April 2013

Vol. 157 No.
4 April 2013

TVAs Paradise Unit 2 Sets
New Long-Run Record
Pick the Best Mercury Technology
Stop Steam Turbine Vibration
NERC CIP Audit Preparation
Global Nuclear Waste Storage Plans
CIRCLE 1 ON READER SERVICE CARD
April 2013
|
POWER www.powermag.com 1
24
Established 1882 Vol. 157 No. 4 April 2013
ON THE COVER
Tennessee Valley Authoritys (TVAs) Paradise Fossil Plant Unit 2 set its 259+ day continu-
ous run record for a cyclone-fired boiler on Jan. 12, 2013. The new record eclipsed the
previous cyclone-fired boiler record of 255+ days, set by the plants Unit 1 in 1993. The
Paradise plant will mark its 50th anniversary of first operation on May 19 this year. Cour-
tesy: TVA
COVER STORY: COAL PLANT OPERATIONS
24 TVAs Paradise Unit 2 Sets New Continuous Operations Record
Tennessee Valley Authoritys Paradise Fossil Plant got off to a rocky start with its
original cyclone-fired boilers, but since replacing them with improved versions and
incorporating emissions upgrades, the plant has racked up several records. Paradise
has more complex equipment now than previously, and that equipment is operated
by a younger, but more rigorously trained, staff.
SPECIAL REPORTS
REGULATORY
28 Preparing for a NERC CIP Audit
Based on real-world NERC CIP audit experiences, this five-step plan will guide
those responsible for audit documentation preparation. The process is applied
to a single NERC CIP sub-requirement as an example, and additional resources
are provided.
EMISSIONS CONTROL
36 Electrostatic Precipitator Upgrade Opportunities
The U.S. Environmental Protection Agency has accepted filterable particulate mat-
ter as a surrogate for virtually all trace metals, which gives power generators the
flexibility to use electrostatic precipitators (ESPs) to comply with the recent Mer-
cury and Air Toxics Standards. That means monitoring the performance of your
ESP is more important than ever.
FEATURES
POWER IN CHINA
53 Wind Power Incidents in China: Investigation and Solutions
The rapid pace of wind power development in China has resulted in excess capacity,
grid integration difficulties, and myriad problems associated with quality. Turbine
trip incidents and equipment faults are the most prevalent. The authors look at the
causes of these problems and propose solutions.
MERCURY CONTROL
56 Enhancing Mercury Capture: An Asset-Based Approach
This article outlines common factors affecting mercury capture performance and
presents a generalized asset-based approach for identifying basic upgrade re-
quirements for U.S. coal-fired plants preparing to comply with the Mercury and
Air Toxics Standards.
Power in the United
Arab Emirates
Shifting Sands: The UAE Power Sector En-
ters a New Era of Diversification, a spon-
sored report from Global Business Reports,
tracks the attempts of the UAE to explore
alternative energy sources in response to
explosive growth in its electricity con-
sumption. From large investments in
nuclear to the unique challenges of solar
power in the desert, a wide range of op-
tions remain on the table. (After p. 44)
56
www.powermag.com POWER
|
April 2013 2
PLANT O&M
62 Steam Turbine Rotor Vibration Failures: Causes and Solutions
Managers of an Iranian coal-fired power plant share their experience with the static
and dynamic causes of extreme rotor bending as well as measures for avoiding the
potentially cascading effects of this problem.
NUCLEAR WASTE POLICY
67 Nuclear Waste Disposal Sites Still Rare After All These Years
Even as more nations build new nuclear power plants, long-term storage options for
various radioactive waste products from nuclear power generation remain scarce.
We look at the types of waste, reuse and disposal options, and the status of long-
term storage sites around the world.
DEPARTMENTS
SPEAKING OF POWER
6 Americas Growth Corridors
GLOBAL MONITOR
8 Europe Embraces Shale Gas
10 THE BIG PICTURE: Subsidy Tug-of-War
12 Bulgarian PM Quits over Power Price Protests
FOCUS ON O&M
14 Battling White Rust
LEGAL & REGULATORY
22 Filling the Hole in Californias Capacity Procurement Plan
By Jeffrey P. Gray and Vidhya Prabhakaran, Davis Wright Tremaine
74 NEW PRODUCTS
COMMENTARY
80 The Pacific Northwests Wind Fleet Integration Struggles
By Eric Christensen, Gordon Thomas Honeywell LLP
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Get More POWER on the Web
Online, associated with this issue (on our homepage, www.powermag.com, during the
month of April, or in our Archives any time), youll find these web exclusives:
Spain Proposes More Power Market Reforms
Global Developments for Nuclear Reactors Under Construction
The UKs Uncertain Nuclear Future
Carbon Capture for Natural Gas
Asian Hydro Sees Mounting Legal Disputes
Fuel Cells Adapted for Unmanned Undersea Vehicles
Ohio State Completes Integrated Operation Test of Coal Chemical Looping Technology
POWER Digest, a selection of recent global power industry deals
Too Dumb to Meter, Part 10 with The Great Uranium Conspiracy and Breeding at
the Turkey Farm
And remember to check our Whats New? segment on the homepage regularly for
just-posted news stories covering all fuels and technologies.
62
14
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April 2013 4
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|
April 2013 6
SPEAKING OF POWER
Americas Growth Corridors
T
he familiar Red StateBlue State
map is a symbolic means of quickly
communicating political prefer-
ences. The maps arent meant to be pre-
dictive of job, economic, or population
trends, yet a recent think tanks report
suggests the metaphor may have broad-
er significance.
The Manhattan Institute for Policy
Research released in February Americas
Growth Corridors: The Key to National Re-
vival, which describes the future growth
of our economy in terms of growth cor-
ridors. The economic and population
trends reported look remarkably like the
iconic election night map with Blue States
(my analogy, not the authors) defined as
strips along the Pacific and Northeast At-
lantic coasts and along the shores of the
Great Lakes. The Red States are those lo-
cated along the Third Coast bordering
the Caribbean, the Intermountain West,
the Great Plains, and the Southeast Manu-
facturing Belt. The report calls these four
regions Americas Growth Corridors, rep-
resenting 45% of the nations land mass
and 30% of its population.
Diverging Economic Directions
Conventional wisdom tells us businesses
prefer regions with a sufficient labor pool,
real estate, reasonable cost of living, rela-
tively low taxes, and a regulatory climate
conducive to business. Availability of low-
cost energy has also jumped near the top
of that list. Its no surprise that recent
data suggest employers uniformly favor
the Red States over the Blue States when
locating new businesses. However, that
trend is indicative of a major economic
shift now under way with the country,
particularly with job creation and manu-
facturing of goods.
The energy industry has led the nation
in job creation over the past decade. Oil
and gas extraction jobs alone, predomi-
nately located in the Red States, have
increased over 27% since early 2008,
producing the highest number of jobs in
that industry since late 1987. Moodys
Analytics reports that the oil and gas
extraction industry created more than
one million jobs since 2002, out of the
2.7 million jobs created across the en-
tire country over the same period! Con-
versely, Blue States generally eschew
energy production businesses with the
consequential loss in jobs and tax rev-
enue. For example, New York Governor
Andrew Cuomos moratorium on hy-
draulic fracking, if continued, will cost
citizens about $11 billion in economic
output, $1.4 billion in tax revenues, and
perhaps up to 90,000 jobs, in a region
of New York that has lost 48,000 jobs
between 2000 and 2010.
Business leaders, particularly those
producing goods, also favor the Red
States. The report notes that 11 of the
top 15 spots in Chief Executive maga-
zines 2012 review of states with the best
business climate were Corridor states.
In fact, the Southeastern Industrial Belt
recently grabbed 10 of the top 12 slots
in Site Selection magazines 2012 list of
best places to locate a new plant. The
Southeast Manufacturing Belt has be-
come a very attractive location for many
international manufacturing firms to re-
locate, particularly from Korea, Japan,
and Germany. Boston Consulting Group
termed this a reallocation of global
manufacturing with auto, steel, aero-
space, and petrochemical plants making
the move to regions with low energy
cost. An additional attraction is lower
taxes. Income taxes have steadily risen
in Blue States (particularly California,
Illinois, New York, and Massachusetts)
while Red States, like Kansas and Loui-
siana, have lowered or eliminated state
income taxes, like Florida and Texas.
Red State job growth, between 2001
and 2012, was between 7.9% and
9.6%, depending on the region, nearly
10 times that of Blue States (only the
Southeastern Industrial Belt followed
the national average). Energy industry
jobs in the Great Plains and Intermoun-
tain West regions increased over 52%
and 46%, respectively, since 2001, com-
pared to an anemic 2.7% experienced by
the remainder of the nation. And these
jobs are not minimum wage jobs. The
average annual wage in Los Angeles was
$46,411 in 2012. In the Houston energy
corridor, home to more than 230,000
energy workers, the average income was
$75,256.
The emerging Latin American econo-
mies will further benefit the Third
Coast ports of entry. Already, imports
have increased 167% over the past de-
cade. Were you aware that the widening
of the Panama Canal should be com-
pleted in 2014? Ships from the Far East
can deliver goods cheaper to market by
offloading in Houston, New Orleans, and
Tampa than by unloading in Los Ange-
les or San Francisco and then trucking
to eastern destinations. The canal ex-
pansion will likely cause enormous job
losses in the logistics industry along the
West Coast and commensurate job gains
along the Third Coast.
Voting Rights
The economic disunions within our coun-
try will continue to widen in the future.
New York Times columnist Thomas Fried-
man rails against the curse of raw-ma-
terial wealth and the dangers of using
raw materials to spur economic growth, a
distinctly Blue State view where limiting
carbon dioxide production trumps all else.
I dont see a path out of the Blue State
economic doldrums, even with a support-
ive administration, until business and jobs
become the priority.
In Red States, global manufacturers
are relocating to the Southern Manufac-
turing Belt, the Great Plains exported a
record $135 billion of food product in
2011the best since the 1980s, and
the politics favoring energy extraction
have produced the majority of new,
well-paying jobs in our economy over
the past decade.
Your right to vote is guaranteed. How-
ever, it seems voting with your feet is of-
ten more effective.
Dr. Robert Peltier, PE is POWERs
editor-in-chief.
2013 Diamond Power International, Inc. All rights reserved.

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April 2013 8
Europe Embraces Shale Gas
Several European governments have so far this year bucked a
reluctance to extract shale gas via hydraulic fracking even as
the practice continues to be strongly opposed in countries like
France and Bulgaria. Following the UKs move in late Decem-
ber to lift a ban on shale gas exploration, Germany on Feb. 26
unveiled a draft law that permits development of the uncon-
ventional fossil fuel through fracking, albeit with conditions.
Reversing a previous decision, Romanian authorities on Jan.
31 awarded energy giant Chevron certificates to explore for
shale gas in the eastern part of the country, while a Ukrainian
regional council voted to approve a deal with Shell to develop
a shale gas field.
These decisions come on the heels of the European Parlia-
ments rejection of a ban on shale gas. And late last year, the
European Commission (EC) Joint Research Centre issued a key
report (Figure 1), which finds that under a best case scenario
(one that takes into account environmental considerations),
future shale gas production in Europe could help the European
Union (EU) maintain a stable dependency on energy imports,
keeping them at the current 60% of total EU energy needs.
The report acknowledged, however, that considerable uncer-
tainty exists about recoverable volumes, as well as regarding
technological developments and public acceptance of shale
gas extraction. Critically, it noted, the EC remained neutral
to member states decisions concerning their energy mix, but
it stressed that the commission would continue to ensure that
an appropriate framework was set up to enable sustainable
shale gas extraction that fits within EU policy objectives of
working toward a decarbonized economy. The framework is
expected sometime this year.
Germany Warms to Fracking
In industry-heavy Germany, shale gas drilling has been a head-
line-making and contentious political subject that features
prominently in the rhetoric of politicians seeking votes in this
years Sept. 22 national election. Germany chose to shut down
six of its nine remaining operational nuclear reactors by 2022
after the Fukushima Daiichi accident in March 2011, but it is
now struggling to secure replacement power. The draft legis-
lation released by Chancellor Angela Merkels government in
February introduces environmental safeguards by outlawing
fracking in protected areas and near drinking wellsan area
estimated to cover about 14% of German territory. All projects
must also undergo environmental impact studies.
Experts suggest that the proposed restrictions may not ap-
pease fracking opponents in the Greens and Social Democratic
parties, which have urged the government to institute a mora-
torium on shale gas development until better techniques are
found. Proponents say, meanwhile, that Germanys economy
would get a badly needed boost if it exploited its estimated
2,300 billion cubic meters (bcm) of technically recoverable
shale gas reserves. They point out that fracking isnt new to
Germany: About 300 wells have already been fracked since the
1960s. But, as Germanys domestic supplies of conventional
natural gas dry up, the country continues to consume about
86 bcm/year of natural gasabout 40% of which it is forced
to import from Russia.
Romanias Government Backs Shale Gas
After the re-electionwith an absolute majority in both the
Chamber of Deputies and the Senatelast December of Roma-
nias Social Liberal Union party, Prime Minister Victor Ponta
has publically said he supports environmentally responsible
shale gas exploration. The statement is a U-turn from Pontas
previous stance, before he was appointed as prime minister
in May, to ban shale gas exploration (he proposed a bill that
was overwhelmingly defeated by the Senate). Despite public
protests in southeast Romania, where the countrys shale
gas reserves are situated, Chevron in January reportedly ob-
tained zoning certificates enabling it to explore for shale gas
with fracking.
Ukraine Prepares Shale Gas Deal
Ukraine also made headway in January, as deputies of the
Donetsk regional council voted to approve a deal with Royal
Dutch Shell to develop the Yuzivska shale gas field. The east-
ern European country harbors Europes third-largest shale gas
reserves (at 1.2 trillion cubic meters, behind France and Nor-
way) but is mired in a contentious 10-year deal signed in 2009
by the previous government with Russias Gazprom for $430
per thousand cubic meters of imported Russian natural gas.
Former Prime Minister Yulia Tymoshenko is serving a seven-
year prison sentencethe subject of a high-profile human
rights campaignas a result of that contract, signed after a
payment dispute between Russia and Ukraine over gas sup-
ply and transit left much of eastern Europe in the cold in the
first three weeks of 2009. Tymoshenko is charged with asking
Ukraines Naftogaz to commit to the exorbitant price while
market prices were relatively low.
In January, meanwhile, as Russias Vladmir Putin and his
Ukrainian counterpart Prime Minister Mykola Azarov failed to
3,500
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2,500
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2010 2015 2020 2025 2030 2035
W. Europe
U.S.
Southeast
Asia
Mexico
India
Former
Soviet
E. Europe
Central/S.
America
China
Canada
Australia
Africa
2040
1. Unconventional gas production to 2040. A recent re-
port from the European Commissions Joint Research Centre projects
that in a scenario most favorable to shale gas development, the U.S.
will capture the lions share (70%) of the worlds total unconventional
gas production by 2020. But U.S. shares will decline to 30% as East
Asian markets (and Chinas in particular) see a surge in production after
that. Other regions will see moderate but steady growth, and of the
worlds total production by 2040, Central/South America will produce
9%, Europe 8%, Africa 7%, and Canada 6%. Source: European Com-
mission Joint Research Centre
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and in production. Our highly skill ed technicians work to earn
your continued trust and conf idence one job at a time.
Satisf ying customer needs since 1973
True 24/7/365 availability
More than 100 worl dwide l ocations
3, 200+ trained and certif ied service specialists
Worl dwide stock of in-house service equipment
Bundl ed approach helps you realize cost savings
Improved productivity meets or exceeds your goals
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April 2013 10
THE BIG PICTURE: Subsidy Tug-of-War
Government decisions to subsidize renewable power to increase its capacity for environmental and security reasons have spurred
investments but also increased cross-border tensions. Increasingly, legal actions that seek to settle international trade disputes al-
lege unfair subsidization. Here are some of the major ongoing cases. Sources: POWER, International Centre for Trade and Sustainable
Development, World Trade Organization (WTO).
Copy and artwork by Sonal Patel, senior writer
FITs: EU, Japan, U.S. v. Canada
Canada in February appealed a December WTO dispute panel nding that
Ontarios local content requirements for renewables (which require up to
60% of project input to be sourced from the province) violate interna-
tional trade rules. Canada argues that resale of electricity through the FIT
program is not commercial in nature. Japan, the EU, and the U.S., which
joined the original dispute in September 2010, argue that this disadvan-
tages producers outside Ontario and amounts to an illegal subsidy.
Rare Earths: Japan, EU, U.S. v. China
A WTO panel is reviewing allegations by the complainants that
Chinas export restrictions on 17 rare earth metals raise domestic
production costs and hurt foreign manufacturers of components for
renewable power. China, which produces 90% of the worlds rare
earths supplies, argues that the measures are necessary to limit
environmental damage and conserve natural resources.
Solar: U.S. v. India
In a February 2013 WTO ling, the U.S. alleged that Indias local content requirement
in its 2010-launched Jawaharlal Nehru National Solar Mission discriminates against
foreign solar equipment manufacturers. India, which is building 2 GW of new solar,
says the domestic content provision applies only to projects totaling 350 MW.
Solar: U.S., EU v. China
The EU last September began investigating whether Chinese solar panel
exports are being dumped or sold below market value. China rebuffed
the charges. The EU in February also launched probes into whether solar
glass imports are being dumped in the European market. After it deter-
mined that Chinese producers and exporters had been dumping crystalline
silicon PV cells and modules in the U.S., the U.S. Commerce Department
in October slapped on nal anti-dumping duties of up to 250%.
Solar: China v. EU, U.S., South Korea
Between July and November 2012, China launched separate anti-
dumping and countervailing duty investigations over solar polysilicon
component exports from the EU, U.S., and South Korea. In May last
year, it also launched a WTO dispute settlement proceeding, arguing
that U.S. countervailing duties affecting $7.3 billion of Chinese solar
panel exports to the U.S. violate WTO law.
FITs, Solar, Wind, Hydro: China v. EU, U.S.
A Chinese-led WTO complaint in November 2012 alleges EU local content
requirements under feed-in-tariffs (FITs) hurt interests of Chinese solar
component producers. In May, China concluded that U.S. support for six
wind, solar, and hydro technologies in ve states violated WTO rules.
Wind: U.S. v. China, Vietnam
The U.S. Commerce Department in December determined nal anti-
dumping and countervailing duties on utility-scale wind tower imports
from China and Vietnam of between 34.3% and 60%.
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April 2013 12
reach an agreement to bring down the prices Ukraine pays
for Russian gas, Moscow and Kiev were embroiled in a fresh
gas dispute. Gazprom billed Naftogas $6.77 billion under a
take-or-pay clause of the 2009 agreement that Ukraine has
to disburse, even if it does not import gas. In 2012, Ukraine
bought 32.9 bcm of Russian gas, while the deal stipulated it
should have imported a minimum of 42 bcm.
Ukrainian officials lauded the regional councils decision
to approve development of the shale gas field in January,
saying its annual production could exceed 20 bcm and lower
gas prices within five or six years while boosting the coun-
trys energy independence from Russia. The country is also
looking to develop the Olesska gas field in the western part
of the country but has yet to make a production-sharing
agreementlikely with Chevronofficial.
UK Lifts Shale Gas Ban
Last December, nearly a year and a half after the UK halted
unconventional shale gas exploration when a project near
Blackpool set off tremors, Energy and Climate Change Secre-
tary Edward Davey approved shale gas fracking. The approval
means shale gas developers can resume fracking but will op-
erate under more stringent rules, including more in-depth
assessments for seismic risks.
The UK is facing a massive power shortfall if it cannot find
new capacity to replace about 21 GW that is set to be phased
out by 2030 due to age and EU pollution rules. Highlighting
the countrys energy dilemma are its dwindling conventional
natural gas reserves that have forced it to become a net
importer. Though the government estimates that the UKs
onshore shale gas reserves hover at 150 bcm, only one shale
gas firm, Cuadrilla Resources, has an exploration license.
However, the government has called for the creation of a
new office to simplify regulation and offer tax incentives to
sprout a working shale gas industry.
Bulgarian PM Quits Over Power
Price Protests
Protests in more than 20 cities by tens of thousands of Bul-
garians over January electricity bills that averaged more
than 100 ($130) forced the countrys prime minister, Boyko
Borissov, and his center-right government to resign in mid-
February.
Bulgarians, who have the lowest average salary in the Eu-
ropean Union (EU)about 387 ($504) a monthreportedly
accused three foreign-owned energy companies of what they
said were unreasonably high electricity bills. Brushing aside
government platitudes that January was an exceptionally
frigid month, they showed outrage at reports that the com-
panies pulled in windfall profits. According to some media
reports, Bulgarians alleged corruption among Czech firms CEZ
and Energo-Pro and Austrias EVN and the government. The
three firms control the countrys power distribution market,
which was divided into three regions when the country priva-
tized its network a decade ago.
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the
company
torque gun
tm
The European Commission (EC) in January had referred
Bulgariawhich joined the EU in 2007 but has been criti-
cized for shortcomings that remain regarding corruption and
organized crimeto the European Court of Justice for failing
to fully abide by EU energy market rules.
An EU country report published last year finds two issues
with Bulgarias recent power sector reforms. First, liberaliza-
tion of the nations wholesale market is incomplete. There
are quotas, there is a dominant player and there are no free
prices, Marlene Holzner, spokesperson for EU Energy Com-
missioner Gnther Oettinger told the EUs web-based media
portal Euractiv in February. Second, despite recommenda-
tions by the EC, the countrys electricity regulator is not
independent. In Bulgaria there were regulated prices for
small and medium enterprises and also for end users. The
Commissions position was that Bulgaria should have market
prices, but also regulated prices for very vulnerable consum-
ers, it said.
Former Prime Minister Borissov had sought to quell the
chaotic protests in February by announcing Czech utility CEZ
would be stripped of its license. Though this failed to diffuse
public tensions and calm protests, he also pledged to cut
power prices by 8% starting March 1. Czech Prime Minister
Petr Necas, meanwhile, reacted to Borissovs statements by
urging the country to keep its international obligations un-
der European law, including those regarding foreign invest-
ment protection.
Bulgarian President Rosen Plevneliev called for an early
election on May 12 to reduce the fallout from the political
crisis that he said could undermine the countrys economic
stability.
Sonal Patel is POWERs senior writer. Look for more
Global Monitor stories associated with this issue online at
www.powermag.com.
2. A power protest. Mass protests by Bulgarians over surging
January electricity bills forced the prime minister, Boyko Borissov, and
his center-right government to resign in mid-February. Bulgarians al-
lege corruption between the government and three utilities that control
the distribution network. Courtesy: Blisses
|
April 2013 14
Battling White Rust
Does your power plant use a chiller for combustion turbine in-
let air cooling or other processes that reject heat? If so, there
is a good chance you also have an auxiliary cooling tower
(Figure 1) or a wet surface air cooler (WSAC, Figure 2) to cool
these systems. (See POWER, September 2008, Wet Surface
Air Coolers Minimize Water Use by Maximizing Heat Transfer
Efficiency.) Galvanized steel has been commonly used in the
construction of smaller, package-type cooling tower systems
because it is relatively inexpensive. These cooling towers are
popular in many different industries and will increase in use
in power applications.
Those of us who work in the water treatment industry are
familiar with the smaller, package-type cooling towers from
our experience in the food and beverage, institutional, and
manufacturing business units. These units are typically con-
structed using galvanized and stainless metallurgies. How-
ever, many in the power industry are only familiar with wood
or fiberglass-reinforced plastic (FRP) because these are the
materials most commonly used in the construction of field-
erected cooling towers at central station power plants.
A cooling water treatment program must consider not just
the galvanized, wood, or FRP but also all the materials that
the water will come into contact with throughout the plant,
such as titanium, stainless steel, and copper-based alloys
used in the condenser and possibly other balance-of-plant
heat exchangers.
The question of acceptable chloride levels in the bulk cool-
ing water always comes up anytime stainless steel alloys are
used. Typically, the engineering firm responsible for the plant
design will select appropriate materials and a water chemistry
program that ensure chloride levels in the cooling water are
kept at acceptable levels, depending on the grade of stain-
less. When stainless steel is used, developing an acceptable
water treatment program is straightforward.
Galvanized cooling towers are a much different story. Al-
though rare in the power industry, towers using galvanized
steel components are becoming more popular with the in-
creased use of chillers for inlet air-cooling combustion
turbines in combined cycle plants, as well as WSACs in the
air-cooled configuration.
In general, all cooling towers are very sensitive to wa-
ter chemistry, particularly chlorides, sulfates, and alkalinity.
These constituents are often overlooked when designing a
cooling water treatment program. (See POWER March 2013,
Selecting a Combined Cycle Water Chemistry Program and
September 2009, Avoid These 10 Mistakes When Selecting
Your New Water Treatment System.) Even so, using galva-
nized parts within a cooling tower makes the problem of wa-
ter treatment even more difficultthe water is tough on the
galvanized parts, and the power industry operates cooling
towers at much higher cycles of concentration than other
industries.
Finally, the propensity for white rust formation in galva-
nized systems is not very well known in the power industry.
The remainder of this article will define white rust, how it
is formed, its potential impacts on equipment integrity, and
how to control its formation.
Galvanized Steel and White Rust
Galvanized steel is carbon steel with a coating of zinc metal
on its surface. Either a hot-dip or electroplating process can
produce a zinc layer that is a protective surface coating as
well as a sacrificial anode. Because zinc is less noble than
carbon steel, it will corrode sacrificially to protect the under-
lying base metal. If the protective zinc layer should corrode
through, the base-layer steel will corrode at the same rate as
unprotected carbon steel. It is important to note that gal-
vanized steel will always have some small amount of general
corrosion occurring, just as with mild steel. The key is to
minimize those general corrosion rates while minimizing the
potential for localized corrosion.
When a galvanized steel system is operated under nonag-
gressive conditions such as a neutral pH and moderately hard
water, a protective layer of nonporous zinc carbonate and
zinc hydroxide forms to prevent further corrosion of the zinc
coating. However, if the system is operated under aggressive
conditions such as high pH, low hardness, or high chloride or
sulfate levels, rapid corrosion of the protective zinc layer can
occur. If the corrosion is severe, all the galvanized coating
2. Go with the flow. The co-current flow of air and water (both
flow downward) in a wet surface air cooler increases the systems heat
transfer efficiency. Courtesy: Nalco Power ITC
1. Cool breeze. This is a typical auxiliary evaporative cooling tower.
Courtesy: Nalco Power ITC
Mechanicals:P35299_EML_I01_V2.indd
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April 2013
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will be removed, exposing the unprotected steel, producing
the familiar rusty-brown or black appearance. In less-severe
cases, the zinc coating can be corroded to form what is known
as white rust (Figure 3).
Both the protective oxide film and white rust are forms of
zinc carbonate and zinc hydroxide. The difference between
the two is the rate of formation and the density of the layer.
Rapid formation of an oxide film produces a porous deposit
that allows continued corrosion of the nonpassive surface, if
left unchecked. A slower formation of the zinc layer provides
a nonporous, protective layer.
A common misconception is that once the layer of white
rust has formed, no further corrosion can take place. Not only
is this not true, but the corrosion byproduct also can create
an oxygen concentration cell, creating an accelerated local-
ized corrosion reaction. This situation is further complicated
with the addition of high levels of sulfates and chlorides.
As stated in the Nalco Guide to Cooling Water System Failure
Analysis (1993), Once the zinc layer is breached, the un-
derlying steel becomes susceptible to attack and is severely
wasted locally (Chapter 5, p. 108). The reference book also
notes: On galvanized steel, tubercles may develop rapidly at
breaches in the zinc layer. Attack is frequently highly local-
ized if aggressive ions such as chloride or sulfate concentrate
beneath deposits (Chapter 4, p. 72).
White rust has a porous, soft, gelatinous, or waxy appear-
ance and is relatively easy to identify. The galvanized zinc
coating can be severely damaged when white rust is formed,
which in turn can shorten the life of the cooling tower. Also,
because white rust formation can be highly localized, once
the zinc layer has been consumed, corrosion of the mild steel
may progress rapidly, as with any penetration of a metal coat-
ing. White rust is typically caused when operating outside of
the typical guidelines for the cooling water pH and alkalinity.
3. Corrosion begins. White rust on a galvanized panel is caused
when the protective zinc coating is attacked. When the galvanized sur-
face is penetrated, the steel base metal will begin to corrode. Cour-
tesy: Nalco Power ITC
www. RETECH2013.com
RETECH i s an unpar al l el ed oppor t uni t y t o connect wi t h ot her manuf act ur i ng
and suppl i er peer s, i ndust r y exper t s, and i nf l uent i al l eader s as t hey share
i nsi ght s on renewabl e ener gy and what t he next year hol ds f or t he i ndust r y.
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April 2013 18
However, many cases of white rust have been attributed to
improper passivation of a new or newly cleaned system, which
is typically caused by compressed commissioning schedules
and short-circuited cleaning steps.
White rust can quickly become a very costly problem. Not
only does it cause heat exchanger degradation across the
tube bundle during normal operation, but also cleaning and
remediating a system with white rust can be a costly ven-
ture. Remediation typically requires mechanical brushing of
the affected area, painting with an aluminum paint or epoxy
coating, followed by a repassivation of the system. These
steps may need to be repeated, depending on the severity
of the white rust (BAC Technical Resource Document - RLD
10699/2010).
Preventing White Rust Formation
A better strategy for battling white rust is to take steps to pre-
vent its formation in the first place. There are five preventive
steps you should consider.
Choose a Different Metallurgy. The obvious first option
would be to select a different alloyone chosen specifically
with the makeup water chemistry in mind. As more plants
become reliant upon relatively aggressive makeup water from
nonstandard sources such as high-conductivity well waters
and municipal gray waters, the use of galvanized steel for
cooling tower construction should start to diminish. How-
ever, one of the attractions to using galvanized steel towers
is the often lower first cost, which may drive the purchase
decision. If that is your situation, then other solutions must
be explored.
Operate Under Manufacturers Guidelines. Though not
popular in the power industry, galvanized cooling systems
have been used extensively in other industries with very good
success. The difference between success and failure can be
as simple as following the manufacturers guidelines. Our ex-
perience has been that when users follow the manufacturers
guidelines to the letter, they tend to not have white rust
formation on their galvanized towers. However, those who
deviate from the guidelines tend to suffer with either white
rust in the wetted areas or sulfate and chloride attack in the
wet-dry areas. This is particularly true of those users who
operate with very high cycles of concentration.
Those in the power industry often overlook the fact that
these package cooling towers tend to have a greater per-
centage of drift than field-erected cooling towers. When drift
occurs in galvanized systems, the evaporated salts can ac-
cumulate on the external structure and attack the galvanized
surfaces. The tube-bundle will appear very well protected, but
the structure of the cooling tower is deteriorating.
Discovering the acceptable chemistry limits for white rust
prevention can be a bit complicated. As Table 1 shows, the
Cooling Tower Institute guidelines have a much higher limit
for sulfates and chlorides than the three leading manufactur-
ers of galvanized cooling towers (Table 2). Following the con-
servative, manufacturer guideline for your particular tower is
the most prudent approach.
Complicating the decision, however, is the presence of two
competing pH guidelines: operating pH for the passivation
process as well as the manufacturers recommended operat-
ing pH for routine service (Table 2). The former guideline
is important for two reasons. First, the initial passivation
process seasons the galvanized steel, making it ready for
normal service. The initial passivation is designed to allow
for slow formation of the protective layer. Second, the passi-
vation process can and should be repeated periodically if the
tower is operated outside the manufacturers guidelines dur-
ing normal operation. This is not to say the normal operating
chemistry can be significantly outside the guidelines and
still be reconditioned. Reconditioning does not restore the
lost galvanized surface when severe damage to the zinc coat-
ing has occurred. Frequent visual inspection is recommended
to ensure damage to the zinc coating caused by white rust
formation is not taking place.
Coat the Galvanized Steel. If galvanized steel is to be
used with an aggressive water treatment program, then coat-
ing the metallurgy may be an option to consider. For instance,
BAC uses Baltibond, a special hybrid polymer that is imperme-
able to fluids. This material is applied by electrostatic spray
to G-235 (Z700 metric) hot-dip galvanized steel surfaces. The
initial and periodic seasoning of the system is not needed
when this coating is applied. Although the coating will pro-
tect the structural surfaces, hot-dip galvanized coils must
use the water quality guidelines for galvanized steel units,
Parameter Range
pH 7.08.0
Chloride as Cl
-
<450 ppm
Sulfates as SO
4
2-
<1,200 ppm
Alkalinity as CaCO
3
50300 ppm
Hardness as CaCO
3
>50 ppm
Table 1. Typical cooling tower chemistry guidelines.
Source: Cooling Tower Institute
Parameter BAC Evapco Marley
Reference Operating manual Engineering
bulletin 036A
Manual 92-114B
Passivation
duration
4 to 8 weeks 4 to 12 weeks Minimum of 8
weeks
pH during
passivation
>7.0 to <8.2 >7.0 to <8.0 >6.5 to <8.0
pH for routine
service
6.5 to 9.0
suggested
>6.0 to <9.0 None found
Hardness as
CaCO
3
>30 ppm >50ppm 100 to 300 ppm
Alkalinity as
CaCO
3
<500 ppm <300 ppm 100 to 300 ppm
Chlorides as Cl
-
<250 ppm <250 ppm None found
Sulfates as SO
4
2-
<250ppm <250 ppm None found
Conductivity <2,400 microS <2,400 microS None found
Chlorine as free
Cl
2
<1.0 ppm as a
routine
<0.5 ppm as a
routine
None found
Comments BAC offers
removal and
treatment
recommendations
for white rust
Critical to have a
passivation plan
and assigned
responsibility prior
to startup
Chromate rinse
used for heavy
mill galvanized
steel sheet
Table 2. Galvanized cooling tower chemistry guide-
lines. Source: White Rust PreventionAn Industry Update and Guide
(2012), Association of Water Technologies
Check out the new POWER iPad app!
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05_PWR_040113_OM_p14-21.indd 19 3/13/13 1:36:47 PM
|
April 2013 20
according to BAC Series V operating and maintenance instruc-
tions. In other words, the coating may prevent white rust
formation on structural surfaces, but it will not prevent cor-
rosion of the tube bundle. Therefore, the chemistry guidelines
in Table 3 must still be followed.
Use Chemical Corrosion Inhibition. Until recently, there
have been no water chemistry offerings to inhibit the forma-
tion of white rust. However, Nalco researchers have devel-
oped a chemical program that has proven to provide good
protection for galvanized steel systems. Nalco 73801WR is
a synergistic blend of passivation agents that can minimize
white rust corrosion. Because NALCO 73801WR is specifically
intended to inhibit white rust formation, it is designed to
supplement other treatment programs such as mild steel cor-
rosion inhibition and scale inhibition (Figure 4).
The corrosion rates for galvanized systems dropped signifi-
cantly, from 0.75 mils per year (mpy) to 0.1 mpy after the ini-
tial feed of Nalco 73801WR on a test cooling tower. Although
the corrosion rate rises and levels off at 0.25 mpy, that still
translates into a 67% reduction in corrosion rate.
Another example involves a plant using a makeup water
source high in conductivity, alkalinity, sulfates, and chlo-
ride, while operating at relatively high cycles of concen-
tration for a galvanized cooling tower. This tower is also
experiencing promising results using Nalco 73801WR (Table
4). This is a fairly new trial, so corrosion rates are not avail-
able yet. However, photos show excellent protection of the
system (Figure 5).
Determine the Dose Rate. The typical dose rate for Nalco
73801WR is 50 ppm. However, halogen use rates and water
conditions may dictate higher dose rates. Because there is
no Trasar component in this chemistry, the additive dose rate
must be slaved to the other chemicals used in the program.
The efficacy of the program will be, as with any corro-
sion-inhibition program, determined by monitoring corrosion
rates. Monitoring for corrosion rates can be achieved via the
following methods:
Galvanized steel corrators measure current flow across two
identical electrodes to which a small current is applied and
measured. From the current flow, corrosion rates can be
calculated and displayed online, from which trend lines can
also be produced.
Galvanized coupons of the same metallurgy can be used to
produce absolute corrosion rates and the most accurate mea-
surement of metal loss.
Visual inspections may be subjective, but frequent inspections
can prove to be very valuable in identifying problems before
they become severe.
Zinc coating testing is critical, as the coating is what you
are protecting. Trend data collection is also important to
help determine if the zinc coating is leaching into the sys-
tem. A baseline should be developed for zinc levels in the
system prior to introducing the program. Once the program
is established, zinc levels should decrease if the program is
working effectively.
Increased awareness of the potential pitfalls of using gal-
vanized components in cooling towers is needed in the power
industry. Though it is relatively inexpensive when compared
to stainless steel, galvanized steel demands a certain dili-
gence when developing a cooling water treatment program.
Specifically, end users need to be aware of the makeup water
source and the desired cycles of concentration in the cooling
tower. Only then can they make an informed decision about
a comprehensive water treatment regimen, including a corro-
sion inhibition plan, prior to startup.
Kevin Boudreaux (kjboudreaux@nalco.com) is a power indus-
try technical consultant for Nalco Co.s Power Group.
1.2
1.1
1.0
0.9
0.8
0.7
0.6
0.5
0.4
0.3
0.2
0.1
0
11/4/2010 12/5/2010 1/5/2011 2/5/2011 3/8/2011 4/8/2011
G
a
l
v
a
n
i
z
e
d

