UKTWG 19

May 2012

BEST AVAILABLE TECHNIQUES FOR EXISTING LOW VOLATILE COAL SUMMARY

1. UK plants

Generator A power station was originally designed and built in the 1970s to burn indigenous low volatile local coals. These coals have typically less than 10% volatile matter (VM) (as received) causing flame stability to be difficult to achieve. In order to burn these coals, downshot-fired boilers were installed to stabilise combustion. Although the downshot-fired design allows these difficult coals to be burned in stable conditions, a consequence of employing this design is that there are higher peak temperatures and longer retention times in the boiler, leading to higher NOx emissions than conventional plant. 2. BAT for plant operating at present

A review was carried out in 2006 which looked at a wide range of alternative abatement techniques to achieve the limits set by the Large Combustion Plant Directive. Thermal Input Biasing (TIB) and Combustion Controls (CC) were determined to be BAT. Since the 2006 review, further work has been carried out installing Dynamic Classifiers to optimise the plant and to help to improve confidence in achieving these limits on the basis of the available coal diet. 3. Conclusions of the 2011 BREF Review

Significant work has already been done to reduce emissions from a high baseline and understand what further techniques would be applicable at Generator A. BAT: 2006 BAT review concluded Thermal input Biasing and Combustion Controls to be BAT and these would deliver a BAT AEL of around 3.6 t/GWh, equivalent to 1050 mg/m3 (36.5% thermal efficiency) and a monthly BAT AEL of 1200 mg/m3, which has been achieved on the basis of the load factor and the available coal diet mix (generally higher calorific value coals). Following on from the 2006 BAT review, a programme of trialling dynamic classifiers has been carried out and although there have been some difficulties with implementing this technique, the station has installed them on 2 units and will complete installation and commissioning of this equipment on the final unit by Q1/2013. A review carried out in 2012 has agreed that BAT is to implement thermal input biasing, combustion controls and dynamic classifiers. Current annual average performance (2009 - 2011) is approximately 3.2 to 3.4 tNOx/GWh (valid, as measured) (38% thermal efficiency). This is equivalent to 960 1020 mg/m3. In future years, it is anticipated that there will be greater reliance on indigenous coals and significant variability resulting from the quality of fuel received and the operating regime. Under these circumstances, modelling of the system predicts that there will be higher NOx emissions possibly up to 3.7 tNOx/GWh. Nevertheless, a more stringent BAT AEL range of 3.3 to 3.5 tNOx/GWh has been agreed, with the range driven by the variability in fuel quality and plant operation. This is equivalent to a continuous emission rate of 980 to Page 1 of 9

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This more stringent limit is likely to constrain the fuel diet and 1050 mgNOx/Nm3. operating regime of the plant. Future compliance with the IED: For downshot boilers, the NOx ELV of 200 mg/Nm3 required for baseload plant under the IED, is challenging and SCR will need to be fitted. Further work is required to refine the preliminary cost estimates and to understand whether investment of that scale is economically viable.

Page 2 of 9

UKTWG 19

May 2012

BEST AVAILABLE TECHNIQUES FOR EXISTING LOW VOLATILE COAL

1. UK plants

Generator A power station was originally designed and built in the 1970s to burn indigenous low volatile local coals. In order to burn these coals, the downshot-fired boilers were installed to optimise combustion. These coals have typically less than 10% volatile matter (VM) (as received), making it difficult to achieve flame stability. The downshot fired method was installed because this allows re-entrainment of hot gas from the tail of the flame to stabilise the root of the flame. The poor reactivity of carbon requires significantly longer burning times than necessary for the medium-high VM coals (VM typically 22-35%) that are used in most power plants in the UK. The downshot firing arrangement facilitates longer burnout time by producing J-shaped flames where coal particles experience up to double the furnace residence times of other boiler types. The consequence of downshot firing is therefore high peak temperatures for a greater duration of time compared with a conventional boiler. Conventional plant emissions are dominated by fuel NOx, whereas in downshot-fired plant, the influence of thermal NOx is a highly significant factor, and has an exponential reaction rate against process temperatures. The combination of fuel type and long combustion residence time results in high NOx emissions from this type of plant, especially thermal NOx, and would result in NOx emissions of up to 2000 mg/Nm3 if no abatement were employed. 2. BAT for plant operating at present

2.1 Techniques considered and applied A range of techniques were considered in 2006 to achieve the 1200mg/Nm3 emission limit that was imposed by the Large Combustion Plant Directive. These techniques included the following;2.1.1 Combustion System Replacement / Further Modifications

2.1.1.1 Low NOx Burners Low NOx burners achieve a reduction in NOx in one of two ways: primarily by delaying air mixing in the region where volatiles are released in order to destroy fuel derived NOx from this volatile matter (VM) secondary and lesser effect is reducing peak flame temperatures to reduce thermal NOx

