CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY
Environmental Technology Certification Program
Evaluation of the
Goal Line Environmental Technologies LLC
SCONOxJ
J System
November 1998
ABSTRACT
The purpose of this report is to document the Air Resources Board==s (ARB==s) evaluation and
verification of the low nitrogen oxide (NOx) emission and no ammonia slip performance claims made
by the Goal Line Environmental Technologies LLC (Goal Line) concerning its SCONOxJ
J air
pollution control system. Upon successful completion of the requirements associated with the ARB==s
Equipment and Process Precertification Program (Equipment Precertification Program), a report is
issued with two companion documents: 1) a certificate; and 2) an Executive Order. These companion
documents serve as official records that the ARB staff has independently verified the performance
claims presented in this report.
Certificates earned under the ARB==s Equipment Precertification Program are valid for three
years from the date issued, presuming the holder of the certificate complies with: 1) the terms and
conditions identified in this report; and 2) the general requirements discussed in the Equipment
Precertification Program Guidelines and Criteria. In addition, Executive Orders issued under the
Equipment Precertification Program identify requirements necessary to retain a valid certificate.
Goal Line has operated a full-scale commercial version of the SCONOxJ
J system since
December 20, 1996. The SCONOxJ
J system is a catalytic control technology for the reduction of NOx
emissions and elimination of ammonia slip from natural gas-fired combined-cycle turbine combustors.
The SCONOxJ
J system technology differs from existing water or steam injection and selective catalytic
NOx reduction technologies by using potassium carbonate in a chemical process. Goal Line wishes to
expand the use of the SCONOxJ
J system to more and larger natural gas-fired combined-cycle turbines,
and believes that becoming certified under the ARB==s Equipment Precertification Program will assist it
with this objective.
As part of its Equipment Precertification application package, Goal Line requested that the
ARB evaluate two proposed performance claims with respect to the SCONOxJ
J system==s ability to
control emissions of NOx and ammonia slip . As part of the precertification evaluation, the ARB
reviewed testing results obtained from Goal Line to verify proposed claims. After review of the final test
results, in conjunction with an evaluation of other documents discussed throughout this report, the
ARB staff recommends that a precertification certificate be issued to Goal Line.
Applicant: Goal Line Environmental Technologies LLC Application Number:
2045 E. Vernon Avenue
Executive Order: G-096-029-013
Los Angeles, CA 90058
Date:
Equipment:
SCONOxJ
J
Contact:
Ted D. Guth, Ph.D
Phone:
(213) 233-2224
E-Mail: [email protected]
ARB Staff Contact: Mr. Glenn B. Simjian
Phone: (916) 322-2891
Title:
Fax:
Website:
Mgr. Environmental Affairs
(213) 233-7428
www.glet.com
ARB Website: www.arb.ca.gov
Table of Contents
Contents
Page
I. Introduction
A. Emissions of Nitrogen Oxides
B. Organization of This Report
II. General Information
A.
B.
C.
D.
Equipment Precertification Program Background
Relationship to Air Quality
Health and Environmental Impacts
Manufacture / Ownership Rights
1
1
1
2
2
2
3
3
III. Summary of Scope
3
IV. Statement of Claims
3
V. Materials Available for Evaluation
3
VI. Technology Description
6
A. SCONOxJ Technology
1. The Oxidation/Absorption Cycle
2. The Regeneration Cycle
3. The Regeneration Gas Generator
6
8
8
10
B. Field Use
C. Control System and Instrumentation
10
12
Technical Evaluation
12
VIII. Evaluation of Claims
13
VII.
Table of Contents
Page Two
IX. Test Results
14
X. Quality Management
15
XI. Environmental and Economic Benefits
15
XII. Recommendations
15
XIII. Suggested Operating Conditions
16
XIV. Precertification Conditions
17
XV. Figures
1. Illustration of the Goal Line SCONOxJ System
2. Exhaust Gas Flow Into SCONOxJ System
3. Exhaust Gas Flow Into SCONOxJ System
4. SCONOxJ Application at the Federal Cogeneration Cold Storage
7
9
9
11
XVI. Appendices
Appendix A - Summary of the Test Results Showing Six Months of
Operating Data on a Unit Using the SCONOxJ System
18
I.
INTRODUCTION
B. Organization of this Report
This report discusses the technology used
by Goal Line Environmental Technologies LLC
(Goal Line) in the design of its SCONOxJ
catalyst system (SCONOxJ system), the
performance claims to be verified by the Air
Resources Board (ARB), the test procedures
used, the test results, and the findings and
recommendations of ARB staff concerning the
SCONOxJ system.
A. Emissions of Nitrogen Oxides
The control of oxides of nitrogen (NOx)
emissions from stationary sources including
natural gas-fired turbines, is part of the overall
strategy to achieve and maintain healthy air
quality in California. Through a series of
complex atmospheric reactions, NOx
contributes to the formation of ground-level
ozone. In addition, atmospheric emissions of
NOx also contributes to the formation of
particulate matter. As such, federal, state and
local air quality programs include strategies to
reduce emissions of NOx into the atmosphere.
