June
29,
2004
MEMORANDUM
From:
William
H.
Maxwell
CG/
ESD
(
C439­
01)

To:
Utility
MACT
Project
Files
Subject:
Meeting
with
Representative
David
Price,
June
29,
2004
Attendees
David
Price,
Member
of
Congress
Tracy
Lovett,
Staff
of
Representative
Price
Darek
Newby,
Staff
of
Representative
Price
(
by
phone)
Frank
Princiotta,
EPA/
ORD
Douglas
McKinney,
EPA/
ORD
Robert
Hall,
EPA/
ORD
Ravi
K.
Srivastava,
EPA/
ORD
Blair
Martin,
EPA/
ORD
Carlos
Nunez,
EPA/
ORD
Larry
Reiter,
EPA/
ORD
John
Bachmann,
EPA/
OAQPS
Bill
Maxwell,
EPA/
OAQPS
Jenny
Noonan,
EPA/
OAQPS
Discussion
At
the
meeting,
the
attached
presentation
was
discussed.

Attachment
Presentation
to
Congressman
David
Price
By
U.
S.
Environmental
Protection
Agency
Office
of
Research
and
Development
National
Risk
Management
Research
Laboratory
June
29,
2004
Control
of
Mercury
Emissions
from
Coal­
fired
Power
Plants
What
we'll
cover
today 


Background

Mercury
(
Hg)
Sources
and
Health
Impacts

Regulatory
Alternatives

ORD/
NRMRL
Role
and
Key
Accomplishments

Control
of
Hg
Emissions
from
Power
Plants
(
White
Paper)
Status
of
Issue:
Mercury
(
Hg)

Control
From
Power
Plants

Hg
known
to
bioaccumulate
in
human
and
animal
tissue
in
most
toxic
form:
methyl
mercury

Human
exposure
associated
with
serious
neurological
and
developmental
effects

EPA
regulated
municipal
waste
combustors
(
MWCs)
and
medical
waste
incinerators
in
1990s;
controlled
more
than
40
tons

Coal­
fired
power
plants
now
major
source;
48
tons
(
1999)


On
January
30,
2004
EPA
proposed
regulations
for
power
plant
Hg
control;
presently
in
comment/
review
phase

Hg
"
white
paper,"
part
of
regulatory
docket,
summarizes
current
and
projected
state­
of­
the­
art
technologies
for
key
coal/
control
configurations
M
 
Currently
44
states
have
issue
fish
consumption
advisories
for
some
or
all
of
their
waters
due
to
contamination
from
mercury.*

States
with
Fish
Advisories
Due
to
Mercury
*
For
more
information
about
the
relationship
between
fish
advisories
and
human
exposure
to
mercury,
see
the
EPA
Report
 
America's
Children
and
the
Environment:
Measures
of
Contaminants,
Body
Burdens,

and
Illnesses 
available
at
http://
yosemite.
epa.
gov/
ochp/
o
chpweb.
nsf/
content/
publication
s.
htm
Mercury
Advisories
by
Type
Advisories
for
specific
waterbodies
only
Statewide
freshwater
advisory
only
Statewide
coastal
advisory
No
mercury
advisory
Statewide
freshwater
advisory
+

advisories
for
specific
waterbodies
Source:
EPA's
Office
of
Air
and
Radiation
Coal­
Fired
Power
Plants
 
There
are
about
530
power
plants
with
305
gigawatt
of
capacity
that
consist
of
about
1,300
units,

1,150
of
which
are
>
25
megawatt.

 
Coal
plants
generate
the
vast
majority
of
power
sector
emissions:

­
100%
of
Hg
­
95%
of
SO
2
­
90%
of
NO
X
Mercury
Emissions
from
Power
Plants
Cause
Human
Exposure
to
Mercury
Wet
and
Dry
Deposition
Emissions
Reductions
Reduce
Atmospheric
Transport
and
Deposition
Reduce
Ecosystem
Transport
and
Methylation
Reduce
Human
and
Wildlife
Exposure
Reduce
Health
Impacts
Fishing
°
commercial
°
recreational
°
subsistence
Mercury
transforms
into
methylmercury
in
soils
and
water,
then
can
bioaccumulate
in
fish
Atmospheric
deposition
Lake
methylation
Ocean
methylation
Impacts
°
Best
documented
impacts
on
the
developing
fetus:

impaired
motor
and
cognitive
skills
°
also:
cardiovascular,

immune,
and
reproductive
system
impacts
Power
Plant
Emissions
Humans
and
wildlife
affected
primarily
by
eating
contaminated
fish
°
The
primary
pathway
of
human
exposure
to
mercury
in
the
U.
S.
is
through
eating
contaminated
fish.

