July
20,
2004
MEMORANDUM
From:
William
H.
Maxwell
CG/
ESD
(
C439­
01)

To:
Utility
MACT
Project
Files
Subject:
Meeting
with
Department
of
Energy,
July
20,
2004
Attendees
EPA:
Michael
O.
Leavitt
Jeffrey
Holmstead
Paul
Gilman
Jessica
Furey
Rob
Brenner
Frank
Princiotta
Don
Zinger
Ann
Johnson
Cynthia
Bergman
Stephanie
Daigle
Natalie
Gouchner
Rich
McKinnon
Chet
Thompson
Amy
Farrell
Sikander
Kahn
Ravi
Srivastava
Ellen
Brown
Robert
Wayland
Bill
Maxwell
Drew
Nelson
Chet
France
Sue
Stendebach
Rich
McKeown
Charles
Ingebretson
Peter
Nagelhout
Department
of
Energy:

Mark
Maddox
David
Hill
Doug
Carter
Tom
Feeley
Dennis
Smith
Discussion
At
the
meeting,
the
attached
materials
were
discussed.

Attachment
DOE­
NETL's
Mercury
Control
Technology
R&
D
Program
for
Coal­
Fired
Power
Plants
Meeting
with
Michael
O.
Leavitt
Administrator,

U.
S.
Environmental
Protection
Agency
July
20,
2004
Washington,
DC
Thomas
J.
Feeley,
III
thomas.
feeley@
netl.
doe.
gov
National
Energy
Technology
Laboratory
Over
a
Decade
of
DOE/
NETL
Hg
R&
D
1990
1995
2000
2005
2010
Emission
characterization/

methods
development
Lab/
bench­
scale
R&
D
Emissions
Characterization
Methods/
CEM
development
Bench­
and
pilot­
scale
R&
D
CEM
development
Emissions
characterization
Byproducts
characterization
Field
testing
Commercial
demos
Field
testing
CEM
development
Plume
chemistry
Byproducts
characterization
­
Hg
and
HAP
Reports
To
Congress
­
1990
Clean
Air
Act
Amendments
­
Hg
Regulatory
Determination
­
Proposed
Hg
Regulations
DOE/
NETL
Funding
for
Hg
R&
D
IEP
Funding
Mercury
Funding
Percentage
of
Total
Funding
Over
$
52.5
million
spent
on
mercury
R&
D
over
the
past
seven
years!

Fiscal
Year
Mercury
Funding
0
5
10
15
20
25
FY98
FY99
FY00
FY01
FY02
FY03
FY04
Million
Dollars
0
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
1
DOE­
NETL
Mercury
Control
Program
R&
D
Goals
Have
control
technologies
ready
for
commercial
demonstration:

 
Near­
term,
reduce
emissions
50­
70%

 
By
2005
for
bituminous
coal
 
By
2007
for
low­
rank
coal
 
Long­
term,
reduce
emissions
90%
by
2010
 
Cost
25­
50%
less
than
current
estimates
Baseline
Costs:
$
50,000
­
$
70,000
/
lb
Hg
Removed
2000
Year
Cost
Sorbent
Injection
DOE/
NETL
Mercury
Control
Technology
R&
D
Baghouse
or
ESP
Scrubber
Boiler
Scrubber
Enhancement/

Oxidation
Combustion/

Chemistry
Modification
Polishing
Technology
°
ACI
°
Amended
silicates
°
Halogenated
AC
°
Ca­
based
sorbents
°
Chemically
treated
sorbents
°
COHPAC/
Toxecon
 
°
Thief
sorbents
°
Cl­
based
additives
°
Combustion
modifications
°
Oxidation
catalysts
°
Reagent
addition
°
Ultraviolet
radiation
(
GP­
254)

°
Electrocatalytic
oxidation
°
SCR
oxidation
°
MerCAP
 
Plume
Chemistry
°
Transport/
speciation
Coal
combustion
byproducts
characterization
Phase
I
Field
Testing
2001­
2003
Summary
 
Activated
carbon
injection
(
ADA­
ES)

 
4
power
plant
sites
 
2
particulate
collection
systems
­
­
ESPs
(
3)
and
COHPAC
(
1)

 
2
coal
types
 
PRB
(
1)
and
bituminous
(
3)

 
Scrubber
enhancement
(
McDermott/
B&
W)

 
2
power
plant
sites
 
Both
burned
high­
S
bituminous
coal
 
1
limestone
wet
FGD,
1
magnesium­
enhanced
wet
FGD
 
Hg
capture
performance
 
ACI
works,
however 

 
Effectiveness
of
ACI
depends
on
coal
type
and
plant
configuration,

i.
e.,
ESP
vs.
baghouse
 
Wet
scrubber
size
and
chemistry
affect
re­
emission
 
Uncertainties
remain
 
Performance
over
longer
periods
of
operation
 
Effectiveness
of
chemically
modified
sorbents
 
Effectiveness
of
SCR
and
Hg­
specific
catalysts
 
Capture
effectiveness
with
low­
rank
coals
and
coal
blends
 
Sorbent
feed
rate
and
costs
 
Effectiveness
with
small
SCA
ESPs
 
Impact
on
ESP
performance
and
bag
life
 
FGD
Hg
reduction/
re­
emission
 
By­
product
use
and
disposal
 
Need
for
fabric
filter
for
units
equipped
with
ESP
Observations
From
Phase
I
Field
Tests
TJ
Feeley_
Scotland_
May
2004
DOE/
NETL
New
Phase
II,
Round
1
Mercury
Control
Field
Test
Projects
 