These control strategies rely heavily on
promoting the development and use of
continually improving technologies, as well as
periodic inspection and maintenance procedures
to ensure that performance requirements are
maintained.
Goal Line believes that the SCONOxJ
system is effective at reducing NOx emissions
and eliminating ammonia slip from natural gasfired combined-cycle turbine combustors. As
such, Goal Line submitted an application under
the ARB=s Equipment Precertification Program.
As part of its application package, Goal Line
requested verification of the claims that its
SCONOxJ system reduces NOx emissions and
eliminates ammonia slip.
Page 5
This report is organized into several sections.
The first section, General Information, provides
background information on the ARB=s
precertification program, as well as the SCONOxJ
system being evaluated. The next four sections
Summary of Scope, Statement of Claims,
Materials Available for Evaluation, and
Technology Description discuss the breadth of our
evaluation, the performance claims for the
SCONOxJ system, the information that we relied
on to conduct our evaluation, and a detailed
description of Goal Line=s SCONOxJ system.
The following three sections: Technical
Evaluation; Evaluation of Claims; and Test
Results present detailed information on our
technical review and assessment of the
performance of the SCONOxJ system. The
following sections entitled: Quality
Management and Environmental and Economic
Benefits provide supporting information on
Goal Line=s procedures to yield performance
results which meet the company=s claims.
These sections also provide a brief assessment
of the potential environmental and economic
impacts of the technology.
Finally, the remaining sections:
Recommendations; Suggested Operating
Conditions; and Precertification Conditions
discuss the ARB staff=s determination of the
performance of the SCONOxJ system relative
to the company=s claims. These sections also
provide some general guidance with respect to
air quality permitting considerations as well as
specific conditions that must be met for the
certificate to remain valid for three years. The
Appendix contains additional information
supporting the evaluation documented in this
report.
II. GENERAL INFORMATION
Under the regulations established by the
program, equipment or processes eligible for the
Equipment Precertification Program must:
1) have an air quality benefit; 2) be commonlyused or have the potential to be commonly-used
in the near future (market ready); and, 3) not
pose a significant potential hazard to public
health and safety and the environment.
Furthermore, to be eligible, applicants for the
program must demonstrate that they have
sufficient control over the manufacture of the
equipment or process to ensure that they can
consistently and reliably produce equipment
which performs at least as well as that
considered as part of this evaluation.
A. Equipment Precertification Program
Background
The Equipment Precertification Program is
a voluntary statewide program for
manufacturers of commonly-used equipment or
processes. A precondition for entry into the
program is that the equipment has an air quality
benefit. On June 14, 1996, the ARB adopted
section 91400 of Title 13 of the California Code
of Regulations which incorporates the Criteria
for Equipment and Process Precertification
(criteria). The regulation and Criteria were
approved by the California Office of
Administrative Law on October 31, 1996 and
became effective on November 30, 1996.
Under the Equipment Precertification
Program, manufacturers request that the ARB
conduct an independent third-party verification
of performance claims which focus on the air
quality benefits of its equipment or process. If
the claim is verified, the manufacturer is free to
refer to the results of the ARB=s evaluation in its
marketing literature. Upon successful
completion of the verification process, the
Page 6
applicant may also request that the ARB notify
specific air pollution control and air quality
management districts (districts) in California of
the ARB=s determination. As a result of the
ARB=s notification, the district has an advanced
opportunity to become familiar with the
performance of the equipment or process.
On January 15, 1998, the ARB received an
eligibility request from Goal Line that the ARB
determine if the SCONOxJ system was eligible
for the Equipment Precertification Program.
After receiving confirmation from the ARB that
the SCONOxJ system was eligible for the
program, Goal Line submitted a precertification
application package to the ARB. As part of
our review of the application package, we
evaluated the emission testing results along
with other information concerning the past
performance of the SCONOxJ system to
determine whether the claims were verifiable.
B. Relationship to Air Quality
In an effort to make progress towards
attaining healthy air quality in California,
regulations restrict emissions of NOx from a
broad spectrum of activities. The reduction of
NOx emissions from natural gas-fired
combined-cycle turbine combustors is one part
of California=s clean air strategy. Typically,
natural gas-fired combined-cycle turbine
emissions are controlled through water or
steam injection and/or selective catalytic
reduction (SCR). As such, local air district
rules and regulations specify emission limits
and inspection schedules (see section XIII.
Suggested Operating Conditions). Because the
use of the SCONOxJ system is claimed to
reduce NOx emissions and eliminate ammonia
slip, the ARB evaluated the SCONOxJ system
as air pollution control equipment.
C. Health and Environmental Impacts
As part of our evaluation, staff conducted a
cursory review of the potential environmental
impacts associated with the SCONOxJ system.
