1 BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
     
    2
     
    3 IN THE MATTER OF: )
    )
    4 PROPOSED NEW 35 ILL. ADM. )
    CODE 225 CONTROL )
    5 EMISSIONS FROM THE LARGE ) RO6-25
    COMBUSTION SOURCES ) (Rulemaking - Air)
    6 (MERCURY)
     
    7
     
    8 HEARING DAY EIGHT
    (Testimony of James Staudt)
    9
    Proceedings held on June 21st, 2006, at 1:30
    10 p.m., at the Illinois Pollution Control Board,
    1021 North Grand Avenue East, Springfield,
    11 Illinois, before Marie E. Tipsord, Hearing
    Officer.
    12
     
    13
     
    14
     
    15
     
    16 Reported by: Beverly S. Hopkins, CSR, RPR
    CSR License No: 084-004316
    17
     
    18
     
    19
     
    20
     
    21 KEEFE REPORTING COMPANY
    11 North 44th Street
    22 Belleville, IL 62226
    (618) 277-0190
    23
     
    24
     
    KEEFE REPORTING COMPANY 1

     
     
     
     
     
    1
    APPEARANCES
    2
    Board Members present:
    3 Chairman G. Tanner Girard
    Board Member Andrea S. Moore
    4 Alisa Liu
     
    5 Board Staff Members present:
    Timothy Fox
    6
    ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
    7 BY: Mr. John J. Kim
    Managing Attorney
    8 Air Regulatory Unit
    1021 North Grand Avenue East
    9 Springfield, Illinois 62794-9276
    On behalf of the Illinois EPA
    10
    BY: Mr. Charles E. Matoesian
    11 Assistant Counsel
    1021 North Grand Avenue East
    12 Springfield, Illinois 62794-9276
    On behalf of the Illinois EPA
    13
    SCHIFF HARDIN LLP
    14 BY: Mr. Stephen J. Bonebrake
    Attorney at Law
    15 6600 Sears Tower
    Chicago, Illinois 60606
    16 On behalf of Dynegy and Midwest Generation
     
    17 BY: Ms. Kathleen C. Bassi
    Attorney at Law
    18 6600 Sears Tower
    Chicago, Illinois 60606
    19 On behalf of Dynegy and Midwest Generation
     
    20 BY: Mr. Sheldon A. Zabel
    Attorney at Law
    21 6600 Sears Tower
    Chicago, Illinois 60606
    22 On behalf of Dynegy and Midwest Generation
     
    23
     
    24
     
    KEEFE REPORTING COMPANY 2

     
     
     
     
     
    1
    JENNER & BLOCK
    2 BY: Mr. Bill S. Forcade
    Attorney at Law
    3 One IBM Plaza
    Chicago, Illinois 60611-7603
    4 On behalf of Kincaid Generation LLC
     
    5 BY: Ms. Katherine M. Rahill
    Attorney at Law
    6 One IBM Plaza
    Chicago, Illinois 60611-7603
    7 On behalf of Kincaid Generation LLC
     
    8 MCGUIRE WOODS LLP
    BY: Mr. James T. Harrington
    9 Attorney at Law
    77 West Wacker Drive, Suite 4400
    10 Chicago, Illinois 60601-1681
    On behalf of Ameren Energy Generating
    11 Company, AmerenEnergy Resources Generating
    Company and Electric Energy, Inc.
    12
    ENVIRONMENTAL LAW & POLICY CENTER
    13 BY: Ms. Faith E. Bugel
    Staff Attorney
    14 35 East Wacker Drive, Suite 1300
    Chicago, Illinois 60601-2110
    15 On behalf of the Environmental Law
    & Policy Center
    16
    AYRES LAW FIRM
    17 BY: Richard A. Ayres
    Attorney at Law
    18 1615 L. Street, N.W.
    Suite 1350
    19 Washington, DC 20036
     
    20 MIDWEST GENERATION
    BY: Kent Wanninger
    21 Manager, Environmental Controls & Strategy
    One Financial Place
    22 440 South LaSalle Street, Suite 3500
    Chicago, Illinois 60605
    23
     
    24
     
    KEEFE REPORTING COMPANY 3

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: Before --
     
    2 After our break this morning, Mr. Zabel brought
     
    3 up some concerns about continuing the hearing on
     
    4 the record. And in consideration of a number of
     
    5 things, and with the idea that we really want to
     
    6 be done as much as possible with the Agency's
     
    7 testimony by Friday, we, the Board, has asked
     
    8 that Dr. Staudt and Dr. Hausman be presented now
     
    9 and that we -- to the extent that Mr. Nelson can
     
    10 help answer those questions, that Mr. Nelson
     
    11 remain with us. But I understand that Mr. Nelson
     
    12 has to leave by four o'clock or so?
     
    13 MR. KIM: Yes.
     
    14 HEARING OFFICER TIPSORD: Excuse me,
     
    15 we're back on the record. Gentlemen, gentlemen,
     
    16 we're back on the record. With that being said,
     
    17 one of the things that led to this decision was
     
    18 consideration of instead of continuing on the
     
    19 record or having new additional hearings between
     
    20 now and the scheduled August hearing, that what
     
    21 might be feasible is written responses to
     
    22 pre-filed questions and then follow-ups to be
     
    23 held in August.
     
    24 And we sort of looked at Mr. Nelson's
     
    KEEFE REPORTING COMPANY 4

     
     
     
     
     
    1 testimony. We think some of Mr. Nelson's
     
    2 testimony and questions that -- that are being
     
    3 directed to him will profit by having his
     
    4 studies, which he has talked about in the record,
     
    5 and so we thought that might be the best use of
     
    6 hearing time through Friday. I'm not saying
     
    7 that's what we're definitely going to do, but
     
    8 that's sort of where we're leaning at this point.
     
    9 So with that being said, we thought it
     
    10 best to go with Dr. Staudt and Dr. Hausman. Mr.
     
    11 Harrington?
     
    12 MR. HARRINGTON: Does that mean we
     
    13 will have a chance to complete, at some point,
     
    14 the cross-examination of Mr. Nelson?
     
    15 HEARING OFFICER TIPSORD: Absolutely.
     
    16 MR. HARRINGTON: There's been several
     
    17 critical areas. His testimony this morning is
     
    18 very emphatic on certain points, which we
     
    19 obviously disagree strongly, and feel that
     
    20 differed also from Dr. Staudt's, so follow-up is
     
    21 very critical for us.
     
    22 HEARING OFFICER TIPSORD: Absolutely.
     
    23 And I do not mean this in any way to cut off your
     
    24 ability to cross-examine or ask questions. Like
     
    KEEFE REPORTING COMPANY 5

     
     
     
     
     
    1 I said, we just thought that perhaps that it
     
    2 might be a better use of our time to go with Dr.
     
    3 Staudt and Dr. Hausman. And, yes, we will -- you
     
    4 will get the opportunity to finish questioning or
     
    5 follow-up with questions of Mr. Nelson, if at
     
    6 worst, the beginning of the August hearing.
     
    7 MR. KIM: Yeah. That's fine. I say
     
    8 that without having talked to Mr. Nelson, but we
     
    9 will do the best we can to accommodate that.
     
    10 We'll talk very emphatically with him.
     
    11 MS. MOORE: We're going to beg him to
     
    12 come.
     
    13 MR. KIM: Yes.
     
    14 HEARING OFFICER TIPSORD: And again, I
     
    15 just want to state, Mr. Nelson, we appreciate
     
    16 your testimony. We appreciate your comments and
     
    17 like -- we think that quite frankly we thought
     
    18 that your questions led themselves to best to
     
    19 answers as far as that they -- they follow-up
     
    20 with more so than -- than either Dr. Staudt or
     
    21 Dr. Hausman or quite frankly anyone else before
     
    22 you because partly that they asked you some more
     
    23 specific questions and these are more general
     
    24 questions. So I thank you very much for your
     
    KEEFE REPORTING COMPANY 6

     
     
     
     
     
    1 time and your testimony.
     
    2 MR. KIM: So it's clear for the
     
    3 record, the modifications you're making is Mr.
     
    4 Nelson will provide written answers to the
     
    5 remainder of his questions that were submitted in
     
    6 pre-filed form, and to the extent it is needed or
     
    7 requested or desired, we would have follow-up of
     
    8 Mr. Nelson, if nothing else, at the outset of the
     
    9 Chicago hearing?
     
    10 HEARING OFFICER TIPSORD: If we do not
     
    11 get to him -- Did you say you'd be back tomorrow,
     
    12 Mr. Nelson?
     
    13 MR. NELSON: Yeah. If you can -- I'll
     
    14 be happy to stay until tomorrow if I could --
     
    15 that way if there are cross-examination
     
    16 questions, then they can submit written
     
    17 questions, I'd will be happy to do that, written
     
    18 answers, but that does not give the opportunity
     
    19 to follow-up questions.
     
    20 HEARING OFFICER TIPSORD: Right. We
     
    21 would make that accomodation at a later date.
     
    22 MR. KIM: As far as that's the only
     
    23 modification we're getting into at this point?
     
    24 HEARING OFFICER TIPSORD: Right.
     
    KEEFE REPORTING COMPANY 7

     
     
     
     
     
    1 MR. KIM: Would you like me to provide
     
    2 both Mr. Hausman -- Dr. Hausman and Dr. Staudt's
     
    3 testimony at the same time?
     
    4 HEARING OFFICER TIPSORD: Let's do
     
    5 both. And let's swear in Dr. Hausman and Dr.
     
    6 Staudt. And, Mr. Nelson, remind you you're still
     
    7 under oath.
     
    8 MR. HARRINGTON: Are we starting with
     
    9 Dr. Hausman or --
     
    10 HEARING OFFICER TIPSORD: Dr. Staudt.
     
    11 (At this point in time Dr. Hausman and
     
    12 Dr. Staudt were sworn.)
     
    13 HEARING OFFICER TIPSORD: For the
     
    14 record this amended testimony of James Staudt is
     
    15 the amended testimony that was allowed by hearing
     
    16 officer order, correct, Mr. Kim?
     
    17 MR. KIM: I'm sorry?
     
    18 HEARING OFFICER TIPSORD: The amended
     
    19 testimony allowed is pre-filed testimony?
     
    20 MR. KIM: That is correct. That is
     
    21 the most recent version of Dr. Hausman.
     
    22 HEARING OFFICER TIPSORD: We will mark
     
    23 that as Exhibit No. 50 if there's no objection.
     
    24 Seeing none, congratulations, Dr. Staudt, you're
     
    KEEFE REPORTING COMPANY 8

     
     
     
     
     
    1 number 50. And the pre-filed testimony of Dr.
     
    2 Hausman, if there's no objection, we will mark
     
    3 that as Exhibit No. 51. Seeing none, it's marked
     
    4 as Exhibit No. 51. And to be clear, we are going
     
    5 to go to Dr. Staudt's questions now at whatever
     
    6 order of questions the Agency would like to
     
    7 begin.
     
    8 DR. STAUDT: Well, I'll start with the
     
    9 Ameren questions. Question No. 1.
     
    10 HEARING OFFICER TIPSORD: Excuse me,
     
    11 identify who you're starting with, please.
     
    12 DR. STAUDT: I'm starting with -- This
     
    13 is Dr. James Staudt. I'm starting with questions
     
    14 from -- questions with James Staudt filed from
     
    15 Ameren. First question is, "Please describe your
     
    16 personal experience in the design, construction,
     
    17 and installation in major pollution control
     
    18 projects at coal-fired electric power plants."
     
    19 My previous employers include Fuel
     
    20 Tech and Research Cottrell, who are both
     
    21 suppliers of air pollution control equipment to
     
    22 the electric utility industry. Research Cottrell
     
    23 sells a wide range of technology including
     
    24 electrostatic precipitators, fabric filters, NOx
     
    KEEFE REPORTING COMPANY 9

     
     
     
     
     
    1 control systems, SO2 control systems. And Fuel
     
    2 Tech is -- so primarily NOx control system.
     
    3 At those employers I served in senior
     
    4 technical management role, involved in a number
     
    5 of electric utility projects in both the design
     
    6 and startup -- at those employers I served in
     
    7 senior technical management role.
     
    8 Since starting Andover Technology
     
    9 Partners in 1997, I worked at several electric
     
    10 utility companies to help optimize an existing
     
    11 air pollution control systems, troubleshoot air
     
    12 pollution control systems and determine
     
    13 cost-effective approaches for pollution control,
     
    14 and I also have software and reports that I've
     
    15 developed that are sold to electric utilities.
     
    16 They are associated with selective catalytic
     
    17 conduction systems which are air pollution
     
    18 control technology.
     
    19 In addition, during -- since forming
     
    20 my own business in '97, during that time I have
     
    21 assisted USEPA in analysis of cost and
     
    22 performance of pollution control systems for
     
    23 utility boilers.
     
    24 HEARING OFFICER TIPSORD: Mr.
     
    KEEFE REPORTING COMPANY 10

     
     
     
     
     
    1 Harrington?
     
    2 MR. HARRINGTON: The variety of roles
     
    3 for working in skills and I'm trying to --
     
    4 HEARING OFFICER TIPSORD: Excuse me,
     
    5 Mr. Harrington. I'm not sure the microphone is
     
    6 on. If it is, could you move a little closer?
     
    7 MR. HARRINGTON: Is that better?
     
    8 HEARING OFFICER TIPSORD: Yes.
     
    9 MR. HARRINGTON: The variety of roles
     
    10 and engineering -- environmental engineering, I'm
     
    11 trying to pin down, you know, where your
     
    12 expertise, particular expertise, do you -- have
     
    13 you done detail design of installations air
     
    14 pollution control installation for power plants?
     
    15 DR. STAUDT: I have supervised
     
    16 detailed design of -- of the systems.
     
    17 MR. HARRINGTON: Have you done the
     
    18 cost estimation for the actual installation of
     
    19 systems?
     
    20 DR. STAUDT: Yes, yes.
     
    21 MR. HARRINGTON: What kind of systems,
     
    22 may I ask?
     
    23 DR. STAUDT: Selective non-catalytic
     
    24 reduction systems and selective catalytic
     
    KEEFE REPORTING COMPANY 11

     
     
     
     
     
    1 reduction systems.
     
    2 MR. HARRINGTON: And was this for
     
    3 bidding purposes too?
     
    4 DR. STAUDT: Yes.
     
    5 MR. HARRINGTON: Have you personally
     
    6 supervised the installation of these systems?
     
    7 DR. STAUDT: Yeah. Actually usually
     
    8 there was a project manager who took that role,
     
    9 but I was also involved in -- in providing input
     
    10 and supervision on the installation and startup.
     
    11 But the details of -- the details usually had a
     
    12 project manager who interfaced with the
     
    13 construction firms.
     
    14 MR. HARRINGTON: Did that project
     
    15 manager report to you?
     
    16 DR. STAUDT: Yes.
     
    17 MR. HARRINGTON: Okay. No questions.
     
    18 HEARING OFFICER TIPSORD: Question No.
     
    19 2.
     
    20 MS. BASSI: I have --
     
    21 HEARING OFFICER TIPSORD: I'm sorry.
     
    22 Ms. Bassi.
     
    23 MS. BASSI: I'm sorry. This is a --
     
    24 this is a administrative thing. I thought
     
    KEEFE REPORTING COMPANY 12

     
     
     
     
     
    1 yesterday, or some day, sometime during these two
     
    2 weeks we were talking about Chris Romaine and Jim
     
    3 Ross being on the panel with Dr. Staudt. Did I
     
    4 -- do I remember that incorrectly?
     
    5 HEARING OFFICER TIPSORD: Mr. Ross is
     
    6 at the back, so he is here. I understand that
     
    7 Mr. Romaine might be present if there were
     
    8 questions he needed to answer.
     
    9 MR. KIM: We can go get him.
     
    10 MS. BASSI: Okay. Well, as I was
     
    11 telling Mr. Kim earlier, I do have a couple of
     
    12 just very short, I promise you, specific
     
    13 questions that I -- one for Mr. Romaine and one
     
    14 for Mr. Kaleel sometime before the end of Friday,
     
    15 if we can accommodate that, please. Sorry to
     
    16 interrupt as well.
     
    17 HEARING OFFICER TIPSORD: That's okay.
     
    18 Question 2.
     
    19 DR. STAUDT: Question 2 is, "Prior to
     
    20 preparing your written testimony in this
     
    21 proceeding and your work on the technical support
     
    22 document, did you perform a detailed study of the
     
    23 existing coal-fired power plant in the State of
     
    24 Illinois?"
     
    KEEFE REPORTING COMPANY 13

     
     
     
     
     
    1 Well, during the course of this work
     
    2 the information has continually improved so
     
    3 starting from -- so -- so -- we've continuously
     
    4 have had better information. The -- When
     
    5 detailed -- In terms of the detailed study of the
     
    6 existing coal-fired powered plants, we did
     
    7 conduct a detail -- did conduct a detailed study
     
    8 all along and that over time our level -- our
     
    9 level of understanding of the equipment did
     
    10 improve, so, and that study was started well
     
    11 before the TSD.
     
    12 HEARING OFFICER TIPSORD: Question No.
     
    13 3.
     
    14 DR. STAUDT: "Were you familiar with
     
    15 the size and design of electrostatic
     
    16 precipitators used on each of these facilities?"
     
    17 My question is: Is this in reference to the
     
    18 prior question which it says -- says on the date,
     
    19 you know, prior to preparing written testimony
     
    20 and the TSD?
     
    21 MR. HARRINGTON: Both before preparing
     
    22 your -- the TSD originally and then as of now.
     
    23 DR. STAUDT: Well, again, this is
     
    24 another situation where although -- while I --
     
    KEEFE REPORTING COMPANY 14

     
     
     
     
     
    1 when I initially started working on this program
     
    2 for the Illinois EPA, I had a general
     
    3 understanding of the situation in terms of ESPs
     
    4 and other -- and other matters, and it has
     
    5 significantly, you know, it's significantly
     
    6 improved over that time.
     
    7 MR. HARRINGTON: Maybe for ease, are
     
    8 you familiar with the document which, I believe,
     
    9 has been marked Exhibit 44?
     
    10 DR. STAUDT: I think so.
     
    11 MR. HARRINGTON: Statewide Coal-fired
     
    12 Electric Utility --
     
    13 DR. STAUDT: Yeah, I think it -- if
     
    14 it's what I think it is. That -- Yeah, I have
     
    15 seen this.
     
    16 MR. HARRINGTON: Is this -- is this
     
    17 the document you relied on or are relying on as
     
    18 of this time for information about the utility?
     
    19 DR. STAUDT: Well, this -- this and
     
    20 other information that it was the -- it was also
     
    21 the inspection reports.
     
    22 MR. HARRINGTON: This and the
     
    23 inspection reports?
     
    24 DR. STAUDT: And are you saying at
     
    KEEFE REPORTING COMPANY 15

     
     
     
     
     
    1 what point in time was I relying on this or -- or
     
    2 if you could give me a specific time?
     
    3 MR. HARRINGTON: When you prepared the
     
    4 TSD, what information did you rely on?
     
    5 DR. STAUDT: I had this information --
     
    6 I had this information. And in addition to this
     
    7 information, there is data that's readily
     
    8 available from EPA on their NEEDS (phonetic)
     
    9 database and also the -- it's submitted as of
     
    10 tool emissions -- or submitted emissions levels
     
    11 for NOx and SO2.
     
    12 MR. HARRINGTON: When you filed the
     
    13 shortcut, that's when you filed your final
     
    14 amended testimony, what data do you then have in
     
    15 your possession?
     
    16 DR. STAUDT: Well, in addition I also
     
    17 had -- I also had this -- the information that
     
    18 you saw from -- you're aware of from the
     
    19 inspection reports.
     
    20 MR. HARRINGTON: The inspection
     
    21 reports and version -- and Exhibit 44?
     
