Notice of Intent to Create

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1 Notice of Intent to Create Date: November 9, 2004 Proponent: Proponent Contact: Standard Method: Project Location: Whitby Cogeneration 1550 Wentworth St. W. Whitby, Ontario L1N 7C1 Brent Gibson Chief Operation Engineer Ph: Fax: The standard method used to calculate the reduction in emissions is Standard Method #1 from the Ontario Emissions Trading Code, NO Emissions reduction Credits from installation of Low-NOx Burners on Electricity Generators. Whitby Cogeneration 1550 Wentworth St. W Whitby, Ontario L1N 7C1 Expected Emission Reductions: Expected Annual Emission Reductions is 134 Mg (NO) Expected Cumulative Emission Reductions (7 years) is 938 Mg (NO)

2 Summary 1. Introduction Whitby Cogeneration is a natural gas fired cogeneration plant utilizing an industrial gas turbine. The turbine was fitted with new Low NOx combustors in July Proponent Identification Whitby Cogeneration L.P. is the owner of the facility. 3. Emission Reduction Project Description 3.1 Site Descpiption: The facility consists of a 58 megawatt baseload turbine exhausting into a boiler which supplies steam to an adjacent paper mill 3.2 Pre-Project description: Same turbine with an earlier technology of Low Nox Combustors. 3.3 The Standard Method: Method #1 3.4 Actions Taken: Installation of latest technology available for Low Nox Combustors 3.5 Post Project conditions: 60% reduction in NOx emissions. 4. Validity of Emission Reductions 4.1 Real: Production and fuel consumption remain the same, emission reduction is real. 4.2 Surplus: The reductions are surplus. Baseline emissions have always been below C of A limitations. 4.3 Quantifiable: The facility uses Continuous Emission Monitoring Data. 4.4 Unique: The emission reductions have not been used in any other trading regime. 4.5 Verifiable: The emission reductions are verified by a third party. 5. Quantification of Emission Reduction 5.1 Process Description: The natural gas turbine had Low NOx Combustors installed 5.2 Data Collection: A Data Acquisition System is used to collect data from the Continuous Emission Monitoring System.

3 5.3 Baseline Determination: Baseline was determined with 12 months of hourly data prior to the installation of Low NOx Combustors. 5.4 Emission Reduction Calculation: ER = ( Baseline Emission Rate Actual Emission Rate ) x Actual Activity 6. Reporting of Emission Reductions Standard Method #1 is used. 7. Final Sections 7.1 Documents Examined: Documents are listed 7.2 Warranties: Warranties are provided Addenda: Appendix A, Hourly Data with Regression Chart

4 Table of Contents 1. Introduction 2. Proponent Identification 3. Emission Reduction Project Description 3.1 Site Description 3.2 Pre-Project Conditions 3.3 The Standard Method 3.4 Actions Taken 3.5 Post Project Conditions 4. Validity of Emission Reductions 4.1 Real 4.2 Surplus 4.3 Quantifiable 4.4 Unique 4.5 Verifiable 5. Quantification of Emission Reductions 5.1 Process Description 5.2 Data Collection 5.3 Baseline Determination 5.4 Emission Reduction Calculation 6. Reporting of Emission Reductions 7. Final Sections

5 7.1 Documents Examined 7.2 Warranties 1.0 Introduction Protocol for Whitby Cogeneration Low NOx Combustion Emission Reduction Whitby Cogeneration Limited Partnership is the owner of the Whitby Cogeneration natural gas turbine generating station in Whitby, Ontario. During a ten day retrofit in July 2003, the emission source, an aeroderivative industrial gas turbine was fitted with new technology Dry Low NOx combustors. This costly installation significantly reduced the NOx emissions while at the same time increased power production. After a few days commissioning, the emission reduction period began on August 1, This protocol follows the guidelines of the Ontario Emission Trading Code issued January This protocol is based on the Standard Method in Appendix 1 of the Code, Section 8.1 NO Emission reduction Credits from installation of Low-NOx Burners on Electricity Generators 2.0 Proponent Identification Project Owner: Company Contact: Facility Location: Whitby Cogeneration Limited Partnership 1550 Wentworth St. Whitby, Ontario L1N 7C1 Brent Gibson Chief Operating Engineer bgibson@whitbycogen.com Whitby Cogeneration Generation Station 1550 Wentworth St. Whitby, Ontario L1N 7C1 3.0 Emission Reduction Project Description 3.1 Site Description