Based on this review, we concluded that the
catalytic system would not likely present health
or environmental impacts significantly different
from those associated with other control
systems for natural gas-fired combined-cycle
turbines which are currently in wide use
throughout California. Unlike SCR, use of the
SCONOxJ system negates the need for the onsite storage of ammonia. However, the system
does require the use of hydrogen gas to
regenerate the catalyst. The hydrogen is
generated onsite through the use of a reformer.
Please note that Goal Line and/or purchasers of
the SCONOxJ system are required to meet all
applicable health and safety standards with
respect to the manufacture, installation, use, and
maintenance of the SCONOxJ system.
D. Manufacture / Ownership Rights
emissions from natural gas- fired combinedcycle turbines involves using efficient air
pollution control equipment, increasing
monitoring and inspection frequency, and
improving maintenance practices.
IV. STATEMENT OF CLAIMS
The following are the claims verified by
ARB staff concerning the SCONOxJ system.
The verification of these claims is predicated on
the presumption that the catalytic system is
installed and operated in accordance with the
manufacturer=s installation, operation, and
maintenance instructions.
1. The SCONOxJ
J catalytic system
demonstrated emissions of oxides of
nitrogen of 2.0 parts per million
volume dry (15 percent oxygen, 3hour rolling average) for a 34megawatt, LM2500 natural gas-fired
combined-cycle turbine employing
water injection.
2.
The SCONOxJ
J system does not use
ammonia injection. Therefore, the
SCONOxTM system is not expected to
produce ammonia slip.
The recommendations in this report are
contingent upon Goal Line having the legal
rights to produce and/or market the SCONOxJ
system. Goal Line documented its ownership of
these rights in a letter to the ARB dated May
18, 1998, which stated, AGoal Line has received
several patents on the SCONOxJ process, the
first of which was granted September 19, 1995.
Goal Line is the sole source of SCONOxJ
systems.@
The following materials were used by the
ARB as part of its evaluation of Goal Line=s
SCONOxJ system:
III. SUMMARY OF SCOPE
1.
Goal Line claims that the use of the
SCONOxJ system will control NOx emissions
and ammonia slip associated with the operation
of natural gas-fired combined-cycle turbine
combustors. Generally, the control of NOx
Page 7
V. MATERIALS AVAILABLE FOR
EVALUATION
Goal Line Environmental Technologies
LC, Applications for the Certification of
SCONOxJ to be Best Available Control
Technology for Gas-Fired Turbines and
Certain Other Stationary Sources of
Pollution, February 19, 1997.
2.
Seven months of performance data from
Mr. Steven Ringer, United States
Environmental Protection Agency (U.S.
EPA), for the SCONOxJ system from
June 1, 1997 through December 31, 1997,
January 6, 1998.
3.
Letter from U.S. EPA to Goal Line
Environmental Technologies LLC,
acknowledging a NOx emission rate at the
tested facility of 3.5 ppm as achieved in
practice, January 6, 1998.
4. Request to Determine Eligibility for the
ARB Equipment Precertification
Program from Dr. Ted Guth of
Goal Line Environmental Technologies to
Ms. Kitty Martin of the ARB transmitting
the Determination of Eligibility and a
SCONOxJ summary data for calender year
1997, January 20, 1998.
5.
Letter from Mr. Richard Corey of the ARB
to Dr. Ted Guth of Goal Line
Environmental Technologies LLC
concerning a request for additional
information needed to complete the
Equipment Precertification Evaluation,
January 29, 1998.
6. Copy of Sunlaw Cogeneration Partners I
Power Plant Project, Energy Commission
Docket Number: 97-SIT-3, California
Energy Commission Power Plant Siting
Case, from California Energy Commission
Internet site, February 2, 1998.
7. Application for the ARB Equipment
Precertification Program from Dr. Ted Guth
of Goal Line Environmental Technologies
LLC to Mr. Glenn Simjian of the ARB,
transmitting the application and application
fee for the ARB precertification program,
February 17, 1998.
Page 8
8. Report from the South Coast Air Quality
Management District, Particulate Matter
Emissions and Reclaim Relative Accuracy
Audit of the Nitrogen Oxides, and Exhaust
Flow Continuous Emission Monitors from
a Gas Turbine; source test report from
South Coast Air Quality Management
District, Source Test Protocol for
SCAQMD Rule 2012 (Reclaim) Relative
Accuracy Test Audit=s at Sunlaw
Cogeneration Partners I, Growers Facility,
February 17, 1998.
9. Copy of South Coast Air Quality
Management District=s Announcement of
the Scientific Review Committee (SRC)
Meeting discussing the agenda for the next
meeting including a presentation on the gas
turbine standard, February 27, 1998.
10. Copy of U.S. EPA letter to Goal Line
Environmental Technologies LLC
acknowledging performance results of the
SCONOxTM system and discussing the
effect the results may have on future
projects, March 23, 1998.
11. Phone log of conversation between ARB
staff and Dr. Ted Guth of Goal Line
Environmental Technologies LLC
concerning the data needed to complete
the ARB=s evaluation report on the
SCONOx TM system, March 23, 1998.
