### EPA/600/R-10/006 February 2010



### Control of Mercury Emissi ons from Coal Fired El ectric Utility Boilers: An Update

by

Ravi Strivastava Air Pollution Preventi on and Control Division National Risk Management Research Laboratory Research Triangle Park, NC 27711

National Risk Management Research Laboratory Office of Research and Development U.S. Environmental Protection Agency Cincinnati, Ohio 45268Glossary of Terms

ACI Activated Carbon Injection APC Air Pollution Control APPCD Air Pollution Preven tion and Control Division B-PAC Brominated Powdered Activated Carbon (product name from Sorbent Technologies Corp, Twinsburg, OH) CFD Computational Fluid Dynamics CS-ESP Cold-side Electrostatic Precipitator DOE United States Department of Energy EPA United States Environmental Protection Agency EPRI Electric Power Research Institute ESP Electrostatic Precipitator E-3 Product name of Norit Americas’ ha logenated powdered activated carbon FF Fabric Filter (baghouse) FGD Flue Gas Desulfurization FGD (Norit) Norit FGD is the product name for an activated carbon produced by Norit Americas HS-ESP Hot-side Electrostatic Precipitator ICR Information Collection Request L/G Liquid-to-Gas ratio LSFO Limestone Forced Oxidation scrubber MEL Magnesium Enhanced Lime scrubber NETL National Energy Technology Laboratory NOx Nitrogen Oxides ORD Office of Research and Development PAC Powdered Activated Carbon PJFF Pulse Jet Fabric Filter PM Particulate Matter PPPP Pleasant Prairie Power Plant PRB Subbituminous coal mined in Wyoming’s Powder River Basin PS Particulate Scrubber R&D Research and Development RD&D Research, Development, and Demonstration SCA Specific Collection Area SCR Selective Catalytic Reduction SDA Spray Dryer Absorber SDA/FF Spray Dryer Absorber with downstream Fabric Filter SEA Sorbent Enhanced Additive STS Sodium Tetrasulfide TBD To Be Determined UBC Unburned Carbon

2

### Control of Mercury Emissions from Coal Fired Electric Utility Boilers: An Update

Air Pollution Prevention and Control Division National Risk Management Research Laboratory Office of Research and Development U.S. Environmental Protection Agency Research Triangle Park, NC February 18, 2005

INTRODUCTION

Coal-fired power plants in the U.S. are known to be the major anthropogenic source of domestic mercury emissions. 1 The Environmental Protection Agency (EPA) has recently proposed to reduce emissions of mercury from these plants. 2 In March 2005, EPA plans to promulgate final regulations to reduce emissions of mercury from coal-fired power plants. To help inform this regulatory effort, a White Paper on the status of me rcury control technologies for electric utility boilers was released in February 2004 by EPA’s Office of Research & Development. 3 Subsequently, much new information has become available on these technologies. This White Paper has been prepared to document the current st atus of mercury controls and help inform the upcoming regulatory action. As will be discussed, control of mercury emissions from coal-fired boilers is currently achie ved via existing controls used to re move particulate matter (PM), sulfur dioxide (SO 2 ), and nitrogen oxides (NO X ). This includes capture of particulate-bound mercury in PM control equipment and soluble mercury com pounds in wet flue gas desulfurization (FGD) systems. Available data also show that us e of selective catalytic reduction (SCR) NO X control enhances the concentration of soluble mercury compounds in flue gas from some coal-fired boilers and results in increased mercury remova l in the downstream wet FGD system. Controls are also under development specif ically for the purpose of controlling mercury emissions. This White Paper will focus on the control options that have been, or are curr ently being, used/tested at power plants.

THE U.S. POWER SECTOR

The U.S. fleet of coal-fired ge nerating assets covers a range of coals and plant configurations. The coal and plant characteristics impact the effectiveness of vari ous mercury control methods at these plants. The U.S. coal-fired power plants typically burn one of three types of fuel: (1) bituminous coal (also referred to as “high rank” coal), (2) subbituminous coal, and (3) and lignite (subbituminous coal and lignite are referred to as “low rank” coals). Some of the characteristics of interest for these coal types are given in Table 1. 4

The current capacity of U.S. coal-fired power pl ants is just over 300 GW and includes a wide range of combinations of instal led air pollution cont rol (APC) configurati ons. In response to current and proposed NO X and SO 2 control requirements, additional NO X control and flue gas

3desulfurization (FGD) systems are expected to be installed and more widely used in the future (see Figures 1 and 2 below). Over ha lf of the U.S. coal-fired capacity is projected to be equipped with selective catalytic re duction (SCR) and/or FGD tec hnology by 2020. Table 2 shows the current and projected coal-fired capacity by APC configuration. 5

BEHAVIOR OF MERCURY IN COAL-FIR ED ELECTRIC UTILITY BOILERS

Mercury may be present in the flue gas in severa l forms. The specific chemical form – known as the speciation – has a strong impact on the cap ture of mercury by boile r air pollution control (APC) equipment. * Mercury may be present in the flue gas as elemental mercury vapor (Hg 0 ), as a vapor of an oxidized mercury species (Hg 2+ ), and as particulate-bound mercury (Hg p ).

Mercury is present in coal in trace amounts (a pproximately 0.1 ppm on average). Research by the U. S. Geological Survey indicates that much of the mercury in coal is associated with pyrite. Other forms of mercury that have been reporte d are organically bound, elemental, and in sulfide and selenide minerals. 6 During combustion the mercury is released into the exhaust gas as elemental mercury vapor, Hg 0 . This vapor may then be oxidized to Hg 2+ via homogeneous (gasgas) and heterogeneous (gas-so lid, surface catalyzed) reactions.

The primary homogeneous reaction is that with gas-phase chlorine. As the combustion exhaust gases exit the boiler and cool, thermodynamic e quilibrium shifts to favor formation of HgCl 2 vapor. The temperature window where this transformation o ccurs varies, based upon coal conditions, from about 620 °F to 1250 °F. 7 At the temperature after the last heat exchanger, normally around 300 °F, one would expect all of the mercury to be in the oxidized form if the reactions went to equilibrium. However, gas- phase mercury oxidation is slow and highly dependent upon the amount of chlorine 8 in the flue gas and, in pr actice, the amount of oxidized mercury in the flue gas can range from a few pe rcent to over 90%. Theref ore, the transformation of elemental mercury to oxidized mercury is ki netically limited, i.e., the chemical reactions associated with mercury oxida tion do not go to completion.

Heterogeneous (gas-solid, surface catalyzed) mercury oxidation is more complex and depends upon the availability of surfaces having electrophyllic groups that attract the electron-rich Hg 0 atom. The heterogeneous reactions occur mostly on fly ash surfaces or boiler surfaces, especially if the fly ash contains high amounts of unburned carbon. A proposed heterogeneous oxidation mechanism indicates the chlorination of carbon by HCl is a first step toward heterogeneous oxidation of Hg 0 to HgCl 2 , and adsorption of the mercury onto the carbon. 9 The mercury that is adsorbed onto solid surfaces, such as fly ash or unburned carbon, is the particulate-bound mercury, Hg p , which can be captured by downstream PM control devices. Hence, fly ash characteristics – especially carbon - as well as coal chlorine content play an important role in mercury speciation and capture.

* In general it is thought that Hg 0 will not be removed by pollution control equipment without first converting it to another form of mercury – either Hg 2+ or Hg p However, there is also the possibility for interaction between a charged surface and the elemental mercur y vapor. These interactions may be in the form of electrostatic, van de Waals, and polarization energies (elemental mercury vapor is polarizable).

4Other flue gas species – especially SO 3 and H 2 O – have also been shown to affect mercury speciation, tending to suppress Hg 0 oxidation to Hg 2+ . This is due to competition for active sites on the surface of carbon or other flue gas solids. In general, bituminous coals tend to have higher chlorine contents and also tend to produce hi gher levels of unburned ca rbon (UBC) in the fly ash. As a result, the flue gas from the burni ng of bituminous coals tends to contain higher amounts of Hg 2+ species while that of subbituminous a nd lignite coals tends to contain more Hg 0

vapor.

MERCURY REMOVAL BY EXISTING CONTROLS

Mercury may be captured as a c obenefit of PM controls and SO 2 controls, as well as through mercury-specific control technologies. The degr ee of this cobenefit can vary significantly depending upon the type of coal being burned an d the specific control technology configuration. This native capture (i.e., merc ury capture without add-on mercury- specific control technology) is seen in Figure 3, which shows mercury rem oval rates from EPA’s Information Collection Request (ICR) for three different coal types and APC configurat ions in use at power plants. There are some important trends in this figure.

• For the same APC configuration, the average mercury removal for bituminous coal was greater than that for other coals.

• Mercury removal for a fabric f ilter (FF) was significantly higher than those for a coldside ESP (CS-ESP) or hot-side ESP (HS- ESP) for both bituminous and subbituminous coals (no FF data for lignite coals).

• Average mercury removal for bituminous coal-f ired boilers with Spray Dryer Absorber and FF (SDA/FF) was very high (over 95%); for subbituminous coal-fired boilers with the same control configuration mercury re moval was considerably less (about 25%), which was actually less than for a FF alone (about 75%).

• In several cases there was a high level of variability in capture efficiency.

The tendency for a higher native mercury capture from boilers burning bituminous coal is likely a result of the higher chlorine content in the coal and of the tendency of these coals to produce higher levels of unburned carbon in th e flue gas. Both factors will co ntribute to greater levels of mercury as Hg 2+ and Hg p , which are easier to capture in ex isting air pollution control equipment than Hg 0

. The improved mercury capture for plants using FF as compared to those using ESPs can be explained by the increased contact the gas expe riences with fly ash a nd unburned carbon (UBC) as those accumulate as a filter cake on the FF. The filter cake acts as a fixed-bed reactor and contributes to greater hete rogeneous oxidation and adsorption of the mercury.

The poor removal of mercury by SDA/FF on low ra nk coals can be explained by the fact that much of the HCl in the flue gas is captured by the SDA, leaving inadequate HCl at the FF to participate in the oxida tion and capture of Hg 0 . For bituminous coals, usually having a higher percentage of mercury as Hg 2+ due to higher coal chlorine and UBC, this HCl stripping effect appears not to be important.

5The high variability of mercury capture for severa l situations indicates that for several cases there are other important factors besides coal rank and APC configuration. For example, the bituminous coal with CS-ESP data covers a ra nge of coal chlorine, fly ash carbon, ESP inlet temperature and coal sulfur levels – all of which can impact merc ury capture efficiency. So, even within any classification of coal or control technology, there ma y be a significant amount of variability in the native mercury capture.

Mercury Capture in PM Controls

As seen earlier in the ICR data (Figure 3), a FF can be very effective for mercury capture, especially for bituminous coals, but for subb ituminous coal as well. However, this FF-only configuration represents less than 5% of the U.S. coal bur ning capacity and is expected to decline in the next 15 years (see Table 2).

The native mercury capture in plants having onl y CS-ESP or HS-ESP was shown to be much less effective when compared to those with the FF-only configuration. This is because there is much less contact between gaseous mercury and fly as h in ESPs. Also, HS-ESPs operate at higher temperatures at which capture in fly ash is not effective. As with the FF-only configuration, the ESP-only configuration is expected to become less common (though still approximately 20% of the total capacity) in the next 14 year s with the expected installation of NO X and SO 2 controls.

Mercury capture in PM control devices becomes much more important with the injection of sorbents to the flue gas stream. This is disc ussed in great detail later in this document.

Mercury Capture in FGD Systems

FGD systems typically fall into one of two broa d categories. The wet FGD systems include the common limestone forced oxidation (LSFO) scrubber and the magnesium-enhanced lime (MEL, or “mag-lime”) scrubber. The dry FGD system s are typically spray dryer absorbers (SDA), which are usually installed in combination with a FF (SDA/FF).

Mercury Capture in Wet FGD Systems Mercury in the oxidized state (Hg 2+ ) is highly water sol uble and thus would be expected to be captured efficiently in wet FGD systems. Data fr om actual facilities has shown that capture of over 90% Hg 2+ can be expected in calcium-based wet FGD systems, though there are cases where significantly less has been measured. It has been suggested that this is primarily a result of scrubber equilibrium chemistry and good predictive capability for total mercury capture in wet FGD systems using a thermochemical e quilibrium model has been discussed. 10 It has also been shown that under some conditions Hg 2+ will be reduced to Hg 0 and the mercury will be reemitted. 11 In some cases, the reduction of Hg 2+ to Hg 0 and subsequent re-emission have been abated with the help of sulfide-donating liquid reagent. 7 So this limiting FGD scrubber chemistry and reemission of mercury may result in Hg 2+ capture that is signi ficantly less than 90%. Experience has shown that Hg 2+ reduction and reemission may be more difficult to avoid in magnesium-enhanced lime (MEL) scrubbers due to the much higher sulf ite concentration in these systems. 12

6The effect of scrubber chemistry and operating conditions on mercury em issions exhibited in Figure 4, which shows the measured mercury emissi ons as liquid-to-gas ra tio (L/G) was varied on a 100 MMBtu/hr pilot facility with inlet merc ury concentration in the range of about 10-25 μg/dsm. 3 Higher L/G resulted in lower outlet mercury emissions which has implications for wet FGD type – Limestone Forced Oxidation ha ving higher L/G than Magnesium Enhanced Limestone (MEL) wet FGD.

Figure 5 shows the mercury removal for various FGD systems reported by different sources, including mercury removal with SCR in operation. 12, 13, 14, 15 All results, except those on the far right of the figure, are from wet FGD systems. There isn’t enough data in this figure to show clear trends between various wet FGD system type s. But, more detailed examination of scrubber operating characteristics would lik ely reveal that the scrubber chemistry may be optimized to achieve high mercury removal as well as high SO 2 removal. 10, 11, 12 In any event, it is clear that the use of SCR and FGD combination consistently yielded mercury removal of nearly 90% in each of the applicable cases shown in Figure 5. In a comparable study partially funded by the U.S. DOE, 6 boilers fired with bituminous coal and equipped with SCRs, ESPs, and wet FGDs were shown to reduce total mercury emissions by 85%. 16 SCR impact on mercury speciation is discussed in the following section.

Oxidation of Hg 0 to Hg 2+ by SCR Catalysts Because Hg 2+ can be captured much more effectively than Hg 0 in wet FGD systems, methods to increase the amount of Hg 2+ upstream of the wet FGD should improve mercury capture in the wet FGD system. Under certain conditions, SCR catalysts have been shown to promote the oxidation of Hg 0 to Hg 2+ , particularly for bituminous coal . The impact of SCR on mercury oxidation is being investigated in two series of field tests: (1 ) EPRI-EPA-DOE sponsored field
tests 15 and (2) DOE sponsored test s being conducted by CONSOL. 13 The results of field test programs suggest that oxidation of elemental mercury by SCR cat alyst may be affected by the following: 15

• The coal characteristics, esp ecially the chlorine content

• The amount of catalyst used to treat the gas stream

• The temperature of the reaction

• The concentration of ammonia

• The age of the catalyst

The above factors have significan ce regarding the potential benef its of SCR on mercury capture for bituminous coals vis-à-vis subbituminous or lignite coals. A compar ison of the effects of SCR shows that oxidation of Hg 0 to Hg 2+ is greater for bituminous coals than for subbituminous coals (no data is available for lignite). In fact, in most cases the use of SC R resulted in about 85 – 90+% mercury in the oxidized form when firing bituminous coals. Figure 6 shows data from the EPRI-EPA-DOE field test, the DOE-CONSOL field tests and fr om field tests conducted at Dominion Resources Mount Storm Unit 2. 12 In particular, the figur e reflects the percent Hg 2+
measured at the inlet of the CS -ESP for boilers equipped with SCR. 12, 13, 15 Where data is available with the SCR off-line, it is also show n. In every bituminous coal case except S3, the percent Hg 2+ increased. In the case of S3, a sampling artifact is suspected. 11 In the case of the PRB-fired unit, Hg 2+ concentration remained very low. It should be noted that there may be some uncertainty associated with speciated me rcury measurements upstream of a PM control

7device. This is because PM in the extracted sa mple may cause oxidation of elemental mercury in that sample.