    22 DR. STAUDT: Yes, and Exhibit 44.
     
    23 MR. KIM: And the additional documents
     
    24 that we discussed, I don't think that we reached
     
    KEEFE REPORTING COMPANY 16

     
     
     
     
     
    1 a resolution as to how to handle, the -- This
     
    2 document that we handed out the other day
     
    3 entitled Control Configuration Inspections.
     
    4 MR. HARRINGTON: Okay.
     
    5 HEARING OFFICER TIPSORD: Is this the
     
    6 inspection report that we were just talking
     
    7 about?
     
    8 DR. STAUDT: Yeah, that's what --
     
    9 that's what I was referring to.
     
    10 HEARING OFFICER TIPSORD: And this is
     
    11 the report you're still trying to figure out how
     
    12 to put in the public record?
     
    13 MR. KIM: The last I recall discussion
     
    14 that -- that's where we left it, yes.
     
    15 HEARING OFFICER TIPSORD: We really
     
    16 need to get that in however we can. And -- Well,
     
    17 never mind. Wait until we're off the record. I
     
    18 apologize for interrupting.
     
    19 DR. STAUDT: We're at number 4, I
     
    20 think. "Is it not true that ESPs in Illinois
     
    21 facilities are typically much smaller than those
     
    22 in various studies referred to in the TSD?" The
     
    23 answer is in some cases -- in some cases, yes.
     
    24 MR. HARRINGTON: Have you prepared any
     
    KEEFE REPORTING COMPANY 17

     
     
     
     
     
    1 chart or anything else that indicates to you
     
    2 which are larger and which are smaller between
     
    3 the two line for reference?
     
    4 DR. STAUDT: No, I -- no, I -- well,
     
    5 we have the information -- the information from
     
    6 the inspection reports.
     
    7 MR. HARRINGTON: So you're relying on
     
    8 the inspection reports for those description?
     
    9 DR. STAUDT: That's what I'm relying
     
    10 on for the inspection reports for those
     
    11 descriptions, that's correct.
     
    12 MR. HARRINGTON: But you don't have
     
    13 any separate document that you're relying on?
     
    14 DR. STAUDT: I don't have a separate
     
    15 document that was -- that's been produced or --
     
    16 or that I've obtained for that information. You
     
    17 mean associated with Illinois ESPs?
     
    18 MR. HARRINGTON: Correct.
     
    19 DR. STAUDT: Correct, yes.
     
    20 MR. HARRINGTON: I would suggest that
     
    21 if we don't figure out how to enter the
     
    22 inspection reports themselves, something showing
     
    23 that data that Dr. Staudt was relying on would be
     
    24 useful for the record and for us, obviously, to
     
    KEEFE REPORTING COMPANY 18

     
     
     
     
     
    1 see whether it all got down correctly between
     
    2 various transmissions along the way if he doesn't
     
    3 have this latter one.
     
    4 MR. KIM: We're certainly amenable to
     
    5 that as well.
     
    6 DR. STAUDT: Number 6.
     
    7 MR. HARRINGTON: I think we skipped 5.
     
    8 DR. STAUDT: Oh, I'm sorry. "Were you
     
    9 familiar with the gas conditioning that is used
     
    10 on some of these facilities?" Again, the level
     
    11 of understand -- I was aware and I expected that
     
    12 SO3 conditioning was used at some of the
     
    13 facilities, but now as a result of the site
     
    14 inspections we have more detailed information on
     
    15 specific information.
     
    16 MR. HARRINGTON: Did you take --
     
    17 HEARING OFFICER TIPSORD: I'm sorry,
     
    18 Mr. Harrington. Mr. Zabel?
     
    19 MR. ZABEL: Just so I can get clear
     
    20 the sequence of events --
     
    21 HEARING OFFICER TIPSORD: Excuse me,
     
    22 Mr. Zabel. New court reporter. You need to
     
    23 identify yourself.
     
    24 MR. ZABEL: Oh, I'm sorry. I'm
     
    KEEFE REPORTING COMPANY 19

     
     
     
     
     
    1 Sheldon Zabel. I'm representing Midwest
     
    2 Generation & Dynegy. Dr. Staudt, kind of
     
    3 sequence of events, you assisted in the
     
    4 preparation of the TSD; is that correct?
     
    5 DR. STAUDT: That is correct.
     
    6 MR. ZABEL: And you prepared your
     
    7 first round of testimony before you saw the
     
    8 inspection reports; is that correct?
     
    9 DR. STAUDT: That is correct.
     
    10 MR. ZABEL: And you prepared your
     
    11 second and third round of testimony after you saw
     
    12 the inspection reports; is that correct?
     
    13 DR. STAUDT: That is correct.
     
    14 MR. ZABEL: And did the inspection
     
    15 reports have an impact on the revisions that you
     
    16 made in your second and third round of testimony?
     
    17 DR. STAUDT: Not -- not -- not a great
     
    18 -- not to a great degree.
     
    19 HEARING OFFICER TIPSORD: Mr.
     
    20 Harrington?
     
    21 MR. HARRINGTON: All right.
     
    22 HEARING OFFICER TIPSORD: Ready to go
     
    23 onto question 6?
     
    24 MR. HARRINGTON: Let me finish with 5.
     
    KEEFE REPORTING COMPANY 20

     
     
     
     
     
    1 Did you take the presence of gas conditioning, SO3
     
    2 conditioning in particular, into account when you
     
    3 prepared the TSD, the portion of it?
     
    4 DR. STAUDT: Well, I'm not sure if
     
    5 there's any reference to the gas conditioning in
     
    6 the TSD. I don't remember. I don't recall if I
     
    7 wrote -- if I wrote that in, but I did take -- I
     
    8 -- I don't have -- I don't believe I have a
     
    9 reference to SO3 conditioning in the TSD.
     
    10 MR. HARRINGTON: When you reached the
     
    11 conclusions in the TSD as to the technology that
     
    12 would be required at the various individual
     
    13 facilities, did you take the presence of SO3 gas
     
    14 conditioning into account at that time?
     
    15 DR. STAUDT: At the time of the TSD?
     
    16 MR. HARRINGTON: Well, fine with --
     
    17 DR. STAUDT: On my initial -- initial
     
    18 testimony. Could we read the question back,
     
    19 please?
     
    20 (The Reporter read from the record as
     
    21 follows: When you reached the
     
    22 conclusions in the TSD as to the
     
    23 technology that would be required at
     
    24 the various individual facilities,
     
    KEEFE REPORTING COMPANY 21

     
     
     
     
     
    1 did you take the presence of SO3 gas
     
    2 conditioning into account at that
     
    3 time?)
     
    4 DR. STAUDT: Yes.
     
    5 MR. HARRINGTON: And how did you take
     
    6 it into account?
     
    7 DR. STAUDT: The -- And I think we're
     
    8 going to go -- get into SO3 conditioning quite a
     
    9 bit of detail later so we can either explore that
     
    10 now and -- or -- or not.
     
    11 MR. HARRINGTON: I'm looking
     
    12 particularly at the time you prepared the TSD in
     
    13 the original testimony. I believe you said you
     
    14 took the SO3 conditioning into account in reaching
     
    15 your conclusion?
     
    16 DR. STAUDT: Yeah. I was aware that
     
    17 there was SO3 conditioning and also aware that
     
    18 there are alternatives to SO3 conditioning that
     
    19 can substitute for SO3. There's also -- You can
     
    20 also inject the sorbent upstream of the SO3 so
     
    21 that there is not an interference. And I'm not
     
    22 sure if Sid Nelson testified to that effect or
     
    23 not but he --
     
    24 MR. HARRINGTON: We didn't get to that
     
    KEEFE REPORTING COMPANY 22

     
     
     
     
     
    1 point.
     
    2 DR. STAUDT: Okay. But there's -- the
     
    3 -- I'm aware that Sorbent Technologies has run a
     
    4 test where they were able to address that.
     
    5 MR. HARRINGTON: Did you take all that
     
    6 into account at the time the TSD was prepared or
     
    7 subsequently?
     
    8 DR. STAUDT: Well, it's, you know, if
     
    9 trying to go back and remember specifically all
     
    10 the thoughts that were going through my mind when
     
    11 I wrote the TSD, but I was aware that SO3
     
    12 conditioning was used at Illinois power plants,
     
    13 and I would not have reached the conclusions that
     
    14 are in the TSD without that consideration having
     
    15 -- having known that.
     
    16 MR. HARRINGTON: We will come back to
     
    17 the current situation later, but let me proceed.
     
    18 HEARING OFFICER TIPSORD: Question No.
     
    19 6.
     
    20 DR. STAUDT: "How familiar were you
     
    21 with the sources and chemical compositions of the
     
    22 coals that were consumed at these power plants,
     
    23 including the amount and types of mercury in the
     
    24 coals used at these plants?" As for the types of
     
    KEEFE REPORTING COMPANY 23

     
     
     
     
     
    1 coals, we had the -- originally the
     
    2 information -- I don't know what exhibit this is,
     
    3 the one you brought up earlier --
     
    4 HEARING OFFICER TIPSORD: Exhibit 44.
     
    5 DR. STAUDT: Exhibit 44. That
     
    6 provided information on the coals being used at
     
    7 the plants. In addition to that, as far as
     
    8 mercury content, there was information that --
     
    9 data that was -- let me check my notes here --
     
    10 Massoud Rostam-Abadi of the Illinois Geological
     
    11 Survey provided us information on the mercury
     
    12 contents of various coals used in Illinois, not
     
    13 just Illinois coals but PRB coals, and those
     
    14 provided my -- my understanding of the coals
     
    15 being used at Illinois power plants.
     
    16 MR. HARRINGTON: Is that -- and is
     
    17 that the information that's contained elsewhere
     
    18 in the technical support document you received
     
    19 from the gentleman at the Illinois Geologic
     
    20 Survey.
     
    21 DR. STAUDT: Well, it's referenced in
     
    22 the TSD, that data is referenced in the TSD.
     
    23 MR. HARRINGTON: Was there separate
     
    24 data other than what's contained in the TSD that
     
    KEEFE REPORTING COMPANY 24

     
     
     
     
     
    1 you relied on?
     
    2 DR. STAUDT: Yes. And that was one of
     
    3 the data that -- there was the presentation that
     
    4 he made, that POWERPoint presentation, and that's
     
    5 referenced in the TSD. And I know -- I know that
     
    6 was turned over -- that was given to, you know,
     
    7 the state, I think, should have posted that as a
     
    8 reference.
     
    9 MR. HARRINGTON: We can proceed.
     
    10 HEARING OFFICER TIPSORD: Question No.
     
    11 7.
     
    12 DR. STAUDT: Number 7, "Did you review
     
    13 engineering plans or drawings on these plants to
     
    14 determine the feasible locations for installing
     
    15 the types of technology recommended in your
     
    16 testimony and whether it would provide adequate
     
    17 reaction time prior to ESPS?" I did not have
     
    18 detailed engineering drawings, but later I had
     
    19 the information on the general dimensions of the
     
    20 duct work.
     
    21 It is important to note that there is
     
    22 not a reaction time limitation with halogenated
     
    23 activated carbon sorbent injection. Halogenated
     
    24 sorbent performance is limited by mixing --
     
    KEEFE REPORTING COMPANY 25

     
     
     
     
     
    1 mixing and not by the speed of the chemical
     
    2 reactions. It's mixing that is the time-limiting
     
    3 step. This is because the chemical reactions
     
    4 associated absorption are much faster than
     
    5 mixing; therefore, if appropriate measures are
     
    6 taken to get the sorbent in good contact with the
     
    7 gas stream, less mixing distance is needed.
     
    8 MR. HARRINGTON: Reaction time may be
     
    9 the wrong choice of words there. Is contact time
     
    10 important, the amount of time that the sorbent
     
    11 has to contact the gas for that molecule of
     
    12 mercury to contact the particle of sorbent?
     
    13 DR. STAUDT: What matters is how well
     
    14 -- how well is the sorbent distributed and mixed
     
    15 in the gas stream. There are a couple of ways to
     
    16 do that. You can just inject it to the -- inject
     
    17 it with a single injector and hopefully if you
     
    18 have a very long duct, it will be long enough to
     
    19 get good mixing. But there are other ways if you
     
    20 -- if you have a grid or you could even have good
     
    21 mixing devices in the duct work, you can improve
     
    22 that mixing so that you don't need such a long
     
    23 duct -- long length so the -- there's not so much
     
    24 -- for any given situation, you can -- this is a
     
    KEEFE REPORTING COMPANY 26

     
     
     
     
     
    1 matter of you look at the circumstances, the type
     
    2 of duct work you have and you design the
     
    3 injection system to properly address that -- that
     
    4 particular situation because the reaction time
     
    5 is, you know, rather not the reaction time, but
     
    6 the time -- the distance and the duct work is a
     
    7 given with the plant, so you design the -- you
     
    8 design the injection system to address the
     
    9 circumstances you have in the plant.
     
    10 MR. HARRINGTON: So if you have a
     
    11 short duct work within which to inject the
     
    12 material before it enters the ESP, then you might
     
    13 need a more elaborate system to inject it; is
     
    14 that correct?
     
    15 DR. STAUDT: That is correct.
     
    16 MR. HARRINGTON: Did you assume any
     
    17 such system for any other plant you considered in
     
    18 the TSD?
     
    19 DR. STAUDT: Well, in terms of cost?
     
    20 I mean, I imagine you're in terms of cost?
     
    21 MR. HARRINGTON: Cost, yes.
     
    22 DR. STAUDT: Yeah, my assumption -- my
     
    23 assumption -- well, my assumption was a fairly
     
    24 simple assumption. Those -- And when you discuss
     
    KEEFE REPORTING COMPANY 27

     
     
     
     
     
    1 an elaborate system, the cost of these -- the
     
    2 hardware even with a more elaborate injection
     
    3 grid is not going to be a big part of the cost of
     
    4 -- is not going to be -- make a big difference in
     
    5 the cost of the system.
     
    6 For these sorbent injections systems
     
    7 that are upstream of an ESP, the real cost is the
     
    8 sorbent, that that -- that the equipment becomes
     
    9 pretty unimportant on a relative basis.
     
    10 MR. HARRINGTON: If you have to put
     
    11 mixing into the duct work, does that require an
     
    12 outage in the plant?
     
    13 DR. STAUDT: If you -- Yes. If you
     
    14 have to go -- depending upon if you have to put
     
    15 in -- if you -- depending upon the type of
     
    16 equipment you need to install, yes, but usually
     
    17 such an outage would be fairly -- fairly short,
     
    18 And over a period of three years, I'm sure that
     
    19 -- that such an outage can be accommodated.
     
    20 MR. HARRINGTON: At -- Neither at the
     
    21 time of the TSD or today, did you take any
     
    22 additional consideration of any additional costs
     
    23 associated with better mixing just --
     
    24 DR. STAUDT: Well, I did not include
     
    KEEFE REPORTING COMPANY 28

     
     
     
     
     
    1 that in my -- in my estimates, but we're going to
     
    2 get to this. I know there's another question
     
    3 about, you know, perhaps my estimates on the
     
    4 capital costs are low, but I'm going to give you
     
    5 my answer now and we can repeat it later. You
     
    6 know, you can double or triple the capital costs
     
    7 on the sorbent, the assumed capital costs on the
     
    8 sorbent injection systems, and the effect -- the
     
    9 effect would be on the overall analyzed costs of
     
    10 control, it's really pretty much negligible
     
    11 because most of the cost -- most of the cost of
     
    12 this technology is associated with the sorbent
     
    13 that's injected.
     
    14 The capital cost, as we discussed, the
     
    15 sorbent for a 500 megawatt plant, a sorbent
     
    16 injection system might cost on the order of a
     
    17 million dollars where if you double or triple
     
    18 that, maybe it's three million dollars. But
     
    19 relatively speaking an SCR might be 50 million
     
    20 dollars. A wet scrubber might be, you know, 100
     
    21 million dollars. So the sorbent injection
     
    22 technology, even -- even if I'm off by a factor
     
    23 of three or four on the capital cost in the whole
     
    24 economic analysis, it makes almost no difference.
     
    KEEFE REPORTING COMPANY 29

     
     
     
     
     
    1 The cost is in the sorbent. That's it.
     
    2 HEARING OFFICER TIPSORD: Question No.
     
    3 8.
     
    4 DR. STAUDT: "Over the past five years
     
    5 how much of your work has been done directly for
     
    6 the operators of coal-fired electrical generating
     
    7 units?" Perhaps in the range of about, you know,
     
    8 20 percent. Can I go to question 9?
     
    9 HEARING OFFICER TIPSORD: Yeah.
     
    10 DR. STAUDT: "Over the last five
     
    11 years, how much of your work has -- oh, over --
     
    12 how much of your work has been done for the
     
    13 suppliers of pollution control equipment and air
     
    14 pollution control supply such as sorbents?"
     
    15 Perhaps in the range of about 30 percent, maybe
     
    16 as high as 40 percent.
     
    17 MR. HARRINGTON: And who else --
     
    18 remaining portion of your work?
     
    19 DR. STAUDT: A lot of it is for
     
    20 government USEPA.
     
    21 MR. HARRINGTON: Thank you.
     
    22 HEARING OFFICER TIPSORD: Question No.
     
    23 10. I'm sorry. Mr. Bonebrake?
     
    24 MR. BONEBRAKE: Steve Bonebrake
     
    KEEFE REPORTING COMPANY 30

     
     
     
     
     
    1 representing Dynegy Midwest Generation. Have you
     
    2 done any work for Mr. Nelson's company?
     
    3 DR. STAUDT: No, I haven't. 10, "Are
     
    4 there any other professionals with Andover
     
    5 Technology other than yourself?" There are no
     
    6 other full-time employees.
     
    7 HEARING OFFICER TIPSORD: Number 11.
     
    8 DR. STAUDT: 11, "Has or does Andover
     
    9 Technologies do work for a company called Sorbent
     
    10 Technology?" I've already answered that, and I
     
    11 don't. And 12.
     
    12 HEARING OFFICER TIPSORD: Has been
     
    13 answered.
     
    14 MR. HARRINGTON: 13 has been answered
     
    15 as well.
     
    16 DR. STAUDT: 13, I think, is a repeat.
     
    17 HEARING OFFICER TIPSORD: Question No.
     
    18 14.
     
    19 DR. STAUDT: 14, "How much of Chapter
     
    20 8 of the technical support document were you
     
    21 responsible for writing?" I wrote most of it.
     
    22 And Illinois EPA made some comments and
     
    23 suggestions. "Did you prepare all the tables in
     
    24 Chapter 8?" I prepared most of them. I think --
     
    KEEFE REPORTING COMPANY 31

     
     
     
     
     
    1 I think all of them except for Table 8.2 is
     
    2 drawing from another source, but all of the rest
     
    3 are -- I think I prepared. 16, "Did you
     
    4 calculate the costs due to the impact of
     
    5 activated carbon injection on ash disposal?"
     
    6 Yes, I did. "Did you do the calculations in each
     
    7 of the tables in which it is referenced in the
     
    8 TSD?" And that would be correct.
     
    9 In some cases there was data drawn --
     
    10 some of the tables is data actually drawing from
     
    11 EIA Form 767 data. The power plants have to
     
    12 submit each year information about their
     
    13 operation. They get sent to the government. The
     
    14 government compiles that, and it's made available
     
    15 on the internet. The latest information is 2004,
     
    16 so I used the 2004 EIA Form 767 data for all the
     
    17 ash quantities. Question 18.
     
    18 HEARING OFFICER TIPSORD: I'm sorry.
     
    19 Ms. Tickner?
     
    20 MS. TICKNER: I just have one
     
    21 follow-up question. My name is Dianna Tickner
     
    22 with Prairie State Generating. You mentioned you
     
    23 used 767 to get the ash quantities. I'm curious
     
    24 why you didn't use it to get the coal quality?
     
