EPA-450/3-89-12
   OVERVIEW OF THE REGULATORY BASELINE,

 TECHNICAL BASIS, AND ALTERNATIVE CONTROL

  LEVELS FOR SULFUR DIOXIDE (SO2) EMISSION

STANDARDS FOR SMALL STEAM GENERATING UNITS
            Emission Standards Division
         U.S. Environmental Protection Agency
             Office of Air and Radiation
       Office of Air Quality Planning and Standards
         Research Triangle Park, N.C. 27711
                 May 1989

-------
This report has been reviewed by the Emission Standards Division of the
Office of Air Quality Planning and Standards, EPA, and approved for
publication.  Mention of trade names or commercial products is not intended
to constitute endorsement or recommendation of use.  Copies of the report
are available through the Library Service Office  (MD-35), U.S. Environmental
Protection Agency, Research Triangle Park, N.C.  27711, or from National
Technical Information Services, 5285 Port Royal Road, Springfield,
Virginia  22161.
                                      ii

-------
                              TABLE OF CONTENTS
Section                                                               Page
  1.0     INTRODUCTION	    1
  2.0     SUMMARY  .	    2
  3.0     OIL S02 EMISSIONS AND CONTROL TECHNIQUES   	    4
          3.1  REGULATORY BASELINE EMISSION LEVELS  	    4
          3.2  MEDIUM, LOW, AND VERY LOW SULFUR OIL	    4
          3.3  SODIUM SCRUBBING FGO SYSTEMS 	    7
          3.4  DUAL ALKALI FGD SYSTEMS	12
          3.5  LIME/LIMESTONE FGO SYSTEMS	14
          3.5  ALTERNATIVE CONTROL LEVELS		14
  4.0     COAL S02 EMISSIONS AND CONTROL TECHNIQUES	15
          4.1  REGULATORY BASELINE EMISSION LEVELS	  .  .  .    15
          4.2  LOW SULFUR COAL	:..........   15
          4.3  SODIUM SCRUBBING  FGD SYSTEMS	   18
          4.4  DUAL ALKALI FGD SYSTEMS	20
          4.5  LIME/LIMESTONE FGD SYSTEMS  .  .  .	   22
          4.6  LIME SPRAY DRYING FGD SYSTEMS	   23
          4.7  fLUIDIZED BED COMBUSTION (FBC)  	   26
          4.8  ALTERNATIVE CONTROL LEVELS  	   32
   5.0     REFERENCES  .  .	  .   .  .   33

-------
LIST OF TABLES
Table
3-1
3-2
3-3.
3-4
4-1
4-2
4-3
SO- EMISSION RATES FOR VARIOUS OIL TYPES 	
EMISSION DATA FROM SODIUM SCRUBBING FGO SYSTEMS APPLIED
TO OIL-FIRED SMALL STEAM GENERATORS 	
AVERAGE RESULTS FROM SODIUM SCRUBBING FGD SYSTEMS APPLIED
TO OIL-FIRED SMALL STEAM GENERATORS 	
SHORT-TERM EMISSIONS DATA FOR DUAL ALKALI SYSTEMS USING
EPA TESTING METHODS 	 - 	
MAXIMUM EXPECTED EMISSION RATES FOR COAL COMBUSTION . . .
SUMMARY OF SHORT-TERM EMISSIONS DATA FOR FOUR INDUSTRIAL
LIME SPRAY DRYING FGD SYSTEMS 	
FLUIDIZED BED COMBUSTION EMISSION TEST DATA 	
Pace
5
9
11
13
17
24
27
       iv

-------
                               LIST OF FIGURES

Figure                                                                Page

 4-1      Daily Average SCL Removal, Boiler Load, and Slurry pH
          For Coal-Fired Boiler Equipped with a Sodium Scrubber  .  .     19

 4-2      Daily Average SO- Removal Efficiency for the FBC Boiler
          at Prince Edward Island  	     29

 4-3      Daily Average Ca/S Molar Feed Ratio for the FBC Boiler at
          Prince Edward Island  	     30

 4-4      Daily Average Boiler Load for the FBC Boiler at Prince
          Edward Island 	     31

-------
                             1.0   INTRODUCTION

     This report provides an overview of the regulatory baseline, technical
basis, and alternative control levels available for developing new source
performance standards (NSPS) limiting sulfur dioxide (SO-) emissions from
small steam generating units (i.e., boilers).  Small boilers are defined as
industrial-commercial-institutional steam generating units having a heat
input capacity of 29 MW  (100 million Btu/hour) or less.
     Many SO- control techniques were considered for the purpose of
evaluating alternative SO- emission standards for small boilers.  Detailed
discussions of the design and operating principles of each of these
techniques can be found  in the report entitled "Small Steam Generating Unit
Characteristics and Emission Control Techniques"  and References 2 and 3.
     This report discusses the quantity of S02 emissions generated and the
technical feasibility of controlling those emissions from boilers with heat
input capacities of 29 MW (100 million Btu/hour) and less.  However, this
report does not address  natural gas or nonfossil fuels because they have
negligible amounts of sulfur and correspondingly low SO- emissions
potential.

-------
                                2.0   SUMMARY

     The national average State implementation plan (SIP) emission limit for
small, oil-fired boilers is 1,010 ng/J (2.35 Ib/million Btu).  However,
projected fuel prices are available only for fuel o.ils capable of meeting
S02 emission limits of 1,290 and 690 ng/J (3.0 and 1.6 ID/million Btu).
Consequently, for purposes of analysis, the regulatory baseline emission
level selected for oil-fired boilers is 1,290 ng/J (3.0 Ib/million Btu) heat
input.
     The control techniques considered for reducing SO- emissions from
oil-fired boilers include medium sulfur oil, very low sulfur oil, sodium
scrubbing flue gas desulfurization  (FGD), dual alkali FGD, and
lime/limestone FGD.  The use of medium sulfur oil can reduce SO- emissions
to 690 ng/J  (1.60 Ib/million Btu) heat input.  Similarly, the use of very
low sulfur oil can reduce SO- emissions to 210 ng/J (0.50 ID/million Btu)
heat  input.  The use of FGD systems can reduce SO- emissions from oil-fired
boilers by 90 percent or more over  uncontrolled levels.  Emission levels of
690 ng/J (1.6 Ib/million Btu), 210  ng/J (0.50 Ib/million Btu), and
90 percent SO- reduction, therefore, are selected as Alternative Control
Levels 1, 2,  and 3, respectively, to represent the SO- control performance
of medium sulfur oil, very low sulfur  oil, and FGD systems.
      The national average SIP emission limit for small, coal-fired boilers
is 1,460 ng/J  (3.4 Ib/million Btu)  heat input.  However, projected fuel
prices are only  available for coals capable of meeting SO- emission limits
of 1,550 and 1,120 ng/J  (3.6 and 2.6 Ib/million Btu).  Consequently, for
purposes of  analysis, the regulatory baseline emission level selected  for
coal-fired boilers is 1,550 ng/J (3.6  To/million Btu).
      The control techniques considered for reducing S02 emissions from
coal-fired boilers include low sulfur  coal, sodium scrubbing FGD, dual
alkali FGD,  lime/limestone FGD,  lime spraying drying FGD, and fluidized bed
combustion  (FBC).  The  use of low  sulfur coal can reduce SO- emissions from
small coal-fired boilers to 520  ng/J  (1.2 million Btu/hour).  The use  of FGD

-------
systems or FBC units can reduce SO- emissions by 90 percent or more over
uncontrolled levels.  An emission level of 520 ng/J (1.2 1 fa/million Btu)
heat input is, therefore, selected as Alternative Control Level 1 and
90 percent reduction is selected as Alternative Control Level 2 to represent
the SO- control performance of low sulfur coal and FGD or FBC systems,
respectively.

-------
               3.0   OIL S02 EMISSIONS AND CONTROL TECHNIQUES

     The control techniques considered for reducing SO- emissions from small
oil-fired boilers include medium sulfur oil, very, low sulfur oil, sodium
scrubbing FGD, dual alkali FGD, and lime/limestone F6D.

3.1  REGULATORY BASELINE EMISSION LEVELS

     The regulatory baseline SO- emission level for small oil-fired boilers
is based on the national average SIP emission limit for small, oil-fired
boilers.  The national average SIP SO- emission limit for small oil-fired
boilers is 1,010 ng/J (2.35 Ib/million Btu) and is essentially independent
of boiler size.  However, projected fuel prices are available only for oils
capable of meeting SO- emission limits for  1,290 and 690 ng/J (3.0 and
1.6 Ib/million  Btu).  As a result, a regulatory baseline of  1,290 ng/J
(3.0 Ib/million Btu)  is selected for purposes of analysis.