It would be desirable to incr ease the oxidation of mercury by SCR when firing subbituminous coals to levels approaching the oxidation levels of bituminous coal s. To investigate if this was possible, Senior and Linjewile 17 compared the results of thermochemical equilibrium calculations of mercury species concentration to full-scale and pilot test results. There was good correspondence between the results of the calculati ons and test results, su ggesting that oxidation of Hg 0 to Hg 2+ with SCR when firing subbituminous coal is limited by equilibrium rather than by kinetics. Hence, an improvement in catalytic oxidation of Hg 0 to Hg 2+ with SCR on boilers firing low-rank coals is not possi ble without a change in flue gas ch emical composition (such as from a higher chlorine in coal) or a lower catalyst temperature.

Senior and Linjewile also found that, wh en ammonia was injected, oxidation of Hg 0 to Hg 2+ tended to drop somewhat. 17 This suggests that the presence of ammonia may interfere with mercury oxidation on the catalyst. Another conc ern regarding the use of SCR for mercury oxidation is that of the catalyst age (i.e., as the SCR catalyst ag es, the oxidation of mercury may decline due to a loss in catalyst activity). Although field tests of catalyst oxidation between years did not show a significant change in mercury oxidation, it is thought that the age of this catalyst may not be adequate to show a significant change . Most SCR systems installed on U.S. facilities have been operating for only a few years, so th e effect of catalyst ag e on mercury oxidation may not be apparent yet.

Mercury removal by SDA/FF systems As shown in Figure 3, mercury is very efficien tly removed by SDA/FF comb inations when used on bituminous coal-fired boilers – an average of approximately 95%. Mercury – mostly in the form of Hg 2+ at the inlet of the SDA with bituminous coals - is captu red in the filter cake of the FF. However, mercury capture in SDA/FF systems te nds to be much less in low-rank coals. For low-rank coals, the low capture of mercury by SDA/FF systems is believed to be a result of the scrubbing of HCl in the SDA, which makes oxida tion and capture of mercury (mostly in the form of Hg 0 for these coals) in the downstream FF less effective. In fact, Figure 3 shows higher mercury capture by FF when firing subbituminous co al than mercury capture by SDA/FF. This is believed to be a result of the SDA scrubbing eff ect in removing HCl that could otherwise be available to react on the FF.

Data/Science Gaps and Associated Recommendations

To meet regulatory time lines, research and development (R&D) efforts should be focused on those areas that are likely to aff ect the largest number of boilers or are likely to significantly impact the ability of a class of boilers to reduce mercury. The following are items (in no particular order) where there is a shortage of data or where knowledge remains inadequate:

• Public information regarding mercury oxidation across SCR catalysts when lignite coal is fired could not be found.

• The role ammonia plays in interfering w ith mercury oxidation should be studied in greater detail. If ammonia in terferes with mercury oxidation in the manner previously

8suggested, then SCR effectiven ess in oxidizing mercury may be reduced as the catalyst
ages.

• The speciation of mercury at th e inlet of the SCR, or inlet of the PM control device (in the case where SCR is not installed), remain s difficult to predict because the processes that govern mercury speciation in the boiler are not yet adequately understood. A better understanding of this would im prove the ability to predict mercury removal performance of FGD and other air poll ution control equipment.

• The understanding of mercury oxidation ac ross SCRs may best be conducted with coordinated laboratory/pilot and field testing. Field test ing alone does not provide adequate control of conditions to understand this phenomenon.

• More information on the effectiveness of me rcury control with wet scrubbers on lignite or subbituminous fired boilers is needed.

• Reduction of oxidized mercury in wet F GD and subsequent re-emission requires enhanced understanding.

• Parallel efforts to improve measurement a nd data collection accuracy and to reduce the effort necessary for speciated measurements of mercury are critical. These are very challenging, labor intensive measurements. Significant progress has been made over the last few years to improve the reliability and accuracy of on-line measurement systems. However, accurate and dependable measurement of mercury at very low concentrations will be needed to prove the efficacy of mercury control systems.

• An improved understanding of the behavior of mercury in the boiler and air pollution control system may offer insights to a ddressing operational variability. Modeling supported by verification testing should be pursued to develop these capabilities.

• Efforts examining the potential for leaching of Hg and other metals (e.g., Se, As) from coal combustion residues (fly ash, scrubbe r sludge, etc.) are ongoing. Based on limited number of samples, results of these efforts have indicated that leaching of mercury from flyash and flyash-sorbent mixtures does not appear to be of concern. However, the potential for leaching of Hg and other metals should continue to be evaluated over a range of coal combustion residue ty pes and their management practices.

• The potential for release of mercury in pr ocesses involving beneficial use of coal combustion residues (e.g., wallboard production and other high temperature processes) should be evaluated.

APPROACHES FOR ENHANCIN G MERCURY CAPTURE BY SO 2 OR PM CONTROLS

Important factors that have been found to influe nce the mercury capture as a cobenefit of other APC equipment include the coal characteristics, especially the chlorine content, and the carbon content of the fly ash. Therefore, efforts to im prove capture efficiency of existing equipment have been directed primarily at several a pproaches: fuel blending, addition of oxidizing chemicals, controlling UBC content of the fl y ash, addition of a merc ury-specific oxidizing catalyst downstream of the PM control device. Many of these options are shown in Figure 7.

9Fuel Blending

Blending of small amounts of bituminous coal wi th subbituminous or lignite coal may provide some benefit to capture of mercury by existing equipment. Coal blending has been shown to affect UBC and mercury removal. For example, Sjostrom showed that at Holcomb Station, a 360 MW, PRB a -fired boiler equippe d with SDA/FF for SO 2 and PM control, vapor phase mercury capture across the SDA/FF system could be incr eased from less than 25% to nearly 80% by blending small amounts of western b ituminous coal with the PRB coal. 18 Since mercury removal of SDA/FF systems firing 100% bituminous coals ha s been shown to be about 90% or greater, this permits mercury removal performance appro aching that of bituminous coals while firing mostly PRB. The effectiveness of this approach in improving cobenefit mercury controls is likely to be very facility-specific. The long-term eff ects of blending fuels would need to be evaluated for each application. Blending may change boile r slagging/fouling characteristics or the performance of APC equipment.

Addition of Oxidizing Chemicals

The addition of chlorine to the fu el or injection into the flue gas is another approach that is being tested for enhancing intrinsic cap ture of mercury. At Laskin 2 (firing PRB) and at Stanton 10 (firing North Dakota lignite), chlo rine salts were added to the fuel to assess the impact of increasing fuel chlorine on merc ury oxidation and capture. Laskin 2 is equipped with a Particle Scrubber (PS) and Stanton 10 with a SDA/FF. In both cases, mercury oxidation increased, although for some salts the mercury capture did not increase. In the case of Laskin, opacity was observed to increase as a result of salt addition and in the ca se of Stanton 10, pressure drop across the FF increased. Long-term effects, su ch as corrosion, plugging, impacts on combustion equipment could not be assessed duri ng the short-term parametric tests. 19 Therefore, the use of coal additives offer some promise at improving mercury capture; however, they may have other impacts that need to be evaluated.

Increasing UBC in Fly Ash

Carbon in the fly ash has been shown to be an im portant factor in mercur y capture by PM control equipment. For example, at Salem Harbor #1, which fires bituminous coal and has a CS-ESP, mercury removal rates over 80% were measured on some occasions. These were attributed in large part to the very high carbon content in the fly ash – on the order of 15% or more and sometimes around 30%. 20 As a result of this phenomenon, it is possible to optimize the trade off between higher fly ash carbon and improved merc ury control by adjusting combustion conditions or fuels. Since unburned carbon is unavailable for the production of steam and electricity following combustion there is a trade-off between the overall plant efficiency versus mercury adsorption. In general, this approach may be employed at any plant with a CS-ESP or FF, but may be more applicable to those with dry botto m boilers. However, the carbon content in the fly ash may need to be kept within acceptable limits due to constraints with ESP or FF performance or opacity. For plants with HS-ESPs, this approach is not expected to be effective because the carbon is not very effective in capturing mercury at HS-ESP temper atures. Finally, other impacts

a PRB coal is a commonly used subbituminous coal that is mined in the Powder River Basin (PRB) in Wyoming.

10of increased UBC (e.g., waste dis posal and byproduct use) could al so pose additional constraints on use of this mercury control approach.

Mercury-Specific Catalysts

Enhancing capture by wet FGD processes is possible if Hg 0 can be oxidized to Hg 2+ . Research efforts are underway to evaluate catalysts that are installed upstr eam of the wet FGD or injection of oxidizing chemicals upstream of the FGD. These approaches are undergoing full-scale evaluation. Important concerns i nvolve longevity of the catalyst and the long-term effects of oxidizing chemicals on downstream equipment.

Improvement of Mercury Capture in Wet FGD

As mentioned earlier the amount of mercury that is captured in the wet FGD system is limited by the amount of oxidized mercury entering the scrubbe r and by the scrubber equilibrium chemistry. The mercury removal performance of the scru bber may also decrease if absorbed Hg 2+ is reduced and reemitted as Hg 0 vapor.

Evaluation of ICR Data An analysis of the EPA ICR data was conducted in order to evaluate reemission from the FGD system. The data for systems with CS-ESP/we t FGD and HS-ESP/wet FGD were evaluated. The increase of the amount of elemental mercury acr oss the entire system was assumed to be the result of Hg 2+ mercury that was absorbed in the wet scrubber and subsequently reduced and reemitted as Hg 0 vapor. The data * was evaluated using the following equation:

0 0 

# ( Hg

− Hg 

# )

0 out in % Hg increase = x 100 Total 

# ( Hg 

# )

in
For the CS-ESP/wet scrubber configurat ion there was a 5% increase in Hg 0 across the system for bituminous (1 unit). The subbituminous (3 units) a nd lignite (2 units) plan ts showed a 4-50% and 12-21% decrease of Hg 0 across the system, respectively.

For the HS-ESP/wet scrubber configuration, however, there was a greater tendency for increasing Hg 0 across the system. For bituminous plants (2 units) the Hg 0 increased by 2-12%, while the subbituminous plants (4 units) ranged from a 30% decrease up to 67% increase (note: 3 of the 4 subbituminous units showed a net in crease of elemental mercury across the APC system). There were no lignite plants w ith the HS-ESP/wet scrubber configuration.

Field Testing Babcock & Wilcox (B&W) and McDermott Tec hnology, Inc. completed field tests at two commercial coal-fired utilities with wet FGD systems. The work was funded by DOE/NETL, the Ohio Coal Development Office, and B&W. The test sites were (1) Michigan South Central Power Agency’s (MSCPA) 55 MW Endicott St ation and (2) Cinergy’s 1300 MW Zimmer

* Only data where the inlet and outlet flows were within +/ - 30% were used in this analysis. Also, cases where there was a net increase of Hg 2+ across the system were not used in this analysis.

11Station. Endicott Station uses a limestone forced oxidation (LSFO) wet FGD system, while Zimmer Station using Thiosorbic® Lime (magnesium enhanced lime, MEL) and ex situ oxidation. High-sulfur bituminous coal was burned at both locations. The resu lts of the tests were as follows: 21

At the Endicott Station, total mercury removal across the wet FGD system during the 4-month long tests ranged from 76% to 79%. Most of the oxidized mercury present in the flue gas was removed in the scrubber system (approximately 96% removal). No increase in elemental mercury concentration across the scrubber was observed. This indicated that the control technology was successful in maintaining high le vels of oxidized mercury removal and also simultaneously suppressing mercury reemission.

Following the Endicott test program, a 15-day ve rification test was performed at the Zimmer Station. The average total mercury removal acros s the wet FGD system averaged approximately 51% during this test. Lower removal of oxidized mercury was observed, as compared to that measured at Endicott (87% vs. 97%). Additi onally, the elemental mercury concentration increased across the wet FGD system, by approxima tely 40%. This indicated that the technology was less effective in removing oxidized mercury and ineffective in suppressing reemission of captured mercury from the scrubber.

In order to evaluate the indivi dual and cumulative role of SCR catalyst, ammonia injection and chemical additive on the speciation and removal in a limestone forced oxidation (LSFO) scrubber, testing was conducted at Dominion Resources Mount Storm power plant (Unit 2, 563 MW, firing medium-sulfur Eastern bituminous coal). 12 Baseline mercury removal testing was completed under several scenarios including full flue gas bypass of the SCR and flue gas flowing through the SCR with and without ammonia injection. After baseline testing, a chemical additive (sodium hydrosulfide, NaHS) was injected into th e scrubber recirculation pumps to evaluate its impact on oxidation and reemission of elemental me rcury. The results of the tests are given in Table 3.

The results showed that during testing with the SCR bypassed and no injection of the additive, the scrubber still captured great er than 90% of the oxidized mercury (71% total mercury). However, there was reemission of Hg 2+ as Hg 0 vapor as indicated by the approximately 15% net increase of elemental mercury across the scr ubber. Under the same conditions (SCR bypassed) but with the chemical additive injected, there was again greater than 90% capture of the Hg 2+ and approximately 30% capture of Hg 0 (actually Hg 0 that was oxidized and retained as Hg 2+ ). There was also an increased total mercury removal, at 78%. In tests where the flue gas was directed through the SCR, both with and without chemi cal additive injected into the scrubber recirculation pumps, the removal of Hg 2+ increased to greater than 95% and the total mercury removal increased to greater than 90%.

These results indicate the effec tiveness of the chemical additi ve (a NaHS injection technology that has been patented by B&W) in suppressing the reemission of elemental mercury. The tests also showed that the presence of the SCR catal yst significantly impacted the mercury speciation profile at the inlet of the we t scrubber, causing oxidation of the remaining elemental mercury. The oxidized mercury was effectiv ely removed by the wet scrubber. 12

12Data and Science Gaps and Associated Recommendations

For each of these methods used to enhance the removal of mercury by existing equipment, the effectiveness under the range of ope rating conditions, and range of coals that a plant may operate with, would need to be evaluated. Long-term imp acts to the plant, partic ularly corrosion with approaches that involve chemical additives to th e flue gas or fuel, should be examined. Impacts to other air pollution control devi ces must also be considered.

The effectiveness of oxidation catalysts over an extended period of exposure to flue gas may need to be understood better before such technology can be commercially implemented.

MERCURY CONTROL BY SORBENT INJECTION

Unlike the technologies described earlier, wher e mercury removal was achieved as a cobenefit with removal of other pollutants, mercury control via injection of sorbent materials into the gas stream of coal-fired boilers is under developmen t. Injection of dry sorbents, such as powdered activated carbon (PAC), has been used for contro l of mercury emissions from waste combustors and has been tested at numerous utility units in the United States. However, sorbent injection experience on waste combustors may not be directly transferable to coal-fired electric utility boilers due to the following reasons.