Eight
new
projects
selected
in
September
2003
 
Focus
on
longer­
term,

large­
scale
field
testing
 
Broad
range
of
coal­
rank
and
air
pollution
control
device
configurations
 
Sorbent
injection
&

mercury
oxidation
control
technologies
TJ
Feeley_
Scotland_
May
2004
DOE/
NETL
New
Phase
II,
Round
1
Mercury
Control
Field
Test
Projects
Project
Title
Lead
Company
Preliminary
Test
Schedule*
Host
Utility
Test
Location
Coal
Rank
PM
FGD
3/
04
­
6/
04
Sunflower
Electric
Holcomb
PRB/
Bit.
Blend
FF
SDA
8/
05
­
11/
05
Ontario
Power
Nanticoke
PRB/
Bit.
Blend
ESP
­­­

8/
04
­
11/
04
AmerenUE
Meramec
PRB
ESP
­­­

3/
05
­
6/
05
AEP
Conesville
Bit.
ESP
Wet
FGD
Amended
Silicates
for
Mercury
Control
Amended
Silicates
9/
04
­
10/
04
Cinergy
Miami
Fort
6
Bit.
ESP
­­­

Southern
Yates
1
Bit.
ESP
Wet
FGD
Southern
Yates
2
Bit.
ESP
w/

NH3/
SO3
­­­

6/
04
­
7/
05
TXU
Monticello
3
TX
Lignite
ESP
Wet
FGD
2/
05
­
3/
06
Duke
Marshall
Bit.
ESP
­­­

2/
04
­
8/
04
Great
River
Energy
Stanton
10
ND
Lignite
FF
SDA
1/
05
­
6/
05
Southern
Yates
1
Bit.
ESP
Wet
FGD
4/
04
­
6/
04
Basin
Electric
Leland
Olds
1
ND
Lignite
ESP
­­­

9/
04
­
10/
04
Great
River
Energy
Stanton
10
ND
Lignite
FF
SDA
4/
05
­
6/
05
Basin
Electric
Antelope
Valley
1
ND
Lignite
FF
SDA
4/
04
­
5/
04
Great
River
Energy
Stanton
1
ND
Lignite
ESP
­­­

6/
05
­
8/
05
Minnkota
Power
Milton
R.
Young
2
ND
Lignite
ESP
Wet
FGD
8/
05
­
9/
05
TXU
Monticello
3
TX
Lignite
ESP
Wet
FGD
1/
05
­
4/
05
Duke
Buck
Bit.
Hot
ESP
­­­

6/
04
­
9/
04
Detroit
Edison
St.
Clair
Bit./
PRB
blend
ESP
­­­

3/
04
&
9/
04
­

10/
04
Advanced
Utility
Mercury­
Sorbent
Field­
Testing
Program
Sorbent
Technolgies
Enhancing
Carbon
Reactivity
in
Mercury
Control
in
Lignite­
Fired
Systems
UNDEERC
Mercury
Oxidation
Upstream
of
an
ESP
and
Wet
FGD
UNDEERC
Pilot
Testing
of
Mercury
Oxidation
Catalysts
for
Upstream
of
Wet
FGD
Systems
URS
Group
Evaluation
of
MerCAP
for
Power
Plant
Mercury
Control
URS
Group
Evaluation
of
Sorbent
Injection
for
Mercury
Control
ADA­
ES
Sorbent
Injection
for
Small
ESP
Mercury
Control
URS
Group
*
These
are
preliminary
test
schedules
subject
to
change
based
on
plant
availability.
TJ
Feeley_
Scotland_
May
2004
Phase
II
Hg
Field
Testing
Program
FF/
SDA,
ESP/
wet
FGD
ND
lignite,
bituminous
2
Fixed
structure
gold
sorbent
ESP/
wet
FGD
ND
lignite,
TX
lignite
2
Chlorine
injection
HSESP,
ESP
Bit.,
bit/
PRB
blend
2
Halogenated
ACI
ESP,
FF/
SDA
ND
lignite
4
Chemical
inject.
w/
ACI,

chem.
mod.
ACI
ESP,
ESP/
wet
FGD
TX
lignite,
bituminous
2
Oxidation
catalyst
ESP
Bituminous
1
Amended
silicates
FF,
ESP,
ESP
w/

NH3/
SO3
injection
PRB,
Bit.,

PRB/
Bit.
blend
5
Activated
carbon
injection
(
ACI)
Downstream
Control
Equipment
Coal
Types
Host
Sites
Hg
Control
Approach
TJ
Feeley_
Scotland_
May
2004
Phase
II
Field
Testing
Long­
Term
Test
Schedule
Sorbent
Injection
ADA­
ES
Amended
Silicates
Amended
Silicates
Sorbent
Injection
URS
Group
Mercury
Oxidation
Catalysts
For
Upstream
of
Wet
FGD
URS
Group
Evaluation
of
MerCAP
URS
Group
Enhancing
Carbon
Reactivity
In
Lignite­
Fired
Sytems
UNDEERC
Mercury
Oxidation
Upstream
Of
an
ESP
and
Wet
FGD
UNDEERC
Mercury­
Sorbent
Field­
Testing
Sorbent
Technologies
2004
Feb.
Mar.
Apr.
Jun.
Jul.
Aug.
Oct.
Nov.
Dec.
Feb
Mar.
Jun.
Jul.
Oct.
Nov.
Dec.
Feb.
Mar.
Apr.
Jun.

