Control Technology Review 59a389541723dd667e274fb1

Prevention of Significant Deterioration
Air Pollution Control Construction Permit Application
Appendix A.
Control Technology Review for the

Biomass-Fired Boiler B01.
50 MW Biomass Fuels-Fired Cogeneration Facility to be

Located at the Domtar – Rothschild Mill.
March, 2010
Prepared for:
We Energies
231 W. Michigan St.
Milwaukee, WI 53203
Prepared By:
RTP ENVIRONMENTAL ASSOCIATES INC.®

903 Superior Avenue, Suite 6
Tomah, WI 54660
Executive Summary
This document is a Control Technology Review for the proposed new biomass fuels-fired boiler at We
Energies’ 50 MW Biomass Fuels Cogeneration Facility to be located at the Domtar – Rothschild Mill.
This control technology review is required for major new sources under the Prevention of Significant
Deterioration (PSD) program under NR 405.08, Wis. Adm. Code. The proposed boiler will be a
circulating fluidized bed (CFB) boiler with a maximum design heat input capacity of 800 million Btu per
hour. The primary boiler fuels will be wood, bark, wood waste, forest residues, and wastewater treatment
plant sludge from the Domtar Paper Mill. The boiler will also be designed to fire natural gas for a startup
fuel and for load stabilization and supplemental firing, with a maximum natural gas firing rate of less than
250 mmBtu per hour.
Based on this control technology review, We Energies is proposing to utilize an advanced circulating
fluidized bed boiler designed to fire natural gas and biomass fuels, selective non-catalytic reduction, and a
fabric filter baghouse. The following table summarizes the proposed control technologies and emission
limits which represent the best available control technology (BACT) for this new biomass fuels-fired
boiler.
Proposed control technologies and emission limits representing BACT for the biomass-fired boiler.
PROPOSED POTENTIAL
POLLUTANT PROPOSED CONTROL TECHNOLOGY LIMIT, TO EMIT,
lb/mmBtu ton/year
Carbon Monoxide Advanced Circulating Fluidized Bed Boiler and
0.20 701
(CO) Good Combustion Practices
Nitrogen Oxides Circulating Fluidized Bed Boiler and
0.10 350
(NOx) Selective Non-Catalytic Reduction
Particulate Matter
Fabric Filter Baghouse 0.03 105
(PM/PM10)
PM < 2.5 microns Fabric Filter Baghouse with
0.023 81
(PM2.5) Felted Filter Media Bags
Sulfur Dioxide Circulating Fluidized Bed Boiler and Low Sulfur
0.09 315
(SO2) Fuels including Biomass Fuels and Natural Gas
Organic Circulating Fluidized Bed Boiler and
0.017 60
Compounds (VOC) Good Combustion Practices
Fluorides Circulating Fluidized Bed Boiler and Low Fluoride
n/a 3.5
(as HF) Fuels including Biomass Fuels and Natural Gas
We Energies - Air Pollution Control Construction Permit Application for a

50 MW Biomass Fuels-Fired Cogeneration Facility RTP Environmental Associates, Inc.
Appendix A: Control Technology Review for the Biomass-Fired Boiler. March, 2010
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Table of Contents
Chapter 1. Introduction and Source Description. ...............................................8
1.1 Fluidized Bed Boiler Technology.................................................................................................... 9
1.2 CFB Boiler Fuels. ............................................................................................................................ 9
1.3 CFB Boiler Design......................................................................................................................... 10
1.4 Potential Air Emissions.................................................................................................................. 10
Chapter 2. Control Technology Review Methodology......................................12

2.1 Best Available Control Technology Definition. ............................................................................ 12
2.2 Top Down BACT Methodology. ................................................................................................... 13
2.3 New Versus Modified Facilities. ................................................................................................... 13
2.4 Technical Feasibility...................................................................................................................... 14
2.5 Economic Feasibility. .................................................................................................................... 15
2.5.1 Average Cost Effectiveness. ............................................................................................. 15
2.5.2 Incremental Cost Effectiveness......................................................................................... 16
2.5.3 Agency Decisions on Cost Effectiveness. ........................................................................ 16
Chapter 3. Carbon Monoxide (CO) Control Technology Review. ..................21

3.1 BACT Baseline. ............................................................................................................................. 21
3.2 STEP 1. Identify All Available Control Technologies. ................................................................ 21
3.3 STEP 2. Identify Technically Feasible Control Technologies...................................................... 21
3.3.1 Oxidation Catalysts........................................................................................................... 22
3.3.2 Thermal Oxidation............................................................................................................ 23
3.3.3 Good Combustion Practices.............................................................................................. 23
3.4 STEP 3. Rank the Technically Feasible Control Technologies. ................................................... 25
3.5 STEP 4. Evaluate the Most Effective Controls............................................................................. 25
3.6 STEP 5. Proposed Carbon Monoxide BACT Determination........................................................ 25
Chapter 4. Nitrogen Oxides (NOx) Control Technology Review. ....................26

4.1 BACT Baseline. ............................................................................................................................. 26
4.2 STEP 1. Identify All Potential Control Strategies. ....................................................................... 26
4.3.1 Fluidized Bed Boilers. ...................................................................................................... 28
4.3.2 Low NOX Burners and Overfire Air. ................................................................................ 28
4.3.3 Overfire Air (Staged Combustion).................................................................................... 29
4.3.4 Flue Gas Recirculation...................................................................................................... 29
4.3.5 Oxygen-Enhanced Combustion. ....................................................................................... 29

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4.3.6 Natural Gas or Coal Reburning......................................................................................... 30
4.3.7 Selective Catalytic Reduction. .......................................................................................... 30
4.3.8 High Dust SCR. ................................................................................................................ 31
4.3.9 Tail Gas SCR. ................................................................................................................... 33
4.3.10 Selective Non-Catalytic Reduction................................................................................... 34
4.3.11 Catalytic Absorption/Oxidation (SCONOx™) ................................................................. 35
4.3.12 Emerging Control Technologies. ...................................................................................... 35
4.3.13 Summary of the Technically Feasible Controls................................................................ 36
4.5.1 Rank No. 1: Selective Catalytic Reduction...................................................................... 38
4.5.2 Rank No. 2: Selective Non-Catalytic Reduction. ............................................................ 41
4.6 STEP 5. Proposed Nitrogen Oxide BACT Determination............................................................ 42
Chapter 5. Particulate Matter and PM10 Control Technology Review...........43

5.1 Reference Method 202 and Artifact Formation. ............................................................................ 43
5.2 Other Test Method 28. ................................................................................................................... 45
5.3 Particulate Matter and PM10 ........................................................................................................... 45
5.4 Basis for Evaluating PM Limits..................................................................................................... 46
5.5 BACT Baseline. ............................................................................................................................. 46
5.6 STEP 1. Identify Potential Control Technologies......................................................................... 46
5.7.1 Fabric Filter Baghouses. ................................................................................................... 48
5.7.2 Dry Electrostatic Precipitators. ......................................................................................... 49
5.7.3 Wet Electrostatic Precipitators.......................................................................................... 50
5.7.4 Wet Scrubbers................................................................................................................... 50
5.7.5 Mechanical Collectors. ..................................................................................................... 50
5.8 STEP 3. Rank the Technically Feasible Technologies. ................................................................. 51
5.9.1 Rank No. 1: Fabric Filter Baghouse. ............................................................................... 51
5.10 STEP 5. Proposed Filterable Particulate Matter and PM10 BACT Determination........................ 52
Chapter 6. PM2.5 Control Technology Review...................................................53

6.1 BACT Baseline. ............................................................................................................................. 53
6.2 STEP 1. Identify All Potential Control Technologies................................................................... 54
6.2.1 Direct PM2.5 Emissions. .................................................................................................... 54
6.2.2 PM2.5 Precursors................................................................................................................ 54
6.3.1 Fabric Filter Baghouses. ................................................................................................... 54

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6.3.2 Dry Electrostatic Precipitators. ......................................................................................... 58
6.3.3 Wet Electrostatic Precipitators.......................................................................................... 58
6.3.4 Wet Scrubbers................................................................................................................... 58
6.3.5 Mechanical Collectors. ..................................................................................................... 58
6.5.1 Rank No. 1: Fabric Filter Baghouse with Advanced Filter Media. ................................. 60
6.6 STEP 5. Proposed PM2.5 BACT Determination............................................................................ 60
Chapter 7. Sulfur Dioxide (SO2) Control Technology Review.........................61

7.1 BACT Baseline. ............................................................................................................................. 61
7.2 STEP 1. Identify Potential Control Technologies......................................................................... 61
7.3.1 Wet Flue Gas Desulfurization........................................................................................... 63
7.3.2 Dry Flue Gas Desulfurization. .......................................................................................... 66
7.3.3 Sorbent Injection............................................................................................................... 67
7.3.4 Emerging Flue Gas Desulfurization Technologies. .......................................................... 68
7.3.5 Low Sulfur Fuels and Fuel Cleaning. ............................................................................... 69
7.4.1 Low Sulfur Biomass Biomass Fuels. ................................................................................ 71
7.4.2 Wet Flue Gas Desulfurization........................................................................................... 72
7.4.3 Dry Flue Gas Desulfurization. .......................................................................................... 72
7.4.4 Dry Sorbent Injection........................................................................................................ 72
7.4.5 Ranking of the Technically Feasible Control Options...................................................... 72
7.5.1 Rank No. 1: Wet Flue Gas Desulfurization. .................................................................... 73
7.5.2 Rank No. 2: Dry Flue Gas Desulfurization...................................................................... 75
7.5.3 Rank No. 3: Sorbent Injection. ........................................................................................ 76
7.5.4 Rank No. 4: Low Sulfur Biomass Fuels. ......................................................................... 76
7.6 STEP 5. Proposed Sulfur Dioxide BACT Determination............................................................. 77
Chapter 8. Organic Compound (VOC) Control Technology Review. ............78

8.1 BACT Baseline. ............................................................................................................................. 78
8.2 STEP 1. Identify All Available Control Technologies. ................................................................ 78
8.3.1 Oxidation Catalysts........................................................................................................... 79
8.3.2 Thermal Oxidation............................................................................................................ 79
8.3.3 Good Combustion Practices.............................................................................................. 81

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8.6 STEP 5. Proposed VOC BACT Determination. ........................................................................... 82
Chapter 9. Fluorides (as HF) Control Technology Review. .............................83

9.1 BACT Baseline. ............................................................................................................................. 83
9.2 STEP 1. Identify All Potential Control Technologies................................................................... 83
9.3.1 Flue Gas Desulfurization Systems. ................................................................................... 85
9.4 STEP 3. Rank The Technically Feasible Control Technologies................................................... 85
9.4.1 Biomass Biomass Fuels. ................................................................................................... 85
9.4.2 Flue Gas Desulfurization. ................................................................................................. 87
9.4.4 Ranking of the Technically Feasible Control Options...................................................... 87
9.6 STEP 5. Proposed Fluorides BACT Determination...................................................................... 90
Tables
TABLE 1-1. Potential air pollutant emissions for the proposed biomass-fired boiler............................... 11
TABLE 2-1. Summary of recent BACT economic analyses in which the control technology was rejected
as not cost effective for BACT. .......................................................................................................... 17
TABLE 3-1. Carbon monoxide (CO) BACT emission limits for similar biomass fuel-fired boilers. ........ 24
TABLE 4-1. Biomass-fired boiler nitrogen oxides (NOx) emission limits representing BACT................. 27
TABLE 4-2. Summary of the technical feasibility of retrofit NOx control technologies. .......................... 36
TABLE 4-3. Ranking of the technically feasible NOx control technologies for the biomass boiler. ........ 37
TABLE 4-4. Cost effectiveness of the NOx control technology options for the biomass-fired boiler....... 40
TABLE 5-1. Biomass-fired boiler particulate matter/PM10 BACT emission limits. .................................. 47
TABLE 5-2. Ranking of the technically feasible PM control technologies for the biomass-fired boiler.. 51
TABLE 6-1. Ranking of the technically feasible PM2.5 control technologies. .......................................... 59
TABLE 7-1. Biomass-fired boiler sulfur dioxide (SO2) BACT emission limits. ....................................... 62
TABLE 7-2. Typical proximate and ultimate analyses for several biomass fuels. .................................... 69
TABLE 7-3. Wood fuels analyses data and uncontrolled SO2 emission rates........................................... 70
TABLE 7-4. Ranking of the technically feasible SO2 control technologies. ............................................. 72
TABLE 7-5. Cost effectiveness of the SO2 control technology options for the biomass-fired boiler. ...... 74
TABLE 8-1. Biomass-fired boiler VOC emission limits representing BACT. .......................................... 79

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TABLE 9-1. Biomass-fired boiler hydrogen fluoride (HF) emission test results. ...................................... 84
TABLE 9-2. Ranking of the technically feasible HF control technologies. .............................................. 87
Figures
FIGURE 1-1. Typical CFB boiler power block showing the furnace, cyclone, baghouse, and stack. ........ 8
FIGURE 4-1. High dust SCR catalyst plugging, fouling, and structural support failure........................... 31
FIGURE 3-2. Coal and biomass ash composition showing the high levels of potassium and sodium in
biomass ash relative to coal ash. ......................................................................................................... 32
FIGURE 4-1. Reference Method 5 and Method 202 sample train............................................................. 44
FIGURE 4-2. Reference Method 5 and Other Method 28 sample train. ................................................... 45
FIGURE 5-2. Depiction of the flue gas flow through the fabric filter baghouse filter cake showing the
mechanism for particulate collection. ................................................................................................. 48
FIGURE 6-1. Cumulative emission factor for PM emissions versus the particle size. ............................. 55
FIGURE 7-1. Typical modern wet flue gas desulfurization system absorber tower. ................................ 64
Attachments
Attachment 1. Cost estimates for a Tail Gas or Regenerative Selective Catalytic Reduction (SCR)
system.
Attachment 2. Cost estimates for wet and dry FGD systems from the U.S. EPA’s CUECost Air Pollution
Control Systems Economics Spreadsheets, and cost estimates for sorbent injection.

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Chapter 1. Introduction and Source
Description.
This document is a Control Technology Review for the proposed new biomass fuels-fired boiler at We
Energies’ 50 MW Biomass Fuels Cogeneration Facility to be located at the Domtar – Rothschild Mill.
This control technology review is required for major new sources under the Prevention of Significant
Deterioration (PSD) program under NR 405.08, Wis. Adm. Code.
The proposed boiler will be a circulating fluidized bed (CFB) boiler designed to provide up to 550,000
pounds per hour of steam at 1,550 psig and 950 oF. The boiler will have a maximum design heat input
capacity of 800 million Btu per hour. The primary boiler fuels will be woody biomass consisting of
logging residues, and wastewater treatment plant wood residue from the Domtar Paper Mill. The boiler
will also be designed to fire natural gas for a startup fuel and for combustion stabilization, with a
maximum natural gas firing rate of less than 250 mmBtu per hour. A typical CFB boiler power block
showing the boiler, the CFB cyclone, the fabric filter baghouse, and the stack is shown in Figure 1-1.
FIGURE 1-1. Typical CFB boiler power block showing the furnace, cyclone, baghouse, and stack.

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1.1 Fluidized Bed Boiler Technology.
The atmospheric pressure, fluidized bed boiler technology was developed to minimize SO2 and NOx
emissions from the combustion of high sulfur fuels such as coal and petroleum coke. The fluidized bed
boiler combustion process minimizes NOx formation and removes SO2 in the boiler before post
combustion air pollution control systems. Fluidized bed boilers are also excellent boilers for firing highly
variable and low heat value fuels such as biomass.
There are two major fluidized bed boiler types: the bubbling fluidized bed (BFB), and the circulating
fluidized bed (CFB) boiler. In the BFB boiler, the bed of materials including the limestone, fuel, and ash
is suspended by the combustion air flowing upward through an air distribution plate at velocities of 1 to 5
ft/sec. In a BFB boiler, the fluidized bed is typically about 4 feet deep, and is characterized by a sharp
density profile at the top of the bed. The sharp drop off in density indicates the end of the fluidized bed.
In a BFB boiler, the bed level is easy to see, and there is a distinct transition between the bed and the
space above. Solid material is drained from the bed to maintain the desired bed depth. Some solid
material is also entrained in the flue gas and is carried out of the furnace with the flue gas.
The CFB boiler is a more advanced fluidized bed boiler technology. CFB boilers have higher fluidizing
air velocities ranging from 10 to 20 ft/sec, lack a distinct transition from the dense bed at the bottom of
the furnace to the dilute zone above, and have a very high flow rate of re-circulated solids. The high
fluidizing air velocity results in a turbulent fluidized bed and a high rate of entrained solids carried out of
the boiler. These solids are separated from the combustion gases by cyclones located at the outlet of the
boiler furnace and are returned to the furnace to maintain the bed in the furnace and to improve
combustion efficiency.
When firing high sulfur containing fuels, limestone is injected with solid fuel to create a fuel and
limestone “bed”. For low sulfur fuels such as biomass fuels, sand is used rather than limestone to avoid
excessive calcium in the bed which can lead to particle agglomeration, excessive particle size, and even
“freeze-up” of the fluidized bed. The limestone or sand particles create an abrasive bed of particles which
assists in eroding fuel particles and completing the combustion process. Combustion air introduced at the
bottom of the furnace keeps the mixture of fuel, limestone, sand, char, and ash “fluidized” in a constantly
upward flowing stream. Although the fuel and limestone/sand are solids, the combination of fuel,
limestone/sand, ash, and combustion air exhibit fluid-like properties. The highly turbulent, erosive
conditions of the CFB achieves very high combustion efficiencies even though combustion takes place at
relatively low temperatures of 1,500 to 1,650°F.
1.2 CFB Boiler Fuels.

The primary fuel for the CFB boiler will be woody biomass fuels. The primary target source and anchor
fuel for this project will be woody biomass. For purposes of this application, “biomass” means a resource
that derives energy from wood or plant material or residue, clean solid wood waste and crops grown for
use as a resource. It excludes edible portions of food crops, refuse derived fuel, treated wood, municipal
solid waste, sewerage sludge, and animal waste. Fuel sources may include but are not limited to:

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logging residue
discarded woody material from primary manufacturing facilities such
as paper mills, sawmills, or chip mills
on-site wastewater treatment plant residue
leftover woody material from secondary manufacturers such as door,
window, cabinet manufacturers
woody biomass from municipality wood waste, tree services, and
construction companies
clean solid wood waste from discarded wood packaging such as
pallets/crating and from construction and demolition activities
woody biomass plantations, energy crops and agricultural residues
The design fuel – forest residues - will have a heat value of 8,430 Btu per pound on a bone-dry basis, or
approximately 4,530 Btu per pound on an as-received basis. The biomass fuel consumption rate will be
46 tons per hour (dry basis), or 86 tons per hour on an as-received basis when burning the design fuel.
The boiler will also be equipped with natural gas start-up burners. Natural gas may also be used as a
support fuel using secondary lance burners during upset conditions or for short periods when the biomass
moisture is higher than normal.
1.3 CFB Boiler Design.

The Company is proposing to construct a steam/electric cogeneration facility, to be located on the Domtar
property. The facility will be designed to produce 50 MW net electric generation, as well as provide the
full process steam requirements of the Domtar paper mill. In normal operating mode, process steam for
the mill will be extracted from the turbine generator, slightly reducing net generation capability. The CFB
boiler will be equipped with a single steam drum and multiple economizer, generating bank, superheater
and steam attemperator systems. High pressure, high temperature steam will be fed to a new 50 MW
(electric) steam turbine electric generator set. The boiler will be equipped with air heaters to preheat the
combustion air using hot flue gases and/or steam to improve thermal efficiency and to compensate for
high moisture biomass. Steam soot blowers will be located at strategic positions to maintain heating
surfaces clean. There will be a single electrically driven induced draft fan downstream of the baghouse.
The CFB boiler will have a recirculating sand system to replace the sand purged from the fluidized bed
with the ash. The sand system will consist of a sand silo which will feed sand by gravity to the sand chute
that ends in the furnace. The ash will bind itself to the sand in the bed. As a result, the mixture will be
collected in a cyclone for the sand to be screened and recirculated back to the boiler combustion zone.
The heavier particles will be discharged onto a conveyor system which will transfer the ash to the ash
silo. The sand consumption will be dependent on the fuel and sand quality.
1.4 Potential Air Emissions.

Potential emissions for this biomass fuels-fired, circulating fluidized bed boiler are summarized in Table
1-1.

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TABLE 1-1. Potential air pollutant emissions for the proposed biomass-fired boiler.
Uncontrolled Controlled
Heat Input Maximum Theoretical Control
Emission Emission Potential to Emit
Pollutant Capacity Emissions Efficiency
Factor Factor
lb/mmBtu mmBtu/hr lb/hr tons/yr % lb/mmBtu lb/hr ton/yr
Carbon Monoxide CO 0.20 800 160 701 0.20 160.0 700.8
Nitrogen Oxides NOx 0.15 800 120 526 33.3% 0.10 80.0 350.4
Particulate Matter PM/PM10 12.0 800 9,600 42,048 99.75% 0.030 24.0 105.1
Particulate Matter PM2.5 12.0 800 9,600 42,048 99.81% 0.023 18.4 80.6
Sulfur Dioxide SO2 0.09 800 72 315 0.0% 0.09 72.0 315.4
Organic Compounds OC 0.017 800 13.6 60 0.017 13.6 59.6
Lead Pb 0.00003 800 0.02 0.11 0.00003 0.024 0.11
Mercury Hg 0.0000029 800 0.0023 0.010 0.0000029 0.0023 0.01
Fluorides (as HF) HF 0.001 800 0.8 3.5 0.001 0.80 3.5
Sulfuric Acid Mist H2SO4 0.0018 800 1.4 6.3 0.0018 1.44 6.3
Footnotes
1. Potential controlled emission rates for CO, NOx, PM/PM10, PM2.5, SO2, VOC, and fluorides are based on the proposed
BACT emission limits in this control technology review.
2. The lead emission factor is from the U.S. EPA document, Compilation of Air Pollutant Emission Factors, AP-42, 5th
Edition, Wood Residue Combustion in Boilers, Table 1.6-4.
3. The mercury emission factor is based on the proposed case-by-case MACT emission limit for mercury contained in
Appendix D of the application.
4. Sulfuric acid mist emissions are estimated to be 2% of the sulfur dioxide emissions on a mass basis.

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Chapter 2. Control Technology Review
Methodology.
2.1 Best Available Control Technology Definition.
The Clean Air Act and the Prevention of Significant Deterioration (PSD) rules in the Code of Federal
regulations, 40 CFR 52.21(b)(12) define “best available control technology” (BACT) as:
“…an emission limitation based on the maximum degree of reduction for each pollutant subject to
regulation under this Act which would be emitted from any proposed major stationary source or major
modification which the administrator on a case-by-case basis, taking into account energy,
environmental, and economic impacts and other costs, determines is achievable for such source or
modification through application of production processes and available methods, systems, and
techniques, including fuel cleaning or treatment of innovative fuel combustion techniques for control of
each such pollutant. In no event shall application of BACT result in emissions of any pollutant which
would exceed the emissions allowed by any applicable standard under 40 CFR Parts 60 and 61.”
In Wisconsin, BACT is defined as:

…means an emissions limitation, including a visible emissions standard, based on the maximum degree
of reduction for each air contaminant subject to regulation under the Act which would be emitted from
any proposed major stationary source or major modification which the department, on a case-by-case
basis, taking into account energy, environmental, and economic impacts, and other costs, determines is
achievable for such source or modification through application of production processes or available
methods, systems, and techniques, including clean fuels, fuel cleaning or treatment or innovative fuel
combination techniques for control of the air contaminant. In no event may application of best available
control technology result in emissions of any air contaminant which would exceed the emissions
allowed by any applicable standard under chs. NR 440 and 445 to 449 and under sections 111 and 112
of the Act (42 USC 7411 and 7412). Emissions from any source utilizing clean fuels or any other means
to comply with this subsection may not be allowed to increase above the levels that would have been
required under this subsection as it existed prior to enactment of the 1990 clean air Act amendments on
November 15, 1990. If the department determines that technological or economic limitations on the
application of measurement methodology to a particular emissions unit would make the imposition of
an emissions standard infeasible, a design, equipment, work practice, operational standard or
combination thereof, may be prescribed instead to satisfy the requirement for the application of best
available control technology. The standard shall, to the degree possible, set forth the emissions
reduction achievable by implementation of such design, equipment, work practice or operation, and
shall provide for compliance by means which achieve equivalent results.
(NR 405.02(7), Wis. Adm. Code)
The BACT requirement applies for a given pollutant to each individual new or modified emission unit
when the project, on a facility-wide basis, has a significant net emissions increase for that pollutant.
Individual BACT determinations are performed on a unit-by-unit, pollutant-by-pollutant basis.

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2.2 Top Down BACT Methodology.
The U.S. EPA recommends a “top-down” approach in conducting a BACT analysis. This method
evaluates progressively less stringent control technologies until a level of control considered BACT is
reached, based on the environmental, energy, and economic impacts. The top-down method was used in
this analysis. The five steps of a top-down BACT analysis are:
1. Identify all available control technologies with practical potential for application to the emission
unit and regulated pollutant under evaluation;
2. Eliminate all technically infeasible control technologies;
3. Rank remaining control technologies by effectiveness and tabulate a control hierarchy;
4. Evaluate most effective controls and document results; and
5. Select BACT, which will be the most effective practical option not rejected, based on economic,
environmental, and/or energy impacts.
The impact analysis of any BACT review includes an evaluation of environmental, energy, technical, and
economic impacts. The net environmental impact associated with a control alternative may be considered
if dispersion modeling analyses are performed. The energy impact analysis estimates the direct energy
impacts of the control alternatives in units of energy consumption. If possible, the energy requirements
for each control option are assessed in terms of total annual energy consumption. The most important
issue of the BACT review is generally the economic impact. The economic impact of a control option is
assessed in terms of cost effectiveness and ultimately, whether the option is economically reasonable. The
economic impacts are reviewed on a cost per ton controlled basis, as directed by the U.S. EPA’s Office of
Air Quality Planning and Standards (OAQPS) Cost Control Manual, Fifth Edition.
The EPA has consistently interpreted the statutory and regulatory BACT definitions as containing two
core requirements, which EPA believes must be met by any BACT determination, irrespective of whether
it is conducted in a “top-down” manner. First, the BACT analysis must include consideration of the most
stringent available technologies: i.e., those that provide the “maximum degree of emissions reduction.”
Second, any decision to require a lesser degree of emissions reduction must be justified by an objective
analysis of “energy, environmental, and economic impacts” contained in the record.
2.3 New Versus Modified Facilities.

There can be significant differences in the technical and economic feasibility of retrofitting controls on
existing boilers, versus the use of these same controls on new boilers. In addition, a given control
technology may not be able to achieve the same level of control when retrofitted onto existing units as the
same control technology can achieve on new units. For example, the use of low NOx burners on existing
boilers often cannot achieve the same NOx, CO, and VOC emission rates as the use of low NOx burners
on a new boiler which has been designed to optimize the low NOx burner design. This can in turn affect
the ultimate NOx emission rates which can be achieved by post combustion controls such as selective
catalytic reduction.

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Retrofitting controls on existing boilers can also have significantly different costs as compared to the use
of these same technologies on new units. Retrofitting controls on existing boilers can have numerous
issues, including site constraints and room for the new controls, demolition requirements for existing
controls, and down time during construction and interconnection of the new systems.
2.4 Identifying Potential Control Technologies.

As stated in the U.S. EPA’s October 1990 New Source Review Workshop Manual, the first step in a "top-
down" analysis is to identify, for the emissions unit in question, all "available" control options. Available
control options are those air pollution control technologies or techniques with a practical potential for
application to the emissions unit and the regulated pollutant being evaluated. Air pollution control
technologies and techniques include the application of production process or available methods, systems,
and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control
of the affected pollutant, including technologies employed outside of the United States. In some
circumstances, inherently lower-polluting processes are appropriate for consideration as available control
alternatives. The control alternatives should include not only existing controls for the source category in
question, but also (through technology transfer) controls applied to similar source categories and gas
streams, and innovative control technologies. Technologies required under lowest achievable emission
rate (LAER) determinations are available for BACT purposes and must also be included as control
alternatives and usually represent the top alternative. In Step 1, applicants should identify all control
options with potential application to the emissions unit under review.
2.5 Technical Feasibility.

Step 2 of the BACT analysis involves the evaluation of all of the identified available control technologies
from Step 1 to determine their technical feasibility. A control technology is technically feasible if it has
been previously installed and operated successfully at a similar emission source, or there is technical
agreement that the technology can be applied to the emission source. Technical infeasibility is
demonstrated through clear physical, chemical, or other engineering principles that demonstrate that
technical difficulties preclude the successful use of the control option.
The technology must be commercially available for it to be considered as a candidate for BACT. EPA’s
New Source Review Workshop Manual, page B.12 states, “Technologies which have not yet been applied
to (or permitted for) full scale operations need not be considered available; an applicant should be able to
purchase or construct a process or control device that has already been demonstrated in practice.” In
general, if a control technology has been "demonstrated" successfully for the type of emission source
under review, then it would normally be considered technically feasible. For an undemonstrated
technology, “availability” and “applicability” determine technical feasibility. Page B.17 of the New
Source Review Workshop Manual states:
Two key concepts are important in determining whether an undemonstrated
technology is feasible: "availability" and "applicability." As explained
in more detail below, a technology is considered "available" if it can be
obtained by the applicant through commercial channels or is otherwise

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available within the common sense meaning of the term. An available
technology is "applicable" if it can reasonably be installed and operated
on the source type under consideration. A technology that is available
and applicable is technically feasible. Availability in this context is
further explained using the following process commonly used for bringing
a control technology concept to reality as a commercial product:
• concept stage;
• research and patenting;
• bench scale or laboratory testing;
• pilot scale testing;
• licensing and commercial demonstration; and
• commercial sales.
Applicability involves not only commercial availability (as evidenced by past or expected near-term
deployment on the same or similar type of emission source), but also involves consideration of the
physical and chemical characteristics of the gas stream to be controlled. A control method applicable to
one emission source may not be applicable to a similar source depending on differences in physical and
chemical gas stream characteristics.
2.6 Economic Feasibility.

Economic feasibility is normally evaluated according to the average and incremental cost effectiveness.
From the U.S. EPA’s New Source Review Manual, page B.31, average cost effectiveness is the dollars
per ton of pollutant reduced. The incremental cost effectiveness is the cost per ton reduced from the
technology being evaluated as compared to the next lower technology. The EPA NSR Review Manual
states that, “where a control technology has been successfully applied to similar sources in a source
category, an applicant should concentrate on documenting significant cost differences, if any, between the
application of the control technology on those sources and the particular source under review”.
2.6.1 Average Cost Effectiveness.

