Fugitive Dust Management Plan

Transcription

1 Lansing Board of Water & Light July 2014

2 1.0 INTRODUCTION The Renewable Operating Permit B requires continuously implementing a written Fugitive Dust Control Program for the purpose of minimizing fugitive dust caused in conjunction with the delivery, storage, handling, and use of coal. Any changes to the written program shall be approved by the District Supervisor. BWL had developed procedures in accordance with the Michigan Air Pollution Control Rule to mitigate the impacts of fugitive dust from reaching the property boundaries of its. Fugitive emissions are defined as emissions that are not emitted through a stack, chimney, vent, or other functionally equivalent opening. At the, the potential sources of fugitive emissions from the delivery, storage, handling and use of coal include operations at the: Car Dumper Building, Coal Conveyance System, Crusher House, Coal Pile (outdoor storage), Reclaim Activities, and Roads. Details on the process and the mitigation of each of these potential fugitive emissions sources can be found below. Car Dumper Building Process Coal is delivered by rail to the Car Dumper Building. The cars are de-coupled and then rotated for the coal to exit through the top of the car into a hopper, located at the bottom of the Car Dumper Building. Fugitive Dust Mitigation Rubber curtains cover the area between the top of the car and the Car Dumper Building entrance and exit to minimize the wind from sweeping through the building. A dust suppression wetting agent is applied (unless there is enough precipitation to effect potential dust dispersion) as the cars are unloaded and again at the beginning of the conveyance system as Page 1 of 6

3 coal leaves the Car Dumper Building. The wetting agent reduces the surface tension of the applied water spray so that water droplets break over the fine dust particles and capture the particles. Assigned plant staff will perform an inspection of fugitive dust mitigation and controls prior to unloading the rail cars, including verification that the suppression system is operating correctly. Coal Conveyance System Process After unloading activities have taken place in the Car Dumper Building, coal is transferred via conveyor to the Crusher House for further transport to either the coal pile or the bunker room inside the power plant. Fugitive Dust Mitigation All conveyors have 3-sided enclosures and are equipped with belt scrapers to minimize fugitive emissions during coal conveyance. The conveyors are inspected for dust buildup on a monthly basis and cleanings are scheduled as needed. As coal is unloaded and placed on the feeder belts (loading point of #1A coal conveyor) a dust control chemical wetting and binding agent is applied which creates a tackiness on the coal surface to minimize dust. This tackifier coats or stabilizes coal to minimize fugitive dust over the periods of pile storage. Also, a telescopic chute is used to minimize the drop height (thus minimizing emissions) onto the coal pile. The drop height is generally 1.0 feet with a maximum drop height of 2 feet. Crusher House Process The Crusher House receives coal from the Car Dumper Building and reclaim from the coal pile. Inside the Crusher House, uncrushed coal can be sent to the coal pile or the Bunker Room or the coal can be crushed before it is sent to the Bunker Room. Fugitive Dust Mitigation All activities at the Crusher House take place in a completely enclosed building. After the crusher (loading point of 4A conveyor) a dust control foaming agent is applied over the top of the coal to cover it and prevent dust from leaving the coal on the belt. Page 2 of 6