Aug.

Aor.
2005
2006
Jan.

04
May
Sept.
Jan.
May.
Sept.
Jan.
May
Holcomb
Nanticoke
Meramac
Conesville
Miami
Fort
6
Yates
1
Yates
2
Monticello
3
Marshall
Stanton
10
Yates
1
Leland
Olds
1
Antelope
Valley1
Stanton
10
Milton
R.
Young
2
Monticello
3
Buck
St.
Clair
Stanton
1
TJ
Feeley_
Scotland_
May
2004
DOE/
NETL
New
Phase
II,
Round
2
Mercury
Control
Field
Test
Projects
 
Proposals
due
by
end
of
April
2004
 
Focus
on
technologies
for
plants
that
burn
low­
rank
coal
 
Powder
River
Basin
 
Texas
Lignite
 
Coal
blends
TJ
Feeley_
Scotland_
May
2004
Toxecon
 
Retrofit
for
Mercury
and
Multi­

Pollutant
Control
 
CCPI
Demonstration
Project
 
Demonstrate:

 
Multi­
pollutant
control
with
PRB
coal
 
90%
Hg
reduction
 
70%
SO2
reduction
 
30%
NOx
reduction
 
Hg
recovery
from
sorbent
 
Hg
CEM
performance
We
Energies
Presque
Isle
Power
Plant
Challenges
to
Increased
CUB
Utilization
 
Future
air
pollution
regulations,

e.
g.,
Hg
MACT/
Cap­
and­
Trade
 
Increase
volume
of
coal
utilization
by­
products
 
Change
characteristics
(
i.
e.,

quality)
of
by­
products
 
NETL
sponsoring
research
to
assess
fate
of
Hg
and
other
trace
elements
in
byproducts
from
Hg
field
testing
projects
Fly
Ash
FGD
Byproduct
Mercury
Hazardous
Waste
Designation
of
All
By­
products
Could
Cost
$
11
Billion
/
Year
 
Future
solid
waste
regulations
under
RCRA?

 
Limit
use
applications
 
Regulate
coal
utilization
by­
products
as
hazardous
 
Public
perception
Summary
of
Future
Plans
 
Continue
Phase
II
field
testing
of
technology
capable
of
achieving
50­
70%
Hg
removal
through
FY06
 
Carry
out
field
testing
of
technologies
capable
of
achieving
+
90%
Hg
capture
starting
in
FY06­
07
 
Commercially
demonstrate
promising
Hg
technologies
selected
under
DOE's
Clean
Coal
Power
Initiative
 
Continue
characterization
of
byproducts
from
Hg
field
testing
projects
 
Assess
economics
of
Hg
control
technologies
based
on
results
of
field
testing
 
Evaluate
promising
pre­
combustion
Hg
removal
technology
DOE/
NETL
Environmental
and
Water
Resources
(
Innovations
for
Existing
Plants
Program)

To
find
out
more
about
DOE­
NETL's
Hg
R&
D
activities
visit
us
at:

www.
netl.
doe.
gov/
coalpower/
environment
Additional
Information
Mercury
Field
Testing
2001­
02
ADA­
ES
 
Sorbent
Injection
Alabama
Power
 
Gaston
We
Energies
 
Pleasant
Prairie
PG&
E
 
Brayton
Point
PG&
E
 
Salem
Harbor
McDermott­
B&
W
 
Enhanced
Scrubbing
Michigan
South
Central
Power
 
Endicott
Cinergy
 
Zimmer
April
2001
November
2001
August
2002
November
2002
October
2001
November
2001
Technology
/
Utility
Plant
Test
Completion
ADA­
ES
Phase
I
Field
Test
Results
Activated
Carbon
Injection
Brayton
Point:

Bituminous
coal,
ESP
Pleasant
Prairie:

Subbituminous
coal,
ESP
Gaston:
Bituminous
coal,

ESP
+
fabric
filter
0
20
40
60
80
100
0
5
10
15
20
25
30
Injection
Concentration
(
lb
/
MMacf)

Mercury
Removal
(%)
Gaston,
Pleasant
Prairie,
and
Brayton
Point
test
data
from
ADA­
ES
presentation
at
August
2002
EPA
Utility
MACT
Working
Group
meeting.

Salem
Harbor
test
data
from
ADA­
ES
technical
paper
"
Results
of
Activated
Carbon
Injection
Upstream
of
ESP
for
Mercury
Control"
presented
at
May
2003
Mega
Symposium.

Salem
Harbor:

Bituminous
coal,
ESP
(
gas
temp.
at
280­
290
°
F)
McDermott
Technology
and
B&
W
Enhanced
Mercury
Control
in
Wet
FGD
Michigan
South
Central
Power's
Endicott
Plant
 
60
MW
 
High­
sulfur
bituminous
coal
 
ESP
 
Limestone
wet
FGD
Cinergy's
Zimmer
Plant
 
1300
MW
 
High­
sulfur
bituminous
coal
 
ESP
 
Magnesium­
enhanced
wet
FGD
McDermott
Technology
and
B&
W
Phase
I
Enhanced
Mercury
Control
in
Wet
FGD
76%

~
60%

Total
20%

~
(
40%)

Elemental
93%

~
90%

Oxidized
Reagent*

Baseline
Mercury
Species
MSCP's
Endicott
Plant
*
Reagent
feed
results
during
two­
week
verification
testing.

