Acurex Project 7418




A REVIEW OF FGD. SYSTEM OPERATION AND PROCESS CONTROLS
                                               .• -

                  t


                    FINAL REPORT
 Acurex Corporation/Energy & Environmental Division
           South/East Regional Operations
                  Route 1, Box 423
         Morrisville, North Carolina  27560
                    December 1979
                    Prepared for

              Lead Engineer Larry Jones
        U.S.  Environmental Protection Agency
    Office of Air Quality Planning and Standards
     Emission Standards and Engineering Division
    Research Triangle Park, North Carolina  27711
                         68-02-3064

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                 Acurex Project 7488



A REVIEW OF FGD SYSTEM OPERATION AND PROCESS CONTROLS



                     FINAL REPORT
         John Chang and Anthony Marimpietri
 Acurex Corporation/Energy & Environmental Division
           South/East Regional Operations
                  Route 1, Box 423
         Morrisville, North Carolina  27560
                    December 1979
                    Prepared for
              Lead Engineer Larry Jones
        U.S. Environmental Protection Agency
    Office of Air Quality Planning and Standards
     Emission Standards and Engineering Division
    Research Triangle Park, North Carolina  27711
                Contract 68-02-3064

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                             TABLE OF CONTENTS
                                                                      Page
1.0  Introduction 	        1
2.0  Summary	        1
3.0  Review of EPA Test Data	        2
4.0  Process Controls for FGD Systems	       11
5.0  Further Reduction of Efficiency Variability  	       15
6.0  Conclusions	       1?
7.0  References	       18
8.0  Attachments	       19

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1.0  INTRODUCTION

     On June 11, 1979, the U.S. Environmental Protection Agency (EPA)

promulgated revised new source performance standards (NSPS) for sulfur

dioxide (S02) emissions from utility boilers.  The standards were based in

part on a series of flue gas desulfurization (FGD) system test data.  The

data are available in air pollution emission test reports included in Utility

Boiler Docket OAQPS-78-1.  In a petition to EPA for reconsideration of the

S02 percent reduction standards, the Utility Air Regulatory Group (UARG)

presented a statistical analysis of these data (OAQPS-78-1, VI-A-5).  EPA

has also performed a statistical analysis of these data (OAQPS-78-1, VI-B-13).

The EPA analysis differs from the UARG analysis in that different conclusions

are reached based on distinctions in the type of FGD system, process control,

and mode of operation of the FGD systems tested.

     The purpose of this report is to discuss the conditions under which

these data were obtained and to explain the distinctions in the FGD systems

tested.  Existing S02 removal efficiency test data are examined to determine

representative efficiency variabilities.  This report also focuses on the

control of FGD efficiency variation by process control systems.  Typical

process control modules used in FGD systems in the United States and the

more advanced, automatic control modules used in Japan are also discussed.

Other factors that can affect FGD performance variation are considered.

2.0  SUMMARY

     In considering the relevance of the test data to a projection of

efficiency variability in new FGD systems, only lime/limestone systems were

included because they are the primary (but not only) basis for the NSPS.

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In Addition, they are the only type of FGD system control equipment venders


can supply  in sufficient quantity to meet the total projected market demand
    _    	   _                 	      	     - -        _....  _   	    f

(OAQPS-78-1, II-A-33).  In addition, lime/limestone systems, in comparison


to regenerable FGD  systems, are considered to be less responsive  to process


control  systems because of the slower reaction rate of absorbent.  Thus,


the process  control variation from a lime/limestone system is the "worst


case" example with  respect to applying process control.  In evaluating the


90 percent  reduction requirement, FGD application on high-sulfur  coal is


the most relevant example because low-sulfur coal applications would be


affected by  the 0.6 Ib/million Btu emission floor or the 70 percent minimum


control  level.


     An  examination of the test conditions shows that, with the exception


of three tests, the facilities tested experienced equipment malfunction or


operating problems  or were otherwise not characteristic of well-designed


and well-operated lime/limestone  systems on high-sulfur coal applications.


The three facilities that experienced no malfunctions or abnormal operating


conditions were Shawnee, Pittsburgh 2, and Louisville.  Of these, Louisville


experienced  the  largest efficiency variability and Shawnee the smallest.


The degree of supervision over the process was greater at Shawnee than at


any other system tested.  Close process supervision and other factors dis-


cussed below have resulted in good process stability (low efficiency


variability).  New  FGD system designs can be expected to utilize  new control


systems  (as  has been done in Japan) and benefit from the experience of the


best U.S. and Japanese facilities.


