0789-7COM-202 Tees Valley 2 Commissioning plan

DATE 26-Aug-15
SITE NAME TEES VALLEY 2 RENEWABLE ENERGY F
EPR permit Number EPR/XP3336NN/A001
REVISON HISTORY
REV AUTHOR
0 G McGibbon

EA notes on template
Commissioning Plan template for new waste incineration plants

This template sets out the minimum information and considerations that
must be included in the commissioning plan required by the relevant pre-
operational condition in your permit. Some of the information may be taken
from other plans prepared for the commissioning process. Please note that
a copy of the final plan will be placed on the Public Registers unless we
agree your application that some or all of the information is confidential. We
have included guidance notes and examples in blue text; these should be
removed in the final version. Your Commissioning Plan must be submitted to
the Environment Agency for our approval.

During commissioning, the plant will be tested to verify its functions

according to design specifications. The commissioning process will need to
demonstrate that the plant can meet all the requirements of the permit
conditions so that it can enter full operation. The plan must ensure that any
issues that arise during commissioning are addressed and re-tested.
BASIS

Template for the thermal treatment of waste sector. Final version 1.0 dated
25 April 2013.
Author Helen Durrant
Revsion 0

Approved

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S VALLEY 2 RENEWABLE ENERGY FACILITY
XP3336NN/A001

Comments DATE REWIEWED DATE

draft 8/26/2015

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1.0 Requirements of Chapter IV of the Industrial Emissions Table 1.1 below sets out the individual requirements of Ch IV IED. You
Directive (Ch IV IED) must use this to demonstrate how these requirements will be met
during commissioning.
WID Article Description Notes

Your plan must show how compliance is demonstrated through

acceptance testing, including the export of power and heat off-site.
Although being an R1 energy recovery operation under the Waste
Framework Directive is not an obligation of the environmental permit,
to save time, you may also wish to design the reporting of acceptance Air Products response to pre operational condition PO2 heat , part of
testing to make it suitable for the post-commissioning stage of R1 plant performance test will be to demonstrate the plant operates at the
Article 44(b) - Heat recovery. validation. design capacity

A waste management plan will be drawn up for the commissioning

activity, this will cover the wastes specified in the application and any
specific wastes that will be generated during commissioning and will
specify the waste hierarchy and disposal routes.
In addition to the by products and wastes specified in the permit
application there will be residues for washout, cleaning and passivation
Recovery and disposal routes must be in place to accommodate the of the boilers, cooling towers and other equipment. This will be tested
Article 44(c) - Minimise amount and harmfulness of residues and type and quantity of residues generated from the activity and either sent to the waste water treatment plant at Bran sands or
recycle if possible. implementing the Waste Hierarchy. shipped off site for treatment and disposal

Article 52 (1) - Prevent (or limit as far as practicable) pollution, The waste acceptance procedure approved by the Agency for pre
odour, noise and risks to human health during delivery and operational condition PO5 Waste acceptance procedures will be followed
reception of waste. Assess (qualitatively) how this is done during commissioning. during commissioning.

Slag testing will be carried out during the commissioning phase in

accordance line with the IBA protocol , as specified in our response to pre
Article 50 (1) - Slag/bottom ash has TOC<3% or LOI<5% of dry You must describe what testing you will do to achieve this and when operational condition PO2 . guidance document TGN M4 issued by the
weight. you will do it. Environment Agency

Details of how this requirement will be measured and demonstrated

must be included. You must specify the method you intend to use to
test residence time, for example plug flow method. Further guidance Not applicable to our process, however as part of plant performance
Article 50 (2) - 850°C for 2 seconds minimum gas residence time can be found in our guidance note: How to comply with your testing we will be verifying performance vs. design
after last injection of air, under the most unfavourable conditions as environmental permit. Additional guidance for the incineration of See summary below of how we plan to verify our alternative operating
measured near the inner wall. waste (EPR 5.01). techniques

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 In the permit application we proposed alternative operating techniques
to ensure compliance with the WID ELVs, these are summarised as
1. Maintaining operating conditions in the gasifier, including
operation of the Gasifier torches
2. Operating the gas clean up system and abatement system
3. Maintaining design combustion conditions in the GTs and boiler
4. Operating the SCR to design

During commissioning we will these as follows

1. Test operation of gasifier systems vs. design
2. Verify plant contain systems operate correctly
Article 50 (3) - Each line shall be equipped with at least one auxiliary 3. Take syngas samples before and after the clean up train to
burner, which must operate automatically if the temperature drops demonstrate the clean up is working and is free of contaminants
below 850°C and also on start up and shut down to ensure the 4. Verify the GT and boiler operating parameter
temperature is maintained above 850°C for as long as there is 5. Check the operating of the SCR and verify that all ELVs can be
unburned waste in the furnace. Demonstrate that the control system works before burning waste. consistently met

Article 50 (4) - There will be an automatic system to prevent waste

feed:
a) At start up until temperature reaches 850°C Demonstrate that the control system works on start up and when the
b) Whenever 850°C cannot be maintained temperature cannot be maintained above 850°C. Describe how you
c) Whenever continuous monitoring shows that any ELV is will show that the system works if an Emission Limit Value (ELV) is
exceeded due to disturbances or failures of the purification devices exceeded. see description in previous section

covered in our response under 'hot commissioning tab in this

spreadsheet.
Article 46(2) - ELVs of Annex V shall be met See comments under sections 2.0 and 5.0.

As part of the CEMS QAL 1,2 tests we will endure that the air monitoring
Article 48 - Monitoring results shall be standardised to the systems are working correctly. Our CEMS contractor CBISS will be
conditions (pressure, oxygen etc) laid down See comments under section 4.0. carrying out these tests

Article 53(2) - Transportation and intermediate storage of dry

residues. Also, prior to determining the disposal or recycling route,
the physical and chemical properties and the pollution potential of The slag testing plan part of pre operational condition PO3 . Other waste
each residue type shall be measured. The analysis shall concern the management arrangements will be documented in the Air products
total soluble fraction and heavy metals soluble fraction. commissioning waste management plan

Article 48 - Measurement equipment shall be installed and Part of plant pre commissioning tests / safe to commission handover is
techniques used in order to monitor the parameters, conditions and that environmental and process instrumentation is correctly installed
mass concentrations relevant to the process. See comments under section 4.0. functional

As part of the CEMS QAL 1,2 tests we will ensure that the air monitoring
systems are working correctly. Our CEMS contractor CBISS will be
Article 48 - Compliance of Continuous Emissions Monitors (CEMs) carrying out these tests.
with requirements. Note, this includes temp, oxygen concentration, CEMs will operate at QAL 1 through commissioning until the plant has
pressure, temperature and water vapour concentration of exhaust established stabilised , reliabile operation. Once thisis established then
gas. See comments under section 4.0. QAL 2 (stack testing verification) will be performed.