3.2  MEDIUM,  LOW, AND VERY LOW SULFUR OIL

     The sulfur content of fuel oil determines the SO-  emission  rate  from  an
oil-fired steam generating unit.  Use of medium, low, or very low sulfur oil
limits  SO- emissions  by reducing the amount of sulfur available  for SO-
formation.  Table  3-1 presents the oil classification scheme used to
represent fuel  oils fired  in  steam generating units.   In this classification
scheme,  oil  is  classified  by  its sulfur content.  This  classification scheme
originated from classifications used by the U.S. Department  of  Energy to
study  fuel oil  use patterns and to report  refinery production data.   The
classifications reflect the fact that many distillate  and  residual oils  are
produced to meet  market demands created by existing  Federal, State,  and
local  S02 emission regulations.  For example,  "low  sulfur" distillate and
residual  fuel oils can  be fired to meet the 1971 NSPS  (40  CFR  Part 60,
Subpart D) emission limit of  340 ng/J  (0.80 Ib/million  Btu)  heat input for
steam  generating units  with a heat  input  capacity greater  than  73 MW
 (250 million  Btu/hour),  or more  stringent  standards  adopted  by  Stats  or

-------
            TABLE 3-1.  S02 EMISSION RATES FOR VARIOUS OIL TYPES
                                                              SO-
                                                          Emission Rate
Oil Type                                              ng/J (Ib/million Btu)


Very Low Sulfur                                          .   130 (0.3)


Low Sulfur                                                   340 (0.8)


Medium Sulfur                                                690 (1.6)


High Sulfur                                                1,290 (3.0)

-------
local governments.  Factors such as refinery techniques, storage and
transportation methods, and fuel handling at the steam generating unit site
serve to make a given fuel oil shipment relatively homogeneous with respect
to fuel sulfur content.  Thus, there is little variability in SO- emissions
resulting from the combustion of a specific fuel oil shipment.
     Fuel oils with low sulfur contents are generally produced by refining
low sulfur content crude oils, however, a number of hydrodesulfurization
(HDS) processes are available for producing low sulfur oil from high sulfur
oil.     Although both distillate oils and low sulfur residual oils can be
produced from any crude oil, most low sulfur residual oils are produced from
low sulfur crude oils and/or by blending with lower sulfur oils.  Low sulfur
oils can be fired in any steam generating unit designed to fire oil,
although different burners may be required to achieve good combustion and
fuel heating may be required to reduce viscosity for pumping  and proper
atomization at the burner tip.
     A distinction exists between the sulfur content of most  residual oils
and distillate oils.  Residual oils generally are higher  in sulfur content
and  have a wider  range of sulfur contents- than distillate oil.  The sulfur
content of residual oil, for example, can vary from as little as 0.3 weight
percent to over 3.0 weight percent.  Although the sulfur  content of
distillate oil can be  as low  as 0.2 weight percent, the maximum sulfur
content  is limited to  0.5 weight percent  by  fuel oil specifications adopted .
by  the American Society  for Testing and Materials  (ASTM).
     Medium sulfur residual oil  is widely available throughout the United
States.   Generally speaking,  low  and very low  sulfur residual oils are not
widely available  throughout the  United  States.   Distillate oil, however,  is
widely available.  The maximum sulfur content of distillate oil  (0.5 weight
percent), therefore,  serves as a useful benchmark  for identifying  the  sulfur
content  of those  very  low  sulfur fuel oils that  are widely available
throughout the United  States.   In  a  few areas,  both distillate oil  and  very
low sulfur residual oils with  sulfur  contents of less than 210 ng/J
 (0.5 Ib/million Btu)  heat  input  will  be available.

-------
     Because of their national availability and extensive use in small steam
generating units, medium sulfur oils and very low sulfur oils (distillate
oil and very low sulfur residual oils) are considered demonstrated control
techniques for reducing SO- emissions from small steam generating units.

3.3  SODIUM SCRUBBING FGD SYSTEMS

     Sodium scrubbing FGO systems employ an aqueous solution of sodium
hydroxide  (NaOH) or sodium carbonate  (Na-CO,) in the scrubber to absorb  SO-
from the boiler  flue gas.  Sodium scrubbers are the most extensively  used
wet FGD systems  in the  industrial boiler sector and have been widely  applied
on small oil-fired boilers.
     The vast majority  of sodium scrubbing systems have been applied  on
small  oil  field  steam generating units.  Sodium scrubbers used in these
applications are package systems that are skid-mounted, shipped to the site,
and installed for operation witji a  minimum of on-site fabrication.  One
report estimates that 89 percent of all sodium scrubbers in operation are
used on oil' field steam generating  units, and 74 percent of all sodium
scrubbers  in operation  are  used on  boiler size equivalents  (i.e., the heat
generating capacity  serviced  by the scrubber) less than 29 MW  (100 million
Btu/hour).6
     These boilers  usually  operate  under constant, high-load conditions,
whereas  other  small  industrial-commercial-institutional boilers can
experience significant  load swings.  However, boiler  load  swings  can  be
monitored  and  accommodated  by the  scrubber  system's process control
 instrumentation and,  as a  result,  have  not  been  shown  to be deleterious  to
 sodium scrubber operation.
      In  response to changes in flue gas flow rate  and/or SO- gas
 concentration,  changes  can  be made to the  scrubber liquid  pumping rate  and
 the reagent addition rate.   Moreover, the  buffering capacity  of these
 systems  allows  changes  to  be made  without  affecting SO-  removal  performance.
 The popularity of sodium scrubbers can  be  attributed  primarily to their ease
 of operation (requiring minimal  operator training  and attention)  and overall
 reliability.

-------
     Table 3-2 presents SO- emissions data for 20 oil-fired steam generating
units equipped with sodium scrubbers and operated to produce steam for
tertiary oil recovery.  All SO- emission tests were short-term compliance
tests (typically over a 3-hour period).  Sulfur dioxide emissions were
measured using either EPA Reference Method 8 or continuous emission monitors
(CEM).  The short-term CEM tests were performed using ultraviolet
photometry.  These tests are considered as alternative methods to measure
SO-.  From this table, it can be seen that SO- removal efficiency ranged
from 87.5 to 99.5 percent for oils having sulfur contents ranging from 0.6
to 1.66 weight percent.  Boiler operating loads ranged from 67 to 108
percent of full load.
     Table 3-3 shows that SO- removal efficiency for these 20 sodium
scrubbers averaged 95.2 percent.  The average SO- outlet emissions were
30 ng/J (0.07 Ifa/million Btu).  The sulfur content of the oils and operating
load for the 20 boilers averaged 1.21 weight percent and 87.5 percent of
full load, respectively.
     Although long-term performance data are not available for sodium
scrubbing systems operating on small oil-fired boilers, the long-term
performance of sodium scrubbing systems on oil-fired boilers can be inferred
from analyzing the long-term performance of sodium scrubbers on coal-fired
boilers.  Thirty days of SO- emission data were available and were analyzed
for SO- reduction variability for one sodium scrubbing FGO system on a
coal-fired  boiler.   The data are discussed below in Section 4.3.  Although
these data were collected  for a sodium .scrubber on a larger [55 MW
 (188 million  Btu/hour)] boiler, the variability of a smaller sodium
scrubbing  system should not be significantly different.  Also, because the
sulfur  content of oils  is  more consistent and less variable than the sulfur
content of coals, the variability results using the 30-day SO- emissions
data  from  a coal-fired  boiler would be  a conservatively high estimate of  the
emission variability for  sodium scrubbers on oil-fired boilers.
     The variability results from the coal-fired boiler/sodium scrubber
 system, when  applied to oil-fired boiler/sodium scrubber systems,  indicate
 that  sodium scrubbers  on  oil-fired  boilers could comply with a 90  percent
SO-  reduction specification  using a 30-day rolling averaging period  if  the
                                       8

-------
TABLE 3-2. EMISSION DATA FROM SODIUM SCRUBBING FGD SYSTEMS APPLIED TO
              OIL-FIRED SMALL STEAM GENERATORS (8)