s
t
e
e
l

p
r
o
b
e

(
m
p
y
)
4. Good results. The initial test results of Nalco 73801WR have
been excellent. This figure shows the results of a trial performed in a
power plant closed-loop system. Source: Nalco Power ITC
Parameter Makeup source Circulating water Guideline
pH 8.7 9.3 6.5 to 9.0
Hardness as CaCO
3
4.6 39 >30 ppm
Alkalinity as CaCO
3
210 1,000 <500 ppm
Chlorides as Cl
-
120 460 <250 ppm
Sulfates as SO
4
2-
110 390 <250 ppm
Conductivity 1,000 4,000 <2,400 micromhos
Table 4. The chemistry of the makeup water and
cooling tower bulk water are compared with the As-
sociation of Water Technologies guidelines summa-
rized in Table 2. Source: AWT, Nalco Power ITC
5. Tube protection. Surface corrosion on galvanized tubes was
prevented during recent testing. Courtesy: Nalco Power ITC
Parameter Baltibond Galvanized steel
pH 6.5 to 9.0 7.0 to 9.0
Hardness as CaCO
3
30500 ppm 30500 ppm
Alkalinity as CaCO
3
500 ppm max 500 ppm max
Total dissolved solids 1,200 ppm max 1,000 ppm max
Chloride as Cl
-
250 ppm max 250 ppm max
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|
April 2013 22
Jeffrey P. Gray Vidhya Prabhakaran
Filling the Hole in
Californias Capacity
Procurement Plan
By Jeffrey P. Gray and Vidhya Prabhakaran
I
n February, the California Public Utilities Commission (CPUC) yet
again missed an important opportunity to correct structural flaws
that have plagued the states wholesale generation market in the
wake of the 2001 energy crisis. The CPUC authorized the procure-
ment of as much as 2,100 MW of new resources, without taking steps
to ensure that market structures are in place to appropriately value
and compensate existing generation resources. Absent fixing current
long-term procurement planning and resource adequacy policies, Cal-
ifornia risks stranding existing resources, while saddling consumers
with more costly long-term commitments for new resources that may
be subsequently rendered less valuable by changed circumstances.
A Hole in the Market
Generation capacity in California has traditionally been assessed
generically, without regard to specific operational flexibility or
attributes. Capacity procurement has been analyzed from the
perspectives of planning reserve margins and resource adequacy.
These objectives were understandable responses in the aftermath
of Californias energy crisis when steel in the ground was of para-
mount importance. However, more than 10 years later, these crite-
ria are ill equipped to address fundamental changes resulting from
the influx of large amounts of intermittent renewable resources.
Today, grid operators should be leveraging the existing gas-fired
generation fleet to help integrate renewables. However, the market
structure necessary to encourage investment in maintenance activities
and operational improvements does not exist. On the contrary, com-
pensation available from the limited markets currently available to
noncommitted existing resources, such as the market for energy, has
been declining. Prices for such energy are expected to drop further as
regulators approve the procurement of new resources and more renew-
able resources come online to meet renewable procurement goals.
The adverse impacts from declining market revenues are fur-
ther exacerbated by the fact that existing generation resources
are excluded from participating in long-term resource solicita-
tions under the CPUCs current procurement policies. The Brattle
Group recently found that the compensation available to new
resources in California resource solicitations exceeds the com-
pensation available to existing resources by multiples of five
to ten. This combination makes revenue streams available to
existing resources both insufficient and unpredictable on a year-
to-year basis. These market and price uncertainties discourage
investment in efficiency and flexibility upgrades that could more
cost-effectively increase the amount of capacity with enhanced
flexibility attributes available to grid operators.
CPUC Commissioner Mark Ferron describes the phenomena as a
hole in the market: There are insufficient economic incentives
for [existing] generating plants which provide useful flexible at-
tributes to cover the cost of maintaining these plant[s] in opera-
tion. Under these circumstances, the disparate treatment of new
and existing generating resources leads to inefficient procurement
and undermines least-cost/best-fit procurement objectives.
Use Multiyear Forward Procurement
Procurement policies that unnecessarily differentiate between new and
existing resources must be changed to incorporate nondiscriminatory
practices that advance competition across resource type. Competition
between new and existing resources will provide more revenue certain-
ty and better identify the ability of the existing fleet to cost-effectively
meet integration requirements relative to new resources. For example,
the most economically efficient solution to provide for an incremental
system need may be a relatively inexpensive upgrade to an existing
generating resource, as opposed to the major investment required for a
new resource. However, markets must be open to competition to allow
for the most economically efficient (whether it be an existing or new)
resource to be selected. This competition can occur several ways, such
as through a centralized forward capacity market, but it must include
an explicit multiyear forward procurement requirement.
In general, a multiyear forward procurement requirement should
better ensure the retention of cost-effective existing resources to
satisfy future reliability requirements. For instance, a centralized for-
ward capacity market levels the competitive playing field among all
suppliers. In such a market, suppliers bid to provide exactly the same
product over a defined time period. As a result, the risks buyers typi-
cally bear because of the difficulty in accurately comparing the value
of offers of different terms (for example, a three-year versus a 10-year
term) are substantially reduced.
A centralized forward capacity market would also increase pro-
curement efficiency, particularly as system needs become more
defined and differentiated by specific operating characteristics.
Procuring a portfolio of capacity that meets defined flexibility
requirements for the whole system should be less costly than
having each individual load-serving entity procure a portfolio of
capacity that meets its share of system flexibility requirements.
Address Procurement Comprehensively
When compensation from the markets is insufficient and/or un-
certain to ensure recovery of going-forward costsincluding in-
vestments in operational improvementsprocurement efficiency
decreases, commodity cost increases, and reliability is put at
risk. In other words, everyone loses.
Forward capacity markets are not novel concepts. They are
standard practice in major eastern U.S. power markets, such as
PJM. The CPUC itself has acknowledged that a forward procure-
ment obligation is a regulatory tool that could potentially benefit
reliability and reduce costs. To date, however, the CPUC has failed
to adopt such a requirement. Instead, it has continued to autho-
rize the procurement of new resources without accounting for the
broader market implications. California can no longer afford this
one-dimensional (new is good) planning, and the CPUC must start
addressing procurement on a more comprehensive basis.
Jeffrey P. Gray (jeffgray@dwt.com) is a partner and Vidhya
Prabhakaran (vidhyaprabhakaran@dwt.com) is an associate in
Davis Wright Tremaines Energy Practice Group.
|
April 2013 24
COAL PLANT OPERATIONS
TVAs Paradise Unit 2 Sets New
Continuous Operations Record
T
ennessee Valley Authoritys (TVA)
Paradise Fossil Plant, the largest
power plant in Kentucky, is located in
the western part of the state on the Green
River, near what was once the village of
Paradise. The three hyperbolic cooling
towers, lined up in a row southwest of the
plant, dwarf the remainder of the plant
structures and are local landmarks. May
19, 2013, marks the 50th anniversary of
the commercial operation of the first unit.
The plant has three coal-fired cyclone
furnace generating units with a total sum-
mer net capacity of 2,201 MW. Construc-
tion on the plant began in 1959, and the
first two units entered commercial ser-
vice in 1963. Those two 700-MW units
are subcritical designs. The third unit is a
cyclone furnace supercritical unit rated at
1,150 MW, added in 1970.
When started up in 1963, Units 1 and 2
were the first 700-MW cyclone furnace
equipped units built in the U.S. In 1985 a
barge-unloading facility added fuel flexi-
bility by allowing coal deliveries via train,
truck, or barge. The plant has an insatiable
appetite for fuel, consuming about 22,000
tons of Illinois basin coal a day.
TVA has spent more than $5 billion on
emissions controls upgrades at its fossil
plants, mostly within the past 15 years.
Paradise Fossil Plant was an early benefi-
ciary of that investment. In 2002, Paradise
Unit 2 was the first of TVAs fossil fleet to
be retrofitted with selective catalytic re-
duction (SCR) and overfire air; the other
two units followed within two years. The
reduction of nitrous oxides (NO
x
) from the
plant has been profound. In 1974, all three
units released about 110,000 tons of NO
x
.
In 2011, the NO
x
released was reduced to
10,150 tons, a drop of over 90%. Unit 3 is
also equipped with electrostatic precipita-
tors to control small particle emissions.
Venturi-type limestone slurry wet flue
gas desulfurization (wet FGD) systems
were added to Units 1 and 2 in 1983. Unit
3 was upgraded with a wet FGD system in
2006 that is capable of removing 98% of
the sulfur dioxide (SO
2
) from the entering
flue gas. The overall result of these up-
grades has been significantly reduced SO
2