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 This requires measurement. The commissioning plan must say how
Article 48 - Residence time, minimum temperature and oxygen you will show that your process conditions are consistent with these
content of the exhaust gases shall be verified when the plant is requirements. The plan must identify the conditions under which this
brought into service, and under the most unfavourable operating will be done, justifying why these are considered to be the most
conditions anticipated. unfavourable operating conditions anticipated. Part of the commissioning plant acceptance testing

As far as possible, plan to test how the system will respond to

abnormal operating conditions. Ensure that interlocks function and
Article 46 - how abnormal operating conditions are to be handled, that the limits on CO, TOC and dust are interlocked so that waste feed
with strict limits on CO, TOC and dust. stops immediately on any breach. Part of the commissioning plant acceptance testing

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 Air Products (AP) has appointed Foster Wheeler as the design and build contractor for the
plant and Foster Wheeler (FW) are in operational/EHS control of the Tees Valley 1 site during
the construction phase, in accordance with the CDM regulations.
During the commissioning period up to mechanical completion of the site the AP
commissioning/start up activities will be carried out under the umbrella of FW overall site
procedures.
AP procedures will be followed within any areas that have been handed over as safe to
commission/operate where not in conflict the FW overall site procedures. For example AP
will follow ,where relevant, FW CEMP and site EHS plan and have supplementary procedures
for (for example) commissioning and waste management covering the specific AP activities in
commissioning / operating areas.
EHS management during the commissioning Once the whole site is handed over by FW to the client (AP) AP will assume responsibility for
period overall site control, access, emergency planning etc.
2.0 Commissioning Programme

Phase Key activities/considerations AP Action Expected Emissions Other Notes

CEMS QAL1 ,CEMS will be active and

calibrated but not certified and used to
record emissions data.We plan to
Refractory cure within the auxiliary boiler using natural gas. No tuning of the burners minimize time required to operate at this
Phase 0 possible at this stage. This may take up to 60hrs as the heating rate has to be controlled point. Not applicable

CEMS QAL1 ,CEMS will be active and CO ½ hr = 100 mg/Nm3

calibrated but not certified and used to CO daily=60 mg/m3
Initial start-up on natural gas. Operate for up 168 hours without SCR catalyst to clean out record emissions data. Data will be NOx ½ hr = 600 mg/m3
any debris that could harm the catalyst and SCR system. NG burner tuning will also be analysed and compared against the target PM ½ hr = 50 mg/m3
accomplished. Simultaneously, the generated steam will be used to also clean piping with emissions values accordingly NOx daily = 400 mg/m3
steam blows. All main steam piping will be hydrolyzed to shorten steam blow durations. No We plan to minimize time required to PM daily = 30 mg/m3
waste will be gasified. Rates will vary from 25% to 100% of full output. A higher trigger level operate at this point. If the plant is SO2 ½ hr = 200 mg/m3
is used for NOx in this phase as the SCR is not active. A higher trigger level is used for PM as operating near trigger value plant SO2 daily = 60 mg/m3 Steam blows will occur over a 48 hour period per circuit.
the purpose of this phase is to clean debris from the system. Based on monitoring data conditions will be adjusted to keep under TOC ½ hr = 30 mg/Nm3 Major steam blow circuits will include steam silencers.
Phase 1A - Auxiliary Boiler Start-up from TV1 no significant dust was observed during the cleaning out phase the trigger values TOC daily=15 mg/m3 Minor circuits will be blown to atmosphere.

CEMS QAL1 ,CEMS will be active and CO ½ hr = 100 mg/Nm3

calibrated but not certified and used to CO daily=60 mg/m3
Initially start-up GT's on natural gas. Operate at full speed no load (FSNL) for up 240 hours record emissions data. Data will be NOx ½ hr = 600 mg/m3
(per unit) without SCR catalyst to clean out any debris that could harm SCR catalyst and analysed and compared against the target PM ½ hr = 50 mg/m3
system. Combustor tuning will also be performed. Use steam to also clean piping with emissions values accordingly NOx daily = 400 mg/m3
steam blows. All main steam piping will be hydrolyzed to shorten steam blow durations. No We plan to minimize time required to PM daily = 30 mg/m3
waste will be gasified. Shutdown and repeat for 2nd gas turbine , total 480 hours. operate at this point. If the plant is SO2 ½ hr = 200 mg/m3
A higher trigger level is required for NOx in this phase as the SCR is not active.A higher trigger operating near trigger value plant SO2 daily = 60 mg/m3 Steam blows will occur over a 48 hour period per circuit.
level is used for PM as the purpose of this phase is to clean debris from the system Based on conditions will be adjusted to keep under TOC ½ hr = 30 mg/Nm3 Major steam blow circuits will include steam silencers.
Phase 1B - GT Start-up monitoring data from TV1 no significant dust was observed during the cleaning out phase the trigger values TOC daily=15 mg/m3 Minor circuits will be blown to atmosphere.

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Phase Key activities/considerations AP Action Expected Emissions Other Notes

CEMS QAL1 ,CEMS will be active and

calibrated but not certified and used to CO ½ hr = 100 mg/Nm3
record emissions data. Data will be CO daily=70 mg/m3
analysed and compared against the target NOx ½ hr = 500
emissions values accordingly mg/m3(turbine); aux
In the event of approaching trigger values. boiler 150mg/m3
Adjust ammonia flowrate and look at flue PM ½ hr = 30mg/m3
gas temperatures. If these do not help, NOx daily = 240 mg/m3
we would shutdown and inspect ammonia PM daily = 12 mg/m3
and flue gas distribution system. SO2 ½ hr = 200 mg/m3
Install SCR catalyst and restart auxiliary boiler on NG. Aux. Boiler SCR will be tuned and the We plan to check any inlet air filters, tune SO2 daily = 60 mg/m3
boiler will be tested on NG at full rates. Validate emissions on NG. burners, improve control system TOC ½ hr = 20 mg/Nm3
Phase 2A - Auxiliary Boiler Testing No waste will be gasified. response, and tune controllers. TOC daily=10 mg/m3 Duration is expected to take about 10 days.

CEMS QAL1 ,CEMS will be active and

calibrated but not certified and used to CO ½ hr = 100 mg/Nm3
record emissions data. Data will be CO daily=70 mg/m3
analysed and compared against the target NOx ½ hr = 500
emissions values accordingly mg/m3(turbine); aux
In the event of approaching trigger values. boiler 150mg/m3
Adjust ammonia flowrate and look at flue PM ½ hr = 30mg/m3
gas temperatures. If these do not help, NOx daily = 240 mg/m3
we would shutdown and inspect ammonia PM daily = 12 mg/m3
and flue gas distribution system. SO2 ½ hr = 200 mg/m3
Install SCR catalyst in HRSG's and restart each GT on NG. Each GT SCR will be tuned and each We plan to check any inlet air filters, tune SO2 daily = 60 mg/m3
GT/HRSG will be tested on NG at full rates. Validate emissions on NG. No waste will be burners, improve control system TOC ½ hr = 20 mg/Nm3
Phase 2B - GT Testing gasified response, and tune controllers. TOC daily=10 mg/m4 Duration is expected to take about 10 days.