Boiler
1.0.
7
8
12
30
6
It
U-24
22-4
22-41
30-7
30-71
1
2
34
38
64
4
3
5
U-23
Abaorber
type (a)
LJE
LJE
LJE
LJE
SB
SB
SB
TA(b)
TA
TA(b)
TA
VS
VS
VS
VS
VS
ST
UNK (c)
UNK
UNK
Boiler
equivalent
•Ize. MW
(mUUonBlu/tv)
heal Input
6.7(23)
8.1 (27.6)
14.7 (50)
14.7(50)
16.2(55.2)
7.3 (25)
14.7 (50)
6.4 (22)
6.4 (22)
14.7 (50)
14.7(50)
18.3 (62.5)
18.3 (62.5)
18.3 (62.5)
18.3 (62.5)
18.3 (62.5)
18.3 (62.5)
18.3 (62.5)
8.8(30)
7.3 (25)
OU
autfur
content
(percent)
1.00
1.00
1.65
1.34
0.60
1.00
1.46
1.66
1.61
1.58
1.66
0.85
1.15
1.00
1.10
1.10
1.01
0.80
1.20
1.46
Percent
of
lull
load
92 (d)
75 (d)
92 (e)
96 (e)
73 (d)
95 (d)
88 (e)
71
67
105
101
66 (d)
91 (d)
84 (d)
82 (d)
82 (d)
108(d)
94 (d)
78 (d)
92 (e)
Scrubber
Inlet
pH
NA(f)
NA
NA
NA
NA
NA
NA
7.23
7.57
6.97
7.10
NA
NA
NA
NA
NA
NA
NA
NA
NA
Slowdown
PH
NA
NA
NA
NA
NA
NA
NA
6.60
6.27
6.20
5.75
NA
NA
NA
NA
NA
NA
NA
NA
NA
S02
removal
efficiency
(percent)
91.0
89.0
96.9
96.3
95.0
99.5
98.1
87.5
94.4
89.7
95.8
97.0
97.4
96.0
96.0
96.0
98.0
99.2
93.5
98.1
Outlet SO2
emltslons
(ng/J)
(g)
38.7
43.0
21.5
25.8
17.2
1.7
12.9
103.0
38.7
77.4
34.4
17.2
12.9
21.5
17.2
21.6
19.2
'4.3
30.1
12.9
SO2
test method
(number of rune)
(h)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
CEM (4)
CEM(1)
CEM (5)
CEM(l)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)
EPA 8 (3)

-------
                      TABLE 3-2.  EMISSION DATA FROM SODIUM SCRUBBING FGD SYSTEMS APPLIED TO
                                   OIL-FIRED SMALL STEAM GENERATORS (CONTINUED) (8)
(a) LJE • Liquid Jet aductor; SB - Spray baffle; TA • Tray absorber; VS -         (e) The heat Input during the test Is determined using the
Venturl scrubber; 8T • Spray tower.                                       F-faclor. the flue gas flow rate, and the flue gas oxygen
                                                                    content.
(b) Both sites use two tray absorbers. Two tray absorbers are known to have
lower SO2 removal efficiencies than three tray absorbers. The other two sites     (f) NA - Not available.
(22-41 and 30-71) use three tray absorbers.
                                                                    (g) DMde ng/J by 430 for conversion to Ib/mllllon Btu.
(c) UNK . Unknown.
                                                                    (h) All tests were short-term.(about 1 hour per run). EPA 8 -
(d) The heat Input during the test Is determined by multiplying the oil flow          EPA Reference Method 8; CtM - Continuous emission monitor.
rate to the boiler and an assumed heating value of 43.000 kJ/kg (16,500
Blu/lb). Results of fuel analysis (actual heating value) are not available.

-------
    TABLE 3-3.  AVERAGE RESULTS FROM SODIUM SCRUBBING FGD SYSTEMS APPLIED
                    TO OIL-FIRED SMALL STEAM GENERATORS9
SQ? Removal Efficiencies, Percent
Average Efficiency (± Standard Deviation)                  95.2 ± 3.4

Outlet SO- Emissions. no/J Mb/IP6 Btu)
Average SO- Outlet Emissions
  (± Standard Deviation)                              30 ± 26  (0.07 ±  0.06)
Sulfur Content of Oil. Weight Percent
Average Sulfur Content of Oil Fired
  (± Standard Deviation)                                  1.21 ± 0.31
Boiler Load. Percent of  FullLoad
Average Load (± Standard Deviation)                       87.5 ± 11.3
                                       11

-------
mean SO- reduction is 91 percent or greater.  The average SOg removal
efficiency of the short-term test data summarized above was 95.2 percent,
well above the required 91 percent reduction level.  Thus, the ability of
sodium scrubbers to continuously reduce SO- emission by 90 percent on a
30-day rolling average basis is considered demonstrated.

3.4  DUAL ALKALI FGD SYSTEMS

     Dual alkali FGD systems are the second most prevalent wet FGD
technology for industrial  boiler applications.  The dual "alkali FGD process
is  similar to sodium scrubbing  FGD in the absorption stage; both
technologies use a clear sodium solution for SO- removal.  However, dual
alkali FGD includes a regeneration stage where lime or limestone is used to
regenerate the active sodium alkali for S02 sorption.  Dual alkali
technology has been applied primarily to coal-fired units.  However,
emissions data were available  for one dual  alkali system  applied to an
oil-fired steam generating unit.    As shown in Table 3-4, the SO- removal
performance  of the dual  alkali  system applied to the oil-fired unit  is
comparable to that of the  coal-fired units.  The data for the oil-fired  unit
were obtained from a compliance test; the test duration was unavailable.
The boiler had  a  heat  input capacity of 91  MW (310 million Btu/hour).  The
sulfur content  of the oil  fired was  1.5 weight percent.   The outlet
emissions were  0.091  Ib  SO-/mi 11 ion  Btu, and the SO- removal efficiency  was
91.7 percent.
     Long-term  performance data are  not available  for dual alkali  systems
operating  on small oil-fired  boilers.  However, the design and operating
principles  for  dual  alkali technology are similar  for both coal- and
oil-fired  boilers.   Thus,  the  performance of these systems on oil-fired
boilers  can  be  evaluated from  analyzing their performance on large and  small
coal-fired  boilers.   Seventeen and  24 days  of SO-  emission data were
available  for a dual  alkali system  comprising two  scrubbers  applied  on  two
coal-fired  boilers with  a single  regeneration section.  These test data  are
discussed  below in  Section 4.4.  The average SO- removal  efficiency  of  these
scrubbers  was 92  percent.
                                       12

-------
                  TABLE 3-4.  SHORT-TERM EMISSIONS DATA FOR DUAL ALKALI SYSTEMS
                                 USING EPA TESTING METHODS (11)

Boiler capacity
Company treated (a) Fuel
(location) (million Blu/hour) type
ARCO Polymer* 1,360 Coal
(Monaca, PA)
General Motors 570 Scrubber! Coal
(Parma, OH) Scrubber II Coal
Grlssom Air Force Base 140 System! Coal
(Peru, IN) System II Coal
Santa Fe Energy 310 Oil
Average
Sulfur content
of fuel
(weight percent)
2.5 - 2.8
2.5
2.5
3.0 - 3.5
3.0 • 3.5
1.5
2.61
Outlet SO2
emissions
(Ib/mlllon Btu)
0.65
0.30
0.32
0.56
0.38
0.091
0.38
SO2 removal
efficiency
(percent)
68.0 (b)
92.2 (c)
91.6(d)
88.1 (b)
94.2
91. 7 (b)
91.0
(a) Total capacity of all boilers treated.
(b) Data from short-term compliance tests.
(c) 24-day test.
(d) 17-day test.

-------
     Thus, the ability of dual alkali scrubbers to reduce SO- emissions by
90 percent on a 30-day rolling average basis for small oil-fired steam
generating units is considered demonstrated.

3.5  LIME/LIMESTONE FGD SYSTEMS

     Lime/limestone FGD systems employ a slurry of calcium oxide (CaO, lime)
or calcium carbonate  (CaCO,, limestone) to remove SO- from industrial-
commercial -institutional steam generating units.  Although no emission data
are available to document the performance of lime/limestone FGO systems on
oil-fired boilers, emission data are available for lime and limestone FGD
systems  applied to small and large coal-fired units.  These data, which are
presented and discussed below in Section 4.5, show S02 removal efficiencies
for lime and limestone FGD systems of 91.5 and 94.3 percent, respectively.
Due to the similarity in system design and operation, it can be inferred
from analyzing this performance data that the performance of a
lime/limestone FGD system as  appl-ied to an oil-fired-boiler would be
comparable to the same system applied to a coal-fired boiler.