4 Coal Pile Process Coal is transferred from the conveyor to the coal pile using a telescopic chute to minimize the drop height (thus minimizing emissions). The drop height is generally 1.0 feet with a maximum drop height of 2 feet. The stored coal has been treated with a type of dust suppressant chemical classified as a tackifier which coats or stabilizers the coal and assists with dust control over the period of pile storage. Bulldozers are used for pile maintenance, compaction for long term storage, and for reclaim activities. Fugitive Dust Mitigation The following actions are specific to operations that occur on the coal pile: 1. Coal piles shall be compacted and maintained after the rail unloading to minimize the fugitive emissions from high wind events. 2. Traffic on the pile shall be minimized to include only pile maintenance and reclaim activities. 3. Traffic speeds on the pile shall be maintained in an appropriate manner to minimize fugitive dust. The pile speed is between 5 and 10 mph, generally more at 5.0 mph. 4. Except in the case of an emergency situation, dozer traffic will cease during periods of wind speed exceeding 25 mph. 5. On an annual basis, coal that has spilled within 100 meters of the pile area shall be removed from the spill area. Reclaim Activities Process Bulldozers are used to load from the coal pile into the Reclaim Hopper. From the Reclaim Hopper, coal is conveyed to the Crusher House. Fugitive Dust Mitigation Traffic on the pile shall be minimized to include only pile maintenance and reclaim activities, and traffic speeds on the pile shall be maintained between 5 and 10 m.p.h. Roads Process The has one plant entrance/exit that is controlled through gated access. The main access road is paved for employee and trucking traffic. Page 3 of 6

5 Fugitive Dust Mitigation The plant entrance and main route for trucking traffic is paved to minimize fugitive emissions. All other plant roadways are infrequently used by plant personnel for routine monitoring (e.g., pneumatic ash lines, ponds, etc). A speed limit sign is posted at the plant entrance with a maximum limit of 15 mph. Finally, the roads are swept and/or watered as needed to reduce the dust loading on the roadways. 2.0 PLANT RESPONSIBILITIES All employees have the responsibility to report abnormal conditions (e.g., visible emissions, equipment malfunctions, etc) to the Station Shift Supervisor or the Operations Supervisor. Coal Handling and Plant personnel are responsible for ensuring proper operation of the coal handling equipment and will perform the following duties to mitigate the impacts of fugitive dust: 1. Coal Handling and Plant personnel shall perform a daily inspection of the coal handling operations to assess the potential for fugitive dust. 2. Coal Handling and Plant personnel shall implement preventative actions as a result of the daily inspections. 3. If these fugitive dust mitigation measures fail and fugitive dust is observed that has the potential to reach the plant boundary, the event shall be recorded in the Fugitive Dust Log (as found in the Appendix). This log will include the date, time, duration, wind speed, description, and corrective action(s) planned and taken. The supervisor will determine the appropriate course of action which may include continuing operation while initiating repair, applying local water sprays, or discontinuing the process. 3.0 FUGITIVE DUST COMPLAINTS It is the responsibility of the BWL Environmental Services Department (or their delegate) to respond to all air quality complaints, concerns, and/or inquiries. Page 4 of 6

6 All air quality complaints, concerns, and/or inquiries, as well as any resultant action, shall be recorded in the Fugitive Dust Log. 4.0 TRAINING training will be provided to the appropriate plant personnel at least once per calendar year and within 30 days of any plan revisions. The attendance list for each training session will be maintained with the Plan for a period of at least 5 years. Page 5 of 6

7 5.0 REVISIONS The will be reviewed on an annual basis and updated as needed. The Plan will also be updated upon changes to the coal handling system. Revisions to the plan shall be documented and maintained for at least 5 years following the date of the revision. Plan Date of Revision Revision Summary Version 1.0 Original Original Version 1.1 September 2009 July 2014 Revision made to comply with MDEQ cited plan deficiencies in agency letter of 8/5/09 addressed to Mr. Nicholas Burwell. Changes address maximum drop height from discharge chute to coal pile, clarification of as needed regarding application of dust suppression chemicals, description of dust suppression chemicals, and clarification of actions to be taken when fugitive dust mitigation measures are determined to be inadequate. Revision to reflect plan to be in accordance with MI-ROP- B , EU 001,Section IX, No. 14 Page 6 of 6

8 Appendix Lansing Board of Water & Light July 2014

9 Fugitive Dust Log Date Time Duration Wind Speed & Direction Weather Conditions Fugitive Dust Event/ Complaint Description Corrective Action Supervisor's Initials Records in the Fugitive Dust Log shall be maintained for a period of at least 5 years.