CO ½ hr = 100 mg/Nm3
CO daily=70 mg/m3
NOx ½ hr = 500
mg/m3(turbine); aux
boiler 150mg/m3
PM ½ hr = 30mg/m3
NOx daily = 240 mg/m3
The following plant tests will be conducted with NG fuel, no waste will be gasified: PM daily = 12 mg/m3
• Black Start Test SO2 ½ hr = 200 mg/m3
• GT Trip Test SO2 daily = 60 mg/m3
• Steam Turbine Trip Test CEMS QAL1 ,will be active and calibrated , TOC ½ hr = 20 mg/Nm3
Phase 3 - Plant Testing • Island Mode Test other actions as in phase 1, 2 above TOC daily=10 mg/m3 Duration is expected to take about 14 days.

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Phase Key activities/considerations AP Action Expected Emissions Other Notes

CO ½ hr = 100 mg/Nm3
CO daily=70 mg/m3
NOx ½ hr = 500
mg/m3(turbine); aux
boiler 150mg/m3
PM ½ hr = 30mg/m3
NOx daily = 240 mg/m3
PM daily = 12 mg/m3
Once all of the individual tests have been conducted, we plan to run the GT's and the Aux. SO2 ½ hr = 200 mg/m3
Boiler as needed, to support other areas of plant during commissioning. This includes the SO2 daily = 60 mg/m3
steam turbine commissioning, syngas compressor commissioning etc. Again, this would be CEMS QAL1 ,will be active and calibrated , TOC ½ hr = 20 mg/Nm3
Phase 4 - Intermittent Operation accomplished with NG fuel only, No waste will be gasified. other actions as in phase 1, 2 above TOC daily=10 mg/m4

CO ½ hr = 100 mg/Nm3
CO daily=70 mg/m3
NOx ½ hr = 500
mg/m3(turbine); aux
boiler 150mg/m3
The gasifier will be heated up using the start-up burners and torches. The exhaust gas will PM ½ hr = 30mg/m3
vent through the start-up vent. The initial warm-up will take up to 144 hours. Once proper NOx daily = 240 mg/m3
temperatures are achieved, bed material (met coke or anthracite coal) will be added and the PM daily = 12 mg/m3
operation is changed from combustion to gasification. The torches and downstream quench SO2 ½ hr = 200 mg/m3
and cleanup system will be tested. No waste will be gasified. The Aux. Boiler or one GT will SO2 daily = 60 mg/m3
Phase 5 - Gasifier Initial Start- be operated at low rates to provide the steam required for the gasifier and cleanup circuit. CEMS QAL1 ,will be active and calibrated , TOC ½ hr = 20 mg/Nm3
up/Commissioning NG will be co-fired as necessary. other actions as in phase 1, 2 above TOC daily=10 mg/m5 Duration is expected to take about 16 days.

The gasifier syngas will be sent to the flare Firing with waste
while during this period. CO ½ hr = 120 mg/Nm3
Adjust ammonia flowrate and look at flue CO daily=70 mg/m3
gas temperatures. If these do not help, NOx ½ hr = 480 mg/m3
we would shutdown and inspect ammonia PM ½ hr = 36 mg/m3
and flue gas distribution system. We also NOx daily = 240 mg/m3
After the initial testing, MSW will be fed to the gasifier. Again, torches will be tested. MSW plan to tune burners, improve control PM daily = 12 mg/m3
will be weighed and totalised. The Aux. Boiler or one GT will be operated at low rates to system response, tune controllers, and SO2 ½ hr = 240 mg/m3
Phase 6A- Gasifier Initial Operation on Waste provide the steam required for the gasifier and cleanup circuit. troubleshoot upstream equipment. SO2 daily = 60 mg/m3 The overall duration is expected to take about 3-7 days.

Firing with waste

CO ½ hr = 120 mg/Nm3
CO daily=70 mg/m3
NOx ½ hr = 480 mg/m3
PM ½ hr = 36 mg/m3
NOx daily = 240 mg/m3
For the first bit of gasifier testing, the syngas will be directed to the Quench/Scrubber, Direct PM daily = 12 mg/m3
Contact Cooler, Blower, and WESP. This syngas will be flared after the WESP. The gasifier SO2 ½ hr = 240 mg/m3
Phase 6B - Gasifier/Low Pressure Clean-up will operate ate minimum rates for 4-7 days to tune the various clean-up unit operations. SO2 daily = 60 mg/m3
Section Commissioning on Waste (no sulphur or mercury removal). The Aux. Boiler or one GT will be operated at low rates to TOC ½ hr = 30 mg/Nm3
(Quench/Scrubber, DCC, Blower, WESP) provide the steam required for the gasifier and cleanup circuit. The gasifier syngas will be sent to the flare. TOC daily=15 mg/m3 Duration is expected to take about 5-7 days.

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Phase Key activities/considerations AP Action Expected Emissions Other Notes

Firing with waste

The gasifier syngas will be sent to the CO ½ hr = 120 mg/Nm3
flare. CO daily=70 mg/m3
In the event of approaching trigger value NOx ½ hr = 480 mg/m3
Adjust ammonia flowrate and look at flue PM ½ hr = 36 mg/m3
The initial testing will be followed-up with testing of the remaining clean-up system items, gas temperatures. If these do not help, NOx daily = 240 mg/m3
including the syngas compressor, Mercury Bed, COS Hydrolysis Reactor, and the Lo-Cat we would shutdown and inspect ammonia PM daily = 12 mg/m3
System. This clean syngas will be flared through the high pressure flare circuit. The gasifier and flue gas distribution system. We also SO2 ½ hr = 240 mg/m3
Phase 6C - Gasifier/High Pressure Clean-up will operate ate minimum rates for 4-7 days to tune the various clean-up unit operations. plan to tune burners, improve control SO2 daily = 60 mg/m3
Section Commissioning on Waste (Syngas The Aux. Boiler or one GT will be operated at low rates to provide the steam required for the system response, tune controllers, and TOC ½ hr = 30 mg/Nm3
Compressor, Lo-Cat, Mercury, COS Hydrolysis) gasifier and cleanup circuit. troubleshoot upstream equipment. TOC daily=15 mg/m3 Duration is expected to take about 5-7 days.

Firing with waste

CO ½ hr = 200 mg/Nm3
CO daily=90 mg/m3
NOx ½ hr = 480 mg/m3
PM ½ hr = 36 mg/m3
NOx daily = 240 mg/m3
Once the clean-up system has been tuned, we will feed the syngas to the Aux. Boiler, PM daily = 12 mg/m3
transitioning from NG to MSW based syngas. The Aux. Boiler will be ramped up to full rates SO2 ½ hr = 300 mg/m3 Duration is expected to take about 5-7 days. We may
and a small amount of syngas will be flared through the high pressure flare circuit. The SO2 daily = 100 mg/m3 also trip offline as we adjust operation and begin to
Phase 6D - Gasifier/Aux. Boiler Commissioning gasifier will continue to operate at minimum rates for 4-7 days as the plant produces power Excess gasifier syngas will be sent to the TOC ½ hr = 30 mg/Nm3 make power from MSW-based syngas and need to flare
on Waste from the steam turbine. flare. TOC daily=15 mg/m3 more frequently.