1. The concentration of mercury in the flue gas of waste combustors is an order of magnitude higher than for coal-fired bo iler systems. Consequently, th e amount of mercury captured per unit mass of carbon injected will, in genera l, be higher in waste combustors compared to coal-fired boilers.

2. Typically, the flue gases of wa ste combustors have higher ch lorine concentrations than those found in flue gases of coal-fired util ity boilers. Since pe rformance of ACI in situations with low levels of chlorine in the flue gas may be adversely affected, ACI performance on waste combustors may, in general, not be equivalent to that on coal-fired boilers.

3. In general, coal-fired power plants are much larger in size compared to waste combustors. For example a large municipal waste combustor may be about the same size as a small, 40-50 MW, coal-fired plant. Accordingly, duct dimensions, generally, are much larger in coal-fired plants compared to those at waste com bustors. Since mixing of injected AC and flue gas in the duct affect s mercury capture performance, design of AC injection systems may, in general, be more involved for coal-fired boilers.

Dry sorbent may be injected into the ductwork upstream of a PM control device – normally either an ESP or FF. In some cases, an FGD (d ry or wet) system may be downstream of the sorbent injection point. Usually the sorbent is pn eumatically injected as a powder. The injection location will be determined by the existing plant configuration a nd whether additional downstream PM control equipment, such as a FF, is retrofit. For example, to segregate collected fly ash from collected sorbent it may be beneficial to retrofit a pulse-jet FF (PJFF) downstream

13of an existing ESP and inject the sorbent between the ESP and the PJFF. This type of particulate removal configuration is called a Comp act Hybrid Particle Collector (COHPAC TM ) and when combined with sorbent injection is called Toxic Emission Control (TOXECON TM ). Therefore, for boilers currently equipped only with PM cont rol devices, implementing sorbent injection for mercury control would likely entail either:

• injection of powdered sorbent upstream of the existing PM co ntrol device (ESP or FF); or

• injection of powdered sorbent downstream of the existing E SP and upstream of a retrofit PJFF, the TOXECON TM option; or

• injection of powdered sorbent between ESP fields (TOXECON-II TM approach).

Above powdered sorbent injection approaches mi ght also be employed in combination with existing SO 2 control devices. For example, powdered so rbent might be injected prior to the SO 2 control device or after the SO 2 control device, subject to the ava ilability of a means to collect the powdered sorbent downstream of the injection point.

In general, factors that appear to impact the performance of any particular sorbent include:

• injection concentration of the sorbent measured in lb/MMacf b ;

• flue gas conditions, including temperature and c oncentrations of HCl and sulfur trioxide (SO 3 ) ;

• the air pollution control configuration;

• the characteristics of the sorbent; and

• the method of injecting the sorbent.

These factors are discussed in more detail in the following sub-section.

Mercury Control by Conventional PAC Injection

The most widely tested sorbent for mercury contro l at utility boilers is PAC. Initial work focused on use of PAC because it is a material that is currently available for other uses (e.g., water treatment). PAC has been evaluated for mercury control in several pilot- and full-scale tests. More recently, field tests have been performed w ith other powdered sorbent materials such as enhanced PAC and silica-based sorbents, which are specifically formulated for controlling mercury emissions from power plants. As will be shown in the following sections, these specially-formulated sorbents appear to offer adva ntages over standard PAC in certain situations.

Numerous field tests have been undertaken to evaluate the use of powdered sorbent, especially PAC, on capture of mercury from power plants . These tests have been sponsored by the Department of Energy/National Energy Tec hnology Laboratory (DOE/NETL), the Electric Power Research Institute (EPRI) and utility comp anies. Table 4 shows the test programs that

b Sorbent injection rate is expressed in lb/MMacf, i.e., po unds of sorbent used for each million actual cubic feet of gas. For a 500 MW boiler, a sorbent rate of 1.0 lb/MMacf will correspond to approximately 120 lb/hour of sorbent.

14have either evaluated, or are ev aluating, standard PAC injection for mercury control. As shown in the table, the test programs cover a va riety of configurations and fuel types.

Short-term PAC injection field tests In the 2001-2003 time period, the Department of Energy/National Energy Technology Laboratory (DOE/NETL), the Electric Power Res earch Institute (EPRI) and a group of utility companies funded relatively short-term field test projects to evaluate the use of ACI as summarized in Table 5. The first four projects reflected in the table were DOE/NETL Phase I projects. Experience gained in th ese relatively short-term projects added to insights on factors, mentioned above, that appear to impact the mercury capture performance achieved via PAC injection. Some of this expe rience is described below.

Figure 8 shows the performance of a commonly used PAC product, Norit FGD, in full-scale parametric tests conducted in four of the projects. 22 Results in this figure reveal that, in general, injection of PAC at increasing amounts tends to increase mercury removal efficiency. However, in some cases, a limiting value of removal effi ciency may be reached above which additional injected carbon will not provide additional mercury removal.

Temperature is known to impact the adsorption ca pacity of PAC, and th erefore plays a very significant role. In most cases, the gas temperatur e at the available inje ction point upstream of the PM control device is around 300 °F and PAC ha s been shown to work effectively at this temperature. However, at temperatures appr oaching 350 °F or more, the effectiveness of standard PAC drops off rapidly. 23 This was verified in testing at Salem Harbor, where increasing the ESP inlet temperature from 300°F to 350°F reduced mercury removal from approximately 90 % to the 10-20 % range. Fortunately, cases wher e gas temperatures are this high are less common; such high temperatures, however, are f ound in lignite-fired boile rs. Enhanced PACs or other sorbents may offer th e capability to operate at much higher temperatures.

As shown in Figure 8, mercury removal close to 90% was achievable at injection rates approaching 20 lb/MMacf at Brayton Point 1. On the other hand, at Pleasant Prairie Power Plant (PPPP) #1 it was not possible to achieve greater than about 65% mercury removal regardless of the PAC injection rate. An impor tant difference between these two CS-ESP sites was the amount of unburned carbon in the fly ash. The PPPP fly ash t ypically has very low levels of UBC in the fly ash (<1%) while the Brayton Point unit is equipped with low-NO X burners and typically has higher levels of UBC in the fly ash. Another si gnificant difference between these two sites was the relatively high level of ch lorine in the coal used at Brayton Point (around 2000-4000 ppm) versus the relatively low chlorine level in the PPPP coal (around 8 ppm). 23 Moreover, the alkaline fly ash at PPPP was belie ved to have neutralized some of the HCl in the flue gas, thereby leaving relatively little chlorine availa ble for mercury chemistry. The large difference in the amount of chlorine available in the flue gas fo r mercury chemistry is believed to contribute to the high level of Hg 2+ at Brayton Point and the low level of Hg 2+ at PPPP. Adequate chlorine in the gas stream is believed to be necessary for capture of Hg 0 by standard PAC. Because the mercury in the PPPP gas was almost entirely Hg 0 , the low chlorine content limited the capture possible by the PAC. Nevertheless, test resu lts showed that removal efficiency of Hg 0 and Hg 2+
was about the same at PPPP. 23

15It is believed that acid gas components such as SO 3 compete with mercury for the active sites on PAC, and thereby can impact mercury capture perf ormance of the PAC. In the tests conducted at Abbot, the best performance, 73% mercury capture

, was achieved by injection of fine FGD at 13.8 lb/MMacf at an ESP inlet temperature of 341 °F. The high sulfur flue gas appeared to impair the performance of the PAC.

APC configuration can have a ve ry significant impact on PAC perf ormance. Gaston Unit 3 is a 270 MW bituminous coal fired boiler with a HS-E SP and a FF installed downstream of the air preheater in a COHPAC TM arrangement. The downstream FF in the COHPAC arrangement is smaller than a FF sized for the full ash load ing. As shown in Figure 8, at Gaston, mercury removal rates around 90% attributab le to the PAC were possible at injection rates less than 5 lb/MMacf. It is noted, however, that flue gas temperatures at COHPAC TM inlet, about 270 o F, were lower than those typically found at the inlet of PM contro ls at power plants. Such low temperatures may have enhanced capture of merc ury in the carbon sorbent. Figure 8 also shows that the performance of PAC injection upstream of pilot FF when firing a subbituminous coal is similar to the performance demonstrated at Gaston. 23 The intimate contact between the PAC and the gas stream that occurs in a FF is believed to contribute to much higher removal than is possible through “in-flight” capture alone, such as for injection of PAC upstream of an ESP. Although there may be less chlorine present in the subbituminous coal, the high contact between the PAC and the gas in the FF facilitates th e heterogeneous oxidation and adsorption of Hg 0 onto the PAC.

For all of the results shown in Figure 8, the sorb ent used was a product called Norit FGD. In the case of PAC injection upstream of a CS-ESP, such as at PPPP and Brayton Point, the choice of sorbent made a significant difference in the pe rformance. For example, at PPPP using treatment rates in the narrow rang e of 2.2 to 2.3 lb/MMacf the mercury removal ranged from 37% to 51% depending upon the sorbent selected. And, at Brayt on Point for a treatment rate of 10 lb/MMacf the mercury removal ranged from 55% to 73%, depending upon the sorbent selected. 22 However, when the sorbent was captured in a FF, su ch as at Gaston, no significant difference in performance was observed between standard PAC so rbents (due to increased contact time, as discussed above). Therefore, it is likely that the PAC properties such as particle size make a significant difference in performance when mo st of the mercury capture is in-flight.

Speciated mercury capture data collected in the above projects is presented in Table 6. These data indicate that concentrations of Hg p in flue gas at the outlet of PM controls were less than 0.35 μg/Nm 3 for conditions without and with sorbent in jection. This simply indicates that PM controls were operating reasonably. With regard to gaseous mercury (both Hg 0 and Hg 2+ ), the following observations are made:

• Hg 0 concentrations at the outlet of PM controls were below 0.51 μg/Nm 3 under sorbent injection conditions at Salem Harbor and Gast on. However, the same was not the case at Pleasant Prairie, where such concentrations amounted to about 4.3 μg/Nm 3 . This may be attributed to most of the mercury in the flue gas at Pleasant Prairie being Hg 0 and mercury removal efficiencies being about 70% in contrast to the much higher removal efficiencies achieved at Salem Harbor and Gaston.

16• Hg 2+ concentrations at the outlet of PM controls were below 1 μg/Nm 3 under sorbent injection conditions at all plants.

• ACI was quite efficient in decreasing Hg 2+ concentrations in flue gas at PM control outlets as seen in results fr om Pleasant Prairie and Gaston. At Pleasant Prairie, without ACI, Hg 2+ concentration at ESP exit was more than 6 μg/Nm 3 , which was reduced to less than 0.5 μg/Nm 3 with ACI. Similarly, Hg 2+ concentration at COHPAC exit was reduced from 10.4 μg/Nm 3 under no-ACI conditions to 0.8 μg/Nm 3 with ACI.

Incidentally, at Pleasant Prairie, without ACI, Hg 0 concentration at ESP exit was more than 9 μg/Nm 3 , which was reduced to less than 4.5 μg/Nm 3 with ACI; that is a reduction of approximately 50%. This reduction is lower than the greater than 90% reduction measured for a corresponding decrease in Hg 2+ concentration.

The above observations indicate th at ACI appears to be quite e ffective in controlling emissions of Hg 2+ . However, this needs to be substant iated as more data is available.

Cremer et al. discuss the results of a program to evaluate a model for assessing the injection, mixing, and associated mass transfer effects of in jecting sorbent into the gas stream for mercury capture. 24 In this program the PPPP PAC injection system was modeled using Computational Fluid Dynamic (CFD) software. Modeling suggested that mixing played a si gnificant role in the in-flight mercury capture and, comb ined with test data, it sugges ted that some of the mercury removal was from PAC that had fallen out of the gas stream and deposited on surfaces. Modeling also suggested that only th e smaller PAC particles (< 20 μ m in diameter) were contributing significantly to mercury capture. Other programs to evaluate the importance of injection system design and particle size characteri stics have also confirmed that these mass-transfer factors are significant in influencing performance of in -flight mercury capture by sorbent injection. 25 As a result, the factors that govern mass transfer of the sorbent must be well controlled for good performance. And, comparison of test results from different field test pr ograms should consider if the mixing and distribution effects are compar able before drawing co nclusions regarding the effects of other test conditions.

Longer term field test results with PAC injection 26 Following the short-term testi ng at Gaston described above, some longer term tests were undertaken. The main objectives of these tests were to further evaluate the potential for the mercury capture performance seen in short-term tests and to test higher permeability FF bags with lower pressure drop. In full-load (270 MW) tests, PAC was injected nearly continuously in the period June 26-November 25, 2003, at rates le ss than 0.7 lb/MMacf to maintain acceptable FF cleaning frequency for FF operati on at an air-to-cloth ratio of 8.0 ft/min. This resulted in weekly mercury removal between 80- 90%, with an average of 86%, for the test period as shown in Figure 9. To achieve 90% removal, additi onal lower load (195 MW ), or lower throughput, tests were conducted with FF operati ng at an air-to-cloth ratio of 6.0 ft/min. In these tests, PAC was injected for 2 weeks in November 2003 and greater than 90% mercury removal was achieved at injection rates of 2 lb/MMacf or more. Subsequently, in December 2003 full-load (270 MW) tests were conducted with higher permeability bags c mounted in the FF, which

c The higher permeability bags were 7.0 denier versus the or iginal bags, which were 2.7 denier (denier is a measure of the linear density of a fiber and provides an indication of the cross section or thickness of the fibers). The

17operated at a air-to-cloth ratio of 8.0 ft/min. Gr eater than 90% mercury removal was achieved at injection rates of 0.8 lb/MMacf or more with acceptable FF cleaning frequency. The results of these tests indicate that if the FF is designe d properly to accommodate the carbon loading, 90% or greater removal of mercury with relatively modest PA C injection rates may be possible in a TOXECON TM arrangement.

Potential mercury capture constraints with PAC injection In general, the efficacy of mercury capture in standard PAC increases with the amount of Hg 2+ in flue gas d , the number of active sites e in the PAC, and lower temperature. The amount of Hg 2+ in flue gas is directly influenced by the amount of chlorine present in the flue gas. Based on these factors, standard PAC injection appears to be generally effect ive for mercury capture on lowsulfur bituminous coal applications, but le ss effective for the fo llowing applications:

• Low-rank coals + ESP with current capacity of greater than 150 GW and not expected to grow significantly in the future. Lower chlorine and higher calcium contents in coal lead to lower levels of chlorine in flue gas, wh ich results in reduced oxidation of mercury and, therefore, lower Hg 2+ in flue gas;

• Low-rank coals + SDA + FF with current capacity of greater than 10 GW and expected to grow significantly in the future. Similar eff ect as above, except lime reagent from the SDA scavenges even more chlorine from flue gas;

• High-sulfur coal, current capacity with wet FGD of approximately 100 GW and likely to grow to more than 150 by 2015. Relatively high levels of SO 3 compete for active sites on PAC, which reduces the number of sites ava ilable for mercury. Gene rally, plants will use wet FGD and, in many cases, SCR; PAC injecti on may be needed as a trim application; and

• Hot-side ESPs with capacity greater than 30 GW and not likely to grow. Weak (physical) bonds get ruptured at higher temperatur es resulting in lower sorption capacity.

