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Vol. 156 No. 11 November 2012
Top Plants:
Two Innovative
Nuclear Plants
North Anna: Earthquake Recovery
Chinas Nuclear Industry
Responds to Fukushima
Prepare for New PM2.5 Standards
A compact powerhouse for reliable generation of electricity and heat. The newly developed 6-cylinder
220 kW gas engine sets standards that are nothing short of revolutionary. Its combination of four-valve
technology and new combustion chamber geometry boosts specic performance, optimises cost
efciency and also reduces emissions. The novel engine concept features an overhead camshaft
cylinder head that additionally increase the life and service friendliness of the engine. Come along and
see the new MAN Power at BioEnergy in Hanover from 13 to 16 November.
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MAN Engines
A Division of MAN Truck & Bus
NEW POWER BOOST.
EXPERIENCE THE PREMIERE OF A NEW GAS ENGINE.
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POWER www.powermag.com 1
ON THE COVER
Dominion Virginia Power contracted with Alstom Power to upgrade the two steam turbines
at its North Anna nuclear power station in 2007. The steam turbine rework included replac-
ing the double-flow, high-pressure rotor and diaphragms with a more efficient single-flow
arrangement and two low-pressure (LP) double-flow turbinesshown in the photo as they
are being assembled. The LP turbines last-stage blade length increased from 48 to 57
inches, requiring replacement of the LP inner casing and significant rework to the exhaust
hoods, condenser connections, and surrounding structural steel. Courtesy: Alstom Power
COVER STORY: nuClEaR TOp planTS
30 north anna power Station, louisa County, Virginia
For decades now, U.S. nuclear generators, faced with daunting barriers to new con-
struction, have had to practice a special kind of energy efficiency by way of up-
grades. Dominions North Anna station recently completed its second uprate, this
one made possible by steam turbine retrofits.
32 Oconee nuclear Station, Seneca, South Carolina
Nuclear plant operators and regulators are cautious by naturefor good reason.
But you cant use outmoded equipment forever. By installing the first nuclear plant
digital control system in the U.S., Duke Energy has positioned itself at the forefront
of an important technology switch.
SpECIal REpORTS
nuClEaR pOwER
34 Dominions north anna Station Sets new Standard for Earthquake
Response
Just six months after the earthquake-and-tsunami-caused nuclear disaster in Japan, a
record-setting earthquake struck Central Virginia. For the nuclear plant located only 11
miles from the epicenter, it was a beyond-design-basis event. How management and
staff responded to that event has set a new benchmark for earthquake recovery.
42 what worldwide nuclear Growth Slowdown?
Although last years nuclear plant disaster in Japan prompted a necessary and ex-
pected reevaluation of nuclear plants and plans worldwide, one year later, the net
effect on the global nuclear outlook is barely measurable.
30
A compact powerhouse for reliable generation of electricity and heat. The newly developed 6-cylinder
220 kW gas engine sets standards that are nothing short of revolutionary. Its combination of four-valve
technology and new combustion chamber geometry boosts specic performance, optimises cost
efciency and also reduces emissions. The novel engine concept features an overhead camshaft
cylinder head that additionally increase the life and service friendliness of the engine. Come along and
see the new MAN Power at BioEnergy in Hanover from 13 to 16 November.
M
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MAN Engines
A Division of MAN Truck & Bus
NEW POWER BOOST.
EXPERIENCE THE PREMIERE OF A NEW GAS ENGINE.
ylinder
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circle 1 on reader service card
Established 1882 Vol. 156 No. 11 November 2012
Look for this web-exclusive story under
the Features heading on our homepage,
www.powermag.com, during the
month of November or in our Archives
any time: Too Dumb to Meter, Part 5.
Its the latest installment of Contribut-
ing Editor Kennedy Maizes history of
nuclear power in the U.S.
And remember to check our Whats
New? segment on the homepage regu-
larly for just-posted news stories cover-
ing all fuels and technologies.
More POWER Nuclear
Coverage on the Web
32
34
02_PWR_110112_TOC&Mast.indd 1 10/13/12 4:01:10 PM
www.powermag.com POWER
|
November 2012 2
FEATURES
POWER IN CHINA
48 Post-Fukushima Nuclear Power Development in China
When Chinas neighbor suffered the devastation of the Fukushima Daiichi nucle-
ar plant disaster, it prompted a reconsideration of Chinas nuclear development
goals. Despite some expected short-term adjustments, the long-term goals re-
main virtually unchanged.
WATER & POWER
53 Potential Impacts of Closed-Cycle Cooling Retrofits at U.S. Power Plants
Though the best technology available (BTA) determination under the Environmental
Protection Agencys proposed rule for cooling water intake structures is not yet written
in stone, industry researchers are looking at the likely consequences if BTA is closed-
cycle cooling. EPRI recently completed a study of estimated costs, benefits, impacts,
and environmental consequences of a potential national requirement to retrofit cool-
ing towers on all once-through facilities in the U.S. The estimated costs? Over $100
billion.
AIR QUALITY
57 Hazy Timetable for EPAs Proposed Tighter PM2.5 Standards
Its a question of when, not if tighter particulate standards will be released by
the Environmental Protection Agency, so its time to take a close look at the techni-
cal and economic particulars of whats likely to be involved for plants that will be
affected by the new limits.
PLANT DESIGN
62 The Evolution of Steam Attemperation
Increased superheated steam volumes and temperatures plus diverse operational
modes challenge steam attemperator systems at combined cycle plants. Know the
design options and engineering considerations before you choose a new or replace-
ment system.
DEPARTMENTS
SPEAKING OF POWER
6 Economic Meltdown
GLOBAL MONITOR
8 France Considers Departure from Iconic Stance on Nuclear Energy
10 THE BIG PICTURE: Advanced Fission
12 After Blackouts, India Plans Reforms
12 Progress for Germanys Power-to-Gas Drive
14 Research Center Dedicated to Power Plant Water Use Opens
15 POWER Digest
FOCUS ON O&M
18 Seismic Instrumentation at Nuclear Power Plants
20 Maximizing Steam Turbine/Compressor Performance with Precise
Torque Monitoring at the Coupling
22 Measuring On-Time Completion to Improve Your EHS Audit Program
LEGAL & REGULATORY
28 EPAs Title V Source Policy Takes a Hit
By Angela Neville, JD
66 NEW PRODUCTS
COMMENTARY
72 Preparing for the EPAs Cooling Water Rule
By Harold M. Blinderman, JD, partner, Day Pitney
Connect with POWER
If you like POWER magazine, follow us
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November 2012 4
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TWO GREAT
COMPANIES.
ONE BRIGHT
FUTURE.
How do you create a global company built
for the future? By combining two powerful
histories in pursuit of a bold visionto help
companies around the world contribute to
healthier, safer environments.
Building on the achievements of Pentair and Tycos Flow Control
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and Water & Environmental Systems, the new Pentair delivers
exceptional depth and expertise in filtration and processing, flow
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businesses, comprised of Valves & Controls, Thermal Controls
and Water & Environmental Systems, the new Pentair delivers
exceptional depth and expertise in filtration and processing, flow
management, equipment protection and thermal management.
From water to power
From energy to construction
From food service to residential
Were 30,000 employees strong, combining inventive thinking
with disciplined execution to deploy solutions that help better
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November 2012 6
SPEAKING OF POWER
Economic Meltdown
T
he bill for German Chancellor An-
gela Merkels coalition governments
knee-jerk decision to close all 17
of its nuclear plants by 2022 is coming
due. Merkels energy plan is to radically
expand the use of renewable energy to
35% of total power consumption by 2020
and to 80% by 2050. Currently, renew-
ables represent 20% of the countrys en-
ergy mix.
You may recall my editorial (Irrational
Exuberance, December 2011) in which I
estimated the cost of replacing Germa-
nys lost nuclear capacity with wind and
solar. My back-of-the-envelope numbers
suggested that the added costs to Ger-
man electric rates for renewables would
rise to 7 cents/kWh by 2020 and that the
plan will cause household electric rates
to rise about 6% per year for the next
nine years. I was wrong. My long-term
rate of increase estimate took place in
the first year and is not sustainable.
Steep Residential Rates
The German Economy Ministry has stated
that the renewable energy subsidy portion
of the Renewable Energy Act (EEG) of the
residential electricity bill will rise to be-
tween 5.9 and 6.6 cents/kWh this year (not
including the 19% value added tax, VAT) to
help pay for Merkels renewable energy poli-
cies, an increase of 30% to 50% over last
year. Some in the government have sug-
gested the EEG may soon rise to 7.5 cents/
kWh, a 70% increase in one year.
Berlin Technical University Professor
Georg Erdmanns calculations show the
EEG portion of the consumers electricity
bill will jump to over 10 cents/kWh, or
nearly three times what Merkel pledged
to consumers when revealing her energy
plan less than a year ago. Remember,
this is only the additional cost to the
monthly bill to pay for the extremely lu-
crative 20-year feed-in tariff contracts
for renewable electricity. For 2011, the
average household electricity price was
31.6 cents/kWh, according to Eurostat,
not including the VAT, three and one half
times more than the average household
pays in the U.S.
German government data suggests that
consumers will pay out $125 billion over
the next 20 years to subsidize renew-
ables installed before the end of 2011;
the number rises to $250 billion if future
hookups are included. Erdmann predicts
the real number is well over $375 billion
because the rate of photovoltaic (PV) in-
stallations is much higher than govern-
ment predictions. In 2011 alone, 7.5 GW
of solar were installeddouble govern-
ment estimates.
Public interest groups condemn these
rapidly accelerating electricity prices as
unfairly impacting those on fixed incomes.
Private households are expected to pay
for an energy transition for which no clear
plan exists, says Holger Krawinkel of the
Federation of German Consumer Organiza-
tions. The group says that one-seventh of
Germanys households now live in energy
poverty. Government data shows that
more than 600,000 households had their
electricity turned off for non-payment in
2011. Its no wonder that many public ad-
vocacy groups are protesting the rapidly
rising rates in the name of social justice.
Industrial Advantage
Germanys largest industrial power consum-
ers have always enjoyed generous electric-
ity rate subsidies. Eurostat data shows that
the price of electricity for the largest indus-
trial users is one-half of that for consumers.
In fact, industrial users are required to pay
only 0.3% of the cost of the EEG mandated
renewable feed-in tariffs!
Even so, the large industrial rates are
the highest in the European Union and
are expected to rise 20% by 2020. Ac-
cording to the Association of German
Chambers of Industry and Commerce
(DIHK), high electricity rates are a prin-
cipal cause of the acceleration of Germa-
nys de-industrialization. DIHK reports
that almost one in five industrial compa-
nies plans to increase capacities abroad,
if it hasnt done so already.
Projects Behind Schedule
PV projects are moving quickly, but off-
shore wind projects are becalmed. Moving
expensive yet abundant offshore wind en-
ergy to Germanys industrial south requires
thousands of kilometers of new transmis-
sion lines. Its not surprising that many
local jurisdictions dont want these new
transmission towers in their districts or
are demanding expensive undergrounding
of the wires. Siting of these new lines is at
a virtual standstill across Germany.
In May, the operators of Germanys
four power grids presented their esti-
mates of the costs to comply with the
German governments national expan-
sion of the grid: $25 billion over the
next 10 years. TenneT, the Netherlands
state-owned grid operator (which also
supplies about a third of Germany), says
it will cost an additional $15 billion in
grid improvements to connect just the
first wave of offshore wind turbines to
the grid by 2020, and the economics
dont justify the investment. In addi-
tion, another 4,000 kilometers (km) of
existing lines must be modernized, al-
though that cost wasnt noted.
Many offshore wind parks are now un-
der construction, some up to 200 km out
in the Baltic Sea and the North Sea, but
none has been finished. Without trans-
mission lines, many projects are at a
standstill; at least one project is three
years behind schedule. Also, technical
problems are confounding developers
relying on unproven HVDC systems con-
nected to very long undersea cables. In
the meantime, the government is again
looking to the consumer to pay for these
project delays.
The Green Party has taken the position
that it is necessary to make financial sac-
rifices for the sake of the environmen-
tal transformation of society. Germanys
transformation has barely begun, but
it seems to me that the consumers have
already been sacrificed.
Dr. Robert Peltier, PE is POWERs
editor-in-chief.
he Westinghouse AP1000 nuclear power plant is the most advanced
design available in the global marketplace. he AP1000 plant was
designed to make use of modern, modular-construction techniques
enabling shorter construction times, lowering construction costs and
bringing opportunities to local suppliers.
he AP1000 design is the only advanced plant that can ofer regulatory
certainty with the recent issuance of Final Design Certiication from
the U.S. Nuclear Regulatory Commission (NRC) and interim design
approval by regulatory authorities in the United Kingdom.
To date, a total of ten AP1000 reactors are under contract four in
China and six in the US. Construction is underway on four units
in the US (Vogtle and VC Summer), ater receiving their combined
construction and operating licenses in 2012. All four Chinese plants
remain on schedule, with the irst Sanmen unit on track to produce
electricity by the end of 2013.
he AP1000 plant is ready to provide future generations with safe,
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Check us out at www.westinghousenuclear.com
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November 2012 8
France Considers Departure from Iconic
Stance on Nuclear Energy
No other country has been as frequently cited as an example
of exploiting the virtues of a nuclear-heavy energy policy as
France. Deriving more than 75% of its electricity from 58 op-
erational nuclear reactors with a total capacity of about 63 GW,
France has one of the lowest costs of generation and is the
worlds largest net exporter of power, earning 3 billion ($3.9
billion) a year from sales of surplus power to buyers beyond its
borders. But that is all about to change.
Having few indigenous energy resources, and impelled by the first
oil shock of 1974, the French government embarked on a pointed
mission to rapidly expand the countrys nuclear power capacity. Sub-
sequent parliamentary debate reaffirmed nuclears central role in the
countrys energy policy, which stresses security of supply and ad-
dressing environmental concerns, including mitigating greenhouse
gas emissions and properly managing radioactive waste. As well as
developing a closed fuel cyclenearly 17% of the countrys electricity
is produced from recycled nuclear fuelFrance has also established
research policy that incorporates its heavy engineering experience
and seeks to develop innovative nuclear energy technologies.
Considering that nuclear energy is so important to France, it is no
surprise that it has featured in blueprints of the countrys economic
future. Spearheaded by former President Nicolas Sarkozy, the coun-
try in 2008 established the Agence France Nuclaire International
(AFNI), a vehicle to help set up civil nuclear programs in other
countries. Sarkozys government called for a massive resurgence of
nuclear power, extolling its ability to combat climate change, pro-
vide an economic boost, and achieve energy independence.
But even before the devastating Fukushima crisis in Japan in
March 2011, experts say some French citizens had been pushing
back, contesting the almost religious consensus on the matter
of the countrys reliance on nuclear power. As early as 2008, a few
nuclear experts associated with Global Chance (whose members are
academic and institutional scientistsa group comparable to the
Union of Concerned Scientists in the U.S.) confronted what it called
the official narrative.
They alleged that the image of Frances nuclear program as a highly
successful industry was a sham. Development of nuclear power was
marked by a succession of technological blind alleys, planning errors
and all kinds of difficulties, which are generally noted and corrected
without any public discussion. The economic justification of vend-
ing nuclear technology was also particularly suspicious, the group
claimed, citing a lack of transparency on several crucial levels: Official
projected investment costs for a number of projects were consistently
lower than actual costs, andas exemplified by the two EPR reac-
tors under construction at sites in France and Finlandconstruction
times and load factors often lagged behind projected figures.
When the Fukushima accident happened, as Germany and Tai-
wan vowed to phase out nuclear power entirely, cracks in Frances
nuclear facade widened. Public concerns for safety mounted as anti-
nuclear groups highlighted startling statistics that showed French
nuclear plants saw 700 to 800 incidents a year, varying in serious-
ness. And when Socialist Franois Hollande ran on a platform pro-
posing to reduce nuclears share of the countrys energy mix from
75% to 50% by 2025, and pledged to order the closure of the two-
unit Fessenheim before the end of his first term in 2017, he won,
albeit narrowly, over incumbent Sarkozy, who had called Hollandes
policies economically disastrous.