    KEEFE REPORTING COMPANY 32

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: I didn't
     
    2 hear the last part of that.
     
    3 MS. TICKNER: Why he did not use 76 --
     
    4 EIA 767 to get the coal quality that each of the
     
    5 generators reported to EIA?
     
    6 DR. STAUDT: Well, first of all, this
     
    7 had already been put together, which saved me
     
    8 some work. Second, I'm pretty sure that -- that
     
    9 I was -- my understanding, and I believe I may be
     
    10 wrong, but my understanding is that this draws on
     
    11 the Form 767 data as well as the -- as well as
     
    12 other data basically.
     
    13 HEARING OFFICER TIPSORD: Excuse me,
     
    14 Dr. Staudt. This, you're referring to as Exhibit
     
    15 44?
     
    16 DR. STAUDT: Exhibit 44, I'm sorry. I
     
    17 apologize.
     
    18 MS. TICKNER: Maybe I'm confused. I
     
    19 thought you said you got the coal quality data
     
    20 from the Illinois Geologic Survey?
     
    21 DR. STAUDT: No, I got the content of
     
    22 mercury --
     
    23 MS. TICKNER: Okay. Thank you.
     
    24 DR. STAUDT: -- from Illinois Geologic
     
    KEEFE REPORTING COMPANY 33

     
     
     
     
     
    1 Survey.
     
    2 HEARING OFFICER TIPSORD: My question
     
    3 is, what is the -- is it EIA?
     
    4 DR. STAUDT: EIA. Yeah, Energy
     
    5 Information Administration.
     
    6 HEARING OFFICER TIPSORD: And what
     
    7 exactly is that? Is that a document or form?
     
    8 DR. STAUDT: It's a -- it's something
     
    9 that each of the power plants submits each year
     
    10 to the Department of Energy. It's -- The data
     
    11 gets compiled, and it's downloaded on their
     
    12 Website on the internet. And so that's publicly
     
    13 available information and, you know, each of the
     
    14 power plants or -- they submitted the data, so
     
    15 they have it, all right.
     
    16 HEARING OFFICER TIPSORD: No, we
     
    17 don't. Would it be possible for us to get that
     
    18 information in this record at least for the
     
    19 Illinois power plants or is that --
     
    20 DR. STAUDT: Basically the table --
     
    21 the table is drawn right out of the --
     
    22 HEARING OFFICER TIPSORD: Which --
     
    23 which table?
     
    24 DR. STAUDT: The table in -- Go to the
     
    KEEFE REPORTING COMPANY 34

     
     
     
     
     
    1 TSD.
     
    2 HEARING OFFICER TIPSORD: In the TSD?
     
    3 DR. STAUDT: Yeah. The table in the
     
    4 TSD for -- that shows the data taken from EIA
     
    5 Form 767.
     
    6 MR. KIM: I think 168.
     
    7 HEARING OFFICER TIPSORD: 161,
     
    8 Table --
     
    9 MR. KIM: 8.8.
     
    10 HEARING OFFICER TIPSORD: -- 8.8?
     
    11 DR. STAUDT: 2000 forms, Form 767 as
     
    12 far as my -- I did the calculated dollars per ton
     
    13 because what they do is they have a revenue line
     
    14 and then they have a tons line, and basically you
     
    15 divide one by the other to get your -- to get the
     
    16 ton.
     
    17 HEARING OFFICER TIPSORD: Okay. Thank
     
    18 you. That wasn't clear from the record that the
     
    19 information was actually in our record, that's
     
    20 why we asked.
     
    21 CHAIRMAN GIRARD: But could you submit
     
    22 the web address or where ever it is exactly you
     
    23 got the information.
     
    24 DR. STAUDT: Sure. I would be happy
     
    KEEFE REPORTING COMPANY 35

     
     
     
     
     
    1 to do that.
     
    2 HEARING OFFICER TIPSORD: Mr.
     
    3 Bonebrake?
     
    4 MR. BONEBRAKE: A related question.
     
    5 You were holding up Exhibit 44 and Exhibit 44
     
    6 contains, I think for each plant, a summary of
     
    7 it's called fly ash information.
     
    8 DR. STAUDT: Yes.
     
    9 MR. BONEBRAKE: Is that information
     
    10 that's listed in Exhibit 44 under the heading
     
    11 "Fly Ash Information" is that taken from EIA 767?
     
    12 DR. STAUDT: Can you tell me the page?
     
    13 MR. BONEBRAKE: Just an example, I'm
     
    14 looking at page 2 which relates to the Crawford
     
    15 facility.
     
    16 DR. STAUDT: I believe it is. I
     
    17 believe that's the same -- same information from
     
    18 Form 767.
     
    19 MR. ROSS: And it says that.
     
    20 HEARING OFFICER TIPSORD: You have to
     
    21 identify yourself for the new court reporter and
     
    22 use the microphone.
     
    23 MR. ROSS: Jim Ross. The very first
     
    24 page of Exhibit 44 has the data sources by which
     
    KEEFE REPORTING COMPANY 36

     
     
     
     
     
    1 the exhibit -- the information was complied. And
     
    2 it does, in fact, state that the fly ash
     
    3 information came from EIA-767 which is the form
     
    4 Dr. Staudt has been referring to.
     
    5 HEARING OFFICER TIPSORD: Thank you,
     
    6 Mr. Ross. And for the record, Mr. Ross is under
     
    7 oath and has been for two weeks.
     
    8 DR. STAUDT: I'm not sure what
     
    9 question we're on.
     
    10 MS. TICKNER: Just a follow-up. Is
     
    11 Exhibit 44 where you said you got the coal
     
    12 quality?
     
    13 DR. STAUDT: Well, the information on
     
    14 the types of coals.
     
    15 HEARING OFFICER TIPSORD: Dr. Staudt,
     
    16 you're turned away from the microphone.
     
    17 DR. STAUDT: Oh. Yes, that's where I
     
    18 got information on the coal that's being burned.
     
    19 MS. TICKNER: I guess I'm just
     
    20 confused. On the first page it says the
     
    21 principal coal supplier information was from
     
    22 plats coal bass database (phonetic) is that where
     
    23 the coal quality actually came from. It's not
     
    24 clear?
     
    KEEFE REPORTING COMPANY 37

     
     
     
     
     
    1 DR. STAUDT: Well, that's a better
     
    2 question for the Illinois EPA that put together
     
    3 this document. I don't know.
     
    4 HEARING OFFICER TIPSORD: Mr. Ross,
     
    5 can you answer that question?
     
    6 MR. ROSS: Probably. What was the
     
    7 question?
     
    8 MS. TICKNER: Well, I believe Dr.
     
    9 Staudt said that the coal quality data actually
     
    10 did come from EIA 767 and -- but he was
     
    11 referencing Exhibit 44 which, I believe, is this
     
    12 document. And it says under here number 3 that
     
    13 the coal supplier information, the source data
     
    14 was plats coal bass database, that's where the
     
    15 quality also came from?
     
    16 MR. ROSS: Yeah, I'm unclear on what
     
    17 you mean by coal quality. The plats coal bass
     
    18 database is something that we were given
     
    19 information or access to from the Department of
     
    20 Commerce and Economic Opportunity. And as it
     
    21 says here in the document, it provides the amount
     
    22 and type of Illinois coal, the source is utilized
     
    23 along with other -- that coal quality.
     
    24 MS. TICKNER: Well, you would need to
     
    KEEFE REPORTING COMPANY 38

     
     
     
     
     
    1 know whether it -- Was it subbituminous?
     
    2 MR. ROSS: That's -- Yeah, that's what
     
    3 I'm referring to as coal type.
     
    4 MS. TICKNER: Okay. Well, that's not
     
    5 EIA.
     
    6 MR. ROSS: The amount and type of
     
    7 Illinois coal, it says type of coal is whether
     
    8 they are firing subbituminous or bituminous coal.
     
    9 And that is in the plats coal bass database.
     
    10 DR. STAUDT: Just to -- I may have
     
    11 said that I thought this was -- this was -- the
     
    12 coal data was from 767, but I don't know if --
     
    13 apparently it's Illinois EPA, but this is what I
     
    14 -- Exhibit 44 is what I used for my role.
     
    15 MR. ROSS: My understanding --
     
    16 HEARING OFFICER TIPSORD: We lost all
     
    17 of that.
     
    18 MR. ROSS: That's -- My understanding
     
    19 is the plats coal base database is
     
    20 semi-expensive. It's an expensive subscription
     
    21 service that they subscribe to.
     
    22 CHAIRMAN GIRARD: Well, Mr. Nelson, I
     
    23 have a question. Did they give you a hard copy
     
    24 that you then extracted the data from?
     
    KEEFE REPORTING COMPANY 39

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: Mr. Ross?
     
    2 MR. ROSS: I would have to double
     
    3 check on that. I'm uncertain. I know that we
     
    4 sent -- staff actually went over to the DCEO
     
    5 headquarters here in Springfield and spoke with
     
    6 individuals, and then after that initial meeting
     
    7 they traded e-mails back and forth and
     
    8 information was provided to us as we requested
     
    9 it. So whether it was in the form of a disc or a
     
    10 hard copy or attached to an E-mail, I'm
     
    11 uncertain. I could certainly follow-up on that
     
    12 and get back to you.
     
    13 CHAIRMAN GIRARD: So you're saying
     
    14 it's not in that the bankers box of extra
     
    15 documents we have?
     
    16 MR. ROSS: No, I don't believe so.
     
    17 CHAIRMAN GIRARD: It certainly would
     
    18 be good to have that in record. We need to have
     
    19 access to anything you looked at and put into
     
    20 writing. I mean, this is basic principle here.
     
    21 We need to be able to look at everything you used
     
    22 to come up with your proposal. So if there's
     
    23 other things out there, you need to be proactive
     
    24 and get them in the record.
     
    KEEFE REPORTING COMPANY 40

     
     
     
     
     
    1 MR. ROSS: I can follow-up on that.
     
    2 It is a subscription service. I don't think it
     
    3 would be any problem to print out the data that
     
    4 we used and provided.
     
    5 CHAIRMAN GIRARD: That would be
     
    6 perfect. Thanks.
     
    7 HEARING OFFICER TIPSORD: Mr. Zabel?
     
    8 MR. ZABEL: Before we leave that, Mr.
     
    9 Ross, and before you go away, since we're on
     
    10 this, there's one entry I just don't understand
     
    11 and maybe you can explain it. Page 17 on the
     
    12 Baldwin plant.
     
    13 HEARING OFFICER TIPSORD: Still with
     
    14 Exhibit 44?
     
    15 MR. ZABEL: Yes, ma'am. If you look
     
    16 under principal cost supplier information, the
     
    17 very last column is entry for 2005, and I realize
     
    18 it's a partial year, but it only shows Wyoming
     
    19 coal at 85 percent and a total -- a total that's
     
    20 greater than the Wyoming coal supply, and I just
     
    21 don't understand those entries.
     
    22 DR. STAUDT: They -- What was
     
    23 explained to me, I mean, I didn't put this
     
    24 together, but what was explained to me -- I had
     
    KEEFE REPORTING COMPANY 41

     
     
     
     
     
    1 the same question when I looked at this is
     
    2 there's -- they get -- they're able -- they have
     
    3 information on the major suppliers but this --
     
    4 then there's other sources that they don't have
     
    5 information on. So it's kind of like other
     
    6 sources that are unaccounted for.
     
    7 MR. ZABEL: I have no reason to doubt
     
    8 that explanation. It might have been clear on
     
    9 this table if there would have been another
     
    10 lines. 600,000 tons of coal is a fair amount of
     
    11 coal.
     
    12 DR. STAUDT: Well, I should -- I had
     
    13 the same question when I looked at it.
     
    14 MR. ZABEL: Thank you.
     
    15 HEARING OFFICER TIPSORD: I think
     
    16 we're ready to move on then to Question No. 18.
     
    17 Mr. Harrington?
     
    18 MR. HARRINGTON: If I could drop back
     
    19 for a minute to earlier discussion. On page 153
     
    20 of the technical support document, Table 8.5 --
     
    21 DR. STAUDT: Yes.
     
    22 MR. HARRINGTON: -- is that the data
     
    23 you relied on for the mercury content of coal in
     
    24 doing your work?
     
    KEEFE REPORTING COMPANY 42

     
     
     
     
     
    1 DR. STAUDT: Yes, that is.
     
    2 MR. HARRINGTON: Was there other data
     
    3 in addition to that that you relied on?
     
    4 DR. STAUDT: For the --
     
    5 MR. HARRINGTON: For the mercury
     
    6 content of coal?
     
    7 DR. STAUDT: For the mercury content
     
    8 of coal, that is -- that is the information from
     
    9 that presentation that's presented there.
     
    10 MR. HARRINGTON: That's the totality
     
    11 of it. There is -- We don't have to look
     
    12 someplace else for additional data?
     
    13 DR. STAUDT: Not -- no.
     
    14 MR. HARRINGTON: Okay. Thank you.
     
    15 DR. STAUDT: Now in terms of the
     
    16 information I used, that's what I used.
     
    17 HEARING OFFICER TIPSORD: Question No.
     
    18 18.
     
    19 DR. STAUDT: "With reference to the
     
    20 technical support document on page 115 it states,
     
    21 "effective capture in the range of about 90
     
    22 percent appears to occur for all types of FGD
     
    23 when SCR is used combination with FGD." This is
     
    24 intended -- is this -- rather is this intended to
     
    KEEFE REPORTING COMPANY 43

     
     
     
     
     
    1 or imply that such applications will consistently
     
    2 achieve over 90 percent removal so to comply with
     
    3 the Illinois rule?" And did you hand these -- I
     
    4 don't know what this exhibit number is.
     
    5 HEARING OFFICER TIPSORD: We haven't
     
    6 marked that as an exhibit. But we will do so
     
    7 now. Figures and data from the TSD, which Mr.
     
    8 Kim handed out earlier, we will mark as Exhibit
     
    9 No. 52 if there's no objection. Seeing none,
     
    10 this is marked as Exhibit No. 52.
     
    11 MR. HARRINGTON: Before we go to the
     
    12 exhibit, could we have an answer to 18?
     
    13 DR. STAUDT: Well, yeah. I'm going to
     
    14 use it as part of my answer, okay. If you -- The
     
    15 statement on page 115 that your -- the question
     
    16 refers to, it's made in reference to field test
     
    17 data shown on page 116 on Figure 8.3 and if you
     
    18 look at --
     
    19 HEARING OFFICER TIPSORD: Microphone.
     
    20 DR. STAUDT: -- if you go to the
     
    21 exhibit, Figure 8.3, the first figure that shows
     
    22 up, and so that statement is written in reference
     
    23 to data that is shown on page -- the statement on
     
    24 page 115 is written in reference to data on page
     
    KEEFE REPORTING COMPANY 44

     
     
     
     
     
    1 116. So it's not in reference -- it's not
     
    2 written in reference to the Illinois rule.
     
    3 Now to look at -- I show the Figure
     
    4 8.3 for your -- we talked about co-benefit
     
    5 reductions, what this shows comparison for
     
    6 different types of systems, it shows that with
     
    7 the type of mercury removal that Wet FGD
     
    8 technology has been able to achieve in some cases
     
    9 with an SCR and other cases without an SCR, and
     
    10 the white bars are without the SCR and the red
     
    11 bar is with the SCR in service, so my statement
     
    12 is in reference to that, you get about, you know,
     
    13 this data shows that you get about 90 percent
     
    14 removal, so that's what the statement is in
     
    15 reference to. It's in reference to this data.
     
    16 I'm just referring to the data.
     
    17 HEARING OFFICER TIPSORD: And for the
     
    18 court reporter you tended to run together that's
     
    19 Wet FGD technology.
     
    20 DR. STAUDT: And for co-benefit
     
    21 removal, when we talk about co-benefit removal,
     
    22 that's the removal that's provided by other air
     
    23 pollution control technologies that are not
     
    24 specific to mercury. And I know we're going to
     
    KEEFE REPORTING COMPANY 45

     
     
     
     
     
    1 be talking about a lot of different things here
     
    2 but for the sake of time, I want to keep my
     
    3 answers short. But just for the benefit of you
     
    4 folks, if there's any concept that comes up,
     
    5 term, please ask, I'll be happy to explain it.
     
    6 HEARING OFFICER TIPSORD: Trust me, I
     
    7 think you'll get asked.
     
    8 MR. HARRINGTON: And I would ask the
     
    9 same thing with respect to my questions or
     
    10 follow-up questions. If I say an abbreviation or
     
    11 misuse abbreviations, I will be happy to explain.
     
    12 HEARING OFFICER TIPSORD: I think I
     
    13 hold the record on misusing abbreviations so far.
     
    14 MR. HARRINGTON: So the question -- is
     
    15 the question -- answer to 18 yes or no?
     
    16 DR. STAUDT: No. It's not intended to
     
    17 imply that. It's in reference to the data on
     
    18 page 116.
     
    19 MR. HARRINGTON: Okay. Thank you.
     
    20 Since we're looking at that data now, I have a
     
    21 couple of questions if I may. Is -- Do you know
     
    22 whether this data and your conclusions you've
     
    23 drawn from it take into account uncertainty in
     
    24 mercury measurements for the gas and coal in --
     
    KEEFE REPORTING COMPANY 46

     
     
     
     
     
    1 and coal?
     
    2 DR. STAUDT: Well, to the best of my
     
    3 knowledge these were -- these were tests
     
    4 sponsored by the U.S. Department of Energy. And
     
    5 so to the extent that we have confidence in their
     
    6 ability to supervise these tests, I would say
     
    7 yes.
     
    8 MR. HARRINGTON: No matter how well
     
    9 they supervise the tests there is an errant
     
    10 variability in the sample; is that correct?
     
    11 DR. STAUDT: I can't -- I can't -- I'm
     
    12 not an expert on sampling. I'm an expert on
     
    13 control technology, so -- so I can't comment on
     
    14 details on coal sampling.
     
    15 MR. HARRINGTON: Just for the record,
     
    16 I know it is in evidence, but as I look at Figure
     
    17 8.3 I see several of the red bars not reaching 90
     
    18 percent removal level, am I correct?
     
    19 DR. STAUDT: That's -- that's correct.
     
    20 You see some below; and you see some above.
     
    21 MR. HARRINGTON: Thank you.
     
    22 HEARING OFFICER TIPSORD: Mr.
     
    23 Bonebrake?
     
    24 MR. BONEBRAKE: A related question.
     
    KEEFE REPORTING COMPANY 47

     
     
     
     
     
    1 Figure 8.34 is entitled "Mercury Removal By Wet
     
    2 FGD - Technology with and without SCR," the
     
    3 statement from your report on page 115 reflected
     
    4 in question 18 seems to refer to all types of
     
    5 FGD, and I was wondering am I misreading Figure
     
    6 8.3, or is there some other data that you are
     
    7 relying upon with respect to Dry FGD technology?
     
    8 DR. STAUDT: The -- on the right SDA
     
    9 stands for Spray Dryer Absorber and that is Dry
     
    10 FGD. So those two -- the two right bars to the
     
    11 far right. That's -- Yeah. The title is
     
    12 misleading.
     
    13 HEARING OFFICER TIPSORD: Actually the
     
    14 SDA --
     
    15 DR. STAUDT: SDA is a dry -- is a Dry
     
    16 FGD actually.
     
    17 HEARING OFFICER TIPSORD: I believe
     
    18 you said the two white bars were correct.
     
    19 DR. STAUDT: The two red bars on the
     
    20 far right. I'm sorry.
     
    21 HEARING OFFICER TIPSORD: Ms. Bassi?
     
    22 MS. BASSI: So then should -- should
     
    23 this Table 8.3 or Figure 8.3 be amended so that
     
    24 word wet is taken out of the title, is that what
     
    KEEFE REPORTING COMPANY 48

     
     
     
     
     
    1 you were saying?
     