Mercury Control by Halogenated PAC Injection

Some situations, described above, may not have adequate chlorine present in the flue gas for good mercury capture by standard PAC. Accord ingly, halogenated PAC sorbents have been developed to overcome some of the limitations associated with PAC injection for mercury control in power pl ant applications. 27, 28 Two different halogenated PAC sorbents have been tested in field tests. They are Sorbent Technologies Corp. br ominated-PAC (B-PAC) and Norit America’s halogenated PAC (E-3).

Halogenated PACs offer several potential benefits. Relative to standard PAC, halogenated PAC use: (1) may expand the usefulne ss of sorbent injection to many situations where standard PAC

permeability of the bags was 130 cfm/ft 2 @ 0.5” H 2 O versus the nominal 30 cfm/ft 2 @ 0.5”H 2 O for the original bags. d Standard PAC binds mercury via physical (i.e., weak) bonds, which are formed more easily with Hg 2+

. There have been results that show a similar removal for both elemental and oxidized mercury. However, the results do not account for surface oxidation/ sorption on the carbon.

e These are collection of atoms/radical s such as oxygen, chlorine, hydroxyls, which provide binding sites.

18may not be as effective; (2) may avoid insta llation of downstream FF, thereby improving costeffectiveness of mercury capture ; (3) would, in general, be at lower injection rates, which potentially will lead to fewer plant impacts and a lower carbon content in the captured fly ash; (4) may result in somewhat better performance with low-sulfur (incl uding low-rank) coals because of less competition from SO 3 ; and (5) may be a relatively inexpensive and attractive control technology option for develo ping countries as it does not i nvolve the capital intensive FF installation.

As shown in Table 7, halogenated PACs have been tested at full-scale for many different combinations of coal type and PM controls. In each of these tests, relatively high levels of mercury removal were achieved with relatively mode st injection rates when compared to results from tests with non-halogenated PAC inj ection in similar plant configurations.

Mercury control perform ance with halogenated PACs Figure 10 shows comparative results from PPPP (full scale parametric data with PAC and pilotscale data with B-PAC), St. Clai r (full scale parametric test re sults with PAC and with B-PAC), and measured full-scale in-flight B-PAC mercur y removal at Stanton 10 (S10), and parametric test data from Brayton Point. 22, 27 In all cases, injection was upstream of a CS-ESP or in-flight removal upstream of the FF was measured. Also, ex cept for Brayton Point, in all cases the HCl content was expected to be very low due to the coal type (subbituminous in the case of PPPP and St. Clair, and lignite in the cas e of S10). As shown, PAC was unabl e to remove more than about 70% of the mercury at PPPP or St. Clair. In contrast, with B-PAC about 90% removal was achieved at around 5 lb/MMacf at both St. Clai r and with the PPPP pilot. Also, for all cases where B-PAC was tested, similar results in terms of percent removal vs. injection rate were achieved. It should be noted that the ESP associated with B-PAC te sting at St. Clair has a larger than typical SCA (700 ft 2 /kacfm) 29 and this may potentially have contributed to high levels of mercury removal with modest B- PAC injection rates. On the other hand, since B-PAC injection rates were modest, they likely did not require a larger collection surface. As shown in Table 7, 70% mercury removal with a B-PAC injection rate of 4 lb/MMacf was obt ained at the Lausche plant, which fires a high-sulfur bituminous coal and has a mid-sized ESP with SCA (370 ft 2 /kacfm). 27 It is believed that mercury capture at Lausche was affected by the high sulfur content in coal; SO 3 in flue gas is believed to compete with mercury for active sites in the sorbent. At Cliffside (Low-sulfur bituminous co al with a hot side-ESP, and B-PAC), mercury reductions of 80% were measured at minimal lo ad, and 40% at full load, during short term (2­ weeks parametric) tests. 30 It is noted, however, that addi tional HS-ESP test programs with longer-term (30-day continuous) tests are pla nned/underway. These programs are summarized later in this document. Based on above observati ons, for boilers not firing high-sulfur coals and/or not using hot side-ESPs, injection of halogenated PAC, such as B-PAC, appears to have the potential to provide high leve ls of mercury removal under condi tions that are challenging for PAC.

Figure 11 shows comparative test results from programs including PAC and B-PAC sorbents where a downstream FF was used. In these tests, B-PAC performance consistently was superior in terms of percent reduction for a given injection concentration. For the bituminous coal cases, the Valley pilot and the Gaston full-scale data correspond almost exactly. Similarly, the Stanton 10 and Valley pilot data correspond almost exactl y, although Stanton 10 is a lignite-fired boiler

19with SDA/FF and Valley is bituminous coal-fire d. A comparison of the Stanton 10 data with PAC injection versus Stanton 10 data with B-PA C injection shows how dramatic the difference in performance can be.

Performance of a halogenated so rbent such as B-PAC appears to be relatively consistent regardless of coal type and appears to be mostly determined by whether ornot the capture is inflight (as in upstream of a CS-ESP) or on a fabr ic filter. This is shown in Figure 12 where BPAC results from parametric tests are shown fo r in-flight and upstream of a fabric filter for various coal types. This is a significant development because pe rformance of standard PAC is impacted by coal type as well as equipment.

Finally, available data shown in Figure 13 refl ect that performance of B-PAC and E-3 for Western coal (PRB, lignite) is similar to th at of TOXECONTM (using conventional PAC) for Eastern bituminous.

All of the data described above in this section are from shorte r term parametric tests. The purpose of these tests was to determine conditions for longer-term testing with sorbents of interest. In these parametric tests, a sorben t was injected continuously for a few hours and mercury measurements were made. Subsequently, an operational parameter (usually the sorbent injection rate) was adjusted and the effect on mercury capture was measured. Each of the data points in Figures 10, 11 and 12 represents such a measurement. The results from these shorter term parametric tests were used to determine the condition s for longer-term tests, which are discussed below.

Longer term tests with halogenated PAC injection As shown in Table 7, halogenated PACs have been tested for periods of 10 to 30 days at three plants. The results shown in Figures 14, 15, and 16 reflect relatively hi gh levels of mercury removal were maintained for most of the test ing periods with modest injection rates.

Speciated mercury capture data collected in the above projects is presented in Table 8. These data indicate that concentrations of Hg p , Hg 0 , and Hg 2+ in flue gas at the outlet of PM controls were less than 0.6 μg/Nm 3 each with halogenated sorbent injection. Thus, in general, halogenated PAC injection appears to be quite effective in contro lling emissions of each of Hg p , Hg 0 , and Hg 2+ . Note, however, that data from Pleasant Prai rie indicated that injection of standard PAC may be limited in controlling Hg 0

.
Additional testing with halogenated PAC injection A significant numbers of field tests are planned or ongoing over the next two years to further evaluate halogenated PACs for power plant applications. These are summarized below.

DOE Phase II Round 1 Projects

• B-PAC: 1-week parametric testing at D uke Energy, Cliffside 2, 40 MW, low-sulfur bituminous, HS-ESP; December 2004

• B-PAC: 30-day parametric and 30-day con tinuous testing at Duke Energy, Buck 5, 140 MW, low-sulfur bituminous, HS-ESP; Spring 2005

20• Norit E-3: 30-day continuous testing at AEP Conesville 6, 500 MW, bituminous, ESP, wet FGD; June 2005

• Norit E-3: 30-day continuous testi ng at Detroit Edison Monroe 4, 375 MW, PRB/bituminous blend, ESP; November 2005

DOE Phase II Round 2 Projects (expected for 2006)

• B-PAC: 30-day parametric and 30-day con tinuous testing at Pr ogress Energy, Lee 1, 80 MW, low-sulfur bituminous, ESP

• B-PAC: 2-week parametric testing at Progress Energy, Lee 2, 75 MW, low-sulfur bituminous, HS-ESP

• B-PAC: 30-day parametric and 30-day c ontinuous testing at Midwest Generation, Crawford 7, 100 MW, subbituminous, ESP, sell ash for concrete

• B-PAC: 2-week parametric testing at Midwest Generation, Will County 3, 130 MW, subbituminous, HS-ESP, sell ash for concrete

• Norit E-3: Testing at TXU Big Brown Steam Electric St ation, lignite-subbituminous blend

• Norit E-3: Testing at 2 faci lities with TOXECON IITM c onfigurations; one bituminous and one PRB; locations TBD

Other Advanced Sorbents and Additives

Aside from standard and halogena ted PACs, other advanced sorben ts and additives, designed to overcome shortcomings of PAC in certain power plant applications, ar e being developed and tested. These are briefly described below.

About 15% of the power plant fly ash in the Unite d States, or about 10 million tons, is sold as a cement additive. PAC, when added to fly ash, ho wever, adsorbs the Air Entraining Admixtures (AEA) that are used to provide the proper am ount of fine air bubbles in concrete for good strength. 31 It is possible to segregate the fly as h from the PAC by the use of a TOXECON TM system. However, this entails significant capita l expenditure and operatin g expense associated with the retrofit FF. An alternative is to modify the sorbents. Silica-based sorbents and speciallyformulated PACs are under development to overcom e some of the difficulti es associated with use of PAC on facilities that sell their fly ash as a cement additive. Silica-based sorbents are being introduced by a company called Amended Silicates. These sorbents have not yet been tested for mercury removal at the full scale, but will be tested in 2005 at the Miami Fort unit 6, a 175 MW bituminous coal fired boiler with three small ESPs in series. 32, 33, 34 Speciallyformulated B-PAC has been show n to avoid high foam index and offer similar mercury removal performance as B-PAC in a laboratory test facility. 31 However, additional development and testing of such specially-form ulated sorbents is needed.

Sodium Tetrasulfide (STS) is a liquid chemical reagent that is injected into the gas stream in the same location as PAC. STS has been used on muni cipal waste combustors to remove mercury. It has the benefit of reacting to form a stable mercury compound (cinnabar) that can safely be added to concrete or disposed of. This technology has been tested for coal power plant use at the pilot scale. 35

21Efforts are underway to develop lower cost so rbents than commercial PAC sorbents. Sources include capture of devolatilized char from the furnace for use as a low-cost sorbent or oxidizing catalyst. 36 This carbon, known as the “Thief Process”, was tested in a TOXECON TM slipstream at the Pleasant Prairie Unit 1. The mercury reduc tion provided by the Thief carbon was not as high as for conventional PAC injected at the same rate, however, if the cost is significantly less it may justify the higher injection rate . Testing of several other low-cost sorbents such as corn char or treated fly ash, which may provide cost-effective benefits in some cases, has been undertaken. 37 These sorbents may be most useful in a TOXECON TM arrangement, which will both segregate the sorbent from the ash and provi de improved gas-sorbent contact so that even low capacity sorbents can provide good performance without impa cting fly ash quality. Another possibility is to use a low-cost sorbent in co mbination with an additi ve to enhance sorbent capacity.

As discussed in the previous sections, chlorine pl ays an important role in facilitating the capture of Hg 0 on sorbent. For low-rank fuels in particular, th ere may not be adequate chlorine to achieve high Hg 0 capture efficiency with PAC. Use of halogenated PAC sorbents comprises one approach. Another is to inject a chemical into the fuel, or into the ga s stream, to provide the halogens needed for high sorbent capacity. At the 220 MW Leland Olds plant firing lignite coal and equipped with CS-ESPs, a Sorbent Enhancement Additive (SEA) has been tested. SEA, a fuel additive, was added between the feeders and pul verizers. For the field tests, average baseline mercury removal was 18% and the objective was to determine the treatment regimen to reach 55% removal. A one month test with SEA and PAC showed that a 63% mercury removal rate was achieved over the period. 38 Therefore, as an alternative to more expensive sorbents, it may be possible to use standard PAC, or even less expensive sorbents, along with an additive, when such additives are broadly available.

Potential Plant Impacts Rela ted to Sorbent Injection

Sometimes a technology may be very useful in reducing the pollutant requi red, but result in other adverse side effects that could significantly impact the plant re liability. The following are some issues that have been considered as possible concerns for sorbent injection.

Impact of PAC injection on downstream PM collector Calculations reveal that the increase in PM load ing to the ESP or FF due to PAC injection would be relatively modest (see Figure 17). For exampl e, at a standard PAC injection rate of 10 lb/MMacf, with an ESP arrangement, about a 4% or less increase in total ash loading will be expected. For most applications, ha logenated sorbents will likely be injected at rates less than 5 lb/MMacf and incremental PM loading in flue gas will be limited to a bout 2 percent. Thus, change in PM loading from PAC or halogenate d PAC injection may be less than the loading change expected from routine fuel or fuel batch changes at a power plant. Consequently, concerns related to impact on ESP performance generally should not relate to increased mass loading with injection of these sorbents. In fact, in full-scale tes ting on large (SCA > 400) and small (SCA~140) ESPs, no adverse impact was shown on PM removal performance. 23, 39 Results from Brayton Point shown in Figure 18 reflect th at ESP operation did not change with increase in PAC injection rate, even when th is rate was as high as 20 lb/MMacf. 23

22Balance-of-plant impacts resulting from standa rd carbon injection are un der investigation at Georgia Power’s Yates Units 1 and 2, which ar e equipped with CS-ESPs with SCA’s 173 and 144 ft 2 /kacfm, respectively. During parametric ACI test s on these units, sorbent was injected at rates ranging from 2 lb/MMacf to greater than 12 lb/MMacf. 40 It was observed that at both units, ESP arc rates within all fields in creased from 0 to 1 arcs/min to greater than 10 arcs/min. In some instances arc rates as high as 35 arcs/min were observed, but the arcing was very sporadic in
nature. 41 Since arcing can degrade ESP PM capture performance, this was addressed in the subsequent one-month duration longer-term te sting conducted on Unit 1 in the period midNovember through December 2004. Observations from longer-term tests are pending. In the longer-term testing, however, it was noted that so rbent injection rate greater than 4.5 lb/MMacf did not result in increased mercury removal, which ranged from 71-96% across the system. 42 Thus it appears to be unclear at this time if in creased ESP arcing will occur at practical injection rates. Results from the longer-term testing at Yates Unit 1 should provide valuable information in this regard and this issu e needs further investigation.

Measurements of PM concentrations at the outle ts of ESPs at Yates Units 1 and 2, taken during parametric and longer-term testing, reflected that 70% of these measured concentrations were within, or less than, those measured during base line testing. PM concentrations greater than baseline values were measured when sorbent in jection rates were in ex cess of 4.5 lb/MMacf. It was observed that injection rates greater than 4.5 lb/MMacf did not appear to provide additional mercury removal beyond that obtained at 4.5 lb/ MMacf. Thus, it is not clear if unacceptable excursions in ESP outlet PM concentration will take place at practical injections rates. It was also observed that the highest ESP outlet PM concen tration (0.3 lb/MMBtu) o ccurred at a sorbent injection rate of 17 lb/MMacf. 42 Based on these observations, the potential for unacceptable PM emissions occurring due to sorbent injection at plants with small ESPs needs further investigation.