Firing with waste

CEMS will be active and calibrated but not CO ½ hr = 200 mg/Nm3
certified and used to record emissions CO daily=90 mg/m3
data will be analysed and the target NOx ½ hr = 500 mg/m3
emissions values accordingly PM ½ hr = 100 mg/m3
We plan to tune burners, improve control NOx daily = 300 mg/m3
Once stable operation is maintained, the gasifier will be ramped up to full rates. A gas system response, tune controllers, and PM daily = 30 mg/m3
turbine will be transitioned to syngas and the flow to the flare will be cut back substantially. troubleshoot upstream equipment. We SO2 ½ hr = 300 mg/m3 Duration is expected to take about 10-14 days. We may
Phase 6E - Gasifier/Power Generations System This will be followed by the second gas turbine and the flare will be closed. Once at full will look to adjust operation of venturi SO2 daily = 100 mg/m3 also trip offline as we adjust operation and begin to
(Aux. Boiler, GT's, and Steam Turbine) operation with the flare closed, the system will be tested and tuned. This will require about scrubber, DCC, and WESP. TOC ½ hr = 30 mg/Nm3 make power from MSW-based syngas and need to flare
Commissioning on Waste 7-10 days as the Aux. Boiler burner and the GT combustors are tuned on syngas. TOC daily=15 mg/m3 more frequently.

Firing with waste

CO ½ hr = 200 mg/Nm3
CEMS will be active and calibrated but not CO daily=90 mg/m3
certified and used to record emissions NOx ½ hr = 500 mg/m3
data will be analysed and the target PM ½ hr = 100 mg/m3 Duration is expected to take about 14 to 35 days. We
emissions values accordingly NOx daily = 300 mg/m3 may also plan a 14 day outage to shutdown and inspect
We plan to tune burners, improve control PM daily = 30 mg/m3 unit. If we do, then we would restart, check all systems,
system response, tune controllers, and SO2 ½ hr = 300 mg/m3 and declare commercial operation once we were at
Once the Gasifier and Power generation Systems are Commissioned, testing will commence, troubleshoot upstream equipment. We SO2 daily = 100 mg/m3 appropriate throughput. We may also trip offline as we
Phase 6F - Gasifier/Power Generation System including, Reliability Testing, Gasifier Performance Testing until stable operations are will look to adjust operation of venturi TOC ½ hr = 30 mg/Nm3 adjust operation and begin to make power from MSW-
Testing on Waste reached. In this phase the plant will run at stable operations below maximum rate scrubber, DCC, and WESP. TOC daily=15 mg/m3 based syngas and need to flare more frequently.

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Phase Key activities/considerations AP Action Expected Emissions Other Notes

Firing with waste

CO ½ hr = 200 mg/Nm3
CO daily=90 mg/m3
NOx ½ hr = 500 mg/m3
PM ½ hr = 100 mg/m3
NOx daily = 300 mg/m3
PM daily = 30 mg/m3
CEMS will be active and calibrated but not SO2 ½ hr = 300 mg/m3
certified and used to record emissions SO2 daily = 100 mg/m3
During this period we may hold the gasifier with no coke ,or MSW, running on NG and data will be analysed and the target TOC ½ hr = 30 mg/Nm3
hot start up-part of phase 6F venting to the start up vent, so as not to thermally cycle the gasifier between tests emissions values accordingly TOC daily=15 mg/m3 up to 21 days during the gasifier testing period

Firing with waste

CO ½ hr = 200 mg/Nm3
CO daily=90 mg/m3
NOx ½ hr = 500 mg/m3
PM ½ hr = 100 mg/m3
NOx daily = 300 mg/m3
PM daily = 30 mg/m3
CEMS will be active and calibrated but not SO2 ½ hr = 300 mg/m3
certified and used to record emissions SO2 daily = 100 mg/m3
During this period we may have additional flaring over and above the normal operating cases data will be analysed and the target TOC ½ hr = 30 mg/Nm3
Plant performance testing part of phase 6F to cover periods where individual unit operations are optimised emissions values accordingly TOC daily=15 mg/m3 up to 90 days during the gasifier testing period

Firing with Waste meeting

permit ELVs
CO ½ hr = 100 mg/Nm3
CO daily=50 mg/m3
NOx ½ hr = 400 mg/m3
CEMS will be active and calibrated at QAL PM ½ hr = 30 mg/m3
2 NOx daily = 200 mg/m3
Once the Gasifier and Power generation Systems are Commissioned and system testing System tuning will still take place as per PM daily = 10 mg/m3
Reliability Testing, Gasifier Performance Testing are complete and stable operations are phase 6 F and in these cases, we will SO2 ½ hr = 200 mg/m3
achieved the and Environmental/Stack Testing QAL 2 will be performed . At the end of revert to the trigger limits in phase 6 F SO2 daily = 50 mg/m3
Phase 6G - Gasifier/Power Generation System successful testing, the facility will be declared commercial and will abide by WID rules for rather than the permit ELVs TOC ½ hr = 20 mg/Nm3
stable operation emissions. TOC daily=10 mg/m3 up to 21 days during the gasifier testing period

 Start up of burners
 Approximate duration CEMS will be active and calibrated at QAL1
 No waste incinerated/gasified but not certified and used to record
 Emission levels and monitoring/reporting considerations emissions data will be analysed and the
First firing with non-waste fuel target emissions values accordingly See Phases 1A, 1B, 2A, 2B,3, 4, and 5 above.

• Approximate duration
• Steam blowing activities (frequency, water use)
• No waste incinerated
• Emission trigger values and monitoring/reporting considerations CEMS will be active and calibrated but not
• Calibration of CEMs certified and used to record emissions
Further firing with non-waste fuel – Steam • Emergency testing with burners data will be analysed and the target
Blowing emissions values accordingly See Phases 1A and 1B above.

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Phase Key activities/considerations AP Action Expected Emissions Other Notes

· • Approximate duration
• Shutdown and start up on auxiliary fuel
• Waste quantity profile
• Abatement system operation (and adjustment)
• Turbine commissioning and load/synchronisation testing
• Live tests, tuning and optimisation CEMS will be active and calibrated but not
• Emission trigger values and monitoring/reporting considerations certified and used to record emissions
• Ash transportation, collection and storage data will be analysed and the target
First firing with waste and steam circuit testing emissions values accordingly See Phases 6A, 6B, 6C, and 6D above.

• Approximate duration
• Waste throughput adjustments
• Systems testing
• Emission trigger values and monitoring/reporting considerations
Reliability testing
• Continuous operation
• Maximum waste throughput
• Emission trigger values and monitoring/reporting considerations CEMS will be active and calibrated but not
• QAL 2 certified and used to record emissions
• IBA sampling data will be analysed and the target
Throughput testing emissions values accordingly See Phases 6E and phase G above.

See Phases 6F above.