3.0  REVIEW  OF EPA  TEST DATA


     During  the development of new source performance standards (NSPS) for


S02 emissions from  electric utility generation units, the U.S. Environmental

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Protection Agency (EPA) conducted various field studies of FGD systems to



better define the performance and operational characteristics of lime/lime-



stone slurry FGD processes.  Since the promulgation of the Utility Boiler



NSPS, the UARG has further analyzed the EPA data to evaluate the capability



of FGD systems to achieve 90 percent S02 removal (OAQPS-78-1, VI-A-5).



Some of the data used  in their analysis were obtained from FGD systems without



adequate process control systems and from FGD systems not operating under



normal conditions.



     In fact, the EPA  test data were obtained under varying conditions.



Table 1 lists the locations of the FGD systems tested in EPA field studies



in the order in which  they are discussed below along with the type of scrubber



modules for each facility.  Only tests conducted on lime/limestone FGD systems



and high-sulfur coal are considered in the final analysis because the most



stringent S02 percent  reduction requirement, 90 percent S02 removal, is



applied only to high-sulfur coal.  Review of the operating conditions and



types of FGD systems tested shows that only the data from Pittsburgh 2.



Shawnee, and Louisville (the last three in Table 1) were obtained from lime/



limestone slurry FGD systems under normal operating conditions, treating



flue gas from high-sulfur coal./Two other tests (Eddystone and Mitchell)



were conducted on non-lime/limestone systems and thus are not discussed.



Four other tests (Conesville A and B, Lawrence and Pittsburgh 1) were con-



ducted under conditions that did not represent well-operated lime/limestone



slurry FGD systems for high-sulfur coal.  The specific reasons these four



FGD systems do not represent good operation are discussed below.



     At the Conesville Power Station of Columbus and Southern Ohio Electric



Company, two modules (A and B) of the turbulent contact absorber (TCA)  system

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                            Table 1.  EPA FGD SYSTEM DATA BASE
   Site
                                                 Scrubber module
                            Comments
0  Eddystone (Philadelphia, Pennsylvania)        Magnesium oxide
 O Mitchell (Chicago,  Illinois)
 ^Conesville A  (Columbus, Ohio)
   Conesville B  (Columbus,  Ohio)
   Lawrence  (La Cygne,  Kansas)
Wei 1 man-Lord
TCA/lime
TCA/lime
Rod and spray
towers/1imestone
O  Pittsburgh 1  (Bruce Mansfield,  Pennsylvania)  Venturi/lime

 O Pittsburgh 2  (Bruce Mansfield,  Pennsylvania)  Venturi/lime

 t1 Shawnee  (TVA,  Paducah,  Kentucky)              TCA/lime

 O Cane Run  (Louisville,  Kentucky)               TCA/lime
Not a lime or limestone
system

Not a lime or limestone
system

Intermittent operation
Low data availability

Intermittent operation
Low data availability

Low absolute S02
emission rate

Poor pH control
                   Step change of L/G

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were tested.  Lime was used as the scrubbing reagent (OAQPS-78-1, IV-A-8).

The many equipment failures encountered during the tests reduced the

reliability of the modules to a low level.  The problems included:

     (1)  pressure surges in the piping,

     (2)  maldistribution of gas flow,

     (3)  excessive mist entrainment,

     (4)  acid rainout,

     (5)  failure of the plastic coating  in the stack flues,

     (6)  failure of the plastic piping,

     (7)  plugging in the thickener lines,

     (8)  corrosion in the presaturator,  and

     (9)  detachment of the rubber lining in the scrubber and recycle tank.

These problems resulted in excessive downtime for repair and consequently

led to short run duration and low data availability* (OAQPS 78-1, IV-D-611).

The longest continuous run of a module was 10 operating days.  A more typical

run duration lasted 4 to 6 days.  Over a  6-month period from June 15, 1978,

to December 15, 1978, module A was operated intermittently for 60 days;

however, 24-hour average S02 removal efficiency data were available for

only 24 days.  Module B was operated 63 days, and the data were available

for only 21 days.  These represent 40 percent and 33 percent data availa-

bility, based on scrubber operating time  for Modules A and B, respectively

(OAQPS-78-1, IV-A-19).  These figures are low compared with the 85.7 percent

data availability over a 49-day period at the Shawnee test site (OAQPS-78-1,
JU
 Data availability is defined as the number of days for which 24-hour
 average S02 removal efficiency data are available divided by the possible
 number of operating days.  An operating day is defined as 18 or more hours
 of operation in a 24-hour period beginning at midnight.