    2 DR. STAUDT: Perhaps it should be
     
    3 amended to say the title of the figure should
     
    4 just be FGD technology perhaps.
     
    5 MS. BASSI: Why do you say perhaps?
     
    6 DR. STAUDT: Well, okay, yes. Score
     
    7 one for you.
     
    8 MS. BASSI: Well, it's not a
     
    9 competition. It's -- I want to know.
     
    10 HEARING OFFICER TIPSORD: Mr. Zabel?
     
    11 MR. ZABEL: I have one to follow-up.
     
    12 Dr. Staudt, the SDA, the Dry FGD, I'm going to
     
    13 try to read the acronyms right, are both of those
     
    14 equipped with fabric filters?
     
    15 DR. STAUDT: I believe those were --
     
    16 those two tests were spray dryers with fabric
     
    17 filters, yes.
     
    18 MR. ZABEL: Thank you.
     
    19 DR. STAUDT: And these are all
     
    20 bituminous coal, I believe.
     
    21 MR. ZABEL: Thank you again.
     
    22 HEARING OFFICER TIPSORD: Ready for
     
    23 question 19?
     
    24 DR. STAUDT: "Page 119 of the
     
    KEEFE REPORTING COMPANY 49

     
     
     
     
     
    1 technical -- page 119 of the technical support
     
    2 document states some of the bituminous coal-fired
     
    3 boilers may not achieve adequately low mercury
     
    4 emissions --
     
    5 HEARING OFFICER TIPSORD: Excuse me.
     
    6 Let me interrupt you. I appreciate that you need
     
    7 to confer, but the court reporter is sitting next
     
    8 to you guys and she's having trouble hearing. We
     
    9 may look at moving her around later but for now,
     
    10 go ahead, Dr. Staudt.
     
    11 DR. STAUDT: "Page 119 of the
     
    12 technical support document it states "Some of the
     
    13 bituminous coal-fired boilers may not achieve
     
    14 adequately low mercury emission by co-benefits
     
    15 alone. Therefore, these plants may need
     
    16 additional controls to achieve the levels of
     
    17 mercury removal that are being required in the
     
    18 proposed rule." Which if any Illinois plants do
     
    19 you believe would require additional controls to
     
    20 comply with the rule of mercury -- with the rule
     
    21 of mercury removal beyond flue-gas
     
    22 desulfurization and selective catalytic
     
    23 reduction?"
     
    24 And there are unscrubbed bituminous
     
    KEEFE REPORTING COMPANY 50

     
     
     
     
     
    1 coal-fired units such as Meredosia that are not
     
    2 expected to get anywhere close to 90 percent
     
    3 removal through co-benefit reduction with
     
    4 co-benefit. And as I noted earlier, I expect
     
    5 those bituminous units with SCR and FGD will
     
    6 achieve close to 90 percent for the Alpha-based
     
    7 standard through co-benefit. Based upon the
     
    8 information I have at this time I can't determine
     
    9 which, if any, units with SCR and FGD may require
     
    10 additional removal beyond co-benefit.
     
    11 MR. HARRINGTON: May I follow-up?
     
    12 DR. STAUDT: 20 --
     
    13 HEARING OFFICER TIPSORD: Wait. Mr.
     
    14 Harrington had a follow-up.
     
    15 MR. HARRINGTON: Let me make sure I'm
     
    16 looking at the right chart this time. Am I
     
    17 correct on Table 8.9 -- strike that. Thank you.
     
    18 HEARING OFFICER TIPSORD: Question 20.
     
    19 DR. STAUDT: "What additional control
     
    20 would be required?" The -- It's really up to the
     
    21 owner to decide what controls may be needed.
     
    22 Sorbent injection is only one option. I expect
     
    23 that owners of scrubbed units might pursue other
     
    24 approaches first such as possible optimization of
     
    KEEFE REPORTING COMPANY 51

     
     
     
     
     
    1 scrubber chemistry or injection of oxidizing
     
    2 chemicals. Other approaches also include
     
    3 improving the co-benefit removal associated with
     
    4 the particulate removal device. Because all of
     
    5 those -- most all the units in Illinois have that
     
    6 -- that are -- that are scrubbed also have ESP so
     
    7 they could potentially also improve the co -- the
     
    8 amount of co-benefit from the ESP.
     
    9 And just as far as discussing
     
    10 oxidizing chemicals, the Figure 8.4 shows a
     
    11 configuration shows how oxidizing chemicals, you
     
    12 have the boiler on the far left, you see there's
     
    13 an SCR. The SCR has the effect of it tends to
     
    14 oxidize the mercury -- that's in the element of
     
    15 mercury, it's in gas. Then there's the ESP,
     
    16 particulate control device. Then you can
     
    17 potentially put an oxidizing catalyst there under
     
    18 development or other oxidizing chemicals
     
    19 immediately upstream or into the wet scrubber.
     
    20 So there are a couple of different -- there are
     
    21 lots of different scenarios that people might
     
    22 pursue.
     
    23 HEARING OFFICER TIPSORD: And for the
     
    24 record, Dr. Staudt, that was Figure 8.4 of the
     
    KEEFE REPORTING COMPANY 52

     
     
     
     
     
    1 Department's exhibit?
     
    2 DR. STAUDT: Yes.
     
    3 HEARING OFFICER TIPSORD: Mr.
     
    4 Harrington?
     
    5 MR. HARRINGTON: Are those
     
    6 technologies presently proven, the additional
     
    7 technologies you just referred to?
     
    8 DR. STAUDT: Could you -- could you
     
    9 define for me what your criteria for proven?
     
    10 Could you specify a criteria for proven?
     
    11 MR. HARRINGTON: Are they actually in
     
    12 commercial operation in power plants today?
     
    13 DR. STAUDT: Well, it's kind of
     
    14 interesting, if all of these -- if these mercury
     
    15 control technologies were in commercial
     
    16 operation, I don't think we would be here today.
     
    17 But people do install the mercury controls until
     
    18 -- until it's a requirement or rule that forces
     
    19 them to.
     
    20 MR. HARRINGTON: Are you aware of what
     
    21 testing has been done on each the technologies
     
    22 you just referred to.
     
    23 DR. STAUDT: Yes, I'm aware -- I don't
     
    24 know that I'm aware of all the testing that's
     
    KEEFE REPORTING COMPANY 53

     
     
     
     
     
    1 been done, but I'm aware there's been a fair
     
    2 amount of testing that's been done.
     
    3 MR. HARRINGTON: Are those
     
    4 technologies presently commercially available?
     
    5 DR. STAUDT: To the best of my
     
    6 knowledge some of them are.
     
    7 MR. HARRINGTON: Are those that are
     
    8 commercially available been demonstrated in
     
    9 conjunction with the FGD and SCR to achieve
     
    10 consistency over 90 percent removal?
     
    11 DR. STAUDT: If you could specify what
     
    12 you mean by consistently? Give me a criteria.
     
    13 MR. HARRINGTON: Consistently so that
     
    14 they would comply with the 90 percent removal
     
    15 requirement in the Illinois regulation?
     
    16 DR. STAUDT: Yes, they have.
     
    17 MR. HARRINGTON: And where is that?
     
    18 DR. STAUDT: Dominions Mt. Storm plant
     
    19 is one. There are other plants as well.
     
    20 HEARING OFFICER TIPSORD: Excuse me.
     
    21 I think Mr. Nelson has something to add.
     
    22 MR. NELSON: Actually, Mr. Porter.
     
    23 HEARING OFFICER TIPSORD: Identify
     
    24 yourself again.
     
    KEEFE REPORTING COMPANY 54

     
     
     
     
     
    1 MR. PORTER: David Porter. There is
     
    2 question that was there a guarantee on
     
    3 oxidization catalyst, and it's Cormetech actually
     
    4 has one. It's on our Website.
     
    5 DR. STAUDT: Okay. Or part of a
     
    6 question.
     
    7 HEARING OFFICER TIPSORD: Cormetech?
     
    8 MR. NELSON: Sid Nelson. Cormetech,
     
    9 they are a major SCR catalyst producer --
     
    10 HEARING OFFICER TIPSORD: Could you
     
    11 spell it, please.
     
    12 MR. NELSON: C-O-R-N-E-T-E-C-H,
     
    13 Cornetech [sic]. It's a Corning & Glass and
     
    14 Mitsubishi adventure.
     
    15 HEARING OFFICER TIPSORD: Mr.
     
    16 Bonebrake?
     
    17 MR. BONEBRAKE: When you were
     
    18 referring to oxidizing catalyst, which are
     
    19 identified on Figure 8.4, I think you used the
     
    20 term "in development" to describe such catalyst.
     
    21 Can you describe for us what you mean by "in
     
    22 development"?
     
    23 DR. STAUDT: Well, I've seen tests of
     
    24 them but I've just seen tests -- I've seen the
     
    KEEFE REPORTING COMPANY 55

     
     
     
     
     
    1 results of testing. And I'm not -- I'm not aware
     
    2 that they are being offered commercially at this
     
    3 time.
     
    4 HEARING OFFICER TIPSORD: Mr.
     
    5 Harrington and then Ms. Tickner?
     
    6 MR. HARRINGTON: Are you aware of what
     
    7 coals are burned at the Mt. -- Dominions Mt.
     
    8 Storm plant?
     
    9 DR. STAUDT: Those are bituminous
     
    10 coals.
     
    11 MR. HARRINGTON: Are those high sulfur
     
    12 eastern bituminous coals?
     
    13 DR. STAUDT: To my knowledge, yes.
     
    14 MR. HARRINGTON: Do you know what
     
    15 methods we used at that facility for the tests
     
    16 that were referred to?
     
    17 DR. STAUDT: They did have continuous
     
    18 mercury monitors, but again, this is another DOE
     
    19 -- this is also -- I received sponsorship from
     
    20 DOE so there was quite a bit of -- DOE usually
     
    21 has pretty extensive requirements on quality
     
    22 control for data.
     
    23 MR. HARRINGTON: Are you aware there
     
    24 was one short-term stack test?
     
    KEEFE REPORTING COMPANY 56

     
     
     
     
     
    1 DR. STAUDT: Excuse me. One
     
    2 short-term stack test?
     
    3 MR. HARRINGTON: That demonstrated
     
    4 a --
     
    5 DR. STAUDT: There was a -- the
     
    6 testing was -- was run with the -- with
     
    7 continuous analyzes over -- over a period of
     
    8 time. It wasn't just -- there may have been a
     
    9 single extractive stack test, but there was data
     
    10 collected over an extended period of time using
     
    11 continuous analyzers.
     
    12 MR. HARRINGTON: Do all of which
     
    13 demonstrated over 90 percent removal?
     
    14 DR. STAUDT: We -- Over the period of
     
    15 time tested, yes.
     
    16 HEARING OFFICER TIPSORD: Ms. Tickner?
     
    17 MS. TICKNER: I'm just confused a
     
    18 little bit. If we go back to Figure 8.4 the
     
    19 location where, Dr. Staudt, you're showing the
     
    20 oxidizing catalyst after the PM control and I
     
    21 think Mr. Porter just mentioned the Cormetech
     
    22 catalyst which actually goes in the SCR, aren't
     
    23 we really talking about two different things
     
    24 here?
     
    KEEFE REPORTING COMPANY 57

     
     
     
     
     
    1 DR. STAUDT: What this shows -- Let me
     
    2 just clarify. Figure 8.4 shows a full range of
     
    3 -- a full range of possibilities, not
     
    4 specifically what Cormetech -- Cormetech is a --
     
    5 is primarily an SCR catalyst supplier. To my
     
    6 knowledge they -- I know they're working on
     
    7 mercury oxidization for SCR catalyst and that
     
    8 would be the SCR catalyst. I don't know that --
     
    9 I don't know whether or not Corning offers --
     
    10 Cormetech offers an oxidization catalyst that
     
    11 would be downstream of the PM control device.
     
    12 I'm not aware of that.
     
    13 MS. TICKNER: Okay. I just want be to
     
    14 be clear. He was talking about something totally
     
    15 different than --
     
    16 DR. STAUDT: Than the oxidizing
     
    17 catalyst, right, yes.
     
    18 MS. TICKNER: Okay.
     
    19 HEARING OFFICER TIPSORD: Mr. Porter,
     
    20 did you have anything else to add to that?
     
    21 MR. PORTER: I was just going to say
     
    22 that Jim is correct, that you could put the
     
    23 catalyst --
     
    24 HEARING OFFICER TIPSORD: Hold the
     
    KEEFE REPORTING COMPANY 58

     
     
     
     
     
    1 microphone up.
     
    2 MR. PORTER: -- configuration and
     
    3 Cormetech is doing -- is guaranteeing the
     
    4 oxidization catalyst. Now where it's actually
     
    5 located will be up to the individual facilities
     
    6 to make a determination how it works. They're
     
    7 also working on different formulations of
     
    8 catalyst that deal with other things like SO3 and
     
    9 things like that that Sid Nelson has already
     
    10 discussed. So there's a number of different
     
    11 catalyst formulations out there considering we
     
    12 had -- had our first catalyst in the country in
     
    13 the late '90s basically.
     
    14 HEARING OFFICER TIPSORD: Mr. Forcade?
     
    15 MR. FORCADE: Would it be all right if
     
    16 we reserved the right to ask Mr. -- Dr. Staudt
     
    17 tomorrow questions about the Dominion plant after
     
    18 we've checked tonight and find out the exact
     
    19 makeup of the plant, the dates of the test since
     
    20 we don't have it at our fingertips right now?
     
    21 HEARING OFFICER TIPSORD: Fine with
     
    22 me, yeah. Are we ready then to -- Mr.
     
    23 Harrington, do you have any follow-up?
     
    24 MR. HARRINGTON: Hopefully one.
     
    KEEFE REPORTING COMPANY 59

     
     
     
     
     
    1 You're familiar, Doctor, are you not, with the
     
    2 sampling methods and the details of the Illinois
     
    3 regulation?
     
    4 DR. STAUDT: Not the sampling methods.
     
    5 I'm not a sampling -- I'm not a coal sampling
     
    6 expert. I'm an expert in control technology.
     
    7 MR. HARRINGTON: Well, when you say --
     
    8 I think you said you felt that there were
     
    9 techniques that would achieve compliance with the
     
    10 Illinois rule using co-benefit plus other things
     
    11 you mentioned. I'm wondering if you took into
     
    12 account the sampling analytical methods in
     
    13 averaging methods specified in the Illinois rule?
     
    14 DR. STAUDT: Well, I certainly took
     
    15 into consideration the averaging. It's a
     
    16 12-month average so variability typically --
     
    17 while there may be variability on a day-to-day
     
    18 basis, that usually -- that gets averaged out
     
    19 pretty well. That's one of the reasons why power
     
    20 plants in general would much prefer a 12-month
     
    21 average to a one-hour average. And I can't
     
    22 imagine that the power plants here would be --
     
    23 would feel equally -- would prefer a one-hour
     
    24 average to a 12-month rolling average. So that's
     
    KEEFE REPORTING COMPANY 60

     
     
     
     
     
    1 -- the 12-month average would address large -- a
     
    2 large part of the variability that you see.
     
    3 MR. HARRINGTON: I'm trying to -- I'm
     
    4 not trying to pin you down to answer a question
     
    5 outside of your expertise. I'm just trying to
     
    6 make sure we understand how far that expertise
     
    7 goes. In this case am I correct you're not an
     
    8 expert in sampling or analysis and you're not --
     
    9 you're not saying whether the method in Illinois
     
    10 rules for sampling and analysis will properly
     
    11 reflect the removal rates that will be achieved
     
    12 with co-benefit with whatever improvements you
     
    13 have?
     
    14 DR. STAUDT: Yeah. I cannot speak to
     
    15 the co-measurement analysis methods that you're
     
    16 referring to.
     
    17 MR. HARRINGTON: Can you speak to the
     
    18 flue-gas mercury measurements?
     
    19 DR. STAUDT: I'm not -- I'm not a
     
    20 mercury CEM measurement expert either.
     
    21 MR. HARRINGTON: Thank you.
     
    22 HEARING OFFICER TIPSORD: Mr. Nelson,
     
    23 you have something to add?
     
    24 MR. NELSON: I have -- I do have some
     
    KEEFE REPORTING COMPANY 61

     
     
     
     
     
    1 experience in supervising multiple kinds of
     
    2 mercury analysis. If you have particular
     
    3 questions, I'd be happy to try.
     
    4 MR. HARRINGTON: No, I'm just -- my
     
    5 questions have been answered in terms of
     
    6 expertise.
     
    7 DR. STAUDT: There's another aspect to
     
    8 this is that utilities have a choice between the
     
    9 mercury reduction, percent reduction requirement
     
    10 or an output based standard, and if they comply
     
    11 with the output based standard, the -- there
     
    12 really isn't a need to be measuring the unit of
     
    13 coal.
     
    14 MR. HARRINGTON: That still is based
     
    15 on the accuracy and reliability of the flue-gas
     
    16 measurement; is that correct?
     
    17 DR. STAUDT: Yes, to the -- Yes.
     
    18 Which are consistent with what EPA requires.
     
    19 MR. HARRINGTON: And are you aware of
     
    20 what the accuracy of those methods are?
     
    21 DR. STAUDT: No.
     
    22 MR. HARRINGTON: Are you aware what
     
    23 the flue-gas concentration would be with a
     
    24 facility complying with 0.008 pounds per million
     
    KEEFE REPORTING COMPANY 62

     
     
     
     
     
    1 to go out in power?
     
    2 DR. STAUDT: Off the top of my head I
     
    3 couldn't tell you that.
     
    4 MR. NELSON: If I --
     
    5 DR. STAUDT: That's something that
     
    6 could be calculated.
     
    7 MR. HARRINGTON: I'd like to direct my
     
    8 questions to -- unless Mr. Nelson is going to be
     
    9 qualified as an expert in flue-gas sampling.
     
    10 HEARING OFFICER TIPSORD: We'll stick
     
    11 with Dr. Staudt at this point. Thank you. Ready
     
    12 for question 21?
     
    13 MR. HARRINGTON: Yes.
     
    14 DR. STAUDT: "Table 8.9 indicates that
     
    15 Duck Creek, Dallman, and Marion would achieve
     
    16 compliance with the Illinois rule through
     
    17 co-benefit. On what do you base that statement?"
     
    18 Well, Table 8.9 is a table that shows cost
     
    19 estimates. It's not a statement. So just to
     
    20 clarify that there's no statement in Table 8.9
     
    21 and it's a table and it is associated with how
     
    22 people might -- might control.
     
    23 It's my expectation that these units
     
    24 are close to compliance with the mercury emission
     
    KEEFE REPORTING COMPANY 63

     
     
     
     
     
    1 requirements at this time due to co-benefit, if
     
    2 not already a compliance.
     
    3 MR. HARRINGTON: Am I correct that you
     
    4 just said that the technologies listed in Table
     
    5 8.9, for example, technology and cost are -- are
     
    6 not your opinion that those technologies will, in
     
    7 fact, achieve compliance?
     
    8 DR. STAUDT: You basically said that
     
    9 you -- I'm just talking about the wording of your
     
    10 question.
     
    11 MR. HARRINGTON: Okay.
     
    12 DR. STAUDT: Okay.
     
    13 MR. HARRINGTON: Let's -- I understand
     
    14 there may have been some error in my wording but
     
    15 --
     
    16 DR. STAUDT: There isn't a statement
     
    17 there that says that, okay. There's a table here
     
    18 and the table associated with how -- what the
     
    19 table is associated with is how I estimated the
     
    20 total cost of the rule. And when I put -- put
     
    21 co-benefit for those -- for those units,
     
    22 essentially I meant -- what my intention was to
     
    23 say that they are -- it's -- it's my expectation
     
    24 that if they are not already in compliance with
     
    KEEFE REPORTING COMPANY 64

     
     
     
     
     
    1 the rule, they are very close and the cost would
     
    2 be pretty small. So Table 8.9 is associated with
     
    3 how I developed a cost -- the cost of compliance
     
    4 with the mercury rule.
     