12. Memorandum from Mr. Raymond E.
Menebroker of the ARB=s Stationary
Source Division to Mr. George Lew of the
ARB=s Monitoring and Laboratory
Division transmitting a Request for
Assistance-Method and Test Data Review
for Precertification Verification Testing for
Goal Line Environmental Technologies
LLC SCONOxTM system, March 24, 1998.
13. Memorandum from Mr. Raymond E.
Menebroker of the ARB=s Stationary
Source Division to Mr. George Lew of the
ARB=s Monitoring and Laboratory Division
transmitting supplemental information
concerning the evaluation of the
SCONOxJ system, April 20, 1998.
19. Letter from Dr. Ted Guth of Goal Line
Environmental Technologies LLC to Mr.
Glenn Simjian of the ARB, transmitting a
copy of The South Coast Air Quality
Management District facility permit (ID#
55711) for the SCONOxJ system power
generator, May 26, 1998.
14. Letter from Mr. Steve Weirman to Mr.
Anupom Ganguli of the South Coast Air
Quality Management District, expressing
concerns over continuous emissions
monitoring system (CEMS) accuracy in
reporting NOx levels for the SCONOxJ
system, April 28, 1998.
20. Fax from Glenn Simjian of the ARB to Dr.
Ted Guth of Goal Line Environmental
Technologies LLC, transmitting request for
additional information needed to complete
the evaluation report on the SCONOxTM
system, May 28, 1998.
15. Memorandum from Mr. George Lew of the
ARB=s Monitoring and Laboratory Division
to Mr. Raymond E. Menebroker of the
ARB=s Stationary Source Division
transmitting Monitoring and Laboratory
Division=s Review of Goal Line
Environmental Technologies SCONOxJ
system, May 1, 1998.
16. Letter from Goal Line Environmental
Technologies LLC, confirming proposed
claims for the SCONOxTM system (faxed
on May 18, 1998.) May 21, 1998.
17. Letter from Dr. Anupom Ganguli of the
South Coast Air Quality Management
District to Mr. Steve Weinman, in response
to concerns over the accuracy of continuous
emission monitors, May 22, 1998.
18. Letter from Dr. Ted Guth of Goal Line
Environmental Technologies LLC to Mr.
Glenn Simjian of the ARB transmitting
a cover letter, modified proposed claims,
company brochure, sample figures,
SCONOxJ system data summary
for 1997, and U.S. Patent information for
the SCONOx TM system, May 26, 1998.
Page 9
21. Fax, e-mail, and letter from Mr. Bob
MacDonald of Goal Line Environmental
Technologies LLC, transmitting photos
and figures to be used in the preparation of
the ARB=s evaluation report on the
SCONOxTM system, June 25, 1998.
22. Fax and letter from Josh Perelson of Goal
Line Technologies LLC, transmitting a
report on expected effects of temperature
on the SCONOxTM system, July 14, 1998.
23. Fax and letter from Mr. Josh Perelson of
Goal Line Technologies LLC, transmitting
SCONOx operating temperature
information, July 22, 1998.
For information on how to obtain these
materials, please contact the ARB at the
number provided at the beginning of this
document.
VI. TECHNOLOGY DESCRIPTION
Natural gas-fired turbines are a source of
relatively clean power. Generally, the most
significant sources of pollutants from natural gasfired turbines are NOx and CO. However,
emissions can also include particulate matter,
oxides of sulfur, volatile organic hydrocarbons,
and toxic air contaminants. Oxides of nitrogen are
formed at temperatures typically occuring during
natural gas combustion (i.e., 3,000+ deg F).
district operating permit to 10-20 parts per
million volume dry at 15 percent O2.
Historically, there have been three primary
ways for controlling the production of NOx
emissions from natural gas-fired turbines: water
injection, steam injection, and selective catalytic
reduction (SCR).
As the SCR unit ages, ammonia slip may
increase because excess ammonia can be
required to drive the reaction to higher
conversion as the catalyst degrades. The
ammonia slip can lead to the formation of
ammonia nitrate and ammonium sulfate in the
atmosphere.
Water or steam injection injects water or
steam respectively into the combustion zone
lowering the temperature. By lowering the
temperature in the combustion zone, NOx
production is reduced. Water injection can
yield NOx emissions in the 25 parts per million
range, while steam injection can yield NOx
emissions in the 15 parts per million range.
Although water or steam injection reduces NOx
production, it increases CO levels. To
counteract CO production, a catalyst is typically
installed to oxidize CO to CO2.
The third main form of NOx control for
emissions from natural gas-fired turbines is
known as SCR. Selective catalytic reduction is
used in combination with water or steam
injection, or independently depending on the
turbine configuration. Selective catalytic
reduction employs the injection of ammonia into
the exhaust stream, in approximately
stoichiometric amounts, to bring about the
following reaction:
4NO + 4NH3 + O2 $ 6H2O + 4N2
This reaction is carried out over a catalyst at
temperatures ranging from 450 - 1100 degrees
Fahrenheit (deg F) and at space velocities of
10,000 to 30,000 feet per hour. Typically, a
new SCR unit on a (20 megawatt and above)
combined-cycle natural gas-fired turbine, has an
average emission performance of 3.5 to 6 ppm
NOx, with some ammonia slip (excess unused
ammonia emerging through the exhaust stream).