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IV-J-20).  In the  latter stage of  data  acquisition  at  the  Conesville  Power


Station, EPA staff determined that the  FGD  system could  not  be  operated


under maximum removal conditions (see Attachment 1)  because  of  original


design problems, and that  improvement was not  likely without major  equipment


changes.  The tests at  the  Conesville facility were  subsequently  terminated


by EPA.  Because of the continual  system plugging and  resulting intermittent


operation during the Conesville tests,  the  efficiency  variability of  the
 »»	m__m_u_i_ii_Mir-r'.	   i 	 " r~i	B.-I.- '	..i_i	 i   ii ii -  i  	- - _j.j-__.ii-.- __.-i_i.-	—i-	       - ii

data did not represent  that of a well-controlled, normal FGD system operation.


     In tests at Kansas Power and  Light Company's Lawrence Unit No. 4, limestone


slurry was used in both rod scrubbers and spray towers to  absorb  S02  from


low-sulfur coal (0.5 percent sulfur) flue gas  (OAQPS-78-1, II-I-5).   This


system was originally intended to  achieve S02  removal  of 73  percent,  but


because of the  low sulfur  content  of the coal  used,  the  system  was  able to


achieve high removal.   The  median  S02 removal  efficiency during the test


was 96.6 percent.  The  combination of low-sulfur coal  and  high  S02  removal


by the FGD resulted in  an  extremely low median outlet  S02  emission  of


0.03 lb/106 Btu (OAQPS-78-1, IV-J-22).  Therefore,  small variations in outlet


S02 concentration  appeared  as a significant efficiency variability, especially


when log-normal distribution [In (1-eff.)]  is  used  to  describe  the  efficiency


variability (OAQPS-78-1, VI-A-5).


     As stated  above, the  Lawrence test results were obtained under significantly


different conditions (i.e.,  low-sulfur  coal and high efficiency S02 removal)


than the other  tests discussed in  this  report.   If  the test  results were


combined, the results would be misleading,  especially  because the statistical


methods employed exaggerate variability.  The  results  from the  Lawrence


facility, therefore, should not be used to  evaluate  the  process stability


(i.e., efficiency  variability) of  high-sulfur  coal  FGD systems.

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     The FGD system used at the Bruce Mansfield Station of Pennsylvania

Power Company consists of venturi absorber modules with lime slurry used as

the reagent (OAQPS-78-1, IV-D-611).  Pittsburgh 1 and 2 (Table 1) represent

the data collected in two different periods of operation at the same plant.

The pH meter of the FGD process control system did not work during the first

period of testing.  Initial problems occurred with pH meter electronics;

later, the suspended solids in the slurry tended to abrade and break the

flow-type pH probes.  Operators had to record hourly scrubber and absorber

slurry pH readings with a portable pH meter.   Thus, the entire FGD system

was not under proper control during the first period, and the data obtained

can not be used to interpret system performance adequately.

     During the second test period at Bruce Mansfield, the FGD system operated

under good pH control conditions  (OAQPS-78-1, II-D-432).  The electronic

problem with the  pH meter had been resolved, and other improvements made

before the second test period began included the relocation of the pH meter

and modification  of the sampling  procedure.  Scrubbing pH was better controlled,

and S02 removal efficiency was consistently improved.  In addition, the

modules operated  without any substantial development of hard scale (gypsum)

or plugging (OAQPS-78-1, II-B-86).  For these reasons, the data obtained

during the second test porjnri a+  Pit.tshurgh represent the performance of a  5

well-operated FGD system equipped with manga] proce.^ mnt.rnls.

