### 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 Colora do 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/s hutdown provisions of the final Mercury and Air Toxics Standards (MAT S). The attached materials were discussed.

Attachments

## M EETING ON 

## MATS W ORK 

## P RACTICE 

## S TANDARDS
J ANUARY 

### 21, 2014
A GENDA



### 1. P URPOSE OF 

### M EETING



### 2. I NTRODUCTIONS



### a. B ACKGROUND ON 

### E ACH 

### P UBLIC 

### P OWER 

### S YSTEM 

### b. E LECTRIC GENERATING UNITS OF CONCERN



### 3. P RIMARY 

### C ONCERNS OF ENERGIZING 

### ESP S UPON 

### F IRST



### ‐ F IRE OF 

### C OAL



### a. D ESIGN AND OPERATING PROCEDURES FOR 

### O LDER 

### V INTAGE 

### ESP S 

### b. S AFETY 

### R ISKS OF 

### F IRES AND 

### / OR 

### E XPLOSIONS FROM SPARKING



### c. D AMAGE TO 

### ESP
d. D IMINISHED CONTROL EFFICIENCY OF 

### ESP S



### e. I NCREASED MAINTENANCE COSTS 

### f. PM CONTROL BY 

### FGD SYSTEMS DURING STARTUP



### g. P ROBLEMS WITH STARTING UP 

### ESP S ON FUEL OIL 

### h. P OSSIBLE DEVELOPMENT OF NEW 

### ESP STARTUP PROCEDURES


### i. C ONCLUSION 

### : N O OVERALL ENVIRONMENTAL GAINS 

### ; INCREASED SAFETY RISKS 

### ;

REDUCED 

### PM CONTROL EFFICIENCIES 

### ; INCREASED MAINTENANCE COSTS



### 4. P RIMARY 

### C ONCERNS OF ENERGIZING 

### B AGHOUSES UPON 

### F IRST



### ‐ F IRE OF 

### C OAL



### a. D AMAGE TO BAGS 

### b. D IMINISHED BAGHOUSE CONTROL EFFICIENCY



### c. I NCREASED MAINTENANCE COSTS 

### d. P OSSIBLE DEVELOPMENT OF NEW BAGHOUSE STARTUP PROCEDURES



### 5. R ECOMMENDED REVISIONS TO WORK PRACTICE STANDARDS



### a. ESP S 

### , 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. W ET 

### FGD SYSTEMS MUST BE OPERATED FOR 

### PM CONTROL UPON FIRST FIRE OF FUEL



### 6. C ONCLUDING 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 Labor atory, 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 d ewpoint temperature has been surpassed, to avoid excessive sparking and to minimize buildup on the
ESP internals.”

2. “The concern with sticky particul ate and sparking is two‐fold. At best, if the sticky particles fuse or clink er on the plates and wires, t he ESP will have to be shut down and washed out. At worst, unstable combust ion 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 Inst itute, SI 412B‐Lesson 6: ESP Ope rations and Maintenance; 2.0‐2/98, available at
http://yosemite.epa.gov/oaqps/EOGtrai n.nsf/1df696dab59d623685256b2100542b18/b6c72f7e09cff3b 185256b66004f3530/$FILE/12bles6.pdf



### 1. Page 6‐5: “If an ESP is used on a coal‐fired boiler, the ESP sh ould not be started until coal firing can be verified. This will help preve nt combustible gases from accumulating in the unit and causing exp losive
conditions.”

2. Page 6‐6 (from Table 6‐2 ‘Typical startup procedures for electr ostatic precipitators’): “10. After gas a t temperature of 200 oF has en tered 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 b eing operated. Before repositioning the ground sw itch

, verify that the SMPS circuit breaker is open and locked out, and that the Precipitator inlet temperature is approximately 250°F.



### 29GAS 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 primar y 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

.

2-10GENERAL 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 co a l fir ed

, 2 6 50 F; 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** electrod es, 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 elec trode, 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