Wet
FGD
Mercury
Removal,%
51%

~
45%

Total
(
41%)

~
(
20%)

Elemental
87%

~
90%

Oxidized
Reagent*

Baseline
Mercury
Species
Cinergy's
Zimmer
Plant
TJ
Feeley
Feb.
2004
Mercury
Control
Using
ACI
Preliminary
Cost
Estimate
Without
lost
ash
sales
penalty
Levelized
Cost
90%
w/
COHPAC
70%

50%

Mercury
Removal,%
With
lost
ash
sales
penalty***
2.15
1.27
0.37
Mills/
kWh
49,000
46,100
32,700
$/
lb
mercury
removed**
2.15
3.69
2.79
Mills/
kWh
49,000
133,800
245,700
$/
lb
mercury
removed**
Activated
Carbon
Injection
System
for
500
MW
Bituminous
Coal­
Fired
Plant*

*
Plant
equipped
with
cold­
side
ESP
**
Incremental
cost
excluding
co­
benefit
ESP
mercury
capture
(
36%)

***
Penalty
includes
lost
sales
revenue
($
18/
ton)
and
ash
disposal
cost
($
17/
ton).

Note:
mills
equal
to
one
tenth
of
a
cent.
 
Apogee
Scientific
 
Advanced
novel
sorbent
testing
at
Midwest
Generation's
Powerton
Plant
and
We
Energies'
Valley
Plant
 
CONSOL
 
Evaluate
effect
of
lowering
flue
gas
temperature
on
Hg
capture
with
ESP
at
Allegheny
Energy's
Mitchell
Power
Station
 
UNDEERC
 
Sorbent
injection
testing
with
Advanced
Hybrid
Particulate
Collector
(
AHPC)
at
Otter
Tail
Power's
Big
Stone
Plant
Mercury
Pilot­
Scale
Testing
Projects
Conducted
in
2001­
03
 
Powerspan
 
Multi­
pollutant
control
for
Hg,
SO2,

NOx,
particulates,
and
acid
gases
using
electro­
catalytic
oxidation
(
ECO)
at
FirstEnergy's
R.
E.
Burger
Plant
 
Southern
Research
Institute
 
Evaluate
calcium­
based
sorbents,

oxidation
additives,
and
coal
blending
 
URS
Group
 
Evaluate
fixed­
bed
oxidation
catalysts
at
Great
River
Energy's
Coal
Creek
Station
and
City
Public
Service
of
San
Antonio's
J.
K.

Spruce
Plant
Designed
to
Achieve
 
90%
Hg
Removal
 
ADA­
ES
 
Long­
term,
full­
scale
sorbent
injection
test
on
the
COHPAC
at
Southern's
E.
C.
Gaston
Plant
 
General
Electric
Energy
and
Environmental
Research
Corp
 
Evaluate
OFA
and
coal
reburn
to
optimize
mercury
removal
with
an
ESP
at
Western
Kentucky
Energy's
Green
Power
Station
 
CONSOL
 
Mercury
speciation
field
testing
at
several
plants
equipped
with
both
SCR
and
wet
FGD
Additional
Field­
and
Pilot­
Scale
Testing
Projects
Initiated
in
2003
 
Reaction
Engineering
 
Pilot­
scale
mercury
oxidation
test
for
several
NOx
SCR
catalysts
at
AEP's
Rockport
Power
Plant
which
burns
PRB
coal
 
UNDEERC
 
Laboratory
and
field
testing
of
the
potential
release
of
mercury
and
other
air
toxics
from
coal
utilization
by­
products
Long­
term
Testing
at
Gaston
Station
0
10
20
30
40
50
60
70
80
90
100
7/
20/
03
8/
3/
03
8/
17/
03
8/
31/
03
9/
14/
03
9/
28/
03
10/
12/
03
10/
26/
03
11/
9/
03
Date
Mercury
Removal
(%)
0
5
10
15
20
25
Mercury
Concentration
(

µ
g/

m
3)

Mercury
Removal
(%)

Inlet
Mercury
Concentration
Outlet
Mercury
Concentration
 
Average
Hg
Removal
 
86
%

 
Average
Inlet
Concentration
 
14
µ
g/
m3
 
Average
Outlet
Concentration
 
2
µ
g/
m3
Average
Weekly
Data
from
S­
CEM
Measurements
TJ
Feeley_
Scotland_
May
2004
Evaluation
of
Sorbent
Injection
for
Mercury
Control
­
ADA­
ES
 
Sunflower
Electric's
Holcomb
Station
PRB/
Bit
coal
blend
and
equipped
with
SDA/
FF
 
Ontario
Power's
Nanticoke
Station
PRB/
Bit
coal
blend
and
equipped
with
ESP
 
AmerenUE's
Meramec
Station
PRB
and
equipped
with
ESP
 
AEP's
Conesville
Station
Bituminous
coal
and
equipped
with
ESP
and
wet
FGD
 
Evaluate
full
scale
sorbent
injection
with
existing
pollutioncontrol
equipment
at
four
plants
TJ
Feeley_
Scotland_
May
2004
Amended
Silicates
for
Mercury
Control
­

