Guidance on Air Emissions and Monitoring Requirements during Combustion of Non-Gaseous Fuels

Transcription

1 Guidance on Air Emissions and Monitoring Requirements during Combustion of Non-Gaseous Fuels

2 Additional copies of this document may be obtained by contacting: Alberta Environment Information Centre Main Floor, Oxbridge Place Street Edmonton, Alberta Canada T5K 2J6 Phone: (780) (toll free, dial ) Fax: (780) Website: ISBN: (Printed) ISBN: (On-line) Date of Publication: July 2011 Cover photos courtesy of office.microsoft.com. Copyright in this publication, regardless of format, belongs to Her Majesty the Queen in right of the Province of Alberta. Reproduction of this publication, in whole or in part, regardless of purpose, requires the prior written permission of Alberta Environment. Her Majesty the Queen in right of the Province of Alberta, 2011

3 Table of Contents Table of Contents... 3 List of Tables Overview Application Design and Operational Guidance Monitoring Requirements... 6 List of Tables Table 1: Emission Guidelines for the Use of Non-gaseous Fossil Fuels... 5 Table 2: Analysis of Non-gaseous Fuels... 6 Table 3: Source Monitoring Requirements for the Use of Non-gaseous Fuels Guidance on Air Emissions and Monitoring Requirements during Combustion of Non-Gaseous Fuels

4 1.0 Overview The purpose of this document is to guide project proponents and regulators on air emissions and monitoring expectations where non-gaseous fuels are the proposed fuel source for specified types of equipment. This guidance is based on technical studies conducted for Alberta Environment on the use of non-gaseous fuels in the oil sands for steam production. Emission ranges are based on an assessment of available control technologies. 2.0 Application For Project Proponents Proponents of projects shall consider this guidance for equipment and fuels as outlined in the scope section of this document. Proponents are expected to design; select equipment; and operate and monitor the emissions from equipment in a manner that will meet these guidelines, or provide rationale as to why these requirements should not be met. For Regulators Approval Engineers will consider this guidance along with other existing regulations, standards, and policies to set approval limits and monitoring requirements for equipment and fuels that fall within those specified in the scope section of this document. Professional judgment on necessary requirements for specific applications will also apply. General Environmental evaluation of processing equipment and projects remains subject to all existing regulatory policies, including but not limited to the Industrial Release Limits Policy. Due to complexities involved in the design and operation of facilities and site specific considerations such as ambient air quality pressures in some areas or regional plan requirements, it is recognized that there may be instances when more stringent pollution controls than those required to achieve the emission ranges in this guidance document are required. Alternatively, there may be equipment complexity that prevents the guidelines from being achievable. These conditions will be considered on a case-by-case basis. Scope of Application This guidance applies when the non-gaseous fossil fuels and equipment outlined below are to be used in a processing facility. For equipment that does not fall into these categories, the user of the document should seek advice from Alberta Environment Approvals or Air Policy staff. Applicable Fuel Types Petroleum coke (pet coke) Coke (produced as a byproduct of conventional oil or bitumen upgrading) Asphaltenes Bitumen Applicable Equipment (may also be subject to other regulations depending on sulphur recovery requirements) Boilers / steam generators Cogeneration Guidance on Air Emissions and Monitoring Requirements during Combustion of Non-Gaseous Fuels 4