emissions, down from 481,000 tons in
1974 to 37,700 tons in 2011a plantwide
reduction of over 92%. In 2009, TVA add-
ed hydrated lime injection prior to the wet
FGD at all three units to improve SO
3
re-
moval. Further upgrade of the Unit 1 and
2 wet FGDs was completed in early 2012
as part of TVAs plan to become one of
Paradise Fossil Plant Unit 2s record-setting performance of 259+ days of con-
tinuous operation for a cyclone-fired boiler is attributed to excellence in plant
operations and maintenance processes, a diligent and well-trained staff, and
leadership that places high value on both. The Paradise experience proves that
plants cant help getting older, but they dont have to get old.
Courtesy: TVA
By Dr. Robert Peltier, PE
April 2013
|
the nations leading suppliers of cleaner
energy by 2020.
Record-Setting Performance
The long-run record for cyclone-fired
boilers259 days, 16 hours, and 40
minutesnow belongs to Paradise Unit
2. That eclipses the previous record held
since 1993 by Paradise Unit 1: 255 days, 8
hours, and 50 minutes. Astute readers will
recall a similar record-setting performance
of TVAs Shawnee Fossil Plant Unit 6 (see
the February 2008 issue in our archives at
www.powermag.com). That long-run re-
cord of 1,093+ days was for a pulverized
coal boiler. The Shawnee and Paradise
boilers were both supplied by Babcock &
Wilcox, but the similarity between the boil-
ers ends there (see the sidebar, Cyclone
Furnaces Are Unique).
It is a great distinction to surpass any
industry record such as this, said Dennis
Spencer, vice president of Coal Operations.
It makes me even more proud when the
world record we break is a record held by
another TVA unit. It demonstrates what we
all knowour employees have the capabil-
ity, willingness, and passion to accomplish
great things.
The record run began May 1, 2012, and
ended Jan. 16, 2013, at 8:26 a.m., when
Unit 2 came offline for a planned mainte-
nance outage (Figure 1).
Current Operations Are Tougher
The new long-run record has added sig-
nificance when the increased complexities
and additional equipment found in todays
plant are considered. And dont forget that
the plant is now operated and maintained
by a less-experienced but better-trained
staff than in 1993.
Twenty years ago, only Units 1 and 2
were equipped with mature wet FGD sys-
tems but no SCR system. The wet FGD and
SCR systems can be tricky to operate; a
poor batch of fuel can cause plugging of
the SCR, and the wet FGD must maintain
its chemistry and has many moving parts.
Both devices can be problematic during
normal plant operation and are often the
cause of plant outages and reductions in
plant availability. Unit 2s run includes the
added complexities of operating a 20-year-
old wet FGD system and its new SCR sys-
tem and ammonia grid, not to mention the
unit has aged another 20 years, particularly
the cyclones.
Staff today also operate a unit that is
much less forgiving and has much less
room for operator error. For example, Unit
2 now operates with reduced margin in its
induced draft fans with the SCR addition,
particularly during load swings. Also, the
SCR has an ammonia grid that demands
routine attention, and combustion has to
be spot on to minimize excess dust that
will accumulate in the ductwork, perhaps
causing an outage. Since 1993, the control
system has also been upgraded from its
original analog configuration to a modern
digital control system, which is capable of
maintaining tighter control of plant opera-
tions (Figure 2).
The experience profile of the typical
plant operator has noticeably changed
since 1993. Billy Sabin, Paradise assistant
plant manager, estimated that assistant
unit operators averaged 15 to 20 years of
experience and control room operators 20
to 25 years during the plants 1993 record
run. Since that time, operator retirements
have provided an opportunity for a new
generation to take control of the plant. To-
day there are 398 employees on site, and
five years is the average experience level
for plant operators. In fact, shift supervi-
sors, usually promoted from the ranks of
control room operators, now average less
than three years' experience as supervi-
sors with TVA. Paradise has added nine
new shift supervisors over the past year
and a half.
Today, plant operators and maintain-
ers do enjoy one significant advantage:
training. The past generation of operators
1. Dedicated to success. Plant Man-
ager Scott Fallacker (left) and Assistant Plant
Manager Billy Sabin lead the 398 staff mem-
bers at Paradise. Courtesy: TVA
2. Tighter control. Digital control upgrades provided better tools for managing plant opera-
tions. This photo was taken during a recent plant outage. Courtesy: TVA
Today there are 398
employees on site,
and five years is
the average experi-
ence level for plant
operators.
|
April 2013 26
Cyclone Furnaces Are Unique
The Paradise Fossil Plant Unit 2s new
long-run record has added significance for
those familiar with the peculiarities of the
cyclone furnace. There are 109 Babcock
& Wilcox Co. (B&W) cyclone-fired boilers
in service in the U.S.; 98 are subcritical
and 11 are supercritical, including Paradise
Unit 3. This number represents perhaps 6%
of all utility-owned units. TVA owns a total
of five subcritical cyclone-fire units: the
two units at Paradise and three at the Al-
len Fossil Plant.
The cyclone furnace was developed
by B&W to combust coal fuels that were
not compatible with pulverized coal (PC)
combustion. The weightiest difference be-
tween the two coals is the ash fusion or
melting temperature. Coals with a low ash
fusion temperature easily form slag that is
then carried through the remainder of the
furnace, often sticking to the superheater
tubes when burned in a PC furnace. The
cyclone furnace, normally smaller than the
equivalent PC furnace, was designed to
handle coals with a low ash fusion tem-
perature (Figure 3).
The cyclone furnace is water-cooled
and attached to the side of the boiler fur-
nace. To give perspective on the size of
the cyclone furnace, Paradise Units 1 and
2 each have 14 of the 10-foot-diameter cy-
clonesseven each on the front and back
wall of the furnace. Steam is produced at
2,450 psia and 1,003F.
The PC boiler burns fuel that has been
dried and ground to the consistency of tal-
cum powder, usually around 74 microns,
and it burns without difficulty when mixed
with the turbulent combustion air in the
furnace. The cyclone furnace burns larger
crushed coal particles (nominal 0.187 in
or 4.75 mm, depending on the fuel). These
particles are too large to be burned in sus-
pension, as occurs in the PC furnace, and
would just be carried through the furnace
before complete combustion could occur.
According to B&Ws Steam 41st Edition,
The large particles must be retained in
place with the air passing over the particle
(air scrubbing) for complete combustion
to occur. The cyclone furnace accomplishes
this by forming a molten sticky slag layer
that captures and holds the heavier parti-
cles. While the large particles are trapped
in the slag layer, the volatiles and fine
coal particles burn in suspension, provid-
ing the intense radiant heat required for
slag layer combustion. Ideally, all of the
large coal particles become trapped in the
molten slag, where they complete carbon
burnout, leaving behind ash to replenish
the slag layer.
Within its first year of commercial op-
eration, each unit equipped with cyclones
began experiencing failures of cyclone wa-
terwall tubes. According to TVA, by 1972
most of the crotch tubes, reentrant throat
tubes, wrapper tubes, and face tubes had
been replaced at least once. A manpower-
intensive program of frequent, proactive
tube replacements continued through
1982. During this period, the Unit 1 and
2 forced outage rate (FOR) grew from just
under 20% in 1964 to a peak of approxi-
mately 42% in 1979 (20.5% attributable
to a steam turbine failure), dropping back
down to about 20% in 1982. The overall
FOR trend was unacceptably high, about
20% for almost 20 years, with about three-
quarters of the FOR caused by cyclone fur-
nace problems. In 1982, 10 forced outages
were attributed to cyclones.
TVA elected to replace all cyclones in a
single scheduled outage, incorporating ad-
vances in materials to solve problems cre-
ated by corrosion and erosion of materials
based on fleetwide lessons learned by B&W.
Perhaps the two most prevalent problems
were the corrosive iron sulfide attack on
pressure part tubing and erosion in areas
opposite the secondary air throat, where a
protective slag coating cant form.
Further upgrades to the cyclone fur-
naces were made to reduce NO
x
production,
in conjunction with the selective catalytic
reduction (SCR) system installation. The
cyclones were updated with air staging
to reduce NO
x
formation within the burner
zone by reducing the oxygen present. The
reburning or air-staging retrofit produced
NO
x
reduction up to 80%. Air staging con-
trols the amount of primary air sent to each
cyclone and the overfire air port located
higher on the furnace wall; about 80% of
the combustion air goes to the cyclone lo-
cated in the sub-stoichiometric (lower) re-
gion of the furnace and 20% to the overfire
air port located in the burnout zone locat-
ed high in the furnace. With this design,
an acceptable residence time is possible
in the burnout zone to complete combus-
tion of the fuel. The downside of using air
staging is the reducing atmosphere formed
in the lower regions of the furnace, which
often accelerates tube corrosion and flyash
production.
The cyclone design doesnt lend itself
well to rapid load cycling. However, Units
1 and 2 are capable of operating at reduced
load, down to 400 MW to 450 MW, and Unit
3 can operate down to 650 MW. The mini-
mum flue gas temperature entering the SCR
determines the low-load limit.
3. Capable combustor. The cyclone furnace provides a means to fire lower-quality
fuels, such as low-volatile bituminous coals and lignite. Shown is a cutaway drawing of a typi-
cal cyclone (left) and a photo of an original cyclone from Unit 3 (right). Courtesy: Babcock &
Wilcox Co., TVA
Gas burners Secondary air
Coal deslagging
oil burner
Crushed
coal inlet
Tertiary air
Primary air
Radical burner
Main oil burner
Replaceable
wear liners
Re-entrant
throat
Slag tap opening
April 2013
|
spent some time in the classroom learning
fundamentals but largely focused on more
ad hoc hands-on trainingteam up with a
more senior person to show you the ropes.
Today, there is a much more holistic train-
ing philosophy for the entire staff. On-
the-job training remains very important
but is now conducted as part of an array
of human performancefocused training
that extends over the employees career.
For example, operators attend refresher
training programs every quarter, and hu-
man performance reviews are regularly
conducted to sharpen job skills.
Plants dont operate and maintain
themselves, so progressive utilities, such
as TVA, recognize that people are their
number one asset. As Sabin noted, its the
behind-the-scenes work of many people
that keeps Paradise running with high re-
liability. He also credits the involvement
of all employees in important decision-
making, from job design to plant outage
planning. Sabin describes the process us-
ing the mnemonic 4Es: Engage staff in de-
cision-making; Empower staff to do their
jobs with the right training and equipment;
Encourage staff to accept only operational
excellence in all that they do; Energize
the staff by offering opportunities for
personal growth and the plants culture.
When this approach is implemented well,
as demonstrated by the recent Unit 2 long-
run records, remarkable accomplishments
are possible (Figures 4 and 5).
This level of performance cannot be
achieved without the proper oversight
and critical decisions from our corporate
partners, as well as site employees, said
Sabin when interviewed by POWER af-
ter Unit 2s record run was announced.
Countless hours making sure these units
stay online means fixing the right things,
prioritizing the right work, and attention
to detail when it comes to planning. We
cant allow ourselves to become compla-
cent, and daily activities cannot be consid-
ered routine. That attention to detail can
be the difference between a unit staying
online and coming off.
More Records Fall
According to Sabin, Paradise broke sev-
eral other long-run records during FY12:
a simultaneous Unit 1 and 2 record run
at 137+ days set on Nov. 4, 2011; a prior
Unit 2 long-run record of 216+ days set
on Jan. 7, 2012; and Unit 3s third-longest
run at 130+ days set on Apr. 10, 2012. The
equipment is obviously running better than
at any time in the past.
Operating records are important, but
safety comes first at Paradise. During
FY12, Paradise experienced its best ever
Occupational Safety and Health Adminis-
tration recordable injury rate of a minus-
cule 0.23a single injury away from a
perfect record.
Paradise employees should feel proud,
Sabin said. Its one thing to accomplish
a world record, but when we look back at
the year weve had, its obvious that they
have worked very hard, day in and day out,
to continuously improve our performance
and do our part to keep injury rates low for
the people of the Tennessee Valley Author-
ity. I cant say thank you enough for all the
work they do.
Our congratulations to the staff of TVAs
Paradise Fossil Plant for demonstrating that
operational excellence rests largely with staff
quality rather than equipment vintage.
Dr. Robert Peltier, PE is POWERs
editor-in-chief.
4. Every detail counts. Paradise Elec-
trician Bruce Stewart completes repairs on a
light fixture. Courtesy: TVA
5. Operational excellence. Paradise Assistant Unit Operators Dale Welborn and Marty
Mefford confirm the procedure to add water to a stator cooling system. Courtesy: TVA
"We can't allow ourselves to become
complacent, and daily activities cannot be
considered 'routine.'"
-Assistant Plant Manager Billy Sabin
|
April 2013 28
REGULATORY
Preparing for a NERC CIP Audit
Undergoing a NERC CIP audit is an ordeal, particularly when the ground rules
are not clearly spelled out in advance. An experienced NERC CIP auditor
lays out a comprehensive five-step plan that will show you how to pre-
pare for a successful audit.
By James E. Chance, Corporate Risk Solutions Inc.
I
ts no surprise that a North American Electric
Reliability Corp. (NERC) Critical Infrastruc-
ture Protection (CIP) audit generates plenty
of anxiety during the weeks preceding one.
However, there is a preparation strategy that will
allow you to get those emotions under control.
This article presents a detailed analysis of a
five-step audit preparation strategy, followed
by its application to a specific NERC CIP task.
The strategy, based on real-world NERC CIP
audit experiences, is a useful guide for those
responsible for audit documentation prepara-
tion. Next, the entire five-step process is ap-
plied to a single NERC CIP sub-requirement
as an example. You also will find some sug-
gestions on where to seek additional help.
The NERC CIP audit environment is chang-
ing. Regional Entities (REs) are doing more
work upfront and less on site. There are eight
REs representing, according to NERC, virtual-
ly all the electricity supplied in the United States,
Canada, and a portion of Baja California Norte,
Mexico. If the Entity (essentially any compa-
ny that generates or manages power flow on a
transmission and distribution network) submits
a clear Reliability Standard Audit Worksheet
(RSAW) with good supporting evidence, most
of the audit can be done before the Regional
Auditors (RA) arrive at the Entitys site. Every
requirement the RAs check off before arriving
on site means one less activity that you need to
interrupt your subject matter experts (SMEs)
schedule for, which is always a good thing.
Step 1: Understand the
Requirements
The NERC CIP Reliability Standards (CIP
Standards) were written by committee and,
generally, without the benefit of a technical
writer. The result is that they are not extreme-
ly clear and are often confusing. Although
understanding the current version is vital, it is
also useful to review the next version that is
in draft form. Review your registration status
against the requirements so that you are ad-
dressing the proper version and constraints.
The key sections in each of the eight CIP
Standards are the two sections entitled Re-
quirements and Measures. The Requirements
describe what the Entity needs to do, and the
Measures describe what evidence the audi-
tors will be checking, although the section is
written at a summary level.
The first step in understanding the Require-
ments within any of the CIP Standards is to
review the language. Two especially interesting
concepts are presented in the Requirements sec-
tion that require close interpretation.
The first interpretation problem involves
the use of technical and/or procedural con-
trols. These require documentation, and when
technical controls cannot be implemented, a
technical feasibility exception (TFE) is re-
quired. Sometimes written with an and and
sometimes with an or, the documentation
requirements of the two cases are different.
CIP-005 R2 uses the phrase organization-
al processes and technical and procedural
mechanisms, whereas CIP-007 R5 uses the
phrase technical and procedural controls.
What is the difference between the two
phrases? You need to understand this because
it affects your procedures and the evidence
you provide for the auditors. Note that Com-
pliance Application Notice0017 provides
the interpretation that every technical control
implies a procedural control, the process that
implements the technical control. It also pro-
vides guidance on when either technical or
procedural controls or both are applicable.
Another interesting interpretation prob-
lem concerns the collection of terms that
show when documentation is required. The
following words listed throughout the Re-
quirements require the Entity to provide a
document of some sort as evidence: policy,
methods, processes, procedures, identify,
maintain, document, list, approve, develop,
review, implement, assign, assess, establish,
controls, perform, update, retain, create, de-
ploy, exercise, use, and test. Every one of
these words indicates a document or task that
is required by the standards. Eventually, you
will need evidence (documents) each time
one of these words appears.
Go through the Requirements one by one
and read them carefully. Make a note of any-
thing that you dont understand. Create an
outline of the significant statements or start a
spreadsheet to track your information.
The Requirements themselves can be very
confusing. As the example using CIP-005
R2 and CIP-007 R5 demonstrates, it can be
daunting to untangle the true intent without
help from those more experienced in the
audit documentation process. Fortunately, a
number of sources can help you understand
the Requirements (see sidebar).
Step 2: Know What Auditors Are
Looking For
Auditors are looking for just one thingthe
opportunity to verify that you are auditably
compliant with the CIP Standards. The audi-
tors look for documentation of procedures, and
verification that you are executing them (as ref-
erenced in Federal Energy Regulatory Commis-
sion [FERC] Order Docket No. RM06-22-008).
This will include both the RSAWs and the as-
sociated evidence for each requirement.
The RSAWs used during the actual audit need
to present two types of evidence, as referenced
in FERC Order Docket No. RM06-22-008:
In critical infrastructure protection, and es-
pecially in the cyber security environment,
the implementation of security measures is
largely dependent on complex plans, poli-
cies and procedures that must be repeatable
and verifiable. This necessitates documen-
tation of both (1) the procedures to be fol-
lowed and (2) verification that the procedures
were followed as directed. These complex
procedures require clear and consistent in-
structions (documentation) and consistent
execution (implementation). Further, these
procedures also require a method for report-
ing their completion.
To address this requirement, each Entity has
processes, procedures, and policies that describe
how the Entity meets the requirements of a RS,
the means that the Entity uses to meet the re-
quirement. The second type of evidence is used
to show that the Entity is using these processes,
procedures, and policies. This evidence is typi-
cally screen shots, lists, reports generated by
applications, logs, or other evidence generated
from the devices themselves.
Auditors also look for enforcement. If a
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This manual covers all aspects of the business, from the startup of a plant, to safety issues, day-to-day operations, keeping it
proftable, leadership principles, stafng solutions and more. The Sourcebook for Competitive Powerplant Management will
quickly become your number one go-to industry resource.
Table of Contents:
Section 1: The Need for Change
Section 2: Operating the Plant
Thriving through Initial Startup
-Setting Up the Ops Department
-Targets and Standards
-Training Costs a Lot Ignorance Costs More
Section 3: O&M Fundamentals
-Water Treatment
-Lubrication
-Equipment Protection and Preservation
-Turbomachinery Essentials
-Information Technologies
Section 4: Proft-Centered Maintenance
-Competitive Maintenance Strategies
-Predictive Maintenance that Works
-Outage Planning and Execution
-Life-Cycle Asset Management
Section 5: Safety & Environmental
-Prepare a One-Step Shopping Guide
-Create Safety, Not Just Safety Programs
-Trekking through the Environmental Jungle
-Other Regulatory Hurdles
Section 6: Business Management
-Day-to-Day Management
-Understanding Accountants
-Contractor and Inventory Costs
-Managing the Total Risk
-Employment Law
Section 7: Leaders in the Powerplant
Critical Leadership Principals
-Finding and Keeping- an O&M Staf
-Conducting Performance Appraisals
-A Living, Breathing Policy Manual
-Benchmarking
Epilogue: Stepping into the Ring
The Sourcebook for Competitive
Powerplant Management
21617
Order your copy online at
www.powermag.com/powerpress
or call 888-707-5808
Appendices
Appendix A: Professional Organizations
Appendix B: Licensing Requirements for Steam-Plant Operations
Appendix C: Glossary of Abbreviations
Available in a PDF format. 355 pages.
08_PWR_040113_SR_NERC_p28-35.indd 29 3/13/13 2:00:06 PM
|
April 2013 30
REGULATORY
policy says employees should follow a pro-
cedure, the auditor will want to know what ac-
tion you took when an employee didnt follow
the procedure. Find out what the auditors con-
sider good documentation versus weak or
poor documentation. Note that your experi-
ence based on a spot check will most likely
not be a good indicator of readiness for an
audit because a spot check does not have the
same requirements as an audit. A spot check
is much less rigorous than an actual audit, so
evidence that was sufficient for a spot check
may not be adequate for an actual audit.
Usually, the auditors will not want to look
at all of your evidence. Instead they will use
a program called RAT-STATS (available for
download, see sidebar) to select a statistically
representative random sample. No one wants
to look at 90 days of firewall logs (especially
if there are thousands of pages in the logs).
They will want to take a small sample, just
enough to show that your process is retaining
90 days of logs. RAT-STATS will allow them
to select a statistically accurate sample. This
will also be used for personnel risk assess-
ments, training, and access changes.
In summary, auditors want to see a pro-
cedure that meets the Requirement and evi-
dence that you are following the procedure.
Step 3: Analyze Your Evidence
A documentation spreadsheet is very help-
ful for tracking your compliance. For each
Requirement and sub-requirement, create a
column, and then use a row for each piece of
evidence. Each row should have a file name
or document title. You can use a comments
column to provide additional details (perhaps
how to access the data). As each piece of
evidence is analyzed, update the spreadsheet.
Even if all pieces of evidence are not used for
the RSAW, you may need them if the auditors
ask for additional evidence during the audit.
This spreadsheet will be very useful when
packaging your evidence.
Analyzing your evidence is a three-part
exercise:
First, determine what processes and proce-
dures you have that demonstrate compli-
ance. Use the documentation spreadsheet
to track these documents. Your SMEs
should be able to identify all these poli-
cies, procedures, and processes.
Second, for each process and procedure
identified, find the supporting evidence
that shows you are executing processes
and procedures properly. This must be
carefully done, or you will miss some
of the evidence. Consider the size of the
evidence. Typically, firewall logs contain
huge amounts of data, but auditors will
only want to see a sample. Have a plan for
how to extract the sample.
Third, verify that your evidence is complete
and sufficient. This is best done by a dif-
ferent person (not the one who created the
evidence) to demonstrate a more objective
analysis of the sufficiency of the evidence. If
you are missing evidence, go back over the
previous step and see if the evidence can be
located or generated.
The third step can require a lot of work,
as there may be dozens of documents to re-
view. Also, associating documents with Re-
quirements can be confusing, especially as a
single document may be referenced in sev-
eral different Requirements. The key is your
document map that cross-references Require-
ments with the evidence.
When analyzing procedures and processes,
you should also review them for compliance.
Typically, one procedure will meet several
sub-requirements. Note the specific sections
that demonstrate compliance.
When you package your evidence, you
will need this information for the book-
marks. Carefully consider the language in
your procedures. Words like should, gen-
erally, and typically should be avoided.
Use must or shall instead. Look for clear
instructions and positive statements in your
documents. See if reviewers can understand
the document or if they need to ask for an
explanation, especially for a process or pro-
cedure. If they need an explanation, then this
is a good time to rewrite the document to
provide clarity to show that it meets the re-
quirement. Doing this early gives you time to
update the document before your audit.
Review your definitions and look for any
cases where you do not use industry refer-
ences but redefine terms. If a term is in the
NERC glossary and you define it differently,
expect to be asked to defend your definition.
It is best to simply reference the NERC glos-
sary itself in your documents rather than re-
peat the definition.
Step 4: Package Your Evidence
The fourth step requires you to take the raw
evidence (data) and package it into a format that
makes it easy for the auditor to verify compli-
ance. In most cases, the auditor will only want to
see a sample of your evidence, so make sure you
have internal procedures defined for extracting
those samples. Remember that searchable PDFs
are the form of evidence preferred by most au-
ditors, but other formats (such as Excel spread-
sheets) are acceptable.
The first step in packaging your evidence
is to create a folder for each Requirement.
You can also put the document reference in
the folder. This gives you a good place to
track your progress in preparing the evidence.
In this folder, create a copy of your files and
use the actual file names you will supply to
the auditors. This will allow you to leave
the originals untouched and available if you
need them. The first file in the folder should
be the RSAW. You will update the RSAW as
you package your evidence and decide what
should be directly referenced in the RSAW
and what will be held back until it is needed
or requested by the auditors.
Where to Find Help
The first resource is the North American
Electric Reliability Corp. itself (www.nerc
.com). Check the Compliance Application
Notices to see if one of them addresses your
questions. You can also check the balloting
comments; there may be useful information
there also. The next place to check is the
Regional Entities websites. The Regional
Entities also hold seminars and webinars
where you can get additional information
and ask questions. You may also email them
with general questions. Finally, various in-
dustry forums allow Entities to exchange
information and ask questions. Helpful re-
sources include those that follow.
NERC
CIP Standards: http://bit.ly/ptjUG
Compliance Application Notices:
http://bit.ly/abVoyr
Compliance Application Notice0017:
http://bit.ly/12cXWHT
Regional Entities
Florida Reliability Coordinating Council
(FRCC): www.rfirst.org
Midwest Reliability Organization
(MRO): www.midwestreliability.org
MRO guide to compliance: http://bit.
ly/12cY75T
Northeast Power Coordinating Council
(NPCC): www.npcc.org
ReliabilityFirst Corp. (RFC): www.rfirst.
org
SERC Reliability Corp. (SERC): http://
bit.ly/GWSLfD
Southwest Power Pool, RE (SPP):
http://bit.ly/UbJlJ2
Texas Reliability Entity (TRE): www.
texasre.org
Western Electricity Coordinating Coun-
cil (WECC): www.wecc.biz
Other Government Resources
RAT-STATS, Statistical Software:
http://1.usa.gov/WHqJAS
April 2013
|
REGULATORY
You can also create a folder for common
files. That way, you only need one copy of
them. If you do this, be sure that all the book-
marks for each file include every Require-
ment that references the file.
Auditors greatly prefer bookmarked and
searchable PDF files, especially if the docu-
ment is referenced in several Requirements.
Highlighting specific areas that address indi-
vidual Requirements makes them stand out for
the auditors. You may also want to put several
smaller but related documents into one PDF
with an explanation describing why they are
related and what Requirement they address.
Auditors also like Excel spreadsheets because
they are easy to sort and manipulate.
Some evidence may not be obvious. For
instance, if you are using SharePoint, you
may have the document in one place, but the
version history in another. Showing multiple
versions that were effective for various date
ranges during the audit period may require
some manual work. Prepare before the audit
for any versions that may be requested by
auditors if the time to create each version is
longer than you may have available while the
auditors are on site.
A good practice is to put the policies, pro-
cedures, and plans in individual documents,
including the revision history if that is kept
in an individual file (SharePoint documents
may be created this way).
Keep large documents in their own files.
For smaller documents, selected related ones
(usually by sub-requirement), put a summary
at the top, and group them together in one
PDF. Use links in the summary to point to the
individual documents or RSAW references.
Regional Entities now provide secure elec-
tronic means to submit your evidence. Audi-
tors prefer that each RSAW stand alone, so
creating a folder for each Requirement with
the RSAW and the associated evidence is the
best way to submit it.
Presenting your evidence to the RE in
RSAWs with a clear format and a good struc-
ture that is easy to understand and directly
addresses each Requirement will allow the
auditors to check off each Requirement one
by one in their off-site review. Getting the
evidence early allows them to review it at
their location more efficiently. If the Entity
submits a clear RSAW with good supporting
evidence, most of the audit can be done be-
fore the RAs arrive at the Entitys site. Every
Requirement RAs check off before they are
on site means one less activity that you need
to interrupt your SMEs schedule for.
Step 5. Practice the Audit
The fifth and final step is to practice an audit.
You can do this internally with your corpo-
rate audit team (if you have one), by using
cross functionality between SME groups, or
with an external consultant. Be certain to do
this far enough in advance of the audit so that
if you find serious weaknesses you can rem-
edy them before the audit.
If you are using an internal mock audit,
try to structure it so that the same people
do not create the evidence and then audit
it: You want a fresh set of eyes on the evi-
dence. It helps to have a technically qualified
audience, especially if they have not been
involved in preparing the evidence. For ex-
ample, you may have corporate IT staff who
could act as the auditors.
Outside vendors can also be used for the
practice audits. They generally provide a
condensed version of the actual audit. Verify
the credentials and experience of such audi-
tors before selecting an outside vendor.
The goal of the practice audit is to verify
that your evidence is sufficient to meet the Re-
quirements and is clearly presented. Present
only the evidence you have prepared that will
be given to the actual auditors (and in same
format that will be presented to the auditors).
Case Study: CIP-003 R6
This case study applies the five-step plan for
preparing your evidence just described to the
CIP-003 R6 requirement for Change Control
and Configuration Management, particularly
as its Requirements are complicated by its
ties to CIP-005 R1.5, CIP-006 R2.2, and
CIP-007 R1-R5.
CIP-003 R6: Understanding the Re-
quirements. CIP-003 R6 requires that the
Entity shall establish and document a pro-
cess of change control and configuration
management for adding, modifying, replac-
ing, or removing Critical Cyber Asset hard-
ware or software, and implement supporting
configuration management activities to
identify, control and document all Entity or
vendor-related changes to hardware and soft-
ware components of Critical Cyber Assets
pursuant to the change control process.
The first question an Entity must answer
is whether this is one process or two. There
are compliant processes that are separate
and also ones that are a single process. Let
us assume for our example that there are two
processes: one for change control and one for
configuration management, but with com-
mon interaction between the two.
What did the authors mean by change
control, as they did not provide a formal def-
inition? Knowing that all the CIP standards
are focused on protecting the bulk electric
system, the inference is that the negative im-
pact of changes will be minimized or elimi-
nated. A review of the literature available for
change control provides some clarity. As fo-
cused on the CIP standards, change control
includes three components: documentation,
approval, and testing.
CIP-007 R1 also provides guidance on
significant changes and the testing re-
quired, ensuring that the change will not
adversely affect existing cyber security con-
trols. This will be documented as part of the
change control process.
Though not a formal interpretation of the
Requirement, all significant changes should
have documentation of the change approval,
test procedures, test results, and implemen-
tation status. This documentation should in-
clude the date of each activity, so the Entity
can demonstrate that successful testing was
completed before implementation.
Note that the testing must address the ef-
fect of the change on cyber security, especially
cyber security controls. The CIP requirement
does not address application testing. Testing
must include the effect of the change on ports
and services open on the asset. It should also
include any other cyber security controls. For
Windows-based PCs this does include some
of the registry entries, because they directly
affect cyber security. This should be docu-
mented as part of the change control process.
Configuration management is closely re-
lated to change control. CIP-007 R2 requires
that only those ports and services required
for normal and emergency operations are
enabled. Configuration management is the
process that provides the documentation that
the auditors will use to review compliance
with this requirement. A key to this docu-
mentation is the justification for each port
and service active on the asset. Configuration
management will also provide the configura-
tion needed in CIP-009 to recover an asset.
Configuration management is typically
documented using a baseline for each asset or
a group of similar assets. This can take many
forms. For routers, this may be a text file of
the access controls lists. For Windows-based
PCs, it may be a backup file plus a ports and
services baseline. One key is that every asset
should have a baseline configuration.
The configuration management baseline
documentation must be updated anytime the
baseline changes. For example, switching to
a different anti-virus vendor may affect the
ports needed for operation. This could ei-
ther open or close ports in the baseline. The
configuration management process should
document this change with a new version of
the baseline.
CIP-003 R6 Auditors Expectations.
Auditors typically expect to see a change-
tracking system for all significant changes
(it may also track other changes). They will
expect to see that every significant change is
documented, tested, and approved before it
is implemented. The only exceptions auditors
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|
April 2013 34
REGULATORY
expect are cases where there is no test system
or backup system to test the change on. In
those cases, auditors will expect to see spe-
cific procedures documented that will mini-
mize any possible negative impacts.
Auditors will typically select a statistical-
ly accurate sample of all significant changes
and review these changes in detail. This will
include looking at the before and after test
results and matching them to the baseline for
the device. If there were any changes that af-
fected the baseline, they will need to verify
that the baseline was updated as required by
the standards (within 30 days of the change).
Auditors will expect to see a documented
process for configuration management. They
expect to see baseline documentation for the
ports and services for all critical cyber assets
(CCAs) and cyber assets within an elec-
tronic security perimeter (except those with
TFEs for CIP-007 R2). This documentation
should include the justification for each port
and service that is active on the asset. Typi-
cal justification is a manufacturers statement
showing what is required, but if that includes
a very large range of ports, an auditor will
likely question it. Auditors may also ask if
you have turned off any ports and then tested
the asset to see if it will function without
them. Simply doing a display of the current
ports and services is not considered adequate
justification.
Auditors will look for any cases where the
baseline should have been changed as a result
of a significant change to a CCA. All changes
like that typically receive a detailed review.
CIP-003 R6: Analyze Your Evidence.
At this point, review your change control
and configuration management process
documents. Are all the procedures accurately
described? A good check is to take the proce-
dure and see if someone who does not work
in that area can successfully execute it. Al-
ternatively, you can take someone who has
implemented changes and walk them through
everything they did to see if there are any
steps they took that are not documented. You
want to be confident that the procedures ac-
curately represent what people really do.
Also verify the interaction between pro-
cesses. Verify that if the ports and services
baseline changes, part of the change process
is to update the associated documents (this
can include asset lists when decommission-
ing or adding an asset, configuration base-
lines, and even recovery procedures).
The next step is to determine what evi-
dence you need to show that you are follow-
ing the process. For change management,
this will start with your change-tracking
system. Assuming you are using a commer-
cial change-tracking system (like Remedy,
for example), you will need to gather any
additional procedure documentation for the
system if that is not covered in the previous
documents you reviewed.
Export from the change-tracking system a
report of all significant changes. If this is not
easily done, it is a flag that you will need ad-
ditional resources available during the audit to
respond to data requests. The report should in-
clude a description of each change. If possible,
determine which changes resulted in a change
to the baseline documents. If that is not readily
available from your tracking system, then find
an alternate way to get that data.
From this report, you can run RAT-STATS
(with confidence level of 95%, rate of occur-
rence of 0.5%, and precision range of 10%)
to determine the sample size. For example,
if there were 1,000 significant changes, you
would need to sample 34 random changes.
RAT-STATS can then be used to generate the
34 random samples. You can expect the audi-
tors to do a similar calculation.
For the changes in this sample, pull the
required documents and populate them. This
will start with the change ticket, but it will
also include the before and after test results.
It may even include associated e-mail refer-
enced in the ticket; an e-mail containing the
justification for a change in ports and servic-
es is a good example.
Another concern for evidence is the orga-
nization of your Entity. Many Entities have
completely different procedures and docu-
mentation for generation, transmission, and
control centers. Often an IT group maintains
the network connectivity and network devices,
but it typically has different processes as well.
Consider how to organize these different pro-
cesses for presentation to the auditors.
CIP-003 R6: Package Your Evidence.
When you analyzed your evidence, you
should have been thinking about how to
package it. As you documented each piece of
evidence in your document reference spread-
sheet, you should note how and where you
want to package it. You should have created
a folder for each CIP and then copied each
document to that folder as it was analyzed,
unless it was a large file that will be sampled
instead. At this point, you can combine in-
dividual files into PDFs with bookmarks for
the auditors to use.
Prepare each folder so that it contains only
the files you will submit as evidence, the
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April 2013
|
REGULATORY
RSAW, procedure documents, and attributed
evidence. Only keep the samples that you ref-
erence in the RSAW; however, you may want
to keep other samples you have generated in
an easily accessible backup folder.
CIP-003 R6: Practice the Audit. This can
range from a simple exercise to a major ef-
fort. The primary objective is to verify the
accuracy and adequacy of the evidence. A
secondary objective is to prepare your SMEs
for testifying during the audit.
The compliance team can make a first cut
at this by reviewing the evidence. That can
give them a feel for which areas are strongest
and which areas may need more work. As
this is solely in-house, it has the least cost.
They can also select which SMEs will testify
during the audit.
At this point, the Entity must decide
whether to outsource the practice audit or
keep it in house. This is generally a manage-
ment decision. If there are sufficient trained
and available resources within the company,
an in-house practice audit is a good solution.
In most cases, there are not enough internal
resources to do a good mock audit, so an ex-
ternal consulting team with specific NERC
CIP audit expertise is often used.
Set up a room similar to what the audit team
will expect. Typically, they will be on one side
of the room (with no one behind them). The
room should have a projector and a computer
with the data. During the actual audit, you will
want to make sure that the computer you are
using cannot get to live data, only the docu-
ments that you have prepared for the audit.
This will limit what the auditors can see and
will not allow them to see anything unexpect-
ed that could expand their audit.
There are three levels of mock audits that
reflect the Entitys commitment of resources:
An audit by one or two auditors of a single
Requirement (or up to a maximum of three
Requirements) can be done. This will limit
the SME participation and typically only
requires one to three days on site. This is
a good option if you feel that most of your
program is strong but you have one or two
weak areas.
A mock audit with one audit team (typi-
cally, two people) from an external con-
sultant working on site for four to five
days can provide a high-level review of the
evidence. As this is roughly one-eighth of
a typical regional audit (two teams of three
people each on site for one to two weeks),
this will not include a deep dive into the
evidence. It does require SME testimony
during the mock audit.
A full-blown mock audit with two teams
for two weeks can include an exhaustive,
deep dive into the evidence. This will
likely include considerable testimony by
the SMEs. This provides the most detailed
examination of the evidence and the great-
est opportunity for SMEs to practice their
presentation skills.
If you have different groups that will be
presenting evidence, you should present an
overview for the auditors. With different
groups (or business units), you can either
present it all together, point-by-point, for all
groups or do each organizational unit inde-
pendently, one at a time. Let us assume for
the example that there is only one organiza-
tional unit and one set of procedures.
Next, your SME should give a high-level
description of the change control process.
For this example, assume change control will
be presented first, followed by configuration
management. Show the key steps for approv-
al, testing, implementation, and documenta-
tion updates for change control. Demonstrate
the list of all significant changes to the audi-
tors. Pick a sample change and go through
it, showing each key step in the process and
the associated documentation. Describe how
your process meets the requirements at each
step in the process. Explain how the testing
process ties to CIP-005 R1.5, CIP-006 R2.2,
and CIP-007 R1-R5.
Once you have completed presenting the
change control process, then introduce the con-
figuration management process with a high-lev-
el description of the process. List the evidence
you have prepared for the configuration man-
agement process. Introduce your evidence for
the baseline used for comparison purposes. Pick
an example of a baseline that was updated dur-
ing the audit period, and show the details.
If you selected a third-party mock audit,
you will receive an audit report with observa-
tions and recommendations (your internal au-
dit could also create a similar report). Be sure
to allow enough time before the actual audit
to implement the suggestions and improve-
ment so that your evidence will be complete
and sufficient to satisfy the auditors.
James E. Chance (jchance@corprisk
.net) is a senior security consultant with
Corporate Risk Solutions. He is a NERC
CIP consultant and a regional auditor
contracted to multiple regions. This article
is based on a paper presented at the 2012
ISA POWID Conference.
Rittal
www.rittal.us
|
April 2013 36
EMISSIONS CONTROL
Electrostatic Precipitator Upgrade
Opportunities
The results of stack emissions testing conducted at several coal-fired power
plants during the past three years have provided useful guidance for plant
operators who are required to meet new federal guidelines regarding the
release of particulate matter. The data and guidelines presented here will
assist those who operate plants with electrostatic precipitators to develop
a strategy for filterable particulate emissions control.
By K.S. Kumar and J.A. Knapik, Babcock & Wilcox Power Generation Group Inc.
N
ew Environmental Protection Agen-
cy (EPA) rules for the control of
mercury and air toxics, also known
as the Mercury and Air Toxics Standards
(MATS), were established in 2012. The air
toxics portion of the rules includes con-
trol of hydrochloric acid (HCl) and sev-
eral trace metals. After several years of re-
search, proposals, industry comments, and
stakeholder reviews, the EPA has accepted
the premise that filterable particulate mat-
ter (PM) is a surrogate for virtually all
trace metals. In the final MATS rule, the
EPA determined that limiting stack fil-
terable particulate emissions below 0.03
pound per million Btu (lb/MMBtu) based
on EPA Test Method 5 should adequately
safeguard public health.
The specification of filterable PM lim-
its, instead of total particulate matter that
included the highly variable condensable
fractions, has provided additional flex-
ibility for achieving compliance with ex-
isting electrostatic precipitators (ESPs).
Fortunately, during the past 50 years, a
considerable body of literature has been
generated describing research and full-
scale operating experience with ESPs. Our
approach in this article is to draw from this
literature and provide plant operators with
empirical means to assess their ESP per-
formance. We review important research
on the various parameters affecting ESP
outlet emissions. This research summary
guides the discussion that follows on the
interpretation of results from recent test-
ing at several coal-fired power plants. Ar-
eas for further research on reducing stack
filterable emissions are also identified.
Fundamentals of Ash and ESP
Corona Power
Sulfuric acid is an excellent fly ashcondi-
tioning agent. Proper amounts of this acid
can control the ash resistivity to manage-
able levels, in the optimal range of 108
to 1,010 ohm-cm. It is known that some
eastern high-sulfur coals with high iron
content in the ash can generate elevated
levels of sulfur trioxide (SO
3
) in the flue
gas. Depending on the air heater operation,
it is quite possible for these plants to oper-
ate the ESPs at a flue gas temperature that
is below the sulfuric acid dew point. The
fly ash can then become too conductive for
proper control in the ESP, as the particles
are subjected to the pith ball effect, an
electrostatic phenomenon through which
the particles lose their charge at collec-
tor plates and are repulsed back into the
gas stream. The resultant electrical re-
entrainment can greatly diminish the ESP
collection efficiency even if there are no
limitations to the introduction of proper
corona current density in the ESP.
On the other hand, it is also possible for
the fly ash in flue gas to be insufficiently
conductive. This has been known to lead
to premature flue gas breakdown inside the
ESP caused by the incipient back corona
effect. Back corona severely limits the
amount of corona current density that can
be received by a given electrically ener-
gized section of the ESP. Low ash conduc-
tivity (or high ash resistivity) is believed to
be caused by a combination of factors:
Inadequate amounts of free SO
3
in flue
gas due to the highly alkaline nature of
the fly ash.
A combination of insufficient amounts
of SO
3
in flue gas and alternate conduc-
tive species, such as sodium sulfate, in
the fly ash.
A combination of high acidity in the fly
ash, high flue gas temperature, and low
flue gas moisture. That can result in much
of the SO
3
present in the fly ash to be in-
effective to adsorb onto fly ash particles,
rendering it ineffective for providing the
needed conductivity.
Corona Current and Specific
Corona Power
Corona current density is defined as the
maximum corona current that can be intro-
duced by a power supply per square foot of
collecting surface of a given ESP electrical
section. The inlet fields of the ESP expe-
rience the maximum dust concentrations
and are subjected to flue gas breakdown at
lower current density levels as compared to
cleaner outlet fields. Even in the absence
of ash resistivityinduced limitations, it is
not unusual for the inlet field corona current
density levels to be lower by a factor of four
as compared to the outlet fields.
The relationship among corona current
density (mA/1,000 ft
2
), specific corona pow-
er (watts/acfm), a nd collection efficiency
across an ESP has been well researched. It
has been found that when operating an ESP
at ash resistivity levels higher than 5 x 10
10
to
5 x 10
11
ohm-cm, high ash resistivity-related
premature gas breakdown impacts begin to
be noticed. ESP corona current density starts
dropping rapidly and, depending on the size
of the ESP, filterable emissions may start to
increase.
In most cold-side ESP applications, corona
current density levels could vary from values
as low as 5 mA/1,000 ft
2
for highly resistive
ashes to levels as high as 75 mA/1,000 ft
2
for
highly conductive ashes. Operating voltages
will vary, depending on plate spacing and
discharge electrode geometry, between 40
and 75 kV, on average.
As an example, for an ESP operating
at 40 kV average, and at a corona current
density level of 50 mA/1,000 ft
2
, the av-
erage corona power density would be 2.0
watts/ft
2
. If this level of energization were
|
April 2013 38
EMISSIONS CONTROL
powered in an ESP with a specific collect-
ing area (SCA) of 200 ft
2
/1,000 acfm, then
the specific corona power would be 400
watts/1,000 acfm. If the SCA were twice
as large, at 400 ft
2
/1,000 acfm, then a co-
rona current density of 25 mA/1,000 ft
2