Yates Unit 1 is equipped with a Jet Bubbling Re actor FGD. During longer-term testing, samples of the scrubber slurry were taken periodical ly. During the period of 25 November through 10 December the scrubber slurry was observed to be e ither black or dark in color, while the carbon injection rate typically ranged fr om 4 - 6 lb/MMacf (with a few, brief periods at higher rates). Between November 25 and 29, the scrubber slurry wa s its darkest color, w ith its color slowly lightening over this time period. Prior to this time pe riod, the scrubber slurry did not exhibit any visual evidence of carbon contamination. In the s ubsequent time period, the carbon injection rate was as high as 12 lb/MMacf, yet no further darkening was observed. Furthermore, while occasionally high PM concentrations were measured at the ESP outlet, no visible sign of carbon was noted on any of the particulate measurement train (Method 17) filters. From this limited set of data, it was observed that the breakthrough of carbon to the scrubber did not appear to be directly related to the magnitude of the carbon injection rate. Slurry samples will be analyzed to further evaluate this issue. 42

TOXECON TM results from Gaston have indicated, however , that retrofit FF will need to be sized properly to maintain acceptable FF pulsing freque ncy. Also, longer -term (24 days) halogenated carbon (E-3) injection tests on the SDA/FF system at Stanton Unit 10 43 revealed that the cleaning frequency of the FF increased to every 3 to 4 hour s, as compared to 6 to 8 hours during baseline operation without sorbent injection. However, during sorbent injecti on tests, the slurry feed to

23the SDA was varied to accommodate variations in coal sulfur conten t, which did not occur during the baseline testing. Since slurry feed ra te can affect the frequency of FF cleaning, it was not possible to quantify the contribution of the so rbent injection to the changes in FF cleaning cycle. However, it was estimated that sorbent injection increased PM loading by a small amount, nominally 0.2% at an injecti on rate of 1 lb/MMacf and this small increase likely did not influence FF cleaning cycle. In addition to a chan ge in cleaning frequency, a 4 - 6% increase in opacity was also observed for a very short time period (< 5 minutes) immediately after each FF cleaning step.

Potential for increase in fine PM emissions Typically, the median of the par ticle size distribution for PAC or halogenated PAC sorbents is about 20 μ m, and less than 5% of the sorbent particle mass is fine PM (i.e., less than 2.5 μ m in size). 44 Calculations suggest that the increase in fi ne PM loading (i.e., fine PM mass added with sorbent injection relative to total PM mass in th e flue gas) with sorben t injection rate of 10 lb/MMacf would be less than 0.2%. Further, fine PM removal efficiency of ESPs has been noted to be about 96%. 45 Accordingly, sorbent injection would be expected to increase direct fine PM emissions by less than 0.01%. These indications , however, need to be substantiated with
measurements.

Fly ash sale for concrete manufacture As discussed above, there is some concern a bout the impacts to mark eting of fly ash for beneficial reuse, especially when the ash is used as a cement additive. This is more of a concern for units with ESPs where standard PAC treatment rate could be high enough to cause a problem with fly ash sales. But, it may also be a concern in some plants equipped with a FF. At this time there are a few technical approaches that may m itigate such concerns. One is segregating the fly ash with a TOXECON TM system. This, however, would entail higher capital costs. TOXECONII TM may offer a lower cost approach , but it is under early testing. Fi nally, the last and the lowest capital cost approach – specially formulated sorb ents - is under development as discussed above.

Adverse effects of PAC or additives on downstream equipment So far, none of the test programs have show n any significant adverse impact to downstream equipment from the injection of PAC. Additives used to enhance PAC performance or other sorbents that may be used, however, might cau se adverse effects on plant components. The potential for such impacts would have to be ev aluated through long-term field testing conducted over time periods of several months or more.

Other Considerations Associated with Broad -Scale use of Sorbent Injection Systems

An assessment of the potential for broad-scale use of sorbent injecti on systems for mercury control has to take in to consider ation retrofitting time frames that may be necessary to install the equipment and the availability of sorbents and associated hardware. These considerations are described below.

Retrofitting time frames and availability of hardware A dry sorbent injection system is comprised of a storage silo, metering valves, blower and pneumatic material handling equipment, piping to the ductwork where injection occurs, and

24associated control hardware. Injection ports are typically installed on lo w-pressure ductwork. All of this equipment is standard hardware that is readily available. EPA estimated that about 15 months would be needed from initial engineer ing review of technologi es by the owner to completion of control technology testing for a PAC injection system without a retrofit FF. 46 The outage could be a week or so due to the minor ch anges to the ductwork that would be needed for the PAC injection system. Retrofitting a PAC inj ection system becomes more complicated if a TOXECON TM arrangement is chosen. In that case, a bout 26 months would be needed from initial engineering review of technologi es by the owner to completion of control technology testing for the PAC injection system.

Since advanced sorbents will generally be inject ed at lower rates and specialized formulations, currently under development, may not adversely impact the value of the fly ash for beneficial reuse, there is a reduced like lihood that addition of a downstream FF or other PM control device modification will be needed. Therefore, retrofit ting time frames for injection systems utilizing advanced sorbents should be the same as thos e for standard PAC syst ems without retrofit FF.

Availability of Sorbents According to Norit, there is adequate excess cap acity in the standard PAC market to absorb significant growth from current demand levels. However, if the regulations for mercury are passed, they would envision that plant(s) to suppl y this market would be built within 2-3 years. 47

In general, halogenated PAC sorbents are made from standard PAC materials and halogens. Based on indications from vendors, supply of PA Cs may not be a constraint in manufacturing adequate amounts of halogenated PACs to provide significant reductions if this technology is used.

B-PAC is currently available from a facility capable of producing 1500 tons/year of sorbent. According to the vendor, production can be expande d in a six month period to meet market demand. 27

Data/Science Gaps and Associated Recommendations

A number of chemical effects appear to be significant; howev er, they are not understood well enough to permit accurate prediction of sorbent performance under all circumstances, which may be desirable for design and selec tion of a sorbent injection system . Some of these effects include:

• The impact that chlorine, or HCl, has on sorbent capacity to adsorb Hg 0 is recognized but not understood in a quan titative way. This is a particular problem for coals with low chlorine levels that produce me rcury mostly in the form of Hg 0

.

• SO 3 is known to interfere with mercury cap ture. But, like chlo rine, a quantitative understanding is lacking. This is important fo r high sulfur boilers or those with flue gas conditioning.

• Mercury concentration and sp eciation may influence the cap ture effectiveness of the sorbent. However, quantitative da ta on this effect is lacking.

25Improved understanding of the chemical effect s may be addressed through continued lab and pilot programs in parallel with th e full-scale demons tration programs.

Mass transfer plays a critical ro le in influencing the effectiveness of a sorbent in capturing mercury, particularly for an application wher e mercury removal is largely in-flight. Some specific issues include:

• The role of sorbent physical characteristics. Reference 24 suggested that particle size distribution plays an important role.

• The relative importance of macr o-scale (mixing of sorbent w ith the gas) versus microscale (diffusion at sorbent-gas interface) mass transfer processes under different conditions will guide sorbent injection system design.

• The extent to which performance can be im proved by improvements in sorbent injection and distribution methods should be evaluated.

To improve understanding of ma ss-transfer effects, further development and validation of models, such as those described in Reference 2 4, should continue in combination with testing.

There are a significant number of boilers with HS-ESPs. Advanced sorbents may have the potential to dramatically reduce th e control cost for these units th at might otherwise need to add a downstream FF at high capital cost. Although HS -ESP test programs are planned, none of the demonstration programs appear to address HS-ESPs on low rank fuels. This data gap may need to be addressed, especially with advanced sorbents.

Efforts evaluating leaching of mercury and other metals from by products of PAC injection have generally shown that leaching of merc ury does not appear to be a concern. 48, 49 The EPA’s Office of Research and Development also has a program to evaluate the potential for leaching of metals from the management of mercury-enriched co al combustion residues (CCRs). To date, an evaluation of CCR’s from five co al-fired power plants has been co mpleted - three facilities with activated carbon injection (A CI) and two with scrubbers. This includes analysis and quantification of the leaching potential for mercury and non-me rcury metals (arsenic and selenium). Results have also been completed to evaluate mercury leaching potential for 5 additional facilities representing 9 units.

The findings to date indicate that , for most management practices , leaching of mercury from fly ash does not appear to be of concern for land disposal of CCRs from facilities with activated carbon injection (for both regular PAC and brom inated PAC). The limited results from scrubber sludge samples suggest that further evaluation is warranted. Leaching results for arsenic and selenium do suggest a potential concern and warra nt further evaluation. Efforts are underway to obtain additional CCRs from a wider-range of coal types and ai r-pollution control configurations. In addition, be tter information on CCR management practices is being obtained to help clarify and document the fate and transp ort of mercury and other metals. This is an ongoing research program within the EPA’s ORD.

Some concern has been raised that the pres ence of brominated car bon may facilitate the formation of chlorinated and/or br ominated organic air toxics (dioxi ns/furans) in the flue gas.

26In October 2004, the Department of Energy (DOE) sponsored an approximately 30-day continuous B-PAC injection demonstr ation at Detroit Edison’s St. Clair Power Plant. During this 30-day demonstration, an EPA-contracted sampli ng team collected flue gas samples from Unit #1, a 160 MW boiler that was burning PRB coal. Fo r the measured chlorinated and brominated dioxins/furans, only one test (of three) showed a discernible difference in the amount measured as compared to that from the corresponding blank sample. All chlorinated and brominated dioxin/furans measured from the testing at DTE St . Clair were at least an order of magnitude lower than the limit of 60 ng/dscm for large mu nicipal waste combustor (MWC) units with an ESP-based APCS (there are currently no limits fo r coal-fired utility bo ilers). For this reason, ORD does not expect there to be any significant increase in the emission of either the chlorinated or then brominated dioxins/furans from a coal-f ired boiler with the addi tion of B-PAC or other similar brominated activated carbon upstream of a CS-ESP, assuming typical operating temperatures and conditions.

If dioxin/furan compounds were formed in the flue gas, it is likely th at they may actually be captured by unburned carbon in the fly ash and/or on the injected PAC. Samp les of the St. Clair fly ash were subjected to an organic extrac tion procedure to determine if there was enough brominated organic material to pursue a leaching te st. The results were all in the single digit μg/g range. Based on this analysis, it was determined that any brominated compound that may leach from the fly ash would be at or be low the analytical detection limit.

MERCURY CONTROL COSTS ASSOCIA TED WITH SORBENT INJECTION

The cost of applying any technology is comprised of annualized capital co sts, variable operating costs and fixed operating costs. The costs of a so rbent injection system are usually very small compared to other air pollution control equipm ent if addition of a PJFF or other major PM control device retrof it is not performed. According to Re ference 50, capital costs for sorbent injection systems may be in the range of about $5/KW – sometimes less. Being simple pieces of equipment, the fixed operating costs for these syst ems are also relatively low. So, the major costs associated with a sorbent injection system are the cost of the sorbent and the disposal of additional material.

Figure 19 shows estimates of the cost of sorbent and disposal of sorben t for sorbent injection upstream of a CS-ESP. Estimates are made us ing halogenated PAC sorbent cost of $1.00/lb f and PAC sorbent cost of $0.50/lb; disposal is estima ted at a cost of $25/ton. As shown in Figure 19, halogenated PAC is estimated to provide up to about 90% removal at a cost of sorbent and disposal under 1 mill/kWhr (1 mill/kWhr = $1.00/MWhr). Costs for standard PAC are estimated to be greater than those for halogenated PAC due to the significantly higher injection rate that is necessary. At a capital recovery factor of 13.3% and a capacity f actor of 80%, levelized capital charge is approximately 0.1 mills/kWhr, which is significantly less than the variable operating cost associated with sorbent injection and disposal . A potential cost that is not included here is the cost of fly ash disposal in the event that fly ash is currently being sold for beneficial reuse but

f Vendors claim that halogenated PACs cost about $0.75/lb today. However, considering the more developmental nature of these sorbents and the fact that these are aime d at a relatively narrow mark et, conservatively $1.0/lb was assumed in this analysis. It is recognized, however, that if thes e sorbents are available at $0.75/lb under future market conditions, costs associated with their use will only be less than indicated.

27must be disposed of if contaminated with carbon. Since most plants do not currently sell their fly ash, this is not an incremental cost for them. Howe ver, for the minority of pl ants that sell their fly ash, the incremental costs are estimated to be in the range of 0.38 to 1 mill/kWhr, depending upon heating value and ash content of the coal and the heat ra te of the unit and assuming a differential between fly ash revenu es and disposal cost of $30/ton. 50

Figure 20 shows the results of sim ilar cost calculations for PAC injection upstream of a FF. The cost advantage of halogenated PAC over standard PAC when injected upstream of a FF is not expected to be as great as when injected upstr eam of a CS-ESP. Regardless of the sorbent, 90% removal appears to be possible at sorbent a nd disposal costs well below 0.50 mills/KWhr when this technology is available (see a discussion of the outlook for technology availability in a subsequent section). For facilities that sell their fly ash for concrete, if the fly ash is rendered unmarketable, the differential cost to dispose of the fly ash is sim ilar to that described above for CS-ESP.

EXPECTED RESULTS IN NEXT TWO YEARS

The ongoing research activities into control of mercury are proceeding at a rapid pace. Much has been learned in the last year, and more progress is anticipated over the ne xt two years. There are several test programs planned over th e next year that will explore:

• Mercury capture by FGD and the impact of SCR on FGD capture.

• Use of advanced sorbents in difficult confi gurations, such as HS-ESP, and sorbents that are formulated to work with concre te additives when ash is disposed.

• Start up of the first commercial full-scale TOXECON TM system designed expressly to accommodate sorbent addition.

• Testing of advanced sorbents at units with HS-ESPs without a downstream FF.

• Methods to enhance capture of mercury by existing equipment by fuel additives, oxidizing chemicals, or oxidati on catalysts upstream of FGD.

• Methods to enhance capture of mercury by stan dard PAC or low cost sorbents using fuel additives, oxidizing chemicals, or oxi dation catalysts upstream of FGD.

• Further evaluation of the fate of mercury in wall-board produced from FGD by-product to assure that it does not b ecome volatilized and released.

Data available from above testing should help in advancing the development of a broad suite of viable mercury control approaches.

OUTLOOK FOR TECHNOLOGY AVAILABILITY

In order to examine the status of technology and the factors affecting its availability, Table 9 summarizes the available information to reflect po tentially viable mercury control approaches for various boiler configuration a nd coal type combinations. As can be appreciated from the information included in the table, technology availa bility will: (1) vary by boiler configuration and coal type; (2) depend on avai lable data (direct and relevant) with much more data expected in the next 2 years; and (3) de pend on regulatory framework, i.e., a spectrum from minimum risk to technology forcing. The princi ple concerns relating to broad-s cale use of mercury controls are

28the reliability of mercury reductions possible and the risks of advers e side effects. To the extent that required mercury reductions are within th e capabilities of the technology with minimum risks of side effects, mercury controls could be considered available. However, as discussed in this paper, there remain some questions regardin g their performance relative to broad-scale use. These questions are being invest igated in ongoing efforts.

In the February 2004 ORD White Paper, it was projected that PAC in jection technology would be available after 2010 for commer cial application on all key comb inations of coal type and control technology and that mercury removal le vels in the 70% to 90% range could be achievable. In the same white paper, it was projected that enhanced multipollutant control systems (PM controls + dry FGD, PM controls + wet FGD, or SCR + PM controls + dry or wet FGD) would be available after 2010 to provide removal levels between 60 and 90 %. Finally, the February 2004 White Paper also projected that op timized multipollutant control would be able to provide 90-95% mercury removal for all coals after 2015. These projections assumed the funding and successful implementation of an aggressive, comprehensive RD&D program.