In the EPA’s New Source Review Manual, page B.37, average cost effectiveness is calculated as:
Average Cost Effectiveness Control option annualized cost

=
($ per ton removed) Baseline emission rate – Control option emissions rate
The average cost effectiveness is based on the overall reduction in the air pollutant from the baseline
emission rate. In the draft Workshop Manual, the EPA states that the baseline emission rate represents
uncontrolled emissions for the source. However, the manual also states that when calculating the cost
effectiveness of adding controls to inherently lower emitting processes, baseline emissions may be
assumed to be the emissions from the lower emitting process itself.

- 15 -
2.6.2 Incremental Cost Effectiveness.
In addition to determining the average cost effectiveness of a control option, the U.S. EPA’s New Source
Review Manual states that the incremental cost effectiveness between dominant control options should
also be calculated. The incremental cost effectiveness compares the costs and emissions performance
level of a control option to those of the next most stringent control option:
Incremental Cost ($ per Control option annualized cost – Next control option annualized cost
=
incremental ton removed) Next control option emission rate – Control option emissions rate
2.6.3 Agency Decisions on Cost Effectiveness.

Numerous permitting authorities have made decisions regarding the economic feasibility of air pollution
controls for coal-fired electric utility boilers which represent BACT. Table 3-1 is a summary of recent
BACT economic analyses by various review agencies in which the control technology was rejected as not
cost effective for BACT. The determinations in Table 3-1 include decisions for PM, PM10, NOx, and SO2
emissions for biomass-fired boilers, pulverized coal-fired boilers, circulating fluidized bed boilers, and
gas turbines. While cost effectiveness is determined on a case-by-case basis, the following information
on comparative economic costs of BACT options gives some perspective on the costs that similar sources
have typically not been expected to bear as BACT.

- 16 -
TABLE 2-1. Summary of recent BACT economic analyses in which the control technology was rejected as not cost effective for BACT.
Cost Effectiveness of Control Average Cost
Control Rejected Technology, Technology Effectiveness of
Boiler
Facility State Pollutant Technology $ per ton controlled Selected Selected
Type
Rejected Technology,
Average Incremental
$ per ton
DTE Energy – Stoneman
1 WI Stoker NOx SCR $9,217 SNCR
Power Plant
We Energies – Concord Gas Good
3 WI NOx SCR 8,236 -
Generating Station Turb Combustion
2 Longleaf Energy Associates GA PC SO2 Wet FGD - $8,964 Dry FGD $724
Rocky Mountain Power
4 MT PC SO2 Wet FGD $1,395 $23,855 Dry FGD $918
Hardin
PM / Baghouse w/ Baghouse w/
Intermountain Power 3 UT PC $31 $14,000 $31
5 PM10 Teflon Bags Ryton Bags
Basin Electric - Dry Fork NOx SCR at 0.04 $2,004 $10,303 SCR at 0.05 $1,511
WY PC
6 Station SO2 Wet FGD $1,595 $15,299 Dry FGD $1,159
Black Hills Power & Light -
7 WY PC NOx SCR at 0.06 $4,156 $7,742 SCR at 0.07 $4,067
WYGEN2
Black Hills Power & Light PM / Baghouse w/ Baghouse w/
8 WY PC $134 $14,609 $130
– WYGEN3 PM10 Teflon Bags Fiberglass Bags
Deseret Power Cooperative
UT CFB SO2 Wet FGD $418 $10,540 Dry FGD $397
9 - Bonanza
Southern Montana Electric Wet FGD - $27,365
MT CFB SO2 Ash Reinjection $4,054
10 Coop- Highwood Dry FGD - $7,939
Montana-Dakota Utilities
11 ND CFB NOx SCR $7,545 $14,339 SNCR $2,926
Gascoyne Station
Red Trail Energy Ethanol
12 ND CFB SO2 Wet FGD $1,041 $10,252 Dry FGD $527
Plant
13 River Hill Power Company PA CFB SO2 Wet FGD - >$5,000 Dry FGD $1,511
14 Cargill - Blair Ethanol Plant NE CFB SO2 Dry FGD - $5,900 No Post Controls
ADM – Columbus Ethanol NOx SNCR - $5,600 SNCR $2,174
15 NE CFB
Plant SO2 Ca Inj. - $6,700

- 17 -
1. In a PSD permit for the conversion of two coal-fired boilers to wood combustion, the Department
concluded that the use of regenerative selective catalytic reduction with an average NOx control cost
of $9,217 per ton was not economically feasible.
2. In a PSD permit for 320 MW of simple cycle combustion turbine capacity, the Department concluded
that the use of selective catalytic reduction with an average NOx control cost of $8,236 per ton was
not economically feasible.
3. In a PSD permit issued by the State of Georgia in 2006 for a new pulverized coal-fired utility boiler at
Longleaf Energy Associates, Georgia determined that the incremental cost effectiveness of $8,964/ton
for wet FGD compared to dry FGD for SO2 control was not cost effective. The average cost
effectiveness of the selected BACT option, dry FGD, was $724/ton. Georgia’s PD is available online
at: http://www.air.dnr.state.ga.us/airpermit/psd/dockets/longleaf/permitdocs/0990030pd.pdf.
4. In a PSD permit issued by the State of Montana in 2005 for a new pulverized coal fired utility boiler
at Rocky Mountain Power’s Hardin project, Montana concluded that an incremental cost
effectiveness of $23,855/ton for a wet FGD system as compared to a dry FGD system was excessive
for BACT. The average cost effectiveness of the wet FGD option was $1,395/ton. The average cost
effectiveness of the selected BACT option, dry FGD, was $918/ton. (Ref: Montana’s Permit
Analysis for Hardin project, Permit #3185-02, pages 15 and 17, dated May 16, 2005.)
5. In a PSD permit issued by the State of Utah in 2004 for a new pulverized coal-fired electric utility
boiler at Intermountain Power’s Unit 3, Utah concluded that an incremental cost effectiveness of
$14,000/ton to $16,350/ton, comparing different types of baghouse fabric filter bags (Ryton-type bags
versus specialty coated bags) for PM/PM10 control, was excessive for BACT. The average cost
effectiveness of the selected BACT option for PM10 control (a baghouse with Ryton-type bags) was
$31/ton. (Ref: Utah’s Modified Source Plan Review for IPP3 project, March 22, 2004, available
online at: http://www.airquality.utah.gov/Permits/PmtPowerPlants.htm.)
6. In a PSD permit issued by the State of Wyoming in 2007 for a new pulverized coal-fired electric
utility boiler at Basin Electric’s Dry Fork Station, Wyoming concluded that an incremental cost
effectiveness of $23,755/ton for NOx control, comparing SCR at 0.043 lb/mmBtu to SCR at 0.040
lb/mmBtu, was excessive for BACT. The average cost effectiveness for SCR at 0.040 lb/mmBtu was
$2,004/ton; the average cost effectiveness for SCR at 0.043 lb/mmBtu was $1,751/ton. Although
Wyoming stated that an incremental cost effectiveness of $10,303/ton was reasonable for SCR at
0.043 lb/mmBtu, for other reasons described by Wyoming the selected NOx control was SCR at 0.05
lb/mmBtu, with an incremental and average cost effectiveness of $3,512/ton and $1,511/ton,
respectively.
Wyoming also concluded that an incremental cost effectiveness of $15,299/ton for SO2 control,
comparing a dry FGD system at 0.073 lb/mmBtu to a wet FGD at 0.054 lb/mmBtu, was excessive for
BACT. The average cost effectiveness of the eliminated wet FGD option at 0.054 lb/mmBtu was
$1,595/ton. Although Wyoming determined that an incremental cost effectiveness of $9,296/ton was
reasonable for a dry FGD at 0.043 lb/mmBtu, for other reasons described by Wyoming the selected
BACT option for SO2 control was a dry FGD system at 0.08 lb/mmBtu, with an average cost
effectiveness of $1,159/ton. (Ref: Wyoming’s Analysis for the Dry Fork project, NSR-AP-3546,
February 5, 2007.)
utility boiler at Black Hills Power & Light’s WYGEN2 project, Wyoming concluded that an
incremental cost effectiveness of $7,742/ton, comparing low-NOx burners plus SCR at 0.06 lb/mmBtu
to low-NOx burners plus SCR at 0.08 lb/mmBtu, for NOx control was reasonable for BACT.
However, for other reasons described by Wyoming, the selected BACT option was low-NOx burners
- 18 -
plus SCR at 0.07 lb/mmBtu, with an average cost effectiveness between $4,067/ton and $4,156/ton.
(Ref: Wyoming’s Permit Application Analysis for the WYGEN2 project, NSR-AP-92, April 24,
2002.)
utility boiler at Black Hills Power & Light’s WYGEN3 project, Wyoming indicated that an
incremental cost effectiveness of $14,609/ton, comparing a baghouse with fiberglass or
polyphenylene sulfide filter bags, listed as capable of achieving 0.012 lb/MmBtu, to a baghouse with
specialty filter bags such as Teflon, listed as capable of achieving 0.011 to 0.010 lb/MmBtu, for
PM/PM10 control, was excessive for BACT. The average cost effectiveness of the selected BACT
option, a baghouse with fiberglass or polyphenylene sulfide filter bags, was $130/ton; the average
cost effectiveness of the eliminated option, a baghouse with specialty filter bags, was $134/ton. (Ref:
Wyoming’s Permit Application Analysis for the WYGEN3 project, NSR-AP-3934, October 9, 2006.)
9. In a PSD permit issued by the U.S. EPA Region 8 in August, 2007 for a circulating fluidized bed
(CFB) boiler at the Deseret Power Cooperative’s Bonanza Power Plant, the EPA concluded that an
incremental cost of $10,540 per ton of SO2 removed to install a wet FGD system rather than a dry
FGD system was too high to justify the expenditure. The average cost effectiveness for the wet FGD
system was $418 per ton of SO2 controlled; the average cost effectiveness for the dry FGD system
selected as BACT was $397/ton of SO2 controlled. Further, the EPA concluded that the costs for
alternative sources of coal in lieu of waste coal of $20,241 per ton of SO2 controlled was also
excessive as BACT.
10. In a PSD permit issued by the State of Montana in May, 2007 for a CFB boiler at Southern Montana
Electric Cooperative’s Highwood Generating Station, Montana concluded that a cost of $27,365/ton
of SO2 control, for a combination of limestone injection, low-sulfur coal and wet FGD was excessive
for BACT. Montana also concluded that a cost of $7,939/ton of SO2 controlled, for a combination of
limestone injection, low-sulfur coal and dry FGD, was excessive for BACT. The selected SO2 BACT
option was a combination of limestone injection, low-sulfur coal, and hydrated ash reinjection with a
cost effectiveness of $4,054/ton. (Ref: Montana’s “Permit Analysis” for Air Quality Permit #3423-00,
May 30, 2007, from the Montana Department of Environmental Quality.)
11. In a PSD permit issued by the State of North Dakota in early 2005 for a CFB boiler at Montana-
Dakota Utilities Gascoyne Generating Station, North Dakota concluded that an incremental cost
effectiveness of $14,339/ton, comparing SCR at 0.04 lb/mmBtu to SNCR at 0.09 lb/mmBtu, for NOx
control, was excessive for BACT. The average cost effectiveness of SCR was $7,545/ton. The
average and incremental cost effectiveness of the selected BACT option, SNCR, was $2,926/ton.
(Ref: North Dakota’s Permit Analysis, March 2005, North Dakota Department of Health,
Environmental Health Section.)
12. In a PSD permit issued by the State of North Dakota in 2004 for a CFB boiler at the Red Trail
Energy’s Richardton, ethanol plant, North Dakota determined that an incremental cost effectiveness
of $10,252/ton, comparing wet FGD plus limestone injection to dry FGD plus limestone injection, for
SO2 control was not cost effective. The average cost effectiveness of wet FGD plus limestone
injection was $1,041/ton; the average cost effectiveness of dry FGD plus limestone injection was
$527/ton. North Dakota rejected wet FGD and determined that BACT is dry FGD plus limestone
injection. (Ref: North Dakota’s Analysis for Red Trail Energy project, May 2004, North Dakota
Department of Health, Environmental Health Section, Air Quality Division.)
13. In a PSD permit issued by the State of Pennsylvania in 2005 for a CFB boiler at the River Hill Power
Company, Pennsylvania concluded that all SO2 BACT options involving wet FGD systems were
economically infeasible at an incremental dollar per ton value greater than $5,000 per ton of SO2

- 19 -
removed. Pennsylvania concluded that the use of dry FGD was economically feasible for the control
of SO2 at an incremental cost of $1,511 per ton of SO2 removed. Pennsylvania also concluded that an
incremental cost effectiveness of $15,975/ton, comparing the use of the waste coal to the nearest
alternative source of coal with lower sulfur content, was excessive as BACT for SO2 emissions. (Ref:
Pennsylvania’s “Plan Approval Review Memo, Application #17-00055A,” May 2, 2005.)
14. In a PSD permit issued by the State of Nebraska in 2006 for a CFB boiler at Cargill’s Blair ethanol
production plant, Nebraska indicated that an incremental cost effectiveness of $5,900/ton, comparing
limestone injection alone to limestone injection plus dry FGD for SO2 control, was excessive for
BACT. (Ref: Nebraska permit CP06-0008, Sept. 8, 2006, available at
http://www.epa.gov/region07/programs/artd/air/nsr/archives/2006/finalpermits/cargill_blair_final_psd
_permit.pdf.)
15. In a PSD permit issued by the State of Nebraska in 2006 for a CFB boiler at ADM’s Columbus corn
milling and ethanol production plant, Nebraska indicated that incremental cost effectiveness of
$5,600/ton for NOx control (comparing SNCR at 0.07 lb/mmBtu to SNCR at below 0.07), and an
incremental cost effectiveness of $6,700/ton for SO2/H2SO4/HF control (comparing limestone
injection to “additional” limestone injection), were excessive for BACT. Nebraska listed incremental
cost-effectiveness of $2,174 for the selected BACT option for NOx control (SNCR at 0.07 lb/mmBtu).
(Ref: Nebraska permit CPM02-0006, August 4, 2006, available online at:
http://www.epa.gov/region07/programs/artd/air/nsr/archives/2006/finalpermits/adm_columbus_final_
psd_permit.pdf.)

- 20 -
Chapter 3. Carbon Monoxide (CO)
Control Technology Review.
Carbon monoxide (CO) is emitted from biomass-fired boilers as a result of incomplete combustion.
Incomplete combustion can also result in reduced boiler efficiency and emissions of particulate matter,
volatile organic compounds, and organic hazardous air pollutants. CO and VOC emissions from the
combustion of biomass fuels are normally expected to be somewhat elevated as compared to the
combustion of natural gas, fuel oil, and coal because of the high moisture content and relatively low
heating value of most biomass fuels. Because fuel costs represent the highest single operating cost for this
boiler, this biomass-fired boiler is designed to achieve the highest combustion efficiencies practicable.
CO emissions can be reduced by operating the boiler with higher furnace temperatures, higher excess
oxygen levels, and longer furnace residence times. Unfortunately, techniques for reducing CO emissions
can increase NOx emissions. Achieving low CO and low NOx emissions is therefore a balancing act in
boiler design and operation.
3.1 BACT Baseline.

There are no specific Wisconsin state implementation plan (SIP) requirements or new source performance
standards for CO emissions from biomass or fossil fuel-fired boilers. Therefore, baseline emissions are
the uncontrolled emissions from the boiler.
3.2 STEP 1. Identify All Available Control Technologies.

Table 3-1 is a summary of carbon monoxide (CO) BACT emission limits for new biomass-fired boilers
contained in the U.S. EPA’s RACT/BACT/LAER Clearinghouse, and in other permits issued in the
United States. Emission limits range from 0.10 to 1.15 pounds per million Btu. Except for one facility,
the only technology selected for all permitted biomass-fired boilers is good combustion practices. For the
South Point Biomass Generation facility (Ohio, 2006), the facility was required to install an oxidation
catalyst. However, this facility has not been constructed and therefore has not demonstrated compliance
with a BACT emission limit. Note that from Table 3-1, of the top 6 ranked facilities, i.e., the Public
Service of NH - Schiller Station, South Point Biomass Generation, Yellow Pine Energy Company,
Nacogdoches Power, LLC, Mancelona Renewable, and Northern Michigan University, only the South
Point Biomass boiler is a stoker boiler. The other boilers are fluidized bed boilers.
3.3 STEP 2. Identify Technically Feasible Control Technologies.

Available control technologies for the control of CO emissions include good combustion practices,
oxidation catalysts, and thermal oxidation.

- 21 -
3.3.1 Oxidation Catalysts.
Oxidation catalysts are used to reduce CO emissions from natural gas or oil-fired combustion turbines,
with typical CO reductions of 50 – 90%. However, oxidation catalysts have limited demonstration on
biomass-fired boilers, and we are not aware of any demonstration or commercial operation of oxidation
catalysts on a fluidized bed boiler. Boilers have several characteristics that make the use of oxidation
catalysts technically infeasible, including catalyst fouling and poisoning by the wood fly ash, and low
excess oxygen levels in the flue gas.
CO oxidation catalysts are generally noble metal catalysts which are susceptible to poisoning from sulfur
and calcium bearing compounds. These catalysts may experience rapid deactivation and fouling in
biomass-fired boiler flue gas streams with high particulate loading. To be effective, the oxidation catalyst
must be placed in a location with gas temperatures of at least 600 oF. This location would be near the
boiler economizer outlets, a location with high ash loading and low excess oxygen levels.
A research effort to assess catalyst deactivation mechanisms was presented at the 2008 Advanced
Combustion Engineering Research Center conference1 reported that SCR catalyst poisoning is the
predominant deactivation mechanism resulting from biomass combustion. Note that oxidation catalysts
and SCR catalysts have similar poisoning mechanisms. The study ranks the order of poisoning of the
alkali-metals and alkaline-earth metals from having the most effect to lesser effect as potassium, followed
by sodium, followed by calcium, and states that the “effects are proportional to basicity of the exhaust
gas.” The study includes Figure 3-2 showing the difference in of coal versus biomass ash composition.
Figure 3-2 shows that the relative proportion of potassium is much greater in the biomass ash than in the
coal ash. Because of the presence of these base compounds and the low acid gas constituents such as
sulfur dioxide (SO2), biomass flue gas tends to be basic while especially high sulfur coal combustion flue
gas tends to be acidic. This exacerbates the catalyst deactivation and is the primary reason that oxidation
catalyst and SCR systems located in a high dust environment are not applicable to biomass combustors.
This problem is worsened by the CFB boiler design which has an extremely high dust loading. Erosion,
plugging, and blinding are major potential problems in fluidized bed boiler applications due to the very
high particulate loading in the boiler.
To reduce the fouling and catalyst poisoning problems, the oxidation catalyst can be located downstream
of the particulate matter control device. However, this “tail gas” oxidation catalyst control configuration
does not eliminate fouling and deactivation, since the exhaust gas stream remains highly alkaline.
In addition to this severe poisoning problem, the use of oxidation catalysts in this boiler application have
another problem; the lack of sufficient excess oxygen to effectively reduce CO emissions. Oxidation
catalysts operate according to the following general reaction:
2CO + O2 → 2CO2
1
Guo, X., et. al. Poisoning/Deactivation Study of V2O5/TiO2 SCR Catalysts, ACERC Annual Conference,
February 2008.

- 22 -
Typical excess oxygen (O2) levels in combustion turbines is 12 – 15%, compared to 3 – 6% in biomass-
fired boilers. These low excess O2 levels will limit the effectiveness of the oxidation catalyst.
Because of these serious technical problems and the fact that oxidation catalysts have not been
demonstrated on similar circulating fluidized bed biomass boilers, we have concluded that oxidation
catalysts are not a technically feasible CO control technology for these biomass-fired boilers.
FIGURE 3-2. Coal and biomass ash composition showing the high levels of potassium and
sodium in biomass ash relative to coal ash.
(Source: Guo, X., et. al. Poisoning / Deactivation Study of V2O5/TiO2 SCR Catalysts, ACERC Annual
Conference, February 2008.)
3.3.2 Thermal Oxidation

Thermal oxidation has never been required nor used on a biomass-fired boiler, and its theoretical ability
to reduce CO emissions from these boilers has not been demonstrated in practice and is questionable.
Thermal oxidation would involve injecting additional air into the flue gas and heating the oxygen
enriched mixture to approximately 1,500 oF to oxidize CO to carbon dioxide. However, since the
combustion of the reheat fuel would itself result in CO emissions, there is no evidence that thermal
oxidation would result in any CO emission reductions. Since thermal oxidation has never been
demonstrated on a biomass-fired boiler, and because there is no evidence that it could reduce CO
emissions, thermal oxidation is not a technically feasible CO control technology for these boilers.
3.3.3 Good Combustion Practices

Good combustion practices or combustion controls generally include the following components:

- 23 -
1. Good air/fuel mixing in the combustion zone.
2. High temperatures and low oxygen levels in the primary combustion zone.
3. Overall excess oxygen levels high enough to complete combustion while maximizing
boiler thermal efficiency.
4. Sufficient residence time to complete combustion.
In biomass-fired boilers, good combustion practices is the only technically feasible CO control
technology. Combustion efficiency is related to the three “T’s” of combustion: Time, Temperature, and
Turbulence. These components of combustion efficiency are designed into utility boilers to maximize
fuel efficiency and reduce the highest single operating cost of a utility boiler: FUEL. A fourth critical
parameter is the level of oxygen in the boiler, referred to as the excess air or excess oxygen level.
Therefore, combustion control is accomplished primarily through boiler design as it relates to time,
temperature, and turbulence, and through boiler operation as it relates to excess oxygen levels.
Combustion design for modern boilers is intended to simultaneously minimize formation of CO and NOx
emissions. This is a difficult task, since emissions of NOx and emissions of CO are inversely related.
That is, measures used to reduce NOx emissions often lead to increases in CO emissions. Therefore, the
boiler design to minimize CO emissions is interrelated with the boiler design to minimize NOx formation.
TABLE 3-1. Carbon monoxide (CO) BACT emission limits for biomass fuel-fired boilers.
Permit Capacity, Limit,
Facility State Primary Fuel
Date mmBtu/hr lb/mmBtu
Pub. Service of NH - Schiller Station NH Oct-04 720 Wood 0.10
South Point Biomass Generation OH Apr-06 318 Wood 0.10
Yellow Pine Energy Company GA May-09 1,529 Wood 0.15
Nacogdoches Power, LLC TX Mar-07 1,374 Wood 0.15
Mancelona Renewable MI Nov-09 565 Wood/Biomass 0.17
Northern Michigan University MI Nov-09 210 Wood/Biomass 0.17
Fibrominn Biomass Power MN Feb-05 792 Poultry Litter 0.24
Virginia PWC - Laurention Energy MN Aug-05 230 Wood 0.30
District Energy St. Paul, Inc. MN Nov-01 550 Wood 0.30
Sierra Pacific Aberdeen facility WA Oct-02 310 Waste Wood 0.35
S.D. Warren Company ME Nov-01 1,300 Wood 0.40
Stoneman Power Plant WI Jan-09 340 Wood 0.40
Koda Energy MN Aug-07 308 Wood / Nat. Gas 0.43
Martinsville Thermal LLC VA Sep-03 120 Wood 0.44
Wheelabrator Sherman Energy ME Apr-99 315 Wood 0.45
Northern Sun ND May-06 100 Wood / Hulls 0.63
Skagit County Lumber Mill WA Jan-06 430 Wood 0.93
Sierra Pacific Industries CA Dec-02 245 Wood 1.15

- 24 -
3.4 STEP 3. Rank the Technically Feasible Control Technologies.
Based on the above analysis, the only technically feasible CO control technology for biomass-fired
boilers is good combustion practices. From Table 3-1, recent BACT determinations have CO limits
ranging from 0.10 to 1.15 lb/mmBtu. The proposed CFB boiler is an advanced boiler which is expected
to achieve low CO emission rates. However, boiler startup, shutdown, and load changes can causes CO
emissions to increase because of unstable combustion conditions. CO emissions are also sensitive to
boiler operating conditions. Changes in operating conditions, such as rapid changes in load, can have a
significant, though temporary, impact on emissions. This condition is further exasperated during boiler
startup because the boiler itself is relatively cool, and the low air flow rates make it difficult to obtain
good air/fuel mixing. For these reasons, CO emissions can “spike” when transient conditions occur
during boiler startup and shut down.
Based on the analysis of this boiler, we have concluded that this boiler can achieve CO emission rates of
0.20 lb/mmBtu, excluding periods of startup and shutdown, averaged over any 30-day period. In
addition, we have concluded that this boiler can achieve an emission rate of 0.20 lb/mmBtu including all
periods, averaged over any consecutive 12-month period.
3.5 STEP 4. Evaluate the Most Effective Controls.

Because the only technically feasible control technology for the control of CO emissions from this boiler
is good combustion practices, further evaluation is unnecessary.
3.6 STEP 5. Proposed Carbon Monoxide BACT Determination.

Based on this analysis, We Energies has concluded that the use of good combustion practices is the best
available control technology (BACT) for CO emissions from the biomass-fired boiler B01. Based on this
analysis, We Energies proposes the following limits as BACT for the control of CO emissions from the
biomass-fired, fluidized bed boiler B01.
(1) Carbon monoxide (CO) emissions from the biomass-fired boiler B01
shall be controlled using good combustion practices as the best
available control technology.
(2) Carbon monoxide (CO) emissions may not exceed 0.20 pounds per
million Btu of heat input, excluding periods of boiler startup and shut
down, averaged over any consecutive 30-day period.
(3) Carbon monoxide (CO) emissions may not exceed 0.20 pounds per
million Btu of heat input, for all periods, including periods of boiler
startup and shut down, averaged over any consecutive 12-month period.
(4) Carbon monoxide (CO) emissions from the biomass-fired boiler B01
shall be continuously monitored and recorded using a continuous
emissions monitoring system meeting the requirements of 40 CFR Part
60 Appendix B, and NR 439.06(4), Wis. Adm. Code.
- 25 -
Chapter 4. Nitrogen Oxides (NOx)
Nitrogen oxides (NOx) consist of several compounds, including nitrogen oxide (NO), and nitrogen
dioxide (NO2). During combustion, NO usually accounts for more than 90% of the total NOx emissions.
However, since NO is subsequently converted to NO2 in the atmosphere, the mass emission rate of NOx
are normally reported as NO2. NOx is formed during combustion by two major mechanisms; thermal
formation, called “Thermal NOx”, and fuel formation, called “Fuel NOx”. Thermal NOx results from the
high temperature oxidation of nitrogen (N2) and oxygen (O2). Thermal NOx formation is influenced by
the flue gas residence time and excess oxygen, but, as its name implies, thermal NOx formation is
primarily influenced by temperature. Thermal NOx formation increases exponentially with temperature,
and becomes significant at temperatures above 2800 °F. Fuel NOx results from the oxidation of organic
nitrogen compounds in the fuel. Fuel bound nitrogen is more easily converted to NOx during combustion.
Fuel NOx may account for up to 80% of the total NOx emissions from solid fuel combustion.
4.1 BACT Baseline.

Boiler B01 will be subject to the Standards of Performance for Industrial-Commercial-Institutional Steam
Generating Units under 40 CFR Part 60, Subpart Db. This subpart applies to steam generating units that
commence construction, modification, or reconstruction after June 19, 1984, and that have a heat input
capacity greater than 100 mmBtu/hr. The current Subpart Db rules for NOx emissions were published in
the Federal Register June 13, 2007. Under 40 CFR § 60.44b(d), an affected facility that simultaneously
combusts natural gas with wood, municipal-type solid waste, or other solid fuel, except coal, may not
exceed a NOx emission rate of 0.30 lb/mmBtu heat input unless the affected facility has an annual
capacity factor for natural gas of 10% or less and is subject to a federally enforceable requirement that
limits operation of the affected facility to an annual capacity factor of 10% or less for natural gas.
4.2 STEP 1. Identify All Potential Control Strategies.

There are two major technology categories for controlling NOx emissions from this biomass-fired boiler:
combustion controls and post-combustion controls. Combustion NOx controls include technologies such
as advanced fluidized bed boilers to avoid NOx formation. Post combustion NOx controls reduce
emissions after NOx has been created. The most common post combustion control techniques involve the
injection of ammonia into the flue gas at various locations in the boiler or downstream of the boiler to
control NOx emissions. When ammonia is injected upstream of a catalyst, the process is called Selective
Catalytic Reduction (SCR); when injected in the boiler without a catalyst, the process is called Selective
Non-Catalytic Reduction (SNCR). Combustion and post combustion controls may be used together to
achieve the lowest emission rates. The following NOx control technologies were identified:

- 26 -
• Staged Combustion
• Low NOx burners (LNB)
• Overfire air (OFA)
Combustion Controls
• Flue Gas Recirculation (FGR)
• Oxygen-Enhanced Combustion (OEC)
• Fuel Reburn
• Selective Non-Catalytic Reduction (SNCR)
• Selective Catalytic Reduction (SCR)
Post Combustion Controls
• SCONOx™
• Emerging Control Technologies.
Table 4-1 is a summary of the NOx BACT emission limits for similar biomass-fired boilers in the U.S.
EPA’s RBLC, and in other permits identified for similar units.
TABLE 4-1. Biomass-fired boiler nitrogen oxides (NOx) emission limits representing BACT.
Permit Capacity, Control Limit,
Date mmBtu/hr System lb/mmBtu
Clean Power Berlin, LLC NH Sep-09 390 Wood SCR 0.065
Concord Steam Corporation NH Feb-09 305 Wood SCR 0.065
Pub. Serv. of NH - Schiller Station NH Oct-04 720 Wood SNCR 0.075
South Point Biomass Generation OH Apr-06 318 Wood SCR 0.088
Mancelona Renewable MI Nov-09 565 Biomass SNCR 0.10
Yellow Pine Energy Company GA May-09 1,529 Wood SNCR 0.10
Nacogdoches Power, LLC TX Mar-07 1,374 Wood SNCR 0.10
Northern Michigan University MI Nov-09 210 Wood None 0.15
Darrington Energy Cogeneration WA Feb-05 403 Wood / Bark SNCR 0.12
Skagit County Lumber Mill WA Jan-06 430 Wood / Bark SNCR 0.13
Virginia PWC - Laurention Energy MN Aug-05 230 Wood SNCR 0.15
Hibbing PUC - Laurention Energy MN Aug-04 230 Wood SNCR 0.15
Sierra Pacific Aberdeen facility WA Oct-02 310 Waste Wood SNCR 0.15
Wood 0.15
District Energy St. Paul, Inc. MN Nov-01 550 SNCR
Natural Gas 0.11
Wood 0.25
Koda Energy MN Aug-07 308 SNCR
Natural Gas 0.18
Fibrominn Biomass Power MN Feb-05 792 Manure SNCR 0.16
S.D. Warren Company ME Nov-01 1,300 Wood SNCR 0.20
Stoneman Power Plant WI Jan-09 340 Wood SNCR 0.20
Hillman Power MI Jul-02 300 Wood /TDF SNCR 0.20
Sierra Pacific Industries CA Dec-02 245 Wood SNCR 0.23
Boralex Stratton Energy, LP ME Jan-05 672 Wood RSCR 0.24
Boise White Paper LLC WA Feb-06 343 Wood / Bark OFA 0.30
Martinsville Thermal LLC VA Sep-03 120 Wood GCP 0.40
Footnotes
For the District Energy St. Paul and the Koda Energy facilities, the second limit is for natural gas firing.

