C03-012 - Selecting the Best Air Pollution Control Strategy - US
C03-012 - Selecting the Best Air Pollution Control Strategy - US
C03-012 - Selecting the Best Air Pollution Control Strategy - US
Control Strategy
P: (877) 322-5800
[email protected]
www.cedengineering.com
Selecting the Best Air Pollution Control Strategy– C03-012
Despite progress over the last 40 years, air pollution is a major public health issue in the
U.S. Over a third of the nation lives in ozone nonattainment areas. The National
Ambient Air Quality Standard for ozone is about to be lowered, causing more areas to
be nonattainment. Ultrafine particulate matter (“PM2.5”) has been implicated in a number
of public health issues, such as asthma. Therefore, the Obama Administration and
USEPA Administrator Lisa Jackson have openly called for making air pollution, as well
as all environmental, rules more stringent. Perhaps more important, neighborhood
environmental groups have gotten more knowledgable and savvy, and know how to use
the system to block proposed plans to make changes or expansions at existing plants or
to block construction of new plants. Minimizing air emissions will be a priority at many
facilities nationwide.
The “best” way to reduce emissions of air pollutants is to optimize your process, so as
less air pollutants are produced. Optimizing your process includes:
In the literature, these efforts are often called “Pollution Prevention” or “P2”. The USEPA
openly encourages companies to implement P2 programs.
In addition to reducing air and other environmental impacts, process optimization also
potentially saves the company much in the way of regular cost, such as purchase of raw
materials, purchase of fuels, maintenance, etc. Therefore, it is also obvious that
companies actively research optimization options extensively, implement optimization
strategies that make sense, and often have staff devoted to this.
But at a certain point, a facility will have implemented all feasible optimization strategies.
It is likely that to comply with applicable air quality regulations some type of “end of
pipe” control device removing contaminants that are formed must be installed and
operated. What site- or process-specific factors are critical to selecting the technology
type? How does one decide on the most appropriate technology to install (advantages
1
Selecting the Best Air Pollution Control Strategy– C03-012
and disadvantages)? What are the key design features that need to be addressed for
each candidate technology type applied to the source of emissions? These are the
issues to be covered in this course. This course is designed for engineers with
responsibility for air quality compliance.
To begin to assess which air pollution control equipment is best for a given operation,
the following determinations need to be made:
Therefore, the environmental engineer needs to fully understand which pollutants are
being emitted and their emission rates leaving the process and entering potential APC
equipment, including how rates may change over time (i.e., do they peak at a certain
segment of the operations cycle and trail off later?). Other courses examine how to
measure and estimate air emissions.
With this information, the environmental engineer should first check all applicable air
quality regulations as well as current air permit limits to determine whether any
compound’s emission rate during the process must be reduced and, if so, by how much.
Evaluating any proposed legislation which may impact the facility in the future is a good
thing, as well. In addition, if APC equipment is necessary, must it be operated
continually or not?
Then after the list of compounds whose emission rates must be reduced and their
degree of control are determined, the environmental engineer must select the type of
APC equipment likely to meet the required reductions. APC equipment that cannot
capture, remove, or otherwise control a certain compound must be removed from
consideration. APC equipment that can control the compound but not sufficiently based
on regulatory requirements or the air permit must be removed from consideration, too.
2
Selecting the Best Air Pollution Control Strategy– C03-012
For sources where more than one compound must be controlled or a very large
reduction in emissions is required, it is possible that more than one APC device must be
utilized.
Minimum APC equipment performance requirements are written into several prominent
air quality regulations. Such performance is summarized by acronyms. First, comes
Reasonably Available Control Technology (RACT). This is the least stringent control
strategy. It is generally based on a “reasonable” technology that many with similar
processes are successfully using. Some RACT rules allow the facility to exempt itself
from different APC equipment if the cost is considered excessive. If such an exemption
is preferred, the environmental engineer must determine the true cost of the equipment,
including its capital cost, amortized cost, and operating costs for the lifetime of the
equipment. Then it must determine total emissions that it will control over its lifetime,
and use these to determine cost per ton of compound controlled. If this rate exceeds a
certain published factor, then the cost of the APC equipment is considered not
“reasonable” and does not have to be considered.
