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HHO - Air Requirements 12-2019
- 1. HAVERHILL OPERATIONS Air Requirements Training Rev. October 2019
- 2. Training Outline • Consent Decree (CD) – Preventative Maintenance and Operations Plan • Air Permit – Work Practice Plan – Startup, Shutdown, Malfunction Plan – Site Specific Monitoring Plan • Door Fires • Common Tunnel • Coked Out Ovens • Sealing Up Oven Doors • Preventing Bypass Venting • PCM • Hot Car • Load Out • Operations and Maintenance Plan • Compliance Assurance Monitoring Plan • QAQC Plans • Heat Recovery • Maintenance • Visible Emissions • Quenching • Air Monitoring • Dust Control • Bypass Venting • Process Gas Pollution Control
- 3. Consent Decree General Requirements PMO Plan Bypass Vent Stack CEMS Restrictions on Bypass Venting Charge Weight Reduction Lower Coal Sulfur, SO2, & PM Limits
- 4. Air Permit Plans Work Practice, Ops & Maint. Practices for Meeting Permit Conditions Startup, Shutdown, Malfunction Response to SSM Events Compliance Assurance Monitoring Site Specific Monitoring QAQC Maintaining SO2/PM Monitoring QAQC Procedures for various equipment Hot Car Monitoring Equipment
- 5. Door Fires • Which of the ovens below has a door fire? Oven 92 Oven 96
- 6. Door Fires • Which of the ovens below has a door fire? Oven 92 Oven 96 • Correct. Oven 96 has a door fire due to positive pressure above the coke loaf • Oven 92 has coal stuck in the seal that is on fire
- 7. Door Fires • Which of the ovens below has a door fire? Oven 92 Oven 100
- 8. Door Fires • Which of the ovens below has a door fire? Oven 92 Oven 100 • We call it a door “fire,” but smoke coming from the oven is also a door fire, unless.. • It is coal that is stuck in the seal that is smoldering
- 9. Door Fires The PCM operator saw oven 96’s door fire at 9:52 am. When must the fire be out?
- 10. Door Fires The PCM operator saw oven 96’s door fire at 9:52 am. When must the fire be out? Within 15 minutes
- 11. Door Fires A Burner is making hits and notices a door fire on oven 3 at 10:00 am. It is very windy out. When must the fire be out? Within 15 minutes, even if caused by wind
- 12. Door Fires Oven 149 often has door fires. What could contribute to that? •Common tunnel pluggages •Uptake damper not in correct position •Uptake damper malfunction •Common tunnel elbow dampers open Reduced draft on “backside” of oven •Ambient Air In-Leakage •Door latches not tight •Door needs kaowool •Holes in door Reduced draft on “frontside” of oven •Oven wall cracks Reduced draft inside oven Corrective Actions Latch doors tightly Sill raking Run air blower on coke side Repair bad equip. Why should you care? Reduced potential exposure to COE Less chance of deviation Burners have VERY short window to respond!
- 13. Door Fires Oven 149 often has door fires. What could contribute to that? •Common tunnel pluggages •Uptake damper not in correct position •Uptake damper malfunction •Common tunnel elbow dampers open Reduced draft on “backside” of oven •Ambient Air In-Leakage •Door latches not tight •Door needs kaowool •Holes in door Reduced draft on “frontside” of oven •Oven wall cracks Reduced draft inside oven Corrective Actions Latch doors tightly Sill raking Run air blower on coke side Repair bad equip. Why should you care? Reduced potential exposure to COE Less chance of deviation Burners have VERY short window to respond!
- 14. Door Fires Oven 149 often has door fires. What could contribute to that? •Common tunnel pluggages •Uptake damper not in correct position •Uptake damper malfunction •Common tunnel elbow dampers open Reduced draft on “backside” of oven •Ambient Air In-Leakage •Door latches not tight •Door needs kaowool •Holes in door Reduced draft on “frontside” of oven •Oven wall cracks Reduced draft inside oven Corrective Actions Latch doors tightly Sill raking Run air blower on coke side Repair bad equip. Why should you care? Reduced potential exposure to COE Less chance of deviation Burners have VERY short window to respond!
- 15. Door Fires Oven 149 often has door fires. What could contribute to that? •Common tunnel pluggages •Uptake damper not in correct position •Uptake damper malfunction •Common tunnel elbow dampers open Reduced draft on “backside” of oven •Ambient Air In-Leakage •Door latches not tight •Door needs kaowool •Holes in door Reduced draft on “frontside” of oven •Oven wall cracks Reduced draft inside oven Corrective Actions Latch doors tightly Sill raking Run air blower on coke side Repair bad equip. Why should you care? Reduced potential exposure to COE Less chance of deviation Burners have VERY short window to respond!