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There are two key concepts in determining the feasibility of potential control technologies: “availability”
and “applicability.” A technology is considered “available” if it can be obtained commercially, has
completed a commercial demonstration, and has reached the point of licensing. When considering a
technology’s applicability, technical judgment must be exercised to determine if it can reasonably be
installed and operated on the proposed source. In determining the feasibility of a given technology to
achieve a given emission rate over the long term there is a third concept, “demonstrated in practice.” A
performance level or emission rate is “demonstrated in practice” if a unit with similar operating
conditions has a continuous, proven performance record.
4.3.1 Fluidized Bed Boilers.

The fluidized bed boiler combustion process has inherently low NOx emissions due to the relatively low
combustion temperatures in the boiler. Modern, advanced fluidized bed boilers include staged
combustion to spread the combustion process out in the boiler and minimize the combustion temperature
to minimize NOx formation. The fluidized bed boiler technology was developed to reduce SO2 and NOx
emissions from the combustion of coal and other high sulfur fuels such as petroleum coke. Fluidized bed
boilers have a great advantage in that they are inherently flexible for fuels selection, making fluidized bed
boilers ideal for biomass combustion.
In the furnace of the fluidized bed boiler, limestone or an inert material such as sand is injected with solid
fuel to create a “bed”. Combustion air forced in at the bottom of the furnace keeps the bed in a constantly
upward moving flow. The mixture of fuel, limestone, char and ash is suspended or “fluidized” in this
upwardly flowing stream. Although the fuel and limestone are solids, the combination of fuel, limestone,
and ash particles and combustion air exhibit fluid-like properties. The highly turbulent, erosive
conditions of the fluidized bed result in very high combustion efficiencies even though combustion takes
place at relatively low combustion temperatures of 1,500 to 1,650°F. Because thermal NOx formation
increases dramatically at temperatures in excess of 2,800°F, the lower fluidized bed boiler temperatures
significantly reduces NOx formation.
Based on vendor information, the NOx emission rate from an advanced fluidized bed boiler firing biomass
without post combustion controls will typically be 0.15 lb/mmBtu. This “uncontrolled” NOx emission
rate is 30 – 50% less than the uncontrolled NOx emission rate for conventional stoker boilers used for
biomass firing. Based on this review, fluidized bed boilers are a feasible control option for this project.
4.3.2 Low NOX Burners and Overfire Air.

Low NOx burners (LNB) are designed to control the mixing of air and fuel to reduce the peak
temperatures of combustion in coal-fired boilers. Fluidized bed boilers do not use burners to inject the
fuel into the boiler. Therefore LNBs are not technically feasible for fluidized bed boilers.

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4.3.3 Overfire Air (Staged Combustion).
Overfire air (OFA) is a combustion staging processes typically used in conjunction with low NOx burners.
A portion of the combustion air is redirected from the LNB to a higher elevation in the furnace to reduce
peak flame temperatures by reducing the concentration of oxygen in portions of the furnace. This
technique is used in pulverized coal and stoker-fired boilers to create an oxygen depleted zone where
unburned hydrocarbon species act to reduce the NOx that was formed near the coal burner or traveling
grates. The overfire air creates an oxidation zone to complete combustion. NOx formation is minimized
by completing combustion in an air-lean environment.
Overfire air systems are similar to the staged combustion used in state-of-the-art fluidized bed boilers. In
a fluidized bed boiler, primary air is introduced at the bottom of the boiler to fluidize the bed while
secondary air is added at a higher elevation to complete combustion. Staged combustion or overfire air is
a part of the standard design for all new fluidized bed boilers.
4.3.4 Flue Gas Recirculation.

Flue gas recirculation (FGR) is an additional combustion process often used in conjunction with low NOx
burners to reduce peak flame temperatures and create an oxygen depleted zone in the boiler by reducing
the concentration of oxygen in portions of the furnace. Flue gas recirculation reduces the oxygen content
of the air at the base of the furnace by diluting the primary air blown into the furnace with recirculated
flue gas from the back pass of the boiler. This technique is used in pulverized coal and stoker-fired
boilers to create an oxygen depleted reducing zone where unburned hydrocarbon species act to reduce the
NOx that was formed near the coal burner. This oxygen depleted zone also reduces the peak flame
temperatures which minimizes NOx formation. FGR systems are NOx reduction techniques used in
smaller pulverized coal-fired boilers. This process is not necessary for a fluidized bed boiler because the
peak flame temperatures and NOx emissions are already minimized by the fluidized bed design.
Therefore, FGR is not an applicable NOx control technology for fluidized bed boilers.
4.3.5 Oxygen-Enhanced Combustion.

Oxygen-Enhanced Combustion (OEC) is a combustion control technology aimed at reducing the
formation of thermal NOx. Praxair Technology, Inc. has developed a method of using oxygen to achieve
additional NOx reduction from low NOx burners on pulverized coal-fired boilers. Field tests were
conducted at the James River Power Station Unit 3, a wall-fired boiler. In pilot- and full-scale testing,
NOx emissions were reduced by as much as 60%, to levels below 0.15 lb/mmBtu, when a small portion of
low-NOx burner combustion air was replaced with locally injected oxygen.
OEC has never been demonstrated or used on a fluidized bed boiler. Because there is no operational
experience with OEC on fluidized bed boilers, and because the application of OEC to fluidized bed
boilers has significant technological questions, OEC is not a technically feasible control option for this
boiler.

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4.3.6 Natural Gas or Coal Reburning
Natural gas or coal reburning are NOx control techniques used primarily for reducing NOx emissions from
existing utility scale coal-fired boilers. Reburning redistributes a portion of both fuel and air into the
upper regions of the boiler furnace to create a second flame zone, generating chemically reducing
conditions that destroy NOx in the primary combustion zone. In large utility pulverized coal-fired boilers,
fuel reburning is conducted between the upper burner row and the furnace exit. Most reburn systems
divert 10 to 20% of the total boiler heat input to the upper furnace. If reburn conditions are not carefully
controlled, high temperature corrosion problems can occur which can damage the boiler.
At least five utility coal-fired demonstrations of reburn are in different levels of operation. In the best
applications, reburning may reduce NOx emissions to 0.15 lb/mmBtu. However, to be effective in
reducing NOx emissions natural gas or coal reburning requires a large furnace volume to adequately stage
combustion. The, natural gas and/or coal reburning process is not applicable to fluidized bed boilers
which are not designed to allow reburning. Therefore, natural gas and coal reburning are not technically
feasible control options for this biomass-fired boiler.
4.3.7 Selective Catalytic Reduction.

Selective Catalytic Reduction (SCR) is a post combustion NOx control system that can substantially
reduce NOx emissions from boilers. SCR systems consist of an ammonia (NH3) injection system and a
catalytic reactor. Urea can be decomposed in an external reactor to form ammonia for use in an SCR.
The ammonia injection grid is located upstream of the catalyst. Ammonia reacts with NOx and O2 in the
presence of the catalyst to form molecular nitrogen (N2) and water according to the following general
equations:
4NH3 + 4NO + O2 → 4N2 + 6H2O

4NH3 + 2NO2 + O2 → 3N2 + 6H2O
2NH3 + NO + NO2 → 2N2 + 3H2O
This process is called “selective” because ammonia reacts preferentially with NOx in the flue gas in the
presence of a catalyst. A catalyst is used to enhance NOx reduction and ammonia utilization. The most
common catalyst for utility boiler applications is a vanadium-based material supported on a honeycomb
substrate that is installed in multiple layers in the catalytic reactor. Secondary reactions also occur in the
presence of the SCR catalyst, including the oxidation of SO2 to SO3 and the oxidation of elemental
mercury.
The SCR reactor operating temperature is critical to SCR performance. For most boiler applications, the
SCR catalyst has an optimum operating range of 650 - 750 oF. There are two types of SCR systems
designed to achieve this operating temperature, called ’high dust‘ and ’low dust‘ systems. A ’high dust‘
SCR is located upstream of the air heater and particulate control system, usually in the back pass of the
boiler downstream of the economizer. A ’low dust‘ or ’tail gas‘ SCR is located downstream of the air
heater and particulate control system. In a ‘low dust’ SCR application, flue gas reheating is necessary to
increase the flue gas temperature to the correct operating temperature required by the SCR process.

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4.3.8 High Dust SCR.
High dust SCR systems have been demonstrated on pulverized coal-fired boilers. However, we are not
aware of a high dust SCR systems on fluidized bed boilers burning either biomass or coal. This is
because a high dust SCR system on a fluidized bed boiler would be subject to very high particulate
loading. In addition, for a biomass-fired fluidized bed boiler, there would be high concentrations of
alkaline earth metals from the biomass ash.
There are four basic mechanisms for deactivation of an SCR catalyst which reduce or eliminate the ability
of the SCR system to control NOx emissions: 1. Poisoning; 2. Plugging; 3. Fouling; and 4. Erosion.
Poisoning results from chemical attack on the surface of the catalyst. Plugging involves microscopic
blockage of catalyst pores by small ash particles. Fouling involves macroscopic blockage of the catalyst
through a build-up of ash. Erosion of the catalyst surface is due to the abrasive nature of the particulates
in a high dust environment and can lead to deactivation through the wearing away of the catalyst surface.
Figure 4-1 is an example of SCR catalyst fouling and plugging.
FIGURE 4-1. High dust SCR catalyst plugging, fouling, and structural support failure.
All of these deactivation mechanisms are at work on a high dust SCR catalyst. The primary mechanisms
for deactivation of an SCR catalyst in a wood-fired fluidized bed boiler is catalyst poisoning where the
active sites on the surface of the catalyst are chemically attacked by alkali metals such as sodium and
potassium, alkaline-earth metals such as calcium, and fouling due to the very high dust loading.
- 31 -
There have been several investigations into the effect of biomass firing on SCR performance. One study
entitled Biomass Impacts on SCR Catalyst Performance2 documents the high level of alkali and alkaline-
earth compounds in biomass as compared with various grades of coal. One conclusion of that report
notes that intimate contact between the alkali and alkaline-earth metals in the high dust environment act
as “effective poisons” of the SCR catalyst. The results of another research effort to assess catalyst
deactivation mechanisms was presented at the 2008 Advanced Combustion Engineering Research Center
(ACERC) conference3 and has a similar conclusion; catalyst poisoning is the predominant deactivation
mechanism resulting from biomass combustion. The study ranks the order of poisoning of the alkali-
metals and alkaline-earth metals from having the most effect to lesser effect as potassium, followed by
sodium, followed by calcium, and states that the “effects are proportional to basicity of the exhaust gas.”
Figure 4-2 is from this study and shows the difference in the ash composition of coal versus biomass.
gas tends to be acidic. This exacerbates the catalyst deactivation and is the primary reason that SCR
systems located in a high dust environment are not applicable to biomass-fired boilers.
FIGURE 4-2. Coal and biomass ash composition showing the high levels of potassium and sodium
in biomass ash relative to coal ash.
(Source: Guo, X., et. al. Poisoning / Deactivation Study of V2O5/TiO2 SCR Catalysts, ACERC Annual
Conference, February 2008.)
2
Baxter, L., Biomass Impacts on SCR Catalyst Performance, IEA Bioenergy Task 32, October 2005.
3
Guo, X., et. al. Poisoning/Deactivation Study of V2O5/TiO2 SCR Catalysts, ACERC, February 2008.
- 32 -
gas tends to be acidic. This exacerbates the catalyst deactivation and is the primary reason that SCR
systems located in a high dust environment are not applicable to biomass combustors. This problem is
worsened by the CFB boiler design which has an extremely high dust loading. Erosion, plugging, and
blinding are major potential problems in fluidized bed boiler applications due to the very high particulate
loading in the boiler. Based on this analysis, high dust SCR is not a technically feasible NOx control
technology for this biomass-fired, CFB boiler.
4.3.9 Tail Gas SCR.

A tail gas SCR system arrangement where the SCR catalyst is located downstream of the particulate
control device can reduce deactivation problems. In a tail gas SCR arrangement, the ammonia injection
rate to the SCR must be very carefully controlled to prevent excess ammonia – called ammonia slip -
from being carried over, since there are no pollution control systems to control the ammonia downstream
of the tail gas SCR. In a tail gas SCR system, ammonia slip should be kept as low as possible to avoid
emissions of ammonia vapor and the potential formation of ammonium bisulfate. The ammonium
bisulfate that is carried over in the flue gas would add to the total PM10 and PM2.5 emissions since there
are no downstream collection devices to capture these emissions in the tailgas SCR arrangement.
There are two possible catalysts for a tailgas SCR arrangement, including low temperature and high
temperature catalysts. Both catalyst types may require reheat of the flue gas, especially if any type of flue
gas desulfurization (FGD) is used. However, low temperature catalysts which require less (or possibly
no) reheat are extremely sensitive to sulfite (SO3) poisoning. In a low dust SCR with a standard catalyst,
reheat would be required to raise the temperature from about 290 oF (the baghouse exit temperature) to
650 oF. In a low dust SCR with a low temperature catalyst, reheat may be required to raise the
temperature to 450 oF.
The Boralex Stratton Energy, LP biomass-fired plant in Maine has a regenerative SCR system. Boralex
voluntarily installed this system with the goal of achieving NOx reductions in order to certify the facility
as a renewable energy generator by the State of Connecticut. Connecticut is focused on low NOx energy
provided by renewable energy sources combusting qualified fuels. Once certified, Boralex was allowed
the opportunity to compete for the sale of renewable energy credits (RECs) directly to those generators or
their energy marketing representatives which must have these credits to meet their Renewable Portfolio
Standard (RPS) requirements. To be eligible for Connecticut’s RPS Program, the NOx emission rate can
not exceed 0.075 lb/mmBtu on a quarterly basis. This plant received a minor modification to its air permit
in 2005 in which the Maine Department of Environmental Protection concluded that the best available
control technology (BACT) for NOx emissions from this boiler is the use of RSCR, and an emission limit
of 0.24 lb/mmBtu. Note that the NOx emission limit of 0.075 lb/mmBtu required to meet the CT RPS
Program is not a requirement of the air permit.
Based on this review, tailgas SCR is a technically feasible control option for this biomass-fired boiler.

- 33 -
4.3.10 Selective Non-Catalytic Reduction.
In a selective non-catalytic reduction (SNCR) control system, urea or ammonia is injected into the boiler
where the flue gas temperature is approximately 1,600 to 2,100 °F. At these much higher temperatures
(as compared to SCR), the reagent, urea [CO(NH2)2] or ammonia [NH3], reacts with NOx, forming
elemental nitrogen [N2 ] and water without the need for a catalyst. The overall NOx reduction reactions
are similar to those for SCR. The U.S. EPA estimates SNCR control efficiencies of 25 – 40%4, although
higher control efficiencies have been reported in limited applications. However, compared to SCR
systems, the ammonia to NOx ratio is normally much higher for SNCR systems. For SNCR, ammonia is
typically injected at an NH3 to NOx molar ratio of 1.2 – 2.0 moles of NH3 per mole of NOx, compared
with 1.0 - 1.1 moles of NH3 per mole of NOX for SCR.
The critical parameters for successful and effective control of NOx emissions using SNCR is a proper
temperature window for SNCR performance, and adequate residence time at that temperature for the
reaction to occur. If the temperature is too high, the ammonia will undergo chemical decomposition, and
NOx emission reductions will not be achieved. If the temperature is too low, the ammonia will not react
with NOx without a catalyst, and again, NOx emissions will not be reduced. To achieve effective SNCR
performance, multiple ammonia injection points at the proper temperature windows are required to
thoroughly mix the reagent in the boiler furnace. The limiting factor for an SNCR system is the ability to
contact the NOx with the reagent without excessive ammonia slip, and without excessive ammonia
decomposition before the NOx can be reduced. Because of the poor reaction kinetics of SNCR, higher
levels of ammonia injection are required for SNCR systems as compared to SCR systems. The SNCR
processes typically requires three or four times as much reagent as SCR systems to achieve similar NOx
reductions, and SNCR cannot achieve NOx reduction efficiencies as high as SCR systems.
As noted by the U.S. EPA, certain boiler types are more suited for SNCR due to the combustion unit
design. Boilers with furnace exit temperatures of 1550°F to 1950°F, residence times of greater than one
second, and high levels of uncontrolled NOx are good candidates5. SNCR has been widely used in
fluidized bed boilers where the high alkaline ash loading of the CFB boilers makes ‘high dust’ SCR
systems technically infeasible.6 Therefore, SNCR is a technically feasible control option for this biomass-
fired boiler.
4
From the U.S. EPA document Compilation of Air Pollutant Emission Factors, AP-42, page 1.1-9.
5
From the U.S. EPA document EPA-452/F-03-031, Air Pollution Control Technology Fact Sheet, Selective Non-
Catalytic Reduction, available at http://www.epa.gov/ttn/catc/dir1/fsncr.pdf.
6
Examples include the AES Puerto Rico facility, the Reliant Energy Seward Plant, the JEA Northside Units 1
and 2, the Kentucky Mountain Power project, and the East Kentucky Spurlock plant.

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4.3.11 Catalytic Absorption/Oxidation (SCONOx™)
SCONOx™ is a control technology that has been applied in combustion turbine and industrial
applications. However, this technology has never been demonstrated on solid fuel-fired boilers. ABB
Alstom Power purchased a proprietary technology called SCONOx™ from Goal Line Environmental
Technologies. A SCONOx system has been in operation since December of 1996 on the 30 MW Sun
Law Energy Federal cogeneration plant in Vernon, California. Since August of 1999, SCONOx has been
in operation on a 5 MW cogeneration plant at Genetics Institute in Andover, Massachusetts. ABB
Alstom Power subsequently completed design of a scaled-up SCONOx system for 100 MW and greater
combined cycle gas turbines.
The SCONOx system is based on a proprietary catalytic oxidation and absorption technology. In
operation, NO and CO are first oxidized to NO2 and CO2. Next, NO2 is adsorbed onto an adsorption
media. When the media is saturated, NO2 is desorbed and treated by the proprietary catalyst. Because the
operation of SCONOx to oxidize CO to CO2 is identical to the simple use of an oxidation catalyst, there is
effectively no difference between SCONOx and an oxidation catalyst in terms of CO and VOC control.
Therefore, SCONOx and an oxidation catalyst are effectively the same technology for controlling CO and
VOC emissions.
To date, SCONOx has only been installed on small scale natural gas-fired combustion turbines.
Therefore, this technology is not technically feasible for solid fuel and biomass-fired boilers.
4.3.12 Emerging Control Technologies.

Emerging technologies to reduce NOx emissions include Enviroscrub, Powerspan’s Electro-Catalytic
Oxidation (ECO™) scrubber, and the NOxStar and Cascade processes. Enviroscrub and ECO are
emerging technologies with the potential to reduce NOx emissions and potentially other pollutants as well.
However, these technologies are either not yet commercially available or are not proven with a long term
demonstrated level of performance. The most advanced process is the ECO system. ECO™ is an
emerging post-combustion multi-pollutant control technology including NOX control and has
demonstrated performance, reliability and economics through testing at a pilot plant. However, no full
size commercial scale ECO™ systems have been installed or operated.
Enhanced and hybrid SNCR and SCR systems that are emerging NOx control technologies include
NOxStar and Cascade. NOxStar is a hydrocarbon enhanced SNCR system that injects hydrocarbons
downstream of an SNCR system to produce radicals that will further reduce NOx emissions. The Cascade
process is a hybrid combination of SNCR and SCR systems. A small section of expanded ductwork
holding SCR catalyst is located downstream of an SNCR system to reduce NOx emissions to levels that
potentially could be comparable with full size SCR systems. This system does not require the significant
capital investment or installation space of a full size SCR system. Neither of these systems has
demonstrated long term levels of performance, and neither of them has been demonstrated on a full scale
boiler. Due to lack of experience and a proven record of commercial operation, these emerging control
technologies are not technically feasible for NOx control for this boiler.

- 35 -
4.3.13 Summary of the Technically Feasible Controls.
Table 4-2 is a summary of the technical feasibility of the NOx controls for the biomass-fired boiler.
TABLE 4-2. Summary of the technical feasibility of retrofit NOx control technologies.
Technical
Technology
Feasibility
Low NOx Burners (LNB) No Cannot be applied to fluidized bed boilers.
OFA is an inherent design feature of all

Overfire Air (OFA) Yes
fluidized bed boilers.
FGR is not technically feasible for fluidized bed
Flue Gas Recirculation (FGR) No
boilers.
Oxygen Enhanced Combustion No Never applied to a fluidized bed boiler.
Natural Gas or Coal Reburn No Never applied to a fluidized bed boiler.
Selective Non-Catalytic SNCR is commonly used on fluidized bed

Yes
Reduction (SNCR) boilers.
Selective Catalytic Reduction High dust SCR has not been used on a fluidized
No
(SCR) – High Dust Arrangement bed boilers.
Selective Catalytic Reduction Standard catalyst with gas reheat is technically
Yes
(SCR) – Low Dust Arrangement feasible. Low temperature catalyst is infeasible.

- 36 -
4.4.1 Circulating Fluidized Bed Boiler.

A circulating fluidized bed boiler has inherently low NOx emissions. Based on vendor information, the
NOx emission rate from this advanced fluidized bed boiler firing biomass without post combustion
controls will be 0.15 lb/mmBtu. This “uncontrolled” NOx emission rate is 30 – 50% less than the
uncontrolled NOx emission rate for stoker boilers firing biomass fuels.
4.4.2 Selective Catalytic Reduction (SCR).

Tailgas SCR systems can be designed for control efficiencies of 90%. However, SCR cannot be expected
to achieve this high level of control on a continuous basis, especially on a CFB boiler which already has
low uncontrolled NOx emissions. For this CFB boiler, a tailgas SCR system is expected to achieve a NOx
emission rate of 0.06 lb/mmBtu, equal to an 60% reduction from the uncontrolled boiler emission rate.
4.4.3 Selective Non-Catalytic Reduction (SNCR).

As noted above, the U.S. EPA estimates SNCR control efficiencies of 25 – 40%. This control range is
supported by other more recent EPA analyses. For example, in the U.S. EPA’s Updates to EPA Base
Case 2009 ARRA Using the Integrated Planning Model (IPM)- Addendum, EPA provides estimated
capital and annual operating costs for SNCR design removal efficiencies of 35% and 50%. It is important
to note that the SNCR effectiveness can be reduced dramatically during low load operation of CFB
boilers. The typical CFB bed temperature ranges from 1,500 – 1,650 oF. At low loads, the fluidized bed
temperature can approach or drop below the minimum SNCR operating temperature of approximately
1,600 oF. For this CFB boiler, SNCR is expected to reduce NOx emissions by 33% to 0.10 lb/mmBtu.
Table 4-3 is a summary of the ranking of the technically feasible NOx control technologies for the
proposed CSHP biomass-fired boilers.
TABLE 4-3. Ranking of the technically feasible NOx control technologies for the biomass boiler.
Expected Emission Rate,

Control System
lb/mmBtu
Circulating Fluidized Bed Boiler with
0.06
Tailgas or Regenerative Selective Catalytic Reduction (SCR)
0.10
Selective Non-Catalytic Reduction (SNCR)
0.15
Good Combustion Practices

- 37 -
4.5 STEP 4. Evaluate the Most Effective Controls
4.5.1 Rank No. 1: Selective Catalytic Reduction.
Environmental and Energy Impacts.

The use of a tail gas SCR can achieve a NOx emission rate of 0.06 lb/mmBtu for this biomass-fired boiler.
Based on a capacity factor of 88% and the resulting uncontrolled emissions, a SCR system could reduce
NOx emissions from this boiler by 278 tons per year, (from 463 to 185 tons per year).
Although the use of a tailgas SCR system can achieve very low NOx emission rates, SCR would have
other adverse environmental and energy impacts. First, SCR can have significant environmental impacts
related to the on site handling and storage of ammonia.
In addition, ammonia slip emissions from the operation of even a state-of-the-art SCR system would
result in direct emissions of ammonia and ammonium nitrate. Ammonia released to the atmosphere will
react with sulfate in the atmosphere to form ammonium sulfate. Together, ammonium sulfate and
ammonium nitrate are sources of regional haze and PM2.5. Because the only feasible SCR control option
is a tailgas system, there is no possibility of controlling ammonia slip emissions. Typical levels of
ammonia slip are expected to be as much as 10 ppmv, equal to an emission rate of 0.0059 lb/mmBtu:
E = ChKF (20.9)
20.9- %O2
where, E = NH3 Emission rate, lb/mmBtu
Ch = NH3 concentration = 10 ppmdv
F = dscf/mmBtu = 9,780 dscf/mmBtu
%O2 = Oxygen concentration = 5.0%
K = 4.61 x 10-8 lb/dscf-ppm NH3
Energy impacts from the application of the technology would include an electricity penalty from the
increase in pressure drop across the system. In addition, the tailgas SCR system would require flue gas
reheat. From Attachment 1, the reheat requirement would consume 38 million cubic feet per year of
natural gas, or a total annual natural gas heat input of 40,000 mmBtu per year. This is enough natural gas
to heat approximately 300 homes each year. In addition, the combustion of this natural gas would result in
non-renewable CO2 emissions of 2,200 tons per year.
Economic Impacts.
The costs for SCR on this boiler will include capital costs for the SCR and ancillary equipment. Included
in the capital costs would be the costs for an air to air heater to preheat the flue gas with the heated gases
leaving the SCR system. In addition, an SCR system will have substantial operating costs, including
reagent (ammonia) costs, natural gas reheating costs, labor, auxiliary power requirements, catalyst

- 38 -
replacement costs, maintenance costs, and administrative costs. The natural gas costs required to reheat
the flue gas, based on 2010, natural gas costs, is $190,000 per year.
Table 4-4 includes a summary of the SCR costs and the estimate of control costs. A detailed cost
analysis is included in Attachment 1. The SCR system is expected to have a total capital cost of $14.2
million, an annual O&M cost of $1.3 million, and a total annual cost of $2.9 million. From Table 4-4, the
tailgas SCR system would reduce NOx emissions by 278 tons per year at an annual capacity factor of
88%. This results in an average cost effectiveness for the tailgas SCR system of $10,300 per ton of NOx
controlled.
In addition, the use of an SCR system would have an increased incremental cost of $1.8 million per year
as compared to the use of SNCR. The SCR system would reduce NOx emissions by 123 tons per year as
compared to the use of SNCR. This would result in an incremental cost effectiveness of SCR, as
compared to SNCR, of $14,960 per ton of NOx controlled.
Conclusions.
The use of a tail gas SCR can achieve NOx emission rates of 0.06 lb/mmBtu for this biomass-fired boiler.
Based on an actual annual capacity factor of 88%, and the resulting uncontrolled emissions from the CFB
boiler, the SCR system could reduce NOx emissions by 278 tons per year (from 463 to 185 tons per year).
However, the use of SCR would have other adverse environmental, energy, and economic impacts. The
tailgas SCR system would also consume 38 million cubic feet per year of natural gas, or a total annual
natural gas heat input of 40,000 mmBtu per year. This is enough natural gas to heat approximately 300
homes each year. In addition, the combustion of this natural gas would result in non-renewable CO2
emissions of 2,200 tons per year.. The use of a tailgas SCR system would also have significant economic
impacts. The tailgas SCR system would have a total capital cost of $14.2 million, a total annual cost of
$2.9 million, and an average cost effectiveness of $10,300 per ton of NOx controlled. Based on the high
costs for a tail gas SCR system, tailgas SCR is not an economically feasible control technology for this
biomass-fired boiler.
Because of the significant, adverse economic and environmental impacts, SCR does not represent BACT
for this biomass fuels-fired CFB boiler.

- 39 -
TABLE 4-4. Cost effectiveness of the NOx control technology options for the biomass-fired boiler.
CFB Boiler
Parameter Tailgas SCR SNCR
Only
Control Efficiency 60% 33% 0%
Controlled Emission Rate, lb/mmBtu 0.06 0.10 0.15
Total Boiler Heat Input, mmBtu 800 800 800
Actual Annual Capacity Factor, % 88% 88% 88%
Actual NOx Emissions, tons per year 185 308 463
Total Capital Requirement, $ $14,273,400 $4,500,000 $0
Capital Recovery Factor (CRF) 0.1098 0.1098 0.1098
Annual Capital Cost, $/yr $1,567,100 $494,100 n/a
Annual O&M Cost, $/yr $1,292,100 $519,900 n/a
Total Annual Cost, $/yr $2,859,200 $1,014,000 $0
Average Annual Cost, $/yr $2,859,200 $1,014,000
Average NOx Reduction, tons per year 278 154
Average Cost per Ton Reduced, $ per ton $10,300 $6,580
Incremental Annual Cost, $/yr $1,845,200
Incremental NOx Reduction, tons per year 123
Incremental Cost per Ton Reduced, $ per ton $14,960
Footnotes
1. "Annual Capital Cost" is calculated by multiplying the capital recovery factor (CRF) by the Total Capital
Requirement as detailed in the U.S. EPA's Air Pollution Control Cost Manual – 6th Edition (EPA 452/B-02-001):
i (1 + i ) n
CRF =
[ ]
where:
(1 + i ) n − 1 i = annual interest rate = 7.0%
n = project life, years = 15
2. The total annual cost is the sum of the annual capital costs and annual O&M costs.
3. "Average Reduction" is the emissions of the uncontrolled boiler minus the emissions of the control option.
4. "Average Cost per Ton Reduced" is the Average Annual Cost of the control option divided by the Average PM
reduction of the control option:
Control option annual cost
Average Cost Effectiveness ($ per ton removed) =
Baseline emission rate – Control option emissions rate
5. "Incremental Annual Cost" is the Total Annual Cost of the control option minus the Total Annual Cost of the
next most effective control option.
6. "Incremental Reduction" is the Potential Emission Rate of the next most effective control option minus the
Potential Emission Rate of the control option.
7. "Incremental Cost per Ton Reduced" is the Incremental Annual Cost of the control option divided by the
Incremental PM reduction of the control option:
Control option annual cost – Next control option annual cost
Incremental Cost ($ per ton removed) =
Next control option emission rate – Control option emissions rate

- 40 -
4.5.2 Rank No. 2: Selective Non-Catalytic Reduction.