Hollande has, since the election, reiterated his pledge to cap
nuclears share at 50%, promising a transition strategy based on
energy efficiency and renewable energy. At a two-day conference
in September, he said his government was pushing for closure of
Frances oldest nuclear plant, the 1977-built Fessenheim plant
in Alsace, near the German border, within four years, and that it
would make an example of successful decommissioning (Figure
1). Meanwhile, he said new tenders for solar and offshore wind
power would be launched before the end of 2012.
Even though Frances nuclear industry employs about 400,000
heavily unionized workers, the avowal has not been strongly po-
litically contestedsave by the Greens Party, which captured 17
parliamentary seats in May after coalescing with the center-right
Socialists and having accepted the Socialists goal of a 50% nuclear
cap (which is far higher than their own goal of zero).
Site directors of all nuclear plants operated by Fessenheims
owner EDF have protested the closure of Fessenheim in an open
letter, calling it a profound injustice. The decision would create
uncertainty about EDFs plans for its nuclear plant fleet and casts
doubt on employment and economic development for the regions
in which nuclear plants are sited, the letter said.
Some experts express skepticism about how France will carry out
the transition. At the end of 2011, of Frances total generating ca-
pacity of 126 GW, 25 GW was hydro, 28 GW fossil fuel, 6.6 GW wind,
and 2.2. GW solar PV. Counting hydro, renewables made up 13% of
the countrys total generated electricitybut that is well below the
23% target set by Sarkozy for 2020. Experts point out that compared
with its neighbors Germany and Spain, only 2% of generated power
comes from wind, while solar power makes up less than 0.5%.
Most nuclear industry stakeholders in France concede that a
fair debate on Frances energy future is warranted. A formal na-
tional discussion has been scheduled by Minister for Environ-
ment, Sustainable Development and Energy Delphine Batho. It
includes an information phase that will take place between
November and December this year, followed by a public participa-
1. The end of an era. Newly installed French President Franois
Hollande defeated incumbent Nicolas Sarkozy in May by running on a
platform that proposed to cut Frances share of nuclear energy from 75%
to 50% by 2025 and to shut the 1978-built two-unit Fessenheim plant,
shown here, before the end of his term in 2017. Fessenheim, located in
the Alsace region of northeastern France, is the countrys oldest nuclear
plant. French regulators in 2011 deemed the plant suitable to operate for
another 10 years if it made some improvements. Courtesy: EDF
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THE BIG PICTURE: Advanced Fission
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November 2012 12
tion phase (via webcast and regional conferences) from January
through April 2013. Recommendations for the energy transition
will be made in May 2013 following the discussion, and a new
energy policy bill could emerge as early as June 2013. Batho has
noted that the discussion will pay particular attention to social
issues and economic transitions as well as industrial and profes-
sional retraining authorities.
After Blackouts, India Plans Reforms
The back-to-back collapse at the end of July of Indias Northern,
Eastern, and Northeastern grids that slashed power to more than
60% of Indias population of 1.24 billion has impelled the coun-
try into a spending frenzy to upgrade its rickety power network,
which, a government inquiry revealed, was one cause of the
unprecedented blackouts. But the 10th-largest economy in the
world has much more work to do, including a much-needed over-
haul of its current patchwork of energy policies, experts say.
The blackouts on July 30 and July 31 afflicted a massive swath
of the subcontinent stretching 2,000 miles from Assam on the
east, near China, to the Himalayas in the north, and the north-
western deserts of Rajasthan. The Western and Southern grids
were unaffected, leaving Gujarat and many southern states un-
touched by the chaos. In the days after the blackouts, as the
country registered how immense the problem was, the govern-
ment jumped into action.
As speculation mounted about the cause of the blackouts,
the governments first order was to assemble a three-member
panel to determine the reason for the massive failures. In an 81-
page report issued on Aug. 16, the panel pinned the causes on
weak interregional power transmission corridors that had been
compromised by multiple existing outages. Northern India was
already seeing excessive power demand, and a chronic supply
shortfall was exacerbated by lower-than-normal rainfall from the
weak summer monsoon that strained the countrys hydroelectric
power supply. But on July 30, several utilities overdrew from the
Northern Grid despite instructions from regional load dispatch
centers, causing its collapse and putting out the lights for the
more than 300 million people it serves across nine states.
On July 31, after the Northern region was separated from the
Western region following the trip of the 400-kV Bina-Gwalior line,
the Eastern and Northeastern grids collapsed, barring a few pock-
ets, due to multiple tripping attributed to the internal power
swings, under frequency and overvoltage at different places, the
report said. Restoration took five hours, eight hours, and two hours
in the Northern, Eastern, and Northeastern regions, respectively.
Several measures could have saved the system from collapse,
the report pointedly concluded, including better coordinated
planning of outages of state and regional networks, specifically
under depleted condition of the inter-regional power transfer cor-
ridors, and better regulation to limit overdrawal/underdrawal.
The panels message was clear. In September, Power Grid Corp.
of India, the nations largest electricity transmission company,
pledged to spend 1 trillion rupees ($18 billion) to upgrade its
network over the next five years. The urgency is not understated,
company officials say, noting that India plans to increase its
generating capacity by 76 GW by 2017. Making sure a collapse
doesnt happen again is our top priority, Power Grid Chairman
R.N. Nayak said in an interview with Bloomberg on Sept. 14.
We may end up crossing that 1 trillion-rupee spending mark to
strengthen and stabilize the gaps exposed by the blackouts.
Yet that is only the tip of the iceberg, say experts from the
International Energy Agency in a September report outlin-
ing challenges that the country must address to create a well-
functioning, financially viable power sector. Hurdling the first of
those challenges will require further reform of the electricity sec-
tor, whereby the nations energy companies can achieve mana-
gerial autonomy from central or state ministries . . . for timely
investment. The key issue is not private- versus publicly-owned
entities; rather, ownership should not interfere with market prin-
ciples, the report says.
Another pressing reform involves pricing mechanisms. The cur-
rent rigid pricing setting determined by the government does not
reflect realistic costs, and this has been a primary cause of Indias
recurring fiscal and supply-side problems, the report says. Indias
power sector is overwhelmingly afflicted by a shortage of fuels,
insufficient infrastructure, and financial weakness of state-owned
power companiesand these are issues caused by distorted pric-
ing mechanisms and a systematic weakness to enforce legitimate
revenue realization.
One way that India could possibly become an open and func-
tioning energy market is by electing strong political leadership to
convey clear policy messages. Frequent populist remarks, which,
for example, promise free electricity, are not conducive to creat-
ing the right public perception of energy as a commodity, not an
entitlement. Furthermore, in the context of an increasing need
for investments and the integration of Indias energy sector into
the global energy market, India needs to align its energy policies
and institutions with global practices, it concluded.
Progress for Germanys
Power-to-Gas Drive
Germanys E.ON this August began construction of a new pilot plant
in Falkenhagen in northeast Germany that will convert excess wind
2. Blackout. When the Northern, Eastern, and Northeastern grids
collapsed on July 30 and 31, more than 60% of Indias population of
1.24 billion across 22 states experienced power outages lasting as long
as eight hours. States shaded in dark red are those that were affected
on July 30; lighter red indicates additional states affected on July 31.
Source: Wikipedia
States and Union Territories
Map of India
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November 2012 14
energy into synthetic natural gas that can then be fed into the re-
gional gas grid, where it can be used to produce heat and power.
The technology is not new. In 2010, German researchers
at the Center for Solar Energy and Hydrogen Research Baden-
Wrttemberg, in cooperation with the Fraunhofer Institute for
Wind Energy and Energy System Technology IWES, announced
they had developed what they called a power-to-gas process,
which essentially employs hydrogen-electrolysis with metha-
nization. It involves splitting water using surplus renewable
energy to create hydrogen and oxygen. A chemical reaction of
hydrogen with carbon dioxide generates methaneor synthetic
natural gas (Figure 3). The researchers then built a 25-kW pilot
plant in Stuttgart, supported by Austrian company SolarFuel. A
second 250-kW research facility is now in the works, scheduled
for completion this year.
The technology seems to have made major strides since the
first pilot. SolarFuel is currently working on a project that will
see the construction of an industrial pilot facility in Werlte near
Oldenburg for the production of renewable gas (or e-gas) for use
in Audi vehicles. If all goes as planned and the facility begins
operating in the third quarter of 2013, power from four 3.6-MW
offshore wind turbines will be sourced to produce around 4,000
cubic meters of renewable methane for a connected load of 6.3
MW, fueling 1,500 turbo-compressed natural gas (TCNG) Audi A3
vehicles for a year. Audi plans to begin serial production of this
vehicle type next year.
Meanwhile, E.ON is just one of a dozen parties interested in
the technology. European firm ENERTAG has also gotten into the
game, partnering with Swedish utility Vattenfall and other com-
panies to build a 6-MW hybrid power station that transforms wind
energy into hydrogen in Prenzlau. After converting excess wind
energy to hydrogen, the plant uses that hydrogen and biogas to
generate power and heat.
But E.ONs project is unique in that it involves methanization
and is of a larger scale, consisting of a 2-MW storage facility
(over a 24-hour period, the facility will store about 30 MWh
of energy). The hydrogen gas produced from the Falkenhagen
plant at a rate of 360 cubic meters per hour will be injected
into the regional natural gas pipeline, making the natural gas
pipeline network a storage system for surplus electrical power
generated from renewable resources.
The project involves a turnkey contract awarded to Canadian
company Hydrogenics Corp., which means that firm will supply,
install, connect, and commission most components of the hy-
drogen production facility, including gas compression and mas-
ter controls, and ready it for operationscheduled for 2013.
In a larger context, the technology had been lauded as showing
tremendous promiseparticularly in Germany, because it is well-
suited to the countrys infrastructure. Germany reportedly has a
natural gas storage reservoir equivalent to more than 200 TWh.
Integration into the infrastructure is simple, developers say: The
natural gas substitute can be stored like conventional natural gas
in the supply network, pipelines, and storage systems in order to
fuel natural gas cars or fire natural gas heating systems.
The approach, which is still relatively new and expensive, is
strongly being promoted by Germanys federal power and gas agen-
cy, the Bundesnetzagentur, which in November 2011 held a con-
ference to discuss new developments in the field. Matthias Kurth,
president of the Bundesnetzagentur, has said that it could also
prove invaluable to Germany in light of the nations change of
direction in energy policy towards a renewable future. In addition
to grid expansion and intelligent load and generation management,
considerably more storage capacity will in fact be required to bal-
ance fluctuations in solar and wind power generation. Pumped-
storage power stations are a good solution for short-term load
balancing, but there is only limited capacity available in Germany.
Long-term storage is therefore a major challenge when it comes to
transforming the energy supply system, he said.
Research Center Dedicated to Power
Plant Water Use Opens
The Electric Power Research Institute and several partners
including the Southern Research Institute, Southern Co. sub-
sidiary Georgia Power, and Southern Researchare testing a
new technology that could reduce the amount of water needed
for power plant cooling. The work is taking place at the new
Water Research Center (WRC) at Georgia Powers Plant Bowen in
Cartersville, Ga.a novel facility dedicated to developing and
testing technologies to reduce power plant water withdrawals
and consumption.
The partners are evaluating a new thermosyphon cooler tech-
nology developed by Johnson Controls (Figure 4). According
to the Wisconsin-based firm, the technology transfers heat
to the environment without evaporative water loss by using
an air-cooled refrigerant that pre-cools water before it enters
the cooling tower. The thermosyphon cooler also reduces the
3. Storing gas. Power-to-gas, a fairly new type of energy storage,
involves converting renewable power to hydrogen, using electrolysis,
and then chemically converting it to methaneor synthetic natural
gasfor storage in existing gas grids. Austrian company SolarFuel
was among the first to collaborate with German researchers as they
developed the process. Source: SolarFuel; Specht, Sterner et al.
Conversion into electricity
Storage of electricity
Combined cycle
plant/CHP
Methanization
Electrolysis/
H
2
tank
Power grid
Gas grid
Wind
Sun
CO
2
CO
2
tank
CO
2
CH
4
CO
2
H
2 H
2
Gas storage
tank
4. Testing the water. The newly opened Water Research Center
at Georgia Powers Plant Bowen in Cartersville, Ga., will develop and
test technologies to reduce power plant water withdrawals and con-
sumption. This image shows Johnson Controls thermosyphon cooler,
which is the first project to become operational at the center. Courtesy:
Georgia Power
November 2012
|
POWER www.powermag.com 15
amount of water that must be cooled by
evaporation in the cooling tower, thus
reducing water consumption. The year-
long testing at the WRC will document
the technologys water-saving potential
and energy consumption characteristics,
developers say.
The WRC will have seven distinct focus
areas: moisture recovery; cooling tower
and advanced cooling systems; zero liq-
uid discharge; low-volume wastewater
treatment; solid landfill water manage-
ment; carbon technology water issues;
and water modeling, monitoring, and
best management practices.
POWER Digest
Global Companies Take on Nigerias
Newly Privatized Plants. Nigerias $1
billion liquidation of five government-
owned thermal and hydropower generation
companiespart of a wider privatization
effort that includes transmission and dis-
tribution assets to encourage investment
in the power shortagestricken countrys
electricity sectorhas attracted a number
of global companies and investors. Eight
firms bid a total of $707 million for the
434-MW Gerugu plant, 832-MW Ugheli
plant, 1,020-MW Sapele plant, 600-MW
Shiroro plant, and 760-MW Kainji plant,
but five consortia were picked as preferred
bidders for the successor companies cre-
ated from the divestiture of Power Hold-
ing Co. of Nigeria.
Among the highest bidders was a con-
sortium listing Nigerian conglomerate
Transcorp and U.S. firm Symbion Power,
which offered $300 million for the gas-fired
Ugheli plant. Another consisted of a Chi-
nese firm and Eurafric, a Nigerian oil and
gas firm, which bid $201 million for the
thermal Sapele plant. And one listing was
for Forte Oil, Shanghai Municipal Electric
Power Co., and BSG Power, which bid $132
million for the gas-fired Gerugu plant. Man-
agement contracts for the two hydropower
plants went to consortiums that included
several Nigerian firms, Russias RusHydro,
and China Three Gorges Corp.
Two CFB Contracts for Foster Wheel-
er in South Korea. Foster Wheeler in
September won a contract from South Ko-
reas Yeosu Cogeneration Corp., a subsid-
iary of Hanwha Corp., for the design and
supply of a 60-MWe circulating fluidized-
bed (CFB) steam generator located in an
industrial complex in Yeosu City, South
Korea, that is slated to go online in the
first quarter of 2015.
In October, the global engineering and
construction company Foster Wheeler re-
ceived a full notice to proceed on a separate
contract with Doosan Heavy Industries &
Construction Co., Ltd. for cooperation in
the design of a 350-MWe CFB steam gen-
erator for the Yeosu Thermal Power Plant
1 Project for Korea South East Power Co.,
Ltd. Doosan will supply the major equip-
ment, including the CFB boiler and turbine
generator for the Yeosu 1 project, which
will replace an existing heavy oilfired
unit. That project is also expected to be
completed in the first quarter of 2015.
Demand for CFB boilers is increasing in
South Korea and other countries, pegged
on the growing use of low-quality coal, of
which there are large reserves, a Doosan
official said in a statement.
Coal Gasification Power Plant Devel-
oper Secures Construction, Financing
Contracts. Seattle-based Summit Power
Group on Sept. 12 signed a memorandum
of understanding with representatives of
Chinas Sinopec Engineering Group for an
engineering, procurement, and construc-
Scan the QR Code for more information
877-4SI-POWER
or go to
www.structint.com/power
Structural Integrity works hard and believes in our expertise to help power plants solve
problems. As Experts in the prevention and control of structural and mechanical
failures, our engineering experts help with:
Comprehensive Turbine Generator Assessment
Planning
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Our expertise encompasses many other plant components and systems, as well as
comprehensive, innovative solutions including Guided Wave Testing, Direct Assessment,
Root Cause Analyses, Welding Engineering, Linear Phased Array NDE and more.
Call us today at 877-474-7693 for a quote or for help preventing future problems.
Were experts you can rely on.
Sir Charles Algernon Parsons
1854 1931 was an Anglo-Irish engineer, best known for his inven-
tion of the steam turbine. He worked as an engineer on dynamo and
turbine design, and power generation, with great inluence on the
naval and electrical engineering ields.