would produce the same specific corona
power of 400 watts/1,000 acfm.
For a given power plant operating at a
given load and a given ESP configuration
reduced corona current density, changes
in coal chemistry, for example, can lead
to much reduced specific corona power.
This lowering of corona current density
has the potential to cause an increase in
stack emissions. A given ESP operat-
ing with proper mechanical integrity can
shift from days and months of very well
energized operation to sudden episodes
of ESP electrical sections operating with
low corona current. While the worsen-
ing of ESP collection can generally be
seen as increased opacity, as monitored
through a continuous opacity monitor at
the ESP outlet, caution needs to be exer-
cised. Stack opacity is not always a good
indication of increasing PM rates because
it is greatly dependent on particle size.
Smaller PM tends to have less impact on
the PM rate while it has a large impact on
refracting and attenuating the light, which
is then seen as higher opacity. Conversely,
larger PM (such as re-entrainment from
hopper leakage) may not impact the opac-
ity monitor, but it can have a significant
impact on the PM rate.
There is wide variability in plate-to-
plate spacing in the collector electrode
ESP designs. Historically, ESP size was
reported in terms of SCA and usually in
units of square feet per 1,000 acfm. To-
days ESP evaluation practice is to report
the ESP size in terms of total residence
time. This will avoid the misinterpreta-
tion of a lower SCA precipitator at higher
plate spacing as a smaller size unit, even
though the treatment times for both may
be identical. Engineering evaluations and
research on the application of wider plate
spacing technology have revealed that col-
lection efficiencies of ESPs with two dif-
ferent plate spacing and SCAs can be the
same, as long as other parameters such as
specific corona power are equivalent.
Performance Variability at a Given
Specific Corona Power
ESP filterable emissions can vary consider-
ably for a given specific corona power. This
is a result of several factors.
First, ash cohesivity can vary depending
on the nature of flue gas and ash constituents.
It is well known that ammonia conditioning
has reduced filterable emissions consider-
ably, principally due to control of sulfuric
acid concentrations and the introduction of a
cohesive agent that is a byproduct of the am-
monia-sulfur compounds. Several approach-
es are reported in the literature, such as:
Injecting ammonia for control of particu-
late re-entrainment from carbonaceous
particulates.
ESP performance enhancement through
ammonia injection on high SO
3
-laden flue
gas on eastern coals.
Maintaining operation above the sulfuric
acid dew point through sufficient mitigation
of SO
3
by ammonia injection (Figure 1).
Considerable research with novel addi-
tives, showing similar results, has also been
conducted for the purposes of reducing ash
resistivity and increasing ash cohesivity.
Second, fine particulate matter may
vary from plant to plant, depending on
fireside conditions. A significant number
of coal-fired power plants have introduced
some form of fireside management to re-
duce flame temperature, and thus reduce
nitrogen oxide (NO
x
) emissions. The cor-
relation between fireside NO
x
emissions
and submicron particulate content has
been thoroughly researched by the Electric
Power Research Institute (EPRI). Figure 2
shows the relationship between nitric ox-
100
90
80
70
60
50
40
C
o
l
l
e
c
t
o
r

e
f
f
i
c
i
e
n
c
y

(
%
)
Gas flow (10
3
cfm)
325 350 375 400 425 450 475 500
Rated full load flow
Gas temp 270F (below acid dewpoint with NH
3
feed)
Gas temp 310F (above acid dewpoint)
Gas temp 270F (below acid dewpoint)
1. Capturing ash. Control of ash re-entrainment through ammonia injection is one means
of reducing filterable emissions. Source: J.T. Reese, J. Greco, Experience with Fly-Ash Collec-
tion Equipment Serving Steam-Electric Generating Plants, Journal of the Air Pollution Control
Association, August 1968, Vol. 18, No. 8.
80
40
0
M
a
s
s

i
n

s
u
b
m
i
c
r
o
m
e
t
e
r

m
o
d
e

(
m
g
/
m
3
)
Nitric oxide (ppmv)
0

360 MW, front wall
540 MW, tangential
520 MW, opposed wall
113 MW, roof fired
360 MW, tangential
25 MW, front wall
500 1,000
2. Fly ash in the gas. Fly ash fine partic-
ulate content versus NO emissions at several
coal-fired plants is illustrated. Source: M.W.
McElroy, R.C. Carr, and G.R. Markowski, Size
Distribution of Fine Particles from Coal Com-
bustion, Science, Vol. 215, January 1982.
April 2013
|
EMISSIONS CONTROL
ide (NO) content and submicron particu-
late concentration for coal-fired boilers of
different designs and differing flame tem-
peratures. Note in the figure that submi-
cron particulate matter decreases by more
than a factor of three, in direct proportion
to the decrease in NO emissions. Other re-
searchers have determined that, for a given
specific corona power in the ESP, filterable
outlet emissions will decrease if the inlet
ESP fine particulate content is decreased
considerably.
Finally, ash re-entrainment from ESPs can
vary and can affect the filterable emissions
considerably. Re-entrainment can occur due
to several factors:
Poor gas flow quality in the ESP, resulting
in high local peak gas velocities. These
high local velocities in the ESP can scour
the particulate from collector plates and
increase stack emissions.
Even a small component of flue gas
flow and entrained ash directed to the
hopper area can find its way to the stack
practically untreated by the ESP, when
poorly distributed gas flow is present.
Excessive sparking in the outlet fields
of an ESP, mostly due to outdated power
supply controls, can cause re-entrain-
ment of ash collected on the plates.
These controllers typically allow the
precipitator power to dwell for excessive
periods in the de-energized state, before
automatically ramping the power back
to the sparking voltage level. While the
average ESP power in these electrical
sections would appear normal, the ESP
particulate collection can suffer from re-
entrainment due to improper automatic
control of ESP energization.
Excessive collector plate rapping in
the outlet fields will release the col-
lected ash back into the flue gas stream.
Typically, rapping an abnormally high
number of collector plates with a single
rapper creates these situations. When
rapper intensity levels are set too high,
the ESP corona power may continue to
show good levels, while the stack filter-
able emissions could still suffer due to
ash re-entrainment.
Wet FGD Co-Benefits Are Possible
The particulate control co-benefits of oper-
ating a wet flue gas desulfurization (FGD)
system after a dry ESP have been well doc-
umented through pilot-scale experiments.
Table 1 illustrates the relatively stable total
PM outlet loadings for a highly varying set
of inlet filterable particulate loadings. Further
analysis of this pilot-scale data indicates that
filterable particulate collection can reach 90%
at wet FGD ash inlet loadings at about 0.10
lb/MMBtu. Other researchers have reported
filterable particulate collection in the neigh-
borhood of 90% across a wet FGD (see, for
example, K.S. Kumar and P.L. Feldman, Un-
derstanding the Relationship Between Trace
Element Removal and Overall Particulate
Control, November 1994, ICAC Forum).
However, you should not expect the
filterable particulate collection efficiency
of 90% across the wet FGD under all con-
ditions. The mechanisms of particulate
collection through impaction and impinge-
ment in a wet FGD are largely influenced
by particulate size distribution entering
the absorber. The finer the particulate
size of fly ash entering the absorber, the
lower the expected collection efficiency
Date
Total inlet
loading (lb/Mbtu)
Total outlet
loading (lb/Mbtu)
Scrubber flux
(gpm/ft
2
) Tray
a
SO
3
inlet/outlet
concentration (ppm
b
)
2/28/92 0.0073 0.023 85 B NA
2/29/92 0.037 0.017 85 B NA
3/2/92 0.042 0.037 35 B NA
3/3/92 0.420 0.041 35 B NA
3/4/92 0.220 0.026 35 B NA
3/6/92 0.150 0.030 35 B NA
3/8/92 0.012 0.027 35 B NA
4/3/92 0.021 0.022 60 B NA
4/4/92 0.130 0.022 85 B NA
4/5/92 0.150 0.014 60 C 9/67
4/6/92 0.061 0.045 60 C 2426/1819
4/7/92 0.046 0.044 60 No tray 16/11
4/7/92 0.046 0.049 85 No tray 16/11
Notes: a. Tray B has 30% more open area than Tray C. b. SO
3
injection during 4/6 to 4/7/1993.
Table 1. Relationship between wet FGD inlet and outlet particulate emis-
sions at a pilot plant. Source: P.A. Bhat and D.W. Johnson, Results of Particulate and Gas-
eous Sampling from a Wet Scrubber Pilot Plant, 10th Particulate Control Symposium, April 1993.
350
325
300
275
250
225
200
175
150
D
e
w
p
o
i
n
t

(
F
)
H
2
SO
4
concentration (ppm)
0.1 1 10 100
Vapor H
2
SO
4
15% H
2
O
5% H
2
O
10% H
2
O
Condensate
H
2
SO
4
3. SO
3
dew point curve. Metal temperatures below the dew point temperature for a
given H
2
SO
4
concentration may form a corrosive acid condensate on its surface. Source: R.R.
Hardman, E. Stacy, K. Dismukes, W. Harrison, and L. Monroe, Estimating Total Sulfuric Acid
Emissions from Coal-Fired Power Plants, U.S. DOE Conference Fate and Formation of Sulfur
Trioxide in Utility Flue Gas Streams, September 1998.
|
April 2013 40
EMISSIONS CONTROL
should be expected. Also, stack filterable
emissions after the wet FGD will be in-
fluenced by the degree of re-entrainment
of scrubber-generated gypsum particulate
from the mist eliminators located at the
wet FGD outlet.
SO
3
Makes a Contribution
ESP filterable outlet emissions data can
vary widely, even for a seemingly consis-
tent level of electrical energization. How-
ever, the contribution of artifacts from
measurement emissions test methods can
introduce considerable positive bias to a
true filterable emission value. Figure 3,
showing sulfuric acid dew point curves,
highlights this phenomenon. EPA Test
Methods 5 and 17 (other than Method 5B),
generally stipulated for unscrubbed units,
require the filter probe temperature to be at
250F or at the stack temperature, respec-
tively. For units operating with a wet FGD
system ahead of the stack, EPA Method 5B
is typically specified.
For an ESP operating at an outlet tem-
perature of 325F and a typical concentra-
tion of 10 ppm SO
3
at a flue gas moisture
level of 10%, the sulfuric acid dew point
can be estimated from Figure 3 to be 277F.
99.98
99.97
99.95
99.92
99.90
99.85
99.8
99.7
99.6
99.4
99.0
98.0
95.0
90.0
85.0
80.0
E
f
f
i
c
i
e
n
c
y

(
%
)
200 300 400 500 600 700 800 9001000
E
a
s
te
rn
h
ig
h
s
u
lfu
r
E
a
s
te
rn
lo
w
s
u
lfu
r w
ith
S
O3
g
a
s
c
o
n
d
itio
n
in
g
E
a
s
t
e
r
n

1
%

s
u
l
f
u
r

o
r

w
e
s
t
e
r
n

l
o
w

s
u
l
f
u
r,

m
e
d
i
u
m

s
o
d
i
u
m
0
.
8
%

1
.
5
%

N
a2
O

i
n

a
s
h
W
e
s
t
e
r
n

l
o
w

s
u
l
f
u
r
,

l
o
w

N
O
<
0
.
5
%

N
a 2
O
4. Coal ash collecting. ESP collection efficiency versus specific collecting area (SCA) for
various coals in illustrated. Source: K.S. Kumar and P.L. Feldman, Beyond NSPS: Electrostatic
Precipitator and Fabric Filter Technologies to Meet Future Emission Control Requirements, 9th
Symposium on Transfer & Utilization of Particulate Control Technology, October 1991.
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|
EMISSIONS CONTROL
In this example, the ESP is operating well
above the acid dew point. If stack testing is
to be conducted at 250F on an unscrubbed
unit, assuming that 10 ppm SO
3
is present
at the ESP outlet, Figure 3 indicates that
about 8.5 ppm SO
3
would have condensed
as sulfuric acid aerosol. The extent of pos-
itive bias from condensed SO
3
will depend
on how much of this aerosol gets retained
on the front half of the EPA Method 5 sam-
pling train.
Research has shown that the extent of
positive bias from SO
3
can vary, depend-
ing on the ash loading and alkalinity of
particulate being caught in the probe.
Testing that was done to measure the ac-
curacy of SO
3
measurements revealed
that as much as 40% of the sulfuric acid
can be captured on the filter probe. This
amount of positive bias can have consid-
erable impact on the reported test results.
A 40% capture rate across the filter probe
would amount to 4 ppm SO
3
. If 4 ppm SO
3

is captured on the probe, positive bias on
filterable particulate as a result of conden-
sation of SO
3
on the filter catch can be as
high as 0.015 lb/MMBtu. For ashes that
are more alkaline, such as those derived
from Powder River Basin (PRB) coals or
produced as a result of alkaline sorbents
added for SO
3
mitigation on eastern coal
applications, the capture efficiency of the
condensed acid aerosol on filter probes
could be higher than 40%.
It is not uncommon for ESPs operating
with SO
3
conditioning to experience the
effects of over-conditioning from time to
time. Process control of SO
3
injection can
be difficult if sulfur and alkaline levels in
the coal change considerably. Therefore, it
is possible for flue gas at the ESP outlet to
be saddled with a substantial level of free
SO
3
in the vapor phase. EPA-certified PM
continuous emission monitors (CEMs) op-
erate at a filter probe temperature specified
by Method 5B (320F, plus/minus 25F). At
this temperature, for the stated example,
condensed sulfuric acid aerosol is unlikely
to be present at the filter probe tempera-
ture. Operation of the filter probe at this
temperature has the most probability of
avoiding SO
3
-related positive bias on the
filterable test results.
ESP Performance on Various Coals
Estimated ESP performance curves show-
ing SCA (normalized at 9 in. plate-to-
plate spacing) versus collection efficiency
are illustrated in Figure 4. The figure
demonstrates the expected performance
of ESPs when faced with a variety of dif-
ferent fuels. The prediction curves closely
correspond with performance estimates
reported in the past by EPRI. This early
work projected that, for comparable filter-
able outlet emissions, ESPs treating flue
gas from the combustion of low-sodium,
low-sulfur western PRB fuels would need
to be more than twice as large as ESPs on
plants firing higher-sulfur coals. For rea-
sons discussed earlier, the higher resistiv-
ity of ash resulting from the firing of PRB
coals limits the corona current density in
each electrical section to a much lower
level. This would result in lower spe-
cific corona power for an ESP of similar
size designed for eastern coals. The ESP
size, therefore, would need to be larger
to achieve the necessary particulate col-
lection, as dictated by the specific corona
power considerations.
ESP Performance and Testing Data
The remainder of this article reports on the
stack filterable emissions from six coal-fired
power plants, as well as the associated ESP
configuration and operating data. The discus-
sion above will be helpful when interpret-
ing the descriptions and test data from each
plant. Table 2 shows the configuration of
power plant boilers referenced in the stack
emissions review. Table 3 lists the properties
of coals used at these plants.
Plant and Fuel Descriptions. Plant 1
is an unscrubbed unit that fires a blend
Plant 1 Plant 2 Plant 3 Plant 4 Plant 5 Plant 6
NO
x
control LNB, OFA,
SNCR
LNB, OFA, SCR OFA, SNCR LNB, SOFA OFA, SCR
SO
x
control None Wet FGD Wet FGD None None None
HCl control None Wet FGD Wet FGD Dry sorbent injection of
SBC has been tested
No None
Mercury
control
None Wet FGD Wet FGD Activated carbon
injection
No None
Boiler type Opposed
wall-fired
Opposed
wall-fired
Cyclone-fired Tangential-
fired
None
SO
3

conditioning
No No No Yes, > 20 ppm
injection rate for ash
conditioning. Non-SO
3