    5 MR. HARRINGTON: With respect to Table
     
    6 8.9, is it your opinion the technologies listed
     
    7 there would achieve compliance with the Illinois
     
    8 rule?
     
    9 DR. STAUDT: With the exception of
     
    10 Meredosia -- the small units at Meredosia, while
     
    11 they would achieve compliance -- with the
     
    12 exception of the small units at Meredosia and
     
    13 potentially Hutsonville, if they -- if they
     
    14 continue to burn high sulfur coal, those ones I
     
    15 think would -- would comply through a TTBS, at
     
    16 least initially. The rest, I believe, the
     
    17 technology specified would be able to bring these
     
    18 units into compliance with the emission standards
     
    19 of the rule.
     
    20 MR. HARRINGTON: Thank you. That's my
     
    21 understanding of the opinion. That's all I was
     
    22 trying to do.
     
    23 DR. STAUDT: Okay.
     
    24 MR. HARRINGTON: Thank you.
     
    KEEFE REPORTING COMPANY 65

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: Question No.
     
    2 22.
     
    3 DR. STAUDT: "Have you reviewed the
     
    4 data with respect to Duck Creek, Dallman, and
     
    5 Marion to reach a professional conclusion that
     
    6 co-benefit alone will be sufficient to achieve
     
    7 compliance with the proposed Illinois
     
    8 regulation?" And, you know, I reviewed
     
    9 information on these units. You know, as
     
    10 mentioned earlier, based upon information I have
     
    11 at this time, and you're aware of the
     
    12 information, I, you know, I cannot determine if
     
    13 any units with SCR and FGD will require
     
    14 additional removal beyond co-benefit, but I
     
    15 believe those units -- I believe that those units
     
    16 will be able to achieve compliance through
     
    17 co-benefit, or if there's any additional
     
    18 requirement, any additional need, it would be a
     
    19 relatively low cost.
     
    20 MR. HARRINGTON: I call your attention
     
    21 to page 155, the paragraph immediately above
     
    22 where it starts with an introductory sentence
     
    23 above the bullet point in 155 of the technical
     
    24 support document.
     
    KEEFE REPORTING COMPANY 66

     
     
     
     
     
    1 DR. STAUDT: Okay, 155. Which
     
    2 paragraph?
     
    3 MR. HARRINGTON: Paragraph -- that's
     
    4 the second full paragraph the sentence starts
     
    5 "the units that are assumed".
     
    6 DR. STAUDT: Yes.
     
    7 MR. HARRINGTON: Do you wish to amend
     
    8 that statement?
     
    9 DR. STAUDT: Let me -- let me read
     
    10 this. I don't see a need to -- I don't see a
     
    11 need to -- Let's see. Those -- I don't see a
     
    12 need to revise that.
     
    13 MR. HARRINGTON: Okay. Thank you.
     
    14 HEARING OFFICER TIPSORD: Question 23.
     
    15 DR. STAUDT: I believe --
     
    16 MR. HARRINGTON: I believe that's been
     
    17 answered.
     
    18 DR. STAUDT: Yeah.
     
    19 HEARING OFFICER TIPSORD: Okay.
     
    20 DR. STAUDT: Page 118 of technical --
     
    21 24, "Page 118 of the technical support document
     
    22 --
     
    23 HEARING OFFICER TIPSORD: I'm sorry.
     
    24 Mr. Zabel?
     
    KEEFE REPORTING COMPANY 67

     
     
     
     
     
    1 MR. ZABEL: If I could go back to your
     
    2 answer concerning the statement on page 155, you
     
    3 indicate that you didn't think that they would
     
    4 need to?
     
    5 DR. STAUDT: Didn't need to what?
     
    6 MR. ZABEL: Install additional --
     
    7 install SCR at the Dallman, Duck Creek, and
     
    8 Marion units?
     
    9 DR. STAUDT: They may not have to. My
     
    10 basis is that they won't have to.
     
    11 MR. ZABEL: But if they didn't, and in
     
    12 fact, didn't meet 90 percent, they'd be in
     
    13 violation of the proposed rule, would they not?
     
    14 DR. STAUDT: Well, I would -- my -- my
     
    15 -- what they -- what I would do is have the time
     
    16 to figure out whether or not they are -- are at
     
    17 90 percent, and if they are at that 90 percent
     
    18 already, then they would -- then they would do --
     
    19 take some kind of precaution, do something, might
     
    20 be sorbent injection or something less in order
     
    21 to get -- get to either the 90 percent or the
     
    22 Alpha-based standard.
     
    23 MR. ZABEL: And that would be
     
    24 determining compliance on the current operational
     
    KEEFE REPORTING COMPANY 68

     
     
     
     
     
    1 mode, fuels, etc.; is that correct?
     
    2 DR. STAUDT: That -- Well, based
     
    3 upon -- yeah, their current operating mode and
     
    4 fuel, that's correct.
     
    5 MR. ZABEL: And if something changed
     
    6 and they dropped to 89 percent, they would be in
     
    7 violation, wouldn't they, a 12-month rolling
     
    8 average I understand?
     
    9 DR. STAUDT: Well, it depends. They
     
    10 can -- there is an averaging provision that they
     
    11 can do that if they drop to 89 percent.
     
    12 MR. ZABEL: Assuming they could
     
    13 average and they averaged 89 percent, they
     
    14 couldn't buy an allowance to correct that one
     
    15 percent error, could they?
     
    16 DR. STAUDT: Well, allowance trading
     
    17 is not permitted under the rule.
     
    18 MR. ZABEL: Thank you.
     
    19 HEARING OFFICER TIPSORD: Question 24.
     
    20 Oh, I'm sorry. Mr. Nelson?
     
    21 MR. NELSON: But the -- in the first
     
    22 phase, for a good number of years the bubbles --
     
    23 the whole utilities, so they only have to get 75
     
    24 percent, correct, and the plant -- all the plants
     
    KEEFE REPORTING COMPANY 69

     
     
     
     
     
    1 together have to get 90.
     
    2 MR. ZABEL: For Marion, Mr. Nelson, do
     
    3 you know what constitutes the whole facility?
     
    4 MR. NELSON: Not for Marion, but --
     
    5 MR. ZABEL: So they have the same
     
    6 problem, 89 percent they're in violation; right?
     
    7 DR. STAUDT: Just if -- I think they
     
    8 get to average, don't they, get to average with
     
    9 the -- average with Kincaid and there's a pool.
     
    10 MR. ZABEL: In the first phase and if
     
    11 they're the first one in the door; correct?
     
    12 MR. NELSON: That's for the TTBS.
     
    13 MR. ZABEL: You're right. I
     
    14 apologize.
     
    15 HEARING OFFICER TIPSORD: Ms. Bassi?
     
    16 MS. BASSI: With regard to this
     
    17 averaging though among the pool of orphan units
     
    18 or orphan plants, is it not the case that there
     
    19 has to be some sort of agreement among those
     
    20 plants even though the Agency would not be a
     
    21 party to that agreement?
     
    22 HEARING OFFICER TIPSORD: Introduce
     
    23 yourself.
     
    24 MR. ROMAINE: Chris Romaine. Yes,
     
    KEEFE REPORTING COMPANY 70

     
     
     
     
     
    1 there would have to be such an agreement between
     
    2 the different companies.
     
    3 HEARING OFFICER TIPSORD: And Mr.
     
    4 Romaine is sworn in. All right. Ready to go to
     
    5 question 24 then?
     
    6 DR. STAUDT: At page 118 of the
     
    7 technical support document it states that what
     
    8 FGD additives are -- at what -- 118 of the
     
    9 technical support document I think you meant Wet
     
    10 FGD, not what FGD.
     
    11 MR. HARRINGTON: I think so.
     
    12 DR. STAUDT: Yes. Wet FGD additives
     
    13 are successful in improving mercury removal and
     
    14 by implication achieving compliance with the
     
    15 Illinois regulation. At what facilities has this
     
    16 been demonstrated? And the -- It's been done at
     
    17 a number of facilities just -- again, you saw
     
    18 Figure 8.4. This is a pretty active area.
     
    19 Babcock & Wilcox, which is a company that builds
     
    20 boilers and flue-gas to sulfurization systems,
     
    21 they're very active. And their approach has been
     
    22 tested at the Dominions Mt. Storm plant, LG & E,
     
    23 Mill Creek as well as Babcock & Wilcox's large
     
    24 boiler stimulater. They're have been other tests
     
    KEEFE REPORTING COMPANY 71

     
     
     
     
     
    1 as well some -- but some of these were not on
     
    2 limestone forced oxidation units, which are the
     
    3 type of technology that is used here in Illinois.
     
    4 It's also my understanding that other
     
    5 companies I think Frontier Geosciences have also
     
    6 developed scrubber chemicals that are being
     
    7 testing. EPRI has been testing additives to
     
    8 improve scrubber capture at other plants, and
     
    9 they've been tested at TXU's Monticello plant and
     
    10 Minnkota Powers Young Plant. You know, the whole
     
    11 area here is not limited to what I -- there are
     
    12 things -- there are other tests that I'm sure I
     
    13 may not even be aware of. So there's been a fair
     
    14 amount of activity in this area.
     
    15 MR. HARRINGTON: Were these all
     
    16 short-term tests?
     
    17 DR. STAUDT: Could you tell me what
     
    18 you mean by short term?
     
    19 MR. HARRINGTON: 30 days or less?
     
    20 DR. STAUDT: I believe the Mt. Storm
     
    21 test went for -- went for quite a while and Mill
     
    22 Creek may have gone for a couple of weeks. And
     
    23 they were other tests on -- I think on some
     
    24 magnesium enhanced lime units that went for a
     
    KEEFE REPORTING COMPANY 72

     
     
     
     
     
    1 while too.
     
    2 HEARING OFFICER TIPSORD: I have to
     
    3 ask you the same question. Could you define a
     
    4 while?
     
    5 DR. STAUDT: For -- Anywhere from a
     
    6 few weeks to a few months.
     
    7 HEARING OFFICER TIPSORD: Thank you.
     
    8 Go ahead, Mr. Harrington.
     
    9 MR. HARRINGTON: Excuse me. Do these
     
    10 tests demonstrate over 90 percent removal with
     
    11 these systems.
     
    12 DR. STAUDT: Yes. Well, certainly at
     
    13 Mt. Storm. At LG & E's Mill Creek, they had 84
     
    14 percent across the scrubber, but if you would add
     
    15 to that the co-benefit of the -- of the -- of the
     
    16 ESP, and so these -- which would -- which would
     
    17 probably -- which would probably end up being 90
     
    18 percent. I don't know what -- I don't know what
     
    19 the co-benefit was at that plant for the ESP
     
    20 because they just didn't show the data.
     
    21 MR. HARRINGTON: Thank you.
     
    22 HEARING OFFICER TIPSORD: Question,
     
    23 Mr. Zabel?
     
    24 MR. ZABEL: What were the fuels used
     
    KEEFE REPORTING COMPANY 73

     
     
     
     
     
    1 at those plants?
     
    2 DR. STAUDT: Those were -- at LG & E's
     
    3 Mill Creek and Dominions Mt. Storm, those are
     
    4 high sulfur eastern coals. TXU'S Monticello is
     
    5 Texas Lignite. It's a tougher -- it's actually
     
    6 on those plants because on those types of coal,
     
    7 western coals, because they don't -- they produce
     
    8 primarily elemental mercury which a wet scrubber
     
    9 is not good at catching. So the oxidizing
     
    10 chemicals are used to -- to convert that
     
    11 elemental mercury to oxidized mercury which the
     
    12 wet scrubber is much more effective.
     
    13 MR. ZABEL: A dry scrubber would have
     
    14 the same problem? That's the question.
     
    15 DR. STAUDT: A dry scrubber on a
     
    16 western coal?
     
    17 MR. ZABEL: Right.
     
    18 DR. STAUDT: Yeah. A Dry FGD on
     
    19 western coal, by itself, it can get some removal
     
    20 but it's -- I would not necessarily expect it to
     
    21 get 90. But what they do is with the dry --
     
    22 there are ways to do it with dry scrubbers that
     
    23 have been shown with the oxidizing chemicals or
     
    24 with the halogenated sorbent.
     
    KEEFE REPORTING COMPANY 74

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: Question No.
     
    2 25.
     
    3 DR. STAUDT: "With respect to
     
    4 injection of halogenated activated carbon we call
     
    5 your attention to Figure 8.10 of the technical
     
    6 support document. Does that demonstrate that
     
    7 removal at or about 90 percent with some below
     
    8 and some slightly above was achieved for
     
    9 halogenated activated carbon injection prior to
     
    10 the ESPs? Were not all of those tests based upon
     
    11 a 30-day period?" Just go back to this.
     
    12 MR. HARRINGTON: Page 127.
     
    13 HEARING OFFICER TIPSORD: Thank you,
     
    14 Mr. Harrington.
     
    15 DR. STAUDT: I know it's -- where is
     
    16 that -- the exhibit -- if you go to -- if go to
     
    17 the next page of the exhibit actually.
     
    18 HEARING OFFICER TIPSORD: Exhibit 52.
     
    19 DR. STAUDT: Exhibit 52. First, I
     
    20 think it's worthwhile for you to look at the
     
    21 arrangement for a typical sorbent injection
     
    22 system just so you know what we're talking about
     
    23 at Figure 8.6. The Figure 8.10 document refers
     
    24 to injection of sorbent upstream of an ESP shown
     
    KEEFE REPORTING COMPANY 75

     
     
     
     
     
    1 similar as in Figure 8.6, where the boiler on the
     
    2 left there's an ESP system now -- when you see
     
    3 TOXECON 2 in that dash line, forget about that.
     
    4 We're not going to talk about that. We're mainly
     
    5 talking about injection upstream of an ESP. The
     
    6 sorbent gets sent then upstream of the ESP,
     
    7 captures the mercury that's in the gas phase and
     
    8 that sorbent is then captured in the ESP. And
     
    9 then the gas goes out of the ESP and up the
     
    10 stack.
     
    11 Figure 8.8 is just to show you the
     
    12 equipment, what it looks like. You can see on
     
    13 the left there's a duct coming from the boiler.
     
    14 The big building in the middle is the big Spray
     
    15 Dryer Absorber. It's used for SO2 control and
     
    16 then the big -- the smaller builder but pretty
     
    17 good sized on the right is the fabric filter.
     
    18 There's two ways of capturing particle matter.
     
    19 One is an ESP where you charge the particles and
     
    20 the charged particles get attracted to collection
     
    21 plates, tall plates that have -- and they get
     
    22 attracted to these collection plates. A fabric
     
    23 filter is -- think of it as a gigantic vacuum
     
    24 cleaner, okay. The gas gets pushed through a
     
    KEEFE REPORTING COMPANY 76

     
     
     
     
     
    1 fabric or a bag gets caught there and that's how
     
    2 the particles are collected. So that's what a
     
    3 fabric filter is. Most of the -- Mainly what
     
    4 we're talking about here in Figure 8.10 is
     
    5 injecting the sorbent upstream of an ESP.
     
    6 I wanted to give you that because
     
    7 we're going to -- you go -- if we go two -- go
     
    8 back two pages, you've got Figure 8.10, which is
     
    9 what the question refers to. You know, Figure
     
    10 8.10 and Figure 8.11 of the TSD shows test
     
    11 results from various sorbent injection tests.
     
    12 The figures show the percent mercury removal
     
    13 contributed to sorbent injection, that is over
     
    14 and above that of co-benefit removal versus the
     
    15 injection concentration measured in terms of
     
    16 pounds of sorbent per actual -- million actual
     
    17 cubic feet of boiler exhaust gas. So basically
     
    18 when it's concentration, it's how many pounds per
     
    19 volume of gas passing the -- through the duct.
     
    20 So I guess the total sorbent injection to the gas
     
    21 you multiply the injection rate, or whatever
     
    22 percent reduction you're looking for, times the
     
    23 volume of gas and you get how many pounds per
     
    24 hour sorbent you need to inject.
     
    KEEFE REPORTING COMPANY 77

     
     
     
     
     
    1 Figure 8 -- on Figure 8.10, two data
     
    2 points represent 30-day tests. Sorry. I'll get
     
    3 closer to the mike.
     
    4 HEARING OFFICER TIPSORD: Also you
     
    5 need to speak a little slower. That's the
     
    6 problem. You're actually running together more
     
    7 than not being able to hear.
     
    8 DR. STAUDT: Sorry.
     
    9 HEARING OFFICER TIPSORD: That's okay.
     
    10 DR. STAUDT: There are two data points
     
    11 that represent 30-day tests and those are the
     
    12 ones that are circled. The rest are results from
     
    13 parametric tests. Parametric tests may have run
     
    14 for a few days or for a few weeks. And what the
     
    15 intent of parametric test is, you want to see how
     
    16 much reduction you get at a particular injection
     
    17 rate. It's kind of like, you know, how fast you
     
    18 go for a certain amount of gas that you put in
     
    19 the engine for your car. You want to -- The more
     
    20 -- you put in more sorbent, you catch more
     
    21 mercury. So it's not surprising that some of
     
    22 these results are under 90 percent because they
     
    23 are intended to see how -- how the system
     
    24 responded to different injection rates, but the
     
    KEEFE REPORTING COMPANY 78

     
     
     
     
     
    1 two 30-day tests were above 90 percent removal.
     
    2 The other data points are from
     
    3 parametric tests, and the intent was to vary it
     
    4 so you do see some results under 90 percent. So
     
    5 these test results shows expected that the lower
     
    6 treatment rates less -- that lower treatment
     
    7 rates less mercury removal is possible. At a
     
    8 higher treatment rate, higher mercury removal is
     
    9 possible.
     
    10 And on this test only one full scale
     
    11 test on the data shows -- was not capable of
     
    12 achieving 90 percent at 3 pound per million ACF
     
    13 but it did for five. And that was the Stanton 1
     
    14 data which is a lignite coal not a PRB coal,
     
    15 which is somewhat more difficult, okay, so we
     
    16 would expect it to be a little higher.
     
    17 MR. NELSON: If I can interrupt and
     
    18 update a little bit on Stanton 1. Another
     
    19 company, URS, in the fall ran a 30-day test at
     
    20 Stanton 1 with subbituminous coal. The coal that
     
    21 is mostly here in Illinois, burned in Illinois.
     
    22 They weren't trying for 90 percent. They used
     
    23 our sorbent for 30 days, and they injected it an
     
    24 average injection rate of 1.6 pounds, so you can
     
    KEEFE REPORTING COMPANY 79

     
     
     
     
     
    1 put a little "X" if you go 1.6 they averaged 81
     
    2 percent above your curve that that Stanton 1, 81
     
    3 percent at 1.6 pounds per million cubic feet.
     
    4 DR. STAUDT: Now just draw your
     
    5 attention to the --
     
    6 HEARING OFFICER TIPSORD: Excuse me.
     
    7 Mr. Harrington?
     
    8 MR. HARRINGTON: Mr. Nelson has added
     
    9 testimony here. I just want to ask one quick
     
    10 question. What was the SCA on the Stanton unit?
     
    11 MR. NELSON: I do have that. Give me
     
    12 a second.
     
    13 HEARING OFFICER TIPSORD: It's working
     
    14 but you have to hold it right up to your mouth.
     
    15 It's a directional microphone.
     
    16 MR. NELSON: Stanton 1 plant it was
     
    17 470 square feet per thousand actual cubic feet
     
    18 per minute of gas.
     