3.6  ALTERNATIVE CONTROL LEVELS

     The evaluation of SO- control techniques for small oil-fired boilers
indicates that use of medium  sulfur  oil, very low sulfur oil, sodium
scrubbing FGD  systems, dual alkali FGD systems, and  lime/limestone  FGO
systems  are  demonstrated techniques  that could serve  as the technical basis
for developing NSPS for  small boilers.  Medium sulfur oil combustion will
reduce  SO-  emissions  to  690 ng/J  (1.6 Ib/million Btu); consequently, this
level  is selected  as  Alternative  Control Level 1.  Very low sulfur  oil
combustion  will  reduce SO- emissions to 210  ng/J  (0.50 Ib/million Btu) heat
input;  thus,  an  emission level of 210 ng/J  (0.50 Ib/million Btu) heat input
is selected as Alternative Control Level 2.   Flue gas desulfurization
systems  are capable of  90  percent SO- emission reduction and, as a  result,
90 percent reduction  is  selected  as  Alternative Control Level 3.
                                       14

-------
               4.0   COAL S02 EMISSIONS AND CONTROL TECHNIQUES

     The control techniques considered for reducing S02 .emissions from small
coal-fired boilers include low sulfur coal, sodium scrubbing FGD, dual
alkali FGD, lime/limestone FGD, lime spray drying FGD, dry alkali injection,
FBC, limestone injection multistage burner (LIMB), coal gasification, and
coal liquefaction.
     Limestone injection multistage burner and dry alkali injection
technologies are still in the process development stage and, thus, are not
considered further.  Despite the potential of coal gasifi-cation for
producing a low sulfur fuel, fewgasifiers have been designed specifically
for small boiler applications.  Furthermore, coal gasification is unlikely
to achieve widespread application to new  small boilers  in the near future.
Hence, coal gasification is not examined  further.  Several pilot-scale coal
liquefaction plants have been built and tested.  However, no commercial coal
liquefaction plants have been constructed to date, nor  are any planned or
under construction.   In view of the long  lead time associated with the
design,  construction, and  start-up of  coal liquefaction plants,  it is
unlikely that  these fuels  will be available for use  in  small boiler
applications  in the near future.  As a result, coal  liquefaction  also is not
considered  further.

4.1   REGULATORY BASELINE  EMISSION LEVELS

      The regulatory baseline SO- emission level  for  small coal-fired boilers
is  based on the national  average SIP emission  limit  for small, coal-fired
boilers.  Average SO- limits for small,  coal-fired boilers  range from
1,400 to 1,510 ng/J  (3.26  to 3.51 Ib/million  Btu)  for boilers  of 29  and
2.9 MW (100 and 10 million Btu/hour) heat input  capacity, respectively.   The
overall  national  average SIP emission  limit  is  1,460 ng/J  (3.4 Ib/million
Btu).   However, projected  fuel  prices  are only  available for coals capable
of  meeting S02 emission limits of  1,550  and  1,120 ng/J (3.6 and
2.6 Ib/million Btu)  heat input.  As  a  result,  a  regulatory  baseline  of
 1,550 ng/J (3.6 Ib/million Btu)  heat  input is  selected for  purposes  of
analysis.

                                       15

-------
     As noted in Table 4-1, the medium sulfur Type F coal which corresponds
to the regulatory baseline is characterized by a maximum expected SO-
emission rate of 1,550 ng/J (3.6 Ib/million Btu) heat input.  The difference
between this value and the long-term average S02 emission rate of 1,230 ng/J
(2.86 Ib/million Btu) heat input reflects the allowance for S02 emissions
variability that applies to this coal type.

4.2  LOW SULFUR COAL

     Use of low sulfur coal limits SO- emissions by reducing the amount of
sulfur available in the fuel for S02 formation.  Low sulfur coal is defined
as coal that can meet an emission limit of 520 ng/J (1.2 Ib/million Btu)
heat input on a continuous basis using a 30-day rolling average without
additional SO- control.
     Low sulfur coal is obtained primarily from naturally occurring low
sulfur coal deposits.  Low sulfur coal may also be produced through coal
treatment to reduce the naturally occurring sulfur content.  A commercially
available method for producing  low sulfur coal is physical coal cleaning
(PCC).  The design and operating factors and the mechanism by which PCC can
reduce SO- emissions are discussed in Reference 12.  Low sulfur coal  can  be
burned  in any small  boiler designed  to fire coal, so its applicability  is
not  limited by  boiler size.
     Coal markets that supply  coals  with low sulfur contents  [520 ng/J
 (1.2 Ib/million  Btu) heat  input or less] have developed  throughout  the
Nation.   Because of  widespread  availability and extensive use of low  sulfur
coal  for  steam  generating  purposes,  use of low sulfur coal  is considered  to
be a demonstrated technique  for reducing SO- emissions  from small steam
generating  units.
      Unlike  SO-  emissions  from oil combustion, SO- emissions  from coal
combustion  exhibit  variability because the sulfur content of  coal is  not
homogeneous.  Coal  produced  from  a single coal mine will vary in sulfur
content.  This  variability may be further  influenced by mining  practices.
Whether coal  is  cleaned  or blended with other coals also will  influence its
S02 emissions  variability  when it is combusted.
                                       16

-------
     TABLE  4-1.   MAXIMUM  EXPECTED  EMISSION  RATES  FOR  COAL  COMBUSTION
                                                                     13



Coal
Category
Low Sulfur
Low Sulfur
Medium Sulfur0
Medium Sulfur0
High Sulfur0
High Sulfur0


Coal
Typed
Type B
Type D
Type E
Type F
Type 6
Type H
Long-Term Average
SO- Emissions

ng/J (ID/million Btu)
464 (1.08)
620 (1.45)
900 (2.10)
1,230 (2.86)
1,790 (4.15)
2,380 (5.54)
Maximum
Expected
SO- Emission Ratea

ng/J (Ib/mi
520
690
1,120
1,550
2,240
2,920

llion Btu)
(1.2)
(1-6)
(2.6)
(3.6)
(5.2) .
(6.8)
 Once in 10-year maximum expected 30-day rolling average SO- emission rate.

 Based on a daily average SO- emission rate relative standard deviation
 of 0.10.                   i

°Based on a daily average SO- emission rate relative standard deviation of
 0.20.                      '

 All coals are bituminous coals.
                                      17

-------
     The SO- emissions variability associated with combustion of low sulfur
coals has been addressed in earlier reports.       This variability leads to
the maximum expected emission rates shown in Table 4-1.  These maximum
expected emission rates represent the SO- emission limits that could be
achieved by combustion of low sulfur coals in small boilers.

4.3  SODIUM SCRUBBING FGD SYSTEMS

     Sodium scrubbing FGD technology has been directly applied on small,
coal-fired boilers and is commercially available for small, coal-fired
boiler applications.  One leading manufacturer of sodium scrubbers has
designed, constructed, and started up systems to service steam generators as
small as 1.5 MW  (5 million Btu/hour).
     Emission test data are available to document sodium scrubber
performance for  coal firing.  Thirty days of certified CEM test data were
gathered from a  sodium scrubber applied to a pulverized coal-fired boiler
rated at 55 MW (188 million Btu/hour) heat input.18  The FGD system tested
was  a tray  and quench liquid  scrubber that consisted of a three-stage
impingement tower with a Chevron mist eliminator.  The scrubbing medium was
a  50 percent  aqueous NaOH solution.  The makeup rate to the scrubber was
2.2  liters  per second  (1/s)  (35 gal/rain).  The scrubbing solution pH was
8.1. The boiler operated at  loads between 40 and 60 percent of full load
and  averaged  48  percent of  full load for the test duration.  The sulfur
content  of  the coal fired was 3.6 weight percent.  The design SO- efficiency
of this  system was  90  percent at  an  inlet SO- concentration of 2,000 ppmv.
     Figure 4-1  shows  consistently high SO- removal efficiencies for this
system,  averaging 96.2  percent  for the  test period.  The daily average
outlet  S02  emissions  ranged from  56  to  267  ng/J  (0.13  to 0.62 To/million
Btu), averaging  86  ng/J  (0.20 1 fa/mill ion Btu) for  the  30-day test period.
     The performance  data  from  this  30-day  test were analyzed for SO-
emission reduction  variability.   The results of the variability analysis
indicate that a  long-term  mean  of 91  percent SO- reduction  would be
necessary to  comply with  a  90 percent  SO-  reduction requirement based  on  a
30-day  rolling  average with no  more  than one exceedance  every  10 years.     A
relative standard deviation (RSD)  of 1.2 percent and an  autocorrelation