Amended
Silicates,
LLC
 
Joint
venture
of
ADA
Technologies
and
CH2M
Hill
 
Evaluate
a
new
non­
carbon
sorbent
­
Amended
SilicatesTM
 
Avoid
impact
on
fly
ash
sales
 
Full­
scale
testing
at
Cinergy's
Miami
Fort
Unit
6
 
Burns
bituminous
coal
and
equipped
with
ESP
TJ
Feeley_
Scotland_
May
2004
Sorbent
Injection
for
Small
ESP
Mercury
Control
­
URS
Group
 
Evaluate
sorbents
injected
upstream
of
ESP
with
small
specific
collection
area
(
SCA)

 
Full­
scale
testing
at
Southern
Company
Services'
Plant
Yates
Unit
1
&
2
 
Burns
bituminous
coal
 
Unit
1
equipped
with
ESP
and
wet
FGD
 
Unit
2
equipped
with
ESP
and
NH
3/
SO
3
conditioning
TJ
Feeley_
Scotland_
May
2004
Pilot
Testing
of
Mercury
Oxidation
Catalysts
for
Upstream
of
Wet
FGD
Systems
­
URS
Group
 
Evaluate
honeycomb
catalyst
system
for
oxidizing
elemental
mercury
to
enhance
Hg
removal
in
downstream
wet
lime
or
limestone
FGD
systems
 
Testing
at
two
plants
equipped
with
ESP
and
wet
FGD
 
TXU
Monticello
Unit
3
 
Burns
Texas
lignite
 
Duke
Energy's
Marshall
Station
 
Burns
low­
sulfur
bituminous
coal
TJ
Feeley_
Scotland_
May
2004
Evaluation
of
MerCAP
for
Power
Plant
Mercury
Control
­
URS
Group
 
Evaluate
EPRI's
Mercury
Control
via
Adsorption
Process
(
MerCAPTM)
technology
 
Regenerable,
gold­
coated
fixed­
structure
sorbent
 
Great
River
Energy's
Stanton
Unit
10
 
Burns
ND
lignite
coal
and
equipped
with
SDA/
FF
(
Full­
scale
at
6
MW
equivalent)

 
Southern's
Plant
Yates
Unit
1
 
Burns
bituminous
coal
and
equipped
with
ESP
and
wet
FGD
(
Pilot­
scale
at
1
MW)
TJ
Feeley_
Scotland_
May
2004
Enhancing
Carbon
Reactivity
in
Mercury
Control
in
Lignite­
Fired
Systems
­
UNDEERC
 
Basin
Electric's
Leland
Olds
Station
Unit
1
 
Equipped
with
ESP
 
Basin
Electric's
Antelope
Valley
Station
Unit
1
 
Equipped
with
SDA/
FF
 
Great
River
Energy's
Stanton
Station
Unit
1
 
Equipped
with
ESP
 
Great
River
Energy's
Stanton
Station
Unit
10
 
Equipped
with
SDA/
FF
 
Enhance
effectiveness
of
activated
carbon
injection
at
four
plants
burning
low­
rank
North
Dakota
lignite
 
Use
of
chlorine­
based
additive
to
coal
and
activated
carbon
sorbent
 
Use
of
chemically
treated
sorbents
TJ
Feeley_
Scotland_
May
2004
Mercury
Oxidation
Upstream
of
an
ESP
and
Wet
FGD
­
UNDEERC
 
Minnkota
Power
Cooperative's
Milton
R.
Young
Unit
2
 
Burns
ND
lignite
 
TXU
Monticello
Unit
3
 
Burns
TX
lignite
 
Evaluate
chloride­
based
additive
to
increase
mercury
oxidation
upstream
of
ESP
and
wet
scrubber
 
Full­
scale
testing
at
two
plants
burning
lignite
coal
and
equipped
with
both
ESP
and
wet
FGD
TJ
Feeley_
Scotland_
May
2004
Advanced
Utility
Mercury
Sorbent
Field­
Testing
­
Sorbent
Technologies
 
Evaluate
new
halogenated
activated
carbon
sorbent
in
fullscale
testing
at
two
plants
 
Duke
Energy's
Buck
or
Allen
Station
 
Burn
bituminous
coal
 
Hot­
side
ESP
at
Buck
 
Cold­
side
ESP
at
Allen
 
Detroit
Edison's
St.
Clair
Station
 
Burns
mixture
of
bituminous
and
subbituminous
coal
and
equipped
with
cold­
side
ESP
TJ
Feeley_
Scotland_
May
2004
DOE/
NETL
New
Phase
II,
Round
2
Mercury
Control
Field
Test
Projects
 
Proposals
due
by
end
of
April
2004
 
Focus
on
technologies
for
plants
that
burn
lowrank
coal
 
Powder
River
Basin
 
Texas
Lignite
 
Coal
blends
TJ
Feeley_
Scotland_
May
2004
TOXECON
 
Configuration
TOXECON
 
N
Coal
Electrostatic
Precipitator
Sorbent
Injection
PJFF
Fly
Ash
(
1%)
+
PAC
Fly
Ash
(
99%)
NETL
External
Projects
Addressing
the
Environmental
Characterization
of
CUBs
 
Fate
of
mercury
from
control
technology
field
demonstrations
 
ADA­
ES
and
Reaction
Engineering
 
B&
W
and
McDermott
Technology
 
Trace
element
leaching
from
CUB
disposal
and
utilization
applications
 
CONSOL
Energy
 
University
of
North
Dakota
Energy
&
Environmental
Research
Center
(
UNDEERC)