The ammonia slip is normally limited in the air
Page 10
A. SCONOxTM Technology
The SCONOxTM system (figure 1) utilizes a
single catalyst for the removal of both CO and
NOx emissions. The SCONOxTM system does
not require the use of ammonia. However,
hydrogen gas is generated onsite and used to
regenerate the catalyst. All utilities required to
operate the system (natural gas, water, and
electricity) are typically available at natural gasfired power plants. The applicant has indicated
that the SCONOxTM system can operate
effectively at temperatures ranging from 280 750 deg F, although the test data ARB staff
analyzed represented a temperature ranging
from 290-310 deg F. It should be noted that
the SCONOxTM system is sensative to trace
amounts of sulfur in the exhaust. It has been
reported that the SCONOxTM system achieves
its lowest NOx levels by adding a sulfur
scrubber to the natural gas fuel.
1. The Oxidation/Absorption Cycle
The SCONOxTM system catalyst (figure 2)
oxidizes CO to CO2 and NO to NO2. The
resulting NO2 is absorbed onto the catalytic
surface through the use of a potassium
carbonate absorber coating. These reactions
are referred to as the AOxidation/Absorption
Cycle:@
CO + 2 O2 $ CO2
(1)
NO + 2 O2 $ NO2
(2)
2NO2 + K2CO3 $ CO2 + KNO2 +
KNO3
(3)
Where:
$ = SCONOxJ system catalyst
are exhausted up the stack instead of NOx.
Potassium carbonate is once again present on
the surface of the catalyst, allowing the
oxidation/absorption cycle to begin again.
Generally, there is no net gain or net loss of
potassium carbonate after both the
oxidation/absorption cycle and the regenerated
cycle have been completed.
The CO2 in reaction (1) and reaction (3) is
exhausted through the stack. Note that during
reaction (3), the potassium carbonate coating
reacts to form potassium nitrites and nitrates,
which are deposited on the surface of the
catalyst. Specifically, when the SCONOxTM
system catalyst becomes saturated with NOx it
must be regenerated. When all of the carbonate
absorber coating (potassium carbonate) on the
surface of the catalyst has been converted to
nitrogen compounds, NOx will no longer be
absorbed, and the catalyst must enter the
regeneration cycle.
Because the regeneration cycle must take place
in an oxygen free environment, the section of
catalyst undergoing regeneration must be
isolated from exhaust gases. This is
accomplished using a pair of louvers, one
upstream of the section being regenerated and
one downstream. During the regeneration
cycle, these louvers close and the valves allow
fresh regeneration gas into, and spent
regeneration gas out of, the section (figure 1).
Stainless steel sealing strips on the louvers
provide a durable barrier against leaks during
operation.
2. The Regeneration Cycle
3. The Regeneration Gas Generator
The regeneration of the SCONOxTM system
catalyst is accomplished by passing a dilute
hydrogen reducing gas across the surface of the
catalyst in the absence of oxygen. The hydrogen
in this gas reacts with the nitrites and nitrates to
form water and molecular nitrogen. Carbon
dioxide in the regeneration gas reacts with the
potassium nitrites and nitrates to form potassium
carbonate, which is the chemically absorbing
surface coating that was on the surface of the
catalyst before the oxidation/absorption cycle
began. This cycle is referred to as the
ARegeneration Cycle@ (reaction 4).
Regeneration gas (hydrogen and carbon
dioxide) is produced by reacting natural gas
with oxygen from ambient air. The
SCONOxTM system uses a gas generator
produced by Surface Combustion Corporation.
This unit uses a two stage process to produce
hydrogen and carbon dioxide. In the first
stage, natural gas and air are reacted across a
partial oxidation catalyst at 1900 deg F to form
carbon monoxide and hydrogen. Steam is
added to the mixture, and then passed across a
low temperature shift catalyst, forming carbon
dioxide and more hydrogen. This mixture is
then diluted to under 4 percent hydrogen using
steam. The reactions for the production of
regeneration gas are listed below.
KNO2 + KNO3 + 4H2 + CO2 $
K2CO3 +4H2O(g) + N2
(4)
CH4 + 2O2 + 1.88N2 $ CO + 2H2
+1.88N2
Where:
$ = SCONOxJ system catalyst
Water (as steam) and elemental nitrogen
Page 11
(5)
CO + 2H2 + H2O + 1.88N2 $ CO2
+ 3H2 +1.88N2
(6)
B. Field Use
The first full scale SCONOxJ system was
installed in May of 1995, at Sunlaw
Cogeneration Partners I=s (SCPI) U.S. Growers=
34 megawatt power plant. A second generation
system was developed with modifications for
better performance, reliability, and improved
economic and operational design. This
redesigned system was installed in December
1996, at the 34 megawatt Federal Cogeneration
Cold Storage Power Plant (FCCSPP) (see figure
4), in Vernon, California.
joint to expand from the HRSG dimensions to
the SCONOxJ system catalyst rack size.