                                       18

-------
   100
«
   80
    70
                          10
                                                          *«nov«1  • 34.2:
                                     15
                     20
                                                                     30
    90,
    801


!   «

I   50
*   40
     8'

     7'

     <>

     *»
                           10
10
                                                Average boiler load * 4£
                                      IS
                                      IS
                                   Test Otyt
                     20
                                                 Average slurry pH » 3.1
                                                20
    Figure 4-1.
                 Dally average  S02  removal, boiler load, and slurry pH
                 for coal-fired boiler equipped with a sodium scruboer1-
                                    19

-------
coefficient (AC) of 0.13 were determined from the SO- reduction data for
            21
this boiler.    If the mean SO- reduction performance of 96.2 percent
measured in the 30-day test were maintained at full load, then the sodium
scrubber would exceed the level necessary for compliance (i.e., 91 percent
SO- reduction) with a 90 percent SO- reduction specification using a 30-day
rolling average.
     The SO- removal efficiency of sodium scrubbing systems can vary during
load swings.  Further, changes in flue gas flow rate and SO- concentration
result in  imbalances in the sodium-to-sulfur ratio and the pH of the
scrubber solution.  Therefore, to maintain a constant SO- removal
efficiency, these two parameters must be adjusted during Toad swings.  With
proper design and operation of the scrubber system, consistently high SO-
removal rates can be maintained during fluctuations in boiler load.
     Although the sodium scrubber in this 30-day test was applied to a
boiler rated above  29 MW (100 million Btu/hour) heat input, the performance
data from  this  scrubber are applicable to small boilers.  This application
can be made because sodium scrubber design and operating characteristics
(e.g., L/G ratio, pH, gas distribution, etc.)"do not vary signiffcantly with
size in this general size range.  As a result, performance and variability
of smaller systems  would be similar to those of the scrubber examined here.
Thus, achievement of a 90 percent SO- reduction by sodium scrubbing systems
on small coal-fired boilers on a 30-day rolling average basis is considered
demonstrated.

4.4 DUAL  ALKALI  FGD SYSTEMS

     Dual  alkali  FGO technology has been applied primarily to large
coal-fired units, but  is commercially available for units of most sizes.
Tests of dual  alkali FGD systems operating on coal-fired steam generating
units have shown  short-term SO- removal efficiencies of greater  than
                                                             22
90 percent, with  long-term efficiencies of around  92 percent.
     Emission  data  are  available from two long-term tests to document dual
alkali  FGD system performance for  small coal-fired steam generating units.
As discussed  in Reference 23,  the  dual  alkali system tested consisted of two
S0£ absorbers,  each serving  a separate  steam generating unit,  and a single

                                      20

-------
regeneration section.  Seventeen days of test data were gathered from one
absorber applied to a coal-fired spreader stoker steam generating unit rated
at 40 MW (135 million Btu/hour), and 24-days of test data were gathered from
the other absorber applied to a unit rated at 23 MW (77 million Btu/hour).
Data were collected using continuous SO. emission monitors on both the inlet
and outlet of the FGD system.
     The sulfur content of the bituminous coal received at the plant during
these tests averaged 1,490 ng S02/J  (3.47 Ib S02/million Btu).  During these
tests, the steam generating  units  also burned oil with an average sulfur
content of 320 ng SO-/J (0.74 Ib SOg/nrillion Btu).  During both tests, the
dual alkali FGD system operated at a reliability level of 100 percent.
     In the 17-day test, the steam generating unit operated at an average
load of 67 percent, with the load  varying between 42 and 96 percent.  The
SO- removal efficiency averaged 91.6 percent.  In the 24-day test, the steam
generating unit operated at  an average load of 62 percent, with loads
varying between 5 and 95 percent.  The S02 removal efficiency averaged
92 percent.
     Results of the  24-day test show that at least 90 percent SO- removal
can be reliably and  consistently achieved on a small coal-fired steam
generating unit.   In addition, the results of the 17-day test indicate that
the S02 removal efficiency achieved  on a large steam generating unit .[>29 MW
(>100 million  Btu/hour)]  is  essentially the same as that achieved on a small
steam generating  unit  [£29 MW  (<100  million Btu/hour)].  This same level of
performance can be  achieved  at full  load conditions if vigorous gas-liquid-
contact is maintained  in  the absorber and the sodium-to-sulfur and
liquid-to-gas  ratios are maintained  at a level sufficient to  provide an
adequate  supply of  active  sodium  species.
      Based  on  these analyses of  system performance, dual alkali FGD  is  a
demonstrated technology  for  reducing SO- emissions  from small coal-fired
industrial-commercial-institutional  steam generating units  by 90  percent
on  a  30-day rolling average  basis.
                                       21

-------
4.5  LIME/LIMESTONE FGD SYSTEMS

     Emission data from two long-term tests are available to document
lime/limestone FGD performance on industrial steam generating units.  As
discussed in Reference 24, the scrubbing system serviced six coal-fired
stoker boilers with a total heat input capacity of 62 MW (210 million
Btu/hour).
     The tests were conducted using continuous SO- emission monitors at both
the inlet and outlet of the FGD system.  Data were collected for  a  29-day
period while the system used a lime reagent and for 30  days while the system
used a limestone reagent.
     During the 29-day data collection period when lime was used  as the
reagent  in the wet scrubbing system, the sulfur content of the  bituminous
coal fired averaged 2,150 ng SO-/J  (5.0 Ib S0-/million  Btu).  During this
period,  the steam generating unit load varied from 34 to 65 percent of full
load.  The SO- removal efficiency averaged 91.5 percent, and the  lime wet
scrubbing FGD system operated at a  reliability level of over 91 percent.
     During the 30-day test period  when limestone was used as the reagent  in
the wet  scrubbing system, the sulfur content of the  bituminous  coal burned
averaged about 2,150 ng SO-/J  (5.0  Ib S0-/million Btu). During this period,
the steam generating unit  load varied from 30 to 67  percent of  full load.
The SO-  removal efficiency averaged 94.3 percent, and the  system  operated  at
a reliability level of 94  percent.
     The long-term data presented above for  lime and  limestone  FGD  systems
show SOg removal efficiencies of 91.5 and 94.3 percent, respectively, which
are near or above the  long-term average required to  meet consistently a once
in ten year 30-day rolling average  minimum  performance  level of 90  percent
emission reduction.  Although  these results  were obtained  at less than
maximum  load  conditions,  new  systems could  achieve  this level of  performance
at full  load  by operating  at  a higher liquid-to-gas  ratio.   In  addition,  new
systems  would likely be equipped with a spray  tower or  turbulent  contact
absorber to provide  increased  mass  transfer area  and gas  residence  time  for
 improved SO-  absorption.
                                       22

-------
     Based on this analysis of system performance and system variability,
the lime/limestone wet scrubbing FGD technology is considered a demonstrated
technology for reducing SO- emissions from small coal-fired industrial-
commercial -institutional steam generating units by 90 percent using a 30-day
rolling average to calculate emission reductions.