Performance testing is part of commissioning / start-up
activities. During commissioning phase prior to
introducing MSW natural gas will be used, which
provides an opportunity for equipment tuning and
testing. For example the gas turbines and auxiliary
boiler will be first run on natural gas and we will be
measuring emissions using the in-plant CEMS. Once full
load stable operation (with MSW) is achieved, testing
will be started for major equipments for process
reasons as well as environmental compliance (if the
equipment is designed to function so). During the
testing period, syngas samples will be drawn from
different locations of the plant and analyzed by in-house
or external laboratories. The analytical results will be
used to check against on-line analyzers, e.g. the H2S
analyzer after the sulphur removal unit will be checked.
Syngas samples will be collected in sample cylinders and
analyzed to determine the concentrations of some
environmentally concerned species that are not
monitored on-line; for example dioxin. Samples of
CEMS will be active and calibrated but not waste water and slag from the gasifier will also be
certified and used to record emissions collected to determine their constituents and
data will be analysed and the target concentrations. During the start-up / commissioning
emissions values accordingly phase, gas, water or solid sample collection will be
Approximate duration Most performance testing will be done on routine in order to validate on-line analyzers and comply
 Emergency shutdown phase 6F. if further performance testing is with environmental requirements. As operation
 Turbine testing (island mode, load rejection) required following stable operation (phase becomes steady and all plant analyzers are ensured to
 Demonstration of compliance with permit emission limit values 6G after QAL 2) limits in phase 6F will be function adequately, manual sampling frequency will be
Performance testing  IBA sampling used. gradually reduced to a prescribed schedule

If the timetable set out in the programme is subject to slippage, you must advise us without
delay, providing a full explanation and action plan as appropriate. We may require a revised
Notification timetable to be submitted for our approval. information

Air Products Internal Use Only

Phase Key activities/considerations AP Action Expected Emissions Other Notes

Operating conditions may affect residue quantity and harmfulness, energy efficiency and
emissions to air. In your plan, you must describe how you will establish an acceptable
performance envelope during commissioning. Some examples are provided below. Your plan Solid residues, specifically, slag and sulphur will be
3.0 operating conditions will need to reflect any site specific considerations. collected, sampled, and analyzed.

CEMS: Continuous monitoring must show that the specified ELVs are met. Meeting the ELVs
will form one possible boundary of the operating envelope. However, the final operating CEMS will be active and calibrated but not
envelope may be more restricted than this if it is possible to reduce emissions further, or certified and used to record emissions
improve energy efficiency, or minimise the quantity and harmfulness of residues. See also data will be analysed and the target
CEMS: Continuous monitoring section 4.0. emissions values accordingly CEMS will be operational and calibrated.

Variability during commissioning phases must be detailed. It is useful to include a graphic We will record tonnages and collect samples of the
Waste profile illustration of daily tonnages processed over time across the commissioning phases. incoming MSW using our automatic sampler.

Our normal operating reagents will be delivered just

prior to commissioning and stored in their appropriate
tanks and totes. For certain process chemicals being
stored in bulk there is a specific first fill system to be
followed inconjunction with the supplier. They will be
used to tune, test, and operate the facility. Any special
reagents needed for cleaning or passivating systems will
be addressed on a case by case basis and will follow
Reagents Delivery and storage arrangements for the commissioning phases. MSDS recommendations for storage and containment.
These will be covered in the Air Products waste
Residue disposal Arrangements for storage, sampling and disposal must be detailed. CEMP management plan

This section must include all relevant commissioning activities in relation to CEMS
monitoring. Key activities such as QAL2 testing and calibrations must be included at the
4.0 Monitoring appropriate phase of commissioning (see also section 2.0).

We would expect as a minimum and before waste has been introduced that a calibration of
the CEMs (using bottled test gases from accredited suppliers where available) is carried out
to give the CEMs readings some validity. QAL2 work shall be carried out at a sensible point in
time, when reasonable and reliable running conditions apply while burning waste.
Tests must be completed to verify that the monitors are functional, and that output is
correct (i.e. that software is producing the right readings in the right format and applying the All of the appropriate corrections will be checked and
right ELVs for alarms etc). the alarm levels set for the firt phase of commissioning.
Compliance with MCERTs is essential for all pressure, temperature and emissions measuring Alarm levels will be changed to match the
instruments and demonstration of this must be completed as part of commissioning activities commissioning phase and finally set to the permit limits
at the appropriate phase. This is to ensure that the relevant corrections can be made to at Phase 6G. QAL three will be initiated and appropriate
reference conditions and thus ensure valid monitoring results. Contingency plans must be Sams values entered. We will have a service contract with
CEMS included (for example, the provision of standby monitors). the CEMS supplier to support us should there be
Put in place CEMS monitoring plan problems.

Air Products Internal Use Only

Phase Key activities/considerations AP Action Expected Emissions Other Notes

Monitoring results must be standardised to the conditions (pressure, oxygen etc) as required
by your permit and as laid down in Article 48 of Ch IV IED. During commissioning, you must
demonstrate the effectiveness of process variable monitors, and show how the reference
conditions are used in the calculation of results. It is essential that the readings from the
CEMS are processed to the correct reference conditions before they operate alarms, reach
displays, reports etc.
For periodic monitoring, an assessment of compliance with the requirements set out in our
Technical Monitoring Guidance Note M1: Sampling requirements for stack emissions See above for setting up of corrections. We will employ
CEMS and stack tests monitoring must be included in the plan. a stack tester and follow the proper protocols.

The operating procedures define operator

actions and the review required by plant
management, supervisors, or the
environmental engineer
While the operating envelope is being established, there will be occasions when the permit Environmental engineer has the authority
ELVs may be breached. This is accepted as reasonable. Likely ‘benchmark’ levels of emissions to shut down operations deemed
for all relevant parameters during the various phases of commissioning must be proposed in unacceptable, for example excessive During the commissioning period we will adopt the
the commissioning plan for us to approve. These will give us realistic emission levels against flaring resulting in complaints same warning/ alarm trip and operator actions that we
which to assess performance. We would expect you to achieve operation under the permit CEMS system and stack data will be would during normal operation
emission limit values as soon as practicable. analysed on a regularly basis with
As well as ‘benchmark’ levels, you must propose critical ‘trigger values’ for commissioning feedback into how the plant is operated This is a first of its kind facility so there is no existing
phases that require you to take some identified action, together with a description of what and to adjust the target emissions values plant data we can use to fully predict performance
that action would be (e.g. cease feeding waste, initiate plant shut-down etc.) Unless you can accordingly during the commissioning period. However we will use
justify differently, the trigger levels must not be higher than the ELVs set by the Ch IV IED for We plan to minimize time required to to plant data to refine the plant operation to ensure
abnormal operation. You must set out proposed trigger values for each determinand for each operate near or above the trigger values. convergence to compliance with the ELVs over the
5.0 Trigger Values, Emission Limit Values and phase of hot commissioning. Details of the monitoring standards and methods to be used If the plant is operating near trigger value commissioning period and regularly update and revise
Notifications must be included; further guidance can be found in our Technical Monitoring Guidance Note plant conditions will be adjusted to keep the commissioning limits accordingly
M2: Monitoring of Stack Emissions to Air. An example is provided in table 5.1 below. under the trigger values

When we have approved your proposed values during commissioning, we will not take
enforcement action for breaches of permit ELVs, provided that you have complied with your
trigger levels and corresponding actions. The actions to be taken if trigger values are
exceeded are specific to the stage in commissioning. For example, basing trigger values on
Enforcement action half hourly values rather than daily average values would be appropriate for certain phases.
information