The use of a circulating fluidized bed boiler with inherently low NOx emissions combined with SNCR can
achieve NOx emission rates of 0.10 lb/mmBtu for the biomass-fired boiler. Based on a capacity factor of
88% and the resulting uncontrolled emissions, the use of SNCR could reduce NOx emissions by 154 tons
per year (from 463 to 308 tons per year).
As with SCR, the use of SNCR may have environmental impacts related to the on-site handling and
storage of ammonia. In addition, the use of ammonia would result in ammonia slip emissions which
would result in direct emissions of ammonia and ammonium nitrate. However, while SNCR requires
higher levels of ammonia injection to achieve NOx reductions than does an SCR system, the point of
injection for the SNCR system is before the fabric filter baghouse. Therefore, ammonia slip emissions are
reduced by reactions with flyash in the fabric filter baghouse.
Economic Impacts.
The costs for SNCR on this boiler will include the capital costs for the SNCR system, and operational
costs. These costs are summarized in Table 4-4. The use of SNCR is expected to have a total capital cost
of $4.5 million, annual O&M costs of $494,000, and a total annual cost of $1,014,000. The annual capital
cost is based only on the ammonia reagent costs. From Table 4-4, SNCR would reduce NOx emissions by
154 tons per year at an 88% annual capacity factor. This results in an average cost effectiveness for
SNCR of $6,580 per ton of NOx controlled.
Conclusions.
The use of a circulating fluidized bed boiler with inherently low NOx emissions combined with SNCR can
achieve NOx emission rates of 0.10 lb/mmBtu for the biomass-fired boiler. Based on a capacity factor of
88% and the resulting uncontrolled emissions, the use of SNCR could reduce NOx emissions by 154 tons
per year. However, as with SCR, the use of SNCR may have environmental impacts related direct
emissions of ammonia and ammonium nitrate. The use of SNCR would also have significant economic
impacts. SNCR would have a total annual cost of $1,014,000 and an average cost effectiveness of $6,580
per ton of NOx controlled. Although this is a high cost, We Energies considers this cost to be achievable.

- 41 -
4.6 STEP 5. Proposed Nitrogen Oxide BACT Determination.
Based on this analysis, We Energies has concluded that the use of a circulating fluidized bed boiler with
inherently low NOx emissions combined with selective non-catalytic reduction (SNCR) is the best
available control technology (BACT) for NOx emissions from the biomass fuels-fired boiler. Based on
this analysis, We Energies proposes the following limits as BACT for the control of NOx emissions from
the biomass fuels-fired CFB boiler.
(1) Nitrogen oxide (NOx) emissions from the biomass fuels-fired CFB
boiler B01 shall be controlled using a circulating fluidized bed boiler
and selective non-catalytic reduction as the best available control
technology.
(2) Nitrogen oxide (NOx) emissions may not exceed 0.10 pounds per
million Btu of heat input, excluding periods of boiler startup and shut
down, averaged over any consecutive 30-day period.
(3) Nitrogen oxide (NOx) emissions may not exceed 0.10 pounds per
million Btu of heat input, for all periods, including periods of boiler
startup and shut down, averaged over any consecutive 12-month period.
(4) Nitrogen oxide (NOx) emissions from the biomass-fired boiler B01
shall be continuously monitored and recorded using a continuous
emissions monitoring system meeting the requirements of 40 CFR Part
60 Appendix B, and NR 439.06(4), Wis. Adm. Code.

- 42 -
Chapter 5. Particulate Matter and PM10
Particulate matter (PM) emissions from solid fuel-fired boilers originate from ash in the fuel, non
combustible material in the limestone, from products of incomplete combustion, and from the reaction
products in flue gas desulfurization systems. In Wisconsin, “particulate matter emissions” are defined
under NR 400.02(119), Wis. Adm. Code, as:
(119) “Particulate matter emissions” means all finely divided solid or liquid material, other than
uncombined water, emitted to the ambient air as measured by an applicable reference method or
an equivalent or alternative method specified by the department.
Based on this definition, PM may be solid or liquid materials. PM which exists as a solid or liquid at
temperatures of approximately 250 oF are measured using U.S. EPA’s Reference Method (RM) 5, and are
referred to as “front half” emissions. Particulate matter which exists as a solid or liquid at the lower
temperature of 32 oF are measured using U.S. EPA’s RM 202, and is commonly referred to as “back half”
or “condensable” PM. Condensable PM may include acid gases, volatile organic compounds (VOC) and
other materials, but by definition does not include condensed water vapor. Because of these different
temperatures at which PM emissions are measured, the amount of PM measured from a source will
depend upon the reference methods used.
The measurement of particulate matter under the Standards of Performance for New Stationary Sources,
40 CFR § 60.50Da(b)(2), and NR 440.20(8)(b)2. require the use of only Reference Method 5 for facilities
without wet FGD systems or a variation of this method, Method 5B, for facilities with wet FGD systems.
This is the method required by many states which have approved coal-fired boilers listed in the RBLC.
However, Wisconsin requires the use of both Reference Methods 5 and Reference Method 202 for
demonstrating compliance with PM emission limits. Since the federal NSPS standards and many states
require only Reference Method 5 (or 5B) for demonstrating compliance, the direct comparison of
emission limits required in other states is not always appropriate. In other words, an emission limit
requiring both Reference Methods 5 and 202 would be more stringent than an equivalent limit that
requires only Reference Method 5.
5.1 Reference Method 202 and Artifact Formation.

The measurement of PM using RM 202 is further complicated by the well documented problem of
particulate matter formation in the sample train. The intimate contact of water with flue gas in the sample
train as shown in the following figure can actually create sulfate, nitrate, and silica “artifacts” by
converting gaseous pollutants to solids or liquids in the sampling equipment. This phenomenon creates
condensable particulate matter in the sample train and results in a positive bias indicating more

- 43 -
condensable PM than is actually emitted. In developing Reference Method 202, the U.S. EPA recognized
the potential for artifact formation due to the oxidation of SO2 to SO3 in the sampling equipment7. To
address this issue, Method 202 includes a post-test nitrogen (N2) purge for sources emitting SO2. This
procedure is intended to remove dissolved SO2 from the sample before it can react to form sulfuric acid.
Unfortunately, as the referenced papers indicate, this procedure is not effective in removing dissolved SO2.
FIGURE 5-1. Reference Method 5 and Method 202 sample train.
Stack and Flue Temperature

Gas Flow Sensor
Check Valve
Sampling Heated, Glass Impingers in Ice Bath
Nozzle Lined Probe
To Vacuum
Pump and
Gas Meter
Reference Method 5
Glass Filter Holder
Heated Area:
250 - 300 F
Water in Impingers and

Method 202 Sample
RTP Environmental Associates, Inc.
Reference Method 202 involves evaporating the collected material, mostly water, to a constant end weight.
However, the procedure recognizes that a constant end weight may not be possible if sulfuric acid is present.
Since sulfuric acid is hydroscopic, the sample will begin to increase in weight as soon as the sample is taken
from a dryer into a room with ambient moisture. As a result, Method 202 includes a procedure for titrating
7
Technical papers published regarding this problem including the following:
A. D. Williamson and K. W. Baughman, Southern Research Institute, Study of Chemical Species Formed in
Method 202 Sampling at a Coal Fired Power Plant, Final Report, February 18, 1992.
E. J. Filadelfia (Carnot) and M. D. McDannel (Fossil Energy Research Corporation), Evaluation of False
Positive Interference’s Associated with the Use of EPA Method 202, Presented at the 89th Annual Meeting of
the Air & Waste Management Association, June 23-29, 1996.
B. Nott, Electric Power Research Institute, Measurement of Condensable Particulate Matter, TR-111327, Final
Report, September, 1998.
L. A. Corio (Versar, Inc) and J. Sherwell (Maryland Dept. of Natural Resources), In-Stack Condensable
Particulate Matter Measurements and Issues, Journal of the Air & Waste Management Assn., February, 2000.
Other papers include DeWees et al., 1989, US EPA, 1996, and Wien et al., 2001.

- 44 -
the sample with ammonium hydroxide to convert the sulfuric acid to ammonium sulfate. Paragraph 5.3.2.4
specifies procedures for the analysis of sulfate in the sample for purposes of determining the weight of
ammonium ion (NH4+) that must be subtracted to account for the added substance. Unfortunately, Method
202 does not include any other methods or procedures for preventing artifact formation, nor does it
include any procedures for quantifying artifacts and subtracting that amount from the total.
5.2 Other Test Method 28.

To address these concerns, on April 15, 2009, the U.S. EPA approved Other Method 28, Dry Impinger
Method For Determining Condensable Particulate Emissions From Stationary Sources. The modified
sample train is shown in Figure 4-2. This sample train avoids the intimate contact of water with flue gas
in the impingers, reducing formation of artifact formation in the sampling train.
FIGURE 5-2. Reference Method 5 and Other Method 28 sample train.
Stack and Flue Temperature

Gas Flow Sensor
Sampling Heated, Glass

Nozzle Lined Probe
Condenser CPM Filter
Check Valve
Reference Method 5
Glass Filter Holder To Vacuum
Pump and
Gas Meter
Heated Area:
250 - 300 F
Recirculating Impingers in
Pump Ice Bath
Empty Impingers
5.3 Particulate Matter and PM10

Particulate matter emissions may also be defined by particle size. Often particulate matter emissions are
referred to as PM which includes all sizes of particulate matter emissions. Particulate matter less than 10
microns in diameter is called PM10 and include condensable PM by definition. To address this, some
permits have established a PM limit that does not include condensable material (i.e., filterable PM only),
and a PM10 limit, significantly larger than the PM limit, that includes both the filterable and condensable
matter. Many permit emission limits have begun to specify whether or not the emission limit includes
condensable particulate. Where the limit does include condensable particulate, the emission limits have
risen in recent years to recognize the contribution of both the filterable and condensable portion of the
particulate.

- 45 -
More is being learned as test results using Method 202 become available from boilers required to meet
very stringent emission limits using Method 202. As information has been gathered and analyzed
regarding the contribution of condensable material, the emission limits have either increased, or two
limits have been required; one for filterable and one for combined filterable plus condensable PM10.
5.4 Basis for Evaluating PM Limits.

Based on the above discussion, PM emissions will be evaluated based on the following convention:
PM Emissions will refer to only front half or filterable PM emissions measured in
accordance with U.S. EPA Reference Method 5 or 5B.
PM10 Emissions will refer to both front half or filterable PM emissions measured
in accordance with U.S. EPA Reference Method 5 or 5B, in combination
with back half or condensable emissions measured in accordance with U.S.
EPA Reference Method 202 or other approved method.
5.5 BACT Baseline.

The proposed new biomass fuels-fired CFB boiler will be subject to the Standards of Performance for
Industrial-Commercial-Institutional Steam Generating Units under 40 CFR Part 60, Subpart Db. This
subpart applies to steam generating units that commence construction, modification, or reconstruction
after June 19, 1984, and that has a heat input capacity from fuels combusted in the steam generating unit
greater than 100 mmBtu/hr. The current Subpart Db rules for PM emissions were published in the
Federal Register June 13, 2007. Under 40 CFR § 60.43b(h)(4), an affected facility that commences
modification after February 28, 2005, that combusts over 30 percent wood (by heat input) on an annual
basis, and has a maximum heat input capacity greater than 250 mmBtu/hr may not exceed a PM emission
rate of 0.085 lb/mmBtu heat input. The PM emission standards and opacity limits under § 60.43b apply
at all times except during periods of startup, shutdown, or malfunction. Compliance with the PM emission
standards under § 60.43b are determined through performance testing using Reference Method 5, 5B, or
17. Note that this standard does not include condensable PM emissions.
5.6 STEP 1. Identify Potential Control Technologies.

Table 5-1 is a summary of particulate matter BACT emission limits for both new and modified biomass-
fired boilers contained in the U.S. EPA’s RACT/BACT/LAER Clearinghouse. The technologies selected
include fabric filter baghouses and electrostatic precipitators. Other controls include mechanical
collectors such as multicyclones, and wet venturi scrubbers. Emission limits range from 0.012 to 0.10
pounds per million Btu. From Table 5-1, the most stringent emission limit is 0.01 lb/mmBtu for the
Yellow Pine Energy Company in Georgia. The emission limit for the South Point Biomass Generation
facility is based on a baghouse outlet grain loading of 0.004 gr/dscf. According to the permit to install
(condition A.V.2.), compliance with this limit is based on Method 5 of 40 CFR Part 60.

- 46 -
TABLE 5-1. Biomass-fired boiler particulate matter/PM10 BACT emission limits.
Limit,
Permit Capacity, Primary Control lb/mmBtu
Facility State
Date mmBtu/hr Fuel System
PM PM10
Yellow Pine Energy Company GA May-09 1,529 Wood FFB 0.01 0.018
South Point Biomass Generation OH Apr-06 318 Wood FFB 0.012 None
Wood /
Mancelona Renewable MI Nov-09 565 FFB 0.012 0.025
Biomass
Northern Michigan University MI Nov-09 210 Wood FFB 0.0125 0.025
Nacogdoches Power, LLC TX Mar-07 1,374 Wood FFB 0.015 0.032

Darrington Energy Cogeneration Wood /
WA Feb-05 403 ESP None 0.02
Power Plant Bark
Wood /
Skagit County Lumber Mill WA Jan-06 430 ESP None 0.02
Bark
Poultry
Fibrominn Biomass Power Plant MN Feb-05 792 FFB 0.02 Test2
Litter
Pub Service of New Hampshire -
NH Oct-04 720 Wood FFB 0.025 None
Schiller Station
Virginia PWC - Laurention Energy
MN Aug-05 230 Wood ESP 0.025 0.025
Authority
Wood /
Hillman Power MI Jul-02 300 ESP 0.026 None
TDF
District Energy St. Paul, Inc. MN Nov-01 550 Wood ESP 0.03 0.03
S.D. Warren Co. - Skowhegan, Me ME Nov-01 1,300 Wood ESP 0.03
Boralex Stratton Energy, LP ME 672 Wood ESP 0.03

Wheelabrator Sherman Energy
ME Apr-99 315 Wood ESP 0.036
Company
Wood /
Koda Energy MN Aug-07 308 ESP 0.037 0.01
NG
Stoneman Power Plant WI Jan-09 340 Wood ESP 0.06 0.06
Wood /
Northern Sun ND May-06 100 ESP 0.08
Hulls
Meadwestvaco Kentucky,
KY Feb-02 631 Wood ESP 0.10
Inc/Wickliffe
Footnotes
1. The first limit is for PM or front half emissions; the second limit is for total PM10 emissions or the combined
front and backhalf emissions. Note that many permits only specify the front half emissions.
2. For the Fibrominn biomass-fired boiler, the permit requires the permittee to conduct performance tests for total
condensable PM emissions and propose a limit based on the test results.

- 47 -
As noted above, data from the U.S. EPA’s RBLC indicate that the technologies selected as BACT include
primarily fabric filter baghouses and electrostatic precipitators. Other controls include mechanical
collectors such as multicyclones, and wet venturi scrubbers.
5.7.1 Fabric Filter Baghouses.

A fabric filter baghouse (FFB) separates dry particles from the boiler flue gas by filtering the flue gas
through fabric filters or “bags”. The components of a FFB include the fabric filters, a tube sheet to
support the bags, a gas-tight enclosure, a mechanism to clean accumulated PM from the bags, and a
hopper to collect accumulated ash. Baghouses are compartmentalized to facilitate cleaning and to provide
for maintenance and repair. When the pressure drop across a compartment increases to a specified limit,
the accumulated PM is removed by placing that compartment in the cleaning mode.
PM laden flue gas enters the FFB and passes through the bags. As the flue gas flows through the fabric
filter, a layer of collected material, called the “filter cake”, builds up on the fabric. In an FFB, the
primary filtering media is actually the filter cake rather than the fabric itself. The filter cake acts much
like a fixed-bed reactor, contributing to greater absorption of pollutants, including sulfur dioxide (SO2),
sulfuric acid mist, mercury and hazardous air pollutants including hydrogen chloride (HCl) and hydrogen
fluoride (HF). A depiction of the mechanism for particulate removal is shown in Figure 5-3.
FIGURE 5-3. Depiction of the flue gas flow through the fabric filter baghouse filter cake showing
the mechanism for particulate collection.
Dust Laden Cleaned Flue Gas

Flue Gas to Atmosphere
Layer of Collected Bag Fabric

Ash or "Filter Cake"

- 48 -
FFB have several methods for cleaning, including reverse gas (RGFFB), reverse air with mechanical
shakers, and pulse jet (PJFFB). In a RGFFB, the fly ash is collected on the inside of the bags. Each
compartment of a RGFFB is periodically taken out of service for cleaning by circulating clean flue gas
from the outlet plenum backward through the offline compartment. This dislodges the collected dust,
which falls into hoppers. In a PJFFB, the fly ash is collected on the outside of the bags. Cleaning is
normally accomplished on line by directing a pulse of air backward through the bag. The air pulse
dislodges the fly ash, which falls into hoppers.
A PJFFB can operate at higher air-to-cloth ratios than a reverse gas system. This means that a PJFFB can
be smaller and therefore usually has lower capital costs than a RGFFB. However, because the pulse jet
cleaning method is more aggressive than in the RGFFB, the bags in a RGFFB may have a longer service
life.
FFBs have several advantages when used for PM control from coal-fired boilers, including:
• High particulate matter control efficiencies.
• Relatively constant outlet grain loading over the entire boiler load range.
• Simple operation and maintenance.
The primary disadvantage of fabric filter baghouses is the relatively high pressure drop across the
baghouse as compared to a dry ESP and the resulting increased fan power requirements.
5.7.2 Dry Electrostatic Precipitators.

Electrostatic precipitators (ESP) are a common PM control system for both coal and biomass-fired
boilers. An ESP uses a large enclosure to slow the gas stream, which allows more time to electrostatically
charge particulates and collect them in the ESP. An ESP is arranged in a series of fields which consist of
negatively charged discharge electrodes and positively charged collection plates. The discharge
electrodes impart a negative charge to particles in the gas stream. The negatively charged particles then
migrate to the larger positively charged plates. PM collected on the plates is periodically removed by
rapping the plate. Most of the PM knocked off the plates falls into collection hoppers for removal. A
portion of the collected PM is re-entrained in the gas stream during rapping. This re-entrained PM is
normally collected in subsequent sections of the ESP.
ESP’s may be located either upstream of the air heater (hot-side ESP) or downstream of the air heater
(cold-side ESP). The location is selected to achieve the best PM resistivity8 conditions. Most modern
ESPs are cold-side ESPs.
8
Gas composition and temperature and particle composition all influence resistivity, which is a measure
of the ability of a particle to retain an electrostatic charge. The ability to collect particles using
electrostatic attraction is directly related to particle resistivity. If the particle resistivity is outside the
design range, particle collection efficiency is reduced.
- 49 -
Factors affecting the PM collection efficiency of an ESP include flue gas flow rate through the ESP, total
plate area, PM resistivity, voltage, and the sectionalization of the ESP. The smaller the collection area of
the ESP, the narrower the acceptable resistivity range becomes. To optimize particulate resistivity and
maximize collection efficiency, many ESPs utilize a sulfur trioxide (SO3) injection system to condition
the ash and reduce particulate resistivity. In addition, modern ESP controls allow the ESP operation to be
optimized to maximize PM control through overall ESP performance management, power optimization,
and programmed cleaning cycles. Finally, good sectionalization of the ESP is important to maximize
ESP performance and reliability.
5.7.3 Wet Electrostatic Precipitators.

The principle of operation of a wet ESP is similar to a dry ESP. Particulate matter in the flue gas is
exposed to an electric field which induces a charge on the particle which is then drawn to an oppositely
charged collection electrode. However, in a wet ESP, the flue gas is cooled below the dew point and
consequently particulate matter may be present as either solid or liquid particles. A recent application of
wet ESPs is downstream of a wet FGD for the control of sulfuric acid mist on large, utility scale boilers
firing high sulfur eastern coals. In this application, the flue gas temperature is below the sulfuric acid and
water saturation temperatures as it passes through the wet ESP. As such, water droplets and other
condensable materials in the flue gas, including sulfuric acid, are charged and collected by the ESP plates.
Filterable PM not entrained from the FGD system may also be collected in the wet ESP. The collection
electrodes are either continuously or periodically flushed with water to remove collected materials.
Although wet ESPs can be effective for removing sulfuric acid mist downstream of a wet FGD when
firing high sulfur coals, wet ESPs cannot be used as the primary PM collection devices for biomass-fired
boilers because the PM loading is too great for effective operation. Wet ESPs experience current
suppression when particulate concentrations in the electrode wash water are too high which would reduce
or eliminates the PM control effectiveness of the wet ESP. Therefore, a wet ESP must be considered as a
secondary or “polishing” PM control device for boilers.
5.7.4 Wet Scrubbers.

Wet scrubbers are used in many industrial processes to control PM emissions. Wet scrubbers reduce PM
emissions through several mechanisms, including condensation, inertial impaction of PM with water
droplets, and reactions of PM and PM precursors with the scrubber reagent.
5.7.5 Mechanical Collectors.

Mechanical collectors are not as effective as a FFB or ESP for particulate matter control. Therefore,
while mechanical collectors are a technically feasible BACT alternative, the performance of mechanical
collectors is inferior to FFBs and ESPs.

- 50 -
5.8 STEP 3. Rank the Technically Feasible Technologies.
All of the identified PM control technologies, including fabric filter baghouses, dry ESPs, wet ESPs, wet
scrubbers, and mechanical collectors are technically feasible technologies. However, wet ESPs cannot be
used as the primary control device. Therefore, wet ESPs are not considered technically feasible in this
analysis.
Table 5-2 is a summary of the ranking of the expected performance of the PM control technologies. The
performance is stated in ranges, since the specific performance is dependent on the boiler firing type and
fuels fired. In general, fabric filters are expected to have the best performance for the control of both
filterable and especially condensable PM.
TABLE 5-2. Ranking of the technically feasible PM control technologies for the biomass-fired
boiler.
Expected Performance, lb/mmBtu

Rank Control System
PM PM10
1 Fabric Filter Baghouse 0.015 0.03
2 Dry ESP 0.02 0.035
3 Venturi Scrubber 0.05 0.07
4 Mechanical Collectors 0.15 0.30
5.9.1 Rank No. 1: Fabric Filter Baghouse.

Based on the ranking summarized in Table 5-2, a fabric filter baghouse is expected to have the greatest
potential to reduce both filterable and condensable particulate matter emissions from the biomass-fired
Boiler B01. Based on this analysis, We Energies proposes to utilize a fabric filter baghouse for this
boiler. Therefore, further analysis is not necessary.

- 51 -
5.10 STEP 5. Proposed Filterable Particulate Matter and PM10 BACT
Determination.
Based on this analysis, We Energies has concluded that the use of a fabric filter baghouse is the best
available control technology (BACT) for particulate matter and PM10 emissions from the biomass fuels-
fired CFB boiler. Based on this analysis, We Energies proposes the following limits as BACT for the
control of particulate matter and PM10 emissions from the biomass-fired, circulating fluidized bed boiler.
(1) Particulate matter and PM10 emissions from the biomass fuels-fired
circulating fluidized bed boiler shall be controlled using a fabric filter
baghouse as the best available control technology.
(2) Particulate matter and PM10 emissions may not exceed 0.03 pounds per
million Btu of heat input, excluding periods of startup and shut down.
(3) Compliance with this emission limit shall be based upon the
measurement of particulate matter emissions in accordance with U.S.
EPA Reference Method 5, 5B, or 17, and U.S. EPA Other Method 28, or
another method approved in writing by the department.

- 52 -
Chapter 6. PM2.5 Control Technology
Review.
Particulate matter emissions that are less than 2.5 micrometers in diameter are known as "fine" particles,
and are referred to as PM2.5. Various pollutants may contribute to ambient PM2.5 concentrations. Natural
gas and biomass fuel combustion results in direct emissions of PM2.5, as well as PM2.5 “precursors”.
PM2.5 precursors may also result in the formation of PM2.5 in the atmosphere. The U.S. EPA has
identified SO2, NOx, organic compounds (VOCs), and ammonia (NH3) as PM2.5 precursors. These gas-
phase precursors undergo chemical reactions in the atmosphere to form secondary PM2.5. Direct emissions
of PM2.5 from combustion include solid or filterable PM2.5, and condensable or back half PM2.5.
Under the recently promulgated rules to revise the New Source Review (NSR) program in 40 CFR Part
52 to include PM2.5, the EPA identified the following PM2.5 pollutants, and their significant levels:
1. 10 ton per year of direct PM2.5 emissions

2. 40 ton per year of SO2 emissions
3. 40 ton per year of NOx emissions unless demonstrated not to be a PM2.5 precursor.
Based on the final rules, VOC and ammonia may not be considered to be PM2.5 precursors unless the
State demonstrates that these emissions are a significant contributor to the area PM2.5 concentrations. In
addition, during the PM2.5 SIP development period, the EPA has indicated that NOx emissions will not be
regulated as a PM2.5 precursor to give States the opportunity to determine whether NOx emissions are a
significant contributor to the ambient PM2.5 problem (Fed. Reg., Friday, May 16, 2008, page 28343).
6.1 BACT Baseline.

There are no state implementation plan emission limits or new source performance standards for direct
PM2.5 emissions from this biomass-fired boiler.
Direct PM2.5 emissions from the combustion of biomass fuels include filterable PM2.5, and condensable
PM2.5. The U.S. EPA’s Compilation of Air Pollutant Emission Factors, AP-42, 5th Edition, Table 1.1-6
includes cumulative particle size distribution data for coal combustion. According to this table, one-half
of the filterable PM emissions from coal-fired boilers controlled by fabric filter baghouses may be PM2.5.
While this boiler will fire biomass fuels, this particle size distribution data for the fabric filter baghouse is
a reasonable estimate for biomass combustion. For this analysis, all of the condensable PM emissions are
considered PM2.5. Based on the proposed PM (filterable) and PM10 (filterable plus condensable) BACT
emission limits of 0.015 and 0.03 lb/mmBtu, respectively, the PM2.5 emission rate would be:
EPM2.5 = ½ x (0.015) + (0.03 – 0.015) = 0.0225 lb/mmBtu

- 53 -
6.2 STEP 1. Identify All Potential Control Technologies.
6.2.1 Direct PM2.5 Emissions.

For PM and PM10, the technologies selected as BACT include primarily fabric filter baghouses and
electrostatic precipitators. Other controls include mechanical collectors such as multicyclones, and wet
venturi scrubbers. Note that from the above analysis of direct PM2.5 emissions from this biomass-fired
boiler, one-third of the direct PM2.5 emissions, or 0.0075 lb/mmBtu, is expected to be filterable PM2.5; the
remaining portion of direct PM2.5 emissions, or 0.015 lb/mmBtu, is expected to be condensable PM2.5.
6.2.2 PM2.5 Precursors.

As noted above, the U.S. EPA has identified SO2, NOx, VOCs, and ammonia (NH3) as PM2.5 precursors.
Based on the final rules, volatile organic compounds (VOC) and ammonia (NH3) may not be considered
to be precursors to PM2.5 unless the State demonstrates that these emissions are a significant contributor to
the area PM2.5 concentrations. This control technology review includes a complete control technology
review for SO2, NOx, and VOC emissions. Therefore, further analysis of these pollutants as PM2.5
precursors is unnecessary, since BACT controls will be applied to these pollutants.

As noted above, data from the U.S. EPA’s RBLC indicate that the technologies selected as BACT include
primarily fabric filter baghouses and electrostatic precipitators. Other controls include mechanical
collectors such as multicyclones, and wet venturi scrubbers.
6.3.1 Fabric Filter Baghouses.

Fabric filter baghouse (FFB) were discussed in the PM/PM10 control technology review. Fabric filter
baghouses are very effective at reducing PM emissions, especially in the fine particle size ranges. Figure
6-1 shows the cumulative emission factor for PM emissions versus the particle size for several different
PM control systems for coal combustion9. Figure 6-1 shows that fabric filter baghouses are very effective
in reducing PM emissions, especially fine PM or PM2.5.
As noted in Chapter 5, the primary filtering media in a fabric filter baghouse, especially those using
woven fabric filters, is actually the filter cake rather than the fabric itself. The filter cake acts much like a
fixed-bed reactor, contributing to greater absorption of pollutants, including fine particulate matter, sulfur
dioxide (SO2), sulfuric acid mist, mercury and hazardous air pollutants including hydrogen chloride (HCl)
and hydrogen fluoride (HF). Since pollutants such as sulfuric acid mist, HCl, and HF directly contribute
to condensable PM, fabric filter baghouses are also very effective at reducing the condensable portion of
PM2.5 emissions by controlling these PM2.5 precursors in the baghouse.
9
Data is from the Air Pollution Engineering Manual, Air & Waste Management Association, coal combustion
sources with various air pollution control systems.

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FIGURE 6-1. Cumulative emission factor for PM emissions versus the particle size.
100.00
Multiple Cyclones
Cummulative Emission Factor, lb/ton
10.00
1.00
Electrostatic
Precipitator
Fabric Filter
0.10
Baghouse
0.01
0.00
0.1 1 10 100
Particle Size, um
Filter Media for Fabric Filter Baghouses and PM2.5 Control.

There is a wide variety of fabric filter material available for fabric filter baghouses. For reverse air
baghouses, the most common fabric is a simple woven fabric such as woven fiberglass. For pulse jet
baghouses, the most common fabric is a woven fabric backing called a “scrim” with a felted layer needle
punched into the scrim. Other fabric materials include Nomex®, Ryton®, Gortex®, and Hyglass®.
Developments have been made in fabric filter media to improve PM2.5 control. Advanced filter media
provide enhanced PM2.5 emissions control and may be applicable to this biomass-fired boiler. The U.S.
EPA implemented the Environmental Technology Verification (ETV) program in 1995 to generate
independent data on the performance of innovative pollution control technologies. The ETV program
identified baghouse filtration products as a high priority technology group in 2000. As stated in a
report10, “New fabrics have been developed that offer the combination of highly effective particulate
removal and low operational pressure drop. Improving performance of the fabrics can be observed in
verification test data trends.” Completed verifications of baghouse filtration products are available from
the U.S. EPA’s ETV program at http://www.epa.gov/nrmrl/std/etv/vt-apc.html. ETV test results indicate
10
The Evolution of Improved Baghouse Filter Media as Observed in the Environmental Technology
Verification Program, Andrew Trenholm, RTI International, John Mycock, ETS Inc., John McKenna, ETS Inc.,
and Michael Kosusko, U.S. EPA, Presented at the Air & Waste Management Association Annual Conference, June,
2008, available at: http://epa.gov/etv/pubs/600etv08023.pdf .