As discussed in this document, since the releas e of the earlier White Paper, additional data, mostly from short-term tests, have become av ailable on mercury control approaches for power plants. Also, a broad and aggressive RD&D pr ogram is underway, which will yield experience and data in the next few years. Accordingly, OR D continues to believe that PAC injection and enhanced multipollutant controls will be av ailable after 2010 for comm ercial application on most, if not all, key combinations of coal type and control technology to provide mercury removal levels between 60 and 90%. However, c onsidering the progress ma de with halogenated PAC sorbents and other chemical injection a pproaches, it is now believed that optimized multipollutant controls may be available in the 2010-2015 timeframe for commercial application on most, if not all, key combinations of coal type and control tec hnology to provide mercury removal levels between 90 and 95%. Such optimi zed controls could include less expensive use of sorbent (PAC or halogenated PAC) injec tion with enhanced SCR and/or enhanced FGD systems.

A national retrofit program can be initiated afte r the technology is available. However, full implementation of such a retrofit program would take a number of years to accomplish and achieve emission reductions, since large numbers of utilities would need time to order, design, fabricate and test such units. Based on EPA experience with coal-fired utility boiler retrofit technologies, we estimate that once a utility has signed a contract with a vendor, installation on a single boiler could be accomplished in the following timeframes:

• Sorbent injection upstream of an existi ng ESP or FF could be installed with commissioning complete in six months to 1 year;

• Sorbent injection upstream of a retrofit fabric filter (e.g., COHPAC) could be retrofitted to an existing ESP in under 2 years;

• A new SCR/FGD/PM/mercury control system c ould be retrofitted in 2-3 years dependent on the retrofit difficulty g ; and,

g It is important to note that due to the high capital cost of SCR and FGD, these technol ogies are not expected to be installed solely on the basis of mercury removal, but pr imarily on the basis of contro lling other pollutants, because much less costly mercury removal methods are available.

29• Existing SCR or FGD to enhance mercury contro l could be retrofitted in about one to two
years.

The installation timeframes described above incl ude the time periods asso ciated with control technology fabrication, delivery, construction, and testing; approval of construction permit; and modification of operating permit.

SUMMARY

Although the potential mercury emissi ons from coal-fired U.S. utility boilers are calculated to be 75 tons per year based on the mercury content in coal, the actual current emissions are estimated to be 48 tons per year due to mercury cap ture with pollution controls for PM and SO 2 . NOx controls can augment mercury capture in PM and SO 2 control equipment. And, with increased use of NOx and SO 2 pollution controls in the coming year s as shown in Table 2, the co-benefit removal of mercury from these controls is expect ed to be significantly increased. Furthermore, it may be possible to operate these pollution controls in a way to improve mercury capture without sacrificing control of other pollutants. RD&D efforts aimed at enhancing mercury removal of existing controls in the next ye ar should provide information on strategies to maximize mercury co-benefits.

RD&D activities relating to sorbent injection fo r mercury removal over the last year have shown significant advances in this te chnology. Although most test program s have taken place over a few days, some have run for several weeks, and one has run for 6 months. These longer term tests have confirmed the performance of short term tests, and have also provided insights related to operating concerns expressed by pl ant personnel. At this time no serious adverse effects on the plant have been found with sorb ent injection for tests up to on e month in duration. Moreover, control approaches have been tested at the full scale and pilot scale und er conditions that were previously shown to be difficult for standard PAC. These approaches, involving advanced sorbents, fuel blending, and fuel additives, appe ar to provide effective and less expensive means to address some of the mercury control difficult y previously identified with low rank coals. Halogenated PAC sorbents have shown particularly impressive results; they have been tested on a number of different facilities ove r a range of fuels and appear to capture mercury effectively for a given configuration regardless of fuel type. Also , no balance-of-plant impacts have been reported in field tests conducted thus far.

Some key observations are as follows:

1. Projections reflect that current and future NO X and SO 2 emission reduction requirements are expected to result in growing use of SCR and scrubber systems at coal-fired utility boilers. Ongoing RD&D has the potential to provide the basis for enhan ced mercury removal in such systems. Assuming sufficient RD&D of repres entative technologies, ne w and existing systems installed to control NO X and SO 2 (e.g., SCR+FGD+FF) have th e potential to achieve 90+% control of mercury on bituminous coal-fired boilers. Subbituminous and lignite systems appear to require mercury oxi dation technology and/or additi onal advanced sorbents to achieve these levels.

302. While co-benefit mercury removal from the fl ue gas of boilers firing low rank coals is generally lower than for bituminous coal, methods to improve co-benefit removal – such as fuel blending and fuel additives - have shown great promise. If successful, these approaches will narrow the difference between the various coals. 3. While it is more difficult to rem ove mercury from the flue gas of boilers firing low rank coals with standard PAC injection, new halogenated sorbents appear to offer a very effective and less expensive alternative that can deliver highe r removals than possible with standard PAC alone. However, longer-term demonstrations wi ll be beneficial in that they will provide additional experience and data, which will build confidence in use of these new sorbents. 4. Development and testing of new sorbents or addi tives has proceeded at a very rapid pace, and will likely continue to do so. Sorbent inject ion systems can be installed quickly and new sorbents or furnace additives can be tested relativ ely easily. This is in contrast to more capital intensive technologies like SCR or FGD, which re quire a long time to engineer and install the equipment or to make any significant changes to it , such as a catalyst ch ange. Therefore, it is anticipated that the rapid pace of technology development for new sorbents and chemical additives will continue. 5. There is increased appreciation for the importa nce of mass transfer in the sorbent capture process. Therefore, there is likely to be so me improvement in performance due to improved injection methods, especially for in-flight rem oval. Such enhancements have the potential to improve performance for both standard and new sorbents. 6. Halogenated PAC injection with a CS-ESP has th e potential to achieve 90% mercury control. Standard PAC injection with an ESP (HS or CS) a nd a retrofit fabric filter, or a fabric filter alone, has the potential to achieve over 90% mercury reduction. Proper design and consideration of operational and residue impacts would need to be incorporated. 7. The one application that remains particular ly challenging is units with HS-ESP. This represents about 12% of current coal-fired capacity. Currently , retrofit of a downstream FF after the air preheater and sorb ent injection prior to the FF is the only approach that has proven to be effective for these units at all load conditions. New sorbents have been tested for achieving mercury removal upstream of a HS-E SP. Promising results were achieved with these sorbents at part load conditions. With focused RD&D perhaps these sorbents can be improved to be effective at all load conditions. 8. Cost estimates will vary depending upon specifi c conditions including regulatory structure. Nevertheless, for most units, it is projected th at the mercury removal would add no more than about 2 mills/kWh to the annualized cost of pow er production. For many applications utilizing halogenated PAC sorbents, costs are projected to be generally lower than 1 mill/kWh. For the minority of plants that sell their fly ash and this sale is impact ed due to mercury control, the incremental costs, associated with waste disp osal and lost revenue due to impact on fly ash sale, are estimated to be in the range of 0.38 to 1 mill/kWhr. Control by enhancing/optimizing cobenefit mercury removal in FGD and SCR systems has the potential to reduce costs substantially, since optimized systems may re quire little additional investment and/or operational costs, especia lly for bituminous coals. 9. It is believed that PAC injection and enhanced multipollutant controls will be available after 2010 for commercial application on most, if not all, key combinations of coal type and control technology to provide mercury removal leve ls between 60 and 90%. Also optimized multipollutant controls may be availabl e in the 2010-2015 timeframe for commercial application on most, if not all, key combina tions of coal type a nd control technology to

31provide mercury removal levels between 90 and 95%. Such optimized controls could include less expensive use of sorbent (PAC or halogenated PAC) injection with enhanced SCR and/or enhanced FGD systems. It is noted, however, that broad scale commercial application of control technology to remove mercury will be possible after the technology is available. Therefore, initiation of a potential national retrofit program could take place after the technology is available and such a program would take a number of years to fully implement.

Based on EPA experience with coal-fired utility boiler retrofit technolog ies, we estimate that once a utility has signed a contract with a ve ndor, installation on a si ngle boiler could be accomplished in the following timeframes:

• Sorbent injection upstream of an existi ng ESP or FF could be installed with commissioning complete in six months to 1 year;

• Sorbent injection upstream of a retrofit fabric filter (e.g., COHPAC) could be retrofitted to an existing ESP in under 2 years;

• A new SCR/FGD/PM/mercury control system could be retrofitted in 2-3 years dependent on the retrofit difficulty; and,

• Existing SCR or FGD to enhance mercury cont rol could be retrofit ted in about one to two years.

The installation timeframes described above incl ude the time periods asso ciated with control technology fabrication, delivery, construction, an d testing; approval of construction permit; and modification of operating permit.

32Table 1. General Characteristics of Coals Bu rned in U. S. Power Plants

Mercury Chlorine Sulfur Ash HHV* ppm (dry) ppm (dry) % (dry) % (dry) BTU/lb (dry) Coal Range Avg Range Avg Range Avg Range Avg Range Avg
Bit 0.036 - 0.279 0.113 48 ­ 2730 1033 0.55 ­ 4.10 1.69 5.4 - 27.3 11.1 8646 - 14014 13203

Subbit. 0.025 - 0.136 0.071 51 ­ 1143 158 0.22 ­ 1.16 0.50 4.7 - 26.7 8.0 8606 - 13168 12005

Lignite 0.080 - 0.127 0.107 133 - 233 188 0.8 - 1.42 1.30 12.2 ­ 24.6 19.4 9487 - 10702 10028

* Higher Heating Value

33Table 2 . Projected Coal-Fired Capacity by APC Configuration

APC Configuration Current Capacity, MW 2010 Capacity, MW 2020 Capacity, MW Cold-side ESP 111,616 75,732 48,915 Cold-side ESP + Wet Scr ubber 41,745 34,570 33,117 Cold-side ESP + Wet Scrubber + ACI

- 379 379 Cold-side ESP + Dry Scru bber 2,515 3,161 5,403 Cold-side ESP + SCR 45,984 35,312 22,528 Cold-side ESP + SCR + Wet Scrubber 27,775 62,663 98,138 Cold-side ESP + SCR + Dry Scrubber

- 11,979 13,153 Cold-side ESP + SNCR 7,019 4,576 2,534 Cold-side ESP + SNCR + Wet Scrubber 317 2,830 6,088 Fabric Filter 11,969 10,885 7,646 Fabric Filter + Dry Scr ubber 8,832 8,037 9,163 Fabric Filter + Wet Scr ubber 4,960 4,960 4,960 Fabric Filter + Dry Scrubber + ACI

- 195 195 Fabric Filter + SCR 2,210 2,950 1,330 Fabric Filter + SCR + Dry Scrubber 2,002 2,601 4,422 Fabric Filter + SCR + Wet Scrubber 805 805 2,363 Fabric Filter + SNCR 267 267 345 Fabric Filter + SNCR + Dry Scrubber 559 557 557 Fabric Filter + SNCR + Wet Scrubber 932 932 1,108 Hot-side ESP 18,929 11,763 10,160 Hot-side ESP + Wet Scr ubber 8,724 10,509 10,398 Hot-side ESP + Dry Scrubber

- 538 538 Hot-side ESP + SCR 5,952 3,233 1,847 Hot-side ESP + SCR + Wet Scrubber 688 6,864 9,912 Hot-side ESP + SNCR 684 1,490 1,334 Hot-side ESP + SNCR + Wet Scrubber 474 474 627 Total Existing Units 304,955 298,263 297,161

New Builds of Coal Steam Units Current Capacity, MW 2010 Capacity, MW 2020 Capacity, MW Fabric Filter + SCR + Wet Scrubber

- 221 17,292

Total All Units 304,955 298,484 314,453 Note: IGCC units are not included as part of this list. Note: Current capacity includes some SCR and FGD projected to be built in 2005 and 2006 Note: 2010 and 2020 is capacity projected for final CAIR rule Note: IPM projects some coal retirements and new coal in 2010 and 2020

34Table 3 . Scrubber testing with SCR and/or additive to reduce re-emission of Hg 0 and improve mercury capture.



### Test S i te In for m a t ion Mer c ury Capturury Captur e Across Scrubber, % Scrubber, % Te st /O bservationbservation

Te s t S i te Coal Co ntrols Ele m ent a l Oxidi z ed Total

Dom i n i on R e s o urce s Mo un t S t o r m Me d i u m

sul f ur East ern SC R, Col d -s i d e ESP,
li me s t one fo rced -15% > 9 0 % 71% 4

- da y ; S C R b y -p a s s ed; n o ad di ti v e / H g ( 0 ) re -em i ssion

Po w e r St atio n Un i t 2

, 563 M W bit u m i n o us ox i d at i o n F G D 30% > 9 0 % 78% 4

- da y ; S C R b y -p a s s ed;

w i th ad di ti v e / n o r e

e m i s si on o f H g ( 0 ) 0 > 9 5 % > 9 0 % 6

- da y ; S C R on -l i n e ; no ad di ti v e / n o re

- e m i ssi on of Hg ( 0 ) a n d hig h er Hg

rem o v a l

0 > 9 5 % > 9 0 % 7

- da y ; S C R on -l i n e ; wit h ad di ti v e / n o re

- e m i ssi on of Hg ( 0 ) a n d hig h er Hg

r e mo va l ; no eff e ct f r o m ad di ti v e

35Table 4. PAC test programs on power plant flue gases.

APC Configuration Coal Type Bituminous Subbituminous Lignite CS-ESP Hudson p Brayton Point 1 Salem Harbor 1 Yates 1, 2 Valley p Lausche Miami Fort Allen Conesville Pleasant Prairie 1 Powerton p (TOXECON) St. Clair 1 Meramec Miller p Nantikoke Leland Olds 1 Coal Creek Stanton 1 Poplar River 1, 2

HS-ESP Gaston 3 (TOXECON) Cliffside none none

FF none Comanche 2 p Pleasant Prairie 1, 2 p TOXECON Presque Isle 7-9 TOXECON Spruce

SDA-FF none Holcomb Stanton 10 Antelope Valley 1 PS none Laskin 2 none p: denotes pilot test Italic denotes program not yet completed

Table 5. Relatively short-term PAC injection field test projects.

Test Site Information Mercury Capture, %
Test Site Coal Particulate Control Baseline ACI Test Results “Long-term” Test Duration*

PG&E NEG Brayton Point, Unit 1 Low-sulfur Bituminous Two CS-ESPs in Series 90.8 94.5 ACI for two 5-day periods PG&E NEG Salem Harbor, Unit 1 Low-sulfur Bituminous CS-ESP 90 94 ACI for one 4-day period Wisconsin Electric Pleasant Prairie, Unit 2 Subbituminous CS-ESP 5 65 ACI for one 5-day period

Alabama Power Gaston, Unit 3 Low-sulfur Bituminous HS-ESP + COHPAC 0 25-90 ACI for one 9-day period University of Illinois Abbott Station High-sulfur Bituminous CS-ESP 0 73

* At these plants, both short-term parametric and “long-term” continuous tests were conducted. In each of these tests the “long-term” testing lasted less than 10 days.

36Table 6. Speciated mercury results from ACI field tests.

