PARTICULATE MATTER: THE VIEW FROM A COAL-FIRED POWER PLANT

JurisdictionUnited States
Air Quality Challenges Facing the Natural Resources Industry in the Western United States
(Nov 2007)

CHAPTER 6C
PARTICULATE MATTER: THE VIEW FROM A COAL-FIRED POWER PLANT

Michael G. Jenkins
PacifiCorp Energy
Salt Lake City, Utah

Friendly Coal-Fired Power Plant

[Page 6C-2]

Not-So-Friendly Coal-Fired Plant

(Mexico)

What Comes Out of a Coal Plant?

█ Sulfur Dioxide

█ Nitrogen Oxides

█ Carbon Monoxide

█ Volatile Organic Compounds

█ Hazardous Air Pollutants

█ (Carbon Dioxide)

█ Particulate Matter

[Page 6C-3]

How is a Coal-fired Power Plant Regulated for PM Emissions?

█ Specific PM emission stack limits

█ Opacity limits

█ Fugitive dust limits

█ Other emission limits

PM Stack Emission Limits

█ Set on a pounds per million BTUs basis

█ Includes PM10 and PM 2.5

█ NSPS limits:

█ .03 lb/mmBTU
█ BACT may reduce limit further

█ Large unit (500 - 600 MW) emits about 500 tpy (controlled)

[Page 6C-4]

Opacity Limits

█ NSPS: 20% opacity

█ Older units 40% opacity

█ "Opacity is not a pollutant"

█ "measure of light-blocking property of a plant's emissions"

█ "indicator of the amount of visible particulate pollution"

█ 11th Circuit Court of Appeals; TVA case

Fugitive Dust

█ No emission limits per se

█ Required to minimize emissions

█ Coal piles

█ Haul roads

█ Landfills

█ Material handling (coal, ash, etc.)

█ Controls

█ Water

█ Chemical cover

█ Coal pile size

█ Dust height

█ Work practices

█ Visual observation

[Page 6C-5]

PM Compliance at Coal Plant

█ Difficult to monitor stack PM emissions continuously

█ Annual stack test vs. PM continuous emission monitors

█ Compliance Assurance Monitoring (CAM) Plan

█ Correlation to opacity
█ Control equipment in service

█ "Surrogates" enforced more vigorously than stack PM emission limit

█ Opacity; SO2; NOx

█ Stack PM emissions controlled by: (i) electrostatic precipitators or baghouses; (ii) other pollution controls; and (iii) coal quality.

█ Opacity measured by continuous opacity monitors

█ Fugitive dust monitored by observations and work practices

PM and the Utility Industry

█ PM NAAQS (PM 2.5)

█ Clean Air Interstate Rule (east)

█ Regional Haze (west)

[Page 6C-6]

PM 2.5 Regulation

█ Feds set new ambient PM 2.5 limit

█ States must meet through SIPS

█ Non-attainment areas must be addressed

█ Predominantly in the east

█ New controls added as needed to meet SIP requirements

█ New sources limited until attainment achieved

CAIR

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