Based on a review of typical streams generated by coal-fired EGUs, it is anticipated that the proposed ELGs would have large impacts on units that currently utilize water to transport their ash (i.e., wet sluice their fly ash or bottom ash) and units equipped with wet FGD scrubbers.
FGD Wastewater Proposed ELG Compliance
Potential options for complying with the proposed arsenic (As), mercury (Hg), nitrogen (N), and selenium (Se) limits for FGD wastewater include, but are not limited to: enhanced physical/chemical treatment, biological treatment, and thermal evaporative or zero liquid discharge (ZLD) systems. Coal-fired EGUs with newer wet FGD systems are more likely to include existing physical/chemical wastewater treatment (WWT). However, even if these WWT systems are designed to remove arsenic and mercury to levels consistent with the proposed standards, further treatment would be required to remove remaining nitrates/nitrites and selenium via biological treatment or ZLD for compliance with the proposed ELGs. Biological treatment systems tend to be high in capital cost and require significant footprint. The proposed ELG includes a five-year schedule incentive for compliance using a ZLD approach if the ZLD system eliminates all process wastewater discharges. Various types of ZLD solutions are commercially available, including but not limited to: brine crystallizers/evaporators, wastewater spray dry absorbers (SDA), and fixation/stabilization. The following is a summary of these technologies.
Brine Crystallizer/Evaporator
A brine crystallizer/evaporator utilizes steam to evaporate FGD wastewater, concentrating salts for dewatering and disposal. This process produces a high purity water stream that can be reused within the plant site. A ZLD brine crystallizer/evaporator requires high capital and operating and maintenance (O&M) costs, including significant power consumption requirements. In addition, the concentrated salts may require additional conditioning before disposal in a landfill because they are difficult to dewater.
Wastewater Spray Dryer
FGD wastewater can also be evaporated in a wastewater spray dryer where a slipstream of hot flue gas from the boiler outlet is diverted to the spray dryer and the residual heat is used to evaporate the water. If a plant has an existing physical/chemical WWT, it is possible that with this approach the use of physical/chemical treatment would no longer be required. Due to the arrangement of this option, the solid waste is collected in an existing particulate collection device installed on the boiler. There is limited experience using this technology and there are some risks that the concentrated salts could impact the downstream particulate collection equipment.
Waste Fixation and Stabilization
An alternate method for eliminating FGD wastewater is use in waste fixation and stabilization. Wet FGD byproduct (or gypsum) can be structurally stabilized and chemically fixated by mixing a proportioned blend of water (FGD wastewater), gypsum, ash and lime for disposal in a landfill. The resulting fixated waste is physically stable, making it easier to handle. The mechanism to achieve this stability is the reaction of silicates in the ash with lime to form a cement-like product, which gradually strengthens over time. Fixation/stabilization is useful for landfill disposal as the material resists reliquification and channeling, and minimizes leaching.
ZLD System Sizing
An important variable influencing the cost of ZLD technology is the flow rate processed by the ZLD system. Although a newly installed ZLD system could be designed to treat all process wastewater, one method to reduce FGD wastewater would be to change the absorber materials to allow for higher chloride concentrations, thereby reducing the need to purge chlorides from the system. The quantity of FGD wastewater decreases as the equilibrium chloride in the scrubber increases. The following graph shows an example correlation for a 500 MW unit burning a bituminous, high sulfur coal (see Fig. 1).