Next comes Maximum Achievable Control Technology (MACT), used in many federal
(NESHAP) hazardous air pollutant regulations. This is a standard where an applicable
facility must meet a control efficiency standard based on the average of the top 12% of
facilities for the same process. Cost is not supposed to be a factor in determining
whether a strategy meets the MACT criteria.
Next in stringency comes Best Available Control Technology (BACT), used in the
Prevention of Significant Deterioration program. It is an assessment that a facility must
make to determine which technology is “best.” The USEPA requires a Top-Down
Analysis. The environmental engineer must first create a list of all APC equipment that
are technically feasible for the compound(s) in question and list them in order of
effectiveness for the process in question from most effective (greatest potential control
efficiency) to least effective. Then the engineer must take the most stringent listed APC
3
Selecting the Best Air Pollution Control Strategy– C03-012
and perform an assessment of its economic, environmental, and energy impacts. The
economic impact is similar to the one performed for RACT, except for BACT the cost
threshold (in dollars per ton controlled) that allows an APC to be stricken from
consideration is much higher than for RACT. As a rule requiring more stringent
compound control, it would take a very high cost to exempt a technically-feasible APC.
The environmental evaluation is a technical evaluation of environmental impacts,
including unintentional ones. Does the operation of the APC equipment to remove the
compound convert it into another compound that may be more dangerous (toxic)? Does
its operation cause the contamination or other adverse impacts of another source (i.e.,
major increase in generation of a toxic solid waste or wastewater)? If such an
environmental impact is considered as serious or worse than not operating the APC,
then that candidate APC can be stricken from consideration. Finally, the engineer must
perform an energy evaluation. Will the operation of the candidate APC cause a huge
energy penalty, with its resultant high fuel usage and combustion emissions? In its wish
to conserve energy usage, the USEPA takes a major energy demand into consideration
to potentially exclude an APC from consideration for BACT.
Finally, comes Lowest Achievable Emission Rate (LAER), required for control of
compounds from major new or modified sources in a non-attainment area. Like with
BACT, the environmental engineer must develop a list of technically-feasible APC
equipment from most stringent. The most stringent APC is LAER, unless the cost is so
overwhelmingly expensive, and/or environmental and energy impacts are so large and
able to cause hardship.
The environmental engineer must know what the agency requirements will be for the
source in question so that the right approach can be taken and APC equipment
selected.
Incineration or Oxidation
Incineration is commonly used to control both volatile organic compound (VOCs) and
inorganic gases, such as hydrogen sulfide. Thermal incineration involves having the
exhaust travel into a high temperature chamber, causing the compounds to destabilize
and break down to their elemental components, followed by their oxidation. Therefore,
this technology is often referred to as thermal oxidation. VOCs will be oxidized by high
temperature to carbon dioxide and water. Inorganic gases will be oxidized to simpler
inorganic substances; for example, hydrogen sulfide is oxidized to sulfur dioxide.
These units are sometimes also called afterburners. Control efficiencies for thermal
incinerators of over 99% can be achieved for VOCs and inorganic gases. Often the
literature refers to this as “destruction efficiency”, as the compound is permanently
destroyed. Incinerators are used in many processes to control exhausts laden with
VOCs, such as pharmaceutical and chemical manufacturing, coating operations, and
printing. Incinerators are effective in controlling exhausts with low concentrations of
4
Selecting the Best Air Pollution Control Strategy– C03-012
VOCs.
The two key factors in the design of a thermal incinerator for enhanced performance of
destroying and oxidizing the subject compounds is sufficient high temperatures in the
chamber and sufficient residence time in the combustion zone. Although the ideal
chamber temperature may differ based on the compound being treated, generally
incinerators are programmed to maintain a temperature of 1,200 to 1,500°F.