4.6  LIME SPRAY DRYING FGD SYSTEMS

     Lime spray drying is a dry scrubbing process that involves contacting
the flue gas with an atomized lime slurry or a solution of sodium carbonate.
The hot flue gas dries the droplets to form a dry waste product while the
absorbent reacts with SO- in the flue gas.  The dry waste solids, consisting
of sulfite and sulfate salts, unreacted sorbent, and fly ash are collected
in a baghouse or ESP for disposal.
     Emission test data are available in Reference 25 to document lime spray
drying performance for coal firing.  As shown in Table 4-2, a series of four
short-term tests were conducted to demonstrate lime spray drying
performance.  The first short-term test was a compliance test conducted over
approximately 2 hours, where the lime spray drying system treated flue gas
from a pulverized coal-fired steam generating unit with a heat input
capacity  of  82 MW (280 million Btu/hour).  This unit burned bituminous coal
with an average sulfur  content of 1,430 ng SO-/J  (3.33 Ib S0-/million Btu)
and operated at 100  percent of full load.  The SO- removal efficiency
averaged  74.5 percent.26
     The  second short-term test was also conducted over approximately 2
hours, where the  system treated flue gas from a pulverized coal-fired unit
with a heat  input capacity of 34 MW (115 million  Btu/hour).  This unit,
which fired  a mixture of  bituminous coal with an  average sulfur content of
410 ng S02/J (0.96  Ib S02/million Btu), operated  at  about 75 percent of full
load.  Of the total  heat  input to the unit, 94.2  percent was derived from
coal and  the remainder  from oil.  Sulfur dioxide  removal efficiencies
averaged  92.4 percent during this test period.
     A series of  three  short-term tests was conducted over 8 hours  at a
third site.  The  coal-fired spreader stoker unit  for these tests  operated
                                       23

-------
                               TABLE 4-2. SUMMARY OF SHORT-TERM EMISSION DATA FOR FOUR INDUSTRIAL
                                                LIME SPRAY DRYING FQD SYSTEMS (25)
ro

Number
of
Location runs
1 6
2 6
3 1
3 1
3 1
3 1
3 1
3 1
3 1
3 1
3 1
3 1
3 1
4 3
Test
duration
(hours)
2
2
8
8
8
4
4
4
4
4
4
4
4
1
Average SO2
removal (%)
74.5
02.4
79.7
89.9
95.6
64.0
78.0
74.0
80.8
83.0
87.0
90.0
96.0
96.6
Boiler
load
(%)
100
75
35
70
82
50-74
50-74
50-74
50-74
50-74
50-74
50-74
50-74
100
Reagent
ratio
NA(b)
NA
0.6
1.4
1.9
1.1
1.2
1.3
1.0
1.1
1.2
1.3
1.6
3.3
Coal average
sulfur content
(ng S02/J)
(«)
1.430
2.530 (c)
2,190
2,190
2.190
2,840
2,840
2.840
2.840
2.840
2,840
2,840
2.840
410
Approach
temperature,
degrees C
(degrees F)
19(35)
14 (25)
13 (23)
13 (23)
13 (23)
17 (30)
17 (30)
17 (30)
17 (30)
17 (30)
17(30)
17(30)
17(30)
28-39 (50-70)
Unit
heat Input
capacity. MW
(million Btu/hr)
82 (280)
34(115)
69 (235)
69(235)
69 (235)
69 (235)
69 (235)
69 (235)
69 (235)
69 (235)
69 (235)
69 (235)
69 (235)
69 (235)
                 (a) Divide ng/J by 430 for conversion to Ib/mllllon Btu.
                 (b) NA - Not available.
                 (c) Coat/oil mixture with 94.2% coal heat Input.

-------
with a heat input capacity of 69 MW (235 million Btu/hour) and fired
bituminous coal with an average sulfur content of 2,190 ng SO-/J  (5.09  Ib
S0-/million Btu).  During these three tests, unit load was maintained at 35,
70, and 82 percent of full load.  The reagent ratio was varied during each
testing period to obtain the following results:  79.7 percent SO-  removal at
0.6 reagent ratio; 89.9 percent SO- removal at 1.4 reagent ratio;  and
95.6 percent SO- removal at 1.9 reagent ratio.
     A second series of short-term tests was also conducted at this same
site over a 4-hour period.  For this test  series, the unit fired  bituminous
coal with an average sulfur content of 2,840 ng SO-/J (6..60 Ib SO-Xmillion
Btu) and operated at loads that varied between 50 and 74  percent  of full
load.  Both the reagent ratio and approach to saturation  temperature were
varied during the testing.  At a 17°C  (30°F) approach to  saturation
temperature, SO- removal efficiencies of 64, 78, and 74 percent were
achieved with reagent ratios of 1.1, 1.2,  and 1.3, respectively.   Lowering
the approach to saturation temperature to  12°C (2?°F) resulted in
80.8 percent S02 removal at a reagent ratio of 1.0.  At a 11°C (20°F)
approach to saturation temperature, SO- removal efficiencies of 83, 87, 90,
and 96 percent were  achieved with reagent  ratios of  1.1,  1.2, 1.3, and  1.6,
respectively.
     The fourth  short-term test, which was conducted over three 1-hour
periods, involved a  lime  spray drying  system treating flue gas from a
pulverized  coal-fired steam generating unit with a heat input capacity  of
69 MW  (235  million Btu/hour).  This unit burned bituminous coal with  an
average  sulfur  content of 410 ng S02/J  (0.96 Ib S02/million  Btu)  and
operated at 100  percent of full load.  The SO- removal  efficiency averaged
96.6 percent.
     The short-term  performance data from  these tests  indicate that lime
spray  drying  systems are  capable of achieving at least  93 percent reduction
in S02 emissions from industrial-commercial-institutional steam generating
units.   Few long-term data are  available,  but long-term removal  rates  as  low
as 70  percent  have been reported.  This, however,  reflects the fact that
many  large  commercial  systems have not  been required to achieve  high  removal
levels,  rather than  any  inherent limitation of the technology.   One  spray
drying vendor  believes  that  high reliability can be  achieved at  high

                                       25

-------
performance levels and is prepared to offer a 95 percent reliability
guarantee on lime spray drying systems, irrespective of coal sulfur content
and SO- removal guarantees.  Such a guarantee, however, would require that
owners/operators follow proper maintenance and operating procedures.
     As a result, there appear to be no technical barriers to achieving
greater than 90 percent SO- removal with a lime spray drying system on a
sustained basis at high (90 percent) reliabilities.  Furthermore, due to
similarities in design and operation between large and small systems, it
has been concluded that lime spray dryers would also be capable of meeting
the 90 percent SO- reduction levels on small industrial-commercial-
institutional units.  Therefore, this control technique is considered
demonstrated for purposes of establishing performance standards for small
coal-fired  steam generating units.

4.7  FLUIDIZED BED COMBUSTION  (FBC)

     Fluidized bed combustion  is a boiler design option which, because of
its ability to incorporate limestone addition, can achieve significant SO-
emission reductions.  This technology offers a variety of advantages over
conventional boiler  designs,  including SO- emission reduction without the
use of FGD  systems as well as  greater flexibility  in fuel use.
     Atmospheric fluidized bed combustion  (AFBC) boilers have developed
rapidly over the past five years and are now being applied to small boiler
sizes.  Two AFBC design  alternatives that  are currently available are the
conventional bubbling fluidized bed  (with  or without solids recycle) and the
circulating fluidized bed.   Pressurized FBC technology has been under
development for  over a  decade, but has not yet been used in commercial
practice and  is  unlikely  to  be applied to  small  boiler applications.
     Table  4-3 presents  S02  emission data  for one  circulating bed FBC and
four bubbling  bed  boilers,  ranging  in  size  from  15 to 61 MW  (50 to  208
million Btu/hour).   Certified CEM  or EPA Reference Methods were used to
measure S02 emissions.   Tests using  EPA Reference  Methods were short-term
tests  (approximately three-hour tests) unless otherwise stated in Table  4-3,
while tests using  CEM's  were long-term tests.  The results  from this table
                                       26

-------
                                     TABLE 4-3. FLUIDIZED BED COMBUSTION EMISSION TEST DATA (28)



Plant owner
(location)
Iowa Beef Processors
(Amarillo.TX)
Idaho National
Engineering Labs
(Scoville.lD)
Sohio Oil Corp.
(Lima, OH)
Summerside CFB
(Prince Edward
Island, Canada)
Summerside CFB
(Prince Edward
Island, Canada)
Summerside CFB
(Prince Edward
Island, Canada)
California Portland
Cement (Colion. CA)


Type of
unit (a)
PSB

PBB


PBB

PBB


PBB


PBB


FEC

Boiler
capacity. MW
(million Blu/hr)
heal input
26.4 (90)

24.0(82)


28.4 (97)

14.7 (50)


14.7(60)


14.7 (50)


60.9 (208)

SO2 Emissions Data
Percent
sulfur
in coal
4.2

0.85


3.6

6.0


6.5


5.7


0.43

• VIWVIH
of
lul
load
59

56


72

72


66


56


too


Ca/S
ratio
3.1

ND(e)


NA

3.7


45


72


NA


Sorbent
type
Dolomite

Limestone


Limestone

Limestone


Limestone


Limestone


Limestone

Sorbenl
size
(millimeters)
16x21.7

3.2 x 0.8


6.3x0

2.4 x 0.8


6.3x0


2.4 x 0.8


0.125x0.039

Bed
temperature Recycle
(degrees C) ratio
878 (763) (c) 0

NA(f) 0


NA 0

837 ND(fl)


838 ND (g)


799 ND(g)


NA by design

SO2 removal Outlet SO2
efficiency
(percent)
91

86


90

94


91


99


82

emissions
(ng/J) (b)
258

69


267

258


430


26


56

Emission
test method
(test duration)
(«0
CEM (1 day)

CEM (67 days)


EPA-6 (3 hours)

CEM (7.5 days)


CEM (15 hours)


CEM (5 hours)


EPA-8 (3 hours)

(a) PSB - Packaged staged bubbling bed; PBB - Packaged bubbling bed;
FEC . Field-erecied circulating bed.

