Technical Support Docum ent (TSD)
for the Transport Rule
Docket ID No. EPA-HQ-OAR-2009-0491



## Installation Timing for Low NO X 

## Burners (LNB)

U.S. Environmental Protection Agency

Office of Air and Radiation
July 2010

1Installa tion Timing for Low NO X Burners (LNB)

Section IV.D in the preamble to the Transport Rule discusses EPA’s proposed approach to quantify upwind state emi ssions that significantly contribute to
nonattainment or interfere w ith maintenance downwind. That section of the preamble references EPA’s assumptions regarding the le ngth of time required to install certain air pollution controls including low NO X burners (LNB). In this Technical Support Document we explain briefly EPA’s assumption that suffici ent LNB can be installed by 2012 for the Transport Rule.

EPA analysis in support of the Transport Rule indicates that there may be on the
order of about 30 coal-fired boilers for wh ich it might be economic to install low NO X burners to achieve compliance. These roughly 30 boilers are located in the four states that the proposed Transport Rule would cover but which are not required to reduce emissions under the Clean Air Interstate Rule (CAIR). 1 EPA analyzed only these four
states because it is assumed that sour ces in CAIR states already control NO X emissions.

EPA anticipates finalizing the Tran sport Rule by about June 2011. LNB installations, burner modifications, or other NO X reduction controls would likely have to be installed during fall 2011 or spring 2012 outages in order to achieve significant reductions for 2012. While this schedule is aggressive, industry has shown that it can be met. Limestone Electric Generating Station Unit 2, a 820 MW tangen tially fired lignite unit, was retrofitted with Foster Wheeler’s Tangential Low NO X (TLN3) system in less than six months, including engineering, fabrication, delivery and installation. 2 Harlee

1 The states of Kansas, Nebraska, and Oklahoma are not covered by CAIR but would be covered by the proposed Transport Rule. Minnesota would be covered by the proposed Transport Rule and is included in CAIR, however, EPA stayed the effectiveness of CAIR in Minnesota (74 FR 56,721; November 3, 2009). 2 R. Pearce, J. Grusha, Reliant Energy Tangential Low NOx System at Limestone Unit 2 Cuts Texas Lignite, PRB and Pet Coke NOx , http://www.fwc.com/publications/tech _papers/files/tp_f irsys_01_02.pdf

23 Branch Unit 4, a 535 MW cell-fired unit, was retrofitted with Riley Power’s low-NO X Dual Air Zone CCV burners on a similar schedule. 3

In addition to LNB retrofits and burner m odifications, there are other approaches that can be implemented in a short time frame to achieve significant NO X reduction. Relatively simple Selective Non-Catalytic Reduction (SNCR) systems can be installed quickly. Likewise, the re-tuning or upgrading of existing co mbustion control systems can often provide significant NO X reductions and can be performed quickly. 4

There are many LNB technology suppliers currently working in the U.S., including Alstom, Babcock Power, Babcock & Wilcox, Combustion Components Associates, Foster Wheeler, Fu el Tech, General Electric, RJM, and Siemens. With the current tailing-off of new coal pl ant construction and with recent SO 2 scrubber installations winding down, these and other firms in the supply chain have the ability to respond quickly to a large amount of new orders for emission control systems. They are capable of completing LNB retrofits, burner mo difications, and other control approaches
on at least 30 coal-fired boilers in time to obtain significant NO X reductions in 2012. 5

3 B. Courtemanche, et al, Reducing NO X Emissions and Commissioning Time on Southern Company Coal Fired Boilers With Low NO X Burners and CFD Analysis, http://www.babcockpower.com/pdf/t-182.pdf 4 D. Foerter, Institute of Clean Air Companies (p ersonal communication with EP A staff, June 14, 2010) 5 Ibid