Temperatures significantly above this represent a waste of fuel combusted to reach the
necessary range. In addition, at a certain point (generally, above 1,600°F), the system
begins to form nitrogen oxides (NOx), a regulated pollutant, from the breakdown and
oxidation of nitrogen in the fuel and in the air. Maintaining a temperature below 1,200°F
may cause the exhaust components to not combust completely. And in fact, in such
conditions, not only will VOC or other gases move through the system uncontrolled, but
products of incomplete combustion (PICs) could form. Many of these compounds are
toxic, making the exhaust potentially more toxic than the original vapors being
combusted. Odorous exhaust coming out the stack or a slight black smoke may indicate
the formation of PICs. Therefore, many regulatory agencies in issued air permits set
forth a minimum absolute or average temperature that must be maintained in the
incinerator chamber at all times during operation, and require thermocouples in the
combustion chamber and appropriate recording devices to ensure compliance and have
documentation.
The residence time, or the average time the exhaust travels through the combustion
chamber is critical, as well. Residence time is the ratio of the capacity of a chamber to
hold a substance divided by the rate of flow into and out of the chamber. A chamber not
designed properly for the worst case maximum quantity of compound to be destroyed
will allow compound to be exposed for too short a period at the necessary temperature
and not be destroyed. Typically, an average residence time of 0.5 seconds is sufficient
to meet a 99% destruction efficiency at a temperature range of 1,200°F to 1,500°F.
When an environmental engineer determines that the destruction efficiency is below this
and the temperature monitor is properly calibrated and shows that the right temperature
is maintained, then a likely reason is that too much VOC is entering the incinerator
given the size of the chamber. An expanded chamber or reduced flow rate would raise
the residence time. A knowledge of worst case maximum contaminant inlet is critical to
designing the combustion chamber to meet the minimum residence time necessary to
meet a high destruction efficiency.
While incinerators are highly effective, their operation comes at a great energy cost.
Fuel must be burned to create sufficient heat in the combustion chamber. While energy
released when VOCs and other compounds in the exhaust are combusted can
compensate for this somewhat, this effect is negligible for typical dilute VOC streams.
And for very highly concentrated VOC exhausts, there is a chance that a lower
explosivity limit may be approached. To reduce fuel use, the incinerator/oxidation unit
can be modified by adding a catalyst in the unit. The catalyst slows down the
compounds in the combustion unit to raise its residence time sufficiently to allow a lower
temperature in the combustion unit, yet still maintain a high destruction efficiency.
5
Selecting the Best Air Pollution Control Strategy– C03-012
The benefits of catalytic oxidation compared to thermal oxidation are lower fuel costs
and lower emissions from the byproducts of fuel combustion. A disadvantage of a
catalytic unit is the potentially higher capital cost of the catalyst, although this may be
compensated for (in some cases) by a smaller combustion unit. In addition, catalysts
involve greater maintenance and will need to be replaced during the life of the total unit,
an additional cost. One other factor is critical in deciding between thermal and catalytic
incinerators. To use a catalyst the exhaust must be essentially free of foreign
substances which could stick to and poison the catalyst, such as particulates and
others. So besides knowing the concentrations of the contaminants one wants to
remove from the exhaust stream, determining the presence and quantities of these
other substances are crucial, too. Finally, spent catalyst must be removed. In some
cases (particularly for those containing metals), catalysts must be treated like a
hazardous waste and this adds additional costs.
6
Selecting the Best Air Pollution Control Strategy– C03-012
reduced its target compound, it has formed acid gases, which may have a greater
adverse impact than the compounds you destroyed. Therefore, it is important to know
before making a decision on APC equipment the content of halogens.
Adsorption
Adsorption occurs when a solid surface attracts and retains compounds with which they
come into contact. Both solids and gases (the adsorbate) can be attracted to the solid’s
surface (adsorbent). Typically, adsorption is a physical process, the adsorbate is
attracted by molecular forces onto the adsorbent solid, is adsorbed onto the surface
without being converted chemically or dissolving in it.