    19 MR. HARRINGTON: Thank you.
     
    20 DR. STAUDT: I just want to draw your
     
    21 attention to just below that. What I've done is
     
    22 I've taken the full scale PRB data from Figure
     
    23 8.10 and below that I've applied it in a
     
    24 different way. And this is helpful in the -- Sid
     
    KEEFE REPORTING COMPANY 80

     
     
     
     
     
    1 testified earlier that about plotting these
     
    2 things in a logarithmic fashion engineers and
     
    3 scientists like to -- sometimes like to plot some
     
    4 data on a semi log because some things in -- some
     
    5 things in nature behave that way and you don't
     
    6 get straight lines. Most people don't like it,
     
    7 don't think that way in the semi log -- in
     
    8 logarithmic way, but hopefully this will help
     
    9 you.
     
    10 What happens is I've applied the log
     
    11 to the base 10 up to a fraction of mercury
     
    12 remaining, so minus one refers to -- if you
     
    13 remember back, it's equal to 10 to minus 1 or 10
     
    14 percent, which is the same as 90 percent removal.
     
    15 And so what I showed there I plot the data. You
     
    16 see the red line shows where 90 percent reduction
     
    17 is, and it also -- there's a, you know, at best a
     
    18 curve. So you get a fairly straight line for
     
    19 this data and it does get below 90 percent at
     
    20 adequately high treatment rates at about 3 pound
     
    21 per million ACF or more.
     
    22 I did the same thing with Figure 8.11.
     
    23 You go to the next page. There's a little more
     
    24 scatter with -- with the -- and this is the
     
    KEEFE REPORTING COMPANY 81

     
     
     
     
     
    1 bituminous coal. I also added data from DTE
     
    2 Monroe which is 60 percent bituminous, 40 percent
     
    3 PRB and has similar SO2 levels as some of the
     
    4 Illinois bituminous units we have here. And you
     
    5 can see that also plots in sort of a linear
     
    6 fashion. You can see that the data doesn't go
     
    7 down to a 90 percent without co-benefit but with
     
    8 co-benefits, which we would expect on a
     
    9 bituminous unit, you can reach 90 percent
     
    10 overall. Well, both halogenated and plain
     
    11 carbons were tested at Monroe, but not yours.
     
    12 HEARING OFFICER TIPSORD: Mr.
     
    13 Harrington, and then -- Go ahead.
     
    14 MR. HARRINGTON: What was the SCA at
     
    15 Monroe?
     
    16 DR. STAUDT: I knew you were going to
     
    17 ask that. I have it here, later in my notes. I
     
    18 can get to that. Monroe -- But now that you
     
    19 raised -- Monroe SCA was 258 square feet of
     
    20 collection per million per -- rather thousand
     
    21 cubic feet per minute of gas. Now we're going to
     
    22 get into in concept of SCA since you've raised
     
    23 it.
     
    24 MR. HARRINGTON: I figure we get the
     
    KEEFE REPORTING COMPANY 82

     
     
     
     
     
    1 data out so when we got to it, it would make some
     
    2 sense.
     
    3 DR. STAUDT: Yeah, yeah. But if you
     
    4 want me to go into my thoughts on SCA, we can do
     
    5 it now or later.
     
    6 HEARING OFFICER TIPSORD: Let's wait
     
    7 until later. Mr. Forcade, did you have a
     
    8 follow-up on all this?
     
    9 MR. FORCADE: Not until we get some
     
    10 data.
     
    11 HEARING OFFICER TIPSORD: Okay. In
     
    12 that case, I think we're done with question 25
     
    13 and 26 perhaps. Let's take a brief break. We've
     
    14 been at it about for about an hour and 45
     
    15 minutes. 10 minutes, please.
     
    16 (A 10-minute break was taken.)
     
    17 HEARING OFFICER TIPSORD: I would
     
    18 anticipate we'll go an hour and-a-half and so we
     
    19 will take another break about five o'clock just
     
    20 so you can all plan your breaks. And I believe
     
    21 we were on Ameren's question -- Was 26 answered?
     
    22 We're on Ameren's question 27.
     
    23 DR. STAUDT: Okay. 27, "At pages 127
     
    24 and 128 of the technical support document, it
     
    KEEFE REPORTING COMPANY 83

     
     
     
     
     
    1 states, "The Allen plant is a low-sulfur coal
     
    2 application and Lausche Plant has a higher sulfur
     
    3 coal (although not as high a sulfur level as in
     
    4 most bituminous coals fired in Illinois). As
     
    5 shown, 90 percent removal is approached at
     
    6 injection rates of 7 pounds per million ACF.
     
    7 There is currently no test data on units with
     
    8 sulfur levels as high as those in Illinois
     
    9 coals." How do these results support a
     
    10 requirement of over 90 percent removal from
     
    11 facilities firing high sulfur Illinois coal using
     
    12 halogenated sorbent injection?" And the four
     
    13 small Meredosia have significantly higher sulfur
     
    14 level than what has been tested elsewhere.
     
    15 Therefore, these units are likely to present some
     
    16 difficulty with respect to control mercury
     
    17 through sorbent injection or achieving --
     
    18 achieving 90 percent or the output based standard
     
    19 through sorbent injection, particularly at the
     
    20 rates -- or particularly at the emission levels
     
    21 in Illinois rule.
     
    22 Hutsonville currently had a lower
     
    23 sulfur level than the Meredosia units but a
     
    24 little higher than where sorbent has been tested.
     
    KEEFE REPORTING COMPANY 84

     
     
     
     
     
    1 It's my understanding that Hutsonville plans to
     
    2 burn PRB once they've burned off their high
     
    3 sulfur coal industry. If this understanding of
     
    4 Hutsonville is correct, they should be able to
     
    5 comply with the rule. If this understanding is
     
    6 incorrect, then Hutsonville will continue to burn
     
    7 some high sulfur of coal and may also fall into
     
    8 the category bituminous units with high sulfur.
     
    9 The other bituminous units are either
     
    10 scrubbed and will have a high co-benefit removal
     
    11 or they have coal sulfur levels in the range of
     
    12 what has been tested elsewhere.
     
    13 HEARING OFFICER TIPSORD: Coal sulfur
     
    14 level?
     
    15 DR. STAUDT: Coal sulfur level, yes.
     
    16 HEARING OFFICER TIPSORD: Follow-up?
     
    17 Question 28.
     
    18 DR. STAUDT: 28, "TOXECON. At page
     
    19 129 of the technical support document, it states
     
    20 "Except on western coals downstream of a Spray
     
    21 Dryer Absorber, PAC, which is powder activated
     
    22 carbon, (untreated or halogenated) in TOXECON
     
    23 arrangements or fabric filter arrangements is
     
    24 generally acceptable to be capable of over 90
     
    KEEFE REPORTING COMPANY 85

     
     
     
     
     
    1 percent removal because the sorbent is in very
     
    2 intimate contact with the gas stream as it passes
     
    3 through the filter cake of the fabric filter."
     
    4 What is the basis for this statement?" As we
     
    5 spoke about a fabric filter before, and just to
     
    6 give you information, I don't know if TOXECON is
     
    7 shown -- if you go back to Figure -- Figure 8.7
     
    8 in this --
     
    9 HEARING OFFICER TIPSORD: Exhibit --
     
    10 DR. STAUDT: -- Exhibit 52. And what
     
    11 TOXECON is, you have an existing electrostatic
     
    12 precipitator and you install a fabric filter
     
    13 downstream and between the electrostatic
     
    14 precipitator and the fabric filter, you inject
     
    15 sorbent and the sorbent, you know, removes the --
     
    16 removes the mercury and it's collected on the
     
    17 bag.
     
    18 In a fabric filter the gas passes
     
    19 through a filter that sorbent has built up on.
     
    20 This gives the gas very good contact with the
     
    21 sorbent for good mercury caption -- capture
     
    22 rather. This has been supported by several full
     
    23 scale and pilot scale tests. In fact, there have
     
    24 been no tests that I am aware where over 90
     
    KEEFE REPORTING COMPANY 86

     
     
     
     
     
    1 percent removal is not shown to be achievable.
     
    2 Even Southern Company has reported that 90
     
    3 percent is achievable in a TOXECON arrangement
     
    4 with a properly designed baghouse, quote from the
     
    5 paper the co-authors is shown Table 8.2 which is
     
    6 a couple pages later. You can look at -- it's on
     
    7 the second to last page of Exhibit 52. And this
     
    8 shows the -- this is out of the TSD. You know,
     
    9 they said TOXECON units designed at lower
     
    10 air-to-cloth ratio than --
     
    11 MR. HARRINGTON: What page are you
     
    12 referring to?
     
    13 DR. STAUDT: This is the second to
     
    14 last page of Exhibit 52.
     
    15 MR. KIM: It's also Table 8.2 of the
     
    16 TSD.
     
    17 DR. STAUDT: Yes. It shows the data
     
    18 from -- taken at gas and for stimulated removal
     
    19 simulated -- simulated air-to-cloth ratio of 6.0
     
    20 and air-to-cloth ratio is essentially how much
     
    21 fabric -- there's a ratio of how much air you are
     
    22 allowed to pass through how much fabric. So a
     
    23 low air-to-cloth ratio means that you have more
     
    24 fabric -- more fabric filters. You can imagine
     
    KEEFE REPORTING COMPANY 87

     
     
     
     
     
    1 -- Fabric filters, they're also called baghouses
     
    2 because they have like these long fabric bags,
     
    3 and they hang hundreds of thousands of them and
     
    4 they take the -- the air-to-cloth ratio is how
     
    5 many cubic feet -- a ratio of how many cubic feet
     
    6 of air pass through how many square feet of
     
    7 fabric in a certain amount of time. And the
     
    8 air-to-cloth ratio of six is what they've
     
    9 established as being the proper air-to-cloth
     
    10 ratio for a TOXECON system.
     
    11 But you can see the quote there from
     
    12 Southern Company who has tested TOXECON on their
     
    13 Gaston Station, that it is capable of 90 percent
     
    14 mercury removal for the TOXECON baghouse is
     
    15 recommended that the maximum designed gross
     
    16 air-to-cloth ratio be 6.0 feet per minute.
     
    17 HEARING OFFICER TIPSORD: And for the
     
    18 court reporter, TOXECON is T-O-X-E-C-O-N. Mr.
     
    19 Harrington?
     
    20 MR. HARRINGTON: Would the -- Table
     
    21 8.2 is referring to the Gaston study, the
     
    22 Southern Company; is that correct?
     
    23 DR. STAUDT: Yes, that's from the
     
    24 Gaston study.
     
    KEEFE REPORTING COMPANY 88

     
     
     
     
     
    1 MR. HARRINGTON: And their baghouse
     
    2 was originally designed at 8 to 1 ratio, is it
     
    3 not?
     
    4 DR. STAUDT: Their baghouse -- Yes,
     
    5 that's correct. It was designed -- It was never
     
    6 designed to be a TOXECON unit.
     
    7 MR. HARRINGTON: And they did not
     
    8 achieve 90 percent operating at 8 to 1, did they?
     
    9 DR. STAUDT: No, that's why -- that's
     
    10 why for TOXECON systems you design at 8.0. See,
     
    11 at Gaston Station they had an existing
     
    12 installation where years ago they installed a
     
    13 fabric filter downstream of their Hot-Side ESP.
     
    14 This is because to get better particular removal,
     
    15 and that fabric filter was designed from the
     
    16 start just to catch the small amount of
     
    17 particles, small amount of particle matter that
     
    18 escapes the Hot-Side ESP. It was never designed
     
    19 to catch more than that.
     
    20 When they ran a test program there for
     
    21 TOXECON, because it was a convenient location,
     
    22 you already had the fabric filter, as I'm sure
     
    23 we're going to talk. Fabric filter installations
     
    24 are expensive. They take time to put into place.
     
    KEEFE REPORTING COMPANY 89

     
     
     
     
     
    1 So it was convenient for the Department of Energy
     
    2 to test this concept at the Gaston Station
     
    3 because they had this arrangement already there.
     
    4 MR. HARRINGTON: And did they run an
     
    5 experiment of some kind to see whether it would
     
    6 work at 6 to 1?
     
    7 DR. STAUDT: That's correct, yes.
     
    8 MR. HARRINGTON: And how long was that
     
    9 experiment?
     
    10 DR. STAUDT: That was a short-term
     
    11 test. It may have been a few days.
     
    12 MR. HARRINGTON: A few days. Is there
     
    13 any unit that's been running the TOXECON system
     
    14 at 6 to 1 ratio for any period of time?
     
    15 DR. STAUDT: Well, since we don't
     
    16 have -- No, because we haven't had the mercury
     
    17 rules to put these systems in place, nobody would
     
    18 put the TOXECON in place.
     
    19 MR. HARRINGTON: Isn't it true that
     
    20 the system has been installed at Presque Isle?
     
    21 DR. STAUDT: A system has been
     
    22 installed at Presque Isle, that's correct.
     
    23 MR. HARRINGTON: What happened to that
     
    24 system?
     
    KEEFE REPORTING COMPANY 90

     
     
     
     
     
    1 DR. STAUDT: The system is -- today is
     
    2 up and running is my understanding.
     
    3 MR. HARRINGTON: What happened when
     
    4 they started it up?
     
    5 DR. STAUDT: They ran for several
     
    6 weeks, did some parametric testing. And after a
     
    7 period of time a fire was found in the baghouse
     
    8 and that has been attributed to inadequate
     
    9 evacuation of the fabric filter and improper
     
    10 operation of the hopper heaters. Carbon will not
     
    11 burn -- will not burn at the gas conditions that
     
    12 exist in a fabric filter. It won't ignite at
     
    13 about 300 degrees. It simply won't. We have to
     
    14 do -- The only way it will ignite is you need to
     
    15 heat it up. The -- At Presque Isle, like many
     
    16 plants, they have hopper heaters installed. And
     
    17 what they're designed to do is to prevent
     
    18 condensation from building up inside -- inside
     
    19 the hoppers. If you don't evacuate the hoppers,
     
    20 basically the solid that gets collected, if you
     
    21 don't evacuate it and if it builds up and the
     
    22 hopper heaters aren't properly set, well, low and
     
    23 behold they heat up -- it heats up to a
     
    24 temperature that's too high.
     
    KEEFE REPORTING COMPANY 91

     
     
     
     
     
    1 My understanding at the conference
     
    2 call last week with the project manager for that
     
    3 program, and from what they told me, it is up and
     
    4 running now as far as We Energy is concerned, who
     
    5 owns the plant. They see it as an operational
     
    6 issue. They've learned a lesson.
     
    7 MR. HARRINGTON: But essentially the
     
    8 baghouse burned in significant part, didn't it?
     
    9 DR. STAUDT: Excuse me?
     
    10 MR. HARRINGTON: A significant number
     
    11 of bags burned?
     
    12 DR. STAUDT: That is correct.
     
    13 MR. HARRINGTON: And so you don't have
     
    14 data from that system at this point in time?
     
    15 DR. STAUDT: Yes, we do. The
     
    16 parametric test data has been released.
     
    17 MR. HARRINGTON: Under normal
     
    18 operating conditions?
     
    19 DR. STAUDT: Under normal operating
     
    20 conditions, yes.
     
    21 MR. HARRINGTON: What have they
     
    22 established?
     
    23 DR. STAUDT: They can get over 90
     
    24 percent -- 90 percent removal at about 2 pound
     
    KEEFE REPORTING COMPANY 92

     
     
     
     
     
    1 per million ACF, and that was using untreated
     
    2 carbon. They probably would get better
     
    3 performance -- a lower treatment rate with
     
    4 halogenated carbon.
     
    5 MR. HARRINGTON: How long did they
     
    6 operate it?
     
    7 DR. STAUDT: It was a period of
     
    8 several weeks.
     
    9 MR. KIM: For the record I think we
     
    10 should have Presque Isle spelled for the court
     
    11 reporter.
     
    12 DR. STAUDT: P-R-E-S-C-Q-U-E then
     
    13 I-S-L-E.
     
    14 HEARING OFFICER TIPSORD: Ms. Bugel,
     
    15 did you have a question. No? Okay. I'm seeing
     
    16 things. Mr. Bonebrake?
     
    17 MR. BONEBRAKE: Mr. Staudt, you
     
    18 mentioned that fabric filters are expensive. How
     
    19 extensive typically are fabric filters?
     
    20 DR. STAUDT: They vary in cost based
     
    21 upon -- but you might see them in the range, you
     
    22 know, $40 a kilowatt to -- to a lot higher
     
    23 numbers, but certainly much more expensive than a
     
    24 sorbent injection system.
     
    KEEFE REPORTING COMPANY 93

     
     
     
     
     
    1 MR. BONEBRAKE: And what drives that
     
    2 cost range?
     
    3 DR. STAUDT: The costs are determined
     
    4 by essentially the volume of gas being -- that's
     
    5 being -- being captured. The cost would also be
     
    6 driven by factors in terms of the -- you know,
     
    7 where it's located. There may be site specific
     
    8 things about duct work and what have you but
     
    9 there are a number of factors, but the biggest
     
    10 ones that determine the fabric filter unit cost
     
    11 are air-to-cloth ratio and the volume of gas it's
     
    12 creating and sometimes the level of the amount of
     
    13 particulate that's being driven.
     
    14 MR. BONEBRAKE: So if you --
     
    15 considering a unit that was planning to install a
     
    16 fabric filter for TOXECON purposes for mercury
     
    17 reduction in the manner that you have discussed,
     
    18 what would be your expected fabric filter cost?
     
    19 DR. STAUDT: Are you referring just to
     
    20 the fabric filter or the entire total installed
     
    21 --
     
    22 MR. BONEBRAKE: Right now I'm just
     
    23 talking about the fabric filter portion of the
     
    24 TOXECON arrangement.
     
    KEEFE REPORTING COMPANY 94

     
     
     
     
     
    1 DR. STAUDT: It might be in the range
     
    2 of about $30 a kilowatt or so.
     
    3 MR. BONEBRAKE: And that's below the
     
    4 $40 kilowatt number that --
     
    5 DR. STAUDT: Well, I guess, you know,
     
    6 I gave you a number basically somewhere in the
     
    7 range of, you know, these -- I can't give --
     
    8 there isn't an exact number. You're asking me
     
    9 off the top of my head because there are a lot of
     
    10 variables that might determine what that cost
     
    11 might be.
     
    12 MR. BONEBRAKE: What does -- what does
     
    13 $30 per KW translate into for a 300 megawatt
     
    14 facility?
     
    15 DR. STAUDT: I think it would be about
     
    16 nine million dollars.
     
    17 MR. BONEBRAKE: So are you saying, Mr.
     
    18 Staudt, that a 300 megawatt facility in Illinois
     
    19 could install a baghouse for approximately nine
     
    20 million dollars?
     
    21 DR. STAUDT: No, I didn't say that.
     
    22 Because you asked me just the fabric filter
     
    23 itself. There are other costs involved too, and
     
    24 that would be the duct work and ID fan and things
     
    KEEFE REPORTING COMPANY 95

     
     
     
     
     
    1 like that.
     
    2 MR. BONEBRAKE: Okay. What would be
     
    3 the additional costs above and beyond the nine
     
    4 million for the entire baghouse?
     
    5 DR. STAUDT: That will vary. That
     
    6 will vary based upon the specific site. Very --
     
    7 You know, Presque Isle was an expensive
     
    8 application because there was long series of duct
     
    9 work and they had three very small -- three small
     
    10 boilers that they had a complex duct work just to
     
    11 get them -- the duct work connected together and,
     
    12 in fact, it's shown --
     
    13 HEARING OFFICER TIPSORD: You're
     
    14 fading away from the microphone.
     
