Steam Electric Effluent Limitations Guidelines (ELG) · Today’s presentation will focus on the following: Complying with ELG 15 Overview of ELG Rule Compliance Strategies Applicability

10/29/2015 © Sargent & Lundy, L.L.C. 2015

Steam Electric Effluent Limitations Guidelines (ELG)

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phones are muted to avoid noise disturbances• Today’s presentation will be available for download on S&L’s

website www.sargentlundy.com• Sargent & Lundy’s detailed summary of the ELG rule is also

available for download on our website

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Sargent & Lundy Webinar


Steam Electric Effluent Limitations Guidelines (ELG)

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PanelistsKen Snell – manager of environmental regulatory and permitting group

Matthew Heermann – wastewater treatment technology specialist

Ed Wolfington – manager of material handling group and technology specialist

Darrel Packard – manager of civil design group and civil engineering specialist

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Sargent & Lundy Webinar

PresenterAndy Carstens – director of environmental services


Today’s presentation will focus on the following:

Agenda

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Overview of ELG Rule

Compliance Strategies

ApplicabilityRegulated StreamsKey Definitions and ProvisionsImplementation

Technologies Minimizing Wet FGD WastewaterProject Requirements (Schedule, Costs)Other Considerations


ELG Rule Overview

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ELG Rule Overview

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§ 423.10 Applicability ( to ) 1982 2015


ELG Rule Overview

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Today’s discussion is limited to standards for:

“Existing” coal-fired plants >50MW

10/29/2015 © Sargent & Lundy, L.L.C. 2015 8

Surface Water or POTW

Cooling Tower Blowdown

Once-Through Cooling Water

Coal Pile Runoff

Ash Pond

Metal Cleaning Wastewaters

Low Volume Wastes (LVW)

CCR Leachate

ELG Rule Overview

Regulated Waste Streams (1982)

Wet FGDBoiler

Air Heater

ESP

Fly Ash Transport Water

Bottom Ash Transport Water

FGD Wastewater

Drains

Boiler Blowdown

Streams w/No ELG Limit


CCR Leachate

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Cooling Tower Blowdown

Once-Through Cooling Water

Coal Pile Runoff

Ash Pond



CCR Leachate

ELG Rule Overview

Regulated Waste Streams (2015)

Wet FGDBoiler

Air Heater

ESP



FGD Wastewater

Drains

Boiler Blowdown


FGD Wastewater

Activated Carbon

Baghouse

Flue Gas Mercury Control


ELG Rule Overview

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Standards for Existing Units >50MW

Stream Existing Unit Standards (>50MW) Technology BasisFly Ash Transport Water Zero-Discharge Dry Ash Handling

FGMC Wastewater Zero-Discharge Dry Ash Handling

Bottom Ash Transport Water Zero-Discharge Dry Ash Handling

or 100% Recycle

FGD Wastewater

As – Daily Max < 11 ug/L, 30-day Avg < 8 ug/L

Hg – Daily Max < 788 ng/L, 30-day Avg < 356 ng/L

Se – Daily Max < 23 ug/L, 30-day Avg < 12 ug/L

N – Daily Max < 17 mg/L, 30-day Avg < 4.4 mg/L

Physical / Chemical and

Biological Treatment

Combustion Residual Leachate Same as current Low-Volume Waste Standards Impoundment


ELG Rule Overview

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Definition of Transport Water

ANDTransport Water

Used to convey fly, bottom, or economizer ash

Contacts fly, bottom, or economizer ash

Cyclone boiler cooling water to slag tanks overflows to separate outfall. Does contact bottom ash, but is not used to convey the ash. This is not transport water because it does not satisfy both criteria.

Example:


ELG Rule Overview

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Anti-Circumvention Provisions



Flue Gas Mercury Control

Wet Wet FGD

FGD Wastewater

Any Plant Process that Discharges

Not Allowed

Allowed


ELG Rule Overview

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Anti-Circumvention Provisions

Low Volume Waste

Wet Wet FGD

FGD Wastewater

< 4 ug/L

< 178 ng/L

< 6 ug/L

< 2.2 mg/L

< 8 ug/L

< 356 ng/L

< 12 ug/L

< 4.4 mg/L

< DL

< 89 ng/L

< 3 ug/L

< 1.1 mg/L

As

Hg

Se

N

No Dilution

Diluted Stream

Any 1 below DL

*DL – Detectable Limit

AllowedNot

Allowed


ELG Rule Overview

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Implementation through NPDES Permits