(b) Divide ng/J by 430 for conversion to to/million Blu.

jc) Number In parentheses is the desuMurization bed temperature. Number not
in parentheses is the combustion bed temperature.

fd) CEM - certified continuous emission monitor; EPA-6 - EPA Reference Method 6
EPA-8 - EPA Reference Method 8.
(e) ND > not determined; the Ca/S ration could not be determined at this site
because the coal and limestone feed rates were inaccurate.

(0 NA - Not available.

(g) ND - Not determined; at this site, solids were recycled to the boiler, but
the rale of solids recycled was not determined for the above tests. However,
the recycle ratio was estimated as 4.0 at lest conditions similar to those for
the 7.5-day lest as reported in this table.

-------
show that S02 removal efficiencies ranged from 86 to 99 percent for tests on
the four bubbling bed boilers.  The outlet SO- emissions for a 15 MW
(50 million Btu/hour) bubbling bed boiler at Prince Edward Island,
Nova Scotia, ranged from 69 ng/J (0.16 ID/million Btu) when firing a
5.7 weight percent sulfur coal and operating at a calciura-to-sulfur (Ca/S)
ratio of 7.2:1 to 420 ng/J (0.98 Ib/million Btu) when firing a 6.5 weight
percent sulfur coal and operating at a Ca/S ratio of 3.1:1.  This
                                                                       77
corresponds to 99 and 91 percent SO- removal efficiency, respectively.i/
     In addition to the three test results reported in Table 4-3 for the
15 MW (50 million Btu/hour) boiler at Prince Edward Island, emission data
were collected for the entire test period of 30 days.  Figures 4-2 to  4-4
show the trends  in SO- removal efficiency, Ca/S molar ratio, and boiler
load, respectively, for the entire test period.  The results shown in  these
figures are based on daily average data.  The daily average SOg removal
efficiency ranged from 73 to 97 percent, averaging 93.5 percent.  The  lower
daily average SO- removal efficiency of 73 percent on day  10 was attributed
to operating the boiler at a low Ca/S ratio of 2.5:1.
     Emission data for the first 7.5 days of continuous operation from the
FBC boiler  at Prince Edward Island were analyzed for SO- emission reduction
variability.^^   This time period represented the longest continuous
operating  period for which emission and operating data were collected.
During  this  period,  the FBC unit operated at 94 percent mean SO- reduction
efficiency.  The results of variability analyses applied to the SO-
reduction  data of  this period  indicate that a long-term mean of at least
91.3 percent SO- reduction would be required to comply with a  90 percent  SO-
reduction  limit  based  on a 30-day  rolling average with no  more than one
exceedance every 10  years.   If the mean SO- reduction performance of
93.5 percent measured  in the  7.5 day test were maintained  at full load,  then
the  FBC unit would  exceed  the  level  (i.e.,  91.3 percent S02 reduction)
required  for compliance with  a 90  percent SO- reduction specification  using
a 30-day  rolling average.
     Although  these  performance levels  are  based primarily on  bubbling bed
designs,  equal  or  better  performance  is expected from circulating  and  dual
bed  systems because  of more  rapid  carbon  burnout, higher  limestone  particle
                                       28

-------
 *S02
Removal
100
 90-
 80-
 70
 60-
 50-
 40-
 30  •
 20
 10
  0
                                            Average S02 Removal *  93.55
                                10      15      20      25       30
                                    Test Days
          Figure 4-2.  Dally average S02  removal  efficiency fop the
                     F3C boiler at Prince Edward Island.29

-------
Ca/S Ratio 4-
                                             Average Ca/s ratio »  4.0
                                 10       15       20      25       30
                                      Test Days
            Figure 4-3.  Dally average Ca/S molar feed ratio for the
                        FBC boiler at Prince Edward Island.30
                                    30

-------
            80 -r
            70-
            60-
            50-
Boiler Load  40-
            30-
            20-
            10-
             0--
Average boiler load * 70.6
10      15     20
    Test Days
           25
                                                              30
           Figure 4-4.  Dally average boiler load for trte FBC
                       boiler at Prince Edward Island.31
                                 31

-------
densities in the freeboard area, and more uniform gas-solid contact between
SO- and limestone.  These factors are discussed in more detail in
Reference 32.
     The SO- removal efficiency of FBC systems can vary during load swings.
Changes in coal feed rate and coal sulfur content result in imbalances  in
the calcium-to-sulfur ratio of the fluidized bed.  To maintain a constant
SO- removal efficiency, this parameter must be adjusted during load swings
by adjusting the limestone feed rate.  Alternatively, the fluidized bed can
be operated with a higher-than-required calcium-to-sulfur ratio to
accommodate transient increases in boiler load (i.e., coal feed rate) or
coal sulfur content.  With proper design and operation of the FBC system,
consistently high SO- removal rates can be maintained during fluctuations  in
boiler load.
     "As a result of the above-described technical analysis of FBC units, the
ability of FBC  units to continuously reduce SO- emissions by 90 percent or
more on a 30-day rolling  average  is considered demonstrated.

4.8  ALTERNATIVE CONTROL  LEVELS

     The evaluation of SO- control techniques for small coal-fired boilers
indicates that  use  of low sulfur  coal, sodium scrubbing FGD systems,  dual
alkali FGD systems, lime/limestone FGD systems, lime spray drying FGD
systems, and  FBC  units are demonstrated techniques which can serve as the
technical basis for developing  NSPS for small boilers.  Low sulfur coal
combustion will reduce SOj emissions to 520 ng/J  (1.2 ID/million Btu) or
less.  This,  therefore,  is selected as Alternative Control Level 1.
     Flue gas  desulfurization  systems  and FBC units are capable of
90 percent S02  reduction. Consequently, 90 percent SO- reduction  is
selected as  Alternative  Control  Level  2.
                                       32

-------
                             5.0   REFERENCES
1.  U.S. Environmental  Protection Agency.  Small Steam Generating  Unit
    Characteristics  and Emission Control Techniques.  Research Triangle
    Park, N.C.  March 31,  1989.

2.  U.S. Environmental  Protection Agency.  Fossil Fuel Fired  Industrial
    Boilers  - Background Information.  Volume  I.  Research Triangle  Park,
    N.C.  Publication No.  EPA-450/3-82-006a.   March  1982.

3.  U.S. Environmental  Protection Agency.  Industrial Boiler  S02 Technology
    Update Report.   Research  Triangle  Park, N.C.  Publication No.
    EPA-450/3-85-009.   March  1985.

4.  White, David  and Edward Moretti  (Radian Corporation).  Production  of
    Very Low-Sulfur  Residual  Fuel Oils.   Prepared for U.S. Environmental
    Protection  Agency.   Research Triangle  Park,  N.C.  April 10,  1987.

5.  Energy and  Environmental  Analysis,  Inc.  Small Boiler NSPS  Impacts  on
    Oil Markets.   Prepared for U.S.  Environmental Protection  Agency.
    Research Triangle Park, N.C.  November 19887

6.  Reference 3.

7.  U.S.  Environmental  Protection Agency.  Summary of Regulatory Analysis
    New Source  Performance Standards:  Industrial-Commercial-Institutional
    Steam  Generating Units of Greater  than 100 Million  Btu/hr Heat Input.
    Research Triangle Park,  N.C.   1986.

8.  Reference 1.

9.  Reference 1.

10.  Reference 3,  p.  2-46.

11.   Reference 3,  p.  2-47.

12.   Reference 2,  pp. 4-163 through  4-168.

13.   Reference 7.

14.   Giguere, G.C., et  al. (Radian Corporation).  Determination  of Mean S02
     Emission Levels Required to Meet a 1.2 Lb SOVMillion Btu Emission
     Standard for Various Averaging Times and Compliance Policies.   Prepared
     for U.S. Environmental Protection Agency.   Research Triangle Park, N.C.
     Contract No.  68-02-3816.   March 1985.  p.  B-3.

