January 22, 2014 

MEMORANDUM 

From: William H. Maxwell 

EPA/SPPD/ESG (D243-01) 

To: Docket Number EPA-HQ-OAR-2009-0234 

Subject: Meeting with Santee Cooper, Lower Colorado River Authority (LCRA), and Nebraska 

Public Power District (NPPD) held on January 21, 2014 

Attendees: 

Robert Wayland, OAR/OAQPS 

William Maxwell, OAR/OAQPS 

Rey Forte, OAR/OAP (by phone) 

Nick Hutson, OAR/OAQPS 

Barrett Parker, OAR/OAQPS 

Stephen Fotis, Van Ness Feldman, counsel 

Julie Metts, Santee Cooper 

Kevin Clark, Santee Cooper 

Patti Hershey, LCRA 

Bill Steinhauser, LCRA 

Joe Citta, NPPD (by phone) 

Jason Vanek, NPPD (by phone) 

Discussion: 

A general discussion was held regarding the proposed reconsidered startup/shutdown provisions of the 

final Mercury and Air Toxics Standards (MATS). The attached materials were discussed. 

Attachments 
MEETING ON MATS WORK PRACTICE STANDARDS

JANUARY 21, 2014

AGENDA

1. PURPOSE OF MEETING

2. INTRODUCTIONS

a. BACKGROUND ON EACH PUBLIC POWER SYSTEM

b. ELECTRIC GENERATING UNITS OF CONCERN

3. PRIMARY CONCERNS OF ENERGIZING ESPS UPON FIRST‐FIRE OF COAL

a. DESIGN AND OPERATING PROCEDURES FOR OLDER VINTAGE ESPS

b. SAFETY RISKS OF FIRES AND/OR EXPLOSIONS FROM SPARKING

c. DAMAGE TO ESP

d. DIMINISHED CONTROL EFFICIENCY OF ESPS

e. INCREASED MAINTENANCE COSTS

f. PM CONTROL BY FGD SYSTEMS DURING STARTUP

g. PROBLEMS WITH STARTING UP ESPS ON FUEL OIL

h. POSSIBLE DEVELOPMENT OF NEW ESP STARTUP PROCEDURES

i. CONCLUSION:  NO OVERALL ENVIRONMENTAL GAINS; INCREASED SAFETY RISKS;

REDUCED PM CONTROL EFFICIENCIES; INCREASED MAINTENANCE COSTS

4. PRIMARY CONCERNS OF ENERGIZING BAGHOUSES UPON FIRST‐FIRE OF COAL

a. DAMAGE TO BAGS

b. DIMINISHED BAGHOUSE CONTROL EFFICIENCY

c. INCREASED MAINTENANCE COSTS

d. POSSIBLE DEVELOPMENT OF NEW BAGHOUSE STARTUP PROCEDURES

5. RECOMMENDED REVISIONS TO WORK PRACTICE STANDARDS

a. ESPS, BAGHOUSES, AND ASSOCIATED DRY SORBENT INJECTION SYSTEMS MUST START

UP AS SOON AS PRACTICABLE BUT NO LATER THAN 3 HOURS AFTER CONTINUOUS

FIRE OF COAL

b. WET FGD SYSTEMS MUST BE OPERATED FOR PM CONTROL UPON FIRST FIRE OF FUEL

6. CONCLUDING REMARKS AND WRAP UP
Excerpts from EPA Documents Identifying Proper Operating Procedures

and Problems with Premature ESP Engagement:

Operations and Maintenance Manual for Electrostatic Precipitators, Air and 

Energy Engineering Research Laboratory, Office of Research and 

Development, U.S. EPA, Research Triangle Park; EPA/625/1‐85/017; 

September 1985, available at http://nepis.epa.gov/Adobe/PDF/20008QN4.pdf

1. Page 5‐3: “...wait until the acid dewpoint temperature has been 

surpassed, to avoid excessive sparking and to minimize buildup on the 

ESP internals.” 

2. “The concern with sticky particulate and sparking is two‐fold. At best, if 

the sticky particles fuse or clinker on the plates and wires, the ESP will 

have to be shut down and washed out. At worst, unstable combustion 

could lead to unburned carbon, hydrocarbons, and CO in the ESP, which 

may be set afire or result in an explosion...” 

EPA Air Pollution Training Institute, SI 412B‐Lesson 6: ESP Operations and 

Maintenance; 2.0‐2/98, available at 

http://yosemite.epa.gov/oaqps/EOGtrain.nsf/1df696dab59d623685256b2100542b18/b6c72f7e09cff3b

185256b66004f3530/$FILE/12bles6.pdf

1. Page 6‐5: “If an ESP is used on a coal‐fired boiler, the ESP should not be 

started until coal firing can be verified. This will help prevent 

combustible gases from accumulating in the unit and causing explosive 

conditions.” 