Many of the coals taken by Generator A contain less than 10% VM. These coals are not easily ignited as a flame; they release relatively little nitrogen as volatiles and thus only small NOx reductions can be achieved using low NOx burners. 2.1.1.2 Overfire Air Retrofitted overfire air, installed with low NOx burners is defined as BAT for boilers burning medium/high volatile coal. The technique involves reducing the air fed to the existing burners and then injecting this air through additional air injection ports. The technology has been applied widely with success for NOx reduction in conventional boilers, but with some adverse impacts for issues such as carbon-burn-out, CO emissions and boiler corrosion issues. There is proprietary technology which has been developed for downshot-fired boilers where overfire-air is matched to improved stability (pre-heat) burners. These burners have no additional staging and therefore are not low NOx burners. Instead the nozzles are designed to aid preheating and stability of the flames. The burners and overfire air have been retrofitted to some 50MW boilers in the USA, and two boilers on a Spanish power station. These stations use high ash, low grade, local low volatile coals. The use of overfire in this firing system is the major factor Page 3 of 9

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in reducing NOx as it reduces the peak temperatures in the boiler by delaying combustion. However, this reduces the time available for combustion of relatively unreactive coal and therefore the NOx reduction is at the expense of a doubling of carbon in ash losses. To offset this increase, the manufacturers recommend the use of adjustable static mill classifiers or dynamic classifiers to improve mill product fineness and burn-out. This form of overfire air is unproven for Generator A and evaluation suggests there would be significant problems from: i) Excessive carbon in ash increase (levels are already at up to 30% but average around 15%). When carbon in ash increases above 20%, tests have shown that dust emissions rise and this is an undesirable effect upstream of the stations seawater process FGD system. Heat transfer issues already constrain combustion for Generator A due to the combustion system and heat transfer surface arrangement. Tests have suggested a significant increase in tube failures would be likely. Generator A has a history of poor flame stability, largely due to coal quality issues. There have been many flame out events, some at full load and two major boiler explosions have occurred, the last in 1995. Reduced stoichiometry at the burners will increase the risk of flame outs.

ii)

iii)

Other issues would be similar to those experienced by other generators, e.g. increased fireside corrosion. 2.1.2 Thermal Input Biasing (TIB) This technique involves optimising the heat distribution in the furnace by controlling the burner firing pattern. The technique has been demonstrated and is capable of reducing NOx emissions by around 20% giving an emission concentration of under 1200 mg/Nm3. Operating issues include increased carbon in ash; risk of increased dust emissions; some coal restriction and the risk of furnace wall tube failures. Air is admitted to some out of service burners (similar to overfire air) and the downshot fired arrangement facilitates mixing of this air with the combustion gases to help to achieve carbon burn out. 2.1.3 Thermal Input Biasing Low Excess Air This technique is the same as thermal input biasing but with reduced air supply to the burners. The technique has been tested for short periods and emissions achieved have been similar to those expected for overfire air, i.e. under 1000 mg/Nm3. However, issues associated with overfire have been experienced, i.e. higher carbon in ash; increased dust emissions; furnace wall tube failures etc. 2.1.4 Thermal Input Biasing and Combustion Control The operation of thermal input biasing has been improved by use of a NOx advisor system. This system provides operator guidance to achieve the lowest NOx set-up (Generator A can start and stop individual burners), this facilitates optimisation of NOx but can be constrained by fuel type and drum level issues. The use of this combustion control system has been shown to help to consistently achieve the lower NOx from TIB. 2.1.5 Thermal Input Biasing and Dynamic Classifiers The operation of thermal input biasing can be improved by the use of dynamic classifiers. These achieve better control of the Pulverised Fuel (PF) size distribution between burners allowing fewer burners in-service for a given load under certain fuel conditions. Emissions of NOx are expected to reduce by about 5% compared to TIB but with greatly improved carbon burnout and lower dust emissions. Page 4 of 9