The applicant has indicated that the most
effective operating temperatures for the gas
turbine exhaust flow entering the SCONOxJ
system are between the temperatures of 280 750 deg F. Although temperatures above 750
deg F will render the catalyst ineffective, high
temperatures are not expected to damage the
catalyst. Finally, the applicant has indicated
that once the SCONOxJ system temperatures
cool to below 750 deg F, the catalyst will
resume operating. However, the above claims
are beyond the scope of the evaluation being
discussed in this report.
C. Control System and Instrumentation
The FCCSPP consists of two turbines: 1) a
General Electric LM2500 natural gas-fired
turbine packaged by Stewert and Stevenson; and
2) a 7-8 megawatt steam turbine. The high
pressure steam, produced from the heat
recovery steam generator (HRSG) of the prime
mover (i.e., the natural gas-fired turbine), drives
a the steam turbine. The low pressure steam
drives the unit for chilling the cold storage
facility. Each turbine has its own generator,
which can be used separately or in combination.
Additionally the larger turbine is water injected,
to reduce NOx emissions from approximately
160 ppm to 25 ppm, prior to entering the
SCONOxJ system.
The placement of the SCONOxJ system at
the FCCSPP is in front of the stack, down
stream from the low temperature section of the
HRSG. The number of the SCONOxJ system
layers was determined by the level of
performance required. The FCCSPP
SCONOxJ system catalyst rack is arranged
with twelve rows of seven catalyst cans. Each
can holds twelve catalyst blocks. The catalyst
rack employs a transition piece and expansion
Page 12
The center of the SCONOxJ system is the
Allen Bradley Programable Logic Loop
Controller (PLC). This controller has been
programmed to control all essential
SCONOxJ system functions including:
lowering, opening, and closing of the louver
doors; regenerative gas inlet and outlet valves
opening and closing; and, gas flow for the
positive pressure monitors, records, and reports
system performance.
In addition to the PLC, the SCONOxTM
system is monitored by a Lab View program.
The Lab View program monitors, records, and
reports system performance. It sends
notification and warnings when appropriate,
and it allows the user to control the system by
changing set points (e.g., pressures,
regenerative intervals, and flow rates).
VII. Technical Evaluation
Goal Line Technologies asked the ARB to
verify its claim of 2.0 parts per million volume
dry (ppmvd) of NOx emissions over a three-
hour rolling average. A major part of the
technical evaluation of the SCONOxJ system
claims relied on seven months of performance
and source test data for the 34 megawatt
FCCSPP facility. The data was collected by a
continuous emission monitoring system
(CEMS).
Prior to applying to the ARB=s Equipment
Precertification Program, Goal Line requested
that the the U.S. EPA and the South Coast Air
Quality Management District (SCAQMD)
evaluate the air quality-related performance of
the SCONOxTM system.
Based on their review, the U.S. EPA and
the SCAQMD independently concluded that the
SCONOxJ system achieved a NOx emission
level in practice of 2.0 ppmvd (3 hour rolling
average) and 2.5 ppmvd (1 hour rolling average)
respectively. To support the U.S. EPA and the
SCAQMD evaluation, Goal Line performed
two, six-month tests. The data generated from
the second test was used by the ARB for its
evaluation.
The data set reviewed by the ARB is seven
months of continuous data, from June 1, 1997
through December 31, 1997, which includes the
six months of data analyzed by the U.S. EPA
and the SCAQMD. The ARB received the data
in one-hour and 15 minute time reporting
blocks. The one-hour data was plotted to
observe whether the performance of the
SCONOxJ system achieved the 2.0 ppmvd
proposed claim. The ARB=s Stationary Source
Division (SSD) and the Monitoring and Lab
Division (MLD) reviewed the data to verify a
2.0 ppmvd NOx emission level for the
SCONOxTM system.
Our technical evaluation included a CEMS
system review. During the review process, the
sensitivity and reliability of the CEMS at low
Page 13
NOx levels was explored. A similar evaluation
of the CEMS was also conducted by the U.S.
EPA and the SCAQMD. Our evaluation of the
CEMS system included a review of stack test
data initially prepared for the SCAQMD.
The stack test was conducted by Delta Air
Quality Services at the FCCSPP. Samples
were drawn from the stack downstream of the
SCONOxJ system on January 10, 1997. The
sampling strategy consisted of three, one-hour
tests for CO and NOx. The results of the
source test suggest that the CEMS intake
positioning may lead to reported concentrations
slightly lower than the true average
concentration in the stack. However, the
modest variation between runs may also be
associated with normal process variation rather
than a systematic error introduced by the
CEMS sample outlet location.
Based on an evaluation of the sensitivity
and reliability of the CEMS data, the U.S.
EPA, the SCAQMD, and the ARB have
independantly concluded that the NOx emission
data reviewed from June 1, 1997 to December
31, 1997 is representative of the actual NOx
emission levels.