°
Power
plants
emit
approximately
48
tons
of
mercury
and
are
the
largest
source
of
mercury
emissions
in
the
U.
S.
(
approximately
37%)
Proposed
Regulatory
Alternatives

Regulatory
options
outlined
in
the
January
30,
2004
proposal

Section
112

Command­
and­
control
MACT
requirements

Cap­
and­
trade
approach
under
guidelines
of
section
112(
n)(
1)(
A)


Section
111

Market­
based,
cap­
and­
trade
approach

Final
rule
signed
on/
before
March
15,
2005
ORD/
NRMRL
Role
on
Hg
Control
for
Utility
Boilers

Provide
technical
support
to
OAR
on
regulatory
proposals

Source
monitoring

Technology
cost
and
performance,
including
residues

Collaborate
with
DOE
and
private
sector
on
Hg
technology
evaluation
and
demonstration

Conduct
research
on
key
issues

Lab
and
field
testing
of
CEMs

Leaching
of
Hg
from
residues

Low
cost
multipollutant
controls

International
collaboration
(
e.
g.,
UNEP,
IEA
Coal
Research)
NRMRL
Key
Combustion
Technology
Accomplishments

Key
role
in
flue
gas
desulfurization
(
FGD)

technology
development
and
commercialization;

used
for
SO2
control
worldwide

Key
role
developing
and
commercializing
low
NOX
burners
and
reburning
technologies
used
for
NOX
control
worldwide

Evaluated
FGD
waste
residues

Evaluated
carbon
injection
for
Hg
control
on
MWC's
White
Paper
°
Objective:
Respond
to
a
request
from
OAR
management
to
assess
Hg
control
technology
state­

ofthe
art.

°
Methodology:
Engineering
judgment
applied
to
critically
review
available
information.
Extensive
review
by
senior
Agency
management
(
ORD
and
OAR)
and
OMB.

°
Update
Process
Schedule:
By
late
2004/
early
2005,

update
the
paper
using
most
recent
information
available.
Major
Findings

Hg
can
be
reduced
with
existing
technology
for
NOX,

SO2,
and
PM,
but
effectiveness
varies
significantly.


By
2010,
activated
carbon
injection
(
ACI)
can
potentially
control
70­
90%
Hg
for
all
coal/
technology
configurations.*


By
2015,
90­
95%
Hg
control
is
potentially
achievable
for
all
coals
by
enhancing
existing
NOX/
SO2
technologies.*


Once
demo
is
completed,
additional
time
will
be
required
to
install/
modify
technology
to
implement
regulation.

*
Assuming
focused
RD&
D
program.
Factors
That
Influence
Mercury
Control
from
Coal­
fired
Boilers

Coal
type

Time/
temperature
profile

Flue
gas
composition
and
fly
ash
characteristics
(
carbon,
calcium,
iron,

porosity)


Air
pollution
controls
installed
Looking
Ahead
­
Coal
Use
Consumption
(
million
short
tons)
Production
(
million
short
tons)

Consumption
of
low­
sulfur
coals
in
the
power
generation
sector
is
expected
to
increase
in
the
future.

Source:
Annual
Energy
Outlook
2003
with
Projections
to
2025,
DOE/
EIA­
0383(
2003)
Looking
Ahead
 
Selective
Catalytic
Reduction
(
SCR)
and
FGD
Projections
Need
to
engage
in
focused
RD&
D
efforts
to
determine
cost­
effective
means
for
optimizing/
tweaking
these
controls.
Source:
2003
Technical
Support
Package
for
Clear
Skies
ICR
Data
 
Capture
in
Existing
Equipment
°
Higher
levels
of
Hg
capture
for
bituminous
coalfired
plants
compared
to
low­
rank
coal­
fired
plants
°
Large
ranges
of
Hg
capture
observed
°
Compared
to
electrostatic
precipitators
(
ESPs),

fabric
filters
(
FF)
capture
higher
levels
of
Hg
°
Limited
data
suggested
that
scrubbers
could
potentially
capture
oxidized
Hg
effectively
Potential
Mercury
Control
Routes

Emerging
add­
on
Hg
control

ACIs

Other
sorbents

Modify
(
tweak)
existing
control
technologies
For
Coal­
fired
Power
Plants,
What
are
Key
Configurations
Subject
to
Potential
Control?

Current:
Typical
Eastern
No
Control
Configuration
(>
65%,
1999)

Modified:
ACI­
Based
Hg
Control
Modifications
Boiler
ESP
To
Stack
Ash
To
Stack
Boiler
ESP
Ash
+
Residue
ACI
Carbon
For
Coal­
fired
Power
Plants,
What
are
Key
Configurations
Subject
to
Potential
Control?

Current:
SO
2
and
NO
X
Control
Configuration
Modified:
Hg
Control
Modifications
Boiler
Ash
NH3
ESP
To
Stack
Wet
FGD
Waste
Optimized
SCR
Oxidizer
CaCO3
Boiler
ESP
Ash
To
Stack
Wet
FGD
Waste
SCR
NH3
CaCO3
Sorbent
Injection
The
extent
of
capture
depends
on:


Sorbent
characteristics
(
particle
size
distribution,
porosity,

capacity
at
different
gas
temperatures)


Residence
time
in
the
flue
gas

Type
of
PM
control
(
FF
vs.
ESP)