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These improvements can give combined benefits of reduced carbon in ash losses, lower dust emissions and reduced NOx emissions. However, the interaction between these parameters is complex and there is an increased risk of periods of increased carbon in ash, high dust emissions, or increased slagging in the boiler. There is no previous experience of fitting dynamic classifiers on tube ball mills, and this presented significant challenges to the power station. The ability to run dynamic classifiers is compromised by wet, low calorific value fuels that require the majority of burners to be in-service, taking away some ability for thermal input biasing and thus increasing NOx emissions. Undertaking thermal input biasing too aggressively also brings about safety and integrity concerns to the boiler, imbalancing the drum level and resulting in localised high component temperatures potentially leading to operating above safe operating limits. As a result of the uncertainties, surrounding the effects of installing dynamic classifiers on tube ball mills and this design of boiler, a programme to trial the installation of dynamic classifiers was initiated after the 2006 BAT evaluation. Although there were initially operational difficulties with integrating the classifiers, many of these issues have been or are in the process of being resolved. As a result, a programme to install dynamic classifiers on one full unit was carried out in 2009 which allowed a better understanding of the challenges of operating DCs on all mills and further work has been undertaken to optimise their operation. The power station has installed a second set of dynamic classifiers in 2011 and is planning to complete installation and commissioning of dynamic classifiers by Q1/2013. 2.1.6 Advance Automated Control Techniques for NOx Reduction Advanced combustion control systems were tested in the USA for NOx control in coal-fired plant. These systems have also been tested in the UK. These tests were not successful due to a combination of changing plant conditions, coal diet and fundamental issues with applying the system. These systems have been evaluated for Generator A but the complex control of burners installed, the limited ability for mill biasing and the variation in fuel characteristics would not permit the control and robust model building needed for NOx reduction. Instead, a more robust advisor system has been employed to optimise combustion. 2.1.7 Coal Selection Many coals taken by Generator A are blends of coals from different mines. The major issue relevant to NOx for the coal diet at Generator A is to burn coals that allow full load with fewer than the maximum number of burners. This allows burner distribution to be optimised to help manage NOx. The number of burners increases with mill throughput and therefore mill throughput and number of burners are directly related. Coals that are burned neat at the station are purchased to a minimum net calorific value (NCV) and in recent years, this minimum has generally been exceeded allowing better NOx performance, though this cannot be guaranteed in the future. Dynamic classifiers increase coal flexibility and therefore allow some further optimisation of TIB but feed rate and flexibility when the DCs are processing wet coals inhibit this flexibility and the optimisation of TIB. 2.1.8 Load Reduction For many boilers where total air flow control is linked to load, the NOx concentration is found to decrease with load. For the Generator A design of boiler, the opposite is true, where NOx is found to increase with load, a consequence of the high thermal NOx production for such boilers. Page 5 of 9

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In future years, it is expected that the boilers will operate more during the winter and at a higher percentage of full load output. Combustion controls have been optimised for these high operating loads with regard to controlling NOx emissions.

NOx Emissions (t/GWh)

3.6 3.5 3.4 3.3 3.2 3.1 0.75 0.8 0.85 0.9 0.95 Fraction of Full Load Output 1

For Generator A, TIB operation and combustion control reduce the peak temperatures in the boiler, this is optimised for the highest loads, and is therefore most effective at the highest load. At lower than full load output, these high peak temperatures are not experienced to the same extent, though TIB is still applied to spread the heat distribution more evenly. The original design of the combustion system is based on optimal air flows and combustion at full output, optimisation of TIB at full load and the reduction in efficiency from operating at part loads make load reduction an inefficient abatement technique. 2.1.9 Selective Non-Catalytic Reduction (SNCR) SNCR involves injecting ammonia or urea into the convective passes of the boiler. The ammonia reacts with NO in the flue gas reducing it to nitrogen. It is expected that the reduction in NOx emissions would be up to 1020% for a multi-burner downshot boiler. There are a number of technical issues with the retrofitting of SNCR at Generator A: Multiple injection points required to cover all operating conditions giving high cost and complexity in the control; Complex water/steam cooled injection system; High reagent consumption due to the relatively poor efficiency of utilisation; Excessive contamination of ash with ammonia and therefore this may significantly reduce recycling of the fly ash as a by-product; Fouling issues causing loss of availability and reduction in generating efficiency;

The boiler heat balance, unique to downshot furnaces leads to a very short residence time in the appropriate temperature window for SNCR. This will limit the achievable performance compared with conventional boilers. Consequently SNCR is considered operationally impractical and commercially unavailable.

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2.1.10 Selective Catalytic Reduction SCR involves injecting ammonia into the flue gas and passing it through a catalyst layers. Despite the relatively high inlet concentration of NOx from Generator A, it should be possible to achieve concentrations of 200 mg/Nm3 for typical coals. There are some issues in its installation: Risk of reagent slippage and plugging of down stream surfaces e.g. airheaters; Risk of catalyst poisoning; The costs of fitting an SCR system that would reduce NOx emissions from 1200 to 200 mg/Nm are significantly higher than the costs for conventional coal plant.

