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 ------- 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 ------- 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 ------- 7488/B 12-18-79 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. ------- 7488/B 12-18-79 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 ------- 7488/B 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 ------- 7488/B 12-18-79 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 ------- 7488/B 12-18-79 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. ------- 7488/B 12-18-79 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. ------- 7488/B 12-18-79 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 ------- 7488/B 12-18-79 (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. ------- 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 ------- 7488/B 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. 10 ------- 7488/B 12-18-79 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 11 ------- 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 ------- 7488/B 12-18-79 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. 13 ------- 7488/B 12-18-79 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 14 ------- 7488/B 12-18-79 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 15 ------- 7488/B 12-18-79 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 16 ------- 7488/B 12-18-79 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. 17 ------- 7488/B 12-18-79 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. 18 ------- 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 ------- 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) ------- 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. ------- 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. ------- 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 ------- ACUREX Aerotherm Person placing call: Subject: ATTACHMENT 2 TELECOMMUNICATION Date: Contact: My. JLoa/sri/te Want Followup required: D Yes D No Responsible person/date Name: Phone Number: Title: Synopsis of discussion: $ ^^ << SL. Copies to be routed to: m EED 04H ------- |