     Testing at the Shawnee Power Station, which is operated by the Tennessee

Valley Authority  (TVA), was performed with a pilot-scale (10 MW) TCA system

using lime slurry (OAQPS-78-1, III-B-4).  During these tests, data availability

was 85.7 percent, and neither pH  meter malfunctions nor serious scaling

occurred.   The process was also closely monitored by skilled technicians

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(OAQPS-78-1, II-D-440).  Therefore, data from TVA's Shawnee plant represent
normal FGD system performance of an existing system using manual pH controls
coupled with close operator attention.  With respect to operator attention,
the Shawnee test was superior to any other.
     Tests were also conducted at the Louisville Gas and Electric Company's
Cane Run No. 4 plant.  This FGD system is a TCA using lime as the reagent.
Many problems occurred during the FGD system's initial operating phase,
poor gas distribution and excess pressure drop, which resulted in low S02
removal efficiency (OAQPS-78-1, IV-A-8).   To improve the S02 removal effi-
ciency, additional spray headers were installed in the TCA and additional
slurry recirculation pumps were retrofitted.  Following these modifications,
no pH meter malfunctions were reported, and plugging and scaling have not
been problems (OAQPS-78-1, II-I-7).
     The use of three fixed-speed pumps to control the slurry recirculation
rate, however, resulted in FGD system operation at two levels.   Two pumps
were used when boiler load was lower than 150 MW and three pumps when boiler
load was higher than 150 MW (see Attachment 2).  This arrangement introduced
a step change in the liquid-to-gas ratio (L/G) when boiler load varied across
150 MW (see Figure 1).  Because this facility was used as a peaking unit,
the load varied during normal operation from 90 MW in the morningtoapeak
value of 175 MW in the afternoon (OAQPS 78-1, II-I-301).  As shown in Figure 1,
the unusual pumping arrangement caused the L/G to vary fmm 35 tn fin ja
(a relatively wide range) whenever  load changed.  Examination of the data
shows that this abrupt change in recirculation rate occured in a 1-day operating
period (OAQPS 78-1-76/56, II-B-75).  Such a variation of L/G can strongly
affect the performance of a TCA system as measured by S02 removal efficiency.

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           70 -i
           SO -,
           50 -
L/G
(gal/macf)
           30
 i
80
                          I     »     r
100
120
                                                  HO       160
180
                          BOILER LOAD  (MW)
   Figure 1.   Liquid-to-gas (L/G)  ratios  vs.  boiler load changes

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As the Shawnee data show, for a TCA/lime system, a change in the ratio of



scrubber slurry to flue gas from 60 to 30 gal/macf could cause the S02 removal



efficiency to decrease drastically (from 85 to 55 percent) when other operating



parameters were fixed (OAQPS-78-1, II-A-75).  Adjustments in other process



parameters, such as pH, can partially compensate for this variability in



efficiency; however, the  relatively slow response time of pH controls limits



their ability to follow rapid L/G changes.



     The test data show Louisville to have the largest efficiency variability
        TT|H •!•>•,!      ^


of the three tested facilities which experienced no malfunctions and were



in constant operation during testing.  The degree of supervision over the



process is not known and  may have been a contributing factor to the process



variation  in addition to  the L/G ratio fluctuations.  The degree of process



supervision at Shawnee was relatively high (see Sections 4.0 and 5.0), and



such process supervision  is a factor in achieving good FGD process stability



(i.e., low efficiency variability).



     In summary, the preceding analysis shows that data from Pittsburgh 2,



Shawnee TCA, and Louisville were obtained under normal operating conditions



and without malfunction of pH control meters.  Table 2 shows the logarithmic



means and  standard deviations of those three sets of data (OAQPS-78-1, VI-A-5).



Among them, Louisville has the highest S02 removal efficiency variability



(standard deviation).  This may have resulted from the unusual arrangement



of the slurry pumps, which led to wide L/G variations.  Also, the degree of



process supervision is not known.  In contrast, the Shawnee TCA data give



the lowest performance variability because of careful operation by skilled



personnel.
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 Table 2.   RESULTS OF STATISTICAL ANALYSIS OF PITTSBURGH 2 AND SHAWNEE DATA

                             (OAQPS-78-1, VI-B-13)
Site                                              Process variation and mean

                                                           Geometric standard
                                                  Mean         deviation
Cane Run (Louisville, Kentucky)                  83.3-84.4     0.295-0.343

Pittsburgh 2 (Bruce Mansfield, Pennsylvania)       85.4           0.212

Shawnee TCA (TVA, Paducah, Kentucky)               88.5           0.182




   4.0  PROCESS CONTROLS  FOR  FGD SYSTEMS

        Existing  FGD  systems  in the United States, including the Louisville,

   Shawnee, and Pittsburgh facilities,  use manual pH controls.  A major reason

   for pH control is  the  prevention of  scaling1  (OAQPS-78-1, II-I-8).  Continuous

   maintenance of high  S02 removal efficiency  in new FGD systems requires additional

   controls and operating procedures  designed  to stabilize the process.  This

   section describes  the  use  and limitations of  pH controls and other controls

   expected to be installed on new FGD  units that will  improve process stability.