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filter media with direct PM2.5 emission levels as low as 0.000007 gr/dscf, equal to approximately 0.0001
lb/mmBtu. Note, however, that this is the tested performance for the filter media, not for the entire
baghouse system. Leaks which occur in even the best state-of-the-art baghouse will increase the outlet
grain loading, even when using advanced filter media.
Baghouse filtration product enhancements include felted bags and high efficiency microfiber felts,
intrinsically coated (IC) bags, membrane bags, and electrostatic fabric filter technology.
Felted bags are often used in pulse-jet fabric filter baghouses which use higher energy cleaning systems
than in a reverse air baghouse. Felted filters don’t require the initial filter cake to collect fine particulates
as compared to woven filters. Felted filters are generally 2 to 3 times thicker than woven filters. This
thicker overall filter improves fine particle collection, since each individual randomly oriented fiber acts
as a target for particle capture by impaction and interception. Small particles are collected on the outer
surface of the filter, rather than depending on the filter cake to achieve fine particle control. Figure 6-2 is
a depiction of the fabric filter media filtration process for a simple woven fabric as compared to a felted
fabric media.
High efficiency microfiber felts are based on the same concept as felted filter media, but use ultra-fine
fibers to enhance fine particulate matter control. The U.S. EPA’s ETV program tested outlet PM2.5 levels
as low as 0.0004 gr/dscf (0.00055 lb/mmBtu).
FIGURE 6-2. Depiction of the fabric filter media filtration process for a simple woven fabric as
compared to a felted fabric media.
From the U.S. EPA’s Air Pollution Training Institute (APTI) Course Fabric Filter Operation.

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Intrinsically coated bags use a fabric made of coated fibers. The coating is typically Teflon® or a
similar fluoro-polymer material. Intrinsically coated bags improve bag durability and also reduce the pore
size between fibers, improving direct PM2.5 control. However, this coating also inhibits filter cake
formation. While this can help reduce the pressure drop across the baghouse, the reduced filter cake
accumulation may reduce the control effectiveness of the fabric filter baghouse for PM2.5 precursors and
condensable PM2.5 species by limiting the contact between these precursors and solids in the filter cake
which would otherwise remove these precursors.
Membrane bags have a polytetrafluoroethylene (PTFE) coating such as Teflon® applied to the surface
of the fabric rather than to the individual fibers. Membrane bags have even smaller pore sizes than
intrinsically coated bags. This smaller pore size may further improve direct PM2.5 control. However, the
coating over the entire bag further inhibits filter cake formation and may further reduce the control
effectiveness of the fabric filter baghouse for PM2.5 precursors and condensable PM2.5 species by limiting
the contact between these precursors and solids in the filter cake.
High efficiency microfiber felts are based on the same concept as felted filter media, but use ultra-fine
fibers to enhance fine particulate matter control. The U.S. EPA’s ETV program tested outlet PM2.5 levels
as low as 0.0004 gr/dscf (0.00055 lb/mmBtu).
Electrostatic fabric filter baghouses have been developed through a partnership of the U.S. EPA and
Southern Research Institute. The technology is licensed to General Electric Energy (GE) and is marketed
as the Max-9™ electrostatic fabric filter baghouse. The Max-9™ is a dust collection technology that
combines discharge electrodes and fabric filters in the same casing to provide high collection efficiency
while operating at a 60 to 80% lower system pressure drop. The Max-9 ESFF is an electrostatic
precipitator/pulse-jet baghouse hybrid, employing high voltage discharge electrodes to charge particulate,
but with fabric filters instead of collecting plates in the casing. GE Power states that “The Max-9 ESFF
provides collection efficiencies an order of magnitude higher than those achieved by either the best fabric
filters or precipitators currently on the market, with demonstrated efficiency of 99.999%.”11
GE states that the ESFFB technology is recommended for use in conjunction with a primary particulate
control device; i.e., the Max-9 is recommended as a “polishing” control device for PM emissions. The
U.S. EPA and the Southern Research Institute conducted pilot testing of a slip stream at a major power
plant in the Southern United States. The pilot plant was configured to allow testing with or without
discharge electrode energization. With the electrostatic stimulation turned on, collection efficiency
increased from 99.99% to 99.999%, a full order of magnitude better. Plus, there was an 80% reduction in
pressure drop, and an 80-90% reduction in sub-micron particle emissions.
While the Max-9 ESFFB technology shows great promise, this technology has not been demonstrated on
a full scale facility. Therefore, this technology is not technically feasible for this biomass-fired boiler.
11
As stated at: http://www.gepower.com/prod_serv/products/particulate_matter/en/max9/index.htm.

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6.3.2 Dry Electrostatic Precipitators.
Electrostatic precipitators (ESP) are a common PM control system for both coal and biomass-fired
boilers, and are discussed in the PM/PM10 control technology review. While dry ESPs are a technically
feasible control technology, a dry ESP is expected to have significantly lower control efficiencies for both
direct filterable PM2.5 emissions, and also for PM2.5 precursors.
6.3.3 Wet Electrostatic Precipitators.

The principle of operation of a wet ESP is similar to a dry ESP. Although wet ESPs can be effective for
removing sulfuric acid mist downstream of a wet FGD when firing high sulfur coals, wet ESPs cannot be
used as the primary PM control system for biomass-fired boilers because the PM loading is too great for
effective operation. Wet ESPs experience current suppression when PM concentrations in the electrode
wash water are too high which would reduce or eliminates the PM control effectiveness of the wet ESP.
Therefore, a wet ESP must be considered as a secondary or “polishing” PM control device.
While wet ESPs cannot operate as the primary control device, wet ESPs have shown promise at reducing
PM2.5 emissions as a polishing device. A pilot wet ESP was installed at First Energy’s Bruce Mansfield
Plant in Shippingport, PA. The pilot wet ESP uses a slipstream of flue gas from the outlet of an FGD
system on an 835 MW unit firing 3% sulfur coal. The plant installed the pilot WESP to test for PM2.5 and
SO3 mist removal as a potential control technology to reduce visible emissions. The slipstream results
indicate reductions in PM2.5 emissions from 62% to 96%. These results also showed similar high SO3
mist removal, which may account for mush of the PM2.5 emission reductions. However, these tests were a
slipstream test, not a fullscale test, and were for a limited duration.
6.3.4 Wet Scrubbers.

Wet scrubbers are used in many industrial processes to control PM emissions. Wet scrubbers reduce PM
emissions through several mechanisms, including condensation, inertial impaction of PM with water
droplets, and reactions of PM and PM precursors with the scrubber reagent.
6.3.5 Mechanical Collectors.

Mechanical collectors are not as effective as a FFB or ESP for PM control, especially for fine PM control.
Therefore, while mechanical collectors are technically feasible, their performance is inferior to FFBs.

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Fabric filter baghouses, dry ESPs, wet ESPs, wet scrubbers, and mechanical collectors are technically
feasible technologies. While wet ESPs have shown promise at reducing PM2.5 emissions as a polishing
device, the available data is limited. Since a wet ESP has not been demonstrated on a similar biomass-
fired boiler, wet ESPs are not considered technically feasible in this analysis.
Table 6-1 is a summary of the ranking of the expected performance of the PM control technologies. The
performance is stated in ranges, since the specific performance is dependent on the boiler firing type and
fuels fired. In general, fabric filters are expected to have the best performance for the control of both
filterable and especially condensable PM2.5.
TABLE 6-1. Ranking of the technically feasible PM2.5 control technologies.
Performance,
Rank Control System Notes
lb/mmBtu
Felted filters have a thicker filter which improves
fine particle collection. Small particles are collected
on the filter, rather than depending on the filter cake
to achieve fine particle control. However, felted
filters still allow for a normal filter cake to enhance
control of PM2.5 precursors.
Fabric Filter Baghouse Intrinsically coated bags and high efficiency
with Felted Bags microfiber bags may improve filterable PM2.5
1 0.02 - 0.03
or control without significantly reducing filter cake
Advanced Filter Media accumulation and the subsequent control of PM2.5
precursors such as SO2 and sulfuric acid mist.
Membrane coated bags are expected to achieve very
high filterable PM2.5 control but may reduce filter
cake accumulation which may adversely impact
control of PM2.5 precursors such as SO2 and
condensable PM2.5 such as sulfuric acid mist.
The expected emission range is higher because the
Fabric Filter Baghouse standard bags will have higher filterable PM2.5
2 with Conventional 0.02 – 0.04 emission rates. However, the conventional bags
Woven Bags have good filter cake accumulation and good control
of PM2.5 precursors and condensable PM2.5.
Inferior control, with lower filterable and lower
3 Dry ESP 0.03 - 0.05
condensable PM2.5 control.
4 Venturi Scrubber 0.05 – 0.15 Inferior control.
5 Mechanical Collectors 0.10 – 0.30 Inferior control.

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6.5.1 Rank No. 1: Fabric Filter Baghouse with Felted or Advanced Filter Media.
Based on the ranking summarized in Table 6-1, a fabric filter baghouse with felted filter media or
advanced filter media bags is expected to have the greatest potential to reduce both filterable and
condensable PM2.5 emissions from the biomass-fired boiler. Note that there is a lack of data available on
PM2.5 emissions from biomass combustion, and there is no available information on the PM2.5 emission
rates for different fabric filter media on a CFB boiler firing biomass fuels. With these statements made,
the highest level of PM2.5 emission control from this biomass-fired boiler is expected to be achieved using
felted filter media bags. Based on this analysis, the We Energies proposes to utilize a fabric filter
baghouse with felted filter media or advanced filter media bags for this boiler.
6.6 STEP 5. Proposed PM2.5 BACT Determination.

Based on this analysis, We Energies has concluded that the use of a fabric filter baghouse with felted
filter media bags is the highest ranked control technology for the control of PM2.5 emissions and
represents the best available control technology (BACT) for PM2.5 emissions from the biomass fuels-fired
CFB boiler. Based on this analysis, We Energies proposes the following limits as BACT for the control
of PM2.5 emissions from this biomass-fired boiler.
(1) PM2.5 emissions from the biomass-fired Boiler B08 shall be controlled
using a fabric filter baghouse with felted filter media bags as the best
(2) PM2.5 emissions may not exceed 0.023 pounds per million Btu of heat
input, excluding periods of startup and shut down.
(3) Compliance with this PM2.5 emission limit shall be based upon the
measurement of PM2.5 emissions in accordance with U.S. EPA Reference
Method 201A, and U.S. EPA Other Method 28, or another method approved
in writing by the department.

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Chapter 7. Sulfur Dioxide (SO2) Control
Technology Review.
Sulfur dioxide (SO2) emissions from solid fuel-fired boilers result from the oxidation of sulfur compounds
in the fuel. During combustion, the majority of the fuel sulfur is emitted as SO2. A small portion of the
sulfur is further oxidized to sulfur trioxide (SO3). When the flue gas temperature drops below the dew
point temperature, sulfur trioxide is spontaneously converted to sulfuric acid (H2SO4). Therefore, control
technologies which control SO2 emissions also reduce sulfuric acid mist emissions to varying degrees. A
portion of the SO2 and SO3 will react with alkaline products in the ash such as calcium oxide (CaO),
sodium oxide (Na2O), and potassium oxide (K2O) and water to form calcium sulfate or gypsum (CaSO4 •
2H2O), sodium sulfate (Na2SO4), and potassium sulfate (K2SO4). These reaction products are solids
which are collected in the fabric filter baghouse as filterable particulate matter. These reactions are
particularly important for biomass-fired boilers which produce highly alkaline ash. Therefore, ash in the
boiler and in the filter cake of the fabric filter baghouse will reduce SO2 emissions.
7.1 BACT Baseline.

The biomass fuel-fired CFB boiler will be subject to the Standards of Performance for Industrial-
Commercial-Institutional Steam Generating Units under 40 CFR Part 60, Subpart Db. This subpart
applies to steam generating units that commence construction, modification, or reconstruction after June
19, 1984, and that has a heat input capacity greater than 100 mmBtu/hr.
Under 40 CFR § 60.42b(k)(1), an affected facility that commenced construction, reconstruction, or
modification after February 28, 2005, and that combusts coal, oil, natural gas, a mixture of these fuels, or
a mixture of these fuels with any other fuels may not exceed: 1) An SO2 emission rate of 0.20 lb/mmBtu,
or 2) 8% of the potential SO2 emission rate (92% reduction) and 1.2 lb/mmBtu. Units firing only very
low sulfur oil and/or a mixture of gaseous fuels such as natural gas with a potential SO2 emission rate of
less than 0.32 lb/mmBtu are exempt from the SO2 emissions limit in 40 CFR § 60.42b(k)(1).
Based on these NSPS limits, the baseline SO2 emission rate is 0.20 lb/mmBtu.
7.2 STEP 1. Identify Potential Control Technologies.

Potential sulfur dioxide (SO2) control technologies include pre-combustion controls such as low sulfur
fuels, and post combustion controls, such as flue gas desulfurization (FGD). The following references
were used to identify potential SO2 control technologies: “Controlling SO2 Emissions: A Review of
Technologies (EPA-600/R-00-093, October 2000), the U.S. EPA’s RACT/BACT /LAER Clearinghouse
(RLBC), the U.S. EPA’s National Coal-Fired Utility Projects Spreadsheet Updated July 2007, and
numerous air permits issued by states and the U.S. EPA.

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Table 7-1 is a summary of SO2 BACT emission limits for both new and modified biomass-fired boilers
contained in the U.S. EPA’s RACT/BACT/LAER Clearinghouse. The technologies selected include low
sulfur fuels, duct sorbent injection, limestone injection into fluidized bed boilers, and wet venturi
scrubbers. Emission limits range from 0.014 to 0.80 pounds per million Btu of heat input. Available
technologies also include wet and dry FGD systems. Note that several facilities in Table 7-1 agreed to
“synthetic minor” limits limiting emissions below the PSD significant threshold of 40 tons per year.
TABLE 7-1. Biomass-fired boiler sulfur dioxide (SO2) BACT emission limits.
Permit Capacity, Primary Control Limit,
Facility State
Date mmBtu/hr Fuel System lb/mmBtu
Wood /
Yellow Pine Energy Company GA May-09 1,529 SDA 0.014
TDF
Wood /
Hillman Power MI Jul-02 300 None 0.018
TDF
Mancelona Renewable MI Nov-09 565 Biomass None 0.025
BFB
Boiler
CFB
Northern Michigan University MI Nov-09 210 Wood 0.06
Boiler
Pub Service of New Hampshire - CFB
NH Oct-04 720 Wood 0.02
Schiller Station Boiler
Skagit County Lumber Mill WA Jan-06 430 Wood 0.025
Boralex Stratton Energy, LP ME 672 Wood 0.053
South Point Biomass Generation OH Apr-06 318 SDA 0.07
Poultry
Fibrominn Biomass Power Plant MN Feb-05 792 SDA 0.07
Litter
Wheelabrator Sherman Energy
ME Apr-99 315 Wood 0.12
Company
S.D. Warren Co. - Skowhegan, wet
ME Nov-01 1,300 0.27
Me scrubber
Wood /
Northern Sun ND May-06 100 0.47
Hulls
Meadwestvaco Kentucky,
KY Feb-02 631 0.80
Inc/Wickliffe
Virginia PWC - Laurention
MN Aug-05 230 Wood <38 TPY
Energy Authority
Wood /
Koda Energy MN Aug-07 308 <38 TPY
NG
District Energy St. Paul, Inc. MN Nov-01 550 Wood <39 TPY
Stoneman Power Plant WI Jan-09 340 Wood n/a
Footnotes
1. For the South Point Biomass Generation facility, the BACT limit is 22.13 pounds per hour. For a rated heat
input capacity of 318 mmBtu per hour, this limit is equal to 0.07 lb/mmBtu.
2. For the Public Service of New Hampshire - Schiller Station, sorbent injection into the fluidized bed boiler is
required for coal combustion.

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Flue Gas Desulfurization (FGD) technologies are primarily used for large utility and industrial coal-fired
boilers. FGD systems may be broadly classified as “wet” and “dry” systems. Wet FGD systems are
characterized by low flue gas outlet temperatures, saturated or wet flue gas conditions, and a wet sludge
reaction product which is dewatered before reuse or disposal. For most solid fuels and boiler types, the
flue gas saturation temperature is about 130 oF. In wet FGD applications, the primary PM control system
is located upstream of the wet FGD system so that the fly ash and FGD system reaction products are
collected separately. This is necessary to avoid saturated conditions in the PM control system which
would plug a fabric filter baghouse or dry ESP. Wet FGD systems are also characterized by relatively
high water use as compared to dry FGD systems.
Dry FGD systems are characterized by outlet flue gas temperatures about 20 to 50 °F above the saturation
point, or about 150 oF to 180 oF. In dry FGD applications, the PM system is located downstream of the
dry FGD system so that the fly ash and the FGD reaction product are commingled into a single stream.
Dry FGD systems also have reduced water use as compared to wet FGD systems.
7.3.1 Wet Flue Gas Desulfurization.

Wet FGD is a well demonstrated technology for the control of SO2 emissions from utility scale coal-fired
boilers. In a wet FGD system, the flue gas is exposed to an alkaline reagent which reacts with SO2 to
form a solid. There are several alkaline reagents used in wet FGD systems, including water-based slurries
of lime or limestone, liquors containing dissolved sodium or magnesium salts, or amine based liquors
including ammonia. A typical modern wet FGD system absorber tower is shown in Figure 7-1.
Regardless of the wet FGD design, the flue gas leaving the absorber will be saturated with water, and the
stack will have a visible condensed moisture plume at all times. The conditions downstream of the
absorber are highly corrosive, requiring highly corrosion-resistant materials for the downstream ductwork
and stack. This would require that the stack be specially designed with a fiberglass liner. Equipment is
also needed to manage the condensation that occurs on the downstream ductwork and in the stack. The
wet FGD reaction products also require dewatering, usually by a combination of hydroclones and vacuum
filters. Large areas are needed to manage the dewatering and byproduct storage, as well as the substantial
water treatment facilities required for the FGD systems. These factors contribute to the high capital and
operating costs of wet FGD systems.
Advanced Wet FGD Designs.

The first FGD systems in the U.S. were installed largely in response to the 1971 Clean Air Act. Most of
these original FGD systems were calcium based wet FGD systems. About half of these early systems
were lime and the other half limestone. Many of these FGD systems were plagued with operational issues
including scaling, plugging, and low SO2 removal. These first wet FGD systems utilized spray tower
absorbers, often without a perforated plate tray, as the method for contacting the flue gas with the reagent.

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FIGURE 7-1. Typical modern wet flue gas desulfurization system absorber tower.
FGD systems installed in the 1990’s were 2nd and 3rd generation systems which generally achieved greater
than 90% SO2 removal with improved reliability. The limestone systems installed during this time were
mostly forced oxidation systems which demonstrated the ability to achieve similar performance and
reliability as lime systems. The SO2 removal efficiencies of the 2nd and 3rd generation systems were
improved primarily by improving gas to liquid contact. These improvements include absorption trays
with perforated plates and multiple levels of interspatial reagent spray nozzles.
FGD system suppliers have introduced several new designs to improve the flue gas to FGD liquid reagent
contact and minimize operating costs. Designs such as the Jet Bubbling Reactor developed by Chiyoda
and Alstom’s Flowpac systems were developed to improve the gas-to-liquid contact by forcing the flue
gas to bubble through the liquid reagent using a gas sparger design rather than spraying the alkaline slurry

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into the gas stream. Mitsubishi developed the Double Contact Flow Scrubber (DCFS) which uses
‘fountains’ of slurry to contact the flue gas. Babcock Power Environmental Inc. utilizes bidirectional
sprays and wall rings to maximize contact between the flue gas and liquid reagent. All of these wet FGD
systems use the limestone forced oxidation (LSFO) process.
Wet Limestone with Forced Oxidation.

In recent years, the WFGD market has turned almost completely to the use of wet lime or limestone with
forced oxidation on utility scale coal-fired boilers because it improves SO2 control, reduces chemical
scale formation, and produces gypsum, a stable and potentially saleable byproduct. Wet limestone with
forced oxidation (LSFO) is a modification of the conventional wet limestone FGD process. A
conventional wet limestone system forms a scrubber product composed mostly of calcium sulfite
(CaSO3). The LSFO process further oxidizes calcium sulfite to calcium sulfate dihydrate (gypsum, or
CaSO4·2H2O). The gypsum content of the scrubber sludge is typically 95% on a dry basis, making the
sludge easier to dewater. Gypsum is a naturally occurring mineral that is used as a raw material in the
manufacture of plaster, wallboard, Portland cement, agricultural soil conditioners, and other products.
In the LSFO process, flue gas exits the primary PM pollution control system at approximately 300 oF and
enters a spray tower where an alkaline slurry consisting of limestone (calcium carbonate), calcium sulfite,
and calcium sulfate is contacted with the flue gas. Through a series of reactions, SO2 in the flue gas
reacts with calcium carbonate to form CaSO3. The flue gas exits the absorption tower through a series of
chevron mist eliminators to remove entrained moisture droplets. The calcium sulfite remains in the slurry
which drains into a recirculation tank located at the bottom of the spray tower. By injecting air into the
slurry using fans or blowers, the calcium sulfite is oxidized to CaSO4·2H2O. A portion of the slurry in the
recirculation tank is pumped back into the spray tower, and a portion is removed. The removed slurry is
dewatered and stockpiled for transport offsite. The overall FGD reaction is:
CaCO3(s) + SO2(g) + ½O2(g) + 2H2O → CaSO4·2H2O(s) + CO2(g)
The LSFO process can achieve high levels of control on coal-fired boilers. Recent BACT determinations
put the level of control at 95 - 97% range. However, the same performance principle for any SO2 control
system is also true for the LSFO – as the boiler outlet SO2 concentration decreases, the ability to achieve
high control efficiencies also decreases.
Technical Feasibility
WFGD is a well demonstrated technology for the control of SO2 emissions from coal-fired boilers. Wet
FGD systems have been installed primarily on large utility scale pulverized coal-fired boilers combusting
higher sulfur coals. However, we are not aware of a CFB boiler equipped with a wet FGD system, nor
are we aware of a biomass-fired boiler equipped with a wet FGD system. However, as noted above, the
current wet FGD systems are 3rd generation FGD systems which would integrate many of the advances in
wet FGD design. While we are not aware of the use of wet FGD on similar biomass-fired boilers, wet
FGD is a technically feasible control option.

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7.3.2 Dry Flue Gas Desulfurization.
Dry FGD is also a well demonstrated technology for the control of SO2 emissions from coal-fired electric
generating units. Like wet FGD systems, dry FGD systems can be divided into several types. Dry FGD
systems involve injecting a dry sorbent into the furnace or flue gas duct; the by-product solids are
collected with the boiler fly ash. In semi-dry FGD systems, the sorbent is introduced as an aqueous slurry
or a humidified dry powder to improve SO2 control efficiency. The water content is controlled so that the
reaction by-products are dry solids. While the flue gas temperature in both types remains above the
adiabatic saturation temperature, the semi-dry systems have lower temperatures and a closer approach to
the saturation temperature. The primary PM control system for dry FGD applications is often a fabric
filter baghouse since they can provide higher reagent utilization.
Dry FGD systems do not have a saturated plume and therefore do not require the same design elements
related to a saturated and corrosive plume as wet FGD systems. Since the dry FGD reaction products are
also dry, there is no need for dewatering equipment or wastewater discharge. The reaction product in dry
FGD systems is primarily calcium sulfite, with smaller amounts of calcium sulfate. Because of the
calcium sulfite content, the dry FGD byproduct will undergo pozzolanic (cementitious) reactions when
wetted. This material has limited commercial value and is typically disposed of as waste material.
Lime Spray Drying Absorber

One of the most widely used dry FGD technologies is the lime spray dry absorber (LSDA). LSDA is a
semi-dry FGD technology that is often used on utility scale low sulfur coal-fired boilers. The LSDA
process employs a spray dryer absorber (SDA) and a downstream PM control device. The SDA
introduces a lime or limestone slurry and flue gas at the top of an absorber vessel. Rotary atomizers or
nozzles are used to create a spray of slurry droplets which are dispersed in the flue gas stream. The water
in the slurry droplets evaporates as the flue gas passes through the absorber, cooling and humidifying the
flue gas stream and rapidly drying the slurry to a powder. In practice, water is added to control the SDA
outlet temperature to approximately 155oF, or an approach temperature approximately 25oF above the
saturation temperature. SO2 in the flue gas reacts with calcium hydroxide in the reactor or on the fabric
filter bags to form solid calcium sulfite (CaSO3) and calcium sulfate (CaSO4):
2Ca(OH)2 (s) + 2SO2 (g) + 2H2O (g) → 2(CaSO3 • 2H2O)

2Ca(OH)2 (s) + 2SO2 (g) + 2H2O (g) +O2 → 2(CaSO4 • 2H2O)
Fly ash, reaction products, and unreacted lime are captured downstream in the PM control system. A
portion of the collected material is recycled back to the SDA to improve reagent utilization.
Advanced Semi-Dry FGD Systems

Advanced Semi-Dry FGD systems include circulating fluidized bed (CFB) systems, hydrated lime
injection systems such as Turbosorp, circulating dry scrubbers (CDS), and flash dry absorbers, also called
novel integrated desulphurization system (NIDS). These systems are often utilized in circulating
fluidized bed (CFB) boiler applications where excess lime (CaO) produced in the CFB boiler can be used

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to further reduce SO2 emissions. The ash captured in the baghouse containing excess lime is hydrated to
form calcium hydroxide (Ca(OH)2). The ash is then reinjected into the flue gas in a vessel upstream of
the PM control device.
These advanced semi-dry systems may be contrasted with conventional SDA systems in that the ash is
humidified but remains a free-flowing solid, as opposed to being hydrated to a slurry as in the SDA
process. This lower water content eliminates the need for slurry handling, atomization, and a large
reactor. Reinjecting a dry solid also allows the reagent to disperse rapidly in the flue gas. These systems
may also be contrasted with conventional SDA systems in that the solids recirculation rate is 30 to 100
times, compared to 3 – 5 times in a conventional SDA system. These semi-dry FGD systems have
demonstrated the ability to achieve SO2 emission reductions equivalent to, and in some cases greater than,
that achieved by conventional dry FGD systems and LSDA.
Technical Feasibility.
Dry FGD systems, including lime spray drying absorbers, circulating fluidized bed systems, hydrated
lime injection systems, and flash dryer absorbers, are all demonstrated for the control of SO2 emissions
from coal-fired boilers. While the proposed biomass-fired boiler will fire low sulfur fuels, these dry and
semi-dry FGD systems are never-the-less technically feasible control options. Because of the general
similarities with all of the dry FGD systems, the LSDA is representative of the dry FGD systems and is
used to further evaluate dry FGD systems in this analysis.
7.3.3 Sorbent Injection.

Sorbent injection systems may be considered as dry FGD systems in which a powdered sorbent is injected
into the furnace or into downstream ductwork. Several types of sorbent injection are available, including
furnace sorbent injection, and duct sorbent injection. Dry sorbent injection (DSI) is a dry FGD system.
In a typical DSI system, water is injected into the duct downstream of the air preheater to cool and
humidify the flue gas. The sorbents are typically either sodium or calcium-based and are injected either
in the furnace, or in the downstream ductwork prior to the PM control system. Calcium based sorbents
include limestone and hydrated quicklime; sodium-based sorbents include sodium bicarbonate, and trona
(sodium sesquicarbonate or Na2CO3 • NaHCO3 • 2H2O) may be injected into the duct upstream of the PM
control system. The fly ash, sorbent reaction products, and unused sorbent are collected in the PM control
system. DSI has typical SO2 removal efficiencies ranging from 25 to 50%, although higher removal
efficiencies are reported at high molar ratio sorbent injection rates.
Furnace sorbent injection is also a dry system. Sorbents such as limestone or hydrated lime are injected
into the boiler furnace. The injection point is selected based on the temperature window that is required
for the reagent, typically around 1,000 – 1,500°F. Water is injected into the ductwork between the air
heater and the PM collector for flue gas conditioning to promote additional SO2 removal. The reaction
product and fly ash are collected in the PM collection system. Furnace sorbent injection systems typically
achieve SO2 removal efficiencies of 25 to 50%. However, for fluidized bed boilers, furnace sorbent
injection is capable of removing 90% of the fuel sulfur in high sulfur coal applications.

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Dry sorbent injection into the ductwork is a technically feasible control option for this CFB boiler.
However, furnace sorbent injection is not a technically feasible control option for this CFB boiler. When
firing biomass fuels, the injection of additional calcium in the form of limestone may result in excessive
calcium in the bed. Excessive levels of calcium can cause the solids in the bed to agglomerate and cause
the bed to collapse. This can cause failure of the boiler to fluidize.
7.3.4 Emerging Flue Gas Desulfurization Technologies.

Emerging SO2 control technologies include Enviroscrub (also known as the Pahlman process), ECO
scrubber, REACT, and the Airborne process. These emerging technologies are not yet demonstrated
through installation and successful operation on a full scale boiler or are not available or applicable. Of
these advanced processes, the ECO system process is closest to commercial operation. The ECO process
has been installed as a slip stream unit on a bituminous coal-fired boiler. The ECO system being offered
is a redesigned version of the slip stream scrubber taking into account the “lessons learned.” The ECO
system design has not yet been installed or demonstrated on a full scale on any boiler.
The REACT technology from Japan consists of three major process steps: absorption, regeneration, and
byproduct recovery. The absorption process utilizes pelletized activated coke (ATC) and ammonia for
removal of SO2 and sulfuric acid from the flue gas. The mechanism for the removal of pollutants is very
different between the REACT and wet FGD processes, although they are both located in the flue gas
stream downstream of the primary PM control system. The absorption and regeneration processes of the
REACT technology are dry, and require secondary particulate removal to collect the reaction product.
Airborne ProcessTM
In October, 2004, the U.S. Department of Energy announced that Peabody Energy’s Mustang Energy
project will be awarded a $19.7 million Clean Coal Power Initiative grant for demonstrating technology to
achieve ultra-low emissions at a proposed facility near Grants, New Mexico. The Project is intended to
demonstrate Airborne’s emission control process. The technology would combine dry sodium
bicarbonate injection with enhanced wet sodium bicarbonate scrubbing. Because the sodium bicarbonate
reagent is expensive and the reaction product has limited value, the Airborne Process™ is intended to
regenerate the scrubber reagent. The regeneration process would recover the reagent for reuse and
convert SO2 and NOx into ammonium sulfate and ammonium nitrate fertilizers.
While several advanced FGD technologies show promise in achieving very low SO2 emission rates, these
processes are not commercial, nor are they demonstrated in practice. Due to the lack of demonstrated
performance, these technologies are not technically feasible control options for this biomass-fired boiler.