 
Electric
Power
Research
Institute
(
EPRI)

 
Fate
of
mercury
in
synthetic
gypsum
used
for
wallboard
production
 
US
Gypsum
Mercury
Technologies
Doug
Carter
USDOE/
FE
July
20,
2004
Overview
 
Cobenefits
 
ACI
 
Other
advanced
controls
 
Commercial
availability
 
DOE
position
 
Vendor
positions
 
Other
issues
 
Technology
&
the
form
of
the
rule
 
Data
quality
issues
 
Coal
rank
&
regional
issues
 
Regulatory
options
0%

25%

90%

22%

51%

HS­
ESP/
SCR/
FGD
0%

15%

40%

0%

­
2%

50%

HS­
ESP/
FGD­
Dry
0%

20%

42%

22%

47%

HS­
ESP/
FGD
0%

6%

10%

0%

2%

9%

HS­
ESP
44%

85%

90%

36%

78%

98%

FF/
SCR/
FGD
0%

25%

95%

­
2%

24%

98%

FF/
FGD­
Dry
0%

73%

97%

36%

78%

97%

FF/
FGD
0%

73%

89%

72%

90%

FF
44%

66%

90%

42%

29%

82%

CS­
ESP/
SCR/
FGD
0%

35%

36%

0%

­
4%

45%

CS­
ESP/
FGD­
Dry
44%

16%

66%

42%

29%

78%

CS­
ESP/
FGD
0%

3%

36%

­
4%

3%

36%

CS­
ESP
Lig
Rem
Sub
Rem
Bit
Rem
Lig
Rem
Sub
Rem
Bit
Rem
Control
System
EPA's
IPM
(
May
2003)

DOE
Analysis
Mercury
Co­
benefit
Performance
1.
DOE
generally
agrees
w/
EPA's
assessment
of
average
ICR­
3
values.

2.
These
values
should
not
be
used
for
evaluating
a
MACT
standard.
70%

70%

80%

HS­
ESP
70%

80%

No
ACI
needed
FF
(
no
additional
FF
required)
70%

77%

No
ACI
needed
FF/
FGD­
Dry
(
no
additional
FF)
70%

70%

89%

CS­
ESP/
FGD­
Dry
83%

79%

88%

HS­
ESP/
FGD
70%

70%

80%

CS­
ESP
Lig
Rem
Sub
Rem
Bit
Rem
ACI/
COHPAC
+
Conventional
Control
DOE
Estimate
for
Performance
Potential
with
ACI
ACI
Potential
using
COHPAC
Design
(
2018)

Bituminous
coal
performance
based
on
short­
term
COHPAC
testing
(
A/
C
Ratio
=
6)

Subbituminous
performance
based
on
COHPAC
injection
rate
limitations
Lignite
performance
based
on
full­
scale
baghouse
with
carbon
injection
(
A/
C
Ratio
=
2)

Compared
to
EPA,
DOE/
FE
projects
lower
performance
for
ACI,
even
though
larger
Fabric
Filters
are
assumed
by
DOE.
These
projections
would
not
preclude
meeting
15tpy,
but
would
impact
costs
and
number
of
retrofits.
Distribution
of
ESP
Specific
Collection
Area
0
100
200
300
400
500
600
700
800
900
1000
1100
1200
0
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
1
Cumulative
Fraction
of
Units
Design
SCA,

ft2/

kacfm
Cumulative
Number
Installations
Cumulative
Volume
Flue
Gas
Pleasant
Prairie
Brayton
Point
Salem
Harbor
ESP
units
tested
with
ACI
have
larger
than
average
ESP's.
Smaller
ESP's
would
probably
collect
less
mercury,

and
ACI
could
degrade
collection
of
PM.
Phase
II
ESP/
ACI
tests
Non­
COHPAC
ACI
ACI
Issues
 
Only
one
"
long"
term
test
 
Potential
oxidation
of
SO2
to
SO3
by
activated
carbon,
with
corrosion
impacts.

 
Unknown
impacts
by
additives
needed
to
facilitate
sorption
with
low
chlorine
(
low
rank)

coals.

 
ESP
concerns
 
Representative
data
(
current
tests
are
for
relatively
large
ESPs)

 
Potential
arcing
on
ESP
systems
 
Waste
contamination
by
carbon
 
cost
issue
relevant
to
safety
valves
Other
Advanced
Controls
 
Mercury
oxidizers
(
aka,
scrubber
helpers)

 
Convert
elemental
mercury
to
oxidized
mercury,

which
is
water
soluble
and
can
be
captured
by
a
wet­
FGD.

 
Catalytic,
chemical,
energy
(
corona)
based
 
Have
shown
promise.
Should
be
relatively
low
in
cost,
but
may
be
foreclosed
by
early
reduction
requirements.
Note:
Bit
coal
has
7%
Hg0.

 
Novel
ideas
 
Coal
preparation
concepts
(
heat
coal
to
drive
off
Hg)

 
Coal
blending
(
to
contribute
chlorine
to
low
rank
coals)
Commercial
Availability
 
Cobenefit
technologies
are
commercially
available.