15.   Technical note from Margerum, S.C. and  G. Giguere, Radian  Corporation,
     to J.A.  Eddinger,  EPA:ISB.  July 1985.  Variability of S0?  Emissions
     from Low Sulfur Coal-Fired Industrial Boilers.


                                      33

-------
16.   Dunbar,  D.R.  (PEDCo Environmental, Inc.).  Typical Sulfur Dioxide
     Emissions from Subpart D Power Plants Firing Compliance Coal.  Prepared
     for U.S. Environmental Protection Agency.  Research Triangle Park, N.C.
     EPA Contract  No. 68-02-3152.  May 1984.  88 pp.

17.   Struthers-Andersen.  Points to Consider in Evaluation of Sulfur Dioxide
     Emission Control Systems for Steam Generators in the Oil Fields.
     Atlanta, Ga.   November 1980. p. 1.

18.   Huckabee, D.S., S. Diamond, T. Porter, and P. McGlew.  (GCA
     Corporation).  Continuous Emission Monitoring for Industrial Boilers,
     General  Motors Corporation assembly Division, St. Louis, Missouri.
     Volume I:  System Configuration and Results of the Operational Test
     Period.   Prepared for U.S. Environmental Protection Agency.  Research
     Triangle Park, N.C.  EPA Contract No. 68-02-2687.  June 1980.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
Reference
1.



DeBose, D.A., et al . (Radian Corporation). Statistical Analysis of Wet
Flue Gas Desulfurization Systems and Coal Sulfur Content, Volume I:
Statistical Analysis. Prepared for the U.S. Environmental Protection
Agency. Research Triangle Park, N.C. EPA Contract No. 68-02-3816.
August 18, 1983.
Reference
Reference
Reference
Reference
Reference
Reference
2,
7,
7,
7,
7,
7,
P
PP
PP
PP
PP
PP
. C-165
. 5-46
. 5-44
. 5-38
. 5-28
. 5-28
•
through 5-47.
through 5-47.
through 5-41.
through 5-36.
through 5-36.
U.S. Environmental Protection Agency. Statistical Analysis of Emission
Test Data from Fluidized Bed Combustion Boiler at Prince Edward Island,
Canada. EPA-450/3-86-015. December 1986.
Reference
Reference
Reference
Reference
Reference
1.
1.
1.
1.
7.















                                       34

-------
                                   TECHNICAL REPORT DATA
                           (Please read Instructions on the reverse before completing)
 HSPORT NO.
  EPA-450/3-89-12
                             2.
                                                           3. RECIPIENT'S ACCESSION NO.
 TITLE AND SUBTITLE
 Overview of the  Regulatory Baseline,  Technical Basis,
 and Alternative  Control  Levels for  Sulfur Dioxide (562)
 Emission Standards  for Small Steam  Generating Units
            5. REPORT DATE
               May 1989
            6. PERFORMING ORGANIZATION CODE
 AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
 PERFORMING ORGANIZATION NAME ANO ADDRESS
 Emission Standards Division
 Office of Air  Quality Planning and Standards
 U.S. Environmental Protection Agency
 Research Triangle Park, North Carolina  27711
                                                           10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.

                68-02-4378
2. SPONSORING AGENCY NAME ANO ADDRESS
 Office of  Air  Quality Planning and  Standards
 Office of  Air  and Radiation
 U.S. Environmental  Protection Agency
 Research Triangle Park, North Carolina  27711
             13. TYPE OF REPORT ANO PERIOD COVERED
                Final
             14. SPONSORING AGENCY CODE
               EPA/200-04
5. SUPPLEMENTARY NOTES
6. ABSTRACT
      This  report provides a summary of the technical  data  used in developing  proposed
 new source performance standards  (NSPS) for small  industrial-commercial-institutional
 steam generating units (small  boilers).  The report  focuses on sulfur dioxide (S0£)
 emissions  from boilers firing  coal  and oil with heat input capacities of  100
 million Btu/hour or less.  Conclusions are drawn from the  data regarding  the  per-
 formance of technologies available  to reduce S0£ emissions.  Alternative  control
 levels are then chosen based on the conclusions drawn from the data.
                                KEY WORDS ANO DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lOENTIFIERS/OPEN ENDED TERMS
                             COSATI Field/Group
   Air  Pollution
   Pollution Control
   Standards of Performance
   Steam Generating Units
   Industrial Boilers
   Small Boilers
   Air Pollution Control
18. DISTRIBUTION STATEMENT

   Release unlimited
19. SECURITY CLASS (This Report!
   Unclassified
                                                                          21. NO. OF PAGES
2O. SECURITY CLASS (This page)

   Unclassified
                           22. PRICE
EPA Form 2220-1 (R.v. 4~r7)    PREVIOUS COITION is OBSOLETE

-------
                                                       INSTRUCTIONS

  •L   REPORT NUMBER
      Insert the EPA report number as it appears on the cover of the publication.

  2.   LEAVE BLANK

  3.   RECIPIENTS ACCESSION NUMBER
      Reserved for use by each report recipient.

  4.   TITLE AND SUBTITLE
      Titte should indicate clearly and briefly the subject coverage of the report, and be displayed prominently. Sol subtitle, if used, in smaller
      type or otherwise subordinate it to main  title. When a report  is prepared in more than one volume, repi-at the primary tide, add volume
      number and include subtitle for the specific title.

  5.   REPORT DATE
      Each report shall cany a date indicating at least month and year. Indicate (he hasis on which it \vas selected (e.g.. Jatr of issue, date of
      approval, date of preparation, etc.).

  6.   PERFORMING ORGANIZATION CODE
      Leave blank.

  7.   AUTHOR(S)
      Give name(s) in conventional order (John R. Doe. J. Robert Doe. etc.}.  List author's affiliation if it differs from (he performing organi-
      zation.

  8.   PERFORMING ORGANIZATION REPORT NUMBER
      Insert if performing organization wishes to assign this number.

  9.   PERFORMING ORGANIZATION NAME AND ADDRESS
      Give name, street, city, state, and ZIP code.  List no more than two levels of an organi/ational hircarchy.

  10. PROGRAM ELEMENT NUMBER
      Use the program element number under which the report was prepared. Subordinate numbers may be included in parentheses.

  11. CONTRACT/GRANT NUMBER
      Insert contract or grant number under which report was prepared.

  12. SPONSORING AGENCY NAME AND ADDRESS           .       .
      Include ZIP code.

  13. TYPE OF REPORT AND PERIOD COVERED  .
      Indicate interim final, etc., and if applicable, dates covered.

  14. SPONSORING AGfcNCY CODE
      Insert appropriate  code.

  15. SUPPLEMENTARY NpTES
      Enter information not included elsewhere but useful, such as: Prepared in cooperation with. Translation of, I'rcscnled at conlcreme "I.
      To be published in. Supersedes, Supplements, etc.

  16. ABSTRACT
      Include a brief (200 words or lea/ factual summary of the most significant information contained in the report. II die report contains a
      significant bibliography or literature survey, mention it here.

  17.  KEY WORDS AND DOCUMENT ANALYSIS
       (a) DESCRIPTORS - Select from the Thesaurus of Engineering and Scientific Terms the proper au(hori/.ed terms dial identify the major
      concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.

      (b) IDENTIFIERS AND OPEN-ENDED  TERMS - Use identifiers for project names, code names, equipment designators, etc.  Use open-
       ended terms written in descriptor form for those subjects for which no descriptor exists.

       (c) COSATI MELD GROUP - Field and  group assignments are to be taken from the 1965 COSATi Subject Category Lisl. Since the ma-
      jority of documents are multidisciplinary in nature, the Primary Field/Group  assignment!s) will be specific discipline, area of human
       endeavor, or type of physical object. The application(s) will  be cross-referenced with secondary 1 ield/droup assignments that will lollow
       the primary posting(s).

  18.  DISTRIBUTION STATEMENT
       Denote releasability  to the public or limitation for reasons other than security for example "Release Unlimited."  Cite any availability to
       the public, with address and price.

  19. 81 20. SECURITY CLASSIFICATION
       DO NOT submit classified reports to the National Technical Information service.

  21.  NUMBER OF PAGES
       Insert the total number of pages, including this one and unnumbered pages, but exclude distribution list, if any.

  22.  PRICE
       Insert the price set by  the National Technical Information Service or the Government Printing Office, if known.
EPA Form 2220-1  (R«v. 4-77) (Rev«r.«)

-------