IF YOU BELIEVE IN A
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November 2012 16
tion contract, and with the Export-Import Bank of China to
secure financing for the $2.5 billion Texas Clean Energy Project
(TCEP), a large-scale commercial coal gasification power/polygen
project that the company is developing near Odessa, Texas.
Siemens Energy is expected to provide a high-hydrogen com-
bustion turbine for the project, which proposes to remove carbon
dioxide, sulfur, and mercury from the projects gas stream prior to
combustion, leaving only a high-hydrogen/low-carbon clean syn-
gas as the sole fuel that is burned. The project will capture 90%
of its carbon dioxide emissions for use in enhanced oil recovery by
producers in the Permian Basin of West Texas. TCEP will also produce
more than 700,000 tons per year of urea as fertilizer, which will be
bought entirely by Minnesota-based CHS Inc., and Houston-based
Shrieve Chemical Co. will purchase TCEPs output (about 50,000
tons per year) of sulfuric acid. CPS Energy, San Antonios municipal
electric and gas utility, will buy 200 MW of the plants power.
About $450 million of TCEPs costs will be covered by a Depart-
ment of Energy cost-sharing program under the federal Clean Coal
Power Initiative.
RWE Opens 2-GW CCGT Plant in West Wales. RWE AG
opened its 2,160-MW Pembroke combined cycle gas turbine plant
on Sept. 19, handing over the fifth and final unit of the station
to its UK subsidiary RWE npower and culminating three years of
construction during which more than 10,000 contractors worked
7.4 million man hours to complete the $1.6 billion facility. The
new plant was built on a site formerly occupied by a 2,000-MW
oil-fired power station. The station was outfitted with five Als-
tom GT26 single-shaft gas turbines, five drum-type heat recovery
steam generators, five STF30C steam turbines with axial exhaust,
and five TOPGAS turbo-generators. Swiss company ABB supplied
the automation system and the Shaw Group put up five heat
recovery steam generator boilers.
The power from the new plant in west Wales is badly needed by
the UK: About 40% of the countrys existing generation facilities
were built before 1975 and are expected to be shuttered over the
next 10 to 15 years. Several fossil fuelfired plantsincluding
RWEs own 2,000-MW coal-fired Didcot A power plant and the
1,000-MW oil-fired Fawley plantwill be shut down in line with
requirements of the European Unions Large Combustion Plant
Directive. Many nuclear power plants are also reaching the end
of their operational lives. Meanwhile, power demand in the UK
is expected to surge, forcing the country to increase generating
capacity by 35 GW by 2020 to ensure energy reliability.
SunPower Corp. Completes 1.3-MW Rooftop Solar Proj-
ect in San Francisco. California firm SunPower Corp. on Sept.
19 completed a 1.3-MW solar system on the roof of the Explor-
atorium, a massive science museum under construction at Pier 15
in the heart of San Franciscos waterfront district. The system will
generate as many kilowatt-hours of power as the facility needs
when it opens in the spring of 2013. It uses 5,874 SunPower so-
lar panels, which the company says are up to 50% more efficient
than conventional panels, and a performance-monitoring system
that displays system performance, updated every 15 minutes, in
the lobby of the new 330,000-square-foot facility. Any energy
unused by the Exploratorium will be fed into the utility grid for
use by other Pacific Gas & Electric customers.
FENOC Plans to Expand Nuclear Fuel Storage Capacity at
Beaver Valley. FirstEnergy Nuclear Operating Co. (FENOC) on
Sept. 19 announced plans to expand used nuclear fuel storage ca-
pacity at its two-unit Beaver Valley Power Station in Shippingport,
Pa. The FirstEnergy subsidiary plans to install six above-ground,
airtight steel and concrete canisters that provide cooling to used
fuel assemblies through natural air circulation starting in the fall of
2012, but it says at least 47 additional canisters may be added as
needed after that projects completion in 2014. The canisters will be
stored on a thick concrete pad located within Beaver Valleys highly
secured protected area, providing additional safety assurance. The
storage system will be monitored closely by trained personnel and
the Nuclear Regulatory Commission to ensure its integrity.
Beaver Valley began operation of Unit 1 in 1976 and Unit 2 in
1987, and its used fuel assemblies have been stored in an indoor,
steel-lined pool within the power station. Approximately 40%
of each units 157 fuel assemblies are replaced and then stored
in the pool following each 18-month operating cycle. But the
fuel pool is expected to reach full storage capacity by 2015, and
because a national repository for used nuclear fuel has not yet
been developed, Beaver Valley must plan for additional storage
space, the company said.
Plant Barry CCS Demonstration Begins Underground In-
jection. A carbon capture and sequestration (CCS) demonstration
project jointly under way by Mitsubishi Heavy Industries Ltd.
(MHI) and Southern Co. in September began underground injec-
tion of carbon dioxide (CO
2
) recovered from flue gas emissions
of a carbon capture facility built at Southern Co.s Plant Barry in
Alabama. The demonstration test, which began last June, is the
worlds largest in scale, capturing 500 metric tons per day (mtpd)
with a CO
2
recovery efficiency of above 90%.
Injection is being performed in a saline formation at a depth
of 3,000 to 3,400 meters in the Citronelle Dome geologic struc-
ture, which is approximately 12 miles west of the plant. The se-
questration aspect of the project is being conducted as Phase
III of the Regional Carbon Sequestration Partnerships program, a
program sponsored by the U.S. Department of Energy.
The carbon capture facility consists primarily of a flue gas
scrubber, flue gas CO
2
capture/regeneration system, CO
2
compres-
sion machinery, and electrical components. For CO
2
recovery the
facility adopts MHIs KM CDR Process, which uses a proprietary
KS-1 high-performance solvent for CO
2
absorption and desorption
that was jointly developed by MHI and the Kansai Electric Power
Co., Inc. MHI said it had previously completed small-scale dem-
onstration testing at 10 mtpd in cooperation with the Research
Institute of Innovative Technology for the Earth and Electric
Power Development Co., Ltd. (J-POWER) and confirmed unin-
terrupted stable operation.
Westinghouse Prepares for Possible AP1000 Construc-
tion in Czech Republic. Westinghouse Electric, one of three
bidders vying for a multi-billion-dollar tender from Czech utility
CEZ to construct two new units at its Temeln nuclear power sta-
tion, on Sept. 11 said it would cooperate with Czech construction
company Hutn monte a.s. to prepare for potential construc-
tion of AP1000 nuclear plants in the Czech Republic and region-
ally. If Westinghouse is awarded the tender, the Toshiba Corp.
unit said Hutn monte would be responsible for performing the
vast majority of the mechanical installation and corresponding
construction testing, including assembly and installation of the
containment vessel.
Westinghouse has embarked on an initiative to develop a lo-
cal supply chain to prepare for construction of the reactors at
Temeln, including signing memoranda of understanding with ma-
jor Czech companies, notably I&C Energo a.s., Metrostav a.s.,
and Vtkovice a.s. Westinghouses bidding competitors include
AREVA, which has put forward its EPR design, and Russias At-
omStroyExport consortium, whose bid is based on Gidropress
MIR-1200 third-generation VVER model under construction at
Leningrad Phase II and Novovoronezh Phase II.
Sonal Patel is POWERs senior writer.
M220EM
W E M A K E W A T E R
A N A L Y S I S S I M P L E R .
F o r m o r e t h a n 6 0y e a r s , w e v e b e e n a tt h e c r e s t o f t h e i n d u s t r y
f i n d i n g s o l u t i o n s t h a t h e l p y o u b e s t m a n a g e y o u r w a t e r .
W a t e r a n a l y s i s h a s t ob er i g h t . Y o u d e s e r v e c o m p l e t e s o l u t i o n s y o u
c a n b ef u l l y c o n f i d e n t i n . H a c h i sy o u r r e s o u r c e f o r e x p e r t a n s w e r s ,
o u t s t a n d i n g s u p p o r t , a n d r e l i a b l e , e a s y - t o - u s e p r o d u c t s .
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November 2012 18
Seismic Instrumentation
at Nuclear Power Plants
When a nuclear power plant experiences
ground motion due to an earthquake, an
evaluation may be needed before allowing
the plant to continue operating or to re-
sume operating if it has been shut down,
as was the case after the seismic event
that shut down both units at Dominions
North Anna Power Station on August 23,
2011. (See p. 34 for a complete analysis
of the event and successful recovery pro-
gram.) The Electric Power Research In-
stitute (EPRI) had previously conducted
research to develop guidance regarding
the types of evaluations and inspections
that would be necessary to ensure that an
earthquake had not caused damage that
could affect safe operation of a plant.
More recently, EPRI has formulated guid-
ance relating to the types of instrumenta-
tion necessary to determine the extent of
the ground motion at a plant site.
For every nuclear plant, an operating
basis earthquake (OBE) has been estab-
lished. The OBE has been defined such
that if it can be determined that the
ground motion experienced at the plant
site did not exceed the design basis, the
plant can continue to operate (or can
return to operation if it has been shut
down). If the ground motion exceeds the
OBE, or if it cannot reliably be established
whether the OBE has been exceeded, the
plant may need to shut down and remain
shut down until it can demonstrate that
the earthquake caused no damage that
could affect safe operation.
Although the OBE is often character-
ized in terms of a single parameter, peak
ground acceleration, it is actually defined
by a response spectrum. A response spec-
trum relates the maximum acceleration or
velocity experienced at a particular loca-
tion to the frequency associated with the
vibrations caused by the earthquake. The
response spectrum is typically presented
in the form shown in Figure 1.
Application of the Nuclear Regulatory
Commissions (NRCs) approved OBE ex-
ceedance criterion requires not only mea-
surement of the OBE parameters (that is,
the response spectrum and cumulative ab-
solute velocity, CAV), but also walkdown
inspections of the plant. CAV indicates
the potential for a recorded earthquake to
cause damage to nuclear plant structures.
It is the absolute area under the accelera-
tion vs. time plot as recorded by a time-
history digital recorder.
If the OBE criterion is not exceeded and
the inspections yield no evidence of sig-
nificant damage, the plant can remain in
operation or be restarted. Valid instrument
data, available within 4 hours after an
earthquake, are necessary to support such
a determination. Thus, it is very impor-
tant that nuclear power plants install and
maintain appropriate seismic instrumenta-
tion that can facilitate prompt evaluations
of earthquake data.
Requirements and Options for
Instrumentation Systems
To assess whether an earthquake has ex-
ceeded the OBE for a nuclear power plant,
it is important for a modern, online, digi-
tal seismic instrumentation system to be
in place. EPRI suggests three options for a
seismic instrumentation system:
Minimum system
Basic automatic system
Complete system that complies with
NRC Regulatory Guide 1.2
Minimum System. The minimum sys-
tem would include one or two accelero-
graphs, depending on how the OBE was
defined for the plant. If the OBE had been
defined in the free field, one instrument
in the free field would be sufficient. On
the other hand, if the OBE had been de-
fined at a building location (for example,
1. Typical earthquake response. The usual form of an earthquake response spectrum
is illustrated. The plot shows maximum acceleration, velocity, or displacement caused by the
recorded earthquake at a range of frequencies associated with the vibrations caused by the
earthquake. Source: EPRI
A
c
c
e
l
e
r
a
t
i
o
n
(
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)
Frequency (Hz)
0.1 1 10 100
Key References
A Criterion for Determining Exceedance
of the Operating Basis Earthquake.
EPRI, Palo Alto, CA: 1988. NP-5930.
Final Policy Statement on Technical
Specifications for Nuclear Power Re-
actors. U.S. Nuclear Regulatory Com-
mission (NRC), Federal Register Notice
58FR39132, July 22, 1993.
Guidelines for Nuclear Plant Response
to an Earthquake. EPRI, Palo Alto, CA:
1989. NP-6695.
Nuclear Power Plant Instrumentation for
Earthquakes. NRC Regulatory Guide 1.12,
1997.
Pre-Earthquake Planning and Immedi-
ate Nuclear Power Plant Operator Post-
Earthquake Actions. NRC Regulatory
Guide 1.166, 1997.
Restart of a Nuclear Power Plant Shut
Down by a Seismic Event. NRC Regu-
latory Guide 1.167, 1997.
Seismic Instrumentation in Nuclear
Power Plants for Response to OBE Ex-
ceedance: Guidance for Implemen-
tation. EPRI, Palo Alto, CA: 1994.
TR-104239.
Standardization of the Cumulative
Absolute Velocity. EPRI, Palo Alto,
CA: 1991. TR-100082.
November 2012
|
POWER www.powermag.com 19
at the top of the basemat of the reactor
containment), both an instrument at that
location and one in the free field would
be required.
In addition to being placed in the loca-
tions at which the OBE is defined, these
instruments would need to meet minimum
qualifications:
The accelerographs would need to have
battery backup, with pre-event memory
sufficient to record the entire earthquake
motion and a storage device that could
accommodate rapid data retrieval.
The instruments must be digital, with
a sampling rate of at least 200 samples
per second.
The instruments would need to cover a
frequency bandwidth of 0.2 to 50 Hz.
A stand-alone desktop or laptop com-
puter equipped with software to per-
form the necessary calculations on the
collected data is required. The software
would need to generate the CAV and
the response spectra. The nature of the
data retrieval and transfer to the com-
puter would need to be such that the
calculations could be completed within
4 hours after the earthquake.
Basic Automatic System. Improved
functionality can be achieved by automat-
ing certain steps that must be performed
manually using the minimum seismic in-
strumentation system. The basic automatic
system would add a dedicated online com-
puter to automatically retrieve data from
the accelerographs and perform the calcu-
lations related to possible exceedance of
the OBE. Such a capability would expedite
the process of assembling the information
needed to make a decision with regard to
whether a plant shutdown is required.
To upgrade from the minimum system
to the basic automatic system, a dedi-
cated cable would be needed from each
instrument to the recording location (typ-
ically, the main control room) to capture
the acceleration time history. The analysis
results should be displayed to the control
room operators in a form that is easy to
understand. An uninterruptable power
source for the computer that records and
analyzes the data would also be needed to
ensure that the results could be available
within the 4-hour timeframe.
Complete System. The complete sys-
tem is the most advanced of the three.
Such a system would incorporate an online
computer for data acquisition and analysis
along with more extensive instrumentation.
The system could be configured so that it
complies with NRC Regulatory Guide 1.12.
Although the minimum and basic automatic
systems could facilitate short-term response,
the complete system would facilitate the
collection of more extensive response data
from within plant structures, enabling more
comprehensive long-term evaluations of the
earthquakes damage potential.
A complete system would incorporate
additional accelerograph locations, rather
than accounting only for the free field and
the location at which the OBE is defined.
Data collected from other response locations
within the containment and auxiliary build-
ings would provide more definitive informa-
tion regarding the impact of the earthquake.
The system would be fully battery-backed.
Costs of Seismic
Instrumentation Systems
The costs to implement a seismic instru-
mentation system will vary from plant to
plant, depending on many factors: what
options are desired for the instrument,
where the sensors might need to be locat-
ed, and whether the instrumentation will
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circle 10 on reader service card
05_PWR_110112_O&M.indd 19 10/13/12 4:55:32 PM
www.powermag.com POWER
|
November 2012 20
augment or replace an existing instrument
system. EPRI estimates the cost of the
minimum system in the range of $120,000
to $180,000, the basic automatic system
at $150,000 to $270,000, and the com-
plete system at $225,000 to $300,000,
although specific site locations could add
additional cost.
A seismic instrumentation installation or
upgrade at a nuclear power plant is sub-
ject to certain licensing considerations. It
should be noted first that voluntary im-
plementation of the earthquake-response
guidelines provided in the four EPRI refer-
ences listed in the sidebar, including in-
stalling new seismic instrumentation, does
not generally require prior NRC approval.
This is a synopsis of an EPRI white paper
originally published in January 2012 and
available at no charge from www.epri.com.
Search for document 1024889.
Edited by Dr. Robert Peltier, PE
Maximizing Steam Turbine/
Compressor Performance
with Precise Torque Moni-
toring at the Coupling
All turbo machinery is subject to degrada-
tion that, over time, will affect the systems
efficiency and operational performance.