 
For
ACI,
we
are
already
into
large
scale
testing,
to
establish
operating
parameters
for
commercial
demonstration
 
Other
technologies
are
1­
2
years
behind
ACI
 
Jan
8,
2004
memo
to
Bill
Maxwell,
Docket
#
0043
Bench
R&
D:

2­
4
years
Large
scale
testing:

1
year
Commercial
demonstration:

6
years
50­
70%
tech's:
2005
90%
technologies:
2007
Commercial
Installation:

2
years
Compliance:
2013
­
2015
Stakeholder
Views
 
Alstom
(
Quotes
from
11/
25/
03
letter
to
Sen.
Jeffords)

 
New
sorbent
injection
systems
and
dedicated
FF
for
control
of
mercury
are
currently
being
offered
 
at
a
capital
cost
of
$
20­
35/
kw.

 
ALSTOM
ECS'
technology
for
mercury
control
is
being
offered
commercially
in
the
marketplace
today
for
all
applications
and
coals.

 
ALSTOM
ECS
will
guarantee
a
given
emission
for
a
specified
range
of
coals
having
specified
mercury
content.

 
Sorbent
Technologies
(
Sid
Nelson,
Quoted
in
7/
18/
04
Air
Daily
article)

 
If
you
regulate
it,
the
[
controls]
will
be
there.

 
TXU
(
Quotes
from
6/
29/
04
comments
on
Hg
NPR.)

 
TXU
sent
requests
for
information
to
three
control
equipment
vendors
asking
what
type
of
mercury
control
they
would
propose
to
install
on
our
Big
Brown
Unit
1,
what
percentage
of
total
mercury
removal
they
would
predict,
what
removal
percentage
they
would
guarantee
and
what
conditions
they
would
place
on
the
guarantee.

 
None
of
the
vendors
would
offer
a
guarantee
due
mostly
to
operational
issues
associated
with
lignite
units
in
addition
to
the
coal
properties
of
lignite.
Stakeholders
(
cont'd)

 
Southern
Company
(
L.
Monroe,
6­
28­
04
Conference
Paper)

 
Moreover,
there
are
unresolved
issues
regarding
the
widespread
applicability
of
this
technology
[
ACI]
to
the
rest
of
the
industry.

 
There
are
potential
corrosion
effects
that
may
occur
with
the
injection
of
carbon,
and
the
wear
and
tear
from
the
extra
cleaning
cycles
due
to
the
carbon
addition
must
be
evaluated.

 
Baghouses
have
not
been
traditionally
used
in
higher
sulfur
coal
applications
because
of
short
bag
life
due
to
corrosion
and
bag
blinding .

 
Additionally,
most
experts
in
the
field
believe
that
baghouses
may
suffer
similar
bag
blinding
and
corrosion
at
sites
where
ammonia
(
in
SCRs
or
SNCRs)
is
used
for
NOx
control.

 
Industry
needs
more
DOE
support
for
more
testing
and
a
timetable
that
allows
until
late
2008
to
complete
the
testing
and
performance
evaluation
of
the
existing
technology
set
for
mercury
control.
Following
that
testing
period,
the
installation
phase
should
last
well
into
2015.
This
is
the
earliest
time
by
which
the
industry
could
comply
with
some
reasonable
mercury
regulation.

 
Vendor
warranties
on
processes
for
the
utility
industry
are
generally
weak.
Vendor
warranties
on
emission
control
processes
are
narrowly
defined,
usually
with
unrealistically
low
damage
caps
on
liquidated
damages.
Stakeholders
(
cont'd)

 
Peabody
(
4­
30­
04
comments)

 
Peabody
solicited
replies
from
several
engineering­

procurementconstruction
firms
and
from
air
pollution
control
vendors.
The
highest
guaranteed
removal
rate
PE
has
obtained 
is
a
heavily
qualified
80%....

[
For
a
new
source
burning
Bit
coal.]

 
EPRI
(
6­
16­
04
comments)

 
Mercury
control
technologies
are
not
yet
commercially
available.

 
In
most
cases
[
for
sorbent
injection],
we
have
data
for
just
one
site
for
any
given
fuel,
so
we
do
not
know
if
each
line
[
in
a
performance
chart
of
4
units]
is
unique
or
representative
of
that
class
of
fuel.

 
Recent
data
(
not
yet
published)
from
a
site
with
two
boilers
burning
a
lowsulfur
eastern
bituminous
coal
and
equipped
with
a
small
ESP
showed
much
lower
mercury
removals
with
sorbent
injection
than
measured
at
the
LSEB
site
(
large
ESP).
Further,
the
ESPs
at
this
site
experienced
severe
arcing
under
certain
circumstances
with
sorbent
injection.

 
Activated
carbon
can
oxidize
SO2
to
SO3,
which
can
then
react
with
water
to
form
sulfuric
acid
leading
to
the
potential
for
corrosion
wherever
the
acid­
laden
carbon
deposits
on
a
surface.
Other
Issues
Technology
&
The
Form
of
the
Rule
 
112(
d)

 
3
year
compliance
eliminates
advanced
technologies
 
Lack
of
trading
means
modeling
must
assume
much
lower
performance
from
cobenefit
technologies
 
"
Best
5"
floors
may
not
be
achievable.
Top
5
are
based
on
low
Hg
coals
(
no
PRB
fired
units,
but
PRB
is
82%
of
Subbituminous
use;
no
TX
lignite
in
lignite
T5)

 
New
source
limits
w/
o
advanced
technology
means
major
portions
of
coal
reserves
cannot
be
used
 
Future
coal
based:
expect
substantial
coal
switching
away
from
Bit.