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7.3.5 Low Sulfur Fuels and Fuel Cleaning.
Sulfur dioxide emissions may be controlled by the use of post-combustion FGD systems designed to
remove SO2 from the flue gas after combustion. Because SO2 emissions occur from the oxidation of fuel
sulfur, SO2 emissions may also be controlled by limiting the fuel sulfur content.
Low Sulfur Fuels.

Biomass is an inherently low sulfur fuel. Tables 7-2 and 7-3 are a summary of wood and wood waste fuel
data from two different sources. From the U.S. EPA’s document Compilation of Air Pollutant Emission
Factors, AP-42, 5th Edition, Table 1.6-2, the combustion of wood waste has a typical SO2 emission rate of
0.025 lb/mmBtu. Tables 7-2 and 7-3 indicate that the potential SO2 combustion concentration or
uncontrolled SO2 emission rate is substantially higher than the values from AP-42, ranging from 0.13 to
0.35 lb/mmBtu, with a typical potential SO2 combustion concentration of 0.24 lb/mmBtu. These sulfur in
fuel values are 5 to 14 times higher than the AP-42 value. The lower actual SO2 emission rate is due to
the retention of sulfur in the flyash and bottom ash by the highly alkaline ash.
Fuel Cleaning.
Fuel cleaning is not technically feasible for biomass fuels. The sulfur in biomass is primarily organic;
there is no known commercially available technology for removing organic sulfur from biomass fuels.
TABLE 7-2. Typical proximate and ultimate analyses for several biomass fuels.
Wood Analyses, dry basis, weight % Pine Bark Oak Bark Spruce Bark
Proximate Analysis, %
Volatile Matter 72.9 76.0 69.6
Fixed Carbon 24.2 18.7 26.6
Ash 2.9 5.3 3.8
Ultimate Analysis, %
Hydrogen 5.6 5.4 5.7
Carbon 53.4 49.7 51.8
Sulfur 0.1 0.1 0.1
Nitrogen 0.1 0.2 0.2
Oxygen 37.9 39.3 38.4
Ash 2.9 5.3 3.8
Heat Content, Btu per pound 9,030 8,370 8,740
Potential SO2 Combustion Concentration, lb/mmBtu 0.22 0.24 0.23
Footnotes
Reproduced from Steam, its generation and use, 41st Edition, The Babcock & Wilcox Company.

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TABLE 7-3. Wood fuels analyses data and uncontrolled SO2 emission rates.
90th
Wood Analyses, dry basis, weight % Site 1 Site 2 Site 3 Site 4 Site 6 Site 7 Average
Percentile
Analysis, Dry Basis
Volatile Matter 79.59 80.53 78.52 68.47 78.53 77.24 77.15
Fixed Carbon 15.25 12.09 17.61 15.55 16.33 16.36 15.53
Ash 5.16 7.38 3.87 15.99 5.15 6.40 7.33
Carbon 50.28 50.55 52.90 45.38 50.11 50.45 49.95
Hydrogen 5.92 5.95 5.85 5.17 5.87 5.86 5.77
Nitrogen 0.46 0.53 0.51 0.73 0.52 0.62 0.56
Sulfur 0.12 0.06 0.08 0.05 0.15 0.10 0.09
Ash 5.16 7.38 3.87 15.99 5.15 6.40 7.33
Oxygen 38.07 35.54 36.79 32.69 38.20 36.57 36.31
Chlorine 0.08 0.03 0.16 0.06 0.03 0.05 0.07
Heat Content, Btu per pound 8,238 8,599 8,795 7,543 8,353 8,437 8,327
Uncontrolled SO2 Emission Rate, lb/mmBtu 0.291 0.140 0.182 0.133 0.359 0.237 0.224 0.32
Uncontrolled HCl Emission Rate, lb/mmBtu 0.100 0.036 0.187 0.082 0.037 0.061 0.084 0.14
Footnotes
Data is from the U.S. EPA Report, Wood Products in the Waste Stream - - Characterization and Combustion Emissions, EPA Report EPA-
600/R-96-119a.

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7.4.1 Low Sulfur Biomass Fuels.

The amount of sulfur in biomass fuels is highly variable, and may depend on the geographic source of the
fuel, and the nature of the biomass fuel itself. From the above data sources, the potential SO2 combustion
concentration for biomass fuels, i.e., the theoretical uncontrolled SO2 emission rate based on fuel
sampling and analysis, ranges from 0.13 to 0.35 lb/mmBtu. However, much of this sulfur is normally
retained in the boiler fly and bottom ash. Ash mineral analysis data from the U.S. EPA Report, Wood
Products in the Waste Stream - Characterization and Combustion Emissions, EPA Report EPA-600/R-
96-119a, Table 7-32 indicates that the evaluated fuels in the report had calcium oxide (CaO) levels of
15.3%. The fuel had an average ash content of 7.8%, and an average sulfur content of 0.094%, on a dry
basis. From these values, the fuel had a CaO level of 1.19 lb CaO/100 lb dry fuel, or 0.0213 moles of
calcium per 100 lb dry fuel. The fuel also had a sulfur content of 0.094%, equal to 0.00294 moles of
sulfur per 100 lb dry fuel. Therefore, the effective calcium to sulfur ratio in the boiler when firing this
typical biomass fuel is more than seven to one (7:1).
In the CFB boiler, calcium oxide reacts with SO2 to form calcium sulfate (CaSO4). Calcium sulfate is
removed from the CFB bed and in the fabric filter baghouse as a solid. In CFB boilers firing coal,
calcium to sulfur ratios of 1.8 to 2.5 may be necessary to achieve greater than 90% removal on high sulfur
fuels12. However, as the fuel sulfur content decreases, higher Ca:S molar ratios are necessary to achieve
similar reduction efficiencies. Never-the-less, the very high effective Ca:S ratios when combusting
biomass fuels is expected to result in a high retention of sulfur in the ash.
In January, 2010, a preliminary database of emission test data, continuous emission monitoring system
(CEMS) data, and fuel analysis data for boilers and process heaters at major sources of HAP was made
available at http://www2.ergweb.com/projects/combustion/combustiontesting.html. This data includes
standardized emission data from both the U.S. EPA’s Phase I survey Information Collection Request
(ICR No. 2286.01) and the Phase II test plan (ICR No. 2286.03). SO2 stack test data for biomass
combustion indicates SO2 concentrations in the flue gas ranging from 0.1 to 51 part per million at 3%
excess O2. These concentrations are equivalent to SO2 emission rates of 0.0002 – 0.10 lb/mmBtu. Other
data indicates higher SO2 concentrations for biogas/natural gas combustion and blends of industrial
sludge/natural gas/wood/bark combustion of up to 102 ppm at 3% excess O2, equal to 0.19 lb/mmBtu.
The available data from the U.S. EPA and other databases indicates a wide range of potential SO2
emission rates from biomass fuels combustion. Based on the available data, the combustion of biomass
fuels in the circulating fluidized bed boiler is expected to result in an “uncontrolled” SO2 emission rate of
0.09 lb/mmBtu, equal to an SO2 concentration of 48 parts per million at 3% excess oxygen.
12
From STEAM, its generation and use, 41st Edition, the Babcock & Wilcox Company, Barberton, Ohio, Chapter
17, Fluidized Bed Combustion, page 17-13, available at www.babcock.com; and Combustion and Gasification in
Fluidized Beds, 2006, Prabir Basu, CRC Press, ISBN 0849333962, page 154.

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7.4.2 Wet Flue Gas Desulfurization.
Modern wet FGD designs can achieve 95 - 99% SO2 removal on an initial performance guarantee and
maximum short term basis when firing high sulfur coals. However, it is the conclusion of the U.S. EPA
and other agency decisions that it is not technically feasible to achieve this high control level day after
day, year after year. Further, because these biomass-fired boilers are expected to have a very low
“uncontrolled” SO2 emission rate of 0.09 lb/mmBtu, a 90% reduction would be equal to an SO2 emission
rate of only 0.01 lb/mmBtu, equal to about 5 ppm at 5% O2. For this analysis, a wet FGD system is
expected to reduce SO2 emissions to a level of 0.02 lb/mmBtu, or 10 ppm at 5% O2.
7.4.3 Dry Flue Gas Desulfurization.

Modern dry FGD designs can achieve 90 - 95% SO2 removal on an initial performance guarantee and
maximum short term basis, again, when firing coal. For this analysis, a state-of-the-art dry FGD system
is expected to achieve a long term SO2 emission rate of 0.03 lb/mmBtu.
7.4.4 Dry Sorbent Injection.

According to the U.S. EPA, dry sorbent injection systems have typical SO2 removal efficiencies ranging
from 25% to 50+%13. According to the Institute of Clean Air Companies, dry injection systems typically
have removal efficiencies ranging from 50 - 70%14. Higher removal efficiencies have been reported by
one air pollution control system vendor for trona injection15. For this analysis, dry sorbent injection is
expected to achieve an SO2 emission rate of 0.05 lb/mmBtu, equal to a 45% reduction from the biomass
fuel uncontrolled SO2 emission rate of 0.09 lb/mmBtu.
7.4.5 Ranking of the Technically Feasible Control Options.

Table 7-4 is a summary of the ranking of the technically feasible SO2 control technologies based on the
above analysis of available technologies.
TABLE 7-4. Ranking of the technically feasible SO2 control technologies.

Rank Control System Expected Performance, lb/mmBtu
1 Wet FGD 0.02
2 Dry FGD 0.03
3 Sorbent Injection 0.05
4 Low Sulfur Biomass Fuels 0.09
13
From the U.S. EPA’s Compilation of Air Pollutant Emission Factors, AP-42, Table 1.1-1.
14
Available at http://www.icac.com/i4a/pages/index.cfm?pageid=3401.
15
Refer to several papers presented by Solvair, available at http://www.solvair.us.

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7.5.1 Rank No. 1: Wet Flue Gas Desulfurization.

The most effective SO2 control option is the use of a wet FGD system in combination with firing biomass
fuels. Based on the above analysis, the wet FGD system could reduce potential SO2 emissions from the
biomass-fired boiler to 0.02 lb/mmBtu, and 62 tons per year. However, a wet FGD system would
consume large amounts of water and result in a new wastewater discharge stream. A wet FGD system
would also produce a distinct visual plume. A wet FGD system would produce a new gypsum byproduct
stream. While the gypsum byproduct has some potential for reuse, this byproduct may also require
disposal.
A wet FGD system would also require substantial auxiliary electric power requirements. In a wet FGD
system, auxiliary electric power is required to operate slurry pumps, sludge dewatering, and for the
induced draft fan requirements to overcome the wet FGD system pressure drop.
Economic Feasibility.
Table 7-5 includes a summary of the sulfur dioxide control technology costs. A detailed cost analysis for
the SO2 control technology options is included in Attachment 2. A wet FGD system is expected to have a
total capital cost of $53 million, annual O&M costs of $3.7 million, and a total annual cost of $9.5
million. From Table 7-5, the wet FGD system would reduce actual SO2 emissions by 216 tons per year as
compared to the uncontrolled biomass fuels emission rate and an annual capacity factor of 88%. This
results in an average cost effectiveness for the wet FGD system of $43,800 per ton of SO2 controlled.
In addition, the use of a wet FGD system would have an increased incremental cost of $2.1 million per
year as compared to the use of dry FGD. The wet FGD system would reduce SO2 emissions by 31 tons
per year as compared to the use of a dry FGD system. This would result in an incremental cost
effectiveness of wet FGD, as compared to dry FGD, of $66,500 per ton of SO2 controlled.
Conclusion.
While a wet FGD SO2 control system is technically feasible for the proposed biomass-fired boiler, the use
of the wet FGD system would have significant energy, environmental, and economic impacts. The use of
a wet FGD system would consume large amounts of water and result in a new wastewater discharge
stream. The wet FGD system would also produce a distinct visual plume, and would produce a new
byproduct stream which may require disposal. A wet FGD system would also require substantial
auxiliary electric power requirements. Finally, the use of a wet FGD system would have an average cost
effectiveness of $43,800 per ton of SO2 removed. This cost is not economically feasible.
Based on this analysis, wet FGD does not represent the best available control technology for this biomass
fuel-fired boiler.

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TABLE 7-5. Cost effectiveness of the SO2 control technology options for the biomass-fired boiler.
Low Sulfur
Sorbent
Parameter Wet FGD Dry FGD Biomass
Injection
Fuels
Control Efficiency 78% 67% 45% 0%
Controlled Emission Rate, lb/mmBtu 0.02 0.03 0.05 0.09
Total Boiler Heat Input, mmBtu 800 800 800 800
Capacity Factor, % 88% 88% 88% 88%
Actual Emissions, tons per year 62 93 153 278
Total Capital Requirement, $ $52,642,000 $39,963,000 $3,295,000 $0
Capital Recovery Factor (CRF) 0.1098 0.1098 0.1098 0.1098
Annual Capital Cost, $/yr $5,780,000 $4,388,000 $362,000 n/a
Annual O&M Cost, $/yr $3,683,000 $3,025,000 $881,000 n/a
Total Annual Cost, $/yr $9,463,000 $7,413,000 $1,243,000 $0
Average Annual Cost, $/yr $9,463,000 $7,413,000 $1,243,000
Average SO2 Reduction, tons per year 216 185 125
Average Cost per Ton Reduced, $ per ton $43,840 $40,070 $9,950
Incremental Annual Cost, $/yr $2,050,000 $6,170,000
Incremental SO2 Reduction, tons per year 31 60
Incremental Cost per Ton Reduced, $ per ton $66,500 $102,600
Footnotes
1. "Annual Capital Cost" or capital recovery cost is calculated by multiplying the capital recovery factor (CRF) by
the Total Capital Requirement as detailed in the U.S. EPA's EPA Air Pollution Control Cost Manual - Sixth Edition
(EPA 452/B-02-001):
i (1 + i ) n where:
CRF =
[
(1 + i ) − 1
n
] i = annual interest rate = 7.0%
6. "Average SO2 Reduction" is the emissions of the uncontrolled boiler minus the emissions of the control option.

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7.5.2 Rank No. 2: Dry Flue Gas Desulfurization.

The next most effective SO2 control option is the use of a dry FGD system in combination with firing
biomass fuels. Based on the above analysis, a dry FGD system could reduce potential SO2 emissions
from the biomass-fired boiler to 0.03 lb/mmBtu, and 93 tons per year. However, a dry FGD system
would also consume large amounts of water – although less than that of a wet FGD system. A dry FGD
system would increase ash generation rates and would impact the flyash properties which may reduce the
flyash value for reuse and result in increased ash disposal requirements.
As with wet FGD systems, a dry FGD system would also require additional auxiliary electric power
requirements to operate injection pumps and for the induced draft fan requirements to overcome the dry
FGD system pressure drop.
Table 7-5 includes a summary of the SO2 control technology costs. A dry FGD system is expected to
have a total capital cost of $40 million, annual O&M costs of $3.0 million, and a total annual cost of $7.4
million. From Table 7-5, a dry FGD system would reduce actual SO2 emissions by 185 tons per year as
compared to the uncontrolled biomass fuels emission rate and an annual capacity factor of 88%. This
results in an average cost effectiveness for a dry FGD system of $40,070 per ton of SO2 controlled.
In addition, the use of a dry FGD system would have an increased incremental cost of $6.2 million per
year as compared to the use of sorbent injection. The dry FGD system would reduce SO2 emissions by 60
tons per year as compared to the use of a sorbent injection system. This would result in an incremental
cost effectiveness of dry FGD, as compared to sorbent injection, of $102,600 per ton of SO2 controlled.
Conclusion.
While a dry FGD SO2 control system is technically feasible for the proposed biomass-fired boiler, the use
of a dry FGD system would have significant energy, environmental, and economic impacts. The use of a
dry FGD system would also consume large amounts of water - although less than that of a wet FGD
system, and its use may adversely impact the flyash properties and reduce its value for reuse. A dry FGD
system would also require substantial auxiliary electric power requirements. Finally, the use of a dry
FGD system would have an average cost effectiveness of $40,070 per ton of SO2 removed. This cost is
not economically feasible.
Based on this analysis, dry FGD does not represent the best available control technology for this biomass
fuel-fired boiler.

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7.5.3 Rank No. 3: Sorbent Injection.

The next most effective SO2 control option is the use of a dry sorbent injection system in combination
with firing biomass fuels. Based on the above analysis, a dry sorbent injection system could reduce
potential SO2 emissions from the biomass-fired boiler to 0.05 lb/mmBtu, and 153 tons per year.
However, like the dry FGD system, a dry sorbent injection system would increase ash generation rates
and may adversely impact the flyash properties which may reduce its value for reuse and increase ash
disposal requirements.
As with wet and dry FGD systems, a dry sorbent injection system would also require additional auxiliary
electric power requirements to operate injection pumps and for the induced draft fan requirements to
overcome the additional fabric filter baghouse pressure drop due to the sorbent injection.
Table 7-5 includes a summary of the SO2 control technology costs. A dry sorbent injection system is
expected to have a total capital cost of $3.3 million, annual O&M costs of $880,000, and a total annual
cost of $1.2 million. From Table 7-5, a dry sorbent injection system would reduce actual SO2 emissions
by 125 tons per year as compared to the uncontrolled biomass fuels emission rate and an annual capacity
factor of 88%. This results in an average cost effectiveness for a dry FGD system of $9,950 per ton of
SO2 controlled.
Conclusion.
While a dry sorbent injection SO2 control system is technically feasible for this proposed biomass-fired
boiler, the use of a dry sorbent injection system would have significant energy, environmental, and
economic impacts. Like the use of a dry FGD system, the use of a dry sorbent injection may adversely
impact the flyash properties and reduce its value for reuse. A dry sorbent injection system would also
require substantial auxiliary electric power requirements. Finally, the use of a dry sorbent injection
system would have an average cost effectiveness of $9,950 per ton of SO2 removed. This cost is not
economically feasible.
Based on this analysis, dry sorbent injection does not represent the best available control technology for
this biomass fuel-fired boiler.
7.5.4 Rank No. 4: Low Sulfur Biomass Fuels.

The use of low sulfur biomass fuels in a circulating fluidized bed boiler is expected to have SO2 emissions
of 0.09 lb/mmBtu, and 350 tons per year. Based on this analysis, the use of low sulfur biomass fuels in a
circulating fluidized bed boiler represents the best available control technology for this biomass fuels-
fired boiler.

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7.6 STEP 5. Proposed Sulfur Dioxide BACT Determination.
Based on this analysis, We Energies has concluded that the use of low sulfur biomass fuels and natural
gas in a circulating fluidized bed boiler represents BACT for SO2 emissions for the biomass fuels-fired
CFB boiler. Based on this analysis, We Energies proposes the following limits as BACT for the control
of SO2 emissions from this biomass fuels-fired boiler.
(1) Sulfur dioxide (SO2) emissions from the biomass fuels-fired boiler shall be controlled
using a circulating fluidized bed boiler in combination with the use biomass fuels and
natural gas as the best available control technology.
(a) Only natural gas and biomass fuels may be combusted in the boiler.
(b) “Biomass fuels” means a resource that derives energy from wood or plant material or
residue, clean solid wood waste and crops grown for use as a resource. Fuel sources may
include the following and other qualifying clean sources:
• logging residue
• discarded woody material from primary manufacturing facilities such as paper mills,
sawmills, or chip mills
• on-site pulp & paper wastewater treatment plant residue
• leftover woody material from secondary manufacturers such as door, window,
cabinet manufacturers
• woody biomass from municipality wood waste, tree services, and construction
companies
• clean solid wood waste from discarded wood packaging such as pallets/crating and
from construction and demolition activities
• woody biomass plantations, energy crops and agricultural residues
“Biomass fuels” excludes edible portions of food crops, refuse derived fuel, treated
wood, municipal solid waste, sewerage sludge, and animal waste.
(2) SO2 emissions may not exceed 0.09 pounds per million Btu of heat input, averaged
over any consecutive 30-day period.
(3) SO2 emissions from the biomass-fired boiler shall be continuously monitored and
recorded using a continuous emissions monitoring system meeting the requirements
of 40 CFR Part 75.

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Chapter 8. Organic Compound (VOC)
As with CO emissions, volatile organic compounds (VOC) are emitted from biomass-fired boilers as a
result of incomplete combustion. CO and VOC emissions from the combustion of biomass fuels are
normally expected to be somewhat elevated as compared to the combustion of natural gas, fuel oil, and
coal because of the high moisture content and relatively low heating value of most biomass fuels.
Incomplete combustion can also result in emissions of particulate matter, CO, and organic hazardous air
pollutants, and it reduces boiler efficiency. Because fuel costs represent the highest single operating cost
for these boilers, large industrial boilers are designed to achieve the highest combustion efficiencies
practicable. VOC emissions can be reduced by operating the boiler with higher flame temperatures,
higher excess oxygen levels, and longer furnace residence times. Unfortunately, techniques for reducing
VOC emissions can increase NOx emissions. Consequently, as with CO emissions, achieving low VOC
and NOx emission rates is a balancing act in boiler design and operation.
8.1 BACT Baseline.

There are no specific state implementation plan (SIP) requirements or new source performance standards
for VOC emissions from biomass or fossil fuel-fired boilers. Therefore, baseline emissions are simply the
uncontrolled emissions from the boiler.
8.2 STEP 1. Identify All Available Control Technologies.

Table 8-1 is a summary of VOC BACT emission limits for both new biomass-fired boilers contained in
the U.S. EPA’s RACT/BACT/LAER Clearinghouse, and in other permits issued in the United States.
Emission limits range from 0.005 to 0.50 pounds per million Btu.
Except for one facility, the only technology selected for all permitted biomass-fired boilers is good
combustion practices. For the South Point Biomass Generation facility (Ohio, 2006), the facility was
required to install an oxidation catalyst. However, this facility has not been constructed.

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TABLE 8-1. Biomass-fired boiler VOC emission limits representing BACT.
Permit Capacity, Limit,
Date mmBtu/hr lb/mmBtu
Public Service of NH - Schiller Station NH Oct-04 720 Biomass 0.005
S.D. Warren Co. ME Nov-01 1,300 Wood Waste 0.007
Northern Michigan University MI Nov-09 210 Wood/Biomass 0.017
South Point Biomass Generation OH Apr-06 318 Wood 0.013
Skagit County Lumber Mill WA Jan-06 430 Bark/Waste Wood 0.019
Yellow Pine Energy Company GA May-09 1,529 Wood 0.02
Wheelabrator Sherman Energy Co. ME Apr-99 315 Wood 0.030
Inland Paperboard and Packaging, Inc. GA Oct-04 856 Bark 0.050
Clewiston Sugar Mill FL Nov-03 936 Bagasse 0.050
Del Tin Fiber LLC AR Feb-03 291 Wood Waste 0.073
Deridder Paper Mill LA Nov-03 454 Bark 0.096
U.S. Sugar Clewiston Mill FL Nov-00 633 Bagasse 0.500
U.S. Sugar Corporation FL Nov-99 633 Bagasse 0.500

Available control technologies for the control of VOC emissions include good combustion practices,
oxidation catalysts, and thermal oxidation.
8.3.1 Oxidation Catalysts.

Oxidation catalysts are used to reduce CO emissions - and to a lesser extent VOC emissions - from
natural gas or oil-fired combustion turbines, with typical VOC reductions of 50% or less. However,
oxidation catalysts have limited demonstration on biomass-fired boilers, and we are not aware of any
demonstration or commercial operation of oxidation catalysts on a fluidized bed boiler. Boilers have
several characteristics that make the use of oxidation catalysts technically infeasible, including catalyst
fouling and poisoning by the wood fly ash, and low excess oxygen levels in the flue gas.
Oxidation catalysts are generally noble metal catalysts which are susceptible to poisoning from sulfur and
calcium bearing compounds. These catalysts may experience rapid deactivation and fouling in biomass-
fired boiler flue gas streams with high particulate loading. To be effective, the oxidation catalyst must be
placed in a location with gas temperatures of at least 600 oF. This location would be near the boiler
economizer outlets, a location with high ash loading and low excess oxygen levels.
A research effort to assess catalyst deactivation mechanisms was presented at the 2008 Advanced
Combustion Engineering Research Center conference reported that SCR catalyst poisoning is the
predominant deactivation mechanism resulting from biomass combustion. Note that oxidation catalysts
- 79 -
and SCR catalysts have similar poisoning mechanisms. The study ranks the order of poisoning of the
alkali-metals and alkaline-earth metals from having the most effect to lesser effect as potassium, followed
by sodium, followed by calcium, and states that the “effects are proportional to basicity of the exhaust
gas.” 16 The study includes Figure 3-2 (refer to the CO control technology section) showing the difference
in of coal versus biomass ash composition.
gas tends to be acidic. This exacerbates the catalyst deactivation and is the primary reason that oxidation
catalyst and SCR systems located in a high dust environment are not applicable to biomass combustors.
This problem is worsened by the CFB boiler design which has an extremely high dust loading. Erosion,
plugging, and blinding are major potential problems in fluidized bed boiler applications due to the very
high particulate loading in the boiler.
To reduce the fouling and catalyst poisoning problems, the oxidation catalyst can be located downstream
of the particulate matter control device. However, this “tail gas” oxidation catalyst control configuration
does not eliminate fouling and deactivation, since the exhaust gas stream remains highly alkaline.
To reduce the ash fouling and catalyst poisoning problems, the oxidation catalyst can be located
downstream of the particulate matter control device. However, this “tail gas” oxidation catalyst control
configuration has another problem; the lack of sufficient excess oxygen to effectively reduce VOC
emissions. Oxidation catalysts operate according to the following reaction for propane as an example:
C3H8 + 5O2 → 3CO2 + 4H2O
Typical excess oxygen (O2) levels in combustion turbines is 12 – 15%, compared to 3 – 6% in biomass-
fired boilers. These low excess O2 levels will limit the effectiveness of the oxidation catalyst.
Because of these serious technical problems and the fact that oxidation catalysts have not been
demonstrated on similar circulating fluidized bed biomass boilers, we have concluded that oxidation
catalysts are not a technically feasible CO control technology for these biomass-fired boilers.
8.3.2 Thermal Oxidation

Thermal oxidation has never been required nor used on a biomass-fired boiler, and its theoretical ability
to reduce VOC emissions from these boilers is questionable. Thermal oxidation would involve injecting
additional air into the flue gas and heating the oxygen enriched mixture to approximately 1,500 oF to
oxidize VOC to carbon dioxide and water. However, since the combustion of the reheat fuel would itself
result in VOC emissions, there is no evidence that thermal oxidation would result in any CO emission
reductions. Since thermal oxidation has never been demonstrated on a biomass-fired boiler, and because
16
Guo, X., et. al. Poisoning/Deactivation Study of V2O5/TiO2 SCR Catalysts, ACERC Annual Conference,
February 2008.

- 80 -
there is no evidence that it could reduce VOC emissions, thermal oxidation is not a technically feasible
VOC control technology for coal-fired boilers.
8.3.3 Good Combustion Practices

Good combustion practices or combustion controls generally include the following components:
1. Good air/fuel mixing in the combustion zone.
2. High temperatures and low oxygen levels in the primary combustion zone.
3. Overall excess oxygen levels high enough to complete combustion while maximizing
boiler thermal efficiency.
4. Sufficient residence time to complete combustion.
In biomass-fired boilers, good combustion practices is the only technically feasible VOC control
technology. Combustion efficiency is related to the three “T’s” of combustion: Time, Temperature, and
Turbulence. These components of combustion efficiency are designed into utility boilers to maximize
fuel efficiency and reduce the highest single operating cost of a utility boiler: FUEL. A fourth critical
parameter is the level of oxygen in the boiler, referred to as the excess air or excess oxygen level.
Therefore, combustion control is accomplished primarily through boiler design as it relates to time,
temperature, and turbulence, and through boiler operation as it relates to excess oxygen levels.
Combustion design for modern boilers is intended to simultaneously minimize formation of VOC and
NOx emissions. This is a difficult task, since emissions of NOx and emissions of CO and VOC are
inversely related. That is, measures used to reduce NOx emissions often lead to increases in VOC
emissions. Therefore, the boiler design to minimize VOC emissions is interrelated with the boiler design
to minimize NOx formation.

Based on the above analysis, the only technically feasible VOC control technology for biomass-fired
boilers is good combustion practices.

From Table 8-1, recent BACT determinations have VOC limits ranging from 0.005 to 0.5 lb/mmBtu.
Fluidized bed boilers are efficient boilers, and are generally expected to achieve low VOC emission rates.
However, boiler startup, shutdown, and load changes can causes VOC emissions to increase because of
unstable combustion conditions. Like CO emissions, VOC emissions are also sensitive to boiler
operating conditions. Changes in operating conditions, such as rapid changes in load, can have a
significant, though temporary, impact on emissions. This condition is further exasperated during boiler
startup because the boiler itself is relatively cool, and the low air flow rates make it difficult to obtain
good air/fuel mixing. For these reasons, VOC emissions can “spike” when transient conditions occur
during boiler startup and shut down

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Based on the above analysis, we have concluded that good combustion practices can achieve a VOC
emission rate of 0.017 pounds per million Btu based on a 30-day average, excluding periods of startup
and shutdown. Further, we have concluded that these boilers can achieve a VOC emission rate of 0.017
pounds per million Btu based on a 12-month average, including periods of startup and shutdown.
8.6 STEP 5. Proposed VOC BACT Determination.

Based on this analysis, We Energies has concluded that the use of good combustion practices is the best
available control technology (BACT) for VOC emissions from the biomass-fired boiler. Based on this
analysis, We Energies proposes the following limits as BACT for the control of VOC emissions from the
biomass-fired, circulating fluidized bed boiler.
(1) Volatile organic compound (VOC) emissions from the biomass-fired

boiler shall be controlled using good combustion practices as the best
(2) Volatile organic compound (VOC) emissions may not exceed 0.017
pounds per million Btu of heat input, excluding periods of boiler
startup and shut down, averaged over any consecutive 30-day period.
(3) Volatile organic compound (VOC) emissions may not exceed 0.017
pounds per million Btu of heat input, for all periods, including periods
of boiler startup and shut down, averaged over any consecutive
12-month period.

