Technologies Control Environmental Control Feasible Technologies Impacts, and Technologies ‘ontrol Remaining Technologies Useful Life

Not analyzed

dueto

technical

Use Add-On difficulty Control of No N/A N/A N/A N/A expressed by

control Baghouse

technolo

vendors.

The Department has reviewed the BART analysis performed by the City of Dover. Based on this

review, DNREC is establishing 0.5 % sulfur as BART for City of Dover— Unit 3. AP-42 statesthat sulfur content in residual fuel is directly proportional to a one to one ration with particle

emissions._ Therefore, by-reducing sulfur content by half reduces PM by half. Evaluation of

all ofthe five (5) factors shows that a sulfur limit of 0.5 % is BART for the following reasons:

• Residual fuel with a sulfur content of 0.5 percent is cost-effective for purposes of improving

visibility at Class I areas. 22

• No significant energy or non-air quality environmental benefits or dis-benefits associated

with using lower sulfur fuel were identified.

A mechanical tyciune 1i are already in place, and 0.5% sulfur fuel will reduce PM emissions

by approximately 50%, accordino to AP 42

• Since the remaining useful life ofthe unit is expected to be greater than the life ofthe control

options, no weight was given to the remaining useful life parameter.

• Although there are small visibility incremental benefits that could be reasonably anticipated

as a result of installation of other control options (<0.1 dv on the worst day impact), DNREC

believes that the increased costs associated with higher cost options are not justified by the

minimal visibility improvement.

8.4.2.4 Conectiv Edge Moor Units 4 and 5

21 EPA Technology Transfer Network Clearinghouse for Inventories & Emissions Factors, Chapter 1

Volume 3 http:Ilvvww. epa.gov/ttn/chief/ap42/chOl /final/cO I s03. pdf

22 This applies only to this BART analysis, and that it does not imply that we have determined that

additional PM controls are not cost effective for any other future purpose or analysis.

68
g 

• The addition of a fabric filter was not had a high cost-effective for purposes of improving

visibility at Class I areas.

• Energy or non-air quality environmental benefits or dis-benefits were not considered in

ruling out any control technology.

• The existing ESP is effective at reducing particulate matter emissions, and the addition of

the DSI system will reduce condensable emissions.

• Since the remaining useful life of the unit is expected to be greater than the life of the

control options, no weight was given to the remaining useful life parameter.

• The incremental benefit in visibility that would result from the installation of a fabric

filter was small (comparable to 0.1 dv on the 8th highest day impact).

The Department has reviewed Conectiv’s BART analysis for Unit 5. Based on this review

DNREC is establishing 0.5 % sulfur as BART for PM at Edge Moor Unit 5. AP-42 states that

sulfur in fuel is a one-to-one ratiofl with particle emissions. Therefore, by reducing sulfur

content by half reduces PM by half. Evaluation of all of the five (5) factors shows that a sulfurlimit of 0.5 % is BART for the following reasons:

• Residual fuel with a sulfur content of 0.5 percent is cost-effective for purposes of

improving visibility at Class I areas.

• A mechanical cyclone is already in place, and 0.5% sulfur would reduce PM emissions

by 50%. AP ‘1223 states that sulfur in fuel is a one to one ration with particle emissions.

Therefore, by reducing sulfur content by half reduces PM by half.

• There are no significant energy or non-air quality environmental benefits or dis-benefits

associated with using lower sulfur fuel.

• Since the remaining useful life of the unit is expected to be greater than the life of the

control options, no weight was given to the remaining useful life parameter.

• This option will provide a small visibility incremental benefit.

23 EPA Technology Transfer Network Clearinghouse for Inventories & Emissions Factors, Chapter 1

Volume 3 http://www. epa. gov/ttn/chief/ap42/chOl /flnal!cOl s03. pdf

70
NRG provided an analysis of the available control technologies, and a “five factor analysis”

pursuant to the requirements of 40 CFR 51 .308(e)(1)(ii)(A) for the technologically feasible

options. Table 8-10 summarizes the cost effectiveness. In summary:

Cost.