Particulate Elemen tal Oxidized Total ( μ g/dNm 3 ) ( μ g/dNm 3 ) ( μ g/dNm 3 ) ( μ g/dNm 3 ) Pleasant Prairie (Baseline) ESP Inlet 1.97 12.22 2.51 16.71 ESP Outlet 0.01 9.8 6.01 15.82 Removal Efficiency (%) Pleasant Prairie (ACI, 11 lbs/MMacf) ESP Inlet 99.49

1 19.8

14.7 *

1.7 5.27

17.4 ESP Outlet 0 4.3 0.4 4.7 Removal Efficiency (%) 100 70.75 76.47 72.99 Salem Harbor (Baseline) ESP Inlet 10.15 < 0.27 0.09 < 10.51 ESP Outlet < 0.34 < 0.50 0.41 < 1.25 Removal Efficiency (%) Salem Harbor (ACI, 10 lbs/MMacf) ESP Inlet > 96

4.9 *

< 0.27 *

0.07 ≅ 88

< 5.24 ESP Outlet < 0.09 < 0.51 0.02 < 0.62 Removal Efficiency (%) > 98 * 71.43 ≅ 88 Gaston (Baseline) COHPAC Inlet 0.1 5.5 8.8 14.4 COHPAC Outlet 0 3.1 10.4 13.5 Removal Efficiency (%) Gaston (ACI injection, 1.5 lbs/MMacf) COHPAC Inlet 100

0.2 43.64

4.2 *

5.9 6.25

10.3 COHPAC Outlet 0.1 < 0.1 0.8 1 Removal Efficiency (%) 50 > 97 86.44 90.29

* Efficiency calculation not appr opriate because outlet value is greater than inlet value.

37 Table 7. Full-scale halogenated PAC testing.

Coal Type PM Control Hg Removal (%) Sorbent Injection Rate (lb/Mmacf) Plant Testing Period Duration

Sub-bit Blend CS ESP 94 B-PAC 3.0 St. Clair Oct-04 30 day continuous

Sub-bit Blend SD/FF 93 E-3 1.2 Holcomb Jun-04 30 day continuous

Sub-bit CS ESP 80-90+ E-3 4.0 - 4.5 Meramec Oct-04 10 day continuous

Bit High-S CS ESP 70 B-PAC 4.0 Lausche Jan-03 2 - 3 hr tests

Bit Low-S HS ESP >80 B-PAC 6.4 Cliffside (minimum load) Sep-03 2 wks parametric

40 B-PAC 5.7 Cliffside (full load) do do Lignite SD/FF 95 B-PAC 1.5 Stanton 10 early 2004 2 hr parametric Lignite * 70 B-PAC 1.5 Stanton 10 early 2004 2 hr parametric Lignite SD/FF 95 E-3 1.5 Stanton 10 early 2004 2 hr parametricTable 8. Speciated mercury results from hal ogenated PAC injection field tests.

Particulate Elemen tal Oxidized Total ( μ g/dNm 3 ) ( μ g/dNm 3 ) ( μ g/dNm 3 ) ( μ g/dNm 3 ) Meramac (Baseline) ESP Inlet 3.54 9.03 2.2 14.77 ESP Outlet 0 6.57 2.73 9.3 Removal Efficiency (%) Meramac (E-3 injection, 3 lbs/MMacf) ESP Inlet 100

3.2 27.2

3.8 *

3.1 37.03

10.1 ESP Outlet 0 0.4 0.2 0.6 Removal Efficiency (%) 99.9 89.47 93.55 94.06 Holcomb (Baseline) Inlet 0.47 7.71 2.38 10.56 Outlet 0.01 10.75 0.47 11.23 Removal Efficiency (%) Holcomb (E-3 injection, 1.2 lbs/MMacf) Inlet 97.87

0.01 *

8.49 80.25

0.9 *

9.4 Outlet 0 0.39 0.1 0.49 Removal Efficiency (%) 100 95.4 88.89 94.8 St. Clair (Baseline) ESP Inlet 0.11 7.18 0.61 7.9 ESP Outlet < 0.01 6.99 4.24 11.23 Removal Efficiency (%) St. Clair (B-PAC injection, 3 lbs/MMacf) ESP Inlet > 90.9

0.26 2.65

7.11 *

0.97 *

8.08 ESP Outlet < 0.1 0.38 0.55 0.93 Removal Efficiency (%) > 61 94.66 43.3 87.65 *Efficiency calculation not appr opriate because outlet value is greater than inlet value.

38Table 9. Potentially most-suitable mercury control appro aches for various boiler configuration and coal type combinations.

Coal/Technology,

(Capacity, %) h Incremental Mercury Control Direct Experience i Relevant Experience j Remaining Issues Ongoing Efforts

Subbit + CS-ESP – w/ or w/o SCR (~66 GW, 22.3%) Hal-PAC > 90% St. Clair (80 MW tested); 80­ 90% Meramec (70 MW tested) None a) Direct experience with longer-term testing; testing with larger duct sizes; air toxics; ESP impacts, residue impacts; long-term corrosion; sorbent supply. DOE Phase II Round 1: 30-day testing with E-3 at DTE Monroe 4 (375 MW), November 2005

DOE Phase II Round 2: 30-day continuous testing with B-PAC at Midwest Gen Crawford 7 (100 MW), TBD

DOE Phase II Round 2: testing with Alstom’s enhanced sorbent at PacificCorp. Dave Johnston plant, TBD Low-S bit + CS-ESP – w/ or w/o SCR (~ 55 GW, 18.6%) Hal-PAC None > 90% St. Clair (80 MW tested); 80­ 90% Meramec (70 MW tested) Same as a) DOE Phase II Round 2: 30-day continuous testing with B-PAC at Progress E. Lee 1 (80 MW), TBD

DOE Phase II Round 2: testing with Alstom’s enhanced sorbent at Reliant En. Portland unit, TBD

h These numbers were generated using the fo llowing approach: (1) current capacity numbers are from information in Table 2; (2) breakdown of coal production was taken from DOE Energy Info rmation Administration, Annua l Coal Report 2003, Table 6, available at (http://www.eia.doe. gov/cneaf/coal/page/acr/table6.html). This re flected production of bituminous, subbituminous, and lignite in 2003 of 51.5%, 41.3%, and 7.7%, respectively; (3) coal production pattern was considered to be similar to usage in electric utilities; (4) coal usage pattern was approximated to 50% bituminous, 40% subbituminous, 5% ND lignite, and 5% TX lignite; and (5) 1/3 of bituminous coal consumed in power plants was considered to be high-sulfur and the remaining 2/3 was assumed to be low-sulfur. i Direct experience is where experience is available with the exact combination of coal type, existing control technology, and mercury technology. j Relevant experience is where applicable experience appears to be available even though not with the exact combination of coal type, existing control technology, and mercury technology.

39Table 9. Potentially most-suitable mercury control appr oaches for various boiler configuration and coal type combinations; (continued).

Coal/Technology,

(Capacity, %) Incremental Mercury Control Direct Experience Relevant Experience Remaining Issues Ongoing Efforts

Hi-S bit + CS-ESP + Hal-PAC None 70% Lausche Same as a) + DOE Phase II wet FGD (~42 GW, (18 MW impact on FGD Round 1: 30-day 14.2%) tested) testing with E-3 at AEP Conesville (500 MW), June 2005 Coal + HS-ESP TOXECON; >90% Gaston None b) Direct DOE Phase II (~35 GW, 12.0%) possibly HalPAC (135 MW tested) experience with longer-term testing; FF impacts, residue impacts; sorbent supply. Round 1: 30-day continuous testing with B-PAC at Duke En. Buck 5 (140 MW), low-S bit., spring 2005

DOE Phase II Round 2: 2-week parametric test with B-PAC at Progress En. Lee 2 (75 MW), low-S bit., TBD

DOE Phase II Round 2: 2-week parametric test with B-PAC at Midwest Gen Will County 3 (130 MW), TBD Hi-S bit + CS-ESP + Hal-PAC None >80% various Same as a) + SCR + wet FGD (trim), if data on wet impact on FGD (~28 GW, 9.4%) needed. SCR + FGD should provide high removal. FGD + SCR; 70% Lausche (18 MW tested)

40Table 9. Potentially most-suitable mercury control appr oaches for various boiler configuration and coal type combinations; (continued).

Coal/Technology,

(Capacity, %) Incremental Mercury Control Direct Experience Relevant Experience Remaining Issues Ongoing Efforts

Hi-S bit + CS-ESP – TOXECON None (coal ICR data and Same as b) w/ or w/o SCR (~27 effects less > 90% Gaston GW, 9.3%) significant with FF) (135 MW tested)ND Lignite + CSESP – w/ or w/o SCR (~8 GW, 2.8%) Hal-PAC None > 90% St. Clair (80 MW tested); 80­ 90% Meramec (70 MW tested) Same as a) DOE Phase II Round 2: testing with Alstom’s enhanced sorbent at Basin Electric Leyland Olds, TBDTX Lignite + CSESP – w/ or w/o SCR (~8 GW, 2.8%) Hal-PAC None > 90% St. Clair (80 MW tested); 80­ 90% Meramec (70 MW tested) Same as a) DOE Phase II Round 2: 30-day testing with PAC and advanced sorbent (TBD) at TXU Big Brown (300 MW), TOXECON configuration, TBD Low-S bit + FF – w/ PAC None (high ICR data and Same as b) or w/o SCR (~ 7 intrinsic > 90% Gaston GW, 2.4%) removal expected) (135 MW tested) Subbit + FF – w/ or PAC Comanche 2 ICR data; > Same as b) w/o SCR pilot (600 90% Gaston (~6 GW, 2.0%) acfm tested) - >90% possible. Good performance expected with FF. (135 MW tested)

41Table 9. Potentially most-suitable mercury control appr oaches for various boiler configuration and coal type combinations; (continued).

Coal/Technology,

(Capacity, %) Incremental Mercury Control Direct Experience Relevant Experience Remaining Issues Ongoing Efforts

Medium-S bit + PAC (trim), if None (high ICR data and > Same as b) SD+FF – w/ or w/o needed intrinsic 90% Gaston SCR (~6 GW, 1.9%) removal expected) (135 MW tested) Subbit + SD+FF – w/ or w/o SCR (~5 GW, 1.5%) Hal-PAC > 90% Holcomb (360 MW tested) None Same as a); duct size may not be an issue for FF applications ND Lignite + FF – w/ or w/o SCR (~0.7 GW, 0.2%) PAC None. Good performance expected with FF. Comanche 2 pilot (600 acfm) - >90% possible

ICR data; > 90% Gaston (135 MW tested) Same as b)

ND Lignite + SD+FF – w/ or w/o SCR (~0.5 GW, 0.2%) Hal-PAC > 90% Stanton MW test 10 (60 ed) None Same as a); duct size may not be an issue for FF applications TX Lignite + FF – w/ or w/o SCR (~0.7 GW, 0.2%) PAC None. Good performance expected with FF. Comanche 2 pilot (600 acfm tested) - >90% possible

ICR data; > 90% Gaston (135 MW tested) Same as b)

TX Lignite + SD+FF – w/ or w/o SCR (~0.5 GW, 0.2%) Hal-PAC None. Good performance expected with FF. > 90% Stanton 10 (60 MW tested) Same as a); duct size may not be an issue for FF applications

42Figure 1 . Projected coal-fired capacity with FGD

200

180

160

140

120

100

80

60

40

20

0 Current 2010 2015
CAIR Retrofits Existing or CAA Title IV/State RetrofitGW

Figure 2. Projected coal-fired capacity with SCR

200

180

160

140

120GW

Current 2010 2015 100

80

60

40

20

0

CAIR Retrofits Existing or NOx SIP Call/State Retrofit

43Figure 3. Mercury removal rates measured for various coal types and air pollution control configurations (from EPA ICR data, 1999).

Bituminous Coal Sub-bituminous Coal Lignite 100 100 100

90 90 90

80 80 80Mercury Removal (%) 70

60

50

40

30

20

10

0 70

60

50

40

30

20

10

0 70

60

50

40

30

20

10

0CS-ESPHS-ESPFFFF/SDACS-ESP/FGDHS-ESP/FGDCS-ESPHS-ESPFFFF/SDACS-ESP/FGDHS-ESP/FGDCS-ESPCS-ESP/FFFF/SDACSESP/FGD

Figure 4. Effect of liquid-to-gas ratio on mercury emission at common operating pH values. 51

44Figure 5. Mercury removal of various FGD systems

0 10 20 30 40 50 60 70 80 90 100S2: ESP+MEL-Bit_1C8: ESP/MEL-BitCa: MELCf: MELZimmer: ESP MELS4: Lime Ven-Bit_1S4: Lime Ven-Bit_2S5: ESP+LSFO-BitC5_2: ESP+LSFO-BitCb:LSFOEndicott: ESP+LSFOMt. Storm: SCR+ESP+LSFOCd: ChiyodaCc: LSNOCe: LSNOC1: SDA/FF-BitC2: SDA/FF-BitHg Removal (%)

% Hg(total) Removal w /o SCR % Hg(total) Removal w / SCR MEL Lime Venturi LSFO JBR LSNO SDA

45Oxidized Hg into ESP (%) Figure 6. Percent oxidized mercury into ESP.

0 10 20 30 40 50 60 70 80 90 100 % Hg(2+) - no SCR % Hg(2+) - w ith SCRS1: ESP-PRBS2: ESP+MELBit_1S2: ESP+MELBit_2S3: ESP-BitS4: Lime VenBit_1S4: Lime VenBit_2S5: ESP+LSFOBitS6:ESP-BitC1: SDA/FF-BitC2: SDA/FF-BitC8: ESP/MEL-BitMt. Storm:SCR+ESP+LSFO

Note: there is a possible sam pling artifact with S3

46Figure 7. Options for enhancing mercury capture in existing air pollution controls.

Coal & Air

Oxidizing Chemicals Wet Scrubber

SCR Oxidizing Catalysts

Residue Stack

Ash PM Control

Coal & Air

Oxidizing Chemicals Wet Scrubber

SCR Oxidizing Catalysts

Residue Stack

Ash PM Control

47Figure 8 . Parametric test results of mercury removal by standard PAC- all data using Norit FGD.

0 10 20 30 40 50 60 70 80 90 100Hg removal by PAC (%)

Gaston, Bit, COHPAC

PPPP, Subbit, CS-ESP

Brayton, Bit, CS-ESP

PAC-Pilot-Subbit-FF

0.0 5.0 10.0 15.0 20.0 25.0 Injection Rate (lb/MMacf)

Figure 9. Results of relatively long-term PAC testing at Gaston 52

48Figure 10. Comparison of mercury removal by B-PAC to th at by standard PAC for injection upstream of CS-ESP; standard PAC data is with Norit FGD.

100

90Hg removal by PAC Injection (%) 80

70

60

50

10 20 30 40 BPAC-PPPP ESP Pilot BPAC S10, Lignite (in flight after SDA) BPAC St Clair, Sub, ESP PAC St. Clair, Sub, ESP
PAC at PPPP Brayton, Bit, CS-ESP

0
0 5 10 15 20 Injection Rate (lb/MMacf) 25 30 35

Figure 11. Comparison of mercury removal by B-PAC to that by standard PAC for injection upstream of FF; standard PAC data is with Norit FGD.

100

90Hg removal b y PAC Injection (%) 80

70

60

50

10 20 30 40 Gas ton, Bit, COHPAC
PAC-Pilot-Subbit-FF PAC, Valley, Bit, Pilot FF BPAC, Valley, Bit, Pilot FF BPAC, S10, Lig, SDA/FF PAC, S10, Lig, SDA/FF

0
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 Injection Rate (lb/MMacf)

49Figure 12. Performance of B-PAC in parametric tests are shown for in-flight and upstream of a fabric filter for various coal types.

