table 4.2-12)
Observation
          Inspect filter cloth for tears.
          Check for spare or discarded filter cloths.
          Check filter cake consistency/product quality.
Process
     o


     o

     o
Filter cake production rate,
 tons/hr

Solids content of filter cake,

Inlet slurry solids content, %

Wastewater effluent production
 rate, gpm

S.ulfite/sulfate ratio in
 filter cake
                                      Design
Actual
                                     C-20

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Process (continued)                   j
     0    Inlet slurry solids content Adequate?  [ ] Yes  [ ] No.
     0    How is the vacuum filter filirate used?/rate (gpm)
Operation and Maintenance
     0    Problems/failures associated
 with  vacuum filtrate pump.
          Problems regarding filter cloth replacement
          Filter cake conveyor failures.
     0    Vacuum filter failure  incidejices/causes/remedial actions
      0     Routine maintenance  procedures/inspection  schedules.
es/ii
                                      C-21

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                           CENTRIFUGE  (Table  4.2-13)
 Observation
Process
     Q

     O

     O
           Centrifuge(s)  operational?   [  ]  Yes   [  ]  No.   If no,  inquire why.
      0     Check  centrifuge cake consistency/product quality.
                                       Design
Actual
 Filter cake  production  rate,
  tons/hr
 Solids content  of  filter  cake,
 Inlet  slurry solids  content, %
'Wastewater effluent  production
  rate,  gpm
 Sulfite/sulfate ratio in
  filter cake
          Inlet slurry solids content adequate?  [ ] Yes  [ ] No.
          How is the centrifuge filtrate used?/rate (gpm)
Operation and Maintenance
     0    Problems due to support equipment factors.
                                     C-22

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Operation and Maintenance (continued)
     0    Centrifuge failure incidences/causes/remedial actions.
Process



Routine maintenance procedur



WASTE PROCESSING SY



js/inspection schedules.



STEM (Table 4.2-14)
          Type of waste processing system:
          [ ] forced oxidation   [ ] ffixation   [ ] stabilization   [ ] none
          What is the energy consumption rate?  Is this typical or excessive?
Operation and Maintenance
     0    Problems associated with the
equipment area.
          Waste processing failure indidences/causes/remedial actions.
                                      ]-23

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Operation and Maintenance  (continued)
     0    Routine maintenance procedures/inspection schedules.
                    WASTE DISPOSAL SYSTEM (Table 4.2-15)
Process
     0    Type of water loop [ ] open   [ ] closed
     0    Type of waste disposal system  [ ] ponding  [ ] landfilling
          [ ] stacking (gypsum)
     0    If ponding is used, how much waste water is returned back to system
          (gpm)?/quality of water.
Operation and Maintenance
     0    Waste disposal failure incidences/causes/remedial  actions.
          Routine maintenance procedures/inspection schedules.
                                     C-24

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                        PUMP AND VALVE (Table 4.2-16)
Observation
          Check for discarded pump impellers and liners/note appearance.
          Signs of leaky pump seals,  bearings,  etc
          Excessive pump vibrations [ |  Yes  [ ]  No.   If yes,  inquire why.
     0    Locate and inspect abrupt expansion,  contraction,  and bends  in
          piping around valves/note any problems.
Process
          Process conditions associated with failure-prone pumps/valves.
                                     C-25

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Process (continued)
     0    Energy  consumption rate of absorber recycle pumps, kW.
                Design	     Actual 	
     0    Inquire about pump redundancy for different operations.
Operation and  Maintenance
     0    Pump failure incidences/causes/remedial  actions.
          Valve  failure incidences/causes/remedial  actions.
          Routine maintenance procedures/inspection schedules.
                                      C-26
                                                       ft U.S.GOVERNMENTPRINTSNQ OFFICE: 1985 - 559-111/20706

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