A potential issue with the SCONOxJ
system is that of scale up. While the ARB
realizes that scale-up of SCONOxJ system to
larger power units is possible, and most likely
probable, we also recognize that there are
several factors which may affect successful
scale-up of the SCONOxJ system. However,
the feasibility and performance of the
SCONOxJ system over a broad range of
turbine sizes and configurations is beyond the
scope of the evaluation presented in this report.
Therefore, the findings presented in this report
only apply to a water injected, 34-megawatt
natural gas-fired combined-cycle turbine.
the waste stream, they are not expected to
represent insurmountable barriers.
VIII. EVALUATION OF CLAIMS:
This section presents additional information
relating to the claims verified by the ARB as
part of this evaluation report. As stated earlier,
the ARB=s evaluation and recommendations
presented in this report are predicated on the
expectation that the SCONOxJ system is
installed, operated, and maintained in
accordance with the manufacturer=s instructions.
Below are supporting comments which may be
used to interpret the significance of the claims
verified in this report. To assist the reader, each
claim is displayed in bold text.
1. The SCONOxJ
J catalytic system
demonstrated emissions of oxides of
nitrogen of 2.0 parts per million
volume dry (15 percent oxygen, 3-hour
rolling average) for a 34-megawatt,
LM2500 natural gas-fired combinedcycle turbine employing water
injection.
The claim language verified by the ARB in this
report is based on our evaluation of the
information discussed under Section V. The
claim language is precise because it must be
directly correlated with the supporting
documentation included with the application
package. Though the supporting documentation
does not allow the ARB to verify the
performance of the SCONOxTM system over a
range of natural gas-fired turbines and
configurations, it is appropriate to include our
overall assessment of the applicability of the
SCONOxTM system to other scenarios. Based
on our evaluation, we believe that it is
technologically feasible to scale-up the
SCONOxTM system to natural gas-fired
combined cycle turbines larger than that
evaluated in this report. Though scaling-up the
technology may present engineering challenges
relating to factors such as flow distribution of
Page 14
It is also important to note that the U.S.
EPA has acknowledged that the SCONOxTM
system demonstrated, in practice, NOx
emissions at 2.0 ppmv over a three hour rolling
average. The U.S. EPA has further indicated
that permitting authorities planning to issue
permits for future natural gas-fired combinedcycle turbine systems which are subject to
LAER, must recognize the 2.0 ppmvd NOx
level. For the majority of such sources, the
U.S. EPA has indicated that the resulting
LAER determination is expected to be
consistent with a level of 2.0 ppmvd NOx.
Finally, based on its evaluation of the
SCONOxTM system, the SCAQMD recently
updated its BACT guidelines to reflect an
achieved in practice determination for natural
gas-fired combined cycles turbines (greater
than 3 megawatts) of 2.5 ppmvd NOx (onehour rolling average).
2. The SCONOxJ
J system does not use
ammonia injection. Therefore, the
SCONOxTM system is not expected to
produce ammonia slip.
The Goal Line Environmental Technologies
SCONOxJ system, unlike SCR, does not
inject ammonia into the system. While it
cannot be said that no ammonia may be
produced as a result of other chemical
interactions, it can be stated that there will be
no ammonia slip as a result of ammonia
injection with the SCONOXTM system.
IX. TEST RESULTS:
The ARB=s evaluation of the SCONOxTM
system consisted of a review of data collected
over a seven month period. The review of
testing data performed by the ARB staff
consisted of an evaluation for the SCONOxJ
system at the FCCSPP facility for emissions data
from June 1, 1997 through December 31, 1997.
The reader may contact the ARB for
information on how to obtain the testing results
considered for this report.
relating to the performance of the CEMS flowcontroller. When evaluated in total, the CEMS
data indicate that the SCONOxTM system
yields a consistent NOx concentration of 2.0
ppmvd over a three-hour rolling average when
the turbine is running at or near its rated
capacity.
As part of our evaluations, we reviewed
source test data, as well as seven months of
continuous emissions data for the same unit.
The source testing of the FCCSPP facility was
originally conducted by Delta Air Quality
Services for submittal to the SCAQMD. A
source test was performed using SCAQMD=s
Method 100.1 (Instrumental Analyzer
Procedures for Continuous Gaseous Emission
Sampling), Method 2.1 ( Determination of The
Stack Gas Velocity and Volumetric Flow Rate
S-Type Pitot Tube), and Method 4.1
(Determination of Moisture Content in Stack
Gases). Each of these methods have been
approved by the U.S. EPA.
X. QUALITY MANAGEMENT
As previously indicated, seven months of
continuous CEMS data was used for the
evaluation presented in this report. During this
seven month period, a Relative Accuracy Test
Audit (RATA) of the CEMS was performed to
verify that the CEMS was operating correctly.
The source test data and the CEMS data were
compared for consistency and used by the ARB
for its evaluation of the SCONOxJ system.