0 10 20 30 40 50 60 70 80 90 100Hg removal by PAC Injection (%)

BPAC-PPPP ESP Pilot BPAC S10, Lignite (in flight after SDA) BPAC St Clair, Sub, ESP BPAC, S10, Lig, SDA/FF BPAC, Valley, Bit, Pilot FF

0.0 1.0 2.0 3.0 4.0 5.0
Injection Rate (lb/MMacf)

Figure 13. Performance of halogenated PACs ve rsus that with standard PACs. 53

50Figure 14. Results from DOE-sponsored 30-day full-scale testing at DTE St. Clair 80 MW boiler with CS-ESP, firing PRB and an 85:15 P RB:bituminous blend and using B-PAC. 54

Figure 15 . 10-day results from DOE-sponsored full-scale testing at Ameren Meramec 70 MW Unit 2 with CS-ESP, firing PRB and using Norit E-3. 55

51Figure 16. Results from DOE-sponsored 30-day full-scale testing at Holcomb 360 MW boiler with SD+FF, firing PRB blend and using No rit E-3. 55

Figure 17. Calculated incremental particulate loadi ng in the flue gas from sorbent injection

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50 4.00 4.50Incremental Loading (%)

OH bit.

PRB ND Lignite

0 1 2 3 4 5 6 7 8 9 10 11 12
Sorbent Injection Rate (lb/MMacf)

52Figure 18 . ESP power behavior at Brayton Point with increase in PAC injection rate. 56

250 40ESP Total Power (KW) 200 30

150 20 100

10

50

0 0 7/13/02 0:00 7/16/02 0:00 7/19/02 0:00 7/22/02 0:00Injection Concentration(lbs/MMacf)

53Figure 19. Estimated sorbent and disposal costs fo r sorbent injection upstream of a CS-ESP.

100

90Hg removal by Sorbent Injection (%) 80

70

60

50

40

30

20

10

0 BPAC In Flight, Param etric

PAC In Flight Sub/Lig

PAC In Flight Bit

0.0 0.5 1.0 1.5 2.0 2.5 Sorbent and Sorbent Disposal Cost (mills/KWhr)

Figure 20. Estimated sorbent and disposal costs fo r sorbent injection upstream of an FF.

100

90Hg removal by Sorbent Injection (%) 80

70

60

50

40

30

20

10

0 BPAC FF

PAC Sub, FF

PAC Bit, FF

0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50 Sorbent and Sorbent Disposal Cost (mills/KWhr)

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–

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, Air Pollution Prevention and Control Divi sion, National Risk Management Research Laboratory, Office of Resear ch and Development, U.S. Environmental Protection Agency, Research Triangle Park, NC; EPA-600/R-01-109, April 2002. 8 Livengood, C.D., Mendelsohn, M.H., Lani, B.W., “The Chemistry of Mercury Oxidation”, DOE/NETL Mercury Control Technology R&D Program Review, Pittsburgh, PA, July 14-15, 2004 9 Niksa, S., Fujiwara, N., “Predicting Comp lete Hg Speciation Along Coal-Fired Utility Exhaust Systems”, Joint EPRI DOE EPA Co mbined Utility Air Pollution Control Symposium, The Mega Sym posium, Washington, D.C., August 30-September 2, 2004. 10 Niksa, S., Fujiwara, N., “The Impact of Wet FGD Scrubbing On Hg Emissions From Coal-Fired Power Stations”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D. C., August 30-September 2, 2004. 11 Nolan, P., Downs, W., Bailey, R., Vecci, S., “Use of Sulfide Containing Liquors for Removing Mercury from Flue Gases” , US Patent # 6,503,470, January 7, 2003. 12 Renninger, S., Farthing, G., Ghorishi, S.B ., Teets, C., Neureuter, J., “Effects of SCR Catalyst, Ammonia Injection a nd Sodium Hydrosulfide on th e Speciation and Removal of Mercury within a Forced-Oxidized Limestone Scrubber ”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 13 Winberg, S., Winthum, J., Tseng, S., Locke, J., “Evaluation of Mercury Emissions from Coal-Fired Facilities with SCR-FG D Systems”, DOE/NETL Mercury Control Technology R&D Program Review, Pittsburgh, PA, July 14-15, 2004.

5514 Nolan, P., Reddinger, K., Amrhein, G., Kudl ac, G. “Mercury Emissions Control in Wet FGD Systems”, Air Quality III, Cr ystal City, VA, September 9-12, 2002. 15 Chu, P., Laudal, D., Brickett, L., Lee, C.W ., “ Power Plant Evaluation of the Effect of SCR Technology on Mercury”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Sympos ium, Washington, D.C., May 19-22, 2003. 16 Cabral, N.J., “Comments of American Co al for Balanced Mercury Regulations,” EPA docket item OAR-2002-0056-5478, December 2004. 17 Senior, C.L, and Linjewile, T., “ Oxida tion of Mercury Across SCR Catalysts in CoalFired Power Plants”, DOE/NETL Mercury C ontrol Technology R&D Program Review, Pittsburgh, PA, July 14-15, 2004. 18 Sjostrom, S., Starns, T., Amrhein, J., Bust ard, J., Durham, M., Penrod, W., Linville, C., O’Palko, A., Chang, R., “Full-Scale Eval uation of Mercury Control by Injecting Activated Carbon Upstream of a Spray Dryer and Fabric Filter”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 19 Richardson, C., Machalek, T., Marsh, B., M iller, S., Richardson, M., Chang, R., Strohfus M., Smokey, S., Hagley, T., Juip G., Rosvold, R., “Chemical Addition for Mercury Control in Flue Gas Derived from Wester n Coals” Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., May 19-22, 2003. 20 DOE National Energy Technology Laborator y Mercury Field Eval uation – PG&E NEG Salem Harbor Station – Unit 1, Project No. 00-7002-76-10, Field Evaluation Summary Report, January 2003. 21 McDonald, D. K., Amrhein, G. T., Kudlac, G. A., Madden Yurchison, D., “Full-Scale Testing of Enhanced Mercury Control Technologies for Wet FGD Systems”, Final Report, U. S. Department of Ener gy Contract DE-FC26-00NT41006, May 7, 2003. 22 Data provided by Jean Bustard, ADA E nvironmental Services, September 16, 2002. 23 Durham, M., “Field Test Program to Develop Comprehensive Design, Operating and Cost Data for Mercury Control”, DOE/NETL Mercury Control Technology R&D Program Review, Pittsburgh, PA, August 12, 2003. 24 Cremer, M., Senior, C., Chiodo, A., Wa ng, D., Valentine, J., “CFD Modeling of Activated Carbon Injection for Mercury Control in Coal Fired Power Plants”, Joint EPRI DOE EPA Combined Utility Air Pollution C ontrol Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004.; Note: the presented results supersede the results discussed in the paper, and the author should be contacted for the presentation rather than using the conference paper provi ded in the conference proceedings. Contact senior@reaction-eng.com 25 Madsen, J., O’Brien, T., Rogers, W., Cugi ni, A., “Computational Modeling of Mercury Capture by Activated Carbon Injection” , DOE/NETL Mercury Control Technology R&D Program Review, Pittsburgh, PA, July 14-15, 2004. 26 Berry, M., Irvin, N., Monroe, L., Bustard, J., Lindsey, C., Brignac, P., Taylor, T., Schlager, R., Sjostrom, S., Starns, T., Chang, R., O’Palko, A., “Field Test Program for Long-Term Operation of a COHPAC® System for Removing Mercur y from Coal-Fired Flue Gas”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004.

5627 Nelson, S., Landreth, R., Zhou, Q., Miller , J., “Accumulated Power-Plant MercuryRemoval Experience with Brominated PAC Injection”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 28 Nelson, S., “Advanced Utility Sorbent Field Testing Program ”, DOE/NETL Mercury Control Technology R&D Program Revi ew, Pittsburgh, PA, July 14-15, 2004. 29 McCoy, M., Rogers, W., Landreth, R., Brickett, L., “Full-Scale Mercury Sorbent Injection Testing at DTE Energy’s St. Clai r Station”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 30 Carpenter, T., McMurry, R., Potter, S., Mc Ginnis, D., Corey, Q., Nelson Jr., S., Landreth, R., Miller, J., “Mercury Sorbent Results for a Hot-Side ESP at the Cliffside Plant,” EPA docket item OAR-2002-0056-5627, January 14, 2005. 31 Zhou, Q., Zhang, Y., Nelson, S., “Evaluations of Concretes Containing Mercury Sorbents”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 32 Butz, J., “Demonstration of Amended Sili catesTM for Mercury Cont rol at Miami Fort Unit 6 – DOE Project 41988”, DOE/NETL Me rcury Control Technology R&D Program Review, Pittsburgh, PA, July 14-15, 2004. 33 Butz, J., Lovell, J., Broderick, T., Sidwell, R., Turchi, C., “Evaluation of Amended Silicate  Sorbents for Mercury Control”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., May 19-22, 2003. 34 Butz, J., “Demonstration of Amended Sili catesTM for Mercury Cont rol at Miami Fort Unit 6 – DOE Project 41988”, DOE/NETL Me rcury Control Technology R&D Program Review, Pittsburgh, PA, July 14-15, 2004. 35 Monroe, L., Berry, M., Irvin, N., Gale, T., Me rritt, R., Heaphy, R., Ch ang, R., Taylor, B., Licata, A., Beittel, R., “An Evaluation of Ac tivated Carbon and Sodium Tetrasulfide for the Removal of Vapor Phase Mercury from PRB Flue Gas at Pilot-Scale”, Joint EPRI DOE EPA Combined Utility Air Pollution C ontrol Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 36 Freeman, M., Pennline, H., Granite, E., Ha rgris, R., O’Dowd, W., “A Technique to Control Mercury From Flue Gas: The Thief Process”, DOE/NETL Mercury Control Technology R&D Program Review, Pittsburgh, PA, July 14-15, 2004. 37 Ley, T., Ebner, T., Fisher, K., Slye, R., Patton, R., Chang, R., “A ssessment of Low-Cost Novel Sorbents for Coal-Fired Power Plan t Mercury Control”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 38 Thompson, J., Pavlish, J., Holmes, M., Bush, C., Brickett, L., “Enhancing Carbon Reactivity for Mercury Control: Field Test Re sults from Leland Olds”, Joint EPRI DOE EPA Combined Utility Air Pollution Cont rol Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 39 Dombrowski, K., Richardson, C., Machale k, T., Chapman, D., Chang, R., Monroe, L., Berry, M., Irvin, N., McBee, K., Sjostrom, S., “Sorbent Injection for Mercury Control Upstream of Small-SCA ESPs”, Joint EPRI DOE EPA Combined Utility Air Pollution

57Control Symposium, The Mega Symposium, Washington, D. C., August 30-September 2, 2004. 40 Richardson, C., “Sorbent Injection for Sm all ESP Mercury Contro l in Bituminous Coal Flue Gas,” DOE/NETL Mercury Program Revi ew Meeting, Pittsburgh, PA, July 14-15, 2004. 41 Barton, R., McRanie, R., “The Potential E ffect of Activated Carbon Injection on Power Plant Operation,” EPA docket item OAR -2002-0056-5485 Southern Att 1.pdf, December 2004. 42 Richardson, C., “Sorbent Injec tion for Small ESP Mercury Control in Low-Sulfur Eastern Bituminous Coal Flue Gas,” Quarterly Tec hnical Progress Report October 1 – December 31, 2004, prepared for DOE/NETL, January 2005. 43 Machalek, T., Richardson, C., Dombrowski, K., Ley, T., Ebner, T., Fisher, K., Brickett, L., Chang, R., Strohfus, M., Smokey, S., Sjostrom, S., “Full-Scale Activated Carbon Injection for Mercury Control in Flue Gas Derived from North Dakota Lignite,” Joint EPRI DOE EPA Combined Utility Air Po llution Control Symposium, The Mega Symposium, Washington, D.C ., August 30-September 2, 2004. 44 McCann, B., Norit Americas, Inc., persona l correspondence with Hu tson, N., U.S. EPA (NRMRL-RTP, NC), Februrary 16, 2005. 45 AP-42, Fifth Edition, Volume 1 Chapter 1: External Combustion Sources , available at http://www.epa.gov/ttn/chie f/ap42/ch01/final/c01s01.pdf. 46 Engineering and Economic Factors Affecting th e Installation of Control Technologies for Multipollutant Strategies , Air Pollution Prevention and C ontrol Division, National Risk Management Research Laboratory, Office of Research and Development, U.S. Environmental Protection Agency, Research Triangle Park, NC; EPA-600/R-02-073, October 2002. 47 Thomas, B., Norit Americas, Inc., persona l correspondence with Hu tson, N., U.S. EPA (NRMRL-RTP, NC), September 6, 2001. 48 Senior, C., Bustard, C.J., Baldrey, K., Star ns, T., Durham, M., “Characterization of Fly Ash From Full Scale Demonstration of Sorbent Injection For Mercury Control On Coal Fired Power Plants”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., May 19-22, 2003. 49 Aljoe, W., Feeley, T., Murphy, J., and Bric kett, L., “The Fate of Mercury in Coal Utilization By-Products - DOE/NETL’s Res earch Program”, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., August 30-September 2, 2004. 50 Performance and Cost of Mercury and Mult ipollutant Emission Control Technology Applications on Electric Utility Boilers, U.S. Environmental Protection Agency, Office of Research and Development, National Risk Ma nagement Research Laboratory, Research Triangle Park, NC; EPA/600/R-03/110, October 2003. 51 Nolan, P., Farthing, G., Yurchison, D., Holm es, M., “Development of Mercury Emissions Control Technologies for the Power Industry” , Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Atlanta, GA, August 16-20, 1999. 52 Berry, M., Irvin, N., Monroe, L., Bustard, J., Lindsey, C., Brignac, P., Taylor, T., Schlager, R., Sjostrom, S., Starns, T., Chang, R., O’Palko, A., “Field Test Program for

58Long-Term Operation of a COHPAC® System for Removing Mercur y from Coal-Fired Flue Gas”, Paper # 118, Joint EPRI DOE EPA Combined Utility Air Pollution Control Symposium, The Mega Symposium, Washington, D.C., May 19-22, 2003. 53 Original figure from Testimony of Dr. Stev en A. Benson, University of North Dakota, Energy & Environmental Research Center ( EERC) to the U.S. Senate, Committee on Environment and Public Works, Subcomm ittee on Clean Air, Climate Change, and Nuclear Safety, June 5, 2003. The figure modified by Sid Nelson of Sorbent Technologies Corp. to overlay data from dem onstrations of halogenated carbon injection, November 27, 2004. 54 Nelson, S., Sorbent Technologies Corp., pe rsonal communication with Hutson, N., U.S. EPA (NRMRL-RTP, NC), October 17, 2004. 55 Starns, T., “Full-Scale Evaluation of Me rcury Control by Injecting Activated Carbon Upstream of a Spray Dryer and Fabric F ilter”, POWERGEN Conference, Orlando, FL, November 30, 2004. 56 Durham, M., Bustard, J., Starns, T., Sjostr om, S., Lindsey, C., Mart in, C., Schlager, R., Chang, R., Renninger, S., Monroe, L., Berr y, M., Johnson, D. “Full-Scale Results of Mercury Control by Injecting Activated Carbon Upstream of ESPs and Fabric Filters”, POWERGEN Conference, Las Vegas, NV, December, 2003.

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