- 16. Door Fires Oven 149 often has door fires. What could contribute to that? •Common tunnel pluggages •Uptake damper not in correct position •Uptake damper malfunction •Common tunnel elbow dampers open Reduced draft on “backside” of oven •Ambient Air In-Leakage •Door latches not tight •Door needs kaowool •Holes in door Reduced draft on “frontside” of oven •Oven wall cracks Reduced draft inside oven Corrective Actions Latch doors tightly Sill raking Run air blower on coke side Repair bad equip. Why should you care? Reduced potential exposure to COE Less chance of deviation Burners have VERY short window to respond!
- 17. Door Fires Oven # Door Obs Prev. Chg Time Prev. Chg Weight Prev. Chg Date Current Chg Time Current Chg Weight Current Chg Date Door Fire Fire Out Time Spill > 250 T Pressure Drop Fan Amp CA Req? CO Time PT Init Comments The PCM operator charged ~40T to oven 79 at 5:42 pm. What did he forget to do?
- 18. Door Fires Didn’t record whether or not he saw a door fire. Oven # Door Obs Prev. Chg Time Prev. Chg Weight Prev. Chg Date Current Chg Time Current Chg Weight Current Chg Date Door Fire Fire Out Time Spill > 250 T Pressure Drop Fan Amp CA Req? CO Time PT Init Comments The PCM operator charged ~40T to oven 79 at 5:42 pm. What did he forget to do?
- 19. Door Fires Didn’t record whether or not he saw a door fire. Oven # Door Obs Prev. Chg Time Prev. Chg Weight Prev. Chg Date Current Chg Time Current Chg Weight Current Chg Date Door Fire Fire Out Time Spill > 250 T Pressure Drop Fan Amp CA Req? CO Time PT Init Comments The PCM operator charged ~40T to oven 79 at 5:42 pm. What did he forget to do? Preventative Actions Remembering to record the observation Reviewing record before leaving machine to check for errors/prevent deviations Supervisor following up with person after review to discuss & correct, if reasonable
- 20. Door Fires Oven # Door Obs Prev. Chg Time Prev. Chg Weight Prev. Chg Date Current Chg Time Current Chg Weight Current Chg Date Door Fire Fire Out Time Spill > 250 T Pressure Drop Fan Amp CA Req? CO Time PT Init Comments What did the operator remember to do? Even though oven 79 was charged late, he remembered to get the DP reading.
- 21. Door Fires XXX Oven # Door Obs Prev. Chg Time Prev. Chg Weight Prev. Chg Date Current Chg Time Current Chg Weight Current Chg Date Door Fire Fire Out Time Spill > 250 T Pressure Drop Fan Amp CA Req? CO Time PT Init Comments The PCM operator noted a door fire on oven 79, but that’s it. What’s missing?
- 22. Door Fires The start and end time of the door fire and the corrective actions XXX Oven # Door Obs Prev. Chg Time Prev. Chg Weight Prev. Chg Date Current Chg Time Current Chg Weight Current Chg Date Door Fire Fire Out Time Spill > 250 T Pressure Drop Fan Amp CA Req? CO Time PT Init Comments The PCM operator noted a door fire on oven 79, but that’s it. What’s missing?
- 23. Door Fires The start and end time of the door fire and the corrective actions XXX Oven # Door Obs Prev. Chg Time Prev. Chg Weight Prev. Chg Date Current Chg Time Current Chg Weight Current Chg Date Door Fire Fire Out Time Spill > 250 T Pressure Drop Fan Amp CA Req? CO Time PT Init Comments The PCM operator noted a door fire on oven 79, but that’s it. What’s missing? Example Door Fire Corrective Actions Adjust door holes, sole flues, uptakes Increase draft Button up oven Repair uptake damper Do not write down “Contacted CRO” - It is NOT a full corrective action per OEPA
- 24. Door Fires Oven # Check Oven for Door Fire? Door Fire Seen? DurationPressure Drop Fan Amp Operator Initial CommentsNotified CRO? Did the Hot Car Operator forget anything after Oven 88 was pushed and charged?
- 25. Door Fires Oven # Check Oven for Door Fire? Door Fire Seen? DurationPressure Drop Fan Amp Operator Initial CommentsNotified CRO? Did the Hot Car Operator forget anything after Oven 88 was pushed and charged? Didn’t record whether or not he saw a door fire.
- 26. Door Fires Oven # Check Oven for Door Fire? Door Fire Seen? DurationPressure Drop Fan Amp Operator Initial CommentsNotified CRO? What could have caused this? Scenario #1 Right after the oven was charged, the PCM shut down causing a delay in charging. Because of the disruption to his routine, he forgot to observe the oven after it was later charged. Scenario #2 This oven was pushed empty hours earlier. When it was charged @ 6:00 pm, the Hot Car was not present because nothing was being pushed. Regardless of where the Hot Car is, someone has to check the oven for door fires.