Your Plan must clearly identify the point at which permit ELVs apply (and trigger values no
longer apply). Once the plant is commissioned to the point where the permit emission limit
values apply, the commissioning emission limit values and trigger values will no longer be
applicable. End of commissioning will be when the plant is fully
Define end of commissioning handed over to the operating team as safe to operate

During the commissioning period, we would neither expect you to report exceedence of the
permit’s emission limit values as breaches of permit conditions, nor to report the exceedance
of agreed trigger values. We will however expect you to notify us if the agreed action
following exceedance of a trigger value is not carried out using a Schedule 1 notice, after Our Air Products procedure on non conformance/
Reporting which we will consider if a breach has occurred and what further action to take. incident reporting will define the action to take

Air Products Internal Use Only

Phase Key activities/considerations AP Action Expected Emissions Other Notes

Our training plan is as follows

All new hire operators will have 6 weeks of classroom
training on
1 Air Products procedures
2 the plant operation and equipment
3 Site work instructions (SWIMS)
4 The permit and permit conditions
5 how to comply, included in the relevant SWIMS
6 Specific equipment training for systems such as CEMS
emergency plan and incident reporting
7 Supervisor level will get CIWM training in operator
competence and relevant UK legislation including waste
Training and competence: You will need to demonstrate that sufficient adequately trained The commissioning team will receive training in the 1
personnel (including contractor personnel) will be available during commissioning activities; operating permit
brief details of required competency levels and training provided must be included. Your plan 2 relevant UK legislation
must detail specific procedures in place to cover commissioning activities, and include key 3 Any of the operator training above that is not already
roles and responsibilities, setting out the management hierarchy in relation to commissioning covered, (items 3-6)
Training and competence activities. All training involves competence testing

The main activity that has the potential to cause noise

nuisance during commissioning is the operation of the
flare.
We will communicate the outline and timings of our
Special consideration shall be give to noise during commissioning. Your plan must include commissioning activity to site industrial and other
details of any noisy activities (source, type, duration etc) as well as any steps you will take to neighbours and to any Port Clarence residents that
Noise keep us and your neighbours informed could foreseeable be impacted

The site is not close to sensitive odour receptors,

Special consideration must be given to potential odour issues during commissioning. Your however a mechanism for dealing with off site
plan must identify potential odour sources during commissioning and include details of how complaints will be communicated to all the site
odour will be minimised and controlled. Your plan must specify any steps you will take to neighbours, see SWIM on community relations
Odour keep us and your neighbours informed. communications

Accident Management: Prior to commissioning, an accident management plan must be An emergency plan will cover AP commissioning
drawn up. The risk of accidents during commissioning activities may be increased. For activities , which will be supplementary to the Foster
example, if you are operating through a problem outside of normal operations, this could Wheeler site emergency plan whilst they have overall
Accident management lead to an incident. Site and activity-specific considerations must be included. site control.

Demonstration of controls in place to minimise these emissions to air, surface water,

groundwater and sewer from localised or diffuse sources which are not controlled by and
Emissions of substances not controlled by emission or background limit. Note – these emissions may still be referred to as fugitive Potential leaks and spills and contingency plans are
emission limits:(fugitive emissions) emissions in existing permits covered in the site emergency and EHS plans

We will be following Foster Wheeler site EHS Air

Planning requirements: There may be specific planning requirements to be met during Products site EHSplans dung the commissioning period
commissioning. These do not necessarily need to be included in detail in this plan, but should which incorporate all the relevant planning
Planning requirements be considered when drafting the plan requirements

Air Products Internal Use Only

 Trigger
Monitoring Permit values values Benchmark 2 x trigger Monitoring standards and
Commissioning phase. Activity and operating conditions determinand mg/m3 mg/m3 levels mg/m3 mg/m3 methods Action to be taken

We plan to minimize time required to

operate at this point. If the plant is operating
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR near trigger value, plant conditions will be
Phase 1 B Gas turbine start up CO ½ hr 100 100 120 200 permit adjusted to keep under the trigger values

We plan to minimize time required to

operate at this point. If the pant is operating
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR near trigger value plant conditions will be
Phase 1 B Gas turbine start up CO daily 60 60 70 120 permit adjusted to keep under the trigger values

We plan to minimize time required to

operate at this point. If the plant is operating
near trigger value plant conditions will be
adjusted to keep under the trigger values.
aux boiler Higher trigger level for NOx in this phase as
Phase 1 A Auxiliary boiler start up 150, turbine aux boiler 300, CEMS at QAL 1, as per EPR the SCR catalyst is not in place as it would be
Phase 1 B Gas turbine start up NOx ½ hr 400 600 600 turbine 1200 permit damaged by the system cleaning

We plan to minimize time required to

operate at this point. If the pant is operating
near trigger value plant conditions will be
adjusted to keep under the trigger values
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR Higher trigger level for PM in this phase as
Phase 1 B Gas turbine start up PM ½ hr 30 30 100 60 permit particlates will be blown though the system

We plan to minimize time required to

operate at this point. If the pant is operating
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR near trigger value plant conditions will be
Phase 1 B Gas turbine start up NOx daily 200 200 400 400 permit adjusted to keep under the trigger values

We plan to minimize time required to

operate at this point. If the pant is operating
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR near trigger value plant conditions will be
Phase 1 B Gas turbine start up PM daily 10 10 30 20 permit adjusted to keep under the trigger values

We plan to minimize time required to

operate at this point. If the plant is operating
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR near trigger value plant conditions will be
Phase 1 B Gas turbine start up SO2 ½ hr 200 200 240 400 permit adjusted to keep under the trigger values

We plan to minimize time required to

operate at this point. If the pant is operating
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR near trigger value plant conditions will be
Phase 1 B Gas turbine start up SO2 daily 50 50 60 100 permit adjusted to keep under the trigger values

Air Products Internal Use Only

 Trigger
Monitoring Permit values values Benchmark 2 x trigger Monitoring standards and
Commissioning phase. Activity and operating conditions determinand mg/m3 mg/m3 levels mg/m3 mg/m3 methods Action to be taken

We plan to minimize time required to

operate at this point. If the plant is operating
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR near trigger value plant conditions will be
Phase 1 B Gas turbine start up TOC ½ hr 20 30 30 60 permit adjusted to keep under the trigger values

We plan to minimize time required to

operate at this point. If the pant is operating
Phase 1 A Auxiliary boiler start up CEMS at QAL 1, as per EPR near trigger value plant conditions will be
Phase 1 B Gas turbine start up TOC daily 10 10 15 20 permit adjusted to keep under the trigger values

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing
Phase 4 - Storage/Intermittent Operation
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR We plan to tune burners, improve control
CO ½ hr 100 100 120 200 permit system response, and tune controllers.