    15 DR. STAUDT: In Exhibit 52, I think
     
    16 it's the fourth page on Exhibit 52, it's Figure
     
    17 8.12. It says configuration of the TOXECON
     
    18 system at the Presque Isle plant in Marquette,
     
    19 Michigan. What you can see is they -- normally
     
    20 you would want to have the fabric filter located
     
    21 right next to the duct work and near the stack.
     
    22 Apparently there wasn't the room there. They had
     
    23 to locate it at another location so there was
     
    24 long duct work -- long set of duct work and there
     
    KEEFE REPORTING COMPANY 96

     
     
     
     
     
    1 was -- and that in this situation three boilers,
     
    2 so a lot of dampers and other controls that had
     
    3 to be added. So this would be pretty -- this I
     
    4 would say is probably a very costly approach.
     
    5 You know, this is towards the high end of the
     
    6 complexity but there might be others that could
     
    7 approach it. But in most cases I would expect --
     
    8 in many cases there might be -- might be less
     
    9 complex than this, but it's going to be
     
    10 determined at each individual location.
     
    11 MR. BONEBRAKE: Is there a rule of
     
    12 thumb from your perspective, Mr. Staudt, on how
     
    13 much the total baghouse would cost as compared to
     
    14 the nine million dollar figure for the fabric
     
    15 filter that we were talking about earlier?
     
    16 DR. STAUDT: You know, there is not an
     
    17 easy rule of thumb because you have to look at
     
    18 every application specifically.
     
    19 HEARING OFFICER TIPSORD: Mr.
     
    20 Harrington?
     
    21 MR. HARRINGTON: Perhaps for the Board
     
    22 and the record it would be useful you can
     
    23 describe the components of the baghouse
     
    24 installation so we get a better picture of what
     
    KEEFE REPORTING COMPANY 97

     
     
     
     
     
    1 we're talking about for the Board. I have an
     
    2 understanding but it's a layman understanding.
     
    3 Rather than me asking many questions, maybe you
     
    4 could explain everything that goes into it.
     
    5 DR. STAUDT: Okay.
     
    6 MR. HARRINGTON: If that's
     
    7 appropriate.
     
    8 DR. STAUDT: The fabric filter itself,
     
    9 it's a large box. Imagine a large box on the
     
    10 top. There's a plenum which is basically a steel
     
    11 sheet with holes in it, all right. Above the
     
    12 plenum is the clean side. Below the plenum is
     
    13 the dirty side. What happens through these holes
     
    14 you drop baskets, long baskets and around those
     
    15 baskets you have filter bags and these are maybe
     
    16 20 feet long or so. Think about a sock about
     
    17 that much -- about 6 inches in diameter that's
     
    18 say 20 feet long. And they're -- depending upon
     
    19 the size of the baghouse, there may be 100s,
     
    20 maybe, you know, a thousand bags or more. There
     
    21 are large big boxes. The gas flows up through,
     
    22 you know, through these -- through these series
     
    23 of socks basically, excuse me, filter bags,
     
    24 passes from the dirty side through the clean side
     
    KEEFE REPORTING COMPANY 98

     
     
     
     
     
    1 and the particles stay -- the solid particles
     
    2 stay on the outside of the bag.
     
    3 Periodically, depending upon the type
     
    4 of baghouse, some are called reverse -- reverse
     
    5 gas baghouses, some are called pulse jet
     
    6 baghouses, but there's a cleaning -- cleaning
     
    7 action where periodically they, you know, this
     
    8 big baghouse with this plenum, they're actually
     
    9 different compartments. They shut the
     
    10 compartment pulse -- either send a pulse of air
     
    11 backwards through the bags or they actually blow
     
    12 gas backwards through the bags. That takes the
     
    13 dirty particles. They drop down into what are
     
    14 called hoppers below, basically a big bin at the
     
    15 bottom of the baghouse. Then, you know, over
     
    16 time, you know, what you do is as that stuff
     
    17 collects in the bottom in the hopper, you --
     
    18 actually there's typically a -- the rotary valve
     
    19 or air lock or something like that that continue
     
    20 -- that takes this material and goes -- takes the
     
    21 solid down to material handling system like a
     
    22 conveyer or something like that and then it gets
     
    23 carried away.
     
    24 As you can imagine, putting gas
     
    KEEFE REPORTING COMPANY 99

     
     
     
     
     
    1 through this filter bag, there's a pressure drop
     
    2 and depending upon how extensive duct work is,
     
    3 there may be additional pressure drop from that.
     
    4 And so usually when you get -- put in a fabric
     
    5 filter, you put in a booster fan as well to
     
    6 overcome this additional pressure drop. So the
     
    7 main components are this big device called the
     
    8 fabric filter. There is, you know, the filters
     
    9 inside. There's duct work. There's a fan and
     
    10 it's, you know, it draws power, and we're going
     
    11 to have questions about the power it draws and,
     
    12 you know, and that's -- those are the key
     
    13 components, and there's the duct work to get to
     
    14 and from the boiler.
     
    15 And if you're -- if you're doing what
     
    16 they're doing at Presque Isle, they're trying to
     
    17 connect three different boilers together. You
     
    18 got a lot of dampers too. So, you know, you got
     
    19 these big -- think of them as a valve for a big
     
    20 duct, you know, something that opens and shuts, a
     
    21 big duct, so there's a lot of equipment involved.
     
    22 HEARING OFFICER TIPSORD: Mr.
     
    23 Harrington?
     
    24 MR. HARRINGTON: Maybe just to
     
    KEEFE REPORTING COMPANY 100

     
     
     
     
     
    1 complete the picture, for example, at Presque
     
    2 Isle, what would be the approximate dimensions of
     
    3 this baghouse?
     
    4 DR. STAUDT: Oh, off the top of my
     
    5 head I don't know.
     
    6 MR. HARRINGTON: Are we talking 20
     
    7 feet by 20 feet or hundreds of feet?
     
    8 DR. STAUDT: It's probably bigger than
     
    9 that. I mean, I haven't been to the Presque Isle
     
    10 plant so I don't know exactly what it would be.
     
    11 It's probably maybe on the order of 40 feet by 40
     
    12 feet, but I'm -- I don't know exactly off the top
     
    13 of my head.
     
    14 MR. HARRINGTON: When you speak of the
     
    15 ducts, what would be the size of the duct work
     
    16 typically at a power plant?
     
    17 DR. STAUDT: Oh, the ducts can be
     
    18 maybe, you know, 10 feet by 20 feet, 10 feet by
     
    19 30 feet, things like that. So it's fairly large
     
    20 pieces of duct work, yeah. That's the cross
     
    21 section.
     
    22 MR. HARRINGTON: And the fans will
     
    23 have to move the air from the original exit point
     
    24 of the plant through the baghouse -- through the
     
    KEEFE REPORTING COMPANY 101

     
     
     
     
     
    1 baghouse back to the stack and up the stack;
     
    2 right?
     
    3 DR. STAUDT: That's correct.
     
    4 HEARING OFFICER TIPSORD: Mr.
     
    5 Bonebrake?
     
    6 MR. BONEBRAKE: The Presque Isle power
     
    7 plant, is its capacity around 270 megawatts?
     
    8 DR. STAUDT: Yeah. We have three --
     
    9 three units, each one 90 megawatts, yeah.
     
    10 MR. BONEBRAKE: And was the cost of
     
    11 the TOXECON system at that plant about $126 per
     
    12 kilowatt?
     
    13 DR. STAUDT: Somewhere in the range of
     
    14 that. It's 120 I've heard, yeah.
     
    15 MR. BONEBRAKE: And did you calculate
     
    16 the cost of TOXECON system at one of the Waukegan
     
    17 units, Mr. Staudt?
     
    18 DR. STAUDT: Waukegan and Will County,
     
    19 yes.
     
    20 MR. BONEBRAKE: Are those cost
     
    21 calculations reflected in Table 8.9 of the TSD?
     
    22 DR. STAUDT: Yes, they are.
     
    23 MR. BONEBRAKE: I believe page 163 of
     
    24 the TSD?
     
    KEEFE REPORTING COMPANY 102

     
     
     
     
     
    1 DR. STAUDT: Yes.
     
    2 MR. BONEBRAKE: What was your total
     
    3 cost calculation for the TOXECON system on -- at
     
    4 the Waukegan unit for which you indicated a
     
    5 TOXECON system would be required assuming that it
     
    6 is your indication from this table?
     
    7 DR. STAUDT: Well, I used $60 a
     
    8 kilowatt, so I'll look at what --
     
    9 HEARING OFFICER TIPSORD: Excuse me.
     
    10 What plan are we looking at again?
     
    11 DR. STAUDT: At Waukegan it was almost
     
    12 20 million dollars.
     
    13 MR. BONEBRAKE: And was that Waukegan
     
    14 Unit No. 7?
     
    15 DR. STAUDT: I believe so, yes.
     
    16 MR. BONEBRAKE: And does that
     
    17 particular unit have a Hot-Side ESP?
     
    18 DR. STAUDT: That is correct. That's
     
    19 my understanding.
     
    20 MR. BONEBRAKE: And did you determine
     
    21 then that the TOXECON system at that particular
     
    22 unit would be required to comply with the
     
    23 proposed Illinois rule?
     
    24 DR. STAUDT: It was my -- when I
     
    KEEFE REPORTING COMPANY 103

     
     
     
     
     
    1 estimated the cost, it was my opinion that that
     
    2 was the technology that could achieve 90 percent
     
    3 removal and comply with the Illinois rule.
     
    4 That's not to say that the plant may choose
     
    5 another technology.
     
    6 MR. BONEBRAKE: The -- You mentioned a
     
    7 $60 per KW figure?
     
    8 DR. STAUDT: That's correct.
     
    9 MR. BONEBRAKE: Can you describe for
     
    10 us how you arrived at that number?
     
    11 DR. STAUDT: That's fairly consistent
     
    12 with what -- in the same range as what EPA and
     
    13 what I've seen from EPRI in the past, but 120 is
     
    14 high and that's not to say that these units might
     
    15 not have costs that are higher than what I've
     
    16 shown here.
     
    17 MR. BONEBRAKE: The -- the number
     
    18 you've reflected for that Waukegan unit is
     
    19 19,680,000, is that correct, for the TOXECON
     
    20 system?
     
    21 DR. STAUDT: That's correct.
     
    22 MR. BONEBRAKE: Does that include the
     
    23 capital cost and all installation cost for both
     
    24 the --
     
    KEEFE REPORTING COMPANY 104

     
     
     
     
     
    1 DR. STAUDT: That's intended to be all
     
    2 inconclusive.
     
    3 MR. BONEBRAKE: All inconclusive. And
     
    4 in terms of the equipment and installation
     
    5 activity that are included in that figure, can
     
    6 you describe all of that for us, please?
     
    7 DR. STAUDT: I did not do a detailed
     
    8 engineering analysis of the site. What is
     
    9 typically done on these kind of cost estimates is
     
    10 you use representative numbers. It's a dollar
     
    11 per kilowatt. And I did not breakdown how much
     
    12 of that was steel versus labor versus other --
     
    13 other materials.
     
    14 MR. BONEBRAKE: Does the cost number
     
    15 that you have there reflect then the installation
     
    16 of a baghouse?
     
    17 DR. STAUDT: It reflects the -- all
     
    18 capital costs -- all of the -- all capital costs
     
    19 associated with installing fabric filter, duct
     
    20 work and the -- and the sorbent injection system,
     
    21 but recognizing that I did not have the
     
    22 opportunity to include any -- do a detailed site
     
    23 specific analysis. So there is a possibility
     
    24 that that could be -- that if some were to
     
    KEEFE REPORTING COMPANY 105

     
     
     
     
     
    1 actually install a TOXECON system at that unit,
     
    2 it might be -- the cost might be significantly
     
    3 different.
     
    4 MR. BONEBRAKE: I assume you haven't
     
    5 seen any cost proposal with respect to
     
    6 installation of such a system at that particular
     
    7 unit?
     
    8 DR. STAUDT: No, I have not.
     
    9 MR. BONEBRAKE: You are -- is it also
     
    10 your opinion, and I'm looking a little bit lower
     
    11 down on Table 8.9, still on page 163, with
     
    12 respect to the Will County site where you
     
    13 identified TOXECON?
     
    14 DR. STAUDT: That's correct.
     
    15 MR. BONEBRAKE: With respect to the
     
    16 Will County site, is it also your opinion that
     
    17 TOXECON would be required for that Will County
     
    18 unit to comply with the proposed Illinois rule
     
    19 mercury reduction requirements?
     
    20 DR. STAUDT: Well, again, the approach
     
    21 that the rule did not specify an emission -- a
     
    22 technology for emission reduction requirement,
     
    23 it's my opinion that this is a technology that --
     
    24 that will enable the plant to achieve, comply
     
    KEEFE REPORTING COMPANY 106

     
     
     
     
     
    1 with the emission reduction requirement, but the
     
    2 plant may choose another course. They may find a
     
    3 better way to do it.
     
    4 MR. BONEBRAKE: Well, is it your view
     
    5 that installation and operation of ACI alone,
     
    6 that is, without a -- also the installation of a
     
    7 baghouse, would permit the Will County unit to
     
    8 achieve the reduction requirements specified by
     
    9 the proposed Illinois rule?
     
    10 DR. STAUDT: If the sorbent injection
     
    11 is done with -- in a TOXECON arrangement, I
     
    12 believe it would enable the plant to meet the
     
    13 emission reduction requirements. Without a
     
    14 TOXECON arrangement, I am less certain. I
     
    15 haven't seen data that indicates that sorbent
     
    16 injection alone upstream of a Hot-Side ESP will
     
    17 get those kind of removal rates.
     
    18 MR. BONEBRAKE: And your cost
     
    19 calculation for the TOXECON system, it --
     
    20 Actually let me identify this unit. Which Will
     
    21 County unit is it that you've identified as a
     
    22 TOXECON unit?
     
    23 DR. STAUDT: That -- I believe it's
     
    24 Will County 3.
     
    KEEFE REPORTING COMPANY 107

     
     
     
     
     
    1 MR. BONEBRAKE: And your projected
     
    2 cost for a TOXECON system at that unit is
     
    3 17,940,000; is that right?
     
    4 DR. STAUDT: Well, this is --- this is
     
    5 basically a ballpark cost. This is -- it's just
     
    6 used as an example cost. In terms of estimating,
     
    7 that's how -- I used $60 a kilowatt. As I said,
     
    8 actual cost, if that's the way the company
     
    9 pursues it, it maybe be higher, may be lower.
     
    10 MR. BONEBRAKE: Did you use the same
     
    11 methodology that you described for us with
     
    12 respect to the Waukegan unit for the Will County
     
    13 unit to derive the cost number?
     
    14 DR. STAUDT: That's correct.
     
    15 HEARING OFFICER TIPSORD: Ready to go
     
    16 on to question 29? Mr. Harrington?
     
    17 MR. KIM: Can I ask one follow-up
     
    18 question of Mr. Nelson before we go on?
     
    19 HEARING OFFICER TIPSORD: Sure.
     
    20 MR. KIM: I haven't asked before this,
     
    21 but he may not be able to answer. Concerning the
     
    22 two TOXECON estimates that Dr. Staudt was
     
    23 describing, would your understanding of those --
     
    24 of those facilities in that application yield the
     
    KEEFE REPORTING COMPANY 108

     
     
     
     
     
    1 same type of cost figures, or would it be any
     
    2 different than Dr. Staudt's?
     
    3 MR. NELSON: He provided all the
     
    4 information that I'm aware of as well, so it's
     
    5 reasonable.
     
    6 MR. KIM: Okay.
     
    7 MR. NELSON: But again, there may be
     
    8 Hot-Side sorbents that will work cheaper than
     
    9 that but that remains to be seen.
     
    10 MR. KIM: Thank you.
     
    11 HEARING OFFICER TIPSORD: Mr.
     
    12 Harrington?
     
    13 MR. HARRINGTON: We may pick this up
     
    14 again, but with respect to the TOXECON cost
     
    15 estimates at Presque Isle, do you have any reason
     
    16 to believe that any installation that might be
     
    17 required on Illinois facilities wouldn't be in
     
    18 the same range as the Presque Isle cost?
     
    19 DR. STAUDT: I have no reason to
     
    20 believe that they'd be higher than that. My
     
    21 expectation is that that is a fairly complex
     
    22 application so that's probably towards the high
     
    23 end, and in some cases they may approach that,
     
    24 but I haven't look -- I haven't made detailed --
     
    KEEFE REPORTING COMPANY 109

     
     
     
     
     
    1 a detailed estimate of what it would be.
     
    2 MR. HARRINGTON: Have you been keeping
     
    3 track of costs, steel, fans, baghouses over the
     
    4 last year or so?
     
    5 DR. STAUDT: I don't -- I don't have
     
    6 -- I don't maintain a database myself, but I'm
     
    7 generally aware that costs have, you know, some
     
    8 costs have been going up.
     
    9 MR. HARRINGTON: Do you have any idea
     
    10 by how much?
     
    11 DR. STAUDT: Not -- No, I don't.
     
    12 MR. HARRINGTON: Thank you.
     
    13 HEARING OFFICER TIPSORD: Mr.
     
    14 Bonebrake?
     
    15 MR. BONEBRAKE: A follow-up clarifying
     
    16 question, Mr. Staudt. The $60 per KW number that
     
    17 we've been talking about, that doesn't include
     
    18 any unit specific upgrade requirements such as an
     
    19 upgrade in fans that might be required with the
     
    20 installation of the TOXECON system; is that
     
    21 correct?
     
    22 DR. STAUDT: No, that's not correct.
     
    23 MR. BONEBRAKE: Okay. Can you
     
    24 describe for me what was inaccurate in the
     
    KEEFE REPORTING COMPANY 110

     
     
     
     
     
    1 statement I just made?
     
    2 DR. STAUDT: Could you repeat the
     
    3 question, please?
     
    4 (The Reporter read from the record as
     
    5 follows: A follow-up clarifying
     
    6 question, Mr. Staudt. The $60 per KW
     
    7 number that we've been talking about,
     
    8 that doesn't include any unit
     
    9 specific upgrade requirements such as
     
    10 an upgrade in fans that might be
     
    11 required with the installation of the
     
    12 TOXECON system; is that correct?)
     
    13 DR. STAUDT: Yeah, that's incorrect.
     
    14 That would be an incorrect statement. In my --
     
    15 The $60 per kilowatt number is intended to be an
     
    16 all inclusive number, but bearing in mind, this
     
    17 is a very rough estimate, not intended to be a
     
    18 detailed engineering study. This is -- this is
     
    19 basically using, you know, the type of -- the
     
    20 type of very first order approximate cost
     
    21 estimate of the nature that perhaps somebody like
     
    22 EPA use -- the USEPA might use in terms of
     
    23 establishing a rule. I did not do a detailed
     
    24 engineering evaluation so I don't have line item
     
    KEEFE REPORTING COMPANY 111

     
     
     
     
     
    1 cost for what makes up that $60 kilowatt number.
     
    2 I hope that clears the air on what it does and
     
    3 what it doesn't.
     
    4 MR. BONEBRAKE: I think so, but let
     
    5 ask a follow-up. I assume, therefore, that it
     
    6 would not surprise you if they -- if a cost
     
    7 calculation generated from a detailed engineering
     
    8 study of a TOXECON system would result in a cost
     
    9 estimate considerably higher than the numbers in
     
    10 your chart?
     
    11 DR. STAUDT: It would not surprise me
     
    12 if the cost were -- were considerably higher, but
     
    13 one of the things I thought about is if -- even
     
    14 if you doubled the estimates that -- doubled it
     
    15 from 60 to $120 a kilowatt, if you take that cost
     
    16 -- if -- took each one of them from, say, roughly
     
    17 20 million to 40 million for a total impacted
     
    18 cost for the rule of about 40 million, an
     
    19 additional 40 million dollars on an annualized
     
    20 basis using about 15 percent, that's about a six
     
    21 million dollar annualized cost impact to the rule
     
    22 across the state. So that's about -- so if you
     
    23 look at the total cost of the rule that I've
     
    24 estimated cost over CAMR of being somewhere in
     
    KEEFE REPORTING COMPANY 112

     
     
     
     
     
    1 the range of 30 to 40 million dollars, well, now,
     
    2 you know, it changes by perhaps 20 percent even
     
    3 if the cost of those units are much greater.
     
