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Contingency Planning in the Design of Air Pollution Control Systems
Carolinas Air Pollution Control Association
Presentation by:Michael Mannuzza
OBG
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CONTINGENCY PLANNING
<Risk: 1. Exposure to the chance of injury or loss, a hazard
or dangerous chance.<Risk Management:
1. The technique or profession of assessing, minimizing, and preventing accidental loss to a business, as through the use of insurance, safety measures, etc.
<Contingency: 1. A chance, accident, or possibility conditional on
something uncertain.
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Risk Associated with Diminishing Emission Limits NSPS Subpart Ce
Emission Standard for Medium HMIWIPollutant Limit
Lead0.0153mg/dscm
0.0079gr/103dscf
Cadmium0.013mg/dscm0.0057gr/103dscf
Mercury0.025mg/dscm0.011gr/103dscf
D/F (TEQ)0.00002mg/dscm
1.0gr/109dscf
RISK
EMISSION LIMITS
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LIMITATIONS OF SOURCE DATA<Process Scale-up
Uncertainties<Material Take-off
Limitations<Properties of Process
Exhaust that Preclude Data Collection
<Process Variability<Repeatability<Confidentiality
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CONTINGENCY PLANNING MEETING• A Type of Risk Assessment
– Systematic, Methodical Approach– Identifies Potential Exposure to Performance
Liabilities– Quantifies Potential Costs
• Provides a Methodology to Identify Potential Impacts on Project Cost & Schedule
• Adds the Most Value When:– Process Streams are Highly Variable– Available Data is Incomplete– Compliance Requirements are Challenging
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CONTINGENCY PLANNING MEETING<Implemented Much Like a HAZOP or Process Hazard
Analysis (PHA) Meeting– Assign a Score for Severity of Event– Assign a Score for Likelihood of Event– Establish a Risk Matrix Used to Drive Decision
Making<Excellent tool for:
– Identifying Regulatory Risk– Quantifying Potential Costs– Quantifying Potential Impacts on Schedule
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CONTINGENCY PLANNING PROCESS• Pre-Requisites:
– Knowledge of Process Constituency– Knowledge of Applicable Regulatory Codes
– Consequences of Non-Compliance– Potential Costs Associated with Non-Compliance
– Additional Labor Costs– Waste Disposal & Storage Costs– Lost Production Revenue– Regulatory Fines– Contractual Penalties– Additional Equipment Maintenance/Repair
Costs– Other Costs
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SEVERITY ASSESSMENTIMPACTS
SEVERITY REGULATORY PRODUCTION MAINTENANCE FINANCIAL1 Non-Reportable
IncidentNone Minorimpacton
equipmentlongevity
< $$$
2 Reportable Incident
Not Likely to Impact.
Minorimpactonequipmentlongevity.
$$$ to $$$
3 Reportable Incident
Possible Shutdown
Moderate.Mayrequireunscheduleddown-time,reduceequipmentlongevity.
$$$ to $$$
4 Reportable Incident
Definite Shutdown
Likelytocauseprematureequipmentfailure,requireextensiverepairs
> $$$
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LIKELIHOOD ASSESSMENT
LIKELIHOOD DESCRIPTION
1 Remote - Doubtful that it will ever occur
2 Unlikely - Might occur once during equipment lifetime
3 Likely - might occur several times during equipment lifetime.
4 Very Likely - could occur more than once on an annual basis.
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RISK MATRIXRISK MATRIXLi
kelih
ood 4 C N N N
3 A N N N2 A C C C1 A A A C
1 2 3 4Severity
A – Acceptable RiskC – Contingency Plan RequiredN – Not Acceptable – Must Design for Control.
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CONTINGENCY STRATEGY CATEGORIES
• APC Contingency Strategies Fall into 3 categories:1. Enhanced Equipment
Flexibility2. Provisions for Future
Equipment Implementation
3. Procedural Adaptation
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ENHANCED EQUIPMENT FLEXIBILITY –VENTURI SCRUBBER EXAMPLE
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FUTURE EQUIPMENT STRATEGIES• Certain Emission Levels May be Impossible to
Identify Prior to Start-Up.– Identify Technical Solution & Plan for it.
• Provisions Incorporated into the System Design to Facilitate the Installation of Additional Equipment if Needed:
– Spool Pieces– Nozzles– Concrete Pad Space– Fan Capacity– Fully Engineered Drawings– Budget
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FUTURE EQUIPMENT STRATEGIES –DRY SORBENT INJECTION
<Dry Sorbent Injection Skids4SO2 & SO3
4Mercury4Dioxin Furan4Enhanced ESP
Performance.
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BAGHOUSES – CATALYTIC FILTER OPTIONS FOR D/F CONTROL
Image provided courtesy of Gore Creative Technology Worldwide
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MERCURY ADSORPTION CONTINGENCY STRATEGIES
Image provided courtesy of Gore Creative Technology Worldwide
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PROCEDURAL ADAPTATION STRATEGIES
• Adjust APC Operating Parameters• Modify Waste Load size & Feed Rates• Limit Production Rates• Stagger Production Processes• Adjust Process Formulations• Employ Chemical Additives
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Conclusion• Contingency Planning Meeting:
– Provides a more focused contingency planning effort
– Engages all project stake-holders– Compensates for data shortfalls and
unknowns– Helps better define project cost exposure
and schedule– Mitigates risk– Helps project & plant managers sleep better
at night.
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