Add-on Control Technologies Selective Non catalytic Reduction (SCNR) Selective Catalytic Reduction (SCR) Step 2: Eliminate technically infeasible options: The primary criterion for any emissions control technology that is being considered for controlling flare system emissions is that it should not impact the NMOC performance of the proposed flare system. Any modifications, that affect the combustion chemistry of the proposed flare system, will have adverse impacts on its NMOC performance. The proposed flare system combustion process is designed to maximize the NMOC destruction while optimizing the emissions of CO and NOx. The low-NOx burner option under the stoichiometry based combustion modifications category is already incorporated in the proposed flare system design as demonstrated by the low level of NOx (0.06 lb/MMbtu). The flue gas re circulation identified under the dilution based combustion modifications is not applicable to the proposed flare system because any circulation of high temperature gases back into combustion chamber is not expected to lower the NOx level. The water/steam injection identified under the dilution based combustion modifications is not applicable to the proposed flare system because any lowering of combustion zone temperature by adding water or steam will adversely affect NMOC performance. In addition, the use of steam will require a steam generating plant nearby resulting in emissions being addressed here. SCNR and SCR add-on control technologies cannot withstand temperatures generally in excess of 1000oF. Typical flare system temperatures range from 1600oF to 2000oF. Therefore SCNR and SCR add-on control technologies are not technically feasible for controlling NOx and CO emissions emitted by the proposed landfill and flare system. Step 3: Ranking remaining control technologies by control effectiveness: Combustion modification or add-on control technologies are not applicable to the proposed flare system for the reasons stated in the previous Step 2 above for both NOx and CO as minimizing NOx usually increases CO emissions. The low-NOx burner technology is incorporated in the proposed flare system designed. BCL has proposed a CO level of 0.2 lb/MMbtu. Step 4: Evaluate most effective controls and document results: Emission Controls for Existing Installations (RBLC) The BACT review requires comparison of the emissions controls proposed for the landfill expansion project sources with other similar sources. USEPA maintains a control technology database, the RBLC on - line database, that includes control technology details for various sources installed
Add-on Control Technologies Selective Non catalytic Reduction (SCNR) Selective Catalytic Reduction (SCR) Step 2: Eliminate technically infeasible options: The primary criterion for any emissions control technology that is being considered for controlling flare system emissions is that it should not impact the NMOC performance of the proposed flare system. Any modifications, that affect the combustion chemistry of the proposed flare system, will have adverse impacts on its NMOC performance. The proposed flare system combustion process is designed to maximize the NMOC destruction while optimizing the emissions of CO and NOx. The low-NOx burner option under the stoichiometry based combustion modifications category is already incorporated in the proposed flare system design as demonstrated by the low level of NOx (0.06 lb/MMbtu). The flue gas re circulation identified under the dilution based combustion modifications is not applicable to the proposed flare system because any circulation of high temperature gases back into combustion chamber is not expected to lower the NOx level. The water/steam injection identified under the dilution based combustion modifications is not applicable to the proposed flare system because any lowering of combustion zone temperature by adding water or steam will adversely affect NMOC performance. In addition, the use of steam will require a steam generating plant nearby resulting in emissions being addressed here. SCNR and SCR add-on control technologies cannot withstand temperatures generally in excess of 1000oF. Typical flare system temperatures range from 1600oF to 2000oF. Therefore SCNR and SCR add-on control technologies are not technically feasible for controlling NOx and CO emissions emitted by the proposed landfill and flare system. Step 3: Ranking remaining control technologies by control effectiveness: Combustion modification or add-on control technologies are not applicable to the proposed flare system for the reasons stated in the previous Step 2 above for both NOx and CO as minimizing NOx usually increases CO emissions. The low-NOx burner technology is incorporated in the proposed flare system designed. BCL has proposed a CO level of 0.2 lb/MMbtu. Step 4: Evaluate most effective controls and document results: Emission Controls for Existing Installations (RBLC) The BACT review requires comparison of the emissions controls proposed for the landfill expansion project sources with other similar sources. USEPA maintains a control technology database, the RBLC on - line database, that includes control technology details for various sources installed
193913.docx