Adsorption can effectively remove a contaminant from an exhaust based on the nature
and degree of attraction between the solid surface and the gaseous component. Some
adsorbents are more capable of attracting compounds than others; some adsorbates
have a greater tendency to be adsorbed than other gases. Another critical factor in
practical terms is the relative area that a solid can adsorb material relative to the flow
rate of exhaust passing through; it must have a large surface area for a given mass.
Without this, the adsorbent gets “filled up” fairly quickly and must be desorbed or
replaced.
To control air pollutants the most common adsorbent is activated carbon, and, in fact,
the technology is called carbon adsorption. Activated carbon has a large surface area
and, more important, a porous structure and a large exposed surface to allow
compounds access to the surface and find a free area to bind to. Activated carbon is
commonly used in other systems to adsorb compounds, too, such as aquariums to
adsorb liquid contaminants. For APC equipment, carbon adsorption is most commonly
used to remove VOCs from an exhaust stream. As with catalytic incineration (above),
particulate matter can bind, block, and disturb the activated carbon surface. Therefore,
particulate matter should be pre-treated and removed from an exhaust stream before a
carbon adsorption system treats the exhaust or not used at all. Note that carbon
adsorption is not appropriate for all VOCs.
In order to select carbon adsorption as the APC for removal of a particular VOC, it is
critical to first determine whether or not the subject VOC adsorbs significantly onto
activated carbon. If the compound has low or no adsorbtivity, then carbon adsorption
should be removed as a candidate for technical applicability reasons. Most
manufacturers of activated carbon or carbon adsorption equipment has a list of common
VOCs and their relative adsorbtivity. Although there are exceptions, most ringed VOC
compounds, such as xylene, toluene, naphthalene, and benzene, adsorb well onto
activated carbon, while chained and halogenated VOC, such as hexane, methane,
acetone, methylene chloride, chloroethane, do not adsorb onto activated carbon well.
The environmental engineer should not select carbon adsorption if compounds such as
these need to be controlled.
Sizing the carbon adsorption unit is dependent on the long term inlet of compounds that
7
Selecting the Best Air Pollution Control Strategy– C03-012
will adsorb onto the carbon. Many units operate some type of measurement device
downstream to determine if pollutant is being captured or is breaking through, an
indication that all of the effective sites on the activated carbon are taken by captured
compound.
One other consideration for a carbon adsorption system design is that adsorption is a
slightly exothermic process. If the solvent-laden exhaust stream is fairly concentrated,
there may be concerns about heat buildup and damage in the system.
Absorption
A key for the effectiveness of absorption is that the contaminant must be soluble in the
scrubbant. Water is the most common scrubbant, and will be the focus of this
discussion. Therefore, absorption cannot be used to remove VOCs from an exhaust
stream that are insoluble or has low solubility in water. Common industrial VOCs, such
as ethanol, methanol, butanol, and ketones, can be successfully removed from an
exhaust stream by a scrubber. But scrubbing would be ineffective for most VOCs as
8
Selecting the Best Air Pollution Control Strategy– C03-012
most are not water soluble. Common industrial VOCs that cannot be removed by
absorption include toluene, benzene, methylene chloride, and ethylebenzene.
Absorption can be effective in removing from an exhaust stream certain non-VOC
gases, such as sulfur dioxide and hydrogen sulfide. Finally, scrubbing can be effective
in removing particulate matter from an exhaust stream.
Once the environmental engineer has determined that the contaminants in question can
be removed by a scrubber, efforts must be taken to design an effective unit. The
consideration in a scrubber design is to optimize the contact between the gas and the
water to allow the greatest degree of gas dissolving in the water. Scrubbers can operate
to control over 99% of the contaminants entering the unit.
The main type of scrubber design used for this purpose is the packed tower. The dirty
exhaust gas enters the tower at the bottom and exits the top. The clean water enters the
unit on the top. This countercurrent motion enables maximum contact across the unit.
