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Contingency Planning in the Design of Air Pollution Control Systems

Carolinas Air Pollution Control Association

Presentation by:Michael Mannuzza

OBG

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CONTINGENCY PLANNING

<Risk: 1. Exposure to the chance of injury or loss, a hazard

or dangerous chance.<Risk Management:

1. The technique or profession of assessing, minimizing, and preventing accidental loss to a business, as through the use of insurance, safety measures, etc.

<Contingency: 1. A chance, accident, or possibility conditional on

something uncertain.

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Risk Associated with Diminishing Emission Limits NSPS Subpart Ce

Emission Standard for Medium HMIWIPollutant Limit

Lead0.0153mg/dscm

0.0079gr/103dscf

Cadmium0.013mg/dscm0.0057gr/103dscf

Mercury0.025mg/dscm0.011gr/103dscf

D/F (TEQ)0.00002mg/dscm

1.0gr/109dscf

RISK

EMISSION LIMITS

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LIMITATIONS OF SOURCE DATA<Process Scale-up

Uncertainties<Material Take-off

Limitations<Properties of Process

Exhaust that Preclude Data Collection

<Process Variability<Repeatability<Confidentiality

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CONTINGENCY PLANNING MEETING• A Type of Risk Assessment

– Systematic, Methodical Approach– Identifies Potential Exposure to Performance

Liabilities– Quantifies Potential Costs

• Provides a Methodology to Identify Potential Impacts on Project Cost & Schedule

• Adds the Most Value When:– Process Streams are Highly Variable– Available Data is Incomplete– Compliance Requirements are Challenging

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CONTINGENCY PLANNING MEETING<Implemented Much Like a HAZOP or Process Hazard

Analysis (PHA) Meeting– Assign a Score for Severity of Event– Assign a Score for Likelihood of Event– Establish a Risk Matrix Used to Drive Decision

Making<Excellent tool for:

– Identifying Regulatory Risk– Quantifying Potential Costs– Quantifying Potential Impacts on Schedule

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CONTINGENCY PLANNING PROCESS• Pre-Requisites:

– Knowledge of Process Constituency– Knowledge of Applicable Regulatory Codes

– Consequences of Non-Compliance– Potential Costs Associated with Non-Compliance

– Additional Labor Costs– Waste Disposal & Storage Costs– Lost Production Revenue– Regulatory Fines– Contractual Penalties– Additional Equipment Maintenance/Repair

Costs– Other Costs

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SEVERITY ASSESSMENTIMPACTS

SEVERITY REGULATORY PRODUCTION MAINTENANCE FINANCIAL1 Non-Reportable

IncidentNone Minorimpacton

equipmentlongevity

< $$$

2 Reportable Incident

Not Likely to Impact.

Minorimpactonequipmentlongevity.

$$$ to $$$

3 Reportable Incident

Possible Shutdown

Moderate.Mayrequireunscheduleddown-time,reduceequipmentlongevity.

$$$ to $$$

4 Reportable Incident

Definite Shutdown

Likelytocauseprematureequipmentfailure,requireextensiverepairs

> $$$

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LIKELIHOOD ASSESSMENT

LIKELIHOOD DESCRIPTION

1 Remote - Doubtful that it will ever occur

2 Unlikely - Might occur once during equipment lifetime

3 Likely - might occur several times during equipment lifetime.

4 Very Likely - could occur more than once on an annual basis.

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RISK MATRIXRISK MATRIXLi

kelih

ood 4 C N N N

3 A N N N2 A C C C1 A A A C

1 2 3 4Severity

A – Acceptable RiskC – Contingency Plan RequiredN – Not Acceptable – Must Design for Control.

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CONTINGENCY STRATEGY CATEGORIES

• APC Contingency Strategies Fall into 3 categories:1. Enhanced Equipment

Flexibility2. Provisions for Future

Equipment Implementation

3. Procedural Adaptation

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ENHANCED EQUIPMENT FLEXIBILITY –VENTURI SCRUBBER EXAMPLE

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FUTURE EQUIPMENT STRATEGIES• Certain Emission Levels May be Impossible to

Identify Prior to Start-Up.– Identify Technical Solution & Plan for it.

• Provisions Incorporated into the System Design to Facilitate the Installation of Additional Equipment if Needed:

– Spool Pieces– Nozzles– Concrete Pad Space– Fan Capacity– Fully Engineered Drawings– Budget

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FUTURE EQUIPMENT STRATEGIES –DRY SORBENT INJECTION

<Dry Sorbent Injection Skids4SO2 & SO3

4Mercury4Dioxin Furan4Enhanced ESP

Performance.

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BAGHOUSES – CATALYTIC FILTER OPTIONS FOR D/F CONTROL

Image provided courtesy of Gore Creative Technology Worldwide

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MERCURY ADSORPTION CONTINGENCY STRATEGIES

Image provided courtesy of Gore Creative Technology Worldwide

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PROCEDURAL ADAPTATION STRATEGIES

• Adjust APC Operating Parameters• Modify Waste Load size & Feed Rates• Limit Production Rates• Stagger Production Processes• Adjust Process Formulations• Employ Chemical Additives

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Conclusion• Contingency Planning Meeting:

– Provides a more focused contingency planning effort

– Engages all project stake-holders– Compensates for data shortfalls and

unknowns– Helps better define project cost exposure

and schedule– Mitigates risk– Helps project & plant managers sleep better

at night.

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