• ASAP considers time, other plant changes, optimization (FGD only)• ASAP date can be different for different streams• If FGD wastewater evaporated, ASAP date is not applicable


Today’s presentation will focus on the following:

Complying with ELG

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Overview of ELG Rule

Compliance Strategies

ApplicabilityRegulated StreamsKey Definitions and ProvisionsImplementation

Technologies Minimizing Wet FGD WastewaterProject Requirements (Schedule, Costs)Other Considerations


Complying with ELG

Planning for Compliance



Ash Pond

Complying with ELG

Biggest Impacts to Coal-Fired Units

Wet FGDBoiler

Air Heater

ESP



FGD Wastewater


Complying with ELG

Technologies – General Format for Following Slides

Other Information• Other Relevant Information

Simplified Process Flow Diagrams

Example schedules from recent projects (note: schedules vary for each project, schedules

shown represent a single example)

Example cost estimates from recent projects (note: costs vary for each project, costs shown

represent a single example)


Complying with ELG

Bottom Ash – Dry Belt Conveyor

Example cost for single 400 MW

Total Installed Cost ~$18 Million

Other Information• Need sufficient room under boiler• Longer outage required for installation• Cooling air recovers some heat back to the

boiler


Complying with ELG

Bottom Ash – Submerged Scraper Conveyor

Example cost for single 450 MW unit

Total Installed Cost ~$13 Million

Other Information• Need sufficient room under boiler• Longer outage required for installation


Complying with ELG

Bottom Ash – Remote Submerged Scraper Conveyor


Total Installed Cost ~$18 million

Other Information• Flexibility with location• Minimal outage time required• Larger, higher capital than under-boiler SSC


Complying with ELG

Bottom Ash – Self-supporting Concrete Basins

Other Information• Minimal outage time required• Larger footprint required




Complying with ELG

Strategies to Minimize FGD Wastewater

• Dry Sorbent Injection

• Alternate FGD Liners

• Produce less wall-board grade byproduct

• Burn lower chloride fuels

• Reverse Osmosis


Complying with ELG

FGD Wastewater – Physical / Chemical Treatment

Other Information• Established technology• Can meet Hg and As limits• Must be used with biological for Se and N

limits

Example cost for two 550 MW units



Complying with ELG

FGD Wastewater – Biological Treatment

Other Information• Only a few in operation• Few suppliers available

Example cost for two 550 MW units



Complying with ELG

FGD Wastewater – Brine Concentration / Evaporation

Other Information• High capital - materials• High O&M• Demonstrated on Wet FGD wastewater in a

few applications




Complying with ELG

FGD Wastewater – Waste Fixation and Stabilization

Example Cost for Two 450 MW Units


Other Information• May still achieve “zero discharge”• Requires testing to determine “recipe” for

chemically fixated and structurally stable product


Complying with ELG

Developing Technologies

Spray Dryer Evaporation

Forward Osmosis

Zero Valent Iron



Ash Pond



Complying with ELG

Impacts of Coal Combustion Residual (CCR) Rule

Drains

Boiler Blowdown


CCR ponds can be used as long as they cease receiving transport water by the compliance date

“Legacy wastewater” can be discharged, but CCR material within causes CCR rule to be applicable

If pond closure required due to CCR, streams routed to ponds must be recycled, re-routed, and / or treated


Complying with ELG

Compliance Planning


Complying with ELG

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Compliance Planning

Technology Implementation ~18 to 24 months

Begin compliance planning now


Additional Questions ?

Selected Sargent & Lundy Services to Support Compliance Planning through ImplementationWater Balance Preparation

Wastewater Flow and Characterization Compliance Planning and Economic Modeling

Equipment Design Basis, Specification Preparation, and Procurement Support Detailed Design for Balance‐of‐Plant Integration

Project Management and Oversight Permit Application Preparation and Support (NPDES, Section 401/404, State Permits, etc.)

CCR Fugitive Dust Plan Preparation Impoundment Safety Hazard Analyses

Groundwater Monitoring Plans and Well Installation Support CCR Impoundment Location Assessments

CCR Impoundment Safety and Hazard Potential Assessments CCR Impoundment Inspection Plans CCR Closure and Post‐Closure Plans


Thanks for AttendingIf you have any further questions about this topic or other environmental support, please contact:

Andy Carstens – Director of Environmental Services

Ken Snell – Manager of Permitting and Licensing

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(312) [email protected]

(312) [email protected]


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Steam Electric Effluent Limitations Guidelines (ELG) · Today’s presentation will focus on the following: Complying with ELG 15 Overview of ELG Rule Compliance Strategies Applicability