SCR is significantly higher cost per tonne of NOx removed that for other technologies. 2.2 Summary of Candidate Options considered in detail in the 2006 assessment The options considered in the 2006 assessment are summarised in Table 1 under various operational and environmental criteria. Some of the techniques listed above can be used in combination with others, so Table 1 includes additional options which are combinations of the basic techniques. Criteria where there are no particular problems are indicated by ; those where there are significant or insoluble problems are indicated by ; those where problems are envisaged but they maybe be overcome are indicated by /. Table 1: Summary of Candidate Options for NOx Reduction
Technology 1200 mg/m NOx Compliance Base case LNB TIB TIB + CC TIB + DC TIB +low excess air TIB+ DC +low excess air OFA +DC Reburn SNCR SCR Coal Selection Derate
1 2 3 4
note 2 3

Safety

Dust Emissions 50 mg/m3 note 1 <

Plant Availability

Overall Rating

/ / /

/

/ /
note 3

/ / note 4

Emissions have now reduced further following the installation of FGD More ammonia would be required than SCR Not Available if TIB used. Incurs excessive cost.

On the basis of this evaluation, the following options were considered in more detail; Page 7 of 9

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1. 2. 3.

Selective Catalytic Reduction Thermal Input Biassing and Combustion Control Thermal Input Biassing

The costs of these techniques were calculated to be; Discounted Costs of NOx Reduction Options (10 Year Lifetime) TIB Present Value Cost M Equivalent Annual Cost M/y 8.16 1.33 TIB+CC 7.98 1.3 SCR 98-123 16-20

On this basis, Thermal Input Biasing and Combustion Controls were determined to be BAT. In 2008 after installation of these techniques, Generator A achieved an annual average NOx under 1000 mg/Nm3. This was in line with expectations for TIB and CC, with the coals used, for the average loads in 2008 and emissions at peak load were generally under 1200 mg/Nm3. Other techniques that have been introduced since the 2006 assessment include a combination of plant improvements and operational changes (operators assisted by training and NOx advisor). To address the lack of information surrounding the capabilities of Dynamic Classifiers with ball mills and this design of boiler in the 2006 assessment, a programme of trialling DCs was initiated. Tests were carried out on the reliability and availability of DCs over a range of coal diets. There were initially significant engineering challenges, which resulted in poor PF distribution, localised slagging which caused blocked burner legs, lower boiler flow velocities, higher flame position, increased boiler temperatures and subsequent tube failures. The findings from the trial identified engineering modifications to mitigate these defects and the station is now moving ahead to install dynamic classifiers on all boilers and striving to resolve the remaining operational challenges that they present. 3. Conclusions of the 2011 BREF Review

Significant work has already done to reduce emissions from a high baseline and understand what further techniques would be applicable at Generator A. From a high initial NOx baseline, Generator A has operated below 1200mg/Nm3 since the 2006 BAT review and with the installation of Dynamic Classifiers, has shown the capability of consistently achieving below this. Even with these techniques installed, the high baseline NOx for this design of boiler, the variation in coal diet, the limitations of dynamic classifiers when processing wet coal and the safety restrictions to flexing burner feed rates mean that these limits will be challenging under certain operational conditions. BAT: 2006 BAT review concluded Thermal input Biasing and Combustion Controls to be BAT and these would deliver a BAT AEL of around 3.6 t/GWh, equivalent to 1050 mg/m3 (36.5% thermal efficiency) and a monthly BAT AEL of 1200 mg/m3, which has been achieved on the basis of the load factor and the available coal diet mix (generally higher calorific value coals). Following on from the 2006 BAT review, a programme of trialling dynamic classifiers has been carried out and although there have been some difficulties with implementing this technique, the station has installed them on 2 units and will complete installation and commissioning of this equipment on the final unit by Q1/2013. Page 8 of 9

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A review carried out in 2012 has agreed that BAT is to implement thermal input biasing, combustion controls and dynamic classifiers. Current annual average performance (2009 - 2011) is approximately 3.2 to 3.4 tNOx/GWh (valid, as measured) (38% thermal efficiency). This is equivalent to 960 1020 mg/m3. In future years, it is anticipated that there will be greater reliance on indigenous coals and significant variability resulting from the quality of fuel received and the operating regime. Under these circumstances, modelling of the system predicts that there will be higher NOx emissions possibly up to 3.7 tNOx/GWh. Nevertheless, a more stringent BAT AEL range of 3.3 to 3.5 tNOx/GWh has been agreed, with the range driven by the variability in fuel quality and plant operation. This is equivalent to a continuous emission rate of 980 to 1050 mgNOx/Nm3. This more stringent limit is likely to constrain the fuel diet and operating regime of the plant.

Future compliance with the IED: For downshot boilers, the NOx ELV of 200 mg/Nm3 required for baseload plant under the IED, is challenging and SCR will need to be fitted. Further work is required to refine the preliminary cost estimates and to understand whether investment of that scale is economically viable.

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