Florida Department of Environmental Protection

Advanced Waste-to-Energy Best Available Control Technology

Air & Waste Management Association (A&WMA)104th Annual International Conference & Exhibition

Orlando, FloridaJune 23, 2011

Alvaro (Al) Linero, P.E.Presented by Scott Sheplak, P.E.

State of Florida Department of Environmental Protection

Renewed Interest in Waste-to-Energy (WTE)

• Municipal solid waste (MSW) is the fuel source

• Burned in municipal waste combustors (MWC)

• Florida has greatest MSW WTE capacity in the country

• A renewed interest in WTE/MWC projects

• Lee County 600 tons per day (TPD) Unit 3 started in 2006

• Hillsborough County 600 TPD Unit 4 started up in 2009

• Now Palm Beach County (PBC) Solid Waste Authority (SWA)

June 23, 2011 | 2PBC SWA investing over $600,000,000 in this project

PBC SWA Expansion Project

• Existing Palm Beach Renewable Energy Facility No. 1 (PBREF-1)

• Located near West Palm Beach next to the Florida Turnpike

• Capacity of PBREF-1 is ~2,000 TPD of refuse derived fuel (RDF)

• New PBREF-2 will be a 3,000 TPD of MSW project

• To include three 1,000 TPD mass burn units

June 23, 2011 | 3

Expanded PBREF will be largest WTE facility in the world!

July 30, 2009 | 4

Existing PBREC-1 and Rendition of New PBREC-2

North

June 23, 2011 | 5

1. Tipping Floor 2. Holding Pit 3. Grapple 4. Feed Chute 5. Stoker Grate 6. Combustion Air Fan

7. Ash Discharger 8. Combustion Chamber 9. Radiant Zone 10. Convection Zone 11. Superheater 12. Economizer

13. Dry Gas Scrubber14. Baghouse 15. Fly Ash System 16. Induced Draft Air Fan 17. Stack

Main Components of a Mass Burn Unit

Typical U.S. Mass Burn MWC Control Equipment

June 23, 2011 | 6

• GCP - Good Combustion Practices in the Furnace• Staged Combustion, Overfire Air, Flue Gas Recirculation, Heat Control• Particulate Matter (PM), Carbon Monoxide (CO), Nitrogen Oxides (NOx),

Volatile Organic Compounds (VOC), Dioxin and Furan (D/F)

• SNCR - Selective Non-Catalytic Reduction in the Furnace• Ammonia (NH3) or Urea Injection to convert NOx to water and nitrogen (N2)

• Possible drawbacks are further NOx, NH3 emissions, fine PM formation

• SDA - Spray Dryer Absorber based on Lime Injection• Absorption and Reaction of Acid Gases and some Metals to PM

• ACI - Activated Carbon Injection after SDA• Adsorption of mercury (Hg) and D/F to PM

• FF - Fabric Filter after SDA and ACI • Filters PM including all the pollutants that are converted to PM

Shorthand is GCP/SNCR/SDA/ACI/FF configuration

GCP/SNCR/SDA/ACI/FF within Typical U.S. Mass Burn Unit

Dry/semidry processes avoid wet scrubber, water consumption, treatment

SNCRGCP

SDA

ACI

FF

Key U.S. Federal Regulations Applicable to PBREF-2

• 40 Code of Federal Regulations (CFR) Part 60, Subpart Eb• Standards of Performance for (New) Large MWC

• Subpart Eb is pursuant to Section 129 of Clean Air Act (CAA)• Contains standards for typical air pollutants & hazardous air pollutants (HAP)• Satisfies Maximum Achievable Control Technology (MACT)• Based on the GCP/SNCR/SDA/ACI/FF configuration• Contains monitoring requirements

• Prevention of Significant Deterioration (PSD)• State of Florida PSD Rule is 62-212.400, Florida Administrative Code (F.A.C.)• PSD requires a Best Available Control Technology (BACT) Determination

(case-by-case)

June 23, 2011 | 8MACT and BACT do not mean the same thing!