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Chapter 9. Fluorides (as HF) Control
Technology Review.
Fluorine (F) is a trace element in biomass fuels. When these fuels are burned, fluorine may be emitted as
hydrogen fluoride or hydrofluoric acid (HF), or as fluorine compounds, such as sodium fluoride (NaF)
and calcium fluoride (CaF2). Fluoride compounds such as sodium and calcium fluoride are solids at the
flue gas temperatures entering the particulate matter control systems, and will therefore be collected as
solids. On the other hand, hydrogen fluoride is a colorless liquid at temperatures less than 66 oF. At
temperatures above 66 oF, hydrofluoric acid is a gas. Hydrofluoric acid is soluble in water and is a strong
acid, it readily combines with the alkaline ash of biomass fuels.
9.1 BACT Baseline.

There are no specific NSPS or SIP emission limitations for fluoride emissions from biomass-fired boilers.
Therefore, the BACT baseline for fluoride emissions is the uncontrolled emission rate.
9.2 STEP 1. Identify All Potential Control Technologies

Based on the permits and information available, We Energies did not identify any wood-fired boiler with
a hydrogen fluoride (HF) emission limit. There is a limited amount of information available on fluoride
levels in biomass fuels. According to NCASI Technical Bulletin No. 0837, Emissions of Sulfuric,
Hydrochloric, and Hydrofluoric Acids from Combination Bark Boilers, HF emissions ranged from
0.00023 to 0.0011 lb/mmBtu for the coal/bark boilers and from 0.000016 to 0.000074 lb/mmBtu for the
oil/bark boilers.
According to the U.S. EPA’s MACT database emission factors from the U.S. EPA memorandum from
Christy Burlew and Roy Oommen, to Jim Eddinger, U.S. Environmental Protection Agency, OAQPS
(C439-01), dated October, 2002, Development of Average Emission Factors and Baseline Emission
Estimates for the Industrial, Commercial, and Institutional Boilers and Process Heaters National
Emission Standard for Hazardous Air Pollutants, the emission factor for HF emissions from wood-fired
boilers is 0.0081 lb/mmBtu. The U.S. EPA’s AP-42, Compilation of Air Pollutant Emission Factors, 5th
Edition, Wood Residue Combustion, does not list an emission factor for HF emissions. In Switzerland,
the combustion requirements for wood limit HF emissions to 2 mg/m3, equal to 0.0011 lb/mmBtu.
(ICR No. 2286.01) and the Phase II test plan (ICR No. 2286.03). The hydrogen fluoride stack test data for

- 83 -
biomass combustion is summarized in Table 9-1. Emission rates ranged from less than 0.000003 to
0.0012 lb/mmBtu, a range of 3 orders of magnitude. Many of the emission test results indicated HF
emissions below the detection limit of the test.
TABLE 9-1. Biomass-fired boiler hydrogen fluoride (HF) emission test results.
Standardized
Non-
Facility ID Value, Fuel
Detect?
lb/mmBtu
AR Potlatch Forest Warren < 0.000003 Hog Fuel
MS Bowater South ND 0.000010 Industrial Sludge/Natural Gas/Wood: Bark
OR Flakeboard Eugene 0.000016 Natural Gas/Wood: Unadulterated Lumber
MT Plum Creek BDL 0.000017 Wood: Bark/Wood: Plywood, Particleboard
AL Meadwestvaco Cottonton ND 0.000018 Industrial Sludge/Natural Gas/Wood: Bark
Biomass/Hydropulper Refuse/Industrial Sludge
MT Smurfit Stone BDL 0.000029
/Natural Gas
GA GP Madison Ply ND 0.000040 Wood: Bark
ID Potlatch 0.000043 Hog Fuel
MS Weyerhaeuser Bruce 0.000050 Hog Fuel
Industrial Sludge/Wood: Bark/Natural Gas/Wood:
SC Marlboro Paper ND 0.000070
Plywood, Particleboard (containing glues or resins)
GA Temple Inland Rome 0.000072 Wood: Bark
TN Bowater Newsprint ND 0.000075 Biomass/Tire Derived Fuel (TDF)/Wood: Bark
AR Anthony Forest Product ND 0.000083 Wood: Bark/Wood: Unadulterated Lumber/Wood
PA Proctor Gamble Mehoopany ND 0.000085 Natural Gas/Paper and Paper Residues
ND Cargill West Fargo BDL 0.000089 Biomass
OR Rosboro Springfield 0.000100 Hog Fuel
KY NewPage-Wickliffe ND 0.000128 Natural Gas/Tire Derived Fuel (TDF)/Wood: Bark
AR Weyerhaeuser Dierks Mill ND 0.000200 Hog Fuel
TN Domtar 2384 0.000200 Hog Fuel/Industrial Sludge
WA Grays Harbor Paper 0.000200 Hog Fuel
OR Weyerhaeuser Co.
ND 0.000259 Hog Fuel
Warrenton Lumber Mill
WA Weyerhaeuser Raymond ND 0.000290 Hog Fuel
ME Boralex Stratton 0.000294 Wood: Bark/Wood: Unadulterated Timber
OR Georgia Pacific Wauna BDL 0.000341 Hog Fuel/Industrial Sludge/Natural Gas
WA Kimberly Clark Everett 0.000360 Hog Fuel/Natural Gas
WA Boise Paper Wallula 0.001005 Hog Fuel/Natural Gas/Noncondensable Gas
WA Grays Harbor Paper 0.001100 Hog Fuel
OR SP Newsprint 0.001200 Biomass/Industrial Sludge/Natural Gas

- 84 -
As noted above, fluoride emissions may be emitted as solids, such as sodium fluoride, or as the acid gas
hydrogen fluoride. Therefore, fluoride emissions may be controlled using particulate matter control
systems, and also acid gas control systems. Technologies that may control fluoride emissions include
fabric filter baghouses, electrostatic precipitators, wet or dry FGD systems, and sorbent injection.
9.3.1 Flue Gas Desulfurization Systems.

Wet and dry flue gas desulfurization systems are effective fluoride control systems. From the EPRI
report, Emission Factors Handbook: Guidelines for Estimating Trace Substance Emissions from Fossil
fuel Steam Electric Plants, Final Report, April, 2002, the expected HF control efficiency for all coal-fired
FGD systems is 94%. There is limited additional information available on HF removal in FGD systems,
especially for biomass combustion. There is very little information on FGD systems for biomass
combustion, since there are essentially no biomass-fired boilers equipped with FGD systems.

Sorbent injection such as the injection of hydrated lime may also reduce emissions of HF. The injection
of lime into the flue gas upstream of a fabric filter baghouse or electrostatic precipitator is well
demonstrated to reduce H2SO4 emissions. However, the continuous reduction of HF via hydrated lime
injection from biomass combustion is not well understood or demonstrated in practice. Further, because
biomass combustion already results in high levels of calcium oxide (CaO) and potassium oxide (K2O) in
the ash, so that the additional injection of sorbent may not achieve substantial emission reductions.
9.4 STEP 3. Rank The Technically Feasible Control Technologies.
9.4.1 Biomass Fuels.

There has been a very limited amount of information available on fluoride levels in biomass fuels.
According to NCASI Technical Bulletin No. 0837, Emissions of Sulfuric, Hydrochloric, and Hydrofluoric
Acids from Combination Bark Boilers, HF emissions ranged from 0.00023 to 0.0011 lb/mmBtu for the
coal/bark boilers and from 0.000016 to 0.000074 lb/mmBtu for the oil/bark boilers.
According to the U.S. EPA’s MACT database emission factors from the U.S. EPA memorandum from
Christy Burlew and Roy Oommen, to Jim Eddinger, U.S. Environmental Protection Agency, OAQPS
(C439-01), dated October, 2002, Development of Average Emission Factors and Baseline Emission
Estimates for the Industrial, Commercial, and Institutional Boilers and Process Heaters National
Emission Standard for Hazardous Air Pollutants, the emission factor for HF emissions from wood-fueled
boilers is 0.0081 lb/mmBtu. The U.S. EPA’s AP-42, Compilation of Air Pollutant Emission Factors, 5th
Edition, Wood Residue Combustion, does not list an emission factor for HF emissions. In Switzerland,
the combustion requirements for wood limit HF emissions to 2 mg/m3, equal to 0.0011 lb/mmBtu.

- 85 -
(ICR No. 2286.01) and the Phase II test plan (ICR No. 2286.03). The database included both fuel
sampling and analysis data for HF, as well as emission test data for HF from biomass-fueled boilers. The
HF fuel sampling and analysis data included over 350 samples for biomass fuels (with descriptions
including wood, bark, plywood, particleboard, hog fuel, and biomass). The HF fuel sampling and
analysis data ranged from 1.1 x 10-6 lb/mmBtu to 0.033 lb/mmBtu. The database also included HF
emission test data using U.S. EPA Reference Method 26. The HF emission test data included 34 tests on
biomass-fueled boilers, with emission rates ranging from 0.000003 lb/mmBtu to 0.0012 lb/mmBtu.
Nineteen (19) of the emission test results indicated HF emissions below the detection limit of the test.
This ICR data is plotted in Figure 9-1 as probability distributions for each data set. The 90% probability
for the HF emission rate, based on fuel sampling and analysis, is 0.006 lb/mmBtu, while the 90%
probability distribution for the HF emission rate, based on emission testing, is 0.0007 lb/mmBtu. This
data suggests that the actual HF emissions are reduced by almost 90% as compared to the uncontrolled,
fuel input or potential combustion concentration for HF.
FIGURE 9-1. Hydrogen fluoride (HF) fuel sampling and analysis and emission test data for
biomass combustion from the U.S. EPA’s industrial boiler ICR.
100%
90%
HF Emission Test Data

80%
HF Fuel Sampling Data
70%
Probability Density
60%
50%
40%
30%
20%
90% Probability, 90% Probability,
0.0007 0.006 lb/mmBtu
10%
0%
0.00001 0.00010 0.00100 0.01000 0.10000
HF Emission Rate, lb/million Btu

- 86 -
This outcome seems logical because of the high levels of calcium and potassium in typical biomass fuels.
Typical biomass fuels have a CaO level of 1.19 lb CaO/100 lb dry fuel, or 0.0213 moles of calcium per
100 lb dry fuel. From the TCR fuel sampling database, the biomass fuels have a typical fluorine content
of well below 100 mg per kg, or 0.01%. A fluorine content of 0.01% is equal to 0.0005 moles of fluorine
per 100 lb dry fuel. Therefore, the effective calcium to fluorine ratio in the boiler when firing this typical
biomass fuel is more than forty to one (40:1). This high level of reactive CaO would be expected to react
with HF in the flue gas to form calcium fluoride.
Based on the available data, we have concluded that HF emissions from this biomass-fueled boiler is
expected to be less than 0.001 lb/mmBtu.
9.4.2 Flue Gas Desulfurization.

As noted above, the EPRI report, Emission Factors Handbook: Guidelines for Estimating Trace
Substance Emissions from Fossil fuel Steam Electric Plants, indicates an HF control efficiency for all
coal-fired FGD systems of 94%. However, there is limited information available on HF removal in FGD
systems, especially for biomass combustion. Because of the high level of calcium and potassium in the
biomass ash, further reduction from FGD systems cannot be assured. For this analysis, wet and dry FGD
systems are expected to reduce HF emissions to 0.0005 lb/mmBtu, equal to a flue gas concentration of 0.8
ppm at 5% excess oxygen.

As with the wet and dry FGD options, because of the high level of calcium and potassium in the biomass
ash, further reduction from sorbent injection systems cannot be assured. For this analysis, dry sorbent
injection is also expected to reduce HF emissions to 0.0005 lb/mmBtu, equal to a flue gas concentration
of 0.8 ppm at 5% excess oxygen..
9.4.4 Ranking of the Technically Feasible Control Options.

Table 9-2 is a summary of the ranking of the technically feasible HF control technologies based on the
above analysis of available technologies.
TABLE 9-2. Ranking of the technically feasible HF control technologies.
Rank Control System Expected Performance, lb/mmBtu
1 Wet or Dry FGD 0.0005
2 Sorbent Injection 0.0005
3 Low Sulfur Biomass Fuels 0.001

- 87 -
9.5.1 Rank No. 1: Wet FGD, Dry FGD, or Dry Sorbent Injection.

The most effective fluorides control option is the use of either a wet or dry FGD system, or dry sorbent
injection, in combination with firing biomass fuels. Based on the above analysis, these control systems
could reduce potential HF emissions from the biomass-fired boiler to 0.001 lb/mmBtu, and 3.3 tons per
year. However, wet and dry FGD systems would consume large amounts of water. A wet FGD system
would also produce a distinct visual plume and a new gypsum byproduct stream. In addition, all of these
post combustion systems would require additional auxiliary electric power requirements.
Table 9-3 includes a summary of the hydrogen fluorides control technology costs. From Table 9-3, the
use of dry sorbent injection, the lowest cost option, would reduce actual HF emissions by 1.5 tons per
year as compared to the uncontrolled biomass fuels emission rate and an annual capacity factor of 88%.
A dry sorbent injection system is expected to have a total capital cost of $3.3 million, annual O&M costs
of $880,000, and a total annual cost of $1.2 million. This results in an average cost effectiveness for the
dry sorbent injection system of $806,000 per ton of HF controlled.
Conclusion.
While the use of wet FGD, dry FGD, or sorbent injection control systems are technically feasible for the
proposed biomass-fired boiler, the use of these post combustion control systems would have significant
energy, environmental, and economic impacts. However, wet and dry FGD systems would consume large
amounts of water. A wet FGD system would also produce a distinct visual plume and a new gypsum
byproduct stream. In addition, all of these post combustion systems would require additional auxiliary
electric power requirements.
The use of dry sorbent injection, the lowest cost option, would reduce actual HF emissions by 1.5 tons per
year and a total annual cost of $1.2 million. This results in an average cost effectiveness for the dry
sorbent injection system of $806,000 per ton of HF controlled. This cost is not economically feasible.
Based on this analysis, the use of wet FGD, dry FGD, or dry sorbent injection does not represent the best
available control technology for the control of HF emissions from this biomass fuels-fired boiler.

- 88 -
TABLE 9-3. Cost effectiveness of the HF control technology options for the biomass-fired boiler.
Low Sulfur
Sorbent
Parameter Wet FGD Dry FGD Biomass
Injection
Fuels
Control Efficiency 50% 50% 50% 0%
Controlled Emission Rate, lb/mmBtu 0.0005 0.0005 0.0005 0.001
Total Boiler Heat Input, mmBtu 800 800 800 800
Capacity Factor, % 88% 88% 88% 88%
Actual Emissions, tons per year 1.5 1.5 1.5 3.1
Total Capital Requirement, $ $52,642,000 $39,963,000 $3,295,000 $0
Capital Recovery Factor (CRF) 0.1098 0.1098 0.1098 0.1098
Annual Capital Cost, $/yr $5,780,000 $4,388,000 $362,000 n/a
Annual O&M Cost, $/yr $3,683,000 $3,025,000 $881,000 n/a
Total Annual Cost, $/yr $9,463,000 $7,413,000 $1,243,000 $0
Average Annual Cost, $/yr $9,463,000 $7,413,000 $1,243,000
Average HF Reduction, tons per year 1.5 1.5 1.5
Average Cost per Ton Reduced, $ per ton $6,137,800 $4,808,100 $806,200
Incremental Annual Cost, $/yr $2,050,000 $6,170,000
Incremental HF Reduction, tons per year 0 0
Incremental Cost per Ton Reduced, $ per ton n/a n/a
Footnotes
1. "Annual Capital Cost" or capital recovery cost is calculated by multiplying the capital recovery factor (CRF) by
the Total Capital Requirement as detailed in the U.S. EPA's EPA Air Pollution Control Cost Manual - Sixth Edition
(EPA 452/B-02-001):
i (1 + i ) n where:
CRF =
[
(1 + i ) − 1
n
] i = annual interest rate = 7.0%
6. "Average Reduction" is the emissions of the uncontrolled boiler minus the emissions of the control option.

- 89 -
9.6 STEP 5. Proposed Fluorides BACT Determination
Based on this analysis, We Energies has concluded that the combustion of low fluorine containing
biomass fuels is the best available control technology (BACT) for HF emissions from the biomass-fired
boiler. Based on this analysis, We Energies proposes the following limits as BACT for the control of HF
emissions from the biomass-fired, circulating fluidized bed boiler.
(1) Hydrogen fluoride (HF) emissions from the biomass-fired boiler shall be controlled
using biomass fuels and natural gas as the best available control technology.
(a) Only natural gas and biomass fuels may be combusted in the boiler.
(b) “Biomass fuels” means a resource that derives energy from wood or plant material or
residue, clean solid wood waste and crops grown for use as a resource. Fuel sources may
include the following and other qualifying clean sources:
• logging residue
• discarded woody material from primary manufacturing facilities such as paper mills,
sawmills, or chip mills
• on-site pulp & paper wastewater treatment plant residue
• leftover woody material from secondary manufacturers such as door, window,
cabinet manufacturers
• woody biomass from municipality wood waste, tree services, and construction
companies
• clean solid wood waste from discarded wood packaging such as pallets/crating and
from construction and demolition activities
• woody biomass plantations, energy crops and agricultural residues
“Biomass fuels” excludes edible portions of food crops, refuse derived fuel, treated
wood, municipal solid waste, sewerage sludge, and animal waste.

- 90 -
Attachment 1.
Cost estimates for a Tail Gas or Regenerative Selective Catalytic Reduction
(SCR) system.

Attachment 1.
Cost estimates for a Tail Gas or Regenerative Selective Catalytic Reduction (SCR) system.
Page 1 and 2 of 8
1
Selective Catalytic Reduction (SCR) Control Technology Parameters .
SCR Equation Inputs

Variable Description Value
2
Qb Boiler Size (mmBtu/hr) 800
NOxin NOx inlet (lb/mmBtu) 0.15
NOxin NOx outlet (lb/mmBtu)4 0.06
5
Plant wide capacity factor 88%
6
S Sulfur content of fuel (weight fraction) 0.01
7
T Gas temperature (°F) 650
NSCR Number of reactor chambers8 1
SCR Parameter Estimates

Variable Description Units Reference9 Value
3
q fuel Volumetric flow rate for fuel ft /min-MMBtu/hr Table 2.4 516
10
q flue gas Flue gas flow rate acfm Calculated Value 323,789
ASR Actual Stoichiometric ratio (ASR) 2.11 1.05
Slip Theoretical ammonia slip11 ppm by volume Page 2-37 10.00
ηadj Efficiency adjustment factor 2.20 1.13
NOxadj NOx adjustment factor 2.21 0.90
Slipadj Ammonia slip adjustment factor 2.22 0.72
Sadj Sulfur in fuel adjustment factor 2.23 0.96
Tadj Temperature adjustment factor 2.24 1.15
NSCR Number of reactor chambers8 1.00
3
Volcatalyst Volume of catalyst ft 2.19 1816
2
Acatalyst Catalyst cross sectional area ft 2.25 337
2
ASCR Reactor cross sectional area ft 2.26 388
l Length and width of reactor ft 2.27 19.7
h'layer Nominal catalyst height ft Page 2-38 3.1
nlayer Number of catalyst layers 2.28 2.0
hlayer Height of each catalyst layer ft 2.29 3.7
nempty Estimated # of empty catalyst layers Page 2-53 1.0
ntotal Total # of catalyst layers 2.30 3.0
C1 Constants for hSCR equation-based on standard Page 2-39 7.0
C2 industry practice Page 2-39 9.0
hSCR Height of SCR reactor ft 2.31 41.1
Mreagent Molecular weight of ammonia g/mole Page 2-39 17.0
MNOx Molecular weight of NO2 g/mole Page 2-39 46.0
SRT Ratio of moles of NH3 per mole of reagent injected Page 1-24 1.0
mreagent Reagent mass flow rate12 lb/hr 2.32 37.3
13
Csol % concentration of aqueous reagent solution Page 2-40 0.19
We Energies 50 MW Renewable Fuels-Fired Facility RTP Environmental Associates, Inc.

Renewable Fuels-Fired Boiler Control Technology Review: Attachment 1. 3/4/2010
Attachment 1.
Page 1 and 2 of 8
1
Selective Catalytic Reduction (SCR) Control Technology Parameters .
SCR Equation Inputs

2
Qb Boiler Size (mmBtu/hr) 800
NOxin NOx inlet (lb/mmBtu) 0.15
NOxin NOx outlet (lb/mmBtu)4 0.06
5
Plant wide capacity factor 88%
6
S Sulfur content of fuel (weight fraction) 0.01
7
T Gas temperature (°F) 650
NSCR Number of reactor chambers8 1
SCR Parameter Estimates

Variable Description Units Reference9 Value
msol Mass flow rate of aqueous ammonia solution lb/hr 2.33 196
3
ρsol Density of aqueous ammonia solution lb/ft Page 2-40 56
3
υsol Specific volume of aqueous ammonia solution gal/ft Page 2-40 7.48
qsol Solution volume gph 2.34 26.2
t Operating days14 days Page 2-54 14
Ammonia Tank Volume gal 2.35 8814
CFPlant Boiler capacity factor 2.7 0.88
qreagent Assuming same as qsol 23.08
top Total Operating Time hours/yr 1.22a 7708.8
ΔPduct Pressure drop (used mid-range value) inches H2O Page 2-46 2.5
ΔPcatalyst Pressure drop (used mid-range value) inches H2O Page 2-46 0.875
Power Electrical power consumption kW 2.48 224.12
Costelect Electrical power costs15 $/kWh 2.49 0.066
Footnotes
1
Calculations based on the EPA Air Pollution Control Cost Manual (CCM), 6th Edition, 2002, EPA/452/B-02-001.
2
Gas temperature is assumed to be at 600 F before entering the SCR.
3
It is assumed that NSCR is equal to nSCR based on example on page 2-53.
4
Equation number or page number as listed in CCM under SCR section.
5
The ammonia slip must be between 2-5 ppm for the CCM equation to be valid.

Attachment 1.
Page 3 of 8
We Energies - 50MW Renewable Fuels-Fired Plant
Item Value
Operating Schedule
Plant Capacity Factor 88%
Total Operating Hours per Year 7,709
Shifts per day 3
Hours per day 24
Days per week 7
Boiler and SCR Parameters

Total Flue Gas Flowrate, acfm 323,789
o
SCR Operating Temperature, F (after reheat) 650
Uncontrolled NOx Emission Rate, lb/mmBtu 0.15
Total Heat Input Capacity 800
Total NOx Emissions at Plant Capacity Factor 463
SCR Control Efficiency, % 60
Electricity Cost, $/kWh 0.070
Operating Labor Cost, $ per hour $50
Maintenance Labor Cost, $ per hour $50
Economic and Financing Parameters

Economic Life, years 15
Interest Rate, % 7.0

Attachment 1.
Page 4 of 8
1
Selective Catalytic Reduction (SCR) Equipment Costs
Direct Cost Calculation

f(hSCR) Adjustment for SCR reactor height, $ per mmBtu per hour $ 63.49
f(NH3 rate) Adjustment for ammonia flow rate, $ per mmBtu per hour $ (28.13)
f(new) Adjustment for a new boiler, $ per mmBtu per hour $ -
f(bypass) Adjustment for installing SCR bypass, $ per mmBtu per hour $ -
3
CCinitial Initial catalyst cost, $/ft $ 240
f(Volcatalyst) Capital cost for initial charge of catalyst 1998 $ $ 435,861
DC Direct Capital Cost, 1998 $ $ 5,016,000
A Direct Capital Cost, 2009 $ $ 6,601,948
Total SCR Equipment Costs $ 6,602,000
Footnotes
1
Calculations based on the EPA Air Pollution Control Cost Manual (CCM), 6th Edition, 2002, EPA/452/B-02-001.
2
Taken from example on page 2-50 of SCR section of CCM.
3
CCM values are in 1998 dollars. Final cost values have been scaled to 2009 dollars using the consumer price index.
4
The allowance for funds used during construction is based on 50% of construction work in progress.

Attachment 1.
Page 5 of 8
Total Capital Requirements
Value Basis
Direct Costs
1.) Purchased Equipment Cost
a.) Equipment cost + auxiliaries $6,602,000 See Page 2 of 8
b.) Instrumentation $660,200 0.10 x A
c.) Sales taxes
d.) Freight $330,100 0.05 x A
Total Purchased equipment cost, (PEC) $7,592,300 B
2.) Direct installation costs
a.) Foundations and supports $379,600 0.10 x B
b.) Pilings $379,600 0.10 x B
c.) Handling and erection $1,518,500 0.20 x B
d.) Electrical $75,900 0.01 x B
e.) Piping $75,900 0.01 x B
f.) Insulation for ductwork & painting $75,900 0.01 x B
g.) Stack modification $151,800 0.02 x B
Total direct installation cost $3,036,920 0.40 x B
3.) Site preparation (including demolition)
4.) Buildings
Total Direct Cost, DC $10,629,200 1.30B + SP + Bldg.
Indirect Costs (installation)

5.) Engineering $759,200 0.10 x B
6.) Construction and field expenses $379,600 0.05 x B
7.) Contractor fees $759,200 0.10 x B
8.) Start-up $151,800 0.02 x B
9.) Performance test $75,900 0.01 x B
10.) Contingencies $1,518,500 0.2 x B
Total Indirect Cost, IC $3,644,200 0.35 x B + Other
Total Capital Investment (TCI) = DC + IC $14,273,400 1.61B + SP + Bldg. + Other

Attachment 1.
Page 6 of 8
Flue Gas Reheat Costs
Description Value
Total Flue Gas Flowrate1, scfm 323,789
o 1
Stack Temperature, F 315
o
SCR Temperature, F 600
o
Flue Gas Reheat Temperature Rise, F 285
Density of flue gas at standard conditions 2, lb/ft3 0.0779
Mass flow rate of Flue Gas, lb/hour 1,512,985
3 o
Heat Capacity of Flue Gas, Cp , Btu/lb- F 0.24
Heat Recovery, % 95%
Required heat Input, mmBtu per hour, Q 5.17
Reheat Requirements, mmBtu per year 39,888
6
Heating Value of Natural Gas, mmBtu/10 scf 1,050
Natural Gas Requirement, scf/year 37,989,034
Natural Gas Cost, $/1,000 scf $ 5.00
Total Reheat Natural Gas Cost, $ per year $ 189,945
Reheat Natural Gas NOx Emission Rate, lb/mmBtu 0.05
Reheat NOx Emissions, ton per year 1.00
Footnotes
1
Based on the estimated flue gas flow for the boiler at full load.
2
Density of flue gas is based on a flue gas molecular weight of 29.57 lb/lb-mole.
3
The specific heat capacity (Cp) for combustion products is from
http://www.engineeringtoolbox.com/spesific-heat-capacity-gases-d_159.html

Attachment 1.
Page 7 and 8 of 8
Total Annual Costs
Value Basis Source
1) Electricity
Total Power Requirement, kW 75 Additional ID fan requirements. Estimate
Electric Power Cost ($/kWh) 0.070
Cost ($/yr) $40,471
2) Operating Costs
Operating Labor Requirement (hr/shift) 1 1 hour per shift Estimate
Unit Cost, $ per hour $50.00 Estimate
Labor Cost, $ per year $54,600
3) Ammonia Reagent Costs
Ammonia Reagent Cost, $ per pound $0.81 Based on $1.30/gallon for 19% ammonia.
Ammonia Input requirement, lb/hr 55.2 Based on 1.2 moles NH3 per mole of NOx.
Annual Ammonia Requirement, lb/year 425,526
Total Ammonia Costs ($/year) $346,606
4) Natural Gas Reheat Costs
Heat Input Requirement, mmBtu per hour 5.2 See Reheat Calculations
Total Cost $189,945
Total Operating Costs (1 + 2 + 3 +4) $631,623
5) Supervisory Labor
Cost, $ per year $8,190 15% Operating Labor OAQPS
6) Maintenance
Maintenance Labor Requirement, hr/year 161 1/2 hour per day Estimate
Catalyst Replacement Labor Req., hr per year 200 800 hours every 2 years Estimate
Unit Cost, $ per hour $50.00 Estimate
Labor Cost, $ per year $18,030
Material Cost, $ per year $18,030 100% of Maintenance Labor OAQPS
Total Annual Cost ($/yr) $36,060

Attachment 1.
Page 7 and 8 of 8
Total Annual Costs
Value Basis Source
7) Catalyst Replacement
3 3
Catalyst Cost $435,861 Catalyst cost: $400/ft and 579 ft requirement
Sales Tax
Catalyst Life, years 4 n Estimate
Interest Rate, % 7.0 i
Capital Recovery Factor (CRF) 0.30 Ammortization of Catalyst OAQPS
Annual Cost, $ per year $128,680
8) Indirect Annual Costs
Overhead $59,310 60% of O&M Costs OAQPS
Administration $285,470 2% of Total Capital Investment OAQPS
Property Tax 1% of Total Capital Investment OAQPS
Insurance $142,730 1% of Total Capital Investment OAQPS
Capital Recovery Factor (CRF) 0.1098 OAQPS
Capital Recovery $1,567,143
Total Indirect Cost, $ per year $2,054,653
Total Annualized Cost, $ per year $2,859,200
Footnotes
1. The annual cost of the total capital requirement is given by the capital recovery factor (CRF):
where:
i (1 + i ) n
CRF =
[
(1 + i ) n − 1 ] i = annual interest rate
n = project life, years
7.0%
15

Attachment 2.
Cost estimates for wet and dry FGD systems from the U.S. EPA’s CUECost
Air Pollution Control Systems Economics Spreadsheets, and cost estimates for
sorbent injection.