2. Page 6‐6 (from Table 6‐2 ‘Typical startup procedures for electrostatic 

precipitators’): “10. After gas at temperature of 200 oF has entered ESP 

for 2 hours – a. Energize T‐R sets.” 

Document then details startup without reaching 200 oF 
@YDE BERGEMANNEE(::;:-

PRECIPITATOR OPERATION AND MAINTENANCE MANUAL 

480064A -SANTEE COOPER- ESP UNIT #3 UPGRADE 

WINYAH GENERATING STATION- GEORGETOWN, SC 

5.2 STARTUP PROCEDURES 

Precautions to Take Before Energizing the Switch Mode Power Supply 

Do not allow the Switch Mode Power Supply to become disconnected from the load while 

energized! 

The ground switch is interlocked to prevent the SMPS from becoming grounded while being 

operated. Before repositioning the ground switch, verify that the SMPS circuit breaker is open 

and locked out, and that the Precipitator inlet temperature is approximately 250°F. 

29 
GAS LOAD (PRECIPITATOR START-UP) 

a. Admit boiler gas into the precipitator and turn 

on the following equipment: 

Support Insulator Heaters 

Support Insulator Seal Air Fans 

Rappers 

Vibrato;rs 

Hopper Heaters 

Hopper Vibrators 

Ash Removal System 

b. After gas of at least 200"F has entered the 

precipitator for two hours (temperature checked 

at precipitator outlet) turn the REMOTE-OFFSTART switch on the transformer-rectifier 

controls to START. 

NOTE 

The SCR heat sinks and some other exposed 

parts of the circuit are now at line 

voltage. 

NOTE 

Although maximum transformer primary 

voltage is possible in air load, it 

is unlikely in gas load. 

c. If it is necessary to check the current limit setpoint and the precipi~ator is sparking and controlling 

at less than normal rated current, push in at the top 

of the amps check switch and set the amps knob to the 

current value that was recorded in step k, Paragraph 

2.3. After checking and/or adjusting the current limit, 

return the amps check switch to normal by pushing it in 

at the bottom. 

d. When all adjustments have been completed, replace the 

center p~nel in the control cabinet. 

2-10 
GENERAL DESCRIPTION OF INSTALLATION 

102175-L 

Page 4 of 10 

PR 3250 

of the prec~pitator in this installation is to 

and collect the suspended material, principally fly 

, present in the gases originating in a pulverized coal 

boiler, located at Georgetown Station No. 2. The 

iler will be fired alternately with #6 fuel oil. 

equipment furnished by Research-Cottrell, Inc., consists of 

electrostatic precipitator, four units wide and four sections 

in the direction of gas flow, with the associated equipment 

described. Also furnished by Research-Cottrell, Inc. are 

following: 

Insulator Housing with Partitions 

Hopper Vibrators, Level Indicators and Electric Heaters 

Motor Control Centers 

Insulator Housing Ventilation System 

GAS VOLUME 

precipitator will treat 1,000,000 ACFM of gas entering at 

fol~owing temperatures: for coa l fired , 2650F; for oil 

, 275oF, with an internal operating pressure of (-8") water. 

PITATOR DESCRIPTION 

precipitatpr unit has 35, nine inch wide ducts, formed by 36 

collecting plates, 30' high by 36' long. The plates in each 

tion are 30' high by 9' long in the direction of gas flow, and 

in four banks of nine plates. A bank of plates is 

at its upper, leading and trailing edges by a horizontal 

1 beam. There are 144 collecting plates in each precipitator 

t for a total of 576 in the precipitator. 

u~•sc~·nded vertically in the center of the ducts of each precipitator 

are 1680 discharge electrodes. Eech unit section has 420 

r~e electrodes, that are supported by a wire supporting 

. The electrodes are assembled from 0.109" diameter hard awn basic wire, without coating, and with a loop ring at the 

and bottom. A 25 pound weight hangs in plumb bob suspension 

tbathe bottom of each electrode, except four wires in each frame 

1 t support the steadying bars. There are 6,720 discharge 

• ectrodes in the precipitator. 

10?171:\-T. 
PM CONTROL DURING STARTUP 

Date fime PM Emissions Rate PM Mass Opacity* Coal Feed ESP In Service 

(lbs!MMbtu) Emissions (lbs/hr) Started (yes/no) (yes/no} 

12/15/13 ~7:00 0.016.,. 4.4 7.6 No No 

12/15/13 ~8:00 0.028 7.8 12.23 Yes No 

12115/13 ~9:00 0.008 3.1 5.42 Yes Yes 

12/21/13 1:00 < 0.000 2.7 5.37 No No 

12/21/13 ~2:00 0.067 5.6 21.63 Yes No 

12/21/13 p:OO 0.008 2.8 5.82 Yes Yes ' 

*Opacity is me~sured after the ESP but prior to the scrubber. Stack opacity would be less as the scrubber will remove particulate. 

1