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing We plan to minimize time required to
Phase 4 - Storage/Intermittent Operation operate at this point. If the pant is operating
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR near trigger value plant conditions will be
CO daily 60 60 70 120 permit adjusted to keep under the trigger values

Phase 2A - Auxiliary Boiler Testing Adjust ammonia flowrate and look at flue gas
Phase 2B - GT Testing temperatures. If these do not help, we
Phase 3 - Plant Testing would shutdown and inspect ammonia and
Phase 4 - Storage/Intermittent Operation aux boiler flue gas distribution system.
Phase 5 - Gasifier Initial Startup/Commissioning 150, turbine aux boiler 300, CEMS at QAL 1, as per EPR Higher trigger level for NOx in this phase we
NOx ½ hr 400 500 500 turbine 1000 permit will be tuning the system

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing
Phase 4 - Storage/Intermittent Operation We plan to check any inlet air filters, tune
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR burners, improve control system response,
PM ½ hr 30 30 36 60 permit and tune controllers.

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing Adjust ammonia flowrate and look at flue gas
Phase 4 - Storage/Intermittent Operation temperatures. If these do not help, we
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR would shutdown and inspect ammonia and
NOx daily 200 200 240 400 permit flue gas distribution system.

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing
Phase 4 - Storage/Intermittent Operation We plan to check any inlet air filters, tune
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR burners, improve control system response,
PM daily 10 10 12 20 permit and tune controllers.

Air Products Internal Use Only

 Trigger
Monitoring Permit values values Benchmark 2 x trigger Monitoring standards and
Commissioning phase. Activity and operating conditions determinand mg/m3 mg/m3 levels mg/m3 mg/m3 methods Action to be taken

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing We plan to minimize time required to
Phase 4 - Storage/Intermittent Operation operate at this point. If the plant is operating
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR near trigger value plant conditions will be
SO2 ½ hr 200 200 240 400 permit adjusted to keep under the trigger values

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing We plan to minimize time required to
Phase 4 - Storage/Intermittent Operation operate at this point. If the plant is operating
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR near trigger value plant conditions will be
SO2 daily 50 50 60 100 permit adjusted to keep under the trigger values

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing We plan to minimize time required to
Phase 4 - Storage/Intermittent Operation operate at this point. If the plant is operating
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR near trigger value plant conditions will be
TOC ½ hr 20 20 20 40 permit adjusted to keep under the trigger values

Phase 2A - Auxiliary Boiler Testing

Phase 2B - GT Testing
Phase 3 - Plant Testing We plan to minimize time required to
Phase 4 - Storage/Intermittent Operation operate at this point. If the plant is operating
Phase 5 - Gasifier Initial Startup/Commissioning CEMS at QAL 1, as per EPR near trigger value plant conditions will be
TOC daily 10 10 10 20 permit adjusted to keep under the trigger values

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on
Waste (Quench/Scrubber, DCC, Blower, WESP)
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis)
Hot start up We plan to tune burners, improve control
Performance testing CEMS at QAL 1, as per EPR system response, tune controllers, and
CO Daily 60 60 70 120 permit troubleshoot upstream equipment.

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on
Waste (Quench/Scrubber, DCC, Blower, WESP)
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on We plan to tune burners, improve control
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis) system response, tune controllers, and
Hot start up troubleshoot upstream equipment. Higher
Performance testing CEMS at QAL 1, as per EPR trigger levels are required during adjustment
CO ½ hr 100 120 120 240 permit of the system

Air Products Internal Use Only

 Trigger
Monitoring Permit values values Benchmark 2 x trigger Monitoring standards and
Commissioning phase. Activity and operating conditions determinand mg/m3 mg/m3 levels mg/m3 mg/m3 methods Action to be taken

Adjust ammonia flowrate and look at flue gas

Phase 6A- Gasifier Initial Operation on Waste temperatures. If these do not help, we
Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on would shutdown and inspect ammonia and
Waste (Quench/Scrubber, DCC, Blower, WESP) flue gas distribution system. We also plan to
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on tune burners, improve control system
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis) response, tune controllers, and troubleshoot
Hot start up upstream equipment.
Performance testing CEMS at QAL 1, as per EPR Higher trigger levels are required during
NOx ½ hr 400 500 500 1000 permit adjustment of the system

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on
Waste (Quench/Scrubber, DCC, Blower, WESP)
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on We plan to tune burners, improve control
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis) system response, tune controllers, and
Hot start up troubleshoot upstream equipment.
Performance testing CEMS at QAL 1, as per EPR Higher trigger levels are required during
PM ½ hr 30 100 36 200 permit adjustment of the system

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on Adjust ammonia flowrate and look at flue gas
Waste (Quench/Scrubber, DCC, Blower, WESP) temperatures. If these do not help, we
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on would shutdown and inspect ammonia and
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis) flue gas distribution system. We also plan to
Hot start up tune burners, improve control system
Performance testing CEMS at QAL 1, as per EPR response, tune controllers, and troubleshoot
NOx daily 200 200 240 400 permit upstream equipment.

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on
Waste (Quench/Scrubber, DCC, Blower, WESP)
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis)
Hot start up We plan to tune burners, improve control
Performance testing CEMS at QAL 1, as per EPR system response, tune controllers, and
PM daily 10 10 12 20 permit troubleshoot upstream equipment.

Air Products Internal Use Only

 Trigger
Monitoring Permit values values Benchmark 2 x trigger Monitoring standards and
Commissioning phase. Activity and operating conditions determinand mg/m3 mg/m3 levels mg/m3 mg/m3 methods Action to be taken

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on
Waste (Quench/Scrubber, DCC, Blower, WESP)
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis) We plan to minimize time required to
Hot start up operate at this point. If the plant is operating
Performance testing CEMS at QAL 1, as per EPR near trigger value plant conditions will be
SO2 ½ hr 200 200 240 400 permit adjusted to keep under the trigger values

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on
Waste (Quench/Scrubber, DCC, Blower, WESP)
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis) We plan to minimize time required to
Hot start up operate at this point. If the plant is operating
Performance testing CEMS at QAL 1, as per EPR near trigger value plant conditions will be
SO2 daily 50 50 60 100 permit adjusted to keep under the trigger values

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on
Waste (Quench/Scrubber, DCC, Blower, WESP)
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis) We plan to minimize time required to
Hot start up operate at this point. If the plant is operating
Performance testing CEMS at QAL 1, as per EPR near trigger value plant conditions will be
TOC ½ hr 20 20 20 40 permit adjusted to keep under the trigger values

Phase 6A- Gasifier Initial Operation on Waste

Phase 6B - Gasifier/Low Pressure Clean-up Section Commissioning on
Waste (Quench/Scrubber, DCC, Blower, WESP)
Phase 6C - Gasifier/High Pressure Clean-up Section Commissioning on
Waste (Syngas Compressor, Lo-Cat, Mercury, COS Hydrolysis) We plan to minimize time required to
Hot start up operate at this point. If the plant is operating
Performance testing CEMS at QAL 1, as per EPR near trigger value plant conditions will be
TOC daily 10 10 10 20 permit adjusted to keep under the trigger values

Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste

Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and
Steam Turbine) Commissioning on Waste We plan to tune burners, improve control
Phase 6F - Gasifier/Power Generation System Testing on Waste system response, tune controllers, and
troubleshoot upstream equipment. Higher
CEMS at QAL 1, as per EPR trigger levels are required during adjustment
CO ½ hr 100 200 200 400 permit of the system

Air Products Internal Use Only

 Trigger
Monitoring Permit values values Benchmark 2 x trigger Monitoring standards and
Commissioning phase. Activity and operating conditions determinand mg/m3 mg/m3 levels mg/m3 mg/m3 methods Action to be taken
Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste
Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and
Steam Turbine) Commissioning on Waste
Phase 6F - Gasifier/Power Generation System Testing on Waste
We plan to tune burners, improve control
CEMS at QAL 1, as per EPR system response, tune controllers, and
CO Daily 60 60 90 120 permit troubleshoot upstream equipment.