        In a typical  pH control  scheme,  a  stream of scrubber slurry  from the

   recirculation  loop is  tapped  and passed through a vessel containing the  pH

   sensor, as shown  in  Figure 2.  If  the inlet S02 concentration increases,

   the increased  S02  absorption  reduces the pH of the  scrubber slurry.  When

   the pH drops below a set point, the  flow of reagent increases, as does the

   rate of reaction  with  absorbed S02 in the scrubber  hold  tank.  The pH  sensor,

   in turn, monitors  the  resulting  increase in pH, and the  controller responds
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                                            RECIRCULATION PUMP
             Figure  2.   Lime/limestone  scrubber  system  pH control  mode.
                                                                                  2
                                                                                                   CM
                                                                                                   o
                                                                                                   C\J
                                                                                                   o
                                                                                                    i
GAS OUTLET
                                                             RECIRCULATION SLURRY
GAS INLET
                                                                                             REAGENT

                                                                                             FEED
                                                 12

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by reducing the reagent slurry flow rate.  This is a continuous process


that oscillates within a band across the set pH point.2


     A number of factors determine the width of the pH control band.  The


         H is constrained by two factors:  (1) the reagent feed rate required
to achieve a given degree of S02 removal and (2) the pH level below which


hard scale (gypsum) formation will tend to occur.  These factors depend on


both system design and operating conditions such as inlet S02 concentration


and liquid-to-gas ratio.


     The maximum pH of the slurry is generally limited by the reagent

                   *
utilization factor,  which may  include calcium carbonate (CaC03) scaling in


lime systems.  An adequate margin must be provided within the upper and


lower pH limits so that a little "overshoot" will not cause scale formation

         2
problems.


     The most common problems associated with pH control systems are plugging


and pH sensor erosion.  For example, in the Pittsburgh FGD system, a flow-type


sensor is used to measure the slurry pH (OAQPS-78-1, II-I-6).  To do so,


slurry sample must be forced through the sensor.  The sample lines to and


from the sensor elements can plug, and the sensor elements are constantly


subject to erosion.   During the Pittsburgh 1 test period, plugging and pH


sensor erosion led to control system failure and caused unstable operating


conditions (OAQPS-78-1, IV-D-611).  After experimentation, the pH measuring


equipment was moved to a more desirable location in the scrubber cycle, and


the sampling techniques were improved.  With these modifications, the pH


sensor worked satisfactorily (OAQPS-78-1, II-1-6).  The FGD  system was  under
 The amount of reagent reacted with S02 divided by the amount of reagent

 added to the system.
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controlled, stable operating conditions during the Pittsburgh 2 test period

at Bruce Mansfield.


     The plugging and erosion problems encountered in pH control systems


may also be solved through the use of dip-type pH sensors.   The dip-type


sensor is  inserted into the slurry tank and can be manually removed for


periodic maintenance and calibration.  Since the slurry does not flow through


the cell when dip-type sensors are used, the measuring electrode, which is


made of glass, is not subject to breakage as it is when flow type sensors


are used.  In the Louisville FGD system, six sets of dip-type pH electrodes


were installed in the recirculation tank.  Each set was checked daily against


the others, and recalibration and repairs were performed as needed.   This

                                                                             o
pH control system has worked well, and no maintenance problems were reported.


     The majority of lime or limestone scrubber installations in the


United States have used manual pH control.  EPA has demonstrated the perfor-


mance capabilities of the pH control method in a pilot-scale FGD system


(Shawnee TCA) and in full-scale FGD systems (Pittsburgh 2 and Cane Run).


The efficiency variability of these systems is shown in Table 2.


     Control system performance can be improved by (1) conversion of the


feed-back  type of process controls to feed-forward controls and (2) the use


of automatic controls.  In pH control systems, which are feed-back controls,


the pH instruments do not detect system variations before the slurry hold


tank chemistry has been upset.  Thus, the reagent (lime or  limestone) is


not added  until a depletion has already occurred.  In contrast, a feed-forward


process control uses instruments at the FGD absorber inlet  to maintain  the


balance of the FGD system as inlet conditions change.  Signals  from the


inlet S02  continuous monitoring equipment enable the operator to anticipate
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the variations in the FGD system.  Thus, slurry tank reagent feed rate may

be adjusted before the absorbent in the hold tank is significantly depleted.