The water is generally atomized to create small droplets, maximizing the quantity of
surface area where the gas enters and dissolves into the water. Finally, the packed
tower contains material to slow the movement and hold up both the gas and water to
allow more opportunities for contact. The packing material is inert, and generally small
in size, maximizing its surface area. Most packing material is made of plastic and may
be in the shape of rings, saddles, and balls. Some scrubbers contain horizontal plates
with strategically placed holes to allow gas and water to pass at limited locations.
One final design type of a scrubber is called a venturi scrubber. These scrubbers are
vertical, like the ones discussed above. However, the unit narrows in the center of the
unit, such that the gas and the water can only pass through a narrow “throat”, raising
the intimacy of their contact. Venturi scrubbers are used mainly for particulate control.
Scrubbers can be used to not only remove a gaseous contaminant from the exhaust
stream, but also to change its chemistry. For example, an acidic stream can be treated
with a scrubber containing water that is made basic to not only dissolve acid gases out
of the exhaust stream, but also to neutralize it. Another example is at wastewater
treatment plants where compounds that are odorous even at low concentrations, such
as hydrogen sulfide and mercaptans, must be removed from gaseous streams. While a
scrubber can succeed in removing these compounds, a small quantity can re-volatilize
from the spent water to the air again, and be detected by its malodorous characteristics.
Therefore, at many wastewater treatment plants, scrubbers of odorous exhaust streams
use water with a dilute quantity of hypochlorite which will chemically oxidize these
compounds from their reduced forms. Should some compound re-volatilize it will not be
in its odorous form. Another form of this approach is using a solid, such as lime, or a
lime-water mixture to neutralize sulfur dioxide or other acidic gases. These are normally
referred to as “dry” scrubbers. Between a basic scrubbant and dry units, scrubbers are
commonly used to control exhaust streams with acid gases, such as hydrogen chloride,
sulfuric acid, sulfur dioxide, etc. In fact, scrubbers to control acid gases are often used
to pre-treat an exhaust stream before it goes to an incinerator or a particulate control
device.
How does one know whether a scrubber is operating properly? It could be prohibitively
9
Selecting the Best Air Pollution Control Strategy– C03-012
expensive to continually measure the percent control or the outlet concentration of the
contaminant in question. A scrubber performing well with the scrubbant being in intimate
contact with the dirty gas takes energy to operate and ensure the gas and water flow
through properly. This is commonly measured as a “pressure drop” across the plate or
packing or venturi throat or wherever the contact occurs. Monitors on both sides will
show a pressure drop across the area. If the pressure drop is low, then the hold up and
contact is poor and the scrubbant is probably not contacting the gaseous flow optimally.
Typically, a stack test under normal or high inlet conditions is performed and the
pressure drop measured during tests of good emission reductions. Many air permits
require the scrubber to maintain a certain range of pressure drops based on the
pressure drops measured during the successful runs.
One of the disadvantages of absorption is that because the contaminant has merely be
transferred from one state (gaseous) to another (liquid) treatment and disposal of the
contaminated water must be planned. While scrubbant water in many cases can be
reused and recycled, there is a point where it is so full of contaminants that at least a
portion must be removed and treated and fresh water inserted. In some cases, the
contaminated water may require pretreatment before discharge to the local municipal
wastewater treatment plant, or transportation offsite to a treatment center. The facility
may need to recalculate its total discharge offsite to ensure it still meets water discharge
permit standards.
Condensation
Condensers are fairly inexpensive equipment typically with a tube for the gas
surrounded by shells containing flow of the cooling media. Depending on the
temperature that needs to be reached, chilled water or refrigerant may be used. A
condenser has an ideal exchange area to allow heat energy to be removed from the
gaseous stream, allowing it to be cooled and the materials condensed.
10
Selecting the Best Air Pollution Control Strategy– C03-012
lower than most other APC equipment. And as mentioned above, collected compounds
could be pure enough to reuse in the process or have other uses.
NOx Control
Nitrogen oxides, made up of NO and NO2 (cumulatively called NOx), derives from the
oxidation of nitrogen in the fuel or air during high temperature combustion. NOx is a
precursor for ozone, and thus is a target for many air quality regulations. Control of NOx
emissions is a particularly difficult technical challenge as NOx is neither acidic, like SO2,
and can be controlled by an acid scrubber, nor is it significantly soluble in water, nor
does it brake down at high temperatures.