- 27. Door Fires Oven # Check Oven for Door Fire? Door Fire Seen? DurationPressure Drop Fan Amp Operator Initial CommentsNotified CRO? What did the operator remember to do? To get the DP and Fan Amps during the push.
- 28. Door Fires Oven # Check Oven for Door Fire? Door Fire Seen? DurationPressure Drop Fan Amp Operator Initial CommentsNotified CRO? Preventative Actions Remembering to record the observation Reviewing record before leaving machine to check for errors/prevent deviations Supervisor following up with person after review to discuss & correct, if reasonable Having someone check the C/S of oven 88 after charging. Anyone could’ve remembered this.
- 29. Questions?
- 30. Common Tunnel • Coke oven emissions are burned in ovens • Process gas goes to common tunnel • > 1400°F • Recorded once per shift • Negative pressure – Recorded once per day
- 31. Coked Out • SunCoke & MACT requirements • Visually inspect each oven before pushing through the door hole
- 32. Coked Out • SunCoke & MACT requirements • Visually inspect each oven before pushing through the door hole • No smoke/gas above the coke bed
- 33. Coked Out • SunCoke & MACT requirements • Visually inspect each oven before pushing through the door hole • No smoke/gas above the coke bed • Unobstructed view of opposite side door
- 34. Coked Out • SunCoke & MACT requirements • Visually inspect each oven before pushing through the door hole • No smoke/gas above the coke bed • Unobstructed view of opposite side door
- 35. Coked Out • SunCoke & MACT requirements • Visually inspect each oven before pushing through the door hole • No smoke/gas above the coke bed • Unobstructed view of opposite side door Additional SunCoke (only) requirements Time & Temperature < 5’x5’ area of flame Any flame is no more than 2-4 feet above the coke bed Any flame is lazy, dull & almost transparent-looking
- 36. Sealed doors maximize oven draft & prevent door fires/deviations Sealing Up Oven Doors Door Machine Operator puts on CS door immediately after pushing
- 37. Sealed doors maximize oven draft & prevent door fires/deviations Sealing Up Oven Doors Door Machine Operator puts on CS door immediately after pushing P/S: Sill raker cleans door sills with water C/S Oven machines have air blowers to remove debris from the door sills P/S & C/S: Operators tighten door latches
- 38. Over the radio, you hear Stack Lids 6-10 just opened. The Boiler Feed Water Pump MCC you were leaning on is shown below. What happened? Is this a Deviation? Preventing Bypass Venting
- 39. Over the radio, you hear Stack Lids 6-10 just opened. The Boiler Feed Water Pump MCC you were leaning on is shown below. What happened? Is this a Deviation? Preventing Bypass Venting Yes. While leaning on the MCC, you inadvertently hit the unprotected E-Stop button.
- 40. Over the radio, you hear Stack Lids 6-10 just opened. The Boiler Feed Water Pump MCC you were leaning on is shown below. What happened? Is this a Deviation? Preventing Bypass Venting Yes. While leaning on the MCC, you inadvertently hit the unprotected E-Stop button. Be very careful & aware of potential venting hazards when working around MCCs
- 41. You are scheduled to do the PM on B ID Fan. Is it running? Preventing Bypass Venting
- 42. You are scheduled to do the PM on B ID Fan. Is it running? Preventing Bypass Venting Green bulb is burnt out, but another indicator light shows B ID Fan is running. Don’t take B ID Fan offline until C is put in service.
- 43. You are scheduled to do the PM on B ID Fan. Is it running? Preventing Bypass Venting Green bulb is burnt out, but another indicator light shows B ID Fan is running. Don’t take B ID Fan offline until C is put in service. When doing maintenance, talk to the CRO, check drawings & labels, ask someone who knows, double-check yourself, etc. to prevent inadvertent trips & deviations.
- 44. Classroom Activity • Using the handouts – Pollution Control Equipment Basics – Visible Emission Limits – Push Report – Hot Car Sheet – Load Out Sheet – Product Tech Door Fire Record – Malfunction Report – Work Order Status Sheet • Complete the Pollution Control Equip. Challenges – PCM – Hot Car – Load Out – Heat Recovery – Burning – Heat Recovery – Control Room – Maintenance – Quench – Rainbirds Skip if Computer Based
- 45. Questions?
- 46. • Baffles knock down coke dust during quenching • Cleaning them removes this buildup – Make sure baffle sprays have good pressure Quenching
- 47. • Baffles knock down coke dust during quenching • Cleaning them removes this buildup – Make sure baffle sprays have good pressure Quenching What’s wrong here?
- 48. • Baffles knock down coke dust during quenching • Cleaning them removes this buildup – Make sure baffle sprays have good pressure Baffle sprays are plugged Quenching What’s wrong here?