     Automatic controls improve on those described above by anticipating

the effects of changes in S02  inlet concentration and gas flow rate caused

by boiler  load changes.  Such  systems, which are currently used in Japan,

have the potential to reduce variations in S02 removal efficiency (OAQPS-78-1,

II-I-359).  These automatic process controls measure flue gas volume and

S02 concentration at the scrubber inlet to determine automatically the slurry

makeup volume requirements.  Fine tuning of the makeup feed rate is maintained

by pH control.  In addition to the automatic controls, a feed-forward control

scheme maintains the stoichiometric ratio between the absorbed S02 and the

added reagent.  Scale formation is avoided by pH adjustment.   Thus, through

the use of automatic controls  and feed-forward process controls, the balance

of the FGD process chemistry is maintained, and the S02 removal efficiency

is stabilized (OAQPS-78-1, IV-B-4).

5.0  FURTHER REDUCTION OF EFFICIENCY VARIABILITY

     In addition to process controls, the following factors may influence

FGD system stability and should receive close attention.

Qualified Full-Time Personnel

     Qualified full-time personnel are needed to operate and maintain an

FGD system.  An FGD system involves a chemical process that must be monitored

by well-trained operators to maintain the chemical balance of the system.

For example, the Shawnee TCA results were achieved using skilled personnel

to monitor and control the process (OAQPS-78-1, II-D-440).  The results

demonstrate that better performance can result when an adequately trained

staff is dedicated to the operation of an FGD system.  In Japan, assigning
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adequately trained operators to FGD process control functions is considered

a major factor in achieving good process stability (OAQPS-78-1, II-I-359;

OAQPS-78-1, II-B-96).

Proper FGD System Design

     FGD control systems should be designed so that process stability is

manageable.  Proper operating margin and flexibility should be incorporated

into FGD systems to provide greater tolerance.  For example, an adequate

margin must be provided within the upper and  lower pH limits for the pH

control band to diminish the effect of overshoot on scale formation.  The

appropriate slurry flow rate must be determined so that the variation of

L/G with boiler load change will not upset FGD system performance.

Stabilization of Inlet S02 Concentration by Coal Blending

     An inherent property of coal is its variability in sulfur content.

Fuel sulfur is unevenly distributed in a coal seam, and even coal shipments

from the same mine will have a range of sulfur content (OAQPS-78-1, III-B-4).

Thus, all  naturally occurring coals can be expected to produce variations

in the S02 concentrations of boiler flue gas.  Coal blending is one method

of reducing the variation in fuel sulfur concentration and, consequently,

of reducing the control system's burden of maintaining FGD process stability.

However, the influence of the variability of  coal  sulfur content on the

efficiency of the scrubbing operation has not been found to be a major factor

(OAQPS-78-1, VI-B-13).

Quality Control of Lime and Limestone

     The reactivity of reagents, especially  limestone, is affected  by both

their particle size distribution and their inert content.  The quality of

the reagents should be controlled to maintain an accurate stoichiometric
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ratio between inlet S02 and reagent feed rate and thus avoid system chemistry

upset (OAQPS-78-1, II-I-359).

6.0  CONCLUSIONS

     The following observations are summarized from the above discussion:

     1.   The performance  test results from Cane Run at Louisville, Kentucky,

Pittsburgh 2 at Bruce Mansfield,  Pennsylvania, and TVA Shawnee TCA at Paducah,

Kentucky, were obtained under normal operating conditions and without pH

control malfunction.  However, the S02 removal efficiency variability of

the Louisville test was higher than that of the other two tests.  It may

have resulted from step change coupled with a wide range in L/G ratio which

can have adverse effects on FGD system stability.  In addition, operator

attention at Shawnee was superior to any other system tested.

     2.   Good results can be achieved with pH controls through careful

attention to probe location and operating procedures, as demonstrated by

the Pittsburgh and Shawnee tests.

     3.   Existing FGD systems can be improved by using automatic control

systems designed to keep proper balance in the stoichiometric ratio between

reagent fed and S02 absorbed and  by maintaining slurry pH stability.  Such

controls are currently used in Japan.  Future FGD systems equipped with

those advanced control modes are  expected to achieve performance variability

equal to or better than the Shawnee and Pittsburgh tests.