Precise monitoring of turbo machinery per-
formance with continuous torque-monitor-
ing systems can be used to identify gradual
efficiency loss. That, in turn, allows a more
focused maintenance scope to be developed
that can return the system to its optimum
operation and efficiency.
Torque monitoring based on heat bal-
ance, energy balance, and other methods
requires measuring numerous parameters
such as pressure, temperature, flow rate,
and gas composition, which require high-
accuracy instrumentation. However, phase
displacement technology can be used to
accurately measure torque directly at the
coupling to within 1% of full-scale torque,
a combination of all electrical and me-
chanical sources of error.
Measure the Torque
A torque-monitoring system was recently
installed on a cracked-gas compressor
train at Qenos Olefins in Australia to de-
termine the causes of a power limitation.
The Kop-Flex Powerlign system installed
utilizes phase displacement technology
for long-term reliability, eliminating the
need for recalibration.
Two rings with pickup teeth are in-
stalled on a torsionally soft spacer and
are intermeshed at a central location. Two
monopole sensors 180 degrees apart are
mounted on the coupling guard. As the
coupling rotates, the ferromagnetic teeth
create an AC voltage waveform in the sen-
sor coil, which is digitally processed using
known calibration parameters. Because of
the intermeshed pickup teeth, the system
is referred to as a single-channel phase
displacement system, producing two inde-
pendent torque measurements (Figure 2).
The Powerlign system will output torque,
power, speed, and temperature, which can
be easily integrated with any distributed
control system (Figure 3).
At the Olefins plant the operating cycle
of the steam-driven, cracked-gas compres-
sor train is seven to eight years. During
this cycle the plant eventually has produc-
tion limitations because the compressor
train encounters a power limit. Turbine
fouling or compressor fouling or a com-
bination of both caused the power limit.
The true cause had long been the subject
of an engineering debate among the Ma-
chinery group, Process Engineering group,
and Operations department.
The power loss was so important that
the plant considered upgrading the tur-
bines power rating from 7.5 MW to 9 MW.
This upgrade would have required a capi-
tal investment of $2 million, so the plant
elected to defer this investment and in-
stead installed a torque meter during the
last eight-year major overhaul shutdown.
The installation involved replacing
the existing coupling spacer and flex-
ible halves with a drop-in torque meter
and integral flexible elements (Figure 4).
The torque meter assembly was dynami-
cally balanced to API standards so it was
not necessary for the user to return any
coupling components for the retrofit. The
coupling guard was modified so that the
two variable-reluctance sensors could be
installed, completing the mechanical in-
stallation (Figures 5 and 6).
Successful Restart
The plant was restarted after completing a
number of compressor efficiency improve-
2. Tracking two signals. The Powerlign system produces two independent torque sig-
nals. Source: Kop-Flex
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3. Important stats. Typical output from Powerlign system includes torque, power, speed,
and temperature. Source: Kop-Flex
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Torque Power Speed Temp
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CIRCLE 11 ON READER SERVICE CARD
www.powermag.com POWER
|
November 2012 22
ments during the overhaul outage. The data
collected from the torque meter clearly
showed the 7.5-MW steam turbine did not
require an uprate and that the major power
losses were coming from the compressor.
The torque meter also allowed online tun-
ing of the seal gas system of the compres-
sor to establish the lowest power draw. The
turbine load was reduced an additional 200
kW with the manual adjustments made on
the seal gas system alone.
The torque meter is now being used to
monitor turbine steam fouling issues and
processes related to compressor fouling so
that the corrective online washing can be ac-
tivated as soon as performance is affected.
The historical data collected from the
torque meter will also provide a baseline
of mechanical loading through the drive
drain of the cracked-gas compressor over
time. This data will be used to determine
if increases in the maximum continuous
operating speed rating of the compressor
and the turbine can be accomplished at
minimal cost. If so, this will increase the
operating envelope of the compressor.
The value of the torque meter justi-
fied installation of a second system in the
plants second steam cracking plant tur-
bine/compressor train in October 2012.
Contributed by Daniel Phillips (daniel.
phillips@emerson.com), manager, field
service engineering, Kop-Flex, Emerson In-
dustrial Automation; Trevor Mayne (trevor.
mayne@qenos.com), machinery engineer,
and Mark Ellul (mark.ellul@qenos.com),
an I & E specialist, for Qenos Olefins Pty
Ltd, Australia.
Measuring On-Time
Completion to Improve
Your EHS Audit Program
Many companies have difficulty ensuring
that issues identified during their envi-
ronmental, health, and safety (EHS) au-
dits get resolved in a timely fashion. This
can be particularly difficult in the utility
industry, where a number of different ac-
tivities may be conducted at a facility,
each managed by a different part of the
organization (such as generation, trans-
mission, and temporary storage of trans-
formers brought in for repair). A number
of factors promote effective and responsi-
ble completion of EHS audit action plans,
with the most important being the proper
alignment of responsibility and authority
for developing and implementing the au-
dit action plan.
Measuring On-Time
Completion Performance
Generally, organizations understand the
need to assign specific corrective and
preventive actions to specific persons.
Ensuring that the periodic review of im-
plemented lockout/tagout procedures is
conducted might be assigned to the facil-
itys maintenance manager. The environ-
mental manager is the probable choice for
realigning written procedures for equip-
ment calibration found in the continuous
emissions monitoring plan with current
practices. The person most closely aligned
with responsibility for implementing the
requirement usually ends up with the as-
signment and the deadline.
But how do you ensure that the actions
do get completed this time? After all, the
item may have been on that persons list
all along, and somehow the responsible
person missed it. The answer is that in
addition to assigning responsibility for
an action to the right person, that person
and his or her supervisor need to be held
accountable for completing the action.
While managing an EHS audit program
at a major waste and recycling services
company that conducts more than 100
audits a year, the corporate managers de-
vised a simple way to monitor progress
on audit action plans. This successful EHS
audit program is outlined in Case Study:
Browning-Ferris Industries Computer-
ized System for Managing Audit and En-
vironmental Performance in Auditing for
Environmental Quality Leadership: Beyond
Compliance to Environmental Excellence,
John T. Willig, Editor, 1995.
Rather than distributing lengthy reports
to management describing actions planned
and actions completed, EHS auditors dis-
tilled their progress into one-page reports
detailing completion performance, showing:
Total number of findings and actions.
Number and percentages of actions
completed.
Number and percentages of actions
completed on or before their respective
target dates.
Short descriptions of actions that were
overdue.
Quickly, and with little need for in-
depth understanding of EHS requirements,
senior management could review these re-
ports and identify which action plans were
being managed well, and which facilities
needed attention and assistance. Regard-
less of how many findings were identified
or how many discrete actions needed to
be tracked to resolve the findings, every
manager could achieve a 100% on-time
completion performanceif he or she
managed the action plan effectively.
This approach adopts the principle
learned from quality management pro-
grams that things that get measured are
things that improve performance. For
example, the Browning-Ferris Industries
(BFI) staff achieved a near doubling of
on-time completion in the first year of
measurement, improving from below 40%
of the items being completed on time to a
nearly 80% completion rate.
Accountability of Senior
Managers
Because supervisors and senior managers
directly influence facility and local manag-
ers by assigning tasks, setting objectives,
and approving budgets and compensation,
senior managers need to be held account-
6. Back in business. This is the com-
pleted mechanical installation of the Power-
lign system. The spacer is covered with the
shaft shield. Courtesy: Kop-Flex
4. Simple retrofit. The Powerlign sys-
tem provides accuracy to within 1% of full-
scale torque, utilizing single-channel phase
displacement. Courtesy: Kop-Flex
5. Shaft replacement. The original
shaft spacer was replaced with a Smart Spac-
er. Courtesy: Kop-Flex
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www.powermag.com POWER
|
November 2012 24
able for completion of EHS audit action
plans as well. This was accomplished by
rolling up the on-time completion perfor-
mance for all the audit action plans for
facilities and activities for which a par-
ticular senior manager has responsibility.
Consider a senior manager who has re-
sponsibility for all the service centers in a
particular geographic area. That manager
would receive a copy of the individual re-
ports showing performance levels for all the
action plans for service centers for which the
manager was responsible. That senior man-
ager would also receive a rating compiled
from the on-time performance for all the ac-
tion items for all of those service centers.
The more activities and properties under a
senior managers direction, the greater the
number of audit action plan items compiled
into that senior managers rating.
In the example shown in Figure 7, the
compiled on-time completion performance
for the two action plans for activities un-
der the control of Senior Manager A is
100%, because all actions for both sites
were completed on time. Senior Manager
B, however, has an on-time completion
performance of only 60%, because 5 of 10
items were completed on time at one site
and 10 of 15 actions were completed on
time at the other site (Figure 8). Manag-
ers in the A grouping receive congratula-
tions, while managers in the B grouping
need assistance and/or attention.
Linking On-Time Completion
Performance to Compensation
Encouraged with the improvement in on-
time completion performance that result-
ed from measurement and reporting, the
company linked measurement to bonus
compensation to promote further improve-
ments. Other operational measures deter-
mined the potential bonus for a manager
and the percentage of actions completed
on time was then multiplied by the poten-
tial bonus. Because on-time completion
performance could range from 0% to 100%,
managers worked hard to complete all their
actions on time so they could receive their
full bonus. Senior managers wanted to
receive 100% of their potential bonus as
well, so they made sure their facility man-
agers completed their action plans on time.
Predictably, as shown in Figure 9, on-time
completion performance of EHS audit ac-
tion plans approached 100% after being
linked to senior managers compensation.
A concern heard too often during EHS
audits of utilities is that the particular
manager initially assigned to implement
an action item doesnt have responsibil-
ity for certain equipment or activities. The
manager might say, The transformer may
be located on this property, but the trans-
mission operations group takes care of it,
not me, or The laboratory is managed by
the shared services group. They essential-
ly lease office space from the generating
plant.
If a responsible manager can be identi-
fied, then responsibility for the action item
can be assigned, and, consequently, on-time
7. Perfect score. Because supervisors and senior managers directly influence facility and
local managers by assigning tasks, setting objectives, and approving budgets and compensation,
senior managers need to be held responsible for completion of environmental health and safety
(EHS) audit action plans. In this example, the compiled on-time completion performance (OTCP)
rate for the two EHS audit action plans under the control of Senior Manager A is 100%, because
all actions for both sites were completed on time. Source: Specialty Technical Consultants
Senior Manager A
OTCP = 100%
25 of 25 actions completed on time
Manager A-1
OTCP = 100%
10 of 10 actions completed on time
Manager A-2
OTCP = 100%
15 of 15 actions completed on time
8. Accountability is key. One of the main principles learned from quality management
programs is that things that get measured are things that can help improve performance. In
contrast to Senior Manager A (Figure 7), Senior Manager B has a low 60% on-time completion
performance rate related to EHS audit action plans because at one site under his supervision
only five of 10 items were completed on time and at another site only 10 of 15 actions were
completed on time. The OTCP rate is a signal that managers in the B grouping need assis-
tance to improve their EHS audit programs. Source: Specialty Technical Consultants
Senior Manager B
OTCP = 60%
15 of 25 actions completed on time
Manager B-1
OTCP = 50%
5 of 10 actions completed on time
Manager B-2
OTCP = 67%
10 of 15 actions completed on time
9. The power of incentives. In this example, the OTCP rate of EHS audit action plans
approached 100% after being linked to senior managers compensation. Assessing senior
staffs management abilities by measuring their on-time completion performance will improve
an organizations ability to resolve audit findings in a timely and effective way and help achieve
the fundamental auditing goal of improving the organizations overall EHS performance. Source:
Specialty Technical Consultants
Early years
When linked to
compensation
First-year
measuring
100%
80%
60%
40%
20%
0%
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CIRCLE 19 ON READER SERVICE CARD
www.powermag.com POWER
|
November 2012 40
NUCLEAR POWER
sustained no functional damage and could be
restarted safely before presenting its finding
to the NRC, which had to give permission for
the units to return to service.
Dominion took the initiative to determine
the process, communicate the details to the
NRC and the public, systematically carry out
the plan, and, finally, present the results in a
clear, convincing manner. The plant tells the
story, Heacock said. We went over North
Anna very systematicallyevery safety sys-
tem, structure and componentand found no
safety-related functional damage. Right from
the beginning, we decided that we would not
bring the station back up until both we and
the NRC independently were fully satisfied
as to its complete safety.
Effective Crisis Management
In Dominions management of the restoration
effort, safety was never compromised and elec-
trical service to customers was never interrupt-
ed, even though the large generation station was
out of service for nearly three months.
Dominion followed extensive safety veri-
fications in restarting the units and worked
very closely with the NRC and other organi-
zations to involve them in the restart process
and keep them informed step by step. Ongo-
ing communications efforts included daily
internal updates through conference calls
as well as coverage in the companys em-
ployee online Connect Today news service,
in its newsmagazine Connect, and in inter-
nal briefings. Company representatives made
presentations to civic organizations about the
earthquake and activities undertaken to re-
turn the units to service.
The NRC conducted and Dominion par-
ticipated in four public meetingstwo in
Louisa County and two at NRC headquarters
in Rockville, Md. The company hosted North
Anna tours for local and national news me-
dia to show them the station and the small
amount of minor of damage incurred at the
site and to counteract any criticism and mis-
information by anti-nuclear organizations.
Coverage was local, regional, national, and
international, with company representatives
issuing no fewer than four formal media an-
nouncements and participating in several
hundred interviews.
Dominion was also proactive in com-
municating with state and local government
officials. The day after the quake, the North
Anna Power Station was visited by both Vir-
ginia Gov. Robert F. McDonnell and House
Majority Leader Eric Cantor, whose Seventh
Congressional District includes the site.
Dominions leadership moved the indus-
try forward. The company worked with the
NRC to establish the protocol for recovering
from a nuclear station shutdown caused by an
earthquake. The agency oversaw the process
and approved the restart within three months
of the quake. In contrast, repairs to the Wash-
ington Monument are scheduled to begin late
this year and are expected to require 12 to
18 months to complete, even though a local
philanthropist donated half the cost of repairs
shortly after the quake.
Shaping the Nuclear Power
Industrys Present and Future
All in all, Dominions rapid and effective re-
sponse to the record Central Virginia quake
prevented an unreasonably extended outage.
It also avoided lingering questions about
nuclear safety and damage to the companys
and the industrys reputations. The company
went above and beyond regulatory require-
ments and in short, efficient order estab-
lished the safety of its units and had them
back online to produce low-cost, emissions-
free power for its customers. In the process,
it demonstrated that Dominion and the U.S.
nuclear industry are capable of handling ex-
treme, nature-induced emergencies in a safe,
effective, and transparent mannerjust as
the public rightfully expects.
Leadership in the nuclear industry cant
be just in science, engineering and technol-
ogy, said Christian. A nuclear operating
company has to be able to perform across
the board, from safety and management to
financial results, from complex regulatory is-
sues to working effectively with a skeptical
and sometimes hostile news media. I believe
our results in this event demonstrated that we
were up to the challenge.
Clearly, the events of August 23 presented a
challenge not only to Dominion but also to the
entire nuclear power industry. Dominions com-
mitment to safety first and the companys lead-
ership in establishing the standards for recovery
from a crisis of this magnitude will positively
affect the future of nuclear power generation in
the U.S. and around the world.
Dr. Robert Peltier, PE is POWERs
editor-in-chief. The substantial assistance
provided by many Dominion employees in
the preparation of this article is gratefully
acknowledged.
North Anna Power Station Restart Timeline
Aug. 23, 1:51 p.m.: A magnitude 5.8
earthquake occurs in Mineral, Va., ap-
proximately 11 miles from North Anna
Power Station. Both reactors shut down
automatically. Safety systems function as
designed to keep the reactors safe.
Aug. 29: U.S. Nuclear Regulatory Com-
mission (NRC) sends an Augmented In-
spection Team (AIT) to North Anna.
Sept. 8: At the first of what will be four
public meetings, Dominion makes an initial
presentation on the earthquake and its im-
pact on North Anna Power Station to NRC
staff in Rockville, Md. The company states
no significant damage has been found.