Concentrations
of
SO
3
and
other
contaminants
Flue
Gas
Ash
and
Sorbent
Sorbent
Injection
ESP
or
FF
Activated
Carbon
Injection
Activated
carbon
injection
system
Activated
carbon
storage
and
feed
system
ACI
system
includes
a
sorbent
storage
silo
and
a
sorbent
injection
system.
It
may
also
include
an
added
fabric
filter
to
capture
the
carbon.
Carbon
Injection
Field
Test
Projects
ACI
for
one
9­

day
period
25­
90
0
HS­
ESP
+

COHPAC
Low­
sulfur
Bituminous
Alabama
Power
Gaston,
Unit
3
ACI
for
one
5­

day
period
65
5
CS­
ESP
Subbituminous
Wisconsin
Electric
Pleasant
Prairie,

Unit
2
ACI
for
one
4­

day
period
94
90
CS­
ESP
Low­
sulfur
Bituminous
PG&
E
Salem
Harbor,

Unit
1
ACI
for
two
5­

day
periods
94.5
90.8
Two
CS­
ESPs
in
Series
Low­
sulfur
Bituminous
PG&
E
Brayton
Point,

Unit
1
Test
Duration
ACI
Test
Results
Baseline
Particulate
Control
Coal
Test
Site
Mercury
Capture,
%

Test
Site
Information
Limitations:
Short­
term
tests,
variability
in
Hg
emissions,
impacts
on
plant
operation,
unique
test
conditions,
limited
capture
of
Hg
for
low­
rank
coal.
Hg
Removal
with
Existing
Technology

Mercuric
chloride
(
HgCl2)
is
water­
soluble
and
can
absorb
in
the
aqueous
slurry
of
a
wet
FGD
system
resulting
in
formation
of
mercuric
sulfide
(
HgS),
which
precipitates
as
sludge.


Mercury
capture
is
dependent
on
the
relative
amount
of
HgCl2
in
the
inlet
flue
gas
and
on
the
PM
control
technology
used.


ICR
data:
average
mercury
captures
ranged
from
29%
for
one
PC­
fired
ESP
plus
FGD
unit
burning
subbituminous
coal
to
98%
in
a
PC­
fired
FF
plus
FGD
unit
burning
bituminous
coal.


SCR
systems
can
enhance
capture
in
wet
FGD
on
bituminous
coal­
fired
boilers.
Need
for
Further
Evaluation

For
ACI,
longer­
term
testing
with
broader
array
of
power
plants
firing
various
coals
under
a
variety
of
operating
conditions.


Small­
and
full­
scale
testing
to
upgrade
(
tweak)

FGD
and
SCR/
FGD
systems
to
enhance
Hg
capture.


Evaluation
of
the
potential
for
leaching/

reemission
of
mercury
from
residues
resulting
from
mercury
control
applications.
RD&
D
Goals
for
Projected
Mercury
Removal
Capability
(%)

Projected
Hg
Removal
Capability
in
2010
by
the
Use
of
ACI
Projected
Hg
Removal
Capability
in
2010
by
Enhanced
Multipollutant
Controls
Projected
Hg
Removal
Capability
in
2015
by
Optimizing
Multipollutant
Controls
Control
Technology
Existing
Capacity
(
MW)
in
2003
Bitum­

inous
(
Bit)
Low­
rank
coals
Bit.
Coals
Low­
rank
coals
Bit.
Coals
Low­
rank
coals
PM
Control
Only­
ESP
153133
70
70
Not
applicable
to
tweaking
PM
Control
Only­
ESP
+

retrofit
FF
2591
90
90
Not
applicable
to
tweaking
PM
Control
Only­
FF
11018
90
90
Not
applicable
to
tweaking
PM
+
Dry
FGD
8919
Tweaking
more
favorable
90
60­
70
90­
95
90­
95
PM
+
Wet
FGD
48318
Tweaking
more
favorable
90
70­
80
90­
95
90­
95
PM
+
Wet
or
Dry
FGD
+

SCR
22586
Tweaking
more
favorable
90
70­
80
90­
95
90­
95
The
dates
above
reflect
the
time
by
which
the
demonstration
of
the
most
difficult
case
(
e.
g.,

lignite)
for
a
particular
technology
would
be
completed.
Summary
&
Conclusions

Hg
capture
with
existing
controls
depends
on
coal
and
technology
type.


ACI
not
commercially
proven
to
consistently
achieve
high
levels
of
Hg
control.


More
difficult
to
control
Hg
from
low­
rank
coal­
fired
boilers.


Hg
control
(
70­
90%)
using
ACI
for
all
coals
is
potentially
achievable
by
2010.


By
2015,
large
numbers
of
SCR
and
FGD
systems
are
expected
to
be
installed
to
control
NOx
and
SO2,
90­
95%
Hg
control
is
projected.
Summary
&
Conclusions
(
continued)


Cost­
effective
Hg
removal
expected
to
add
no
more
than
about
3
mills/
kWh
to
the
annualized
cost
of
power
production.
Tweaking
option
could
potentially
reduced
this
cost
substantially.


The
date
in
previous
table
represents
when
the
demonstration
for
the
most
difficult
case
(
e.
g.,

lignite)
will
be
completed.


Time
to
fully
deploy
such
technologies
will
depend
on
various
factors
(
regulatory
mandates,
vendor
capabilities,
and
time
for
design
and
construction).