conditioning also tested.
No None
Ammonia
conditioning/
other SO
3

mitigation
No Yes,
for SO
3

mitigation
Yes, for SO
3

mitigation
following
SCR
addition
No No Yes, for SO
3

mitigation
following SCR
addition
Notes: LNB = low NOx burners, OFA = overfire air, SNCR = selective noncatalytic reduction, FGD = flue gas desulfur-
ization, SBC = sodium bicarbonate.
Table 3. Coal-fired power plant operational information of tested units.
Source: Babcock & Wilcox Power Generation Group Inc.
Table 2. Coal-fired power plant configurations of tested units. Source: Bab-
cock & Wilcox Power Generation Group Inc.
Coal type PRB/
eastern
coal blend
Eastern
bituminous
Eastern
bituminous
PRB PRB Eastern
bituminous
Coal data, as
recd, avg.
values (Btu/lb)
10,225 12,070 Similar to
Plant 2
8,800 8,800 Similar to
Plant 2
Ash (%) 6.6 10.7 - 5.4 5.3 -
Moisture (%) 20 8 - 27 27 -
Sulfur (%) 0.9 3.3 - 0.3 0.3 -
Ash, LOI (%) 2 NA NA 9 to 10
moderate sodium in
ash (1.3% to 1.7% as
Na
2
O)
5.3 lower
sodium in ash
(1.30% as Na
2
O)
than Plant 4
9 to 10
after
installation
of OFA
Notes: LOI = loss on ignition, OFA = overfire air.
|
April 2013 42
EMISSIONS CONTROL
of PRB coal and eastern high-sulfur Pitts-
burgh No. 8 coal. For NO
x
control, this
plant employs low-NO
x
burners (LNBs)
and overfire air (OFA). The plant also
utilizes selective noncatalytic reduction
(SNCR) as an additional NO
x
control.
There is no dedicated fly ash conditioning
system in use at this plant.
Plants 2 and 3 fire eastern high-sulfur
coal. They both utilize open tower wet
FGD for SO
2
control and LNB and SCRs
for NO
x
control. Both plants also utilize
SO
3
mitigation techniques to control the
increase in SO
3
produced after SCRs were
installed. Plant 2 utilizes sodium-based in-
jection ahead of the ESPs. Plant 3 utilizes
ammonia injection ahead of the ESPs.
Plants 2 and 3 are equipped with particu-
late matter CEMS to monitor stack filter-
able emissions.
Plant 4 is an unscrubbed unit firing
100% PRB coal. SO
3
injection is normally
used. Considerable additional testing was
conducted with injection of activated car-
bon for mercury control and sodium bicar-
bonate for HCl control ahead of the ESPs.
To prevent the adverse impact of SO
3
on
activated carbon injection (ACI) effective-
ness, a proprietary, non-SO
3
-based alter-
native fly ash conditioning technique was
also evaluated.
Plant 5 utilizes 100% PRB coal, but with
slightly lower sodium content in its ash as
compared with Plant 4. This plant utilizes
both OFA and LNB for NO
x
control. Plant
5 is also unscrubbed and does not use fly
ash conditioning.
Plant 6 utilizes eastern high-sulfur
coals. It also employs OFA. This plant
utilizes ammonia injection to control the
increase in SO
3
produced after SCRs were
installed.
Table 4 shows the relevant details of
each ESP and the actual ESP operating in-
formation during the testing period. Plants
1, 3, 4, and 6 utilize the North American
style ESP design, which consists of single-
piece electrodes, weighted wire, and rigid
discharge electrode geometries. These de-
signs utilize top-mounted rappers, located
outside of the flue gas stream, to dislodge
ash collected on both collecting and dis-
charge electrodes. Plants 2 and 5 utilize
the European-style ESP design, with mul-
tiple-piece discharge electrodes hung be-
tween electrode supports in a bed-spring
manner.
In sum, the most important parameters
affecting ESP performance, as presented
in Tables 2, 3, and 4, are:
Average operating corona current density
ESP inlet temperature
ESP design
arrangement
Weighted wire
discharge electrodes,
top rapped
Rigid mast bed frame
with twisted wires,
top rapped
Weighted wire
and rigid discharge
electrodes, top rapped
Weighted wire
discharge electrodes,
top rapped
Bed frame discharge
electrodes, bottom
rapped
Weighted wire
and rigid discharge
electrodes, top rapped
ESP inlet temp (F) 297 319 315 315 358 295
Gas velocity (ft/sec) 6.1 4.3 NA 6.6 5.3 NA
Aspect ratio 0.83 0.6 NA 0.8 1.72 0.9
Treatment time (sec) 4.9 5.5 NA 3.6 14 NA
Average corona
current density
(mA/1,000 ft
2
)
54 15.8 32 52 17.5 33
Stack filterable
emissions (lb/MMBtu)
0.019 0.015 0.003 0.028 0.014 0.015
Filterable emissions
test method
5 Method 5 w/certified
PM CEMS
(after wet FGD)
Method 5 w/certified
PM CEMS
(after wet FGD )
5 5 5
Notes: CEMS = continuous emissions monitoring system, FGD = flue gas desulfurization.
Table 4. ESP operational data from tested units. Source: Babcock & Wilcox Power Generation Group Inc.
0.050
0.045
0.040
0.035
0.030
.0.25
0.020
0.015
0.010
0.005
0.000
F
i
l
t
e
r
a
b
l
e

o
u
t
l
e
t

e
m
i
s
s
i
o
n
s

(
l
b
/
m
m
B
t
u
)
ESP specific power (watts/1,000 acfm)
100
Kumar-Feldman prediction Recent full scale data Plant #4 data WFGD outlet data
0 200 300 400 500 600 700 800
5. Final test results. Filterable emission versus ESP specific corona power. Note the Ku-
mar-Feldman prediction line that is referenced in this article. Source: Babcock & Wilcox Power
Generation Group Inc.
|
April 2013 44
EMISSIONS CONTROL
ESP residence time
If ash conditioning or SO
3
mitigation tech-
niques have been employed
Fireside NO
x
control techniques
Specific ESP corona power
ESP Corona Current Density Perfor-
mance. Plants 1, 3, 4, and 6 show operating
corona current densities between 32 and 54
mA/1,000 ft
2
. This is indicative of a well-en-
ergized precipitator collecting ash that is well
conditioned and properly conductive.
Plants 2 and 5 show operating corona
current densities of 15 to 18 mA/1,000 ft
2
.
This is at least a factor of two less than
the values reported for Plants 1, 3, 4, and
6 and is indicative of process differences
that could result in less-conductive ash
limiting the corona current input to the
ESPs. The ESP behavior of Plant 5 can
be generally explained as due to a com-
bination of variations in the coals sodium
content and a relatively high operating
inlet temperature. However, the reasons
for Plant 2 performing at a relatively low
operating corona current density level on
eastern high-sulfur coal application have
not yet been fully researched.
ESP Specific Corona Power Effect
on Emissions. Based on operating volt-
age and current density data on ESPs from
these six plants, and their respective SCA,
ESP specific corona power values were
developed for each of these plants, utiliz-
ing the approach discussed earlier in the
research review section. Figure 5 plots the
stack filterable emissions data collected
from each of these plants.
To better understand the relationship
between ESP specific corona power and
filterable emissions, three separate curves
are plotted in Figure 5. First a predicted
curve based on SCA versus collection effi-
ciency relationship is developed; second, a
trend line based on data from Plants 1, 4, 5
and 6 (all unscrubbed units) is created; and
finally, a trend line is added based on data
from Plants 2 and 3 (both of which have a
wet FGD system following a dry ESP).
From Figure 5, the following observa-
tions about the ESP performance on the
unscrubbed units is possible:
Though the predicted values of filter-
able emissions would be higher than
0.03 lb/MMBtu in most cases based on
the Kumar-Feldman line for ESPs oper-
ating specific corona power densities of
350 to 400 watts/1,000 acfm, all of the
dry ESPs were able to operate below the
MATS filterable emissions standard of
0.03 lb/MMBtu.
Among the unscrubbed units, Plant 4
shows significant additional filterable
reductions of 0.015 lb/MMBtu when the
ESP was operating with an alternative,
non-SO
3
fly ash conditioning system.
Plant 4 was able to retain the same low
emission levels with a non-SO
3
ash con-
ditioning system even when ACI and so-
dium bicarbonate injection testing were
conducted at this plant, and without loss
of the high ESP specific corona power.
Stack filterable emissions of Plant 2 at
the wet FGD outlet following a small,
two-field dry ESP operating at specific
corona power of about 150 watts/1,000
acfm consistently showed filterable
emissions below 0.02 lb/MMBtu. For
an ESP-only configuration, the Kumar-
Feldman curve predicts filterable emis-
sions in excess of 0.05 lb/MMBtu for
the operating specific corona power
level.
At Plant 3, the dry ESP was operating
at a specific corona power level of 320
watts/1,000 acfm. The stack filterable
emissions after the wet FGD showed val-
ues of 0.003 lb/MMBtu from PM CEMS
data (utilizing a certified method based on
EPA Method 5B). Based on the Kumar-
Feldman prediction, a standalone dry ESP
would perform at levels much higher than
0.03 lb/MMBtu.
Interpretation of the Observations.
Test data on stack filterable emissions have
shown that well-operating ESPs can handle
both eastern high-sulfur coals and PRB
coals. Proper fly ash conditioning seems es-
sential for achieving this result. Several spe-
cific conclusions can be drawn from the data
collected from the six plants and the observa-
tions presented above.
Most promisingly, the stack filterable
emissions testing on stations where ESPs are
followed by wet FGDs indicate that consid-
erable additional particulate collection can be
realized. Additional research seems necessary
to determine the mechanisms controlling this
important particulate control co-benefit.
These observations have significant im-
plications for plant operators interested in
reduced particulate emissions:
Stack filterable emissions data after wet
FGD systems on Plants 2 and 3 cannot
be explained without significant addi-
tional collection occurring across the
wet FGD. Though this co-benefit phe-
nomenon is not altogether surprising
based on the research review presented
earlier, currently there is a scarcity of
publicly available literature validating
the particulate collection mechanisms
that are possible across a relatively
lowpressure drop device such as an
open tower wet FGD.
The trend line of ESP performance on
unscrubbed units in Figure 5 indicates a
consistent under-prediction by a value be-
tween 0.010 and 0.015 lb/MMBtu as com-
pared to the Kumar-Feldman line. Though
this represents no more than a 15% dif-
ference for older units operating at filter-
able emissions of 0.10 lb/MMBtu, it could
have much greater significance for plants
operating near the 0.03 lb/MMBtu level.
Because most of the plants profiled em-
ploy some form of fireside modification
technique to reduce flame temperature,
are these plants also reducing the fine
particulate concentrations in fly ash dur-
ing the practice of this and other NO
x
-
reduction techniques? Additional testing
will be necessary to determine if fireside
modifications to reduce NO
x
could also
result in reductions of fine particulate
matter in fly ash.
It is significant that the data from Plant 4
indicates a factor of two differences in fil-
terable emissions between ESP operation
with SO
3
and non-SO
3
conditioning agents.
Carefully consider the potential damage to
probe filters resulting from condensed sul-
furic acid as well as the data bias caused
particulates collecting on the probe. It ap-
pears that all SO
3
mitigation techniques
tend to avoid the bias that acid mist aero-
sols can introduce into test results.
The testing and analysis also left several un-
answered questions that suggest additional re-
search is required to fully understand the impact
of ESP performance on filterable emissions:
What is the explanation for the optimistic
ESP performance based on stack testing
and evaluation at the six power plants?
Could the positive bias from condensed
SO
3
be a factor in the overprediction by
the Kumar-Feldman curve?
Could the past curves of overprediction be
a direct result of suboptimum control of
ash re-entrainment from ESPs?
Could the use of ESP specific corona pow-
er suggest that the quality of the power ap-
plied to the ESP may improve filterable
emissions?
Could use of pulsed energization, high-
frequency power supplies, or three-phase
power supplies have an impact on filter-
able emissions?
K.S. Kumar (kskumar@babcock.com) is
business development manager and J.A.
Knapik (jaknapick) is technical consultant
for the Babcock & Wilcox Power
Generation Group Inc.
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2
Global Business Reports // POWER UAE April 2013
www.gbreports.com
Global Business Reports
POWER UAE
Dubai, meanwhile, retains a much more
bundled approach to power governance
through the Dubai Electricity and Water
Authority (DEWA). DEWA owns and oper-
ates 11 plants varying from 400 MW to
1,400 MW with a total capacity of almost
9,000 MW. DEWA has stated intentions
to move towards an IPP model, however
phase one of the irst IPP project ten-
dered was subsequently deferred, creat-
ing uncertainty over the future of such a
model in the emirate.
Hassyan was to be Dubais irst partially
private-owned power plant and through
its six phases would have reached an
impressive total capacity of 9,000 MW.
The initial tender in 2009 was eventually
deferred indeinitely in April 2012, DEWA
stating oficially that capacity would be
made up through eficiency measures.
Consortiums would have spent in the
region of $3-5 million preparing their
bids, so a deferral at that stage would
have been extremely disappointing for all
those involved.
On the possibility of a Hassyan
re-tender, David Charlier, partner at
Ashurst commented: Although the de-
ferral was not ideal and it will have dent-
ed bidders conidence, many developers
and lenders were enthusiastic about the
opportunity to do the irst IPP in Dubai so
I suspect that if DEWA were to re-tender
there would be interest. DEWA will need
to consider how to address the concerns
of potential bidders and to convince them
that the project will go ahead.
A great deal of uncertainty remains
on the future of the Hassyan tender and
Dubais IPP model in general. As Dubais
economy continues to grow and develop,
there will be further requirements for in-
creased foreign investment for the con-
struction and operation of power plants.
The ive smaller emirates, or northern
emirates (Sharjah, Fujairah, Ajman, Ras
Al Khaimah and Umm Al Quwain), pos-
sess minimal natural resources and are in
a much earlier stage of industrial devel-
opment. Each is seeking to build on core
industrial sectors and encourage foreign
investment to spur economic growth.
Economic development of the northern
emirates will result in an increasing de-
mand for electricity, to which Abu Dhabi
has committed to providing in the short
to medium term through expansion and
diversiication of its own power sector.
Generation:
Diversiication in motion
As it stands today, 97.5% of power gen-
eration across the country comes from
natural gas-powered plants. However the
next 10 years will see the introduction of
a nuclear program in Abu Dhabi and the
highly anticipated move towards renew-
able technologies, namely solar power,
which holds huge potential in this desert
environment. The push towards power
diversiication is in line with the strategy
of industrial diversiication away from
fossil fuel dependence. For Dubai this
will reduce the cost of liqueied natural
gas (LNG) imports, while in the case of
Abu Dhabi diversiication will give greater
opportunities for export of its remaining
hydrocarbon resources. The UAE might
well have enough gas to last until 2030 or
2050, but it doesnt want to take the risk,
says the regional manager of Hatch, Roy
Dabbous on the push for nuclear power.
In the last four years, there has been
good push to develop the more of the
UAEs sour gas ields. These tend to cost
more and require greater diligence when
it comes to HSE Dabbous continues.
Nuclear
Abu Dhabis nuclear program is the irst
nuclear project in the Gulf Cooperation
Council (GCC), the political and economic
union made up of Saudi Arabia, Kuwait,
Bahrain, Qatar, Oman and the UAE. Abu
Dhabi established the Emirates Nuclear
Energy Cooperation (ENEC) in Decem-
ber 2009 to oversee the nuclear sector,
beginning with the establishment of four
nuclear reactors in the Barakah region of
western Abu Dhabi. The tender for the
project was contested by a number of con-
sortiums including GE-Hitachi, EDF-Areva
and the eventual winners Korea Electric
Power Company (KEPCO) with compa-
triot partners Samsung and Doosan. The
irst reactor is set to come into operation
in 2017, with the fourth to be completed in
2020. Combined, they could make up as
much as 25% of the emirates electricity
capacity, providing the primary baseload
of power demand. Our project is today
regarded as employing global best prac-
tice, so ENEC is being looked at as a role
model. This is something to be proud of,
but not complacent about: we have a long
journey ahead of us, states Mohammed
Al Hammadi, CEO of ENEC.
Solar
Another key element in the UAEs forth-
coming era of diversiication is the highly
anticipated adoption of renewable ener-
gies, namely solar power. The regions ide-
al climate for solar technology has been
matched by the commitment of govern-
ments in Abu Dhabi and Dubai. The Abu
Dhabi government, through its invest-
ment arm Mubadala, has established
Masdar City to advance renewable ener-
gy and sustainable technologies through
education, research and development,
investment and commercialization. Along
with regional ofices for major players in
the power sector such as Siemens and
Boeing, Masdar City will also be home to
the United Nations International Renew-
able Energy Agency (IRENA). The main
reason for placing IRENAs headquarters
in the UAE was the countrys dedication
to renewable energy. Despite being rich
in hydrocarbons, the UAE still has a very
2 pv mini power plant - csem-uae. Courtesy of CSEM
5
5
www.gbreports.com
POWER UAE
director of clean energy. Masdar is the major partner in the
UAEs irst major solar project, Shams One, a 100 MW solar park
in the desert of Abu Dhabi, constructed in association with Total
and Abengoa Solar. Dubai has also made its intentions clear with
the announcement of the 1,000 MW Mohammed Bin Rashid
Al Maktoum Solar Park, which began construction in late 2012.
A debate still runs within the solar industry about which tech-
nology is best suited to this market; photovoltaic (PV) or con-
centrated solar power (CSP). There should, however, be space
for both in the UAE; each technology is good, and people who
talk about the front-end investment cost advantages of PV are
taking too simplistic a view. What you should do is calculate
costs across the 20-25 year life cycle of a power plant suggest
Tonjes Cerovsky, senior VP of sales in the Middle East and Africa
region for KSB.
The 100MW Shams One project has chosen a hybrid CSP and
gas model but when comparing the two technologies, Yousif
Al Ali, general manager of Shams Power Company, suggests:
In 2008, CSP technologies were still cheaper than photovol-
taic (PV); however, as a result of the inancial crisis and large
excess production capacity in China the price of PV dropped
dramatically. Accordingly the generation of electricity from PV
became very competitive, with electricity prices from PV now
below those of CSP. If the dispatch-ability is not that important,
companies will go with the cheapest technology, which at the
moment is PV. When countries begin to increase the percent-
age of renewable energy in the system, they will need a reliable,
dispatch-able source of energy, and thus they will initially need
to go for a mix.
It is clear that this region should make full use of its ideal
climate for utilising solar power. However, despite the year round
sunlight and cloudless skies this harsh desert environment cre-
ates some unique challenges for solar installations. This is not
as good a place for solar power as the likes of North Africa, Aus-
tralia and Chile, which have excellent direct sunlight, but it is
the second best points out Hamid Kayal, CEO of CSEM-UAE.
The main two concerns in the Middle East with regard to solar
deployment are the high heat and dust, and our technology out-
performs in both these aspects, explains Matt Merfert, project
manager at First Solar, whose thin ilm PV modules have been
chosen for phase one of the Dubai project.
There is a clear advantage for thin ilm when it comes to util-
ity-scale plants, and most of the new markets have large-scale
plants. Less electricity is used to produce the thin ilm modules,
adds Christopher Burghardt, First Solars VP of business devel-
opment, referring to the reduced time of energy payback from a
more eficient manufacturing processes.
The market is looded with solar-related irms positioning
themselves to make the most of the highly anticipated boom
in projects. Yet this has been the case for some years now, and
the most signiicant obstacle to the establishment of solar pro-
jects remains: the lack of a regulatory framework in place to give
conidence to both potential investors and the utility companies.
However, there is a case to be made for patience. Although
the lack of regulatory framework is an obstacle to the develop-
ment of the solar industry, rushing the process as in the case
of Jordan results in a framework that many ind overly com-
plex, perhaps dificult to understand. The real challenge for the
UAE is whether it can create a regulatory regime to give the cer-
tainty to attract investment without it being overly complex and
prescriptive, suggests Micheal Rudd of legal irm Bird & Bird.
Clean Coal
Optimizing the extent of diversiication is the construction of a
clean coal plant in the emirate of Ras Al Khaimah by Utico in part-
nership with Shanghai Electric. The UAE has no signiicant coal
reserves and as a signatory to the Kyoto protocol on CO2 emis-
sion reduction, the choice by Ras Al Khaimah for a coal power
plant appears a little surprising at irst. The 270MW plant is set
Central Courtyard of the Masdar Institute Campus, Masdar City
8
Within the UAE the transmission and
distribution network must keep up with
the growth and development of the sec-
tor. The role of smart grids is central to
balancing demand and supply in a diversi-
ied power sector. Investments in distri-
bution and generation must be synchro-
nized and linked to the existing grid, with
a focus on issues such as load-shedding,
explains Goktug Gur, country president of
Schneider Electric.
The transmission and distribution mar-
ket is becoming very competitive in the
build up to these necessary develop-
ments. However as Pradip Kumar Das,
general manager of Gulf Jyoti International
explains: Most of the projects in the coun-
try set prequaliication conditions; utility
companies want to award the contracts
to experienced contractors. Our challenge
at the moment is our experience, and ive
years will give us enough time to build this
experience and become the number one
player in the region, says Kumar Das.
All the major players in the power sec-
tor are now present in the region and
newer companies are looding in year af-
ter year. Abu Dhabi is mainly focused on
cap-ex investment for new projects, Dubai
on op-ex to improve existing systems.
Dubai has also taken the initiative in solar
power, while Abu Dhabi needs more prop-
erty developments to make it attractive to
migrants. The UAE is very challenging in
terms of competition; the market is crowd-
ed with traditional companies as well as
newcomers from the Asia-Paciic region,
says Goktug Gur, country president of
Schneider Electric.
Although we can be fairly sure that there
will be a continuous stream of projects
across the power sector, the competition
will remain ierce for some time in such a
congested market.
The future
The GCC sits on the cusp of a power
revolution, with investments in the sector
estimated at over $250 billion in the next
ive years. The rest of the region will be
assessing the success of the application
of new energy sources, the balancing of a
diversiied power sector and perhaps most
crucially the style of inancial and regula-
tory regimes. The next ive to ten years
will be crucial in shaping not only the UAE
power sector, but the GCC and the wider
Middle East region.
www.gbreports.com
POWER UAE
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April 2013
|
POWER IN CHINA
Wind Power Incidents in China:
Investigation and Solutions
Chinas installed wind power capacity has doubled for six consecutive years.
However, along with the increased capacity come wind power accidents,
incidents, and failures. Considering the sharply rising amount of wind
power, the authors examine and sort wind technology failures by type
and explore their causes in an effort to offer solutions.
By Zeng Ming, Xue Song, Li Ling-yun, Cheng Huan, and Zhang Ge, School of Economics and Management, North China Electric
Power University
C
hina has abundant and readily devel-
opable wind resources. According to
relevant data, the exploitable on-land
wind energy resource represents a power
generation capacity of 2,380 GW; the off-
shore wind energy resource is around 200
GW. Chinas wind resource is centralized,
and the wind energy potential of the three-
north area (composed of north, northeast,
and northwest China) as well as the coun-
trys southeast coastline and islands along
the coast accounts for 80% of that potential.
The geographic distribution of the wind re-
source somewhat coincides with Chinas coal
resource, although it is generally not coinci-
dent with load.
In 2011, some 11,409 wind turbines were
installed in China (excluding Taiwan), repre-
senting 17.63 GW of installed capacity. By the
end of 2011, the total capacity of wind turbines
in China equaled 62.36 GW, representing an
annual growth rate of 39.4% (Figure 1).
Compared with installed capacity, grid-in-
tegrated capacity and grid-integrated output
are more effective ways to measure the qual-
ity of Chinas wind power industry growth.
With the development of advanced technol-
ogy, grid-integrated capacity is increasing
annually, and rose from almost 31.6 GW in
2010 to 45 GW in 2011 (Figure 2).
The rate of growth in the development of
wind power is slowing, but grid-integrated
capacity is increasing, which indicates that
the number of projects not integrated with
the grid is falling. This suggests that Chi-
nas wind power industry is developing in a
healthy way, albeit gradually.
As grid-integrated capacity rises, so
too does wind power production. In 2007
wind generated 5.7 billion kWh and ac-
counted for 0.17% of Chinas total power
production. As the table shows, by 2011
wind power production stood at 73.2 bil-
lion kWh and accounted for 1.55% of the
countrys total electricity production.
1. Growing wind capacity. Newly added and total installed capacity in China between
2006 and 2011. Source: North China Electric Power University
2. Grid-integrated wind capacity. Newly added and total grid-integrated wind gener-
ating capacity in China between 2006 and 2011. Source: North China Electric Power University
70,000
60,000
50,000
40,000
30,000
20,000
10,000
0
2006 2007 2008 2009 2010 2011
I
n
s
t
a
l
l
e
d

c
a
p
a
c
i
t
y

(
M
W
)
Newly added Total
1,290
2,540
3,310
5,850 6,150
12,000
12,800
25,800
18,930
44,730
17,630
62,360
50,000
45,000
40,000
35,000
30,000
25,000
20,000
15,000
10,000
5,000
0
2006 2007 2008 2009 2010 2011
G
r
i
d
-
i
n
t
e
g
r
a
t
e
d