 
111(
d)

 
Reconcile
phased
compliance
with
"
adequately
demonstrated"

 
If
C&
T
is
reversed,
what
is
"
best
technology"?

 
Ditto
new
source
comment
 
112(
n)

 
Risk
does
not
directly
relate
to
control
technology
 
Best
option
for
time­
phased
regulation
 
Cap&
Trade
minimizes
emissions
vs.
Multi­
option
compliance
if
C&
T
is
not
permissible.

 
Ditto
new
source
comment
Data
Quality
 
ASTM
Method
D
3684
is
suspect
w/
Lignite.
TXU
projects
that
their
coals
are
twice
as
high
(#
Hg/
TBtu)
as
they
reported
in
ICR­
2
data.

 
>
20%
of
ICR­
3
data
show
"
negative"
Hg
reductions.

 
Several
ICR­
3
coals
are
cleaner
than
any
ICR­
2
coal
test
for
the
unit.

 
Extensive
data
quality
issues
raised
by
NMA
analysis
(
5­
14­
04
comments).

 
The
wide
range
in
the
performance
values
and
uncertainties
 
indicate
that
the
3­
test
database
is
unlikely
to
be
adequate
for
supporting
standards
development
with
an
acceptable
level
of
statistical
confidence.
[
Statistical
Analysis
of
of
Mercury
Emission
Rate
Database
(
ICR­
3),
AEMS,
2­
1­
02.]
Cited
in
UMWA
comments.
Mercury
in
Coal
0.00
0.01
0.02
0.03
0.04
0.05
0.06
0.07
0.08
11/
01/
98
12/
21/
98
02/
09/
99
03/
31/
99
05/
20/
99
07/
09/
99
08/
28/
99
10/
17/
99
12/
06/
99
01/
25/
00
Date
Mercury,

ppm
(

dry)
ICR
Coal­
Valmont
Coal
w/
Stack
Testing
­
Valmont
5
per.
Mov.
Avg.
(
ICR
Coal­
Valmont)
Mercury
in
Coal
0.00
0.02
0.04
0.06
0.08
0.10
0.12
0.14
11/
01/
98
12/
21/
98
02/
09/
99
03/
31/
99
05/
20/
99
07/
09/
99
08/
28/
99
10/
17/
99
12/
06/
99
01/
25/
00
Date
Mercury,

ppm
(

dry)
ICR
Coal­
Salem
Harbor
Coal
w/
Stack
Testing
­
Salem
Harbor
5
per.
Mov.
Avg.
(
ICR
Coal­
Salem
Harbor)
Mercury
Concentration
in
Lignite
Power
Plants
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%

100%
0
5
10
15
20
25
30
35
Mercury
in
Coal,
lb/
TBtu
Cumulative
%

of
Units
less
than
Lignite
­
ND/
MT
Lignite
­
Gulf
Coast
Based
on
ICR­
2
data,
TX
lignite
is
much
higher
in
mercury
content
than
ND/
MT
lignites.

USGS
"
CoalQual"
database
agrees;

average
#
Hg/
TBtu
is
twice
as
high
for
TX.
Variability
of
Mercury
in
US
Coal
(
From
USGS
CoalQual)

X
=
Average
Hg/
TBtu
n
=
Number
of
samples
Coal
Rank:
Basic
MACT
Issues
 
Bituminous
coal
 
3
of
"
best
4"
are
highly
atypical
of
bituminous
coal
burners
 
Stockton
1
is
a
55
MW
FBC
unit;
burns
mixture
of
Western
Bit,
pet
coke,

and
tires.

 
Dwayne
Collier
2B
is
a
traveling
grate
stoker.

 
Valmont
5
burns
Western
Bit.
Test
coal
is
cleaner
than
any
other
tested
deliveries
for
the
year.

 
Mecklenburg
1
is
OK,
but
would
lead
to
a
much
higher
MACT
limit
 
Subbituminous
coal
 
None
of
the
top
4
uses
PRB
coal.
PRB
=
82%
of
US
subbituminous
coal.

AESHawaii
is
an
AFB
burning
Indonesian
coal
 
Lignite
 
Top
5
are
all
ND
lignite
 
much
lower
in
Hg
than
TX
lignite
(
2/
3
of
US
lignite
use).

RM
Heskitt
2
is
a
FBC
boiler.

 
General
 
High
sulfur
coal
and/
or
SCR
may
preclude
use
of
FF's
due
to
bag
blinding
and
corrosion
of
BOP.

 
Should
subcategorize
for
AFB
&
Stokers
 
"
Future
fuel"
basis
tends
to
encourage
switching
away
from
Bit.
Average
Coal
Mercury,
by
Rank
­
5
10
15
20
25
30
35
40
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%

Percent
of
All
Plants
Mercury,

#/

TBtu
Bituminous
Subbituminous
Lignite
[
Annual
average
of
all
1999
coal
deliveries,
by
plant,
based
on
EPA
ICR­
2
data.]

Proposed
New
Source
Rates
Bit
0.6
#
Hg/
TBtu
Sub
2.0
#
Hg/
TBtu
Lig
6.3
#
Hg/
TBtu
35
90
97
Fraction
of
coal
that
cannot
meet
new
source
limits
With
existing
technology
(
cobenefits)

With
ACI
added.
35
6
7
New
Source
Compliance
Issues