PBREF-2 Limits vs. MACT and Actual Performance of a New MWC

Air Pollutant Units 1 Subpart Eb MACT 2 HCRRF-4 3 PBREF-2 4

NOx ppmvd 150 70 - 110 45 - 50 (BACT)

CO ppmvd 100 26 100 (BACT)

SO2 ppmvd 30 0.56 24 (BACT)

Hydrogen chloride (HCl) ppmvd 25 11.5 20 (BACT)

PM mg/dscm 20 1.0 12 (BACT)

Lead (Pb) µg/dscm 140 18.3 125 (avoid PSD)

Hg µg/dscm 50 1.5 12 - 25 (avoid PSD)

Cadmium (Cd) µg/dscm 10 0.2 10 (MACT)

Total D/F ng/dscm 13 0.26 0.75 - 10 (BACT)

Visible Emissions (Opacity) percent 10 0 10

1. ppmvd = parts per million by volume, dry; mg/dscm = milligrams per dry standard cubic meter; µg/dscm = micrograms per dry standard cubic meter; ng/dscm = nanograms per dry standard cubic meter

2. 40 CFR 60, Subpart Eb as applicable to new mass burn MWC limits.

3. These are the 2009 actual compliance test data from the HCRRF Unit 4 permitted under PSD and Subpart Eb in 2006.

4. Values in 2010 PBREF-2 permit issued by Florida DEP.June 23, 2011 | 9

Extra Focus for Emission Limits on These Pollutants

June 23, 2011 | 10

• NOx - Facilities typically operate near their NOx Limit• Improvements in GCP and SNCR proved values less than MACT achievable• E.g., new HCRRF-4 regularly achieves 70-110 ppmvd with GCP and SNCR• European experience with selective catalytic reduction (SCR) is extensive• Values much less than MACT are achievable as BACT• Set BACT at 45-50 ppmvd versus MACT of 150 ppmvd

• D/F - Values much less than MACT are readily achievable• New boiler MACT e.g. specifies much lower D/F than Subpart Eb MWC MACT• New HCRRF-4 achieved very low D/F emission rate (0.26 versus 13 ng/dscm)• SCR for NOx will also destroy D/F as documented at European WTE plants• Algonquin, Ontario (Canada) installed SCR for Nox and D/F purposes• Due to unknowns, we set a range for BACT with finalization after startup/tests

• Hg - Values much less than MACT achievable, desirable • New boiler MACT e.g. specifies much lower D/F than Subpart Eb MWC MACT• New HCRRF-4 achieved very low Hg emission rate (1.5 versus 50 µg/dscm)• Limits of 12 and 25 µg/dscm (long/short-term) by ACI/FF will avoid PSD and BACT• Hg continuous emissions monitors (Hg-CEMS) used due to variable Hg in feed

The Rest of the Pollutants besides NOx, D/F, Hg

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• PBREF-2 - GCP/SCR/SDA/ACI/FF

• Very much like standard U.S. configuration except for SCR instead of SNCR

• The Eb MACT configuration (w SCR or SNCR) will yield low values on the rest

• Again, HCRRF Unit 4 is a very good demonstration of statement

• The Subpart Eb MACT limits pretty much dictate the assumptions for bids

• Lower limits on the rest would delay projects, but not reduce emissions

• SO2, HCl, PM, metals emissions proven to be low e.g. at HCRRF 4

• SCR on NOx will make it easier to focus on GCP to achieve low CO

• We’ll work with vendors and suppliers to educate them on their own success!

PBREF-2 will be cleanest WTE plant in the U.S.!

Other Issues – Lots of New EPA Requirements

June 23, 2011 | 12

• After submittal of application, came quite a few new rules

• One-hour nitrogen dioxide (NO2) and SO2 ambient air quality standards

• Initial guidance on modeling was a pyramid of overly conservative assumptions

• Applicant actually considered routing emergency engine exhaust through tall stacks

• We suggested limiting engine testing to half hour and not modeling such emissions

• Federal condensable PM rules and test methods – we had not yet adopted

• Federal Greenhouse Gas (GHG) rules would apply if no permit by January 2, 2011

We issued the final PSD permit on December 30, 2010!

June 23, 2011 | 13

Questions? Just ask the Sphinx!

Check out groundwater remediation project on right!