- 49. • Baffles knock down coke dust during quenching • Cleaning them removes this buildup – Make sure baffle sprays have good pressure Baffle sprays are plugged & have low pressure Quenching What’s wrong here?
- 50. • Inspecting baffles each month for damage and >95% coverage ensures efficient dust collection Quenching
- 51. • Inspecting baffles each month for damage and >95% coverage ensures efficient dust collection Quenching What’s wrong here?
- 52. • Inspecting baffles each month for damage and >95% coverage ensures efficient dust collection Baffle is damaged Quenching What’s wrong here?
- 53. • Inspecting baffles each month for damage and >95% coverage ensures efficient dust collection Quenching And here?
- 54. • Inspecting baffles each month for damage and >95% coverage ensures efficient dust collection Baffles have fallen Quenching And here?
- 55. • Inspecting baffles each month for damage and >95% coverage ensures efficient dust collection Quenching What about here?
- 56. • Inspecting baffles each month for damage and >95% coverage ensures efficient dust collection Baffles are missing* Quenching What about here? *for training purposes only, baffles were in place, but obscured by light
- 57. • Water for quenching has a Total Dissolved Solids (TDS) limit – 1100 mg/L – Helps control emissions during evaporation from quenching Quenching
- 58. • Ambient Air Monitoring in the area for SO2 and dust (PM) – Gallia Pike – upwind – Guard Shack – downwind – Back Road – near neighborhood Air Monitoring
- 59. • Continuous Emission Monitoring Systems (CEMs) for SO2 – HH1/HH2 Main Stacks • 192 lb/hr SO2 as a 3 hour avg • 700.8 tons/yr Air Monitoring CEMs Ports on Main Stack
- 60. • Continuous Emission Monitoring Systems (CEMs) for SO2 – HH1/HH2 Main Stacks • 192 lb/hr SO2 as a 3 hour avg • 700.8 tons/yr – HRSG 5/6 Bypass Vent Stacks • 420 lb/hr as a 3 hour avg • 323 lb/hr as rolling 48 hour avg Air Monitoring Bypass Vent Stack CEMs CEMs Ports on Main Stack
- 61. • Continuous Sorbent Trap Monitoring for Mercury (Hg) • Inject powder activated carbon (PAC) into gas stream @ 60 lb/hr to remove Hg – HH2 Main Stack • 0.01 lb/hr as 1 month avg • 55.5 lb as rolling 12 month total Air Monitoring
- 62. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation Dust Control
- 63. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Enclosures – Covered Coal storage Dust Control
- 64. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Enclosures – Covered Coal storage – Covered Coal/Coke Conveyors Dust Control
- 65. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Enclosures – Covered Coal storage – Covered Coal/Coke Conveyors – Quench Tower Hood Dust Control
- 66. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Enclosures – Covered Coal storage – Covered Coal/Coke Conveyors – Quench Tower Hood – Yes…even Paving Dust Control
- 67. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Enclosures – Covered Coal storage – Covered Coal/Coke Conveyors – Quench Tower Hood – Yes…even Paving Dust Control
- 68. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Water Suppression – Coal Pile Rain Birds Dust Control
- 69. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Water Suppression – Coal Pile Rain Birds – Coke Pile Rain Birds Dust Control
- 70. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Water Suppression – Coal Pile Rain Birds – Coke Pile Rain Birds – Water Truck Dust Control
- 71. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Water Suppression – Coal Pile Rain Birds – Coke Pile Rain Birds – Water Truck – Water Sprays on Oven Equipment • Quench Tower Top Sprays • Load Out Dust Control
- 72. • Strict Visible Emission (VE) limits • If you see VEs and don’t take action, it is a deviation • Water Suppression – Coal Pile Rain Birds – Coke Pile Rain Birds – Water Truck – Water Sprays on Oven Equipment • Quench Tower Top Sprays • Load Out Dust Control
- 73. Bypass Venting • Bypass Venting occurs during malfunction, deviation, and maintenance – HCC is only permitted time for FGD maintenance
- 74. Bypass Venting The monthly stack lid PM is scheduled for today, but HRSG 8 is offline & the lid has opened intermittently over the last week. Which lids should you exercise?
- 75. Bypass Venting The monthly stack lid PM is scheduled for today, but HRSG 8 is offline & the lid has opened intermittently over the last week. Which lids should you exercise? 1-5. Exercising HH2 may upset the draft conditions
- 76. Process Gas Pollution Control • Atomizers inject lime slurry into SDA – Removes SO2 – Creates Ash
- 77. Process Gas Pollution Control • Gas/Ash Exits SDA – PAC injected • Removes Hg
- 78. Process Gas Pollution Control • Ash collects on bags • Clean air goes through bags • Continues through ducts
- 79. Process Gas Pollution Control • Is checked for Hg and SO2 • Goes out Main Stack
- 80. Questions?