c
a
p
a
c
i
t
y

(
M
W
)
Newly added Total
1,010
2,070 2,130
4,200 4,190
8,390 9,210
17,600
13,990
31,590
13,410
45,000
|
April 2013 54
POWER IN CHINA
Wind Power Incidents in China
The rapid pace of wind power development in
China has brought with it issues such as excess
capacity, difficulties in grid integration, and
myriad problems associated with quality. These
issues could impede developing still more wind
power. Data analysis suggests that wind power
incidents may be divided into two classes: trip
accidents and equipment faults.
Turbine trip incidents are very common. In
2010, there were 80 trip incidents, 15 of which
resulted in the loss of 100 MW to 500 MW of
electricity. In 2011, 193 turbine trip incidents
occurred between January and August, of which
54 resulted in the loss of 100 MW to 500 MW
of capacity. Another 12 incidents resulted in the
loss of more than 500 MW of capacity.
An analysis of statistics related to equipment
faults among wind-power companies shows
that starting in 2010, the number of wind tur-
bine faults has been increasing. Parts such as
the pitch system, frequency conversion system,
electrical system, control system, gearbox, gen-
erator, and yaw systems have been affected, as
shown in Figure 3.
The technical performance of some wind tur-
bines falls short of meeting the requirements of
safe grid integration. In particular, most turbines
that have been put into use do not have low-
voltage ride-through capability. Efforts aimed at
improving this capability have been hampered
because many wind farms lack a retrofit plan.
This failure to plan for low-voltage ride-through
has resulted in seemingly endless arguments
about retrofit fees and has led to shelving some
reconstruction plans altogether.
Retrofit fees can be high, putting great pres-
sure on operators; its also not easy to prepare a
reconstruction plan. For those turbines that were
put into service early on and whose capacity is
below 1 MW, technical difficulties exist con-
cerning their reconstruction. Furthermore, some
wind farms are poorly managed, and many man-
agers are afraid of reconstruction. As a result, a
few wind farms have stated that they could not
complete reconstruction until 2014; a few wind
farms are not studying the issue at all.
A second issue involves reactive power com-
pensation devices in some wind farms that could
not satisfy grid safety operation requirements.
Most wind farm turbines either are not capable
of regulating reactive power dynamically or their
capacity and regulation speed are incapable of
satisfying grid operation requirements. In a few
instances, reactive power compensation devices
are absent altogether or older devices are run-
ning with a fixed capacitor (reactance) group,
which requires operation that does not regulate
voltage automatically. Other wind turbines have
limited systematic voltage regulation capabili-
ties. Wind turbine monitoring systems provided
by manufacturers often do not offer access to
users or are not capable of regulating power fac-
tors online. Hence, turbines cannot effectively
manage voltage regulation, which increases the
difficulty of systematic reactive regulation and
leads to some wind farms being equipped with
more reactive devices than necessary.
A third issue is construction faults in the
design of some wind farms. For example,
35-kV collector systems in some wind farms
are designed by mechanically referring to the
design standard of the conventional distribu-
tion network, which results in using improper
grounding methods. As a result, operators
are unable to quickly cut off the selected line
when there is single phase fault, which may
lead to accidents and grid disconnection. In
addition, the type of step-up transformer cho-
sen is based on selected distribution network
design principles; package transformers are
widely adopted and more cable terminations
are used than are necessary. As a result, cable
termination fault becomes a main cause lead-
ing to wind farm accidents.
In Chinas southeast coastal areas, wind tur-
bines in some instances are installed without
considering microsite factors, which may af-
fect turbine safety and performance. As a result,
when typhoons create strong turbulence, equip-
ment accidents occur, such as collapsed tow-
ers and broken blades. Other design problems
include improperly positioned leading wire and
improperly secured cable structures, which can
lead to excessive vibration in high winds.
In other cases, major construction quality de-
ficiencies exist. This is the result of some wind
farm construction organizations focusing main-
ly on expediting development while putting
little thought into management. Specifically,
quality, testing, control, and acceptance inspec-
tions are not carried out in strict accordance with
the rules. Whats more, some developers do not
have effective control and management over
construction quality. In some cases, unqualified
organizations perform the primary work.
Recently, more wind power equipment
manufacturers are starting up in China; their
number currently stands at more than 80. To
reduce costs, a few manufacturers have ad-
opted low-cost components, which reduce
equipment quality even as they reduce ex-
penses. Whats more, some domestic wind
turbines are put into use without field opera-
tion tests; hence, turbine accidents typically
occur during construction or soon after the
machines are put into use. In some instances,
the entire turbine falls down, the main shaft
breaks, the motor catches fire, the gearbox
becomes damaged, and blades rupture.
At present, Chinas wind power system is not
sound, and technical standards lag far behind
those in other nations. National technical stan-
dards have not been set, and technical standards
for the centralized control of wind farmsalong
with standards for system design, integration,
and monitoringare still on the way.
Year
Wind power production
(billion kWh) Growth rate (%)
Share of total power
generation (%)
Average utilization of
wind power (hours)
2007 5.7 NA 0.17 NA
2008 13.1 126.79 0.38 2,046
2009 27.6 111.14 0.75 2,077
2010 49.4 78.9 1.17 2,047
2011 73.2 48.16 1.55 1,903
Note: NA = not applicable.
Wind power production in China 20072011. Wind powers share of total energy
production has risen in recent years, but it remains a small part of Chinas overall generation
mix. Source: China National Electric Power Industry Statistics Bulletin
Impeller
Brake system
Hydraulic system
Gearbox system
Generator system
Pitch regulation system
2,000
Jan. Aug. 2011 2010
4,000 6,000 8,000 10,000 12,000 14,000
3. Wind turbine accident classifications. Parts such as the pitch system, frequency
conversion system, electrical system, control system, gearbox, generator, and yaw systems
have been most affected. Source: North China Electric Power University
April 2013
|
POWER IN CHINA
Solutions and Suggestions
Given the problems outlined above, China
should endeavor to take action toward the
following three goals.
Strengthen Research on Key Tech-
nology and Perfect Wind-Equipment
Manufacturing Industry Policies to Com-
prehensively Improve Manufacturing.
Industry policy improvements are required to
make the equipment manufacturing industry
avoid irrational competition. Strict equip-
ment manufacturing standards and authen-
tication systems should be established, and
wind turbine series directories and standard
accessories should be set up to guide orderly
research and development.
Efforts should be made to strengthen re-
search efforts on key pieces of equipment
with more investment devoted to technology
innovation. As a start, China should arrange a
series of major projects in wind power manu-
facturing to improve wind turbine design and
development with an eye toward reliable and
stable operations.
China Should Adopt a Comprehensive
Approach to Wind Resource Planning. As
a first step, policies should encourage taking a
comprehensive approach to wind power and the
construction of transmission lines. China should
keep a balance and a connection between wind
power development and the grids construction.
In areas where wind resources are abundant,
grid construction should be enhanced and at-
tention should be paid to improving the grid to
meet the requirements of wind power develop-
ment. Moreover, China needs to strengthen the
construction of tie-lines between provinces to
improve transmission as well as the grids abil-
ity to accept wind power.
As a second step, China must better inte-
grate wind power, peaking power supplies,
and frequency-tuned (frequency regulation)
power supplies. The construction of flexible,
dispatchable power sources such as pumped-
storage power plants, gas-fired plants, and
conventional hydropower plants should be
speeded up, and fossil-fueled plants could
be encouraged to take part in peak-regulating
operations. Whats more, policies aimed at
linking renewable energy and frequency-
tuned power sources should be carried out
to promote the coordinated development of
wind power, thermal power, and hydropower.
These could be further expanded to meet the
demand of large-scale grid integration.
As a third step, China should take a com-
prehensive view of economic development
and wind power development planning to
ensure resources are developed on the basis
of available wind resources and local load.
China also needs to make the location of en-
ergy-loaded industries compatible with those
areas rich in wind resources.
As a fourth step, China needs to add more
ways to consume wind power at its point of
production. China should combine both dis-
tributed and centralized wind power, encour-
age areas to utilize distributed wind power,
strengthen the construction of distribution
networks, and improve in-situ wind power
consumption. Furthermore, China needs to
strengthen demand-side management in ar-
eas rich in wind power, improve load char-
acteristics, and encourage and use smart grid
technologies to promote the consumption of
wind power.
As a fifth step, China needs to build an in-
formation communication mechanism for wind
energy exploration and grid planning. China
should appropriately arrange early grid engi-
neering work according to relevant departments
wind power and transmission planning, making
efforts to keep grid construction and wind power
development in step with one another.
Improve National Regulations and
Standards. China should build a national
wind-power standard and regulation system that
covers the process of research and manufactur-
ing, planning and construction, installation, inte-
gration detection, and operation management in
an effort to promote the standard development
of its wind power industry.
Relevant policies that promote the wind
power industry need to be improved. Ad-
ministrative regulations and policies that
support renewable energy law need to be
developed, including price subsidies for
peak and frequency regulation, and rea-
sonable compensation standards for grid
integration.
Moreover, policies need to be developed
covering the on-grid price of distributed
wind power, peak and off-peak prices on the
supply side, and interruptible prices on the
demand side to help promote wind power
consumption.
Finally, studies should be undertaken to
examine green-certificate systems and con-
sumption policies that encourage renewable
energy subscriptions.
Pursuing these steps will help encourage
the whole of Chinese society to actively ex-
plore and consume renewable energy such as
wind power.
Zeng Ming, Xue Song, Li Ling-yun,
Cheng Huan, and Zhang Ge are with
the School of Economics and Man-
agement, North China Electric Power
University, Beijing, China. The authors
may be contacted through Li Ling-yun at
lilingyunncepu@126.com.
www.stanleyconsultants.com
800.553.9694
Global Engineering Service Provider
Energy. Environmental. Transportation. Water.
COLLABORATE
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to your complex Power Generation
needs. We listen to your concerns and
evaluate your options to engineer a
solution that will work for you now
and in the future.
|
April 2013 56
MERCURY CONTROL
Enhancing Mercury Capture:
An Asset-Based Approach
The Mercury and Air Toxics Standards will soon force many coal-fired plants
to install mercury-specific emission control equipment. Planners can use
particular characteristics of a plant to quickly screen for the best mercury
removal technology.
By Dr. Michael Trovant, Hatch Consultants Inc.
B
arring successful legal challenges, the
U.S. Environmental Protection Agen-
cy (EPA) has mandated that utility
boilers achieve compliance with new Mer-
cury and Air Toxics Standards (MATS) by
April 2015. While site-specific extensions of
up to one year may be granted in certain situ-
ations, the majority of facilities are expected
to upgrade their flue gashandling systems
to meet the new standards on a timely basis.
MATS is primarily intended to address mer-
cury emissions, although other hazardous air
pollutants (HAPs), such as acid gases (for
example, hydrocholoric acid and hydroflu-
oric acid), heavy metals (such as arsenic and
lead), dioxins, and furans, are also targeted.
Unlike particulate, SO
2
, and NO
x
contami-
nants that can normally be captured quite
consistently with dedicated equipment, the
performance of mercury control technology
is highly dependent on multiple factors, par-
ticularly coal composition and existing flue
gas treatment equipment. As a result, the
most cost-effective and reliable upgrade op-
tion will often be site-specific.
This article outlines common factors affect-
ing mercury capture performance and pres-
ents a generalized asset-based approach for
identifying basic upgrade requirements. The
strategy focuses solely on mercury control.
Upgrades to address other regulations, includ-
ing updates required by the currently vacated
Cross State Air Pollution Rule (CSAPR) and
future National Ambient Air Quality Stan-
dards (NAAQS), are not addressed.
Brief Review of Mercury Speciation
A major consideration in the design of a
mercury control process is the chemical state
of mercury at the boiler exit, known as its
speciation. Mercury vapor typically takes
on three forms: particulate-bound (Hg
p
), oxi-
dized mercury (Hg
2+
), and elemental mercury
(Hg
0
). The distribution among the three forms
is dictated by many factors, such as coal type,
combustion process, and subsequent gas
treatment steps. A good knowledge of these
factors is critical in determining mercury re-
moval equipment requirements.
Hg
0
is generally very difficult to capture
in flue gas. By comparison, Hg
2+
and Hg
p
are
more easily collected using conventional wet
or dry flue gas treatment systems. The only
proven approach to achieving reasonable
overall removal efficiencies is to promote
low levels of Hg
0
in the flue gas at the boiler
exit and, if necessary, convert most of the Hg
0

to either Hg
2+
or Hg
p
upstream of the main
gas-cleaning equipment. The latter approach
is an essential part of the mercury emission
control design strategy for the flue gas sys-
tem; the former is primarily a function of the
boiler fuel source.
Impact of Coal Type
The type of coal or coal blend used by a facil-
ity can greatly affect the resulting distribu-
tion of mercury species in the flue gas and
the potential for subsequent conversion in
downstream treatment equipment.
In terms of mercury speciation, the three
most important characteristics of coal are
its chlorine (Cl) and sulfur content and its
tendency to produce fly ash with high levels
of unburned carbon (UBC). High-chlorine
coals (producing 500 to 2,000 ppm Cl in the
flue gas) generally promote the formation of
Hg
2+
, which is beneficial. Fly ash with high
UBC generally increases the concentration of
Hg
p
, which is also beneficial.
Higher-sulfur coals that produce more
SO
2
in the flue gas do not directly impact
mercury speciation but can interfere with
the potential of other components, including
chlorine, to oxidize mercury. While UBC in
the flue gas is a function of several boiler op-
erational variables (including load and fuel/
air distribution), bituminous coals normally
produce higher levels of UBC than subbitu-
minous coals, which in turn produce higher
levels than lignite. Other coal-related charac-
teristics, such as catalytic metal content and
even water vapor (which can have oxidation
1. Distribution of common U.S. bituminous coals, with medium to high
unburned carbon (UBC). Source: Hatch Consultants Inc.
10,000
1,000
100
0 1 2 3 4
Sulfur content of coal (% wt)
C
h
l
o
r
i
n
e

c
o
n
t
e
n
t

o
f

c
o
a
l

(
p
p
m
)
High chlorine/low sulfur
Good mercury speciation
Low chlorine/low sulfur
Poor mercury speciation
High chlorine/high sulfur
Reduced ACI performance
Low chlorine/high sulfur
Appalachian region
bituminous
Interior province
bituminous
April 2013
|
MERCURY CONTROL
interference similar to SO
2
), would also af-
fect mercury speciation, though typically to
a lesser degree.
The chlorine and sulfur contents of bi-
tuminous, subbituminous, and lignite coals
found in the continental U.S. are generally
well documented. Representative distribu-
tions are illustrated within four approximate
composition quadrants corresponding to
combinations of high or low concentrations
of both sulfur and chlorine in Figures 1, 2,
and 3. As noted, the high-chlorine/low-sul-
fur quadrant is typically the most beneficial
for mercury speciation and adsorption with
activated carbon. The low-chlorine/high-
sulfur quadrant is the most problematic,
and the remaining quadrants have the corre-
sponding mixture of speciation and adsorp-
tion characteristics.
Although extreme variations in coal com-
position exist, most bituminous coals produce
exhaust gas with fairly well-oxidized mercury
compositions and high levels of UBC. Lower-
sulfur Appalachian bituminous coals gener-
ally have higher mercury oxidizing potential,
and interior province bituminous coals have a
somewhat reduced potential. Subbituminous
coals, including Powder River Basin (PRB)
coal, have lower mercury oxidizing poten-
tial owing to lower chlorine content and less
UBC in the fly ash (though sulfur levels are
also typically much lower, which allows for
downstream gas-conditioning options). Lig-
nite coals normally have the lowest oxidiz-
ing potential of all coals, with very low levels
of chlorine and production of low-carbon fly
ash. This family of coals normally requires
more extensive mercury upgrades to achieve
reasonable collection efficiencies.
MATS compliance will require the aver-
age plant to attain an outlet mercury con-
centration of no more than 1.2 lb/TBtu (4
lb/TBtu for lignite), which corresponds to a
collection efficiency of approximately 90%
(80% for lignite). However, it is possible for
certain plants with access to very low mer-
cury content coals to achieve compliance
with existing equipment at much lower col-
lection efficiencies.
For example, facilities that do not have a
scrubber may be able to meet standards sim-
ply on a mass balance basis by switching to
low-mercury coal (though the coal will also
likely need to be low chlorine and, to comply
with likely future CSAPR regulations, low
sulfur). Another short-term strategy could in-
volve facilities with existing high-efficiency
SO
2
gas-scrubbing switching to higher-chlo-
rine coals to enhance mercury collection,
without exceeding acid gas HAP regulations.
Consequently, the demand for these unique
coal types is likely to increase for a period
of time before more stringent second-gen-
eration mercury regulations or rule changes
mandate capital improvements.
Understanding the impact of coal type
on mercury removal is an important consid-
eration in selecting mercury control equip-
ment, but a facilitys fate is not entirely
bound to its fuel.
Options for Enhancing Hg
2+
and
Hg
p
Speciation
Post-combustion mercury speciation can be
significantly altered by several means. The
required extent of conversion to oxidized
or particulate-bound mercury is dictated by
the desired degree of mercury control, the
installed gas treatment equipment, and the
system upgrades (if any) being considered.
The intent is to allow the downstream gas
treatment equipment to best capitalize on the
mercury speciation profile and maximize the
degree of capture.
Options for enhancing mercury col-
lection efficiency have been documented
extensively in the literature. A summary
of the more common options, categorized
for particulate-bound and oxidation-based
10,000
1,000
100
0 1 2 3 4
C
h
l
o
r
i
n
e

c
o
n
t
e
n
t

o
f

c
o
a
l

(
p
p
m
)
PRB region
subbituminous
2. Distribution of common U.S. subbituminous coals, with low to me-
dium UBC. Source: Hatch Consultants Inc.
10,000
1,000
100
0 1 2 3 4
C
h
l
o
r
i
n
e

c
o
n
t
e
n
t

o
f

c
o
a
l

(
p
p
m
)
Western/Gulf
lignite
3. Distribution of common U.S. lignite coals, with low UBC. Source: Hatch
Consultants Inc.
|
April 2013 58
MERCURY CONTROL
conversion routes, is depicted schemati-
cally in Figure 4 with a list of accompany-
ing advantages and risks.
As noted, wet limestone and lime flue gas
desulfurization (wet FGD) based systems
are particularly suited for capturing oxi-
dized mercury. For example, a facility using
higher-chorine/lower-sulfur fuels, with an
installed selective catalytic reduction (SCR)
unit to enhance oxidation and a downstream
wet FGD system would achieve excellent
mercury control (likely in excess of 95% cap-
ture), but it would need to run the SCR year
round and closely monitor scrubber chemis-
try to prevent re-release of mercury from the
scrubbing liquor. If coal chlorine levels hap-
pen to be lower, halogen injection could be
used to restore oxidation potential.
Dry FGD systems, particularly those
equipped with baghouses, circulating dry
scrubbers, spray dryersand, to a lesser ex-
tent, electrostatic precipitators (ESPs)can
be effective at capturing particulate-bound
mercury, in addition to having reasonable
oxidized mercury capture efficiencies. An
example of an effective dry system would be
an Appalachian bituminous coal-fired boiler
coupled with an activated carbon injection
(ACI) system upstream of a baghouse. If only
higher-sulfur bituminous coals are available,
the detrimental impact could be partially off-
set via dry sorbent injection, which can be
easily installed in tandem with ACI equip-
ment (see sidebar Three Site-Specific Sor-
bent Injection Options).
Systems having both wet and dry gas-
cleaning equipment can achieve the com-
bined benefits of both sets of options and
generally attain higher degrees of mercury
capture. This approach may be necessary
for facilities using particularly difficult coal
types, including certain grades of lignite.
The relationships in Figure 4 illustrate
the synergy that can be achieved by cou-
pling two or more mercury reduction unit
operations. With this general set of rela-
tionships established, it is now possible to
construct a road map outlining a range of
equipment combinations that satisfy mer-
cury reduction requirements.
Matrix of Mercury Control
Upgrade Options
The development of a comprehensive asset-
based methodology is a very large undertak-
ing, requiring the evaluation of a vast number
of equipment combinations, fuel grades, and
other complex process factors. A summary
matrix of the results of the asset-based ap-
proach is shown in the table. The purpose of
this table is to highlight the range of equip-
ment configurations capable of achieving
mercury reduction targets and to allow users
to identify the most attractive upgrade alter-
natives for their site on a qualitative basis.
Using the summary table is very straight-
forward:
1. Define the coal type: The coal is defined in
Step 1 (upper three rows of the table). The
coal type is specified as bituminous, subbi-
tuminous, or lignite, and the levels of sul-
fur and chlorine in the coal are defined as
high, medium, or low (coal grades/blends
in between these broad definitions will re-
quire some interpolation of the results).
2. Determine whether existing equipment
configurations are suitable: Some facilities
may be able to achieve MATS compliance
with common gas-cleaning equipment al-
ready installed to control other pollutants
such as particulate matter, SO
2
, and NO
x
.
Suitable existing equipment configura-
tions are represented by the numbered col-
umns in Step 2 (middle rows of the table)
for a given coal composition. Note that
for some coal compositions, no existing
configurations are suitable and mercury-
specific equipment upgrades are required,
as specified in Step 3.
3. Identify upgrade options, if required:
Upgrade equipment configurations are
represented by lettered columns in Step
3 (bottom rows of the table). Each con-
figuration can be expected to achieve, on
average, the required reduction in mercury
emissions for MATS compliance.
For example, a facility firing high-sulfur,
high-chlorine, interior province bituminous
coal would have five existing combinations
of equipment that would preclude the need
for any specific mercury control upgrades:
4. Many paths to compliance. Summary of the challenges and opportunities for im-
proving Hg collection from plant stacks. Courtesy: Hatch Consultants Inc.
Three Site-Specific
Sorbent Injection Options
Three primary sorbent injection pro-
cesses are used for the reduction of mer-
cury in the stack gas. Selection of the
right process is a function of the coal,
existing air quality management system
(principally, the presence of a baghouse
or scrubber), and impact on ash bene-
faction programs.
Activated Carbon Injection (ACI).
Powdered porous activated carbon is in-
jected into the flue gas in a uniformly dis-
tributed and well-mixed manner to adsorb
mercury. The spent carbon is captured in a
particulate collection device. Treated and/
or alternative agents can also be used.
Halogen Injection (HI). Halogen gas
(for example, chlorine, bromine, and/or
alternative agents) is injected into the
flue gas to promote oxidation and the
formation of Hg
2+
. The oxidized mercury
is collected in a wet scrubber or other
particulate collection device.
Dry Sorbent Injection (DSI). Sorbent
(such as hydrated lime, trona, or sodium
bicarbonate) is injected into the flue
gas in a uniformly distributed manner to
absorb scavenging agents (such as SO
2
)
that compete for adsorption sites on
activated carbon and would otherwise
reduce ACI performance.
A
p
r
i
l