     4.   Several other factors,  including adequately trained full-time

operators, contribute to the achievement of process stability.  These factors

should be considered in conjunction with well-designed process  controls  in

new FGD installations.
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7.0  REFERENCES


 1.  Lime/Limestone  Scrubber Operation and Control  Study.   Electric  Power
     Research  Institute.   Palo Alto,  California.   Publication  No.  EPRI  FP-627.
     October 1978.

 2.  Jones, D.  G. ,  0.  W.  Hargrove,  and T.  M.  Morasky.   Lime/Limestone Scrubber
     Operation and  Control.   Control  Technology News,  Journal  of the Air
     Pollution Control Association.   29:1099-1105.   October 1979.

 3.  Lime  FGD  Systems  Data Book.   Electric Power Research Institute.   Palo,
     Alto,  California.  Publication No. EPRI  FP-1030.   May 1979.
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7488/B
12-18-79
8.0  ATTACHMENTS

     1.   Kelly, W. M.  Trip  Report—CSDEC  Conesville Unit 5 S02 Monitoring
          Project,  June 27, 1978.

     2.   Chang, J. C. S.  Telephone  Conversation  Report, Control of  L/G at
          Louisville  Plant FGD  (Cane  Run),  November  15,  1979.
                                     19

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                                         ATTACHMENT 1
                     UNITED STATES ENVIRONMENTAL
         JUN 271978 Offlce of Air Quality PIanni
   DATE:                Research Triangle Park, North"Carolina 27711

          Trip Report—CSOEC Conesville Unit 5 S02 Monitoring Project
   FROM:   Winton E. Kelly, Project Officer  I
          Field Testing Section, Emission Measurement Branch,.ESED (MQ-l'3)

     T0:   J. E. McCarley, Jr.s Chief, Field Testing Section
          Emission Measurement Branch, ESED (MD-13)

          I.   PURPOSE

               The purpose of this visit was to review the S0?  monitoring instru-
          mentation, the contractor's progress in instrument specification  testing,
          and to arrange for acquisition of boiler process data.

          II.  PLACE AND DATES

               The visit was conducted at Columbus and Southern Ohio  Electric
          Company, Conesville Plant, Conesville, Ohio, on June  15-16,  1978.

          III.  PRINCIPAL ATTENDEES

               CSOEC

               Tom Reed
               Harl Todd

               UOP. Air Correction Division

               Dave Lovetere

               PEDCo

               Tony Wisbith
               Dave Howie
               Jon Allen

               Environmental  Protection Agency

               Winton  E.  Kelly

          IV.   DISCUSSION

               The instrument systems were  found to  be appropriately  installed
          and operating properly.   PEDCo had completed final  specification  testing
          on June  14.   Final  results  were not  available at the  time of the  visit,
          but PEDCo personnel  felt confident that all  performance  criteria would
          be achieved.   The only  instrument operating  difficulty has  been
PA FORM 1320-6 (REV. 3-76)

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deterioration of the automatic blowback valves on the probe systems.
This problem was corrected by installing an additional solenoid valve in
the high pressure air lines.  A minor difficulty was observed in the
timer cams for the Dupont track and hold circuits, but correction is a
matter of easy adjustment.  Based on observations of PEDCo's procedures
and preliminary review of reference method measurements, the instrument
systems are providing reliable, accurate results.

     Since all installations and performance tests had been completed,
PEDCo was instructed to begin the formal test period as of June 15, 1978.
Process data will be collected beginning on the same date.  The PEDCo field
personnel are compiling very complete logs of instrument operation and
specific instructions were given to ensure that all periods of missing or
unusable data are properly accounted.  PEDCo was instructed to use the time
allowances currently under consideration for routine calibration and
maintenance; 1 hour per day for calibration and 8 hours per month for
routine maintenance.  Additional testing was directed to determine a
relative accuracy for the 02 analyzer.  Procedures to be included in
revised Specification 3 were described and PEDCo was instructed on their
use.

     Based on their work in ambient monitoring studies, PEDCo is aware
of the need for quality assurance procedures and was familiar with the
approaches currently proposed by QAB/EMSL for ambient monitors.  In order
to provide monthly data for instrument relative accuracy, PEDCo was
instructed to perform Method 6 at both test locations and Method 3 analysis"
on samples extracted at the oxygerf analyzer at 30-day interval's.  A multi-
point calibration will also be performed at these intervals.  Daily
calibration data (zero and calibration drift) will be available from
instrument log records.  As an additional procedure, EMB could.perform
regular audits with NBS gases.