6 Whitby Cogeneration is a baseload cogeneration plant consisting of a 58MW rated natural gas turbine exhausting into a waste heat recovery boiler. The boiler provides 100% of the steam required for an adjacent paper mill. This allows the mill to manufacture their product without the use of boilers. Whitby Cogeneration was commissioned in 1998 and all the electricity generated is transmitted to a Hydro One 230KV corridor for the Ontario market. 3.2 Pre-Project Conditions Prior to the 2003 installation of the Dry Low NOx combustors, the turbine had been fitted from the 1998 start-up with an early generation of Low NOx control. The turbine ran a baseload operation only and from 1998 to July 2003 the NOx (expressed as NO) averaged approximately 50ng of NO per joule heat input. 3.3 The Standard Method The standard method used to accomplish this reduction in emissions is Standard Method #1 from the Ontario Emissions Trading Code, NO Emissions reduction Credits from installation of Low-NOx Burners on Electricity Generators. 3.4 Action Taken The action taken was installing newly designed combustors from the turbine manufacturer. This technology utilizes 3 stages of combustion, Primary, Secondary, and Tertiary. Each stage has a thoroughly mixed extremely lean air/fuel mixture prior to combustion and allows for a uniform cool and stable flame through the 3 zones of combustion. This uniform lower temperature combustion process suppresses thermal NOx formation. A new hot side attenuation technology is also incorporated into the combustors to eliminate any combustion noise. 3.5 Post Project Conditions With the new Dry Low NOx combustors installed the average NOx emissions (expressed as NO) dropped to approximately 20ng per joule of heat input. 4.0 Validity of Emission Reductions 4.1 Real The emission reduction is based on the improved technology of the combustion process alone and there was no decrease in production. The heat rate and

7 efficiency for the turbine was not altered, therefore the increase in production requires an increase in fuel consumption so there is no increase or decrease in natural gas consumption per megawatt-hour. The emission reduction is real. 4.2 Surplus The emission reduction is surplus. The facility s Certificate of Approval from the Ontario MOE Number Notice No. 3 allowed emissions for the baseline and emission reduction period to be 65 parts per million volume of NOx at 15% oxygen based on a 24 hour rolling average. These emission rates are monitored at the plant with a Continuous Emission Monitoring System. The baseline emissions have always been below C of A limitations since the plant started operating in Quantifiable As required by the MOE Guideline for Stationary Turbines (March 1994), the concentration of NOx is measured with a Continuous Emission Monitoring System. In compliance with the C of A: The CEMS is calibrated on a daily basis and includes zero and span calibrations and the readings are automatically corrected for drift by a Data Acquisition System (DAS) Monthly reports are generated by the DAS and include Daily Calibration Reports, 24 Hour Average Concentration Reports, and System Availability Reports. All records are kept for preventative maintenance and repairs. Due to the nature of a gas turbine, the net power output varies with the ambient temperature or air inlet temperature. The baseline data is expressed in mass per unit of power or kg/mwh. The baseline is calculated from data points collected from the DAS. The baseline data is taken from August 1, 2002 to July 31, Unique These emission reductions are unique. They have not been used on any other emission reduction trading regime. 4.5 Verifiable All CEMS data is kept on site as DAS reports, calibration and maintenance records are all kept as well. The Verifier will determine the data and calculations accuracy.

8 5.0 Quantification and Emission Reduction 5.1 Process Description The Standard Method used as mentioned in 3.3 is Low NOx Burners for Electricity Generators. This combustion process takes place in radial mounted combustors on a natural gas turbine. Section 3.4 Action Taken describes the combustion process. 5.2 Data Collection Whitby Cogeneration uses CEMS equipment for the quantification of baselines, activity levels, and emission reductions. Drift corrected data from the analyzers is sent to the DAS computer via PLC. The data is updated every 15 seconds. Data points collected at the 15 second intervals are averaged to calculate one minute averages, which are subsequently used for calculating 5 minute, 15 minute, and 1 hour averages. A 24-hour rolling average is calculated using 24 one hour average points. The daily calibration is accomplished by injecting calibration gases into the stack sample probe. The calibration gases are of the Certified Accuracy Grade of +-1% for Nitric Oxide and +-.02% for Oxygen. A report of each calibration is recorded by the DAS computer containing the date, time, zero and span values, and percentage drift. The allowable zero and span drifts, as calculated by the DAS are 2 and 2.5 percent respectively. If the drift is exceeded, an alarm is generated. The automatic calibration does not make adjustments directly to the analyzer. The raw data is correct for bias by the PLC prior to communication to the DAS. In the event of drift limit exceedence, a manual calibration is performed locally at the analyzers. The manual calibration corrects the analyzer output for any error. Following a manual calibration, an automatic calibration is required to adjust the bias corrections within the PLC. Quality Control procedures are listed in 4.3. In addition, the C of A Specifications for the NOx Analyzer include: Calibration Error cannot exceed 2% of actual concentration Span value is 2 times the average normal concentration Zero Calibration Drift (24 Hour) cannot exceed 2.5% of span value Span Calibration Drift (24 Hour) cannot exceed 2.5% of span value Relative Accuracy must be within 10% of the mean value of the reference method test data The monitor must be operated and maintained so that accurate data is obtained during a minimum of 95% of the time, on a monthly basis.