5 This list is not considered exhaustive, but to provide an overview of equipment types that shall consider emission controls to meet the emission guidelines. 3.0 Design and Operational Guidance Table 1: Emission Guidelines for the Use of Non-gaseous Fossil Fuels Substance Emission Guideline (g/gj input) Sulphur Dioxide (SO 2 ) 70 to 116 Oxides of Nitrogen (Total NO x ) 40 to 50 Fine Particulate Matter (PM 2.5 ) 9 to 11 Carbon Dioxide (CO 2 ) Carbon Capture Ready* Note: The above guidelines are subject to the following energy efficiency requirements (efficiencies based on LHV): 1. If design steam generator efficiency is <80% then guidelines are to be adjusted as follows; (Emission guideline * design efficiency) / 80% 2. If design steam generator efficiency is >90% then guidelines are to be adjusted as follows; (Emission guideline * design efficiency) / 90% *Carbon Capture Ready Until a CO 2 capture ready policy is established by AENV, the following interim definition of CO 2 capture ready adapted from the International Energy Agency (2007) and ICF International (2010) shall apply: A CO 2 capture ready facility is a facility which can include CO 2 capture when the necessary regulatory or economic drivers are in place. The aim of building facilities that are capture ready is to reduce the risk of stranded assets or carbon lock-in. Developers of capture ready plants should take responsibility for ensuring that all known factors in their control that would prevent installation and operation of CO 2 capture have been identified and eliminated. This should include: 1. A study of options for CO 2 capture retrofit and potential pre-investments demonstrating that the facility is technically capable of being retrofitted for CO 2 capture using one or more reasonable choices of technology. This study shall include an evaluation of the economic and other barriers to capture, a timeline for implementation of capture, and identification of sources for expertise, equipment, materials, and services for plant retrofit and capture operations; 2. Adequate space allowance to be maintained for the future addition of CO 2 capture-related equipment, retrofit construction, and delivery to a CO 2 pipeline or other transportation system; 3. Site selection such that transport and storage of captured volumes are technically feasible: a. Identification of reasonable route(s) to storage of CO 2, and b. Identification of reasonable storage reservoir options including evaluation of the capacity and injection rates relative to the expected CO 2 lifecycle emissions from the project. 4. Identification of required environmental, safety, and other approvals required for the capture, transport and storage; 5. Public awareness and engagement activities related to potential future capture facilities have been performed; 6. Capture Readiness is maintained or improved over time as documented in reports and records to be provided to Alberta Environment and other relevant authorities and updated to maintain accuracy until the implementation of capture, at a minimum of every 5 years. The emission guidelines in Table 1 are based on a review of existing standards and controls, as well as performance test results from pilot and/or prototype operations. Data was limited for bitumen, petroleum coke and asphaltene fuels and the emission guidelines for these units are extrapolated from standards and controls from other non-gaseous fuels. Once sufficient performance data is available from operating units burning these fuels and employing best control technologies, the guidelines will be reviewed and may be adjusted accordingly. The emission guidelines may be transformed into emission standards at that time. Guidelines for heavy metals may be added in the future. 5 Guidance on Air Emissions and Monitoring Requirements during Combustion of Non-Gaseous Fuels

6 4.0 Monitoring Requirements An analysis of the non-gaseous fossil fuel is required as outlined in Table 2. Table 2: Analysis of Non-gaseous Fuels Fuel Parameters Frequency Non-gaseous Fuel Sulphur content; Nitrogen content; Heavy Metals; Including Mercury, Vanadium, Selenium, Nickel and Lead. Lower Heating Value and Higher heating value. Once, prior to use; and Monthly, if composition changes significantly, or Semi-annually, if composition is constant. The emission performance of steam generators shall be verified by the monitoring requirements specified in Table 3. Table 3: Source Monitoring Requirements for the Use of Non-gaseous Fuels Steam Generator Capacity (GJ/hr) < > 264 Parameter NO X, SO 2, SO 3, PM, PM 10, PM 2.5, VOCs, CO 2, PAH, Heavy Metals NO X, SO 2, SO 3, PM, PM 10, PM 2.5, VOCs, CO 2, PAH, Heavy Metals NO X, SO 2, PM, PM 10, PM 2.5, CO 2, Heavy Metals NO X, SO 2, SO 3, PM, PM 10, PM 2.5, VOCs, PAH, CO 2, Heavy Metals NO X, SO 2, CO 2, PM, PM 10, PM 2.5, Heavy Metals NO X, SO 2, CO 2 Source Monitoring Requirement Initial stack survey to be conducted at the time the boiler or heater is commissioned. Initial stack survey to be conducted at the time the boiler or heater is commissioned. Semi-annual stack surveys unless fuel composition changes significantly, in which case monthly stack surveys will be done until stack survey data is constant for 3 months. Initial stack survey to be conducted at the time the boiler or heater is commissioned. Semi-annual stack surveys. Continuous emissions monitoring system. Guidance on Air Emissions and Monitoring Requirements during Combustion of Non-Gaseous Fuels 6

7 7 Guidance on Air Emissions and Monitoring Requirements during Combustion of Non-Gaseous Fuels