- Cornell University: ICI Boiler MACT Phase I Study
Burns & McDonnell worked with Cornell University to develop a plan to enable Cornell to best respond to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Industrial, Commercial and Institutional Boilers and Process Heaters (ICI Boiler Maximum Achievable Control Technology, or MACT), CFR 63 Subpart DDDDD. The goal of this phase of the project was to identify compliance options, perform necessary economic analysis on the options and make a recommendation as to the best plan of action while considering time, money, space and the future needs of Cornell.
Burns & McDonnell’s scope included review of existing data (including a preliminary MACT study) to assess project scope and determine need for additional stack testing or project scope changes and evaluation of potential mercury compliance options for Boilers 1 and 8. Compliance options included a variety of technologies including activated carbon or sorbent injection. Life-cycle cost estimates on viable compliance options were developed as well as a recommendation on mercury control technology that best fits the needs of Cornell considering initial costs, operating and maintenance costs, physical constraints, ash reuse or disposal costs, etc. Factors that are difficult to quantify such as fuel procurement flexibility and certainty of meeting the emission limits were also considered.
Burns & McDonnell also provided preliminary hydrogen chloride (HCl) compliance options for Boilers 1 and 8. Compliance options included review of the the health-based risk assessment “off-ramp” and all options considered initial costs, operating and maintenance costs, physical constraints, etc. Evaluation took into account synergistic effects of HCl control relative to mercury (Hg), sulfur dioxide (SO2), nitrogen oxide (NOx) and particulate matter (PM) control. Fuel procurement and anticipated regulatory changes were also considered.
Burns & McDonnell developed timelines indicating major milestones in the implementation of the recommended control options.
- Review of coal analyses and development of design basis
- Regulatory review
- Technology screening and alternatives evaluation
- Cost estimates