Adjust ammonia flowrate and look at flue gas

temperatures. If these do not help, we
Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste would shutdown and inspect ammonia and
Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and flue gas distribution system. We also plan to
Steam Turbine) Commissioning on Waste tune burners, improve control system
Phase 6F - Gasifier/Power Generation System Testing on Waste response, tune controllers, and troubleshoot
upstream equipment. Higher trigger levels
CEMS at QAL 1, as per EPR are required during adjustment of the
NOx ½ hr 400 500 500 1000 permit system

Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste We plan to tune burners, improve control
Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and system response, tune controllers, and
Steam Turbine) Commissioning on Waste troubleshoot upstream equipment. We will
Phase 6F - Gasifier/Power Generation System Testing on Waste look to adjust operation of venturi scrubber,
DCC, and WESP.
CEMS at QAL 1, as per EPR Higher trigger levels are required during
PM ½ hr 30 50(150) 100 100(300) permit adjustment of the system

Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste Adjust ammonia flowrate and look at flue gas
Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and temperatures. If these do not help, we
Steam Turbine) Commissioning on Waste would shutdown and inspect ammonia and
Phase 6F - Gasifier/Power Generation System Testing on Waste flue gas distribution system. We also plan to
tune burners, improve control system
CEMS at QAL 1, as per EPR response, tune controllers, and troubleshoot
NOx daily 200 200 300 400 permit upstream equipment.

Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste

Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and
Steam Turbine) Commissioning on Waste We plan to tune burners, improve control
Phase 6F - Gasifier/Power Generation System Testing on Waste system response, tune controllers, and
troubleshoot upstream equipment. We will
CEMS at QAL 1, as per EPR look to adjust operation of venturi scrubber,
PM daily 10 10 30 20 permit DCC, and WESP.

Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste

Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and We plan to minimize time required to
Steam Turbine) Commissioning on Waste operate at this point. If the plant is operating
Phase 6F - Gasifier/Power Generation System Testing on Waste near trigger value plant condtions will be
adjusted to keep under the trigger values
CEMS at QAL 1, as per EPR Higher trigger levels are required during
SO2 ½ hr 200 300 300 600 permit adjustment of the system

Air Products Internal Use Only

 Trigger
Monitoring Permit values values Benchmark 2 x trigger Monitoring standards and
Commissioning phase. Activity and operating conditions determinand mg/m3 mg/m3 levels mg/m3 mg/m3 methods Action to be taken
Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste
Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and
Steam Turbine) Commissioning on Waste
Phase 6F - Gasifier/Power Generation System Testing on Waste We plan to minimize time required to
operate at this point. If the pant is operating
CEMS at QAL 1, as per EPR near trigger value plant condtions will be
SO2 daily 50 50 100 100 permit adjusted to keep under the trigger values

Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste

Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and We plan to minimize time required to
Steam Turbine) Commissioning on Waste operate at this point. If the plant is operating
Phase 6F - Gasifier/Power Generation System Testing on Waste near trigger value plant condtions will be
adjusted to keep under the trigger values
CEMS at QAL 1, as per EPR Higher trigger levels are required during
TOC ½ hr 20 30 30 60 permit adjustment of the system

Phase 6D - Gasifier/Aux. Boiler Commissioning on Waste

Phase 6E - Gasifier/Power Generations System (Aux. Boiler, GT's, and
Steam Turbine) Commissioning on Waste
Phase 6F - Gasifier/Power Generation System Testing on Waste We plan to minimize time required to
operate at this point. If the pant is operating
CEMS at QAL 1, as per EPR near trigger value plant condtions will be
TOC daily 10 10 15 20 permit adjusted to keep under the trigger values

Phase 6G - Gasifier/Power Generation System stable operation

We plan to tune burners, improve control
CEMS at QAL 2, as per EPR system response, tune controllers, and
CO 100 100 100 200 permit troubleshoot upstream equipment.

Adjust ammonia flowrate and look at flue gas

temperatures. If these do not help, we
would shutdown and inspect ammonia and
Phase 6G - Gasifier/Power Generation System stable operation flue gas distribution system. We also plan to
tune burners, improve control system
CEMS at QAL 2, as per EPR response, tune controllers, and troubleshoot
NOx ½ hr 400 400 400 800 permit upstream equipment.

We plan to tune burners, improve control

Phase 6G - Gasifier/Power Generation System stable operation system response, tune controllers, and
troubleshoot upstream equipment. We will
CEMS at QAL 2, as per EPR look to adjust operation of venturi scrubber,
PM ½ hr 30 30 30 60 permit DCC, and WESP.

Adjust ammonia flowrate and look at flue gas

temperatures. If these do not help, we
would shutdown and inspect ammonia and
Phase 6G - Gasifier/Power Generation System stable operation flue gas distribution system. We also plan to
tune burners, improve control system
CEMS at QAL 2, as per EPR response, tune controllers, and troubleshoot
NOx daily 200 200 200 400 permit upstream equipment.

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 Trigger
Monitoring Permit values values Benchmark 2 x trigger Monitoring standards and
Commissioning phase. Activity and operating conditions determinand mg/m3 mg/m3 levels mg/m3 mg/m3 methods Action to be taken

We plan to tune burners, improve control

Phase 6G - Gasifier/Power Generation System stable operation system response, tune controllers, and
troubleshoot upstream equipment. We will
CEMS at QAL 2, as per EPR look to adjust operation of venturi scrubber,
PM daily 10 10 10 20 permit DCC, and WESP.

Phase 6G - Gasifier/Power Generation System stable operation We plan to minimize time required to
operate at this point. If the plant is operating
CEMS at QAL 2, as per EPR near trigger value plant condtions will be
SO2 ½ hr 200 200 200 400 permit adjusted to keep under the trigger values

Phase 6G - Gasifier/Power Generation System stable operation We plan to minimize time required to
operate at this point. If the pant is operating
CEMS at QAL 2, as per EPR near trigger value plant condtions will be
SO2 daily 50 50 50 100 permit adjusted to keep under the trigger values

Phase 6G - Gasifier/Power Generation System stable operation We plan to minimize time required to
operate at this point. If the plant is operating
CEMS at QAL 1, as per EPR near trigger value plant condtions will be
TOC ½ hr 20 20 20 40 permit adjusted to keep under the trigger values

Phase 6G - Gasifier/Power Generation System stable operation We plan to minimize time required to
operate at this point. If the pant is operating
CEMS at QAL 1, as per EPR near trigger value plant condtions will be
TOC daily 10 10 10 20 permit adjusted to keep under the trigger values

Air Products Internal Use Only