We Energies' 50 MW Renewable Fuels-Fired Facility
Control Technology Review
Attachment 2. Cost estimates for wet and dry FGD systems from the U.S. EPA’s CUECost Air
Pollution Control Systems Economics Spreadsheets.
INPUTS
Description Units Input 1 Input 2
General Plant Technical Inputs

Location - State Abbrev. WI WI
MW Equivalent of Flue Gas to Control System MW 50 50
Net Plant Heat Rate Btu/kWhr 15,000 15,000
Plant Capacity Factor % 88% 88%
Total Air Downstream of Economizer % 120% 120%
Air Heater Leakage % 12% 12%
Air Heater Outlet Gas Temperature °F 320 320
Inlet Air Temperature °F 45 45
Ambient Absolute Pressure In. of Hg 29.4 29.4
Pressure After Air Heater In. of H2O -12 -12
Moisture in Air lb/lb dry air 0.013 0.013
Ash Split:
Fly Ash % 60% 90%
Bottom Ash % 40% 10%
Seismic Zone Integer 1 1
Retrofit Factor Integer 1 1
(1.0 = new, 1.3 = medium, 1.6 = difficult)
Select Coal (Pine Bark Used) Integer 8 8
Is Selected Coal a Powder River Basin Coal? Yes / No No No
Economic Inputs
Cost Basis -Year Dollars Year 2009 2009
Sevice Life (levelization period) Years 15 15
Inflation Rate % 3% 3%
After Tax Discount Rate (current $'s) % 9% 9%
AFDC Rate (current $'s) % 11% 11%
First-year Carrying Charge (current $'s) % 22% 22%
Levelized Carrying Charge (current $'s) % 17% 17%
First-year Carrying Charge (constant $'s) % 16% 16%
Levelized Carrying Charge (constant $'s) % 12% 12%
Sales Tax % 5.5% 5.5%
Escalation Rates:
Consumables (O&M) % 3% 3%
Capital Costs:
Is Chem. Eng. Cost Index available? Yes / No Yes Yes
If "Yes" input cost basis CE Plant Index. Integer 575.4 575.4
If "No" input escalation rate. % 3% 3%
Construction Labor Rate $/hr $35 $35
Prime Contractor's Markup % 3% 3%
Operating Labor Rate $/hr $30 $30
Power Cost Mills/kWh 40 40
Steam Cost $/1000 lbs 3.5 3.5
Limestone Forced Oxidation (Wet FGD or LSFO) Inputs

SO2 Removal Required % 92% 92%
L/G Ratio gal / 1000 acf 125 125
Design Scrubber with Dibasic Acid Addition? (1 = yes, 2 Integer 2 1
Adiabatic Saturation Temperature °F 127 127
Reagent Feed Ratio Factor 1.05 1.05
(Mole CaCO3 / Mole SO2 removed)
Scrubber Slurry Solids Concentration Wt. % 15% 15%
Stacking, Landfill, Wallboard (1 = stacking, 2 = lanfill, 3 Integer 1 1
Number of Absorbers Integer 1 1
(Max. Capacity = 700 MW per absorber)
Absorber Material (1 = alloy, 2 = RLCS) Integer 1 1
Absorber Pressure Drop in. H2O 6 6
Reheat Required ? Integer 2 1
(1 = yes, 2 = no)
Amount of Reheat °F 0 25
Reagent Bulk Storage Days 60 60
Reagent Cost (delivered) $/ton $15 $15
Landfill Disposal Cost $/ton $30 $30
Stacking Disposal Cost $/ton $6 $6
Credit for Gypsum Byproduct $/ton $2 $2
Maintenance Factors by Area (% of Installed Cost)
Reagent Feed % 5% 5%
SO2 Removal % 5% 5%
Flue Gas Handling % 5% 5%
Waste / Byproduct % 5% 5%
Support Equipment % 5% 5%
Contingency by Area (% of Installed Cost)
SO2 Removal % 20% 20%
General Facilities by Area (% of Installed Cost)
Engineering Fees by Area (% of Installed Cost)
Lime Spray Dryer (Dry FGD or LSD) Inputs

SO2 Removal Required % 90% 90%
Adiabatic Saturation Temperature °F 127 127
Flue Gas Approach to Saturation °F 20 20
Spray Dryer Outlet Temperature °F 147 147
Reagent Feed Ratio Factor 0.92 0.92
(Mole CaO / Mole Inlet SO2)
Recycle Rate Factor 30 30
(lb recycle / lb lime feed)
Recycle Slurry Solids Concentration Wt. % 35% 35%
Number of Absorbers Integer 2 2
(Max. Capacity = 300 MW per spray dryer)
Absorber Material Integer 1 1
(1 = alloy, 2 = RLCS)
Spray Dryer Pressure Drop in. H2O 5 5
Reagent Bulk Storage Days 60 60
Reagent Cost (delivered) $/ton $65 $65
Dry Waste Disposal Cost $/ton $30 $30
SO2 Removal % 5% 5%
SUMMARY OF COSTS
Description Units Input 1 Input 2
SO2 Control Costs LSFO LSD
Total Capital Requirement (TCR) $ $52,642,028 $39,963,389
$/kW $1,053 $799
First Year Costs
Fixed O&M $ $3,348,178 $2,555,287
$/kW-Yr 66.96 51.11
Variable O&M $ $334,443 $469,375
$/kW-Yr 6.69 9.39
Attachment 2. Cost estimates for wet and dry FGD systems from the U.S. EPA’s
CUECost Air Pollution Control Systems Economics Spreadsheets.
APC Technology Choices

INPUTS
Description Units Range Input 1
General Plant Technical Inputs
Location - State Abbrev. All States WI
MW Equivalent of Flue Gas to Control System MW 100-2000 50
Net Plant Heat Rate (w/o APC) Btu/kWhr 15,000
Plant Capacity Factor % 40-90% 88%
Percent Excess Air in Boiler % 120%
Air Heater Inleakage % 12%
Air Heater Outlet Gas Temperature °F 320
Inlet Air Temperature °F 45
Ambient Absolute Pressure In. of Hg 29.4
Pressure After Air Heater In. of H2O -12
Moisture in Air lb/lb dry air 0.013
Ash Split:
Fly Ash % 60%
Bottom Ash % 40%
Seismic Zone Integer 1-5 1
Retrofit Factor Integer 1.0-3.0 1.0
(1.0 = new, 1.3 = medium, 1.6 = difficult)
NOTE: A difficult retrofit factor was used because this tailgas SCR system would control both the existing Boiler 4 and the
Select Coal (Fuel) Integer 1-8 8
Is Selected Coal a Powder River Basin Coal? Yes / No See Column K No
Coals Available in Library
Coal 1, Wyoming PRB: 8,227 Btu, 0.37%
Coal 2, Armstrong, PA: 13,100 Btu, 2.6%
Coal 3, Jefferson, OH: 11,922 Btu, 3.43%
Coal 4, Logan, WV: 12,058 Btu, 0.89% S
Coal 5, No. 6 Illinois: 10,100 Btu, 4% S, 1
Coal 6, Rosebud, MT: 8,789 Btu, 0.56% S
Coal 7, Lignite, ND: 7,500 Btu, 0.94% S,
Coal 8, Biomass: 5,679 Btu, 0.065% S, 1.
Economic Inputs
Cost Basis -Year Dollars Year 2009
Sevice Life (levelization period) Years 30
Inflation Rate % 3.00%
After Tax Discount Rate (current $'s) % 9.20%
AFDC Rate (current $'s) % 10.80%
First-year Carrying Charge (current $'s) % 22.30%
Levelized Carrying Charge (current $'s) % 16.90%
First-year Carrying Charge (constant $'s) % 15.70%
Levelized Carrying Charge (constant $'s) % 11.70%
Sales Tax % 5.5%
Escalation Rates:
Consumables (O&M) % 3%
Capital Costs:
INPUTS
Is Chem. Eng. Cost Index available? Yes / No Yes
If "Yes" input cost basis CE Plant Index. Integer 575.4
If "No" input escalation rate. % 3%
Construction Labor Rate $/hr $35
Prime Contractor's Markup % 3%
Operating Labor Rate $/hr $30
Power Cost Mills/kWh 40
Steam Cost $/1000 lbs 3.5
Limestone Forced Oxidation (LSFO) Inputs

SO2 Removal Required % 90-98% 92%
L/G Ratio gal / 1000 acf 95-160 125
Design Scrubber with Dibasic Acid Addition? Integer 1 or 2 2
(1 = yes, 2 = no)
Adiabatic Saturation Temperature °F 100-170 127
Reagent Feed Ratio Factor 1.0-2.0 1.05
(Mole CaCO3 / Mole SO2 removed)
Scrubber Slurry Solids Concentration Wt. % 15%
Stacking, Landfill, Wallboard Integer 1,2,3 1
(1 = stacking, 2 = landfill, 3 = wallboard)
Number of Absorbers Integer 1-6 1
(Max. Capacity = 700 MW per absorber)
Absorber Material Integer 1 or 2 1
Absorber Pressure Drop in. H2O 6
Reheat Required ? Integer 1 or 2 2
(1 = yes, 2 = no)
Amount of Reheat °F 0-50 25
Reagent Bulk Storage Days 60
Reagent Cost (delivered) $/ton $15
Landfill Disposal Cost $/ton $30
Stacking Disposal Cost $/ton $6
Credit for Gypsum Byproduct $/ton $2
Reagent Feed % 5%
SO2 Removal % 5%
Flue Gas Handling % 5%
Waste / Byproduct % 5%
Support Equipment % 5%
Reagent Feed % 20%
SO2 Removal % 20%
Reagent Feed % 10%
INPUTS
SO2 Removal % 10%
Reagent Feed % 10%
SO2 Removal % 10%
Lime Spray Dryer (LSD) Inputs

SO2 Removal Required % 90-95% 90%
Adiabatic Saturation Temperature °F 100-170 127
Flue Gas Approach to Saturation °F 10.-50 20
Spray Dryer Outlet Temperature °F 110-220 147
Reagent Feed Ratio Factor Calc. Based on %S 0.92
(Mole CaO / Mole Inlet SO2)
Recycle Rate Factor Calculated 30
(lb recycle / lb lime feed)
Recycle Slurry Solids Concentration Wt. % 10-50 35%
Number of Absorbers Integer 1-7 2
(Max. Capacity = 300 MW per spray dryer)
Absorber Material Integer 1 or 2 1
Spray Dryer Pressure Drop in. H2O 5
Reagent Bulk Storage Days 60
Reagent Cost (delivered) $/ton $65
Dry Waste Disposal Cost $/ton $30
Reagent Feed % 5%
SO2 Removal % 5%
Reagent Feed % 20%
SO2 Removal % 20%
Reagent Feed % 10%
SO2 Removal % 10%
Wet Limestone Forced Oxidation (LSFO) Material Balance Case1
Flue Gas, Downstream of ID Fans

Temperature °F 315
Pressure in. H2O 10
Flow Rate SCFM 198,301
Flow Rate ACFM 293,441
CO2 lb/hr 167,122
N2 lb/hr 576,106
SO2 lb/hr 172
O2 lb/hr 47,567
HCl lb/hr 0
Other Gases lb/hr 87
H2O lb/hr 98,944
Fly Ash lb/hr 11
Total (gas only) lb/hr 889,998
Flue Gas, to Absorber

Temperature °F 315
Pressure in. H2O 10
CO2 lb/hr 167,122
N2 lb/hr 576,106
SO2 lb/hr 172
O2 lb/hr 47,567
HCl lb/hr 0
H2O lb/hr 98,944
Fly Ash lb/hr 11
Flue Gas, from Absorbers (total)

Temperature °F 127
Pressure in. H2O 4
CO2 lb/hr 167,230
N2 lb/hr 576,628
SO2 lb/hr 14
O2 lb/hr 47,685
HCl lb/hr 0
H2O lb/hr 75,092
Fly Ash lb/hr 11
Heat Capacities
O2 Btu/lbmol°F 7.203
CO2 Btu/lbmol°F 9.263
N2 Btu/lbmol°F 6.990
H2O Btu/lbmol°F 8.048
NO Btu/lbmol°F 7.151
SO2 Btu/lbmol°F 9.771
HCl Btu/lbmol°F 6.951
O2 Btu/lb°F 0.225
CO2 Btu/lb°F 0.210
N2 Btu/lb°F 0.249
H2O Btu/lb°F 0.447
NO Btu/lb°F 0.238
SO2 Btu/lb°F 0.153
HCl Btu/lb°F 0.191
Reheated Gas Temperature: °C 52.8
K 325.8
FGD Outlet Temperature: °C 52.8
K 325.8
Total Btu/hr Btu/hr 0
Hot Reheat Air

Temperature °F 440
Pressure in. H2O 1
Flow Rate SCFM 0
Flow Rate ACFM 0
N2 lb/hr 0
O2 lb/hr 0
H2O lb/hr 0
Total lb/hr 0
Heat Capacities of Hot Reheat Air
O2 Btu/lb°F 0.229
N2 Btu/lb°F 0.254
H2O Btu/lb°F 0.462
Heated Temperature: °C 226.7
K 499.7
FGD Outlet Temperature: °C 52.8
K 325.8
Heat Capacities of Inlet Reheat Air
O2 Btu/lb°F 0.228
N2 Btu/lb°F 0.252
H2O Btu/lb°F 0.458
Heated Temperature: °C 226.7
K 499.7
Inlet Air Temperature: °C 7.2
K 280.2
Required Heat Btu/hr 0
Oxidation Air (total)

Temperature °F 60
Pressure in. H2O 0
Flow Rate SCFM 152
Flow Rate ACFM 155
N2 lb/hr 523
O2 lb/hr 158
H2O lb/hr 9
Total (gas only) lb/hr 689
Limestone to Ball Mill

Temperature °F 45
Wt.% Solids wt. % 100%
Inerts lb/hr 13
CaCO3 lb/hr 259
Total lb/hr 272
Limestone Slurry to Limestone Slurry Tank

Temperature °F 90
Flow Rate GPM 1.0
Inerts lb/hr 13
CaCO3 lb/hr 259
H2O lb/hr 407
Total lb/hr 679
Limestone Slurry to Reaction Mix Tank (total)

Temperature °F 68
Flow Rate GPM 2.3
Inerts lb/hr 13
CaCO3 lb/hr 259
H2O lb/hr 1,086
Total lb/hr 1,358
Slurry to Absorber
Temperature °F 126
Flow Rate GPM 26,694
CaSO3*1/2H2O lb/hr 0
CaSO4*2H2O lb/hr 2,175,508
Inerts lb/hr 65,491
CaCl2 lb/hr 0
CaCO3 lb/hr 63,235
H2O lb/hr 13,057,321
Total lb/hr 15,361,554
Slurry from Rxn Tank to Thickener

Temperature °F 126
Flow Rate GPM 5.2
CaSO4*2H2O lb/hr 424
Inerts lb/hr 13
CaCl2 lb/hr 0
CaCO3 lb/hr 12
H2O lb/hr 2,545
Total lb/hr 2,994
Wet Limestone Forced Oxidation Equipment Capital Costs Case1

Cost Basis (Year) 2009
Sizing Criteria
Reagent Feed System $ kpph Reag. $10,584,021
Ball Mill & Hydroclone System $ TPH Reag. $2,755,315
DBA Acid Tank (pump, heater, agitator) $ gpm DBA $0
SO2 Removal System $ kpph SO2 $2,834,389
Absorber Tower $ kACFM $8,397,987
Spray Pumps $ slurry gpm $583,546
Flue Gas Handling System $ * $3,061,861
ID Fans $ ACFM $963,037
Waste / Byproduct Handling System $ kpph SO2 $120,132
Thickener System $ TPH solids $172,898
Support Equipment $ MW $1,890,418
Chimney $ ACFM $4,213,622
TOTAL $ $35,577,227
* Based on flue gas flow and reheat temperature.
Capital Costs with Retrofit Factors

Reagent Feed System $ $10,584,021
Ball Mill & Hydroclone System $ $2,755,315
DBA Acid Tank (pump, heater, agitator) $ $0
SO2 Removal System $ $2,834,389
Absorber Tower $ $8,397,987
Spray Pumps $ $583,546
Flue Gas Handling System $ $3,061,861
ID Fans $ $963,037
Waste / Byproduct Handling System $ $120,132
Thickener System $ $172,898
Support Equipment $ $1,890,418
Chimney $ $4,213,622
TOTAL $ $35,577,227
General Facilities
Ball Mill & Hydroclone System $ $275,532
SO2 Removal System $ $283,439
Absorber Tower $ $839,799
Flue Gas Handling System $ $306,186
ID Fans $ $96,304
Support Equipment $ $189,042
Chimney $ $421,362
TOTAL $ $3,557,723
Engineering Fees
ID Fans $ $96,304
Chimney $ $421,362
TOTAL $ $3,557,723
Contingency
ID Fans $ $192,607
Chimney $ $842,724
TOTAL $ $7,115,445
Total Plant Cost (TPC) $ $49,808,118

Total Plant Cost (TPC) w/ Prime Contractor's Markup $ $51,302,361
Total Cash Expended (TCE) $ $51,302,361
Allow. for Funds During Constr. (AFDC) $ $0

Total Plant Investment (TPI) $ $51,302,361
Preproduction Costs $ $1,336,733

Inventory Capital $ $2,933
Total Capital Requirement (TCR) $ $52,642,028

$/kW $1,053
Maintenance Cost by Area Case1
TPC w/o Retrofit Factor

Ball Mill & Hydroclone System $ $3,967,654
ID Fans $ $1,386,774
Chimney $ $6,067,615
TOTAL $ $51,231,207
First Year Maintenance Costs

Reagent Feed System $ $762,049
ID Fans $ $69,339
Chimney $ $303,381
TOTAL $ $2,561,560
LSFO O&M Data and Costs Case1


Parameters
Reagent Required lbs/hr 272
lbs/MMBtu 0.362
DBA Required lbs/hr 0.0
Percent SO2 Removal % 92%
FGD Sludge to Disposal lbs/hr, dry 449
Steam to FGD System lbs/hr 0
Total FGD Power Consumption kW 1,000
FGD Byproduct lbs/hr 0
Fixed O&M Costs

Number of Operators 6
(40 hrs/week)
Operating Labor Cost ** $/yr $368,639
Maint. Labor & Matls. Cost $/yr $2,561,560
Admin. & Support Labor $/yr $417,979
TOTAL $/yr $3,348,178
Variable Operating Costs **

Reagent Costs $/yr $15,704
DBA Costs $/yr $0
Disposal Costs $/yr $10,387
Credit for Byproduct $/yr $0
Steam Costs $/yr $0
Power Costs $/yr $308,352
TOTAL $/yr $334,443
** These costs assume inputs are in current dollars (no escalation included).
Lime Spray Dryer (LSD or Dry FGD) Material Balance - Prel Case 2
Flue Gas, Downstream of Air Heater
Temperature °F 320
Pressure in. H2O -12
CO2 lb/hr 167,122
N2 lb/hr 576,106
SO2 lb/hr 172
O2 lb/hr 47,567
HCl lb/hr 0
H2O lb/hr 98,944
Fly Ash lb/hr 2,447
Flue Gas, to Spray Dryer

Temperature °F 320
CO2 lb/hr 83,561
N2 lb/hr 288,053
SO2 lb/hr 86
O2 lb/hr 23,783
HCl lb/hr 0
H2O lb/hr 49,472
Fly Ash lb/hr 1,223
Flue Gas, from Spray Dryers (total)

Temperature °F 147
CO2 lb/hr 167,122
N2 lb/hr 576,106
SO2 lb/hr 48
O2 lb/hr 47,559
HCl lb/hr 0
H2O lb/hr 165,387
Fly Ash lb/hr 6,548
Flue Gas Downstream of Particulate Control Device

Temperature °F 147
CO2 lb/hr 167,122
N2 lb/hr 576,106
SO2 lb/hr 17
O2 lb/hr 47,557
HCl lb/hr 0
H2O lb/hr 165,254
Fly Ash lb/hr 11
Flue Gas Downstream of ID Fans
Temperature °F 152
Pressure in. H2O 1
CO2 lb/hr 167,122
N2 lb/hr 576,106
SO2 lb/hr 17
O2 lb/hr 47,557
HCl lb/hr 0
H2O lb/hr 165,254
Fly Ash lb/hr 11
Lime to Ball Mill
Temperature °F 60
Inerts lb/hr 15
CaO lb/hr 138
Total lb/hr 153
Water to Ball Mill
Temperature °F 60
Flow Rate GPM 1
H2O lb/hr 505
Total lb/hr 505
Lime Slurry to Head Tanks (Total)
Temperature °F 110
Flow Rate GPM 1
Ca(OH)2 lb/hr 182
Inerts lb/hr 15
H2O lb/hr 461
Total lb/hr 658
Lime Slurry from Head Tank

Temperature °F 110
Flow Rate GPM 10
CaSO4*2H2O lb/hr 82
Flyash / Inerts lb/hr 1,987
Ca(OH)2 lb/hr 96
CaCl2 lb/hr 70
H2O lb/hr 4,413
Total lb/hr 6,833
Lime Slurry to Atomizer

Temperature °F 104
Flow Rate GPM 67
CaSO4*2H2O lb/hr 82
Ca(OH)2 lb/hr 96
CaCl2 lb/hr 70
H2O lb/hr 33,234
Total lb/hr 35,655
Solids from Spray Dryers (Total)

Temperature °F 150
CaSO4*2H2O lb/hr 25
Flyash / Inerts lb/hr 642
Ca(OH)2 lb/hr 5
CaCl2 lb/hr 0
H2O lb/hr 15
Total lb/hr 742
Baghouse/ESP Solids to Recycle

Particulate Removal Efficiency % 99.83%
Temperature °F 150
Ca(OH)2 lb/hr 5
CaCl2 lb/hr 140
H2O lb/hr 77
Total lb/hr 3,854
Recycle Solids to Slurry Tank

Temperature °F 150
Ca(OH)2 lb/hr 10
CaCl2 lb/hr 140
H2O lb/hr 92
Total lb/hr 4,736
Blowdown Water to Recycle Solids Tank
Temperature °F 60
Flow Rate GPM 17
H2O lb/hr 8,273
Total lb/hr 8,273
Recycle Slurry to Head Tanks (Total)
Temperature °F 110
Flow Rate GPM 19
Ca(OH)2 lb/hr 10
CaCl2 lb/hr 140
H2O lb/hr 8,365
Total lb/hr 13,009
Dry Solids
Temperature °F 100
Ca(OH)2 lb/hr 4
CaCl2 lb/hr 0
H2O lb/hr 57
Total lb/hr 2,848
Solids to Landfill
Temperature °F 100
Ca(OH)2 lb/hr 4
CaCl2 lb/hr 0
H2O lb/hr 698
Total lb/hr 3,489
Lime Spray Dryer (LSD) Equipment Capital Costs Case 2

Sizing Criteria
Reagent Feed System $ * $5,729,193
SO2 Removal System $ Wt. % S $2,470,418
Spray Dryers $ kACFM $8,658,475
Flue Gas Handling System $ kACFM $1,829,117
ID Fans $ ACFM $720,271
Waste / Byproduct Handling System $ kpph SO2 $1,522,152
Support Equipment $ MW $2,205,055
Chimney $ ACFM $3,855,901
TOTAL $ $26,990,583
* Based on lbs/hr of lime feed and GPM of lime slurry.
Capital Costs with Retrofit Factors

Spray Dryers $ $8,658,475
ID Fans $ $720,271
Waste / Byproduct Handling System $ $1,522,152
Chimney $ $3,855,901
TOTAL $ $26,990,583
General Facilities
Spray Dryers $ $865,848
ID Fans $ $72,027
Chimney $ $385,590
TOTAL $ $2,699,058
Engineering Fees
ID Fans $ $72,027
Chimney $ $385,590
TOTAL $ $2,699,058
Contingency
ID Fans $ $144,054
Chimney $ $771,180
TOTAL $ $5,398,117
Total Plant Cost (TPC) $ $37,786,817

Total Plant Cost (TPC) w/ Prime Contractor's Markup $ $38,920,421
Total Cash Expended (TCE) $ $38,920,421
Allow. for Funds During Constr. (AFDC) $ $0
Total Plant Investment (TPI) $ $38,920,421
Preproduction Costs $ $1,035,797

Inventory Capital $ $7,170
Total Capital Requirement (TCR) $ $39,963,389

$/kW $799
Maintenance Cost by Area Case 2

TPC w/o Retrofit Factor
ID Fans $ $1,037,190
Waste / Byproduct Handling System $ $2,191,899
Chimney $ $5,552,498
TOTAL $ $38,866,440
First Year Maintenance Costs

ID Fans $ $51,859
Chimney $ $277,625
TOTAL $ $1,943,322
LSD O&M Data and Costs Case 2

Parameters
Reagent Required lbs/hr 153
lbs/MMBtu 0.204
Percent SO2 Removal % 90%
FGD Solids - dry lbs/hr 2,792
- wetted lbs/hr 3,489
Fresh Water to FGD gpm 1
Blowdown Water to FGD gpm 75
Total FGD Power Consumption kW 350
Fixed O&M Costs

Number of Operators 5
(40 hrs/week)
Operating Labor Cost ** $/yr $291,358
Maint. Labor & Matls. Cost $/yr $1,943,322
Admin. & Support Labor $/yr $320,606
TOTAL $/yr $2,555,287
Variable Operating Costs **

Reagent Costs $/yr $38,382
Disposal Costs $/yr $322,790
Credit for Byproduct $/yr $0
Steam Costs $/yr $0
Fresh Water Costs $/yr $280
Power Costs $/yr $107,923
TOTAL $/yr $469,375
Cost estimates for a dry sorbent injection system (2 pages).
Facility Input Data

Item Value
Economic Life, years 15
Interest Rate (%) 7
Source(s) Controlled Biomass-Fired Boiler
Total Uncontrolled SO2 Emissions 278
Site Specific Electricity Cost ($/kWh) 0.07
Site Specific Operating Labor Cost ($/hr) $50
Site Specific Maint. Labor Cost ($/hr) $50
Capital Costs
Value Basis
Direct Costs
1.) Purchased Equipment Cost
a.) Equipment cost + auxiliaries $1,500,000 EPA-452/F-03-034
b.) Instrumentation $150,000 0.10 x A
c.) Sales taxes 0.07 x A
d.) Freight $75,000 0.05 x A
Total Purchased equipment cost, (PEC) $1,725,000 B = 1.22 x A
2.) Direct installation costs
a.) Foundations and supports $138,000 0.08 x B
b.) Handling and erection $241,500 0.14 x B
c.) Electrical $69,000 0.04 x B
d.) Piping $34,500 0.02 x B
e.) Insulation for ductwork $17,300 0.01 x B
f.) Painting $17,300 0.01 x B
Total direct installation cost $517,600 0.30 x B
3.) Total site preparation including demolition $517,600 Larry Sorrels, OAQPS Memo. Feb. 2,
4.) Buildings NA As Required, Bldg.
Total Direct Cost, DC $2,760,200 1.30B + SP + Bldg.
Indirect Costs (installation)
5.) Engineering $172,500 0.10 x B
6.) Construction and field expenses $86,300 0.05 x B
7.) Contractor fees $172,500 0.10 x B
8.) Start-up $34,500 0.02 x B
9.) Performance test $17,300 0.01 x B
10.) Contingencies $51,800 0.03 x B
Total Indirect Cost, IC $534,900 0.31B + Other
Total Capital Investment (TCI) = DC + IC $3,295,000 1.61B + SP + Bldg. + Other
Cost estimates for a dry sorbent injection system (2 pages).
Annual Costs
Item Value Basis Source
1) Electricity
Fan Power Requirement (kW) 100
Pumping (kW) 50
Electric Power Cost ($/kWh) 0.07 Local Utility Price Utility
Cost ($/yr) $36,792
2) Operating Costs
Operating Labor Requirement (hr/shift) 4.0 Estimate
Unit Cost ($/hr) $50 Facility Data Estimate
Labor Cost ($/yr) $218,400
Sodium Bicarbonate Cost
Unit Cost ($/ton) $497 FMC Corp. Bulk Chemical Cost
Sodium Bicarbonate Cost ($/yr) $241,370
Disposal Costs ($/ton) $40
Tons Disposal required (tons/year) 347
Disposal Costs ($/year) $13,876
Total Operating Costs $510,438 Vendor
3) Supervisory Labor
Cost ($/yr) $32,760 15% Operating Labor OAQPS
4) Maintenance
Labor Cost ($/yr) $27,600 1% of installed cost Estimate
Material Cost ($/yr) $27,600 100% of Maint. Labor OAQPS
Total Cost ($/yr) $55,200
5) Indirect Annual Costs
Overhead $183,820 60% of O&M Costs OAQPS
Administration $65,900 2% of TCI OAQPS
Property Tax 1% of TCI OAQPS
Insurance $32,950 1% of TCI OAQPS
Capital Recovery $361,770
Total Indirect ($/yr) $644,440
Total Annualized Cost ($/yr) $1,242,800

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Prevention of Significant Deterioration

Air Pollution Control Construction Permit Application

Control Technology Review for the

50 MW Biomass Fuels-Fired Cogeneration Facility to be

RTP ENVIRONMENTAL ASSOCIATES INC.®

We Energies - Air Pollution Control Construction Permit Application for a

Chapter 2. Control Technology Review Methodology......................................12

Chapter 3. Carbon Monoxide (CO) Control Technology Review. ..................21

Chapter 4. Nitrogen Oxides (NOx) Control Technology Review. ....................26

We Energies - Air Pollution Control Construction Permit Application for a

Chapter 5. Particulate Matter and PM10 Control Technology Review...........43

Chapter 6. PM2.5 Control Technology Review...................................................53

We Energies - Air Pollution Control Construction Permit Application for a

Chapter 7. Sulfur Dioxide (SO2) Control Technology Review.........................61

Chapter 8. Organic Compound (VOC) Control Technology Review. ............78

We Energies - Air Pollution Control Construction Permit Application for a

Chapter 9. Fluorides (as HF) Control Technology Review. .............................83

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

1.2 CFB Boiler Fuels.

We Energies - Air Pollution Control Construction Permit Application for a

1.3 CFB Boiler Design.

1.4 Potential Air Emissions.

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

In Wisconsin, BACT is defined as:

We Energies - Air Pollution Control Construction Permit Application for a

2.3 New Versus Modified Facilities.

We Energies - Air Pollution Control Construction Permit Application for a

2.4 Identifying Potential Control Technologies.

2.5 Technical Feasibility.

We Energies - Air Pollution Control Construction Permit Application for a

2.6 Economic Feasibility.

2.6.1 Average Cost Effectiveness.

Average Cost Effectiveness Control option annualized cost

We Energies - Air Pollution Control Construction Permit Application for a

2.6.3 Agency Decisions on Cost Effectiveness.

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

3.1 BACT Baseline.

3.2 STEP 1. Identify All Available Control Technologies.

3.3 STEP 2. Identify Technically Feasible Control Technologies.

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

3.3.2 Thermal Oxidation

3.3.3 Good Combustion Practices

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

3.5 STEP 4. Evaluate the Most Effective Controls.

3.6 STEP 5. Proposed Carbon Monoxide BACT Determination.

4.1 BACT Baseline.

4.2 STEP 1. Identify All Potential Control Strategies.

We Energies - Air Pollution Control Construction Permit Application for a

We Energies - Air Pollution Control Construction Permit Application for a

4.3.1 Fluidized Bed Boilers.

4.3.2 Low NOX Burners and Overfire Air.

We Energies - Air Pollution Control Construction Permit Application for a

4.3.4 Flue Gas Recirculation.

4.3.5 Oxygen-Enhanced Combustion.

We Energies - Air Pollution Control Construction Permit Application for a