2
0
1
3

|
P
O
W
E
R

w
w
w
.
p
o
w
e
r
m
a
g
.
c
o
m

5
9
M
E
R
C
U
R
Y

C
O
N
T
R
O
L
Matrix of Hg control equipment options. A number of assumptions are implicit in constructing the matrix, such as using only equipment combinations that are expected
to achieve at least 90% total mercury collection efficiency (80% on lignite). Also, there are several factors that can influence activated carbon injection (ACI) adsorption efficiency that
are not accounted for in the analysis, such as using treated sorbents (considered as separate options), flue gas temperature and composition, mercury concentration and composition,
fly ash composition (for example, levels of unburned carbon, loss on ignition, and catalytic metal content), flue gas residence time and degree of turbulent mixing at ACI injection area,
and flue gas quench rates (wet systems). Other minor factors related to collection efficiency also are not accounted for in the analysis, including the impact of water vapor in the boiler
exhaust, which can inhibit the formation of Hg
2+
by scavenging the chlorinating agents. A comprehensive site-specific assessment should be conducted to confirm achievable mercury
collection efficiencies. Courtesy: Hatch Consultants Inc.
|
April 2013 60
MERCURY CONTROL
Circulating dry scrubber with baghouse.
Baghouse with wet flue gas desulfuriza-
tion (both systems).
Spray dryer absorber with baghouse
(both systems).
Selective catalytic reduction with a cold
electrostatic precipitator and wet flue gas
desulfurization (all three systems).
Selective catalytic reduction with a hot
electrostatic precipitator and wet flue gas
desulfurization (all three systems).
If the facility did not have any of the above
combinations of equipment, there would
only be one clear upgrade strategy, namely
to install upgrade option Aactivated car-
bon injection with a baghouse (one or two
upgrades, depending on whether the facility
already had a baghouse).
Conversely, a facility firing medium-
sulfur, medium- to low-chlorine lignite coal
would not be able to reliably achieve MATS
compliance with existing common gas-clean-
ing equipment and would need to consider
one of four possible upgrade strategies:
A: Combined activated carbon and halo-
gen injection with a baghouse and spray
dryer absorber.
B: Combined activated carbon and halogen
injection with a circulating dry scrubber.
C: Combined activated carbon and dry
sorbent injection with a baghouse and wet
flue gas desulfurization.
D: Combined halogen and dry sorbent in-
jection with a baghouse and wet flue gas
desulfurization.
The selected upgrade route would pri-
marily depend on any existing installed
equipment. In this case, the use of SCRs
or cold/hot ESPs may partially enhance
mercury collection, but this equipment is
considered optional, as the impact would
be small and would not likely make a sig-
nificant difference in achieving the 90%
mercury reduction target.
A quick review of the table reveals a num-
ber of important trends:
Coal type plays an extremely important
role in defining the available options for
mercury control. As we move from high-
er- to lower-chlorine coals, the possibility
of achieving high collection efficiencies
with common (existing) gas cleaning
equipment soon dissipates. This is evident
by the absence of E options for these cases
in the table. Similarly, coals producing
lower carbon fly ash require more U op-
tions, also evident in the table entries.
All else being equal, baghouses are bet-
ter suited for mercury capture than ESPs.
ESPs using SO
3
as a flue gasconditioning
agent (to meet stack opacity requirements)
are at a further disadvantage. ESPs are re-
ally only relevant for mercury control with
certain high-chlorine coals, though even in
these cases, baghouse collection efficien-
cies are still much higher.
The need for halogen injection to offset low-
7. Additive storage. This is the reagent
addition system at HBCP. Courtesy: Hatch
Consultants Inc.
5. Cleaning up stack gas. CERI testwork on wet flue gas desulfurization (FGD) at the
Huaneng Beijing Cogeneration Power Plant (HBCP). The wet FGD system was supplied by a
third party. Courtesy: Hatch Consultants Inc.
6. Front-end treatment. The programmable logic control, instrumentation, and reagent dos-
ing silo for precombustion mercury control at HBCP are visible. Courtesy: Hatch Consultants Inc.
April 2013
|
MERCURY CONTROL
er chlorine concentrations in the flue gas (and
dry sorbent injection to reduce high sulfur)
can be seen in the upgrade cases for lower
chlorine/higher sulfur coals and more so for
coals producing lower carbon fly ash. Mer-
cury control for lower-ranked coals is cur-
rently the focus of much research and will
drive the development of alternative sorbent
technology in the years to come.
The table is most effective when used to
compare the relative merit of different equip-
ment configurations for the particular char-
acteristics of a given facility (with all other
factors being equal), or to illustrate the impact
of common fuel variables on mercury col-
lection performance. In many situations, the
table can be used in helping a facility decide
the best path forward to meet mercury reduc-
tion targets. However, it is important to keep
in mind that upgrades should always be eval-
uated after consideration of all site-specific
factors, including achieving compliance with
regulations for other common pollutants, lay-
out constraints, and economic considerations.
In some cases, additional test work will be
required to verify some of the upgrade sce-
narios, including piloting trials and/or compi-
lation of site data from similar facilities.
China Embraces Mercury Reduction
Strict control of mercury and other hazard-
ous air pollutants is becoming more impor-
tant in the national environmental strategies
for most countries, especially emerging
economies where capacity is rapidly ex-
panding. Although most U.S. projects in-
volve retrofitting equipment on existing
assets, nations like China have started to
design and incorporate mercury control into
greenfield projects from the ground up. That
means those projects will have the advan-
tage of designing the new plants gas-han-
dling system to promote mercury removal
from conception, rather than as an add-on.
This experience is quickly moving Chinese
vendors to the forefront of mercury control
technology development.
China Huaneng Clean Energy Research
Institute Ltd. (CERI), a division of state-
owned China Huaneng Group, is a good
example of an equipment supplier with a re-
search-oriented mercury control focus. China
Huaneng Group has a total installed capacity
of about 115 GW, which ranks as the largest
in Asia and the second-largest in the world.
As an example, mercury removal upgrades
were recently completed at its Huaneng Bei-
jing Cogeneration Power Plant (HBCP).
One of CERIs current areas of expertise
is the development of monitoring and con-
trol systems to maximize mercury removal
with conventional flue gascleaning equip-
ment using coordinated optimization. The
company is heavily involved in research and
development with lower-mercury coals but
also designs and supplies conventional ACI
mercury removal systems for facilities with
higher-mercury coals (Figures 5, 6, and 7).
Low-mercury coals provide additional op-
portunities for low-cost compliance, because
removal efficiencies do not need to be as
high. One such approach under development
is the addition of calcium bromide or other
additives directly to the fuel coal or in the
primary air to the burners. Another approach
being implemented involves the addition of
reagent to circulation water and/or the flue
gas upstream of the plants wet FGD equip-
ment. CERI is currently conducting tests with
the overall goal of identifying operational pa-
rameters that maximize the mercury remove
effectiveness of each of these strategies.
Dr. Michael Trovant (mtrovant@
hatch.ca) is a Toronto-based consultant
specializing in flue gas handling and other
gas quality control applications at Hatch
Consultants Inc.
For more information, call Wrights Media at 877.652.5295 or visit
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April 2013 62
PLANT O&M
Steam Turbine Rotor Vibration
Failures: Causes and Solutions
Steam turbine rotors bend during operation, but the bearing and supports
are designed to keep the static and dynamic forces under control. How-
ever, bending can cause impact between stationary and rotating parts
often cascading impacts. An operator of many utility-scale steam turbines
shares its extensive field experience identifying the root cause of failures
as well as successful solutions.
By Farshad Shamoradi, Naser Mohammadi, and Mahdi Heidari Kahkesh, Ahwaz Power Generation Management Co.
R
otor bending that results in premature
failure of steam turbine blades and
other internal components is one of the
most serious problems experienced in power
plant operations. The problems often reduce
plant availability by limiting generation and
increase plant operation and maintenance
cost. Extreme rotor bending problems often
involve interaction between the turbines ro-
tor and stationary parts. Rotor bending may
be caused by a variety of static and dynamic
factors, many of which will be explored in
this article.
We begin with mechanical factors related
to the rotor, the largest rotating assembly in
the turbine. Working from the inside out, we
next look at rotor balance issues, followed by
rotor and casing misalignment problems, and
problems caused by the casing. The discus-
sion is based on the authors experiences at
the six-unit, 1,890-MW Ramin Power Plant,
located in Ahwaz, Iran. The units were com-
missioned from 1980 through 1985.
Avoid Rotor Rubs
It almost goes without saying that rubbing in
the labyrinths or diaphragms, caused by in-
sufficient clearances, disrupts the end sealing
of the rotor. This situation commonly occurs
when the high-mass rotor at operating speed
comes in contact with a stationary surface,
typically caused by a too-small clearance
between the labyrinth or diaphragm gland
seals and the rotor. Secondarily, there may be
a localized temperature increase at the point
of contact, causing increased metal tempera-
tures at the point of contact due to friction.
The forces produced by the impact of the
large rotating rotor mass with the poorly
functioning stationary seals often impress a
layer of metal on the surface of the rotor. The
rub can cause elastic deformation of the ro-
tor at the point of impact and temporary rotor
shaft bending. The shaft bending will usually
cause increased vibration levels (Figure 1).
Uneven cooling of the rotor, particularly
after shutdown, also causes the rotor to con-
tact stationary parts. After a unit shuts down,
the relatively high-temperature rotor may
bend solely due to the mass of the rotor and
the distance between bearing supports, if left
in a stationary position to cool. This situation
can cause permanent shaft bending.
The effect of a permanent shaft bend
caused by uneven cooling will immediately
appear as high rotor vibration at the next
startup. The vibration is caused by insuf-
ficient clearance between stationary and
rotating parts, as well as a shaft located off-
center in its bearing. Even if the clearance
change is small, there may be significant
rubbing along the rotor to cause damage.
Again, the rubbing causes friction between
stationary and rotating parts, localized heat-
ing of the rotor metal at the contact point,
and shaft bending.
Furthermore, uneven shaft warming
caused by rubbing between rotating and sta-
tionary parts can cause further bending of
the shaft in the same direction of the exist-
ing bow and cause additional contact with
stationary parts, increasing temperatures and
therefore causing more bending. The effect
cascades if allowed to continue. If the bend-
ing is allowed to continue, it is possible that
the yield strength of the metal could be ex-
ceeded, causing a permanent deformation of
the shaft. The allowed bending in 3,000-rpm
turbines is up to 0.020.03 mm in each sec-
tion. When on turning gearing, the limit is
0.05 mm.
To avoid rotor bending during cooling,
turbine vendors provide very specific in-
structions on the allowable rate of cooling.
For example, the turbine should remain on
turning gear until the high-pressure (HP) cyl-
inder temperature is below 150C and the oil
temperature is below 75C. The turbine ven-
dor also defines the rotational speed of the
turning gear.
Prevent Rotor and Casing
Misalignment
Misalignment of the coupling between two
shafts or between a shaft and bearing may
cause bending in the system. Misalign-
ment between two shafts of an integrated
rotor can cause an eccentricity of the mass
center of the rotor, and this eccentricity at
high rotational speed will produce a cen-
trifugal force in the radial direction, caus-
ing bending of the rotor. Misalignment
between the axis of rotation and the axis of
the shaft can also cause bending in the ro-
tor. There are six primary factors that can
cause misalignment.
A poor connection between the turbine
casing and the bearing pads on the founda-
tion frame is one cause. If a pad experiences
increased friction or stops sliding during
thermal expansion (usually during startup)
in the axial direction, the result is a tipping
torque on the casing. This torque can cause
a misalignment between the casing and bear-
ing surface, causing vibration in the forward
end of the turbine, foundation frame surface
support deformation, and bearing pad stall.
Also pay close attention to the foun-
dation frameincluding bolts, keys, and
1. Blade rubs cause bending. Rub-
bing in the sealing of a high-pressure rotor of
a 300-MW unit caused bending of this rotor
and blade tip rubs. Courtesy: Ahwaz Power
Generation Management Co.
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|
April 2013 64
PLANT O&M
padsso that free movement of the bear-
ing surfaces is possible, particularly while
undergoing startup and load changes. The
extent of the longitudinal and lateral ther-
mal expansion bore centers of the cylin-
ders and pad travel should be recorded for
future comparisons. This process should
be part of routine maintenance equipment
inspections.
Another factor concerns the difficulty
in assembling the HP turbine front bear-
ing. While the shaft is rotating in its jour-
nal bearing, the shaft pushes oil from the
bottom of the bearing, causing the oil film
thickness to change. When this happens,
the centerline of the shaft moves up and to
one side. To account for this shaft move-
ment, the segmented bearing should auto-
matically adjust and the contact surface of
the journal bearing will remain in a good
position. If there is too much contact sur-
face, friction will increase on the bearing
surface, causing increased rubbing and
corrosion of the bearing surface and in-
creasing vibration and rotor eccentricity.
The result will be bearing oil leakage and
rubbing in the sealing glands. On the other
hand, if the bearing contact area decreases,
the oil film will cause uneven movement
of the rotor within the segmented bearing,
and the oil film will not form, also result-
ing in increased vibration (Figure 2).
Dont overlook the concentricity of the
rotor with the bores and couplings. Cor-
rect rotor alignment is lost when the axis
of one rotor is not continuous with the ro-
tor in the following casing, in multi-casing
steam turbines. The individually connected
drivelines must operate as one long con-
tinuous, yet flexible driveline. After major
steam turbine maintenance, it is important
to confirm the alignment of the rotor to
the couplings as well as any other factors
that may cause change to the primary po-
sitions of individual casings, bearing, and
rotors. During maintenance, if rubbing is
observed at the end or intermediate sealing
of the rotor or eccentricity of couplings,
it is necessary to realign the driveline to
avoid high turbine vibration, contact and
rubbing of glands or labyrinth seals, and
so on (Figure 3).
Remember that the axis from the center
of the glands bore should coincide with
the axis of the turbine rotor during normal
temperatures experienced during turbine
operation. Furthermore, it is essential to
quickly identify any loss in sealing clear-
ances during steam turbine warm-up.
Changes in clearance may occur during
warming that could cause bending of the
cylinders due to differential temperatures
between the upper and lower sections of
the cylinder (Figure 4).
Finally, pay close attention to the pos-
sibility of contact rubbing of blade tips
on the cylinder walls in reactive stages.
Rubbing can cause increased vibration to
blade bending, usually at the blade root
(Figure 5).
Rotor Imbalance Increases Vibration
Shaft curvature also shifts the rotation axis of
the shaft by moving the mass center of the ro-
tor, creating vibration. This vibration affects
blades in three significant ways.
First, the vibration causes blade structural
problems. The centrifugal forces encountered
during operation are significant, causing an
increase in the tensile forces in the blade
cross-section and, if the center of mass is not
on the radial line, bending stresses also occur.
Additionally, bending stresses are created in
blade joints under the pressure effects of the
HP steam flowing axially through the turbine
cylinder. The magnitude of these stresses
is dependent on the flow rate of steam, the
temperature drop across the blade stage, the
rotational speed of the blades, and the blade
weight. The temperature of the steam, su-
perheated in the first stage and saturated in
the final stages, will have an effect on the
mechanical properties and corrosion of the
blade materials (Figure 6).
Shaft C
Shaft C
Load on pivot (LOP) Load between pivot (LBP)
Bearing
centerline
Drop in shaft
centerline from
pad rotation
2. Shaft must stay centered. Relocation of shaft center in a segmented bearing while
rotating can cause vibration. Courtesy: Ahwaz Power Generation Management Co.
5. Avoid tenon extrusion rubs. This
is an example of tenon extrusion in high-pres-
sure rotor blades. Courtesy: Ahwaz Power
3. Properly align the diaphragms.
The diaphragms must be carefully aligned to
the shaft centerline within the casing of this
315-MW turbine to avoid contact with the ro-
tor blades. Courtesy: Ahwaz Power Genera-
tion Management Co.
4. Precise alignment required. This
photo shows the expansion key of the upper
half of a low-pressure cylinder. Courtesy: Ah-
waz Power Generation Management Co.
April 2013
|
PLANT O&M
Second, blade vibration can be stimulated
by external means, such as an unsatisfactory
dynamic balance of the rotor, nonconformity
of the diaphragm passages, deviation in the
blade pitch, an improperly assembled joint
between two half-diaphragms, or corrosion
of the eternal edge of fixed blades.
Third, the size of rotary blades and their
method of installation on the rotors may be
different. After a maintenance overhaul, the
same weight and materials of all the blades
must be carefully maintained, particularly
when only a few blades are replaced. Even
a small change in blade weight or center of
gravity can cause a rotor imbalance and vi-
bration (Figure 7).
Casing Also an Important Factor
There are many ways that casing temperature
fluctuations can cause steam turbine vibra-
tion. Casing problems can cause misalign-
ment in many different ways, mostly related
to expansion and contraction due to tempera-
ture fluctuations.
First, the turbine cylinder can have tem-
perature stratification caused by insufficient
thermal isolation from the casing and/or
weak insulation in other areas. Loss of ther-
mal isolation can be caused by poor insula-
tion at connections between joints and pipes
to the casings, usually at the bottom of the
turbine. Poor casing insulation at the bot-
tom, for example, can cause a temperature
gradient from the top to the bottom of the
casing, which can lead to casing distortion
and elastic rotor bending. The vendor will
define the acceptable casing temperature
gradient. In our experience, the gradient
must be no more than 60C. New HP turbines
are particularly sensitive to casing thermal
gradients.
Next, if the turbine is started from a hot
condition before it has returned to within
curvature limits, then rotating blades and
stationary diaphragms may rub and cause
damage to seals and diaphragm glands. As
shaft weights increase, so do the dimen-
sions of the turbine rotor, turbine cylinder,
and the thermal inertia of the shaft. The
effect is to require longer periods of time
between startups (and on turning gear) so
any curvature of the rotor is removed be-
fore the next startup.
The cylinder bending can be estimated
with knowledge of its dimensions and
materials of construction. Cylinder bend-
ing (mm) can be found by the expression
t L
2
/8D, where t is the temperature
difference between the top and bottom of
the cylinder (C), L is the cylinder length
(mm), D is the external diameter of the
shell averaged across its length (m), and
is the coefficient of linear thermal ex-
pansion, usually about 13.6 mm/mm-C,
or any other consistent set of units. The
amount of permitted cylinder bending is
determined by the tightest tolerance be-
tween diaphragm and end glands. For ex-
ample, if the HP cylinder dimensions are
l = 3,620 mm and D = 1,840 mm, and the
tightest tolerance of the diaphragm gland
is 0.6 mm, the allowable temperature dif-
ference from the top to the bottom of the
cylinder is 50C.
The effect of thermal bending of a rotor
on the casing can also be determined. When
the casing top is hotter than the bottom, the
casing tends to bend down. If the temperature
gradient is constant from the top of the casing
to the bottom and along its length, then the
maximum bending stress occurs mid-casing
vertically and between the casing supports
horizontally. The bending or deflection un-
der these conditions can be determined as
t (L Z - Z
2
) x 10
3
/2D, where L is the casing
length between supports (m), Z is the dis-
tance from front casing support to location of
interest (m), and the other variables remain
as defined above. Assuming the midpoint of
the casing length is used, L/2 can replace Z to
find the maximum deflection.
The temperature gradient along the
blades and diaphragms must also be con-
sidered during a hot start. In a hot turbine
startup, if the steam is relatively cool, then
the diaphragm and blade metal temperatures
will be cooler than the rotor. In that case the
diameter of the diaphragm holes will in-
crease more rapidly than the rotor diameter,
producing radial looseness and decreasing
blade and diaphragm clearances. Using a
typical coefficient of linear thermal expan-
sion, a diaphragm sealing diameter of 500
mm will increase 0.3 mm for every 100C
temperature difference between the rotor
and diaphragm.
So, if a rotor has a higher curvature than
the normal range and if steam flow path reg-
ulation has not been done carefully during a
hot startup, rubbing should be expected.
Calculations using these formulas and ap-
plication experience tell us that the tempera-
ture difference between the top and bottom
of the HP cylinder shouldnt get higher than
a defined normal limit during steam turbine
startup. If that temperature difference limit
is exceeded, radial distances in the front end
gland will decrease considerably, causing
rubbing, followed by rotor bending near the
control stage.
The experience of many steam turbine
repair companies is that the reason for the
HP cylinders bending is condensation
of steam within the hot turbine cylinder
when stopped. High-temperature heat
transfer to vaporize this condensate cools
6. Corrosion causes imbalance. Fail-
ure of this high-pressure rotor control stage
was caused by uneven distribution of steam
due to corrosion. Courtesy: Ahwaz Power
7. Failures can be caused by poor
maintenance. This removal of the disk
from the rotor was done incorrectly, causing
deep scratches on the shaft. The repair will
require rework and rebalancing of the shaft
to prevent an imbalance that can cause vi-
bration. Courtesy: Ahwaz Power Generation
Management Co.
8. Steam can bypass bolts. Large
bolts inserted into the holes are used to tight-
ly secure the large horizontal joint flange in
this high-pressure cylinder. The bolt holes are
places where a steam jet leak can form due to
cylinder deformation and changing duct pres-
sures. Courtesy: Ahwaz Power Generation
Management Co.
|
April 2013 66
PLANT O&M
the bottom of the cylinder while the top of
the cylinder remains relatively hot. As a
result, the cylinder will bend down while
the top of the casing will remain straight,
in most cases.
Also, poor clearances in the low-pres-
sure (LP) and intermediate-pressure (IP)
cylinder frames in multi-cylinder turbines
can occur when the distance bolts and
washers are incorrectly installed. Distance
bolts are used to secure the LP and IP cas-
ing frames to the foundation. At the time
of operation and nominal load, if con-
denser pressure (vacuum) and condensate
temperature are within normal range, then
the clearance should be as designed. But if
the condenser pressure (vacuum) is abnor-
mal and condensate temperature is high,
then the LP cylinder gets hotter than the
allowed limit, causing more volume ex-
pansion in the condenser. The result is that
the distance bolt clearance is decreased or
goes to zero. If design clearances arent
observed, turbine vibration may increase
and the turbine load must be reduced.
Next, dont forget the bolts, pins, and
other casing joints. Casings for HP tur-
bines have thick walls, as well as big hori-
zontal joint flanges that require bolts and
pins. There are times when turbine loads
quickly change or the casing flange and
walls are heated unevenly during startup
or shutdown of a unit. A temperature dif-
ference between the top and bottom of the
HP and IP casings (usually 50C to 70C)
and flange pins (maximum 15C to 25C)
can cause steam leakage through the cas-
ing horizontal joint.
Finally, uncompensated movement of
steam pipes connected to the casing can
cause casing movements and rotor vibration.
This is particularly true for large-diameter
pipes with thick walls. When the turbine is
operating, the rotor has axial movement, as
does the turbine casing. Thermal expansion
of the system is accounted for in the turbine
design. The forces and moments that these
large pipes apply to the casing are also con-
sidered during turbine design. Excessive
pipe connection loads may cause casing
deformation, and the bending moments ap-
plied to the casing flanges may also cause
displacement and movement of the cylinder
within the casing, either of which can in-
crease rotor vibration.
Farshad Shamoradi (fshamoradi@yahoo
.com) is manager of the instrument depart-
ment, Naser Mohammadi is manager of the
engineering department, and Mahdi
Heidari Kahkesh is manager of over-
all maintenance at the Ramin Power
Plant, Ahwaz Power Generation
Management Co.
Clear the way
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April 2013
|
Nuclear Waste Disposal Sites Still
Rare After All These Years
Nuclear power generation is well established, but efforts worldwide to de-
velop permanent disposal sites for highly radioactive waste remain na-
scent at best. If this were a horse race, youd have to say the smaller
horses are winning.
By David Wagman
T
he U.S. Department of Energy (DOE)
published in early January its Strategy
for the Management and Disposal of
Used Nuclear Fuel and High-Level Radioac-
tive Waste, an 18-page outline of how the
Obama administration plans to implement
recommendations made by its so-called Blue
Ribbon Commission (BRC) on Americas
Nuclear Future. The commission was set up
in 2010 to review and recommend a plan of
action to manage and dispose of used nuclear
fuel and high-level radioactive waste.
With appropriate authorizations from Con-
gress, the Energy Department said it hopes to
implement a program over 10 years that:
Sites, designs, licenses, constructs, and
begins operations of a pilot interim stor-
age facility by 2021 with an initial focus
on accepting used nuclear fuel from shut-
down reactor sites.
Moves toward siting and licensing a larger
interim storage facility to be available by
2025 that will have sufficient capacity for
enough used nuclear fuel to reduce ex-
pected government liabilities.
Makes demonstrable progress on the sit-
ing and characterization of repository sites
to facilitate the availability of a geologic
repository by 2048.
Other aspects of the administrations pro-
posal include requiring consent-based siting,
reforming the funding approach, and estab-
lishing a new organization to implement the
program.
This seemingly back-to-square-one action
runs counter to the Nuclear Waste Policy Act
of 1982 and subsequent congressional action
that, in 1987, named Yucca Mountain in the
Nevada desert as the sole candidate to receive
U.S. domestic radioactive nuclear waste. Law-
suits are under way challenging the Obama ad-
ministrations decision to scrap development
of a Yucca Mountain repository and establish
a new process for designating and building a
long-term waste storage facility.
Those decisions, which came early in
Obamas first term, were motivated in part
by politics. As described in prior articles
(see the sidebar The Quest for Long-Term
SNF Storage), candidate sites in Texas
and Washington State were dropped from
consideration in favor of Yucca Mountain
largely because Nevadas congressional
delegation couldnt block action anointing
Yucca Mountain. In the intervening years,
Nevada Senator Harry Reid gained stature
and as Senate majority leader found an
ally to stop Yucca Mountains development
once Barack Obama took office in 2009.
As a result, some $15 billion in taxpayer
investment at the Nevada site now seems
likely to lead to nothing. Whats more, the
timetable for establishing a national nucle-
ar waste repository has been reset until at
least 2048, according to the DOEs January
recommendation.
The Nuclear Energy Institute (NEI), an
industry trade group, said it welcomed the
Energy Departments recommendation and
said many of the concepts put forward by
the BRC and recommended by the DOE
have enjoyed support among its members
and other experts.
After two years of BRC deliberations
and an additional year for DOE to develop
its strategy, it is essential that the nuclear
waste fee be used solely for its intended
purposeto cover the cost of used fuel
management and disposal, the NEI said.
The fee (equal to one-tenth of a cent per
kilowatt-hour of electricity) paid by con-
sumers of electricity from nuclear power
plants, totals about $750 million a year and
is at present effectively unavailable for its
intended purpose, the NEI said.
Conflict remains, however. In late Janu-
ary, the NEI joined state utility regulators
1. Nuclear fuel cycle. The multi-step process from uranium mining to enrichment to use
in a reactor is well known. Disposal, at the very end of the cycle, remains something of a black
box. Source: Nuclear Regulatory Commission
|
April 2013 68
in asking a federal court to reopen a law-
suit that challenged the DOEs practice
of continuing to collect fees from nuclear
utilities to pay for long-term storage (see
sidebar Fee Dispute Re-ignites). The
federal government already faces a large
and growing liability to pay claims re-
sulting from its failure to begin accepting
waste from commercial utilities under the
1987 Nuclear Waste Policies Act. Accord-
ing to a Congressional Research Service
report, as of mid-2012 the government had
paid around $1 billion to settle claims by
utilities that the DOE had, at least in part,
breached its contracts to accept spent nu-
clear fuel (SNF). These claims stem from
some 76 contracts the DOE signed in the
early 1980s, largely with commercial utili-
ties, of which 74 have filed claims for dam-
ages arising from failure to accept the SNF
by 1998.
SNF continues to pile up at a rate of
around 2,000 metric tons a year, the con-
gressional report said. To date, more than
67,000 metric tons of SNF in more than
174,000 assemblies currently are stored at
77 sites in 35 states. Of the nations 104
existing nuclear reactors, all have wet stor-
age pools for SNF. These wet pools are
required to allow a safe cooling off pe-
riod of up to five years after fuel assem-
blies are removed from a reactor. The pools
hold around three-quarters (49,338 out of
67,450 metric tons of uranium, or MTU)
of the current commercial SNF inventory.
The remaining one-quarter (equal to about
18,112 MTU) of commercial SNF is stored
in dry casks on concrete pads or in vaults.
As wet storage pools become filled using
dense packing storage methods, dry stor-
age increasingly is being used (Figure 1).
The U.S. is not alone in figuring out
what to do with spent nuclear fuel. World-
wide, some 436 operational nuclear power
reactors operate in 32 countries. There
are another 122 permanently shut-down
nuclear power reactors. To date, however,
few permanent disposal solutions have
been implemented. Whats more, the sit-
ing approach favored by the DOEname-
ly, voluntary cooperation on the part of a
host communitysuffered a setback in the
UK earlier this year when local authori-
ties there voted against a storage scheme,
effectively killing a project that had been
under development for years.
Classifying Radioactive Waste
Not all nuclear waste is the same, and dis-
posal techniques range from tipping it at
commercial landfills to long-term geologic
storage with remote monitoring. As a start-
ing point, consider that a typical 1,000-
MWe light water reactor generates 200 to
350 cubic meters of low- and intermediate-
level waste each year. That reactor also
likely will discharge about 20 cubic meters
(roughly 27 metric tons) of used fuel each
year. In countries where used fuel is repro-
cessed, around 3 cubic meters of vitrified
waste (in the form of glass) are produced.
By comparison, an average 400,000 metric
tons of ash are produced from a similarly
sized coal-fired plant. An overview of the
range of radioactive waste and disposal
techniques follows, adapted from the World
Nuclear Association (WNA).
Exempt waste and very low-level waste
(VLLW) contain radioactive materials at
a level considered not harmful to people
or the environment. It consists mainly of
material produced during rehabilitation or
dismantling operations at nuclear indus-
trial sites. Industries such as food process-
ing, chemical, and steel production also
produce VLLW, but waste typically is dis-
posed of with domestic refuse. Countries
including France are developing sites to
store VLLW in specifically designed dis-
posal facilities.
Low-level waste (LLW) is generated by
hospitals and industry, as well as the nucle-
ar fuel cycle, and contains small amounts
of mostly short-lived radioactivity. It does
not require shielding during handling and
transport and is suitable for shallow land
burial. To reduce its volume, it is often
compacted or even incinerated before dis-
posal and accounts for around 90% of the
volume and 1% of the radioactivity of all
radioactive waste worldwide.
Intermediate-level waste (ILW) contains
higher amounts of radioactivity and some
requires shielding. It typically comprises
resins, chemical sludges, and metal fuel
cladding, as well as contaminated materi-
als from reactor decommissioning. Smaller
items and most nonsolids may be solidified
in concrete or bitumen for disposal. This
type of waste makes up around 7% of the
volume and has 4% of the radioactivity of
all radioactive waste.
High-level waste (HLW) results from
burning uranium fuel in a nuclear reac-
tor. HLW contains fission products and
transuranic elements (that is, elements hav-
ing atomic numbers greater than uranium)
generated in the reactor core. It is highly
radioactive and hot (contaminated), and
requires both cooling and shielding. Re-
ferred to as ash produced by burning
uranium, this waste accounts for more than
95% of the total radioactivity produced
The Quest for Long-Term SNF Storage
The POWER online archives should be your first reference source
for technical and regulatory coverage of the frequently conten-
tious debate about long-term storage of spent nuclear fuel (SNF)
and reprocessing. For example, the following 10 articles may be
useful in your research:
MOX Fuel Fabrication Facility: Turning Swords into Plowshares,
December 2012
The U.S. Spent Nuclear Fuel Policy, Part 2: Playing Hardball,
November 2011
THE BIG PICTURE: Underground Nuclear Waste Disposal, Au-
gust 2011
PRISM: A Promising Near-Term Reactor Option, August 2011
GAO: U.S. Nuclear Waste Policy Plagued with Uncertainties,
June 2011
NRC Chairman Floats Plan for Long-Term Spent Fuel Storage,
November 2010
The U.S. Spent Nuclear Fuel Policy: Road to Nowhere, May
2010
Patchy Progress in Europe with Radioactive Waste Manage-
ment, January 2009
How to Solve the Used Nuclear Fuel Storage Problem, Au-
gust 2008
Developing the Next Generation of Reactors, April 2008
You can search the archives by issue (at the Archives link) or
by keyword, using the Search box in the upper right corner of our
homepage, www.powermag.com. The updated search feature now
automatically searches POWER and all sister publicationsCOAL
POWER, GAS POWER, MANAGING POWER, and POWERnews.
April 2013
|
in electricity generation. HLW has both
long-lived and short-lived components, de-
pending on how long it will take the radio-
activity of particular radionuclides to fall
to levels considered no longer hazardous
for people and the environment.
Uranium oxide concentrate from min-
ing, essentially the well-known yellow-
cake, is considered to be barely more
radioactive than granite used in buildings.
Through refinement and conversion to
uranium hexafluoride gas, it undergoes
enrichment to increase the U-235 content
from less than 1% to about 3.5%. Follow-
ing this step, it is turned into a hard ce-
ramic oxide for assembly as reactor fuel
elements.
The main byproduct of enrichment is
depleted uranium, principally the U-238
isotope. About 1.2 million metric tons of
depleted uranium are now stored. Some is
used in applications where its high density
makes it valuable, such as in the keels of
sailing vessels and military projectiles. It
is also used (with reprocessed plutonium)
to make mixed oxide fuel (MOX) and to
dilute highly enriched uranium from dis-
mantled weapons for use as reactor fuel.
Waste from Electricity Generation
Highly radioactive fission products and
transuranic elements are produced from
uranium and plutonium during reactor
operations and are contained within the
used fuel. LLW and ILW are produced dur-
ing power generation operations (such as
cleaning reactor cooling systems), in fuel
storage ponds, and during decontamina-
tion of equipment, filters, and metal com-
ponents that have become radioactive in or
near the reactor.
Storage is handled mostly using ponds
at reactor sites or, occasionally, at a central
site. If the used fuel is reprocessedas it is
for UK, French, Japanese, and German re-
actorsHLW comprises highly radioactive
fission products and some transuranic ele-
ments with long-lived radioactivity. These
are separated from the used fuel, enabling
the uranium and plutonium to be recycled.
The HLW also generates heat and requires
cooling. It is vitrified into borosilicate glass,
encapsulated into stainless steel cylinders
around 4.5 feet high, and stored for eventual
disposal underground. France operates two
commercial plants to vitrify HLW left over
from reprocessing oxide fuel, and there are
plants in the UK and Belgium. The capac-
ity of these plants is around 2,500 canisters
(about 1,000 metric tons) a year, and some
have been operating for decades.
Used reactor fuel that is not reprocessed
still contains all the highly radioactive iso-
topes, meaning the entire fuel assembly
must be treated as HLW for direct disposal.
However, because it consists largely of ura-
nium (with some plutonium), it represents
a potentially valuable resource. As a result,
an increasing reluctance exists to dispose
of it permanently. Current thinking is that
after 40 to 50 years the heat and radioac-
tivity have fallen to around one-thousandth
the level at removal, providing a technical
incentive to delay permanent storage and
find some other use for it.
Recycling Used Fuel
Used fuel still contains some of the origi-
nal U-235 as well as plutonium isotopes
that have been formed inside the reac-
tor core and U-238. These account for
roughly 96% of the original uranium and
more than half of the original energy con-
tent. Reprocessing, which is done in Eu-
rope and Russia, separates this uranium
and plutonium from the wastes for reuse
in a reactor. Plutonium that results from
reprocessing is recycled through a MOX
fabrication plant, where it is mixed with
depleted uranium oxide to make fresh fuel.
European reactors currently use more than
5 metric tons of plutonium a year in fresh
MOX fuel.
Commercial reprocessing plants oper-
ate in France, the UK, and Russia with
a capacity of some 5,000 metric tons a
year. A new reprocessing plant with an
800 metric ton per year capacity is being
constructed at Rokkasho in Japan. France
and the UK also reprocess used fuel for
utilities in other countries. For example,
Japan has made more than 140 shipments
of used fuel to Europe since 1979. Russia
also reprocesses spent fuel from some So-
viet-designed reactors in other countries.
Storage ponds at reactors, and those at
centralized facilities such as in Sweden,
are 20 to 40 feet deep to allow several feet
of water to cover the used fuel, which is in
the form of racked fuel assemblies 12 feet
long and standing on end. These pools are
made of reinforced concrete with steel lin-
ers and often are designed to hold all the
used fuel for the life of a reactor.
Some storage of fuel assemblies that
Fee Dispute Re-ignites
A U.S. Department of Energy review of
the fees charged to nuclear utilities and
their consumers for the nations nuclear
waste program runs counter to judicial
and congressional intent, state utility
regulators and nuclear utilities claimed
in a filing made in late January with the
U.S. Court of Appeals for the District of
Columbia Circuit. The Nuclear Energy In-
stitute (NEI) and the National Associa-
tion of Regulatory Utility Commissioners
(NARUC) asked the court to temporarily
suspend the fees, calling the Energy De-
partments analysis defending the fees
fundamentally flawed.
The case involves the 1982 Nuclear
Waste Policy Act, which required the
DOE to enter into contracts with the
nations nuclear utilities to pay for the
transportation and eventual storage of
their nuclear waste in a central, geo-
logical repository, which became Yucca
Mountain in the Nevada desert. The
contracts are paid for through fees as-
sessed by the DOE to the nuclear utili-
ties and their consumers. The Obama
administration in 2009 sought to sus-
pend the nuclear waste program and an
ongoing review of the Yucca Mountain
license application. However, Nuclear
Waste Fund fee collection continued
without pause.
After failing to produce a required as-
sessment of the fees adequacy, NARUC
and the NEI sued the DOE in 2010. The
case was dismissed after the DOE sub-
mitted a review that said the fees re-
mained necessary. NARUC and the NEI
successfully challenged this review in
late 2011, and in June 2012, a fed-
eral court ordered the DOE to perform
a thorough and exhaustive assessment
of whether the fees remain necessary.
On Jan. 18, 2013, the DOE filed its re-
sponse to the court and again deter-
mined that the fees are necessary.
NARUC and the NEI allege in a brief filed
with the court that the DOE report does not
comply with the courts directions because
it is based on the speculative belief that
Congress will adopt a new nuclear waste
strategy. Until such time as Congress acts,
the key components of DOEs assumed pro-
gram have not been approved, the plain-
tiffs said. In late February, the U.S. Court
of Appeals for the D.C. Circuit agreed to
reopen the case, with legal briefs accepted
through mid-July.
|
April 2013 70
Global spent nuclear fuel disposal strategies. Reprocessing is a favored strategy in many countries, but long-term geological stor-
age remains years from reality for most nations with nuclear power. Source: World Nuclear Association
Country Policy Facilities and progress toward final repositories
Belgium Reprocessing Central waste storage at Dessel
Underground laboratory established 1984 at Mol
Construction of repository to begin about 2035
Canada Direct disposal Nuclear Waste Management Organization set up 2002
Deep geological repository confirmed as policy, retrievable
Repository site search began 2009, planned for use 2025
China Reprocessing Central used fuel storage at LanZhou
Repository site selection to be completed by 2020
Underground research laboratory to begin 2020, disposal from 2050
Finland Direct disposal Program start 1983, two used fuel storages in operation
Posiva Oy set up 1995 to implement deep geological disposal
Underground research laboratory Onkalo under construction
Repository planned near Olkiluoto, open in 2020
France Reprocessing Underground rock laboratories in clay and granite
Parliamentary confirmation in 2006 of deep geological disposal, containers to be retrievable and policy "reversible"
Clay deposit is likely repository site to be licensed 2015, operating 2025
Germany Reprocessing, but
moving to direct
disposal
Repository planning started 1973
Used fuel storage at Ahaus and Gorleben salt dome
Geological repository may be operational at Gorleben after 2025
India Reprocessing Research on deep geological disposal for HLW
Japan Reprocessing Underground laboratory at Mizunami in granite since 1996
Used fuel and HLW storage facility at Rokkasho since 1995
Used fuel storage under construction at Mutsu, start up 2013
NUMO set up 2000, site selection for deep geological repository under way to 2025, operation from 2035, retrievable
Russia Reprocessing Underground laboratory in granite or gneiss in Krasnoyarsk region from 2015, may evolve into repository
Sites for final repository under investigation on Kola peninsula
Pool storage for used VVER-1000 fuel at Zheleznogorsk since 1985
Dry storage for used RBMK and other fuel at Zheleznogorsk beginning 2012
Various interim storage facilities in operation
South Korea Direct disposal,
but may change
Waste program confirmed 1998, KRWM set up 2009
Central interim storage planned from 2016
Spain Direct disposal ENRESA established 1984, plan accepted 1999
Central interim storage at Villar de Canas starting 2016 (volunteer location)
Research on deep geological disposal
Sweden Direct disposal Central used fuel storage facility, "CLAB," in operation since 1985
Underground research laboratory at Aspo for HLW repository
Osthammar site selected for repository (volunteer location)
Switzerland Reprocessing Central interim storage for HLW and used fuel at ZZL Wurenlingen since 2001
Smaller used fuel storage at Beznau
Underground research laboratory for HLW repository at Grimsel since 1983
Deep repository by 2020, containers to be retrievable
United
Kingdom
Reprocessing Low-level waste repository in operation since 1959
HLW from reprocessing is vitrified and stored at Sellafield
Repository location to be based on community agreement
United States Direct disposal,
but reconsidering
DOE responsible for used fuel since 1998, accumulated $32 billion waste fund
Considerable research and development on repository at Yucca Mountain, Congress decision that geological repository be at Yucca
Mountain countered by Obama administration in 2009
Central interim storage for used fuel now likely, date uncertain
Note: HLW = high-level waste, a type of waste produced by reprocessing spent nuclear fuel or wastes formed by vitrification of liquid HLW.
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|
April 2013 72
have been cooling in ponds for at least five
years is continued in dry casks, or vaults
with air circulation inside concrete shield-
ing. One system involves sealed steel casks
or multi-purpose canisters (MPCs), each
holding about 80 fuel assemblies with in-
ert gas. Casks/MPCs also may be used to
transport and eventually to dispose of the
used fuel. For storage, each is enclosed in
a ventilated storage module made of con-
crete and steel. These commonly stand on
the surface, are about 18 feet high, and are
cooled by air convection. A collection of
casks or modules constitute whats known
as an Independent Spent Fuel Storage In-
stallation. In the U.S. they are licensed by
the Nuclear Regulatory Commission sepa-
rately from power plants and are intended
for interim storage only. About one-quar-
ter of U.S. used fuel is stored this way.
Long-Term Disposal
To ensure that no significant environmen-
tal releases occur over tens of thousands of
years, multiple barrier geological dispos-
al is planned to immobilize radioactive ele-
ments in HLW and some ILW and isolate
them from the biosphere. The main barriers
to be built using this approach include:
Immobilizing waste in a matrix such as
borosilicate glass or synthetic rock.
Sealing waste inside a corrosion-resistant
container, such as stainless steel.
Locating the container deep underground
in a stable rock structure.
Surrounding containers with an imperme-
able backfill.
The process of selecting deep geologi-
cal repositories is under way in several
countries (see table). Finland and Sweden
are well advanced with plans for direct
disposal of used fuel, since their parlia-
ments decided to proceed on the basis
that it was safe, using existing technol-
ogy. Both countries have selected sites,
in Sweden, after competition between two
municipalities.
The UKs radioactive waste disposal pro-
cess stalled in late January after conflicting
votes between regional and local govern-
ment. The Borough of Copeland voted to
continue exploring its suitability, but it
lies within Cumbria County, which voted
against the idea. The site selection process
is based on a principle of voluntarism under
which communities explore their options
and have the right to withdraw at any time.
The same approach has been practiced with
success in Finland and Sweden to find suit-
able and welcoming places for radioactive
waste disposal. Its also the approach now
favored by the U.S. Energy Department, as
outlined in its January announcement. The
negative vote in Cumbria now means that
the current process will be brought to a
close, said the UK Department of Energy
and Climate Change, which will now em-
bark on a renewed drive to find other in-
terested communities that may be able to
host a disposal site.
Canadian Nuclear Waste Disposal
Canadas Nuclear Waste Management Or-
ganization (NWMO) was set up under the
2002 Nuclear Fuel Waste Act by Ontario
Power Generation (OPG), Hydro-Qubec,
and New Brunswick Power Corp. operat-
ing in concert with Atomic Energy of Can-
ada Ltd. (AECL). Its mandate is to explore
options for storage and disposal, make
proposals to the government, and imple-
ment what is decided. Less than 3,000
metric tons of used fuel per year from
Candu reactors is involved. The nuclear
utilities and AECL remain responsible for
low- and intermediate-level wastes, which
are currently stored above ground.
OPG in 2005 moved ahead with plans
to build a deep geological repository for
its LLW and ILW near the Bruce Nuclear
Generating Station on Lake Huron. The
facility will be 2,000 feet beneath OPGs
Western Waste Management Facility,
which it has operated since 1974. Opera-
tion is expected to begin around 2017/18.
In June 2007, the government selected
the retrievable deep geological disposal
option, referred to as adaptive phased man-
agement, recommended by the NWMO
for the long-term management of HLW.
The NWMO has said that a final reposi-
tory would probably be in Ontario, Qu-
bec, New Brunswick, or Saskatchewan,
and host localities would need to volun-
teer for the role. Operation is expected by
around 2025.
French and German Nuclear Waste
Radioactive waste management in France
is governed by a 2006 law, which requires
the updating every three years of a Nation-
al Plan for the Management of Radioac-
tive Materials and Waste. It confirms that
long-term management of HLW would be
by deep geological disposal (with retriev-
ability for at least 100 years). The 2006
law envisages an operational solution for
deep geological disposal to be available
by 2025. The site is likely to be at Bure,
where an underground laboratory in a clay
formation was opened in 2004.
Germany has a nuclear phaseout policy
in place, which, if not reversed, would
result in all nuclear power stations being
closed by around 2021. German policy
had been to reprocess used fuel, but it has
shifted toward direct disposal. Vitrified
HLW from France and the UK is tempo-
rarily stored at facilities in Gorleben and
Ahaus. HLW from reprocessing is stored
at the facilities where they were created.
The Morsleben repository for radioactive
waste was used for the disposal of LLW
and ILW in the former German Democrat-
ic Republic from 1971 to 1991 and later
from 1994 to 1998. That installation is
now being decommissioned. A former iron
ore mine, Konrad in Salzgitter, has been
investigated since 1975 as a possible re-
pository for radioactive waste with negli-
gible heat generation.
Japanese Nuclear Waste
Japan has a policy of reprocessing, and a
large reprocessing complex at Rokkasho-
Mura, Aomori Prefecture is under con-
struction. A large LLW center at the Japan
Nuclear Fuel Ltd. (JNFL) site in Rok-
kasho-Mura has been operational since
1992. JNFL is a private venture led by 10
domestic electric power companies.
Deep geological disposal is the pre-
ferred option for HLW. A site selection
process for a final repository is under way
by the Nuclear Waste Management Orga-
nization of Japan. Site selection could take
place between 2023 and 2027.
Hungarian Facility Crosses the
Finish Line
After 15 years of work and an investment
of more than $300 million, the first dis-
posal chamber at the Bataapati storage fa-
cility in southern Hungary was completed
in early December. The project was built
by the countrys Public Limited Co. for
Radioactive Waste Management (known
as Puram). Underground disposal vaults at
Bataapati will eventually hold all the low-
level and short-lived intermediate-level
radioactive wastes left over from the op-
eration and decommissioning of the Paks
nuclear power plant.
As part of the repository inauguration
in December, the first concrete container
holding nine drums of waste was moved
from a temporary surface storage facil-
ity. Once the facility is fully operational,
waste drums will be stacked 650 to 800
feet underground inside granite bedrock
caverns. Bataapatis modular design will
allow for its expansion should the Paks
plant be granted a 20-year license exten-
sion and if Hungary decides to construct
new reactors.
David Wagman is executive
editor of POWER.
JUNE 10-12, 2013