Sept. 30: NRC issues Confirmatory Ac-
tion Letter, stating that North Anna will
not restart until the Commission has
completed its review of your information,
performed confirmatory inspections, and
completed its safety evaluation review.
The permission to resume operations will
be formally communicated . . . in a written
correspondence.
Oct. 3: At the second public meeting,
the NRCs AIT presents its report at the
North Anna Nuclear Information Center
in Mineral, Va. The NRC also announces
that it will dispatch a Restart Readiness
Inspection team to the station. The AIT
finds that Dominion responded appropri-
ately to protect the public and that the
units are safe.
Oct. 21: Dominion makes its third pub-
lic meeting appearance with the NRC, this
time in front of the NRC commissioners at
NRC headquarters in Rockville. The com-
pany confirms no functional damage was
found after more than 100,000 hours of
inspection and units are ready to restart,
pending NRC approval. The company states
that while some ground force acceleration
frequencies exceeded the stations design
basis for about 3 seconds, the overall im-
pact to the station was well below the de-
sign basis, and the minor damage found
bears this out.
Nov. 1: The NRC has its fourth public
meeting, this time in Louisa County, to
present its Restart Readiness Inspection
Team report. Dominion confirms no func-
tional damage was found, and units are
ready to restart, pending NRC approval.
Nov. 11: Dominion receives NRC letter
granting it permission to restart North
Anna Power Station.
Nov. 15: Unit 1 is restarted and con-
nected to the grid.
Nov. 22: Unit 2 is restarted and con-
nected to the grid.
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CIRCLE 22 ON READER SERVICE CARD
November 2012
|
POWER www.powermag.com 53
WATER & POWER
Potential Impacts of Closed-Cycle
Cooling Retrofits at U.S. Power
Plants
The Clean Water Act Section 316(b) rule changes regarding cooling water in-
take structures that are expected next year could affect up to 428 power
plants, representing 1,156 individual units, according to the Electric Power
Research Institute. Depending on plant size and the complexity of the ret-
rofit project, retrofit capital costs could range from very low to over $500
million for large nuclear plants. The power industry total cost is projected
to be over $100 billion.
By David Bailey, Electric Power Research Institute
P
ower plant owners face numerous chal-
lenges ensuring adequate water supplies
for operations while protecting aquatic
life in the water bodies that provide power plants
with cooling water. In the U.S., Section 316(b)
of the Clean Water Act requires plant owners to
minimize the adverse impacts of impingement
and entrainment mortality by potentially install-
ing fish protection technologies on cooling wa-
ter intake structures. The U.S. Environmental
Protection Agency (EPA) is finalizing regula-
tions under Section 316(b) that may require in-
stallation of cooling water intake fish protection
technologies or potential retrofit of closed-cycle
cooling systems (cooling towers).
On April 20, 2011, the EPA released a pro-
posed rule implementing the requirements of
Section 316(b) for existing facilities. In the
proposed rule, the EPA noted that closed-
cycle cooling systems were not a best tech-
nology available (BTA) for reducing adverse
impacts of cooling water intake structures;
however, entrainment standards developed on
a site-specific basis could require retrofits of
closed-cycle cooling systems. Furthermore,
although the EPA rejected closed-cycle cool-
ing as BTA and selected a regulatory option
that provides for site-specific development of
entrainment standards for protecting aquatic
life, it did consider two options that included
requirements for closed-cycle cooling, and one
of these options could be adopted for the final
rule, scheduled to be issued in June 2013.
EPRI recently completed a study of the
estimated costs, benefits, impacts, and en-
vironmental consequences of a potential na-
tional requirement to retrofit cooling towers
on all once-through facilities in the U.S. The
estimated costs exceed $100 billion on a net
present value basis.
Research Approach
A first key step in the research was to devel-
op an accurate list of once-through facilities.
EPRIs initial draft list was developed with
information from the EPA and the Depart-
ment of Energy. EPRI then sent the draft list
to the electric industry for review and veri-
fication. EPRI also contacted some facilities
directly to seek clarification on plant- and
unit-specific operational status.
A spreadsheet model was developed to esti-
mate the cost to retrofit 125 facilities based on
existing cost estimates and a worksheet com-
pleted by facility owners. These 125 estimates
were then extrapolated to generate the national
retrofit cost estimate for all nuclear and fossil
generating stations. The study results provided
input for an economic model used to estimate
the number of units and megawatts at risk of
premature retirement if they were required to
retrofit closed-cycle systems. The model input
parameters included unit-specific capacity uti-
lization and hourly dispatch power generation
market information.
Results of this analysis were then used to
estimate the potential risk of localized elec-
tric system security or overload violations
as a result of unit retirements. A methodol-
ogy to quantify the environmental and social
impacts of retrofitting facilities with wet
mechanical-draft cooling towers was also de-
veloped and submitted to the EPA for review.
With the exception of a single natural draft
tower, mechanical-draft towers have been
used exclusively for wet closed-cycle cool-
ing for the last two decades and were the as-
sumed retrofit choice in our study.
The study also evaluated potential impacts
associated with salt drift, human health ex-
posures, public safety, noise, aesthetics, and
terrestrial and wildlife changes. Based on a
literature review and modeling of 26 repre-
sentative facilities, impacts were qualitatively
discussed, quantified, and/or monetized. The
quantified and monetized results were then
extrapolated to a national scale for compari-
son to the cost and benefits of retrofits.
To estimate the national economic benefits
of closed-cycle cooling retrofits, a three-tiered
approach was used. In Tier 1, the economic
value of commercial and recreational losses
was either acquired or generated based on
EPA methods. In Tier 2, the same losses were
estimated based on acceptable correlations
between impingement and entrainment loss
data for those facilities that entered data in
the EPRI Impingement and Entrainment Da-
tabase. In Tier 3, estimates were based on the
relationship between cooling water flow and
data from facilities that had conducted im-
pingement and entrainment studies for various
water body types and U.S. regions.
Study Results
The EPRI report examined the impact of the
proposed 316(b) rule in terms of the cost of
the retrofits, financial impact to ratepayers,
impacts to the electric system, other adverse
environmental impacts, and an evaluation of
the costs relative to benefits for a rule that
requires closed-cycle cooling retrofits.
Cost of Retrofits. EPRI identified 428
facilities that use greater than 50 million gal-
lons per day (mgd) of once-through cooling
water, representing approximately 312,000
MW of electricity: 60,000 MW from the
39 nuclear facilities and 252,000 MW from
the 389 fossil facilities. While closed-cycle
cooling is commonly employed for new
generating facilities, the cost of retrofitting
www.powermag.com POWER
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November 2012 54
WATER & POWER
existing facilities can be significantly higher
due to 11 factors:
Availability of suitable on-site tower
location
Distance from turbine/condenser to tower
location
Site geological conditions (rock? soft
sand? wet?)
Existing above-ground or underground in-
frastructure
Need to reinforce existing condenser and
water tunnels
Need for tower plume abatement
Potential impact of on- or off-site salt drift
Need for noise-reduction measures
Use of alternative sources of cooling tower
makeup water
Modifications to plant equipment (such as
auxiliary cooling systems)
Condenser reoptimization
Based on these factors, the capital cost to
retrofit once-through cooled units with wet
mechanical-draft cooling towers was esti-
mated to be $42.4 billion for the 389 fossil
facilities and $19.6 billion for the 39 nuclear
facilities (Table 1). Also estimated were the
annual cost of power to operate the cool-
ing tower fans and pumps ($427 million for
fossil facilities and $141 million for nuclear
facilities) and the cost of reduced generation
output due to the loss of plant efficiency with
closed-cycle cooling systems compared to
once-through systems ($527 million for fossil
and $182 million for nuclear facilities).
Additionally, many facilities would incur
a significant loss of revenue due to extended
outages that would be required, estimated at
$9 billion for fossil facilities and $8.3 billion
for nuclear facilities. The significantly great-
er proportional cost for the 39 nuclear facili-
ties results from the fact that nuclear units are
baseloaded with an average capacity utiliza-
tion on the order of 90% compared to fos-
sil units, some of which operate in peaking
mode and thus have much lower capacity fac-
tors. The total estimated present value costs,
assuming all once-through cooled facilities
were to retrofit, was over $95 billion for the
fossil and nuclear facilities.
Individual facility costs that were not includ-
ed in the study were permitting costs, costs for
labor and chemicals to operate and maintain the
cooling towers, and the cost of capital to finance
construction. The study also estimated that up
to 5% of the fossil generation capacity (15,600
MW) was at risk of premature retirement due to
inadequate space to install closed-cycle cooling
or the inability to acquire the necessary envi-
ronmental permits to construct cooling towers.
Financial Impact. An important area of un-
certainty is the actual number of facilities and
the associated MW generation that might be
retired if they were required to retrofit. Many
of the older fossil facilities have low capacity
utilization and, due to economic inefficiency,
may operate only for a few weeks or months
per year during periods of peak power demand.
Installation of closed-cycle cooling would fur-
ther reduce efficiency, with the result that many
older units may retire for economic reasons
rather than retrofit.
In some cases, retirements may require the
addition of new generation capacity, adding
to the cost of a national requirement to retrofit
with closed-cycle cooling.
The study estimated that about 26,000
MW of generation were at risk of premature
retirement for economic reasons, and the im-
pact varies among North American Electric
Reliability Corp. (NERC) Regions (Table 2).
The study then focused on five NERC Re-
gions: PJM, New England ISO, New York
ISO, ERCOT, and MISO. A modeling analy-
sis of those regions determined that PJM and
MISO had adequate new generation coming
online to meet reserve margins. However,
new unplanned generation would be required
for ERCOT (5,683 MW), ISO New Eng-
land (2,640 MW), and New York ISO (3,441
MW). The cost of new replacement genera-
tion was estimated to be just under $7 billion,
bringing the cost of a closed-cycle cooling
requirement to over $100 billion.
Impacts to the Electric System. The
study identified some 42,000 MW at risk of
premature retirement (26,000 MW of fossil
generation due to financial impacts and 15,600
MW5% of the fossil unitsdue to lack of
space to accommodate cooling towers or be-
cause of permitting issues).
Researchers modeled the potential power
system impacts of eliminating units in PJM,
New England ISO, New York ISO, ERCOT,
and MISO (those evaluated in the financial im-
pacts study). The model results found there is a
potential risk of localized security and/or volt-
age violations in each of the five regions. The
result is that there would be an additional cost
that was not quantified to install electric system
upgrades in these localized areas in order to
maintain electric system reliability.
It is important to note that modeling poten-
tial reliability impacts has a very high level of
uncertainty. One key factor is that once one
company makes a decision to retire a unit, it im-
mediately impacts the economics of other units,
decisions on planned electric system upgrades,
potential unit retirements, and new generation.
Thus, although modeling indicates potential for
voltage and security impacts to the system, the
precise location of those effects cannot be reli-
ably predicted.
Adverse Environmental Impacts. The re-
search considered the following environmental
and social impacts of closed-cycle cooling:
Plant type
Degree of difficulty
for retrofits Allocation (%) Flow (gpm) Cost (billions)
Fossil
Easy 22 30,691,540 $5.56
Easy/average 10 13,950,700 $3.18
Average 26 36,271,820 $9.97
Average/difficult 13 18,135,910 $6.17
Difficult 24 33,481,680 $13.56
More difficult 5 6,975,350 $3.98
Total fossil 100 139,507,000 $42.42
Nuclear Less difficult 30 12,836,700 $3.52
Intermediate 40 17,115,600 $7.86
More difficult 30 12,836,700 $8.27
Total nuclear 100 42,789,000 $19.56
Total facilities 182,296,000 $62.07
Table 1. Degree of difficulty allocations and capital cost for the con-
version to closed-cycle cooling. Source: EPRI
Region
All waterbody types
Units
at risk
Capacity
(MWe) at risk
PJM 21 3,250
ERCOT 25 5,458
ISO-NE 12 2,561
Midwest ISO 7 906
NYISO 11 3,325
SERC 38 3,044
FRCC 21 2,196
SPP 20 1,475
WECC 18 2,699
MRO 8 328
RFC 33 816
Totals 214 26,058
Table 2. Regional estimates of
the number of units and capacity
at risk. Source: EPRI
November 2012
|
POWER www.powermag.com 55
WATER & POWER
Human health
Terrestrial resources
Water resources
Solid waste
Public safety and security
Quality of life
Greenhouse gases
Permitting issues
The overall significance of environmental
impacts varies on a site-specific basis. Facili-
ties located in urban and suburban areas tend
to have more social impacts due to exposure to
noise, drift, fogging, and visible vapor plumes;
rural facilities tend to have greater impacts on
agriculture and wildlife, depending on prox-
imity to farmland, state parks, wetlands, or
other wildlife habitat. Table 3 provides a sum-
mary of some of the quantified impacts.
Even with drift elimination, an estimated
29,000 tons/year of particulate matter (PM2.5
and PM10) would be generated. However, no
studies on the potential human health impacts
of cooling tower particulate matter have been
conducted, and the impact likely varies de-
pending on the composition of solids in the
cooling water.
It was estimated that about 25,000 metric
tons/year of biocides would be required to main-
tain cooling tower operations and that approxi-
mately 500 billion gallons/year of freshwater
would be lost to evaporation, roughly double the
loss from once-through cooling. This volume of
freshwater is sufficient to meet the potable water
needs of the state of Illinois.
The 39 once-through-cooled, baseloaded
nuclear facilities do not emit carbon dioxide
(CO
2
). However, it would take an estimated
six months on average to retrofit these fa-
cilities with closed-cycle cooling and likely
would require replacement power generation
from fossil facilities, resulting in an estimat-
ed 163 tons of CO
2
emissions.
The total willingness to pay to avoid the
social and environmental impacts resulting
from closed-cycle cooling retrofits was esti-
mated to be $33 million nationallyin other
words, what ratepayers would be willing
to pay to maintain the status quo. What the
study did not consider was the economic im-
pact to ratepayers for the cost of closed-cycle
cooling retrofits. The social and environmen-
tal costs break down as follows:
$13,000,000 for CO
2
emissions, estimated
from voluntary carbon credit prices
$16,000,000 for noise, estimated from
noise impact studies on housing prices
$2,400,000 for aesthetic impact, estimated
from studies of viewshed impact on hous-
ing prices
$970,000 for debris removal, estimated
from water cleanup event costs.
Impact type
Freshwater
facilities Great Lakes
Oceans, estuaries
and tidal rivers Total
PM (tpy) 2,000 800 27,100 29,800
Chlorine use (mt/yr) 18,000 7,000 NA 25,000
Evaporative water loss (billion gal/yr) 372 128 NA 500
Debris removal (tpy) 328 241 281 861
CO
2
(tpy); 6-month nuclear unit outage 74 22 67 163
Table 3. Some quantified impacts of a closed-cycle cooling retrofit re-
quirement. Source: EPRI
Notes: tpy = tons per year, mt/yr = metric tons/year.
CIRCLE 23 ON READER SERVICE CARD
www.powermag.com POWER
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November 2012 56
WATER & POWER
Many environmental and social impacts, including, but not limited
to, evaporative water loss, wildlife impacts, icing on roadways, biocide
usage, and salt damage from drift could not be monetized due to lack
of information.
Cost Relative to Benefits. The results of the analysis estimate
that the annual benefits associated with the impingement and entrain-
ment (I&E) reductions resulting from a national closed-cycle cool-
ing retrofit requirement would be approximately $16 million, with a
lower bound estimate of $13.8 million and an upper bound estimate
of $22.7 million. Table 4 provides benefit estimates for 57 facilities
for various dollar ranges.
The national estimated benefit of $16 million to retrofit once-
through-cooled facilities to closed-cycle cooling is on the same order
of magnitude as the willingness to pay estimate of $33 million to avoid
closed-cycle cooling and a fraction of the estimated cost of over $100
billion to retrofit facilities with closed-cycle cooling.
It should be noted that the EPA is engaged in a national willingness-
to-pay study to estimate non-use or other societal benefits that may
accrue. Preliminary partial results for that study were reported in the
Federal Register (Vol. 77, No. 113, June 12, 2012, or at http://water.epa.
gov/lawsregs/lawsguidance/cwa/316b/index.cfm). Including non-use
benefit estimates significantly increases the national benefit estimate.