After evaluating the data discussed
throughout this report, the ARB staff concluded
that the SCONOxJ system achieved a NOx
level of 2.0 ppmvd over a three-hour rolling
average. Though the CEMS indicated brief
excursions above 2.0 ppmvd NOx, they did not
lead to a significant increase in the average
concentrations. Furthermore, the majority of
the increases could be correlated with startup/shut-down activities as well as problems
Page 15
Goal Line is in the process of developing a
quality management manual for practices and
standards for its SCONOxJ system
technology. This manual is expected to
incorporate established quality management
practices. A typical manual includes
information for the following areas:
-- Design, Drawing, Specification
-- Material Control and Procedure Control
-- Process Control
-- Inspection and Testing
-- Control of Measuring
-- Test Equipment
-- Record Retention
-- Forms
Once developed, this manual will be used
by customers purchasing the SCONOxJ
system.
XI. ENVIRONMENTAL AND
ECONOMIC BENEFITS
As part of our review, we evaluated the
potential air quality impacts of the SCONOxJ
system . The use of the SCONOxJ system
likely will result in a reduction of NOx
emissions and ammonia slip when compared to
traditional control technologies for natural gasfired combined-cycle turbine combustors.
In addition to environmental benefits, there
is also the potential for economic benefits.
Given that no ammonia is used with the
SCONOxJ system, the costs associated with
ammonia storage and use will be eliminated. It
should also be noted that under certain
conditions, emission reductions resulting from
the installation of the SCONOxJ system, may
be eligible for emission reduction credits.
Therefore, individual air districts in California
should be consulted to determine the eligibility
for any emission reduction credits.
evaluation of the data submitted by Goal Line,
as well as the other information identified in
this report. Our recommendations are
predicated on the expectation that installation
and operation of the catalytic system are
performed in accordance with the
manufacturer=s specifications.
XII. RECOMMENDATIONS
In California, stationary sources are
permitted at the local level by districts. Each of
California=s 35 districts have rules and
regulations which must be met to receive an air
quality permit. The district rules and
regulations reflect federal and state regulatory
requirements as well as any additional
requirements that the district boards determine
to be appropriate for the region.
After evaluating the information discussed
in this report, the ARB staff recommends that
the Goal Line SCONOxJ system be certified
under its Equipment Precertification Program.
Specifically, we have independently verified the
claims of Goal Line concerning its SCONOxJ
system, as presented in the claims section of this
report.
By accepting certification under the ARB=s
program, Goal Line assumes, for the duration of
the three-year certification period, responsibility
for maintaining the quality of the manufactured
equipment and materials at a level equal to or
better than was provided to obtain this
certification. Certification under the ARB=s
program is also contingent on the recipient
agreeing to be subject to quality monitoring by
the ARB as provided by law.
The ARB makes no express or implied
warranties as to the performance of the
manufacturer=s product or equipment. Nor,
does the ARB warrant that the manufacturer=s
product or equipment is free from any defects in
workmanship or material caused by negligence,
misuse, accident, or other causes. The ARB
staff believes, however, that Goal Line=s
SCONOxJ system will achieve the performance
levels presented in the claims section of this
report. Our determination is based on our
Page 16
XIII. SUGGESTED OPERATING
CONDITIONS
Technologies which have been certified
under the ARB=s Equipment Precertification
Program are subject to the same federal, state,
and local permitting requirements as sources
which have not been certified. In short, receipt
of a certificate under the ARB=s Equipment
Precertification Program does not
in anyway limit the authority of local air
districts. However, it is expected that local air
districts will have an interest in considering the
information presented in this report when
making permitting decisions. Therefore, we
have included some information on operating
conditions that districts may consider helpful
when making permitting decisions on the
SCONOxTM system discussed in this report.
After it has been determined that the
SCONOxJ system has been properly installed,
it may be connected to a CEMS device which
continuously measures the concentration of
NOx emissions. For such cases, RATA testing
can be used as a substitute for source testing.
If CEMS are not employed, it is suggested that
source testing be conducted annually to
determine the post-control NOx concentration.
It is also suggested that an accuracy audit of the
exhaust stack flow monitor be conducted on the
same annual schedule.
Other operating conditions to consider
include:
1. Limit the temperature range for the
exhaust gas entering the SCONOxJ
system. The temperature range specified
should be based on data for a similar
system that has demonstrated
performance results consistent with those
specified by the district.
.
2. Limit fuel to PUC pipeline quality natural
gas.
3. Require applicable CEMS testing procedure
be performed semi-annually.
IV. PRECERTIFICATION CONDITIONS
The recommendations in this report are
conditional on the SCONOxJ system being
installed, inspected and maintained, in
accordance with Goal Line=s recommendations.
In order for the precertification to remain valid,
Goal Line must retain manufacturing rights for
the SCONOxTM system.
.
Page 17
Appendix A
Summary of Test Results Showing Six Months of Operating Data on a
Unit Using the SCONOxJ
J System
For more information
contact the Office of Environmental Technology at
(916) 327-5789
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