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|
April 2013 74
NEW PRODUCTS
TO POWER YOUR BUSINESS
Shaft Alignment
Phone/Tablet App
LUDECA released a new version
of its Laser Align mobile
application. The application
provides a free reference tool
for shaft alignment of rotating
equipment. It allows users to
access important reference
material and learn about key
laser shaft alignment concepts,
and it now has an interactive
Tolerance Table. When users
input their machines revolution
per minute measure using this
feature, the app will kick back the
respective alignment tolerances
for both short-flex and space-
type couplings. It also includes
a thermal growth calculator and
now has a soft foot assistant
to help the user interpret soft
foot values. The app is available
for free in the iTunes Store for
both iPhone and iPad, as well as
in Google Play for the Android
market. (www.ludeca.com/res_
apps.php)
High-Capacity Safety Valve
Pentair Valves & Controls newly introduced
Crosby HCI ISOFLEX is a high-capacity safety
valve to help power plant operators reduce
lifecycle costs and minimize shutdown
periods. The valve ensures cost-effective
power plant operation with a unique full-
nozzle, flanged design and adjustable lift
option that reduces maintenance costs while
maximizing plant efficiency. Specifically
designed for 300 to 3,000 psig steam
generators, the HCI ISOFLEX can withstand temperatures up to
1,100F/593C and is available in various inlet sizes, ranging from
1 inch (38.1 mm) to 6 inches (15.24 cm). An extensive range
of interchangeable spare parts enables operators to repair or
exchange components individually, avoiding costly replacements and
minimizing shutdown time.
The valve is also available with an optional restricted lift feature
to eliminate overcapacity and ensure a more economic distribution
of relieving capacity between the drum and superheater safety
valves. This design not only reduces reaction forces for a greater
lifespan but also allows for the use of smaller superheater safety
valves in some operations, reducing overall installation costs.
Additional benefits include precise blowdown control due to a two-
ring design and exceptional seat tightness up to 95% of valve set
pressure. (valves.pentair.com/valves)
New Abrupt Arched Expansion Joint
The new Garlock 204 EPS (extreme pressure service) abrupt arched
expansion joint is now available for applications where necessary
rated pressures exceed those of the Garlock Style 204 and 204
HP designs. Fully customizable and available in concentric or
eccentric designs, the expansion joint features a seamless tube
to ensure a reliable seal from flange to flange. High pressure and
vacuum resistance increase safety and ensure the joints suitability
for a range of applications. The tube can be manufactured in a
wide selection of elastomers that are resistant to temperatures,
weathering, oxidation, and chemicals, and the abrupt arch
configuration provides
maximum movement,
and pressure and vacuum
resistance. The joints body
is made of a composite fabric
construction with welded,
treated metal body rings for
dimensional stability. (www.
garlock.com/v/204EPSspec)

April 2013
|
NEW PRODUCTS
Inclusion in New Products does not imply endorsement by POWER magazine.
Versatile Boiler Inspection Light
Larson Electronics announced the release of a boiler inspection light with folding boom
designed to provide versatile deployment capabilities and high-output illumination. The
WALBL-2X1000WMH Boiler Light features a right-angle extension arm, wheeled base, and
a pair of 1,000-W metal halide lamps for effective illumination during the servicing and
maintenance of boilers and tanks. The boiler light produces 220,000 lumens of light output in
a wide ood pattern and features an easy-to-deploy wheeled tower with folding boom. The heavy
wheeled base features four lockable steel wheels designed to allow rolling over uneven surfaces
and steel oor grates, and the extendable tower arm can be adjusted vertically or angled to t
inside most boiler access doors. The telescoping arm can also be shortened or lengthened as well
as angled, and an extra support leg on the boom provides added stability when the boom is fully
extended. (larsonelectronics.com)
PV Panel Surge Protection Devices
The ABB Low Voltage Products division released a line of
OVR PV UL 1449 3rd Edition, pluggable DC DIN Rail surge
protection devices (SPD) specically designed for photovoltaic
(PV) applications. The new SPDs protect solar panels from
damage from direct and indirect lightning strikes, which solar
panels are especially susceptible to because of their large,
fully exposed surface areas and typical installation in open,
isolated areas. The new PV product range uses fast-acting
metal oxide varistors to limit overvoltage to values compatible
with the sensitive equipment connected to the network. ABB
says extensive damage and expensive repairs can result from
lightning strikes if surge protection is not present. The PV-
specic SPDs are available in maximum discharge currents
(Imax) of 15 or 40 kA, maximum continuous operating
voltages of 600, 800, and 1,000 VDC, all with pluggable
cartridges (P), and optional integrated remote indicator
contact (TS). (www.abb.com)
Compact AC Tachometer Generators
The ATC DigiTec Division of Marsh Bellofram Corp. launched its highly compact
758-GF86/XF86 series of industrial open-face AC tachometer generators, part of its
WESTCON product family. The tachometers are designed primarily for use on shaft
ends to measure speeds of up to 100,000 rpm and extremely low torque burdens
of less than 1 ounce-inch. Designed primarily for use by original equipment
manufacturers, ATC DigiTec 758-GF86/XF86 series AC tachometer generators are
speed transducers of the most basic form, consisting of simply a stator and a
permanent magnet rotor mounted onto a rotating shaft within a customers own
specied equipment.
Potted models (designated with the letter P in the type number) are also
available with stator windings encapsulated within an epoxy material for greater
protection. The compact size of the 758-GF86/XF86 series allows them to be
installed in hard-to-reach areas such as gear boxes, diesel engines, and conveyor
systems, saving space and reducing costs. As their rugged, bearing-free, and
brush-free design requires no maintenance, they offer increased reliability and
minimized downtime. (www.marshbellofram.com)
|
April 2013 76
Opportunities in Operations and Maintenance,
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April 2013 76
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April 2013 80
COMMENTARY
M
ae West said, Too much of a good thing can be tax-
ing. The Pacific Northwest has a good thingplentiful,
carbon-free power from its huge wind and hydroelectric
fleets. But winds huge variability can be taxing. The Northwests
scramble to integrate growing wind generation, and the resulting
litigation melee, underscore the importance of quickly solving
the variable resource integration puzzle.
Over the past decade, wind generation in the Northwest has
exploded. Wind capacity has grown from almost nothing to nearly
5,000 MW in the regions largest balancing area, the Bonneville
Power Administration. Already, hourly ramps from wind genera-
tion regularly exceed 2,000 MW. These rapid ramps will continue
to grow with the size of the wind fleet, which Bonneville expects
to reach 6,000 MW to 7,500 MW by 2017. With its huge carbon-
free capacity and flexibility to rapidly adjust output, the North-
wests hydro system is ideally suited to balance these ramps. But
the hydro system is now often taxed to the breaking point to
reliably integrate large volumes of wind generation.
The immediate problem stems from Clean Water Act limits on
dissolved gases. These limits are designed to protect aquatic
creatures, including endangered Columbia River salmon, from
gas bubble traumathe equivalent of the bends in human
divers. To avoid violating dissolved gas limits, Bonneville runs
water through hydroelectric turbines (which does not increase
dissolved gases) rather than spilling water over dams (which
does). But the resulting hydro generation, when it coincides with
high wind generation, has periodically exceeded regional de-
mand. Twisting the knife, the Washington State Court of Appeals
recently rejected an attempt to increase dissolved gas limits on
the Columbia River, denying Bonneville an added measure of flex-
ibility to avoid curtailments.
Destructive Litigation
Bonneville has twice proposed solutions to this problem,
relying on curtailments to wind generation. Wind producers
complain that Bonnevilles curtailment policies impose unique
burdens on them, causing, for example, lost production tax
credits and renewable energy credits, in addition to lost pow-
er production. The Federal Energy Regulatory Commissions
(FERCs) decisions raise fundamental legal questions concern-
ing the extent to which Bonneville policy will be dictated by
FERC, as opposed to the regional interests that have tradition-
ally held sway at Bonneville, and litigation can therefore be
expected to continue for years.
However, the litigation involves trivial amounts of power. Only
about 150,000 MWh of wind production have been curtailed over
the past two years in a region that consumes roughly 170 million
MWh annually. Worse, the litigation has driven a wedge between
wind producers and many of their natural allies. The wind boom
has breathed new life into struggling rural economies across the
region. But those same rural areas are mostly served by publicly
owned utilities that rely on power from the federal hydro system,
and many in the rural Northwest view the wind generators litiga-
tion as an attack on this vital resource.
The Real Problem Is Elsewhere
Most importantly, the litigation ignores the Golden Bear in the
roomCalifornias protectionist policies that have effectively
walled off its robust renewable energy market from the rest of the
West. Californias policies are vulnerable legally because, for ex-
ample, they violate the U.S. Constitutions dormant Commerce
Clause. Yet, while Northwest renewable energy interests squabble
over trivial amounts of power, Californias destructive policies
have gone unchallenged. And the curtailment issue is merely a
symptom of the ultimate problemeven the Pacific Northwests
vast hydroelectric system lacks the capacity to integrate ever-
greater amounts of variable wind generation.
To solve the wind integration problem, the Northwest needs to
attack counterproductive policies like Californias. It also needs
to grow the regional capacity pie. The region is already exploring
improved coordination between balancing authorities and other
short-term measures that will marginally improve its ability to
integrate variable resources. Additional physical storage capacity
is also critical. Hence, the region needs to explore major invest-
ments in proven technologies like pumped storage, as well as
cutting-edge storage technologies like advanced batteries. Elec-
trification of the regional transportation system coupled with
smart grid technology may allow electric car batteries to be-
come a major storage resource. The region also needs to improve
transmission links to the major storage reservoirs in British Co-
lumbia and expand the footprint of its wind fleet so that the
fleets output is more diverse and therefore easier to integrate.
Finally, the region needs to encourage greater use of nonvariable
renewables like geothermal.
Following this path, the region can continue developing its di-
verse renewable energy resources. If it does so, it may find, as Mae
West also said, Too much of a good thing can be wonderful!
Eric Christensen is chairman of the Energy, Telecommunica-
tions & Utilities Practice Group at Gordon Thomas Honeywell
LLP in Seattle.
The Pacific Northwests Wind
Fleet Integration Struggles
By Eric Christensen
Even the Pacific Northwests
vast hydroelectric system lacks
the capacity to integrate ever-
greater amounts of variable
wind generation.
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