However, these estimates tend to be highly subjective for a number of
reasons, such as because survey respondents were not informed that in
the majority of cases I&E reductions may not result in any measureable
fishery benefit and were not given a choice between using any extra in-
come to save fish versus paying for better health care, education, or ad-
dressing other environmental issues. (EPRI comments submitted on the
study can be found at www.nera.com/nera-files/PUB_UWAG_0712_
final.pdf. Nuclear Energy Institute comments can be found at www.nei.
org/filefolder/NEICommentEPANODAsurvey.pdf. )
EPRI 316(b) Research Implications Relative to the
Proposed Rule
The EPAs proposed rule (Federal Register, Vol. 76, No. 76, April 20,
2011), did not propose closed-cycle cooling as BTA for existing facili-
ties as its preferred option. However, the EPA requires all facilities us-
ing more than 125 mgd actual intake flow to evaluate fine-mesh screens
and closed-cycle cooling to address entrainment. The BTA decision
would be made on a site-specific basis and could range from closed-
cycle cooling to a determination that the existing cooling water intake
structure is BTA. In the Notice of Data Availability issued in June 2012
(Federal Register, Vol. 77, No. 112, June 11, 2012), the EPA stated it
was not the agencys intention to require closed-cycle cooling as BTA
for impingement.
The EPA considered three other options, any one of which could
serve as the basis for the final rule. Two of those options (Options
2 and 3) are based on closed-cycle cooling as BTA, but they affect
a somewhat different population of facilities than those assumed
by EPRI in its research and modeling. EPRI identified 428 once-
through-cooled facilities potentially affected by a retrofit requirement
(39 nuclear and 389 fossil). Under Option 2, only those facilities
withdrawing more than 125 mgd design intake flow rate (DIF) would
require use of closed-cycle cooling as BTA. The EPRI cost of retrofits
report provides retrofit cost estimates separately for nuclear and fossil
facilities. Since all of the once-through-cooled nuclear facilities use
more than 125 mgd DIF, there is no change for the estimated costs to
retrofit these facilities under Option 2.
Selecting only the fossil facilities using 125 mgd DIF rather than 50
mgd DIF as the closed-cycle cooling retrofit basis reduces the number
of affected fossil facilities from 389 to 322 (a reduction of 67 facilities).
However, these are the smallest facilities on the list, and retrofit costs
are directly related to the size of the facility. The 67 small facilities
represent only 2.9% of the total once-through-cooled fossil facilities
based on flow, and only 2.8% of total generation capacity. The effect of
not including these 67 facilities in the nationwide analysis results in a
relatively small reduction in the retrofit cost estimates and other impli-
cations of a closed-cycle cooling BTA requirement under Option 2.
Under Option 3, the proposed rule would cover additional steam elec-
tric facilities not included in the EPRI analysis based on facilities that
use more than 50 mgd DIF. As with Option 2, there would be no effect
on the study results for nuclear facilities. Though EPRI does not have a
good estimate of the number of fossil power generation facilities that use
less than 50 mgd, EPRI believes many of these facilities already employ
closed-cycle cooling and therefore do not affect research results. (The
EPA estimated 148 in-scope facilities had closed-cycle cooling: Federal
Register, Vol. 79, p. 22191, Exhibit IV-1, April 20, 2011.)
David Bailey (dbailey@epri.com) is senior project manager, Water
and Ecosystems, Electric Power Research Institute.
Dollar range
Number of facilities
in dollar range
Percentage of facilities in
dollar range
$0$10,000 23 40%
$10,000$50,000 14 25%
$50,000$100,000 6 11%
$100,000$500,000 10 18%
<$500,000 4 7%
Total 57 100%
Table 4. Distribution of commercial and recreational
impingement and entrainment economic loss esti-
mates for 57 facilities. Source: EPRI
Statement of Ownership, Management, and Circulation (Requester Publications Only)
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November 2012
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POWER www.powermag.com 57
AIR QUALITY
Hazy Timetable for EPAs Proposed
Tighter PM2.5 Standards
On June 15, in response to a court order, the U.S. Environmental Protection Agen-
cy (EPA) proposed new lower limits on particulate matter (PM) emissions that
are scheduled for release in mid-December. Even with implementation de-
lays, now is a good time to start paying closer attention to the requirements
of the proposed standard.
By Angela Neville, JD
P
articulate matter (PM) is a complex
mixture of extremely small particles and
liquid droplets. PM comprises a number
of components, including acids (such as ni-
trates and sulfates), organic chemicals, metals,
and soil or dust particles. The size of particles
is directly linked to their potential for caus-
ing health problems. The U.S. Environmental
Protection Agency (EPA) is concerned about
particles that are 10 micrometers in diameter
or smaller (PM10) because those are the ones
that generally pass through the throat and nose
and enter the lungs. Once inhaled, these par-
ticles can affect the heart and lungs and cause
serious health effects (Figure 1).
Particles may be emitted directly or formed
in the atmosphere by transformations of gas-
eous emissions such as sulfur oxides (SO
x
),
nitrogen oxides (NO
x
), and volatile organic
compounds (VOCs). Examples of secondary
particle formation include the following:
The conversion of sulfur dioxide (SO
2
) to
sulfuric acid droplets that further react with
gaseous ammonia to form various sulfate
particles such as ammonium sulfate.
Reactions involving gaseous VOC yield-
ing organic compounds with low ambient
temperature (saturation) vapor pressures
that condense on existing particles to form
secondary organic aerosol particles.
The EPA groups particle pollution into
two categories:
Inhalable coarse particles, such as those
found in industries handling dusty materi-
als like coal, are larger than 2.5 micrometers
and smaller than 10 micrometers in diam-
eter. These particles are classified as PM10.
Fine particles (PM2.5), such as those found
in smoke and haze, are 2.5 micrometers in
diameter and smaller. These particles can
be directly emitted from sources such as
forest fires, or they can form when gases
emitted from power plants react in the air.
Due to environmental concerns, coal-fired
power plants are required to operate a par-
ticulate collection system to control the re-
lease of particulate emissions. These systems
include inertial collectors (cyclone collec-
tors), fabric filter collectors (baghouses), wet
scrubbers, and electrostatic precipitators.
POWER has published a variety of articles
about PM standards and PM control technolo-
gies. The most recent examples (available in
the archives at www.powermag.com) include
Particulate Matter Air Quality Standards
Continue to Evolve (June 2011) and EPRI
Bridges Industry R&D Gaps (January 2012).
Regulating Particulates in the Past
The first rules regulating PM were promul-
gated in 1971 under the Clean Air Act (CAA).
Since that time, the EPA has continually up-
dated the PM standards (Table 1) to better
1. Particulate policy. Particulates of dif-
ferent diameters have different effects on the
human body and often originate from different
sources. PM10 and PM2.5 particles are eas-
ily inhaled and penetrate airways and lungs.
Source: California Environmental Protection
Agency Air Resources Board
Human hair
(60 mm diameter)
PM10
(10 mm)
PM2.5
(2.5 mm)
Hair cross section (60 mm)
2. The air is getting cleaner. This graph illustrates the reduction in the amount of the
six common pollutants (SO
2
, NO
x
, PM, CO, ozone, and lead) in relation to other key economic
indicators over the past two decades. Source: EPA
220%
200%
180%
160%
140%
120%
100%
80%
60%
40%
20%
0%
-20%
-40%
-60%
-80%
95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11
Gross domestic product
Vehicle miles traveled
Population
Energy Consumption
CO
2
emissions
Aggregate emissions
(Six common pollutants)
Year
www.powermag.com POWER
|
November 2012 58
AIR QUALITY
protect human health and the environment.
The CAAs centerpiece has been the national
ambient air quality standards (NAAQs),
which were established for six pollutants:
sulfur dioxide, NO
x
, PM, carbon monoxide,
ozone, and lead (Figure 2).
PMs chemical and physical properties
vary greatly with time, region, meteorology,
and source category, thus complicating the as-
sessment of health and welfare effects. Since
the EPA completed the last PM standards
review in 2006, the agency has examined
hundreds of new studies. The new evidence
includes more than 300 new epidemiological
studies, many of which report adverse health
effects even in areas that meet the current
PM2.5 standards. The EPA also has consid-
ered analyses by agency experts.
Court Order Drives EPAs New
Proposed PM Standards
Under the CAA, the EPA is required to con-
sider revising its PM standards every five
years, and it last did so in 2006. Yet, as the
agency approached the five-year deadline in
October 2011, it announced that it wanted to
delay issuing revised PM rules until the sum-
mer of 2013 because it needed more time to
sift through the latest scientific research.
Eleven states, including New York and Cal-
ifornia, plus the American Lung Association
and the National Parks Conservation Associa-
tion, challenged the delay in court, arguing that
it violated the CAA. On June 2, 2012, Judge
Robert L. Wilkins ruled in the case (American
Lung Association v. U.S. Environmental Pro-
tection Agency, U.S. District Court, District
of Columbia) and ordered the EPA to sign a
proposed rule by June 7, a deadline that was
later extended under an agreement between
the agency and the plaintiffs.
On June 14, the EPA proposed to strength-
en the NAAQS for PM2.5. The agency also
proposed to retain the existing standards for
PM10. The agency said that its proposed
changes to the PM2.5 standards are consis-
tent with advice from its independent science
advisors, the Clean Air Scientific Advisory
Committee (CASAC).
Specifically, the agency proposed to take
the following actions:
Strengthen the annual PM2.5 health stan-
dard by setting the standard at a level
within the range of 12 micrograms per
cubic meter (g/m
3
) to 13 g/m
3
. The cur-
rent annual standard, 15 g/m
3
, has been
in place since 1997.
Retain the existing 24hour fine particle
standard, at 35 g/m
3
. The EPA set the
24hour standard in 2006.
Set a separate PM2.5 standard to improve
visibility, primarily in urban areas. The
EPA is proposing two options for this
24hour standard: at 30 deciviews or 28
deciviews. (A deciview is a yardstick for
measuring visibility.)
Retain existing secondary standards for
PM2.5 and PM10 identical to primary
standards to provide protection against
other effects, such as ecological impacts,
effects on materials, and climate impacts.
The EPA also proposed to retain the ex-
isting 24hour standard for PM10. This stan-
dard, with a level of 150 g/m
3
, has been in
place since 1987.
The EPA also made the following
proposals:
Grandfathering preconstruction permit-
ting applications that have made substan-
tial progress through the review process
at the time the final standards are issued.
The agency is taking this action to ensure
a smooth transition to the new standards.
Making updates and improvements to the
nations PM2.5 monitoring network that
include relocating a small number of mon-
itors to measure fine particles near heavily
traveled roads. The EPAs proposal does
not require additional monitors.
Updating the Air Quality Index for
particle pollution.
The EPA anticipates making attainment/
nonattainment designations by December 2014,
with those designations likely becoming effec-
tive in early 2015. A nonattainment area is a lo-
cation considered to have air quality worse than
the NAAQS as defined in the CAA Amend-
ments of 1970. Nonattainment areas must have
and implement a plan to meet the standard. An
area may be a nonattainment area for one pollut-
ant and an attainment area for others.
States would have until 2020 (five years af-
ter designations are effective) to meet the pro-
posed health standards. Most states are familiar
with this process and can build on current work
Final rule
Primary/
secondary Indicator
Averaging
time Level Form
36 FR 8186
Apr. 30, 1971
Primary TSP 24-hour 260 g/m
3
Not to be exceeded more than once
per year
Annual 75 g/m
3
Annual average
Secondary TSP 24-hour 150 g/m
3
Not to be exceeded more than once
per year
52 FR 24634
July 1, 1987
Primary and
secondary
PM10 24-hour 150 g/m
3
Not to be exceeded more than once
per year on average over a 3-year
period
Annual 50 g/m
3
Annual arithmetic mean, averaged
over 3 years
62 FR 38652
July 18, 1997
Primary and
secondary
PM2.5 24-hour 65 g/m
3
98th percentile, averaged over 3
years
Annual 15.0 g/m
3
Annual arithmetic mean, averaged
over 3 years
PM10 24-hour 150 g/m
3
Initially promulgated 99th percen-
tile, averaged over 3 years; when
1997 standards for PM10 were
vacated, the form of 1987 standards
remained in place (not to be ex-
ceeded more than once per year on
average over a 3-year period)
Annual 50 g/m
3
Annual arithmetic mean, averaged
over 3 years
62 FR 38652
July 18, 1997
Primary and
secondary
PM2.5 24-hour 35 g/m
3
98th percentile, averaged over 3
years
Annual 15.0 g/m
3
Annual arithmetic mean, averaged
over 3 years
PM10 24-hour 150 g/m
3
Not to be exceeded more than once
per year on average over a 3-year
period
Table 1. Early evolution of PM standards. The first rules regulating particulate
matter were enacted in 1971 under the Clean Air Act. Since that time, the EPA has continu-
ally updated PM rules under the National Ambient Air Quality Standards (NAAQS). By law, the
agency cannot consider costs in setting or revising NAAQS. Source: EPA
Notes: FR = Federal Register, PM = particulate matter, TSP = total suspended particulates.
November 2012
|
POWER www.powermag.com 59
AIR QUALITY
to meet the news standards. A state may request
a possible extension to 2025, depending on the
severity of an areas PM2.5 problems and the
availability of pollution controls.
The CAA does not specify a date for states
to meet secondary PM2.5 standards; the EPA
and states determine that date through the state
implementation planning process. The same
controls that will be installed to meet the pri-
mary, healthbased standards will also help ar-
eas meet the secondary standards. In 2020, the
EPA expects virtually all counties will meet
the secondary standards without state/local re-
ductions. By law, the agency cannot consider
costs in setting or revising NAAQS.
The EPA intends to issue a regulatory impact
analysis that will estimate the potential benefits
and costs of meeting a revised annual health
standard in the year 2020. The proposed stan-
dards are expected to yield significant health
benefits, valued at $2.3 billion to $5.9 billion
annually for a proposed standard of 12 g/m
3
and $88 million to $220 million annually for
a proposed standard of 13 g/m
3
, according to
the EPA. The EPA will issue final standards by
Dec. 14, 2012, after holding hearings to seek
public comment. The proposed standards re-
flect the continuing trend of tightening the PM
NAAQS over time (Table 2).
How New PM Rules Affect the
Power Industry
In August, POWER interviewed Block An-
drews, PE, director of Strategic Environmen-
tal Solutions, and Robynn Andracsek, PE,
associate environmental engineer, Environ-
mental Studies and Permitting Division, with
the engineering firm Burns & McDonnell
about the new PM standards.
Previous government studies have shown
that the biggest environmental bang for your
buck is from reduction of fine particulate
matter, Andrews said. But, have we gotten
to the point of diminishing returns? I dont
know; I will defer this answer to the toxicolo-
gists and economists.
Andrews said that the EPA has a pro-
cess for evaluating the ambient air qual-
ity standards that includes a working group
(CASAC) with toxicologists that evaluates
health-based studies and uses the results to
set the NAAQS.
PM2.5 can be in a filterable (solid) form,
or a sulfate or nitrate condensable form,
Andrews said. For the filterable portion, air
dispersion modeling can be a problem if the
PM2.5 standard is lowered, especially with
coal-fired plants fugitive emission sources
such as ash handling and road and coal pile
dust. He said, Background PM2.5 levels to-
day are around 80% of the proposed standard.
This does not allow many additional impacts
from an existing or new facility.
Andrews explained that sulfate formation
is a chemical transformation of SO
2
emis-
sions. Natural gas combustion is relatively
free of SO
2
emission, but a coal plant stacks
SO
2
emissions will form sulfates. Nitrate for-
mation is a chemical transformation of NO
x
emissions. Both coal and natural gas com-
bustion would be expected to form nitrates.
Primary standards provide public health
protection, including protecting the health
of sensitive populations such as asthmat-
ics, children, and the elderly, Andrews said.
Secondary standards provide public welfare
protection, including protection against de-
creased visibility and damage to animals,
crops, vegetation, and buildings.
In addition, the EPA is proposing a new
visibility standard for the secondary NAAQS.
Some of the same atmospheric chemistry that
converts SO
2
and NO
x
to form sulfates and ni-
trates can also impact visibility, Andrews said.