     The scrubber was surveyed to determine the easiest way to monitor the
amount of flue gas bypassed.  There are presently no access ports available
in the bypass flue.  Flow exiting each module is monitored using calibrated
annubars.  Total flow from the boiler is not monitored.  It was decided
that the initial approach should be to calculate the total furnace exhaust
flow based on F-factor, coal feed, oxygen, temperature, and moisture results.
The sum of gases exiting modules will be subtracted to determine bypass.
It should be noted that this may prove to be an inadequate approach since
small errors in the larger flow rate determinations could result in large
percentage errors in the absolute value of the bypass.  As soon as a base
of data is available, calculation will be performed to estimate the accuracy
of this procedure.  In order to confirm the annibar calibrations, PEDCo
will perform velocity traverses now and at 30-day intervals at each scrubber
outlet.

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     In discussions with CSOEC personnel, it was determined that the
easiest way to obtain the necessary boiler parameters would be to
have the scrubber operator record the necessary information on a revised
scrubber log sheet.  Since the operator calls the boiler room at hourly
intervals, information in addition to boiler load can be obtained.   In
order to simplify this procedure, requested boiler parameters were limited
to:  (1) boiler load, MW, (2) total coal feed in past hour, (3) scrubber
inlet temperature, and (4) boiler 02.  Copies of the forms to be used by
CSOEC were obtained.  Weekly test intervals will run from midnight Thursday
to midnight Thursday.  Strip charts will be collected at corresponding
intervals for the analyzer system.

     In further discussion with CSOEC personnel, it was determined that
the operating results (percent S02 removal) reported earlier (record of
communication—Winton Kelly dated May 30, 1978) were obtained when the
system was operated under maximum removal conditions for the unit compliance
and acceptance tests.  These conditions could not be maintained for more than
one to two weeks.  The required slurry usage was excessive and the system
thickener was too small to handle the resultant fine material.  The fines
buildup quickly leads to blinding and complete system pluggage.  This was
experienced during the test and as a result, only one module was operational
during the visit.  The other module was being cleaned for restart.   Efficiency
levels observed during the earlier tests would not be applicable to longer
term averages.

     At the time of this visit, the operating module was treating about
50 - 60 percent of the flue gases, at full boiler load.  The resulting      ~
emission levels ranged from 550 to 650 ppm at 5 percent 02 on June 16.
On June 15, the S02 concentrations ranged from 450 to 550 ppm at 7.5
percent Q?.  The inlet S02 concentrations were 2900 to 3000 ppm at 5
percent 0~.  S0? efficiencies based on these averages are 75 to 79 percent.
No attempt was made to evaluate the variability of the data since most of
the recent operating time was with only one operational module and
current strip charts would have to be removed from the recorders.

     CSOEC practices require that when one module is down, the remaining
module treats as much gas as possible.  This condition probably overloads
the system, resulting in less than design S02 removals.  An availability
test on the system should be performed during our monitoring study.  During
this test, at least one module must be available continuously for 30 days
and still be in operational condition at the test conclusion.
b
     In additional discussions, it was determined that the scrubber
system was designed for automatic control, and the inlet and outlet S02
levels were control parameters.  However, CSOEC has not been able to run
on automatic for many reasons, one of them being the lack of successful
analyzer operation.  They also feel that the cost of manpower  necessary
for instrument maintenance would be excessive.

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                                  4

V.   CONCLUSIONS AND RECOMMENDATIONS

     The instrument system design appears to have incorporated all
improvements developed in earlier tests.  The system should yield high
levels of data availability.  PEDCo is performing in an excellent manner
and conscientiously attending to information gathering concerning instru-
ment operation.  A formal program of quality assurance has been formulated
and will be instituted.  Additional relative accuracy tests will be
performed on the oxygen analyzers.  Scrubber bypass will be estimated
using a different technique unless the calculations prove inadequate.
The results obtained during compliance testing are not expected to be
representative of long-term operation.  Current operation with one
module is about 75 to 80 percent S02 removal on about half the gas flow.
No estimate can be made from test information concerning operation with
both modules on line.

cc:  Charles Sedman
     Ken Durkee
     Dick Gerstle, PEDCo
     Larry Jones
     Lou Paley, DSSE
     Roger Shigehara
     Gene Smith

 FILE:   78-SPP-28

 ESED:EMB:W.KELLY:mew:Rm730MU;x5243:6/27/78

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