Table 8-10 Cost Effectiveness for Visibility Improvement for Alternative Control

Technologies Brigantine NWA

Expected

Change in Total Emission Visihilit 3’ Average Cost Control Visibility Capital Cost Direct Cost Indirect Cost Annualized Rate (lb/ Impact Effectiveness ($ per Technology MMBtU) (dv) Impact $ $ $ Cost change in dv) from $

Baseline

Baseline

(existing Cold

side ESP): 0.3 0.173 - - - - -

Emission

Scenario 1

Pulse Jet

Fabric Filter: 0.015 0.01 0.163 $43,419,200 $20,330,504 $15,621,995 $35,952,499 $220,567,479 Emission

Scenario 1

Wet ESP

after FGD: 0.01 0.007 0.166 $88,270,292 $39,882,776 $31,759,177 $71,641,952 $431,578,024 Emission

Scenario 1

Baseline

(existing Cold

side ESP): 0.3 0.466 - - - - -

Emission

Scenario 2

Pulse Jet

Fabric Filter: 0.015 0.404 0.062 $43,419,200 $20,330,504 $15,621,995 $35,952,499 $579,879,016 Emission

Scenario 2

Wet ESP

after FGD: 0.01 0.367 0.099 $88,270,292 $39,882,776 $31,759,177 $71,641,952 $723,656,081 Emission

Scenario_2

Enerv and non-air environmental impacts—There are no significant energy or nonenvironmental impacts for either the Pulse Jet Fabric Filter (PIFF) or the wet ESP. The

higher pressure drop in the PJFF will result in some increase in power requirement. The

PJFF will generate dry ash in the hopper which will be transported to the landfill on the

site as is currently done with the ash from existing ESP.

The Wet ESP consumes electric power similar to dry ESP and thus there will be no

significant change in power demand. The additional condensable acid mist generated by

71
River — precipitator (ESP) ofthe existing equipment and operational standard (i.e., RG Indian River

s

Unit 3 EsP. proper operation ofthe existing ESP) egulation 1102 permit(coal) practically enforceable shall be imposed is changed to reflect

pursuant to Regulation No. 30 Section ART limits, but no6(a)(3)(i)(B), Regulation 1102, Section later than 01/01/2013.

11.2.9 and shall be incorporated into

Regulation_30_operating_permit.

City of ow Sulfur Oil BART shall be Reporting, monitoring, and recordkeeping ART will be effective

Dover, the use of oil requirements to make the BART n and after the dateMcKee with 0.5% operational standard (i.e., burning of low ity of Dover— McKeeRun — Unit sulfur, sulfur oil) practically enforceable shall be un’s Regulation 11023 imposed pursuant to Regulation No. 30 ,ermit is changed to(#6 residual Section 6(a)(3)(i)(B), Regulation 1102, eflect BART limits,oil) Section 11.2.9 and shall be incorporated ut no later than

into Regulation 30 operating permit. 1/01/2013

Conectiv existing BART shall be Reporting, monitoring, and recordkeeping ART will be effective

Edge Moor lectrostatic proper operation requirements to make the BART n and after the date — Unit 4 recipitator (ESP) of the existing equipment and operational standard (i.e., onectiv Edge Moor ‘s(coal) md installaion of ESP and DSJ.. proper operation ofthe existing ESP egulation 1102 permit

)ry Sorbent DST) practically enforceable shall be is changed to reflect

Injection (DSI). imposed pursuant to Regulation No. 30 ART limits, but no

Section 6(a)(3)(i)(B), Regulation 1102, later thanSection 11.2.9 and shall be incorporated )1/01/2013

into_Regulation_30_operating_permit.

Conectiv ow Sulfur BART shall be Reporting, monitoring, and recordkeeping 3ART will be effective

Edge Moor )il the use of oil requirements to make the BART n and after the dateUnit 5 (#6 with 0.5% operational standard (i.e., burning of low onectiv Edge Moor’sresidual sulfur. sulfur oil) practically enforceable shall be .eguIation 1102 permitoil) imposed pursuant to Regulation No. 30 is changed to reflect

Section 6(a)(3)(i)(B), Regulation 1102, 3ART limits, but noSection 11.2.9 and shall be incorporated later than

into_Regulation_30_operating_permit. )1/01/2013

74