A good amount of work to determine re-
gional haze impacts on Class I areas has been
performed. I have not seen any determinations
of visibility outside of the Class I, so it is un-
clear (no pun intended) what, if any impacts
this may have on the coal and natural gas
power plants beyond the primary standard,
Andrews said. My concern is that the visibili-
ty modeling results have not always correlated
well with the real world results. This could
require industry/industries to spend money
without a real visibility reduction return.
Andracsek explained that the model re-
quired for demonstrating compliance with
the PM2.5 NAAQS is AERMOD, which is
the EPAs most commonly used air disper-
sion modeling program. It has been around
for several years. The problem comes in
getting the model to demonstrate PM2.5
NAAQS compliance. The sum of modeled
impacts from the source, plus impacts from
their neighbors within at least 50 kilometers,
plus the background concentration is what
must be compared to the now lower PM2.5
annual NAAQS, she said.
There are two main issues related to prov-
ing PM2.5 NAAQS compliance, according to
Andracsek.
First, PM2.5 is made up of primary PM2.5
and secondary PM2.5. Primary PM2.5 is
what is normally thought of as very fine dust.
Secondary PM2.5 is formed from NO
x
, SO
x
,
VOCs, and ammonia that react chemically in
the air to form fine particulates. The EPA does
not yet have a method to calculate or model
secondary PM2.5, other than using SO
x
and
NO
x
as surrogates. This leaves a hole in com-
plying with any PM2.5 NAAQS, she said.
Second, the background levels for PM2.5
in many parts of the country are 8 mg/m
3
to 11
mg/m
3
. When the NAAQS is lowered from 15
mg/m
3
to 12 mg/m
3
or 13 mg/m
3
, the background
does not change, Andracsek said. This leaves
an even smaller amount of available room for
source emissions. Combined with the fact that
the models are quite conservative, modeling
compliance with the PM2.5 NAAQS at 15 mg/
m
3
is problematic; modeling compliance at 12
mg/m
3
to 13 mg/m
3
is stifling.
The cost to run PM2.5 modeling at a fa-
cility varies greatly, depending on the spe-
cific circumstances, according to Andracsek.
Modeling stacks is much easier and faster
than modeling fugitive emissions. A lot of
primary PM2.5 is from fugitive emissions. A
dispersion modeling project would run from
$15,000 to $50,000 and take from one to six
Year Regulatory action
1971 TSP NAAQS promulgated
1987 PM NAAQS revision; PM10 standards introduced
1997
PM NAAQS revision; PM2.5 standards introduced; PM10 Surrogacy Policy established where-
by permit applicants are allowed to use compliance with PM10 NSR requirements (including
PM10 NAAQS) as a surrogate approach for meeting PM2.5 NSR requirements
2006 PM2.5 24-hour NAAQS revised/lowered; PM10 annual NAAQS revoked
2008
PM2.5 NSR rules finalized; significant emission rates established for primary PM2.5 emis-
sions (10 tpy); and the PM2.5 precursors, SO
2
and NO
x
(40 tpy each)
2010 Final PSD increments, SILs, and SMC for PM2.5 promulgated
2011
PM10 Surrogacy Policy ended; PSD compliance demonstrations required for PM2.5 emis-
sions, including accounting of direct PM2.5 emissions and secondarily formed PM2.5 from
precursors; states must establish limits taking into consideration the condensable fraction
of PM2.5 emissions
2012 (proposed)
Stricter annual PM2.5 NAAQS; secondary standard to address urban visibility concerns; revi-
sion of numerous monitoring requirements
Notes: NAAQS = National Ambient Air Quality Standards, NO
x
= nitrogen oxides, NSR = New
Source Review, PM = particulate matter, PSD = Prevention of Significant Deterioration, SIL =
significant impact level, SIP = state implementation plan, SMC = significant monitoring concen-
tration, SO
2
= sulfur dioxide, tpy = tons per year, TSP = total suspended particulates.
Table 2. Regulatory milestones for PM NAAQS and related compliance
assessment requirements. Source: EPA
www.powermag.com POWER
|
November 2012 60
AIR QUALITY
months, she said. This is a very rough esti-
mate. Compliance costs will vary depending
on what controls may be required to comply
with the PM2.5 NAAQS.
The rule states that, for now, meeting
the 24-hour PM2.5 NAAQS is sufficient to
demonstrate that the secondary visibility
standard is attained, Andracsek said. So if
the EPA issues its guidance along with the
revised final rule, there should be no further
analysis above the normal PM2.5 analysis
and, therefore, no additional cost above that
needed to run the model described above.
There is a lot of uncertainty, however, as to
whether or not the surrogacy policy would be
allowed to stand in court, especially in light
of the fact that visibility is already considered
for Class I analysis and the Best Available
Retrofit Technology regulations.
Andracsek explained that if the EPA re-
leases the new standard before the guidance
is finalized, applicants might then have to
follow the Federal Land Managers Air Qual-
ity Related Values Work Groups 2010 analy-
sis for long-range visibility (such as regional
haze) impacts, which would add $50,000 and
three months, or more, to the projects cost.
She added, It may not be possible to even
meet the regulation given the uncertainty
about the methodology. A big part of the
PM2.5 problem is the uncertainty and lack
of understanding about how these very fine
particulates behave in the atmosphere.
The Impact of CSAPRs
Nullification
On August 21, 2012, the U.S. Court of Ap-
peals for the D.C. Circuit vacated the Cross-
State Air Pollution Rule (CSAPR). Andrews
discussed the impact of the CSAPRs nul-
lification on coal-fired and gas-fired power
plants that have to install new air pollution
control equipment in order to comply with
the proposed PM2.5 NAAQS.
There have been two rules that were driv-
ing PM2.5 controls: CSAPR and the PM2.5
NAAQS. Since CSAPR has been vacated,
it is unlikely that EPA will have a replace-
ment rule in the near future. In fact, it took
EPA three years to replace the original CAIR
[Clean Air Interstate Rule], he said.
After a new CSAPR or similar rule is final-
ized, the states will be given an opportunity
to develop a State Implementation Plan (SIP),
which will have to be approved by the EPA
and give a reasonable timeframe for compli-
ance, according to Andrews. It could easily
be five years or more before any CSAPR com-
pliance would be expected, he said.
The NAAQS regulatory process can be
the timeframe driver as well, Andrews ex-
plained. A typical process would require
states to monitor PM2.5 (which has been
happening for several years), submit to the
EPA a list of non-attainment areas, develop
SIPs for compliance, obtain EPA approval of
the SIPs, and then require controls in or near
non-attainment areas.
The EPA may set a timeframe for this pro-
cess, but history tells us that the timeframe is
not always reliable for a variety of reasons. It
could easily be five years or more before any
PM2.5 NAAQS compliance would be expect-
ed, Andrews said. The bottom line is that a
controls timeframe is uncertain. History tells
us that NAAQS-driven control requirements
are rarely required immediately.
Will Plants Require New Equipment
to Meet Stricter PM Standards?
Andrews explained that for fugitive dust
emissions, meeting the new standard could
require more enclosed coal piles and fur-
ther fugitive dust reduction techniques, such
as road paving, surfactants, and baghouses,
where feasible. For SO
2
and NO
x
emissions,
further reductions could be required such as
scrubbers and selective catalytic reduction
(SCR) technology, he said.
POWER asked Andrews if he thinks the air
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AIR QUALITY
pollution control equipment currently used
by most U.S. coal-fired and gas-fired power
plants will be sufficient to enable them to
comply with the proposed secondary PM2.5
NAAQS. He answered, I dont think we
know at this point what scale of reductions
will be required to meet the proposed visibil-
ity standards. However, if the 24-hour PM2.5
surrogate policy continues to be in place,
then it would have a limited impact.
Andrews had no estimates about the costs
of installing air pollution control technol-
ogy that would enable fossil-fired plants to
comply with the proposed PM standards. He
explained that he would first have to know
if the power plants in question are going
to retrofit a unit, retire, build new genera-
tion, or rely on the market for power. Once
we know this answer, then we would have
to know the stringency and form of the
regulation(s), he said.
When discussing the probable impact that air
pollution control upgrades will have on affected
power plants bottom lines, Andrews referred
to the good old days when there were fewer
moving parts in the environmental arena. He
explained that today there is great uncertainty
about the required controls and cost impacts re-
lated not only to air regulations, but also water
and coal combustion residuals regulations.
Is retrofitting a coal unit cost competitive
compared to buying market power or other
forms of energy such as natural gas com-
bustion? An answer to this question is quite
utility-specific, according to Andrews. It will
depend on many factors, including delivered
fuel costs, environmental costs, the power
market pricing in specific geographical areas
and the individual utilitys future projections
of key cost and risk issues
Historically, energy companies have
done a great job of balancing regulations,
ratepayer costs, andfor investor-owned
utilitiesa reasonable rate of return for the
shareholders, Andrews said. Their job is
even harder today, but I am confident that
they will continue to perform well.
EEI Responds to Proposed PM
Standards
The Edison Electric Institute (EEI), an asso-
ciation of shareholder-owned electric compa-
nies, filed its comments about the proposed
PM standards with the EPA on August 31,
and referred to the regulatory treadmill of
NAAQS standards. The group said that if
the proposed PM rules are finalized, the EPA
will be adding to the already existing list of
separately enforceable PM NAAQS. Accor-
ing to the EEI, finalization of the proposed
PM rules would mean that the EPA and the
states will be concurrently implementing:
The 1997 PM2.5 annual standard.
The 2006 PM2.5 24-hour standard.
A new 2012 PM2.5 annual standard.
A potentially revised 2012 PM2.5 24-hour
standard.
The 1987 PM10 24-hour standard.
A new 2012 secondary PM2.5 visibility
standard.
The 2006 secondary PM2.5 standards as
newly targeted on other welfare effects
apart from visibility.
Under the EPAs currently planned sched-
ule for NAAQS reviews, a new ozone stan-
dard could be promulgated in 2014 that
would layer on top of existing standards and
potentially add another secondary standard
to the two 2012 PM2.5 secondary standards,
according to the EEI. In addition, during this
time period, the newly revised NO
2
and SO
2
NAAQS will be implemented, requiring ad-
ditional designations and SIP submittals.
The EEI said that the EPA needs to do a
far better job of coordinating these regula-
tions and minimizing their overall burden
for the agency itself, states, and regulated
entities. The current situation causes an
immense waste of resources and, given the
lengthy process of designating new nonattain-
ment areas and revising SIPs, fosters years of
uncertainty for states, local governments, and
industry that are affected by revised NAAQS,
it said. The industry group commented that
the EPA should, instead, seek to rationalize
its NAAQS process to better conform to ex-
isting executive orders.
Looking Ahead
Currently, the proposed PM standards imple-
mentation timeline is unpredictable because
of the complicated implementation process.
The most likely scenario would require the
individual states to monitor PM2.5, submit a
list of non-attainment areas to the EPA, de-
velop SIPs for compliance, obtain EPA ap-
proval of the proposed SIPs, and then require
controls in or near non-attainment areas.
Even though the implementation process
could take as long as five years, regulated fa-
cilities need to start planning for how to deal
successfully with compliance and permitting
issues. The increased complexity of PM2.5
NAAQS compliance will no doubt boost fa-
cility costs and staff work hours. Therefore,
it is important to begin assessing projected
PM2.5 emissions and possible permitting
problems to prepare for and, hopefully, avoid
permitting hurdles and delays.
Angela Neville, JD, is senior editor of
POWER.
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November 2012 62
PLANT DESIGN
The Evolution of Steam
Attemperation
The fundamental design principles and process for modern steam desuper-
heating, or the attemperation of superheated steam in the power gen-
eration industry, have been evolving since the early 1930s. Meeting the
requirement for steam quantity, quality, and temperature consistency is
the foundation of traditional attemperator component design, particularly
for fast-response combined cycle plants.
By Martin-Jan Strebe and Arvo Eilau, Tyco Valves & Controls
I
ncreases in steam and combustion turbine
operating temperatures and capacity that
are inherent in the quest to increase steam
cycle efficiency are advancing metallurgy
technology. At the same time, diverse opera-
tional requirementsincluding cycling and
low-load and load-following operations
have added complexity to the design of to-
days combined cycle (CC) plants. Increased
final superheated steam volumes and temper-
atures coupled with these diverse operational
modes are, in turn, challenging many other
vital plant components and systems, particu-
larly the steam attemperator system.
Attemperator Design Overview
An excellent attemperation system for a mod-
ern CC plant requires a balance of design ef-
ficiency, component flexibility, and system
reliability. Rapidly varying load conditions
place strenuous duty cycles on steam attem-
peration components and downstream appa-
ratus. On average, the attemperator system
will experience 700 to 1,000 thermal cycles
per year of normal operation. The thermal
cycles can double in a cycling unit.
Most modern heat-recovery steam genera-
tion (HRSG) superheated steam attemperator
component designs can be characterized as
either circumferential, probe, or a combi-
nation of both technologies. As with many
complex engineering components, designs
evolve from functional requirements derived
from expected plant operations. Each of these
design categories has a unique set of require-
ments that must be met to achieve expected
levels of plant performance and efficiency.
One of the more common superheater attem-
perator designs used in the HRSG CC market
today is a circumferential spray design (Figure
1). The primary function of this design is to
inject water perpendicular to the steam flow
through multiple fixed or floating spray nozzles
via a penetration in the main steam pipe wall and
the attemperators inner spray liner or protective
shield located inside the pipe. The nozzles pro-
duce mechanical atomization of the water drop-
lets into the superheated steam flow. This design
will often utilize external circumferential piping
to the main steam pipe for water supply to the
individual spray nozzles in conjunction with a
remote spraywater control station.
An alternative design for steam tempera-
ture control integrates a probe unit within the
pipe. This design is divided into two major
categories: integrated units (IU) and separat-
ed units (SU). Integrated probes incorporate
the spraywater control valve function within
the component (Figure 2). SUs offer a probe-
style spray for water atomization with a re-
mote spraywater control valve and external
water supply piping (Figure 3). The probe
application, whether of IU or SU design, em-
ploys single or multiple spray probes into the
superheated steam flow, spraying water drop-
lets parallel with the steam flow.
1. Circumferential in-line attemperator. In this design, water is injected perpen-
dicular to the pipe steam flow through spray nozzles to desuperheat steam. Source: Tyco Valves
& Controls
In-line
attemperator
Steam flow
DCS
TIC
2. Probe-style IU desuperheater. In this design, an integrated flow control valve is
inserted into a pipe through which water is injected into the flowing steam. A downstream
probe measures the downstream temperature and is used to control the water flow. Source:
Tyco Valves & Controls
Steam flow
DCS
TIC
November 2012
|
POWER www.powermag.com 63
PLANT DESIGN
Whether an attemperation system is cir-
cumferential or probe style in design, it must
be supported by robust integrated control
components and control functionality. The
placement, design, and function of tempera-
ture probes are critical. A spraywater control
valve or valves must enable bubble tight
shutoff, and manual valves required for com-
ponent and system isolation should be rou-
tinely inspected.
Most current HRSG steam attemperator
systems are designed for minimal to zero
water flow at maximum steam flow. CC
plants that are dispatched through automated
load-following management systems or au-
tomatic generation controls will see constant
superheated steam attemperation as load is
increased or decreased to meet fluctuating
megawatt demand. This mode of operational
dispatch will stress existing design limita-
tions of the attemperation system.
Common system and component failure
issues associated with extreme cycling con-
ditions are:
Spraywater control valve packing leaks or
packing blowout.
Wetting or droplet impingement of down-
stream thermal probes.
Nozzle spring failure.
Nozzle cracking or erosion.
Linear weld attachment (pin) cracking or
complete line failure.
Main steam pipe cracking.
Foreign object damage to the steam
turbine.
Engineering and Design
Considerations
Attemperator system components are de-
signed and engineered to an expected life
span, based on detailed 3-D finite analysis
computer models, operational case histories,
material composition, and expected thermal
cycles associated with each component.
Some shortened component life in the steam
attemperator system can be attributed to sup-
porting operational systems, such as feedwa-
ter or condensate supply conditions, water
chemistry, distributed control system (DCS)
settings, or response times. These support
systems are usually designed for no or mini-
mum spray conditions at design or baseload
conditions for maximum efficiency.