Therefore, the first strategy to reduce NOx emissions is to introduce designs in your
boilers and other combustion equipment that would minimize the formation of NOx.
There is now a whole generation of “Low NOx Burners” (LNB) that arrange combustion
to minimize temperature spikes, such as staged combustion such that the period of
highest temperature occurs with the least amount of fuel and/or combustion air present
to minimize conversion of nitrogen in these medium into NOx. LNB can cause a
reduction of 40 to 70% of NOx formation, compared to conventional burners.
11
Selecting the Best Air Pollution Control Strategy– C03-012
While SCR systems have achieved 70-90% reductions of NOx emissions from coal-fired
furnaces, SCRs have caused emissions of PM2.5 and gaseous mercury as byproducts
of its operations. Therefore, many regulatory agencies require a scrubber be operated
downstream of the SCR system to remove these pollutants.
Fabric Filter
The final two common APC equipment described here pertain to control of particulate
matter, and focus on fine particulates, PM2.5. Links between PM2.5 and a number of
adverse public health conditions, such as lung disease and asthma, have been
substantiated. Future air quality rules will likely focus on APC equipment focused on
removal of PM2.5.
A fabric filter, also known as a baghouse or a dust collector, is a filter that allows the
exhaust gas through but retains the dust or particulate matter. In a simple sense, it is
similar to a vacuum cleaner one has at home. It is a relatively simple and inexpensive
APC device and can achieve PM control efficiencies of over 99% depending on the
design and relative flow going through the system. It is effective for both high and low
concentration dusty streams.
These days fabric filter bags are woven tight and made of a variety of materials, such as
cotton, synthetics, or fiberglass. The bags have pores to allow gases through, but the
pores are small enough to prevent particulates from going through. As particulates build
up around the pores it makes it more difficult for later particulate matter to cross over.
Effective control is common. However, at a certain point this “cake” of solids can be so
thick that it can damage the bag(s) and/or make more difficult the flow of gases. This
can be measured by either a decrease in pressure drop across the bag (there is a tear
in the bag and the entire exhaust can flow through rendering the system ineffective) or a
major increase in pressure drop from normal (gases are held up and are more hard
pressed to flow across). Therefore, most fabric filter systems have automated systems
to remove the dust cake when it builds up to a certain high pressure drop. Most systems
use mechanical shakers to free the dust from the bags with a container on the bottom to
catch it. Some use “reverse air”. Operation of the bags is stopped and air is pumped in
the reverse direction, freeing the dust from the bags. Either way, the environmental
engineer must plan for either disposal of the solid dust (depending on the composition,
such dust may represent a hazardous waste) or potential reuse if it is a fairly pure
product or raw material lost during transfer.
12
Selecting the Best Air Pollution Control Strategy– C03-012
Electrostatic Precipitators
Electrostatic precipitators (ESPs) confer electric charges onto the dust in the exhaust
and then remove them from the stream by a collection electrode. The dust particles
receive a negative charge as they pass through the ionized field between electrodes.
These charged particles are then attracted to a positively-charged electrode and adhere
to it. The collected material is removed by vibrating the collecting electrodes usually at a
predetermined interval. Unlike with fabric filters, collecting dust from an ESP can be
performed without interrupting the control process. Finally ESPs can be assisted in their
particulate control functions by the use of water. These are “Wet ESPs”, as opposed to
conventional or “Dry ESPs”.
Like fabric filters, ESPs are effective APCs for particulate matter and relatively
inexpensive and simple to operate. Also like fabric filters, ESPs are less effective for
fine PM2.5. Particulate matter is not controlled by an ESP if it is able to pass through the
ionizing electrodes without being made ionic. PM2.5 is both smaller and easier to evade
ionization and travels at a higher velocity through the ionizing portion of an ESP
compared to larger PM, explaining its drop in effectiveness.
13