9 The equipment used is listed below. NOx Analyzer Make: Servomex 1491 Model: Type: Chemiluminescence with Photomultiplier Accuracy: +-2% FSD O2 Analyzer Make: Servomex Xentra 4900 Model: 4902 A ABX S/N: Type: Paramagnetic Pm 1156 Accuracy: +-2% FSD Data Acquisition System Make: CEMView Data Acquisition and Reporting System Version: 2.1 Manufacturer: Nexus Solutions 5.3 Baseline Determination The Baseline period is the 12 consecutive months prior to the month the project was completed. Baseline NO emissions data is derived from the Continuous Emission Monitoring System. The turbine at Whitby never operates at a partial load, it is a baseload operation. Baseline NO emission rates were determined from an equation derived from data of the year prior to the reduction period. The equation was formulated from a best fit regression analysis of Power Output vs. NOx hourly data. The relationship was applied to the emission reduction period to calculated baseline NO concentrations from power output. The input heat rate was calculated from fuel rates with the use of an average heating value of.0378gj/mw. Both baseline and actual NO rates were normalized for heat input and presented as ng/j quantities. The difference between baseline and actual per joule quantities was multiplied by the hourly input heat rate to arrive at the NO emission reduction for the hour. The sum of all hourly NO emissions during operational periods was 55.8 tonnes. Smog season emission reduction was 16.6 tonnes and Non Smog season emission reduction was 39.2 tonnes.

10 5.4 Emission Reduction Calculation The Calculation Flowsheet below, provides the calculations used to determine he hourly mass emission rates of NO. Data provided were mass exhaust gas rates, NOx at 15% oxygen and actual oxygen readings recorded on hourly averages from August 1, 2002 to December 31, The flowrate was converted to dry volume rates at the standard temperature and pressure of 25 degrees Celsius and atmospheric pressure. A conservative ratio of 0.95(as recommended by MOE) was applied to NOx data to estimate NO concentrations. Hourly mass data were calculated for NO by multiplying the molecular weight of NO against the moles represented by the total volume of NO over the hour period. The following flowsheet used derives the Standard Method Calculation.

11 ER = ( Baseline Emission Rate Actual Emission Rate ) x Actual Activity Where: ER is the actual reduction of NO in nanograms (ng) Baseline Emission Rate is the ng of NO per Joule ( j) of heat input during baseline period Actual Emission Rate is the ng of NO per j of heat input during the generation period Actual Activity is the j of heat input during the generation period This calculation is derived from the Calculation Flowsheet below.

12 6.0 Reporting of Emission Reductions The calculation required by Standard Method #1 is used for every hour of data provided on Appendix A Hourly Data. An example taken from Appendix A, Hourly Data from October 1, 2003, hour 1 is shown below. 7.0 Final Sections ER= (Baseline Emission Rate Actual Emission Rate) x Actual Activity ER= (62.14 ng (NO) / joule ng (NO) / joule) x E+9 j ER= E+13ng ER=17.68kg 7.1 Documents Examined Whitby Cogeneration CEMS data MOE Certificate of Approval for Whitby Cogeneration Whitby Cogeneration Quality Assurance/Quality Control Manual 7.2 Warranties This Protocol was authored by Brent Gibson, Chief Operating Engineer, Whitby Cogeneration. As the author, I take responsibility of the statements made and the accuracy of the Protocol and Emission Reduction report. I warrant the Emission Reductions have not been previously used in any other emission reduction agency or program. Addenda Appendix A Hourly Data Appendix B- RATA Test Report September 2004

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