The attemperator system installed at a
plant designed for baseload may exhibit much
different operation when cycled. A functional
field test often proves prior factory test set-
tings to be inaccurate. The following is a
minimum list of supporting systems and pa-
rameters associated with the attemperator that
should be reviewed and/or inspected to mini-
mize the chance of downstream damage:
Feedwater or condensate supply pressure,
flow rate, and temperature at the spraywa-
ter control valve during various load con-
ditions, or at the attemperator probe if an
integrated design is present.
Thermal probes, operational temperature,
and location specifications should be veri-
fied and/or tested.
DCS logic settings should be consistent
with plant operation. The dead band of
the control signal should be within the re-
quired tolerance.
Water chemistry should be known through-
out the steam and condensate systems un-
der various load conditions.
This equipment, if not originally designed
for cyclical operation, can be redesigned or
modified to better suit current operational
conditions. Often, a presumed shortage of
feedwater or condensate spray capacity can
be attributed to a logic setting in the DCS for
valve position, or for response at a predeter-
mined load condition.
Additionally, if the plant infrastructure has
been in service for a period of years and has
experienced a series of routine control valve
preventative and corrective maintenance ac-
tions, operators may observe a minor, incor-
rect spraywater control valve stem position
setting. Thermal probes are often placed in-
correctly during unit construction, resulting
in probe wetting or water droplet impinge-
ment, which will result in inaccurate steam
temperature measurement.
Locating the Attemperator
In addition to mechanical design and field
operations, accurately predicting water drop-
let atomization is very important. However,
measuring droplet atomization in the field is
difficult. If atomization of spraywater into
the steam system is negatively affecting the
ability of the temperature probe to measure
downstream steam temperature correctly,
then severe overspray and underspray condi-
tions can produce increased thermal cycles
and component damage.
Thermal probe location is a first step in
verifying or eliminating probes as a possible
contributor to poor steam attemperator sys-
tem performance. Here are two general rules
for measuring and verifying the proper loca-
tion of upstream and downstream attempera-
tor thermal probes (in a straight pipe):
The upstream thermal probe should be a
minimum of five pipe diameters from the
attemperator location.
The downstream thermal probe should be
a minimum of 20 pipe diameters from the
attemperator location.
These rules of thumb should be used as
a quick check of an existing installation in
straight pipe and are useful in determining
if a gross error was made in thermal probe
placement. Droplet atomization calculations
can be used to determine the exact require-
ments and dimensions for the piping arrange-
ment and thermocouple locations.
Advances in Steam
Temperature Control
Precise steam temperature control has been a
challenge for steam plant operators since coal
was first shoveled into a furnace. Todays su-
perheat temperatures and daily plant cycling
place extraordinary stresses on critical com-
ponents. Effective steam temperature control
is needed to protect expensive downstream
equipment, such as the steam turbine.
In a typical CC plant, precise steam tem-
perature control often conflicts with compact
steam piping design. That makes it difficult
to select an attemperator that can operate in
the shortest possible straight length of pipe
yet with an effective evaporation rate. This is
particularly difficult when short pipe length
is coupled with a high turndown ratio and
the desire for a flat temperature distribution
across the steam pipe.
3. Probe-style SU desuperheater. This design is similar to that shown in Figure 2, but
the water flow to the desuperheater is controlled via a separate flow control valve. Source: Tyco
Valves & Controls
Steam flow
DCS
TIC
www.powermag.com POWER
|
November 2012 64
PLANT DESIGN
Primary atomization of the feedwater
used to attemperate the steam is produced by
the nozzle design and geometry within the
desuperheater and the pressure differential
between the cooling water and the steam.
Together with the University of Eindhoven
in The Netherlands, Tyco Valves & Con-
trols commissioned a joint research project
to develop theoretical modeling of primary
atomization using computational fluid dy-
namics (CFD) analysis and laboratory laser
diffraction to analyze water droplet size upon
discharge from the desuperheater.
The study examined two nozzle designs,
spring-loaded and swirl nozzles. Initial re-
sults have identified that when operating at
25 bar (263 psi) with a 0.05 mm lift and K
v
=
0.047 (K
v
is a function of the nozzle design,
and it relates the flow through a nozzle as a
function of the fluid properties and the pres-
sure drop across the nozzle), spring-loaded
nozzles produce droplet sizes of 87 m (the
diameter of a human hair averages 30 m).
The same calculation for swirl nozzles at 25
bar, K
v
= 0.043 resulted in droplet sizes of
27 ma factor of two to four times smaller
than spring-loaded nozzles, depending on the
operational pressure range. Basic engineer-
ing guidelines indicate that the smaller drop-
let sizes will evaporate faster and provide
better desuperheater controllability.
Using this data, Tyco analyzed the sec-
ondary atomization characteristics evident
when the speed differential and drag forces
between the cooling water and pipeline me-
dia cause the droplets to split into smaller
sizes. By measuring the speed differential
of the two nozzle designs, Tyco is able to
define which nozzle achieves higher speeds
and therefore faster secondary atomization.
Optimum atomization will result in frictional
forces breaking the droplet size, which re-
sults in complete mixing and true tempera-
ture control and measurement.
The results of the Tyco desuperheater re-
search study demonstrate that swirl nozzle
designs offer enhanced performance and max-
imum use of water pressure drop for atomiza-
tion in the shortest possible length. Optimized
spray injection angles of swirl nozzles allow
equal temperature distribution within the pipe
and provide the highest turndown ratio using
mass flow control, rather than pressure control.
Having no springs or moving parts within the
nozzle, and no pressure drop and cavitation in
the control valve, maximizes the operational
life cycle of the swirl nozzle design compared
to spring-loaded nozzles.
Improving Desuperheater Design
The next generation of combustion turbines,
HRSGs, and steam turbines will be able to
operate at final steam temperatures that are
projected to reach 1,150F. As steam tempera-
tures rise, the need for tight steam control
also increases, and multiple design solu-
tions are required, depending on the specific
modes of operation expected from the plant.
At these higher steam temperatures it is im-
perative that potential weak points in a steam
temperature control system are identified be-
fore it is installed in the field. That means re-
lying on modern engineering techniques, 3-D
design simulations, and the use of CFD and
finite element analysis (FEA) tools.
For example, using CFD and FEA allows
effective spacing of the nozzle openings to
prevent areas of high stress. These tools can
then be used to confirm whether the spray
water nozzles are designed at the optimum
angle for the shortest evaporation time and
the reduction of cold spots on the inner steam
line, which could lead to pipe cracking. Un-
derstanding the stress of higher cycling on
the attemperator system and desuperheater
nozzle units helps engineers to avoid future
mechanical stress-related failures and maxi-
mize system life.
CFD modeling techniques also enable
close examination of the droplet distribution
within the pipeline from both probe-style and
circumferential desuperheaters. This identi-
fies which design offers more equal droplet
distribution between the hot steam flow and
cooling water and therefore faster and more
effective evaporation. Using CFD analysis
provides greater understanding of attempera-
tor system design and how altering desuper-
heater geometry and spray nozzle angle can
improve droplet evaporation and minimize
impingement on the pipe wall.
FEA offers particular advantages dur-
ing the design and engineering phase of the
project by analyzing the heating and cooling
cycles of critical desuperheater components.
Attemperator components in the hot zone
are at increased risk of thermal fatigue and
shock. Using an FEA program, Tyco can
identify where a crack may appear in, for ex-
ample, the desuperheater nozzle and predict
the potential failure point over the service life
of the product.
Taking its steam temperature control testing
further, Tyco has carried out thermal fatigue
cycle analysis on its desuperheater nozzle in-
jection units in two material typesF91 and
Inconnel 718at steam temperatures up to
1,150F, water temperature of 307F, and up to
10,000 thermal cycles. These analysis tools
have allowed Tyco to improve the design ge-
ometry and metallurgy of its severe service
desuperheaters, which then allow engineers
to produce a design that will minimize stress
points and optimize the design and engineer-
ing characteristics of the attemperator system
(Figure 5).
4. Small droplets desired. This is a
laboratory image of droplet size analysis. The
size of the water droplets flowing into the
steam determines the rate of water atomi-
zation and steam temperature. Source: Tyco
Valves & Controls
5. TempLowHT flow path. TempLowHT incorporates a spraywater control valve lo-
cated outside the heat-affected zone, reducing the risk of thermal shock to critical components.
A single probe provides water droplet atomization through a series of nozzles located parallel to
the steam flow. Source: Tyco Valves & Controls
Steam flow
conditions
Control
shaft
Piston
Uninsulated
atmospheric
conditions
TempLowHT TempLow
Piston
November 2012
|
POWER www.powermag.com 65
PLANT DESIGN
The Future of Steam
Attemperation Technology
Drawing on the results of the water droplet
study, CFD modeling, and FEA, Tyco has
developed a new circumferential steam at-
temperation system for the power generation
industry. CircTemp has been designed and
engineered to improve desuperheater perfor-
mance in severe-service boiler system appli-
cations. In developing the product, Tyco used
the advanced modeling techniques to establish
the performance characteristics and opera-
tional parameters. CircTemps design uses the
high-temperature, high-cycling experience
Tyco has gathered through its Narvik-Yarway
TempLowHT probe desuperheater and applies
it to the new product development.
Tyco started with a nozzle design that pro-
vided good primary atomization, ensuring
that droplets would only become smaller dur-
ing secondary atomization with the shortest
possible evaporation time. This approach has
reduced water droplet sizes from 100 to 20
, delivering shorter evaporation times. The
key is the higher turndown ratio achieved by
the CircTemp desuperheater, compared with
typical spring-loaded nozzle circumferen-
tial designs. Using mass flow, rather than a
pressure-reducing control valve, maintains a
constant pressure differential within the at-
temperator system. This increases the velocity
of the water discharged from the nozzle injec-
tion unit, producing smaller water droplets. In
spring-loaded nozzle designs, the control valve
is the limiting factor because the pressure after
the valve determines the discharge velocity.
The CircTemp design enables individual
nozzles to be shut off as the steam load fluc-
tuates. This means that a considerably higher
turndown ratio can be achieved by sequenc-
ing nozzle open and closing. As the load
increases, smaller nozzles and then larger
nozzles can be opened one at a time, as the
flow requires. When less flow is needed, the
nozzles can be closed in the reverse sequence:
first the largest and then the smaller nozzles.
Tycos study into optimum spraywater an-
gles also determined that cooling water entering
the pipe perpendicular to the steam flow could
impinge on the pipe wall. Optimized spray an-
gles and nozzle configuration creates different
cooling water spray patterns and ensures equal
distribution. This research into desuperheater
spraywater characteristics has influenced the
CircTemp design to prevent potential damage
to downstream pipe and liners by eliminating
cold spots on the inner pipe wall and maintain-
ing constant steam temperature.
Striving for higher CC plant efficiency
means higher steam temperatures and, prob-
ably, high cycling duty over the lifetime of
a plant. Components in direct contact with
the higher-temperature steam must have the
best materials, be based on state-of-the-art
research, and integrate field operating experi-
ence into their design and manufacture. One
of those components, the critical yet problem-
atic desuperheater valve, is ready today for the
next generation of combined cycle plants.
Martin-Jan Strebe (mstrebe@
tyco-valves.com) is director for global
product management control valves and
Arvo Eilau is marketing manager, Tyco
Valves & Controls. As of October 1, 2012,
Tyco Valves & Controls will be officially
known as Pentair Valves & Controls.
For more information, call Wrights Media
at 877.652.5295 or visit our website at
www.wrightsmedia.com
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November 2012
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POWER www.powermag.com
69
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POWER www.powermag.com 71
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November 2012 72
COMMENTARY
Preparing for the EPAs
Cooling Water Rule
By Harold M. Blinderman, JD
W
ith the U. S. Environmental Protection Agencys (EPAs)
issuance of a final rule regulating cooling water intake
structures at existing facilities potentially less than a
year away, facilities should be paying close attention to the pro-
posed rules provisions, data requests, and study requirements as
they evaluate their compliance options and begin to formulate
their compliance strategy.
Overview of Proposed Rule
The proposed rules primary purpose is to regulate existing facili-
ties utilizing once-through cooling water systems. The rule, as
proposed, applies to all existing power plants and manufactur-
ing facilities that have the design capability to withdraw more
than 2 million gallons per day (mgd) from U.S. waters and use
at least 25% of such water exclusively for cooling water pur-
poses. The EPA states that 355 facilities across the U.S. employ
once-through cooling. Of the 104 operating U.S. nuclear units,
60% use once-through cooling systems, according to the Nuclear
Energy Institute.
Under the proposed rule, permitting authorities will use their
best professional judgment in selecting the best technology
available (BTA) to reduce entrainment, the incidental drawing
of fish and other aquatic organisms into a power plants cool-
ing water system. Consequently, while the EPAs draft rule does
not identify closed-cycle cooling or any other technology as the
national standard for minimizing entrainment, the ultimate deci-
sion on how best to reduce entrainment at a particular facility
will be made, in most instances, by state environmental protec-
tion agencies after reviewing all the information before them.
Focusing on Entrainment Reduction
It is incumbent upon facility managers to begin developing their
overall approach from the very first submittal required by the
proposed rule. Provisions in the proposed rule allow for consid-
eration of a number of technical, biological, and economic fac-
tors that may help a facility develop its site-specific approach
to entrainment.
The proposed rule recognizes that energy reliability, increased
air emissions, land availability, and remaining useful plant life
are four key factors, among others, that the permitting authority
must consider in making any decisions regarding BTA for reduc-
ing entrainment. Furthermore, the proposed rule provides that
the permitting authority may reject an otherwise BTA (or not
require any BTA controls) if the control costs are not justified by
the benefits. Thus, any compliance strategy must fully consider
these issues.
In addition, if a nuclear facility can show that compliance
with the proposed rule conflicts with a U.S. Nuclear Regula-
tory Commission safety requirement, the proposed rule pro-
vides that either the EPA or state permitting authority must
make a site-specific BTA determination for minimizing adverse
environmental impact without conflicting with the facilitys
safety requirements.
All plants subject to the proposed rule must be mindful of
the numerous application studies that will be triggered once
the rule is issued, which, at present, is likely to occur in the
summer of 2013. The permitting authority will use these sub-
mittals to assess the entrainment impacts of a facilitys cooling
water intake structure and to reach a determination regarding
the appropriate technological and operational controls to be
implemented at the facility.
Importantly, the amount of information requested is tied to
a facilitys intake flow. The greater the design and actual intake
flow, the more studies are required. Facilities should be aware
that, within six months of the final rules effective date, plants
with a design intake flow of 50 mgd or more must initially submit
a wide range of information, including studies to describe the
source water body, cooling water intake structures, and cool-
ing water system; characterization of the biological community
in the vicinity of the cooling water intake structure; a plan for
controlling impingement mortality; a description of biological
survival studies addressing technology efficacy and other studies
on impingement and entrainment at the facility; and a discus-
sion of the operational status of the facility.
Following these submittals, facilities that fall within this cat-
egory and also withdraw more than 125 mgd, and existing facili-
ties with new units, have more work to do. The proposed rule
calls for the development of information leading to the submit-
tal of an entrainment characterization study within four years
and comprehensive studies assessing technical feasibility, costs,
and benefits of installing various technological and operational
controls within five years of the final rules effective date. These
reports will be critical to any agency BTA assessment, and it is
within the discretion of the permitting agency to move up these
reports timetables.
Throughout this process, facility owners and operators should
be very aware of federal and state regulatory preferences in de-
veloping an overall compliance strategy reflecting the individual
facilitys specific circumstances. For instance, California and New
York have policies in place favoring closed-cycle cooling tech-
nology or achieving reductions in intake flow or entrainment
mortality to levels commensurate with closed-cycle cooling.
Facilities Need to Advocate Site-Speciic Plans
The information submitted by a facility as required by the pro-
posed rule will form the basis for the permitting agencys deter-
mination about what constitutes BTA for entrainment. As any
BTA determination will be based upon the permit writers best
professional judgment, facilities have the opportunity to make
their case based on site-specific economic, technical, and bio-
logical findings as developed throughout the entire process.
Harold M. Blinderman, JD (hmblinderman@daypitney.com) is
a partner at the Day Pitney law firm in Hartford, Conn.
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