    4 HEARING OFFICER TIPSORD: Mr.
     
    5 Bonebrake, are you --
     
    6 MR. BONEBRAKE: I was just going to
     
    7 say the calculations you just referred is
     
    8 predicated upon all the units in the state
     
    9 meeting only the technology that you've
     
    10 identified in Table 8.9; is that correct?
     
    11 DR. STAUDT: Well, the calculation
     
    12 I've -- was based -- That's not correct. It's
     
    13 based upon those two units. The other -- Those
     
    14 two -- I'm assuming that those two units might
     
    15 use TOXECON and only -- I'm only looking at those
     
    16 two units. They may not -- the owner of those
     
    17 units, Midwest Generation, may choose to not use
     
    18 TOXECON because perhaps Sorbent Technologies may
     
    19 have a better sorbent to help them or some of
     
    20 these other units may choose something other than
     
    21 sorbent injection, but this is -- this estimate
     
    22 is based upon an assumption about what people
     
    23 might use to comply with the rule.
     
    24 MR. NELSON: If I may, another less
     
    KEEFE REPORTING COMPANY 113

     
     
     
     
     
    1 expensive technology than TOXECON is simply to
     
    2 change your duct work so you convert your
     
    3 Hot-Side into a Cold-Side. We've done work with
     
    4 Hot-Sides. Duke has a lot of these. They're
     
    5 small units. And that is really the alternative
     
    6 that they were looking at. The way the typical
     
    7 gas train works is the gas comes out about 700
     
    8 degrees, then you -- if you have a Hot-Side ESP,
     
    9 it operates at 600, 700 degrees, then it goes
     
    10 through an air pre-heater that drops it to 300,
     
    11 then you go to a Cold-Side ESP if it's on a
     
    12 Cold-Side. But what Duke was considering in the
     
    13 alternative though with North Carolina rule is --
     
    14 HEARING OFFICER TIPSORD: You're
     
    15 dropping off.
     
    16 MR. NELSON: Taking those Hot-Sides
     
    17 and simply reconfiguring the duct work so that
     
    18 you go through your air pre-heater first and then
     
    19 you go through -- your Hot-Side becomes a
     
    20 Cold-Side then and then you can do your typical
     
    21 Cold-Side injection. And that's a lot less
     
    22 expensive than building a fabric filter, but on
     
    23 the other hand, you don't get the benefit of the
     
    24 fabric filter. Then you still have your existing
     
    KEEFE REPORTING COMPANY 114

     
     
     
     
     
    1 electrostatic precipitator. So it's not just
     
    2 either or. There's multiple technologies and
     
    3 alternatives that are out there, and you have
     
    4 engineering companies come in and figure out what
     
    5 the alternatives are and the cost and you can
     
    6 make a decision based on that.
     
    7 HEARING OFFICER TIPSORD: Mr. Ayres?
     
    8 MR. AYRES: This is for Dr. Staudt.
     
    9 HEARING OFFICER TIPSORD: Give --
     
    10 Again, they're very directional. You have to
     
    11 speak right into it.
     
    12 MR. AYRES: I think this is the
     
    13 appropriate time to ask it. Dr. Staudt, is your
     
    14 experience that once a regulation is adopted,
     
    15 that the actual cost of compliance are typically
     
    16 less than or estimated prior to the time the
     
    17 regulation was adopted?
     
    18 DR. STAUDT: Well, yeah. Generally
     
    19 what happens is once the regulation is adopted,
     
    20 people -- people become conscientious about
     
    21 installing technology and doing it, you know,
     
    22 complying with the rule in the lowest cost
     
    23 approach that's possible. I don't pretend to be
     
    24 able to say that this -- what I've come up with
     
    KEEFE REPORTING COMPANY 115

     
     
     
     
     
    1 is necessarily the lowest cost approach. The
     
    2 companies in this room have some smart engineers.
     
    3 I know a number of them. And I'm sure they're
     
    4 clever enough to find some pretty good ways to
     
    5 deal with this rule should it pass.
     
    6 HEARING OFFICER TIPSORD: Mr.
     
    7 Bonebrake?
     
    8 MR. BONEBRAKE: Mr. Nelson, you're not
     
    9 an engineer; is that correct?
     
    10 MR. NELSON: Yes, I'm an engineer.
     
    11 MR. BONEBRAKE: What are all the
     
    12 engineering factors that must be considered in
     
    13 determining the feasibility of converting
     
    14 Hot-Side to Cold-Side with respect to an ESP?
     
    15 MR. NELSON: It's going to be a very
     
    16 site specific calculation because you would be
     
    17 constructing different duct work. The plant
     
    18 would obviously be down for a period. You could
     
    19 pre-build some of it, but it would it be down
     
    20 for, you know, while you were making the
     
    21 connections. The risk there is you want to make
     
    22 sure that the existing ESP works as a Cold-Side.
     
    23 What happened there were some questions on SCA.
     
    24 SCA is specific collection area is calculated
     
    KEEFE REPORTING COMPANY 116

     
     
     
     
     
    1 based upon the actual cubic feet of gas, and at
     
    2 the 700 temperature or 600 temperature the gas
     
    3 molecules are 50 percent further apart --
     
    4 HEARING OFFICER TIPSORD: We're losing
     
    5 you.
     
    6 MR. NELSON: -- so in converting it to
     
    7 a Cold-Side, your SCA goes up by 50 percent which
     
    8 generally makes -- improves the collection. But
     
    9 it's going to depend on the age of ESP, for
     
    10 example. It's going to depend on the geometry of
     
    11 the arrangement, and it's going to be a very site
     
    12 specific calculation.
     
    13 MR. BONEBRAKE: And I assume you've
     
    14 not done those kinds of calculations or analyses
     
    15 with respect to either of the two Midwest
     
    16 Generation Hot-Side units?
     
    17 MR. NELSON: No. Of course not.
     
    18 HEARING OFFICER TIPSORD: Ready to
     
    19 move on? Question No. 29.
     
    20 DR. STAUDT: Number 29, "Has any pilot
     
    21 test been done employing the halogenated
     
    22 activated carbon injection prior to a baghouse
     
    23 called the TOXECON arrangement on western coals
     
    24 that consistently achieve over 90 percent
     
    KEEFE REPORTING COMPANY 117

     
     
     
     
     
    1 removal?" Well, I think the word consistently is
     
    2 in there and -- but I'll give you my answer.
     
    3 The pilot test is a full scale test on
     
    4 western coal, and fabric filter and halogenated
     
    5 sorbent have shown over 90 percent removal
     
    6 consistently every test. So we have pretty
     
    7 strong reason to believe that on almost any
     
    8 situation, that I can imagine, you would get over
     
    9 90 percent removal with the carbon on a fabric
     
    10 filter.
     
    11 According to the data released by ADA
     
    12 Environmental Solutions and WE Energys, the
     
    13 testing at Presque Isle, which is a TOXECON
     
    14 arrangement with Powder River Basin coal shows 90
     
    15 percent removal at 2 pound per million ACF using
     
    16 untreated carbon. Halogenated carbon would
     
    17 provide even better performance.
     
    18 HEARING OFFICER TIPSORD: Question No.
     
    19 30. Dr. Staudt, on some of these -- like you've
     
    20 already answered -- but if you think you've
     
    21 already answered, please don't hesitate to let us
     
    22 know.
     
    23 DR. STAUDT: Okay. 30, "Based upon
     
    24 the statements in the report, are you stating
     
    KEEFE REPORTING COMPANY 118

     
     
     
     
     
    1 that 90 percent removal would not be achievable
     
    2 downstream of a Spray Dryer Absorber?" No. It
     
    3 would be achievable using halogenated carbon. It
     
    4 would be also achievable with untreated carbon on
     
    5 a unit with western coal where some halogens were
     
    6 added to the fuel or flue gas. However, it would
     
    7 not be achievable with untreated carbon on
     
    8 western coal without the additives.
     
    9 HEARING OFFICER TIPSORD: Question 31.
     
    10 DR. STAUDT: Okay. 31, "At page 129,
     
    11 you reference the southern company Gaston
     
    12 Station. Was not that facility burning
     
    13 bituminous coal?" Yes, Gaston was burning
     
    14 bituminous coal which is actually more difficult
     
    15 than western coal.
     
    16 HEARING OFFICER TIPSORD: Question 32.
     
    17 DR. STAUDT: "Is not the Presque Isle
     
    18 facility a federally funded test program to
     
    19 determine the effectiveness of the TOXECON
     
    20 system?" Yes, it is 50 percent federally funded
     
    21 and is a test to the TOXECON system. I am not
     
    22 sure of the specific project objectives that are
     
    23 -- that might be stated in the project. I think
     
    24 someone would have to go to DOE's documents to
     
    KEEFE REPORTING COMPANY 119

     
     
     
     
     
    1 find that.
     
    2 HEARING OFFICER TIPSORD: 33.
     
    3 DR. STAUDT: "Why is the government
     
    4 funding this test if the technology and its
     
    5 performance are already demonstrated?" That's a
     
    6 better question for the Department of Energy to
     
    7 answer. The Presque Isle project was committed
     
    8 to a few years ago before much of the halogenated
     
    9 sorbent test result and information was
     
    10 available. Am I speaking loudly enough?
     
    11 HEARING OFFICER TIPSORD: Yes. But
     
    12 slower, please.
     
    13 DR. STAUDT: I'll start again. The
     
    14 Presque Isle project was committed to a few years
     
    15 ago before much of the halogenated sorbent test
     
    16 results and information was available. In the
     
    17 meantime, Sorbent Technology has come a long way
     
    18 so it'd be fair to DOE, it was a good idea at the
     
    19 time because we didn't know then what we know now
     
    20 that there are options other than TOXECON for
     
    21 western coal.
     
    22 Moreover, it's worth noting that the
     
    23 Presque Isle plant is the big beneficiary of this
     
    24 program because they got a costly environmental
     
    KEEFE REPORTING COMPANY 120

     
     
     
     
     
    1 retrofit at half price. This retrofit probably
     
    2 would have been necessary at some point due to
     
    3 the plants Hot-Side ESPs and now the long-term
     
    4 viability of the Presque Isle plant is much
     
    5 better thanks to this program regardless of
     
    6 whether they choose to inject carbon in the
     
    7 future for mercury control.
     
    8 HEARING OFFICER TIPSORD: Question 34.
     
    9 I believe you've answered that one about the fire
     
    10 in the baghouse?
     
    11 DR. STAUDT: Yes.
     
    12 HEARING OFFICER TIPSORD: Question 35.
     
    13 DR. STAUDT: 35, I think we went
     
    14 through that that's --
     
    15 HEARING OFFICER TIPSORD: Right. 36.
     
    16 DR. STAUDT: I think we -- I think we
     
    17 went through this in detail.
     
    18 HEARING OFFICER TIPSORD: 37. And
     
    19 obviously, Mr. Harrington, if you think we
     
    20 haven't sufficiently, then --
     
    21 DR. STAUDT: Yeah. I think we talked
     
    22 about 37 as well.
     
    23 HEARING OFFICER TIPSORD: 37.
     
    24 DR. STAUDT: Aside from 37, I think
     
    KEEFE REPORTING COMPANY 121

     
     
     
     
     
    1 I've already done it.
     
    2 HEARING OFFICER TIPSORD: Okay. 38.
     
    3 DR. STAUDT: "Aside from Presque Isle
     
    4 -- aside from Presque Isle, which is not
     
    5 presently operating, that's a question, is there
     
    6 any other TOXECON array, halogenated activated
     
    7 carbon injection prior to a baghouse, in
     
    8 operation on which reliable data can be obtained
     
    9 whether on western low sulfur coals or bituminous
     
    10 coals?" And the -- 38; right?
     
    11 HEARING OFFICER TIPSORD: Yes.
     
    12 DR. STAUDT: Make sure I don't -- It's
     
    13 my understanding that the TOXECON system is back
     
    14 in operation, and that was based upon a phone
     
    15 call with the project manager last week. As
     
    16 noted earlier, there are numerous tests. There's
     
    17 the gas-to-field test to the TOXECON system and
     
    18 that was -- that lasted for many months, and
     
    19 several tests on other plants with fabric filters
     
    20 that have shown that TOXECON will provide over 90
     
    21 percent removal on the type of boiler that you've
     
    22 described in the question. And there are, as I
     
    23 mentioned, there's been a lot of data on fabric
     
    24 filters.
     
    KEEFE REPORTING COMPANY 122

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: Ms. Bassi
     
    2 has a follow-up.
     
    3 MS. BASSI: We're on number 38; is
     
    4 that correct?
     
    5 DR. STAUDT: That's correct.
     
    6 MS. BASSI: Quite the follow-up, isn't
     
    7 it? Okay. I believe you said Gaston was a
     
    8 bituminous site. Were there some low sulfur
     
    9 sites as well?
     
    10 DR. STAUDT: Low -- Well, actually
     
    11 bituminous is harder than a low sulfur site, but
     
    12 there were some low sulfur sites. They weren't
     
    13 TOXECON. They were fabric filters which are
     
    14 essentially from the perspective of controlling
     
    15 mercury. The whole purpose of a TOXECON is to
     
    16 put a fabric filter there because you get much
     
    17 better contact. There's been tests at Holcomb.
     
    18 There's being pilot testing at the Pleasant
     
    19 Prairie Station, which is -- is a PRB plant, and
     
    20 Stanton, which in the case of Stanton, it's a
     
    21 lignite coal.
     
    22 HEARING OFFICER TIPSORD: Mr.
     
    23 Harrington?
     
    24 MR. HARRINGTON: Perhaps I misread it.
     
    KEEFE REPORTING COMPANY 123

     
     
     
     
     
    1 The facilities you just named, were those TOXECON
     
    2 systems for baghouses?
     
    3 DR. STAUDT: Well, no. They -- Well,
     
    4 Gaston definitely was. The others -- the others
     
    5 were fabric filters, existing fabric.
     
    6 MR. HARRINGTON: With any kind of
     
    7 injection of halogenated activated carbon?
     
    8 DR. STAUDT: Yes, I believe so.
     
    9 MR. NELSON: Again, just to clarify,
     
    10 there have been tests -- Stanton has two boilers.
     
    11 Stanton 1 and Stanton 10. Stanton 10 has fabric
     
    12 filter, and there were halogenated sorbents
     
    13 tested in that. Stanton 1, which I described
     
    14 earlier, has a Cold-Side ESP, and halogenated
     
    15 sorbents were tested there. But there are two
     
    16 different boilers at Stanton.
     
    17 MR. HARRINGTON: Is that Stanton done
     
    18 through a dry scrubber prior to the baghouse?
     
    19 MR. NELSON: Yes. It's a spray dry
     
    20 fabric filter, correct.
     
    21 HEARING OFFICER TIPSORD: Anything
     
    22 further? 39.
     
    23 DR. STAUDT: 39, "With respect to
     
    24 design issues and with reference to the Gaston
     
    KEEFE REPORTING COMPANY 124

     
     
     
     
     
    1 Station facility, did not these tests demonstrate
     
    2 the importance of understanding the total
     
    3 particulate load to the baghouse an appropriate
     
    4 design?" Yes. That's why they established a
     
    5 guideline for air-to-cloth ratio 6.0 or less, and
     
    6 that was basically a conclusion of the study.
     
    7 Baghouses are very well understood
     
    8 technology. They've been around for decades.
     
    9 The air pollution control industry has lots and
     
    10 lots of experience building baghouses. The
     
    11 fabric filter at Gaston was installed -- I think
     
    12 we talked about, was installed several years ago
     
    13 never with the intention of just capturing the
     
    14 small amount of particle matter that escapes the
     
    15 Hot-Side ESP, never with the intention of having
     
    16 -- adding additional material. So had -- had
     
    17 they started out with the intention of installing
     
    18 a TOXECON system, they would have done some
     
    19 things differently. They would have made it a
     
    20 bigger baghouse with a lower air-to-cloth ratio.
     
    21 HEARING OFFICER TIPSORD: Question 40.
     
    22 Sorry. Mr. Harrington?
     
    23 MR. HARRINGTON: There are multiple
     
    24 sources of particulate that might be for a
     
    KEEFE REPORTING COMPANY 125

     
     
     
     
     
    1 baghouse on an electrical generating unit, are
     
    2 there not?
     
    3 DR. STAUDT: Multiple sources of
     
    4 particulate?
     
    5 MR. HARRINGTON: Well, start with the
     
    6 particulate that may come off the system
     
    7 originally?
     
    8 DR. STAUDT: That's correct.
     
    9 MR. HARRINGTON: Which may pass
     
    10 through the existing ESP and that particulate has
     
    11 certainly -- usually has certain characteristics
     
    12 which are taken --
     
    13 HEARING OFFICER TIPSORD: You need to
     
    14 speak up or speak closer to the mike.
     
    15 MR. HARRINGTON: The particulate which
     
    16 passes through the ESP and might be captured in
     
    17 the baghouse, whether it's there for that purpose
     
    18 or not, has certain physical characteristics that
     
    19 need to be taken into account or design, do they
     
    20 not?
     
    21 DR. STAUDT: That's correct.
     
    22 MR. HARRINGTON: If you're going to
     
    23 then add the halogenated activated carbon or
     
    24 point activated carbon, that also has certain
     
    KEEFE REPORTING COMPANY 126

     
     
     
     
     
    1 characteristics that need to be taken into
     
    2 account in design?
     
    3 DR. STAUDT: Well, that's correct,
     
    4 yes.
     
    5 MR. HARRINGTON: And if you're going
     
    6 to add a spray dryer in there, there's additional
     
    7 particulate that the baghouse has to deal with
     
    8 and that needs to be taken into account, doesn't
     
    9 it?
     
    10 DR. STAUDT: That's correct. And air
     
    11 pollution control companies know how to do this.
     
    12 MR. HARRINGTON: I'm not arguing if
     
    13 they do.
     
    14 DR. STAUDT: Yeah.
     
    15 MR. HARRINGTON: They -- And they take
     
    16 into account the veracity of the bag among other
     
    17 things?
     
    18 DR. STAUDT: That's correct.
     
    19 MR. HARRINGTON: And estimating how
     
    20 often the cleaning cycle must occur?
     
    21 DR. STAUDT: That's correct.
     
    22 MR. HARRINGTON: In handling the
     
    23 particulate?
     
    24 DR. STAUDT: That's correct.
     
    KEEFE REPORTING COMPANY 127

     
     
     
     
     
    1 MR. HARRINGTON: Also, in fan size and
     
    2 fan design?
     
    3 DR. STAUDT: All of these things are
     
    4 correct.
     
    5 MR. HARRINGTON: So if someone
     
    6 concluded that a baghouse was necessary to -- a
     
    7 TOXECON system is necessary, they also in
     
    8 designing that have to take into account all
     
    9 these other factors which may be site specific;
     
    10 is that correct?
     
    11 DR. STAUDT: Yes.
     
    12 MR. HARRINGTON: So even though
     
    13 baghouses are well understood in numerous
     
    14 applications, probably more outside the power
     
    15 industry, it is still going to require an
     
    16 engineering effort to get both the proper design
     
    17 of the baghouse as well as all the systems to get
     
    18 the air there and back to the stack?
     
    19 DR. STAUDT: Well, that's correct.
     
    20 MR. HARRINGTON: Do your cost
     
    21 estimates take all that into account?
     
    22 DR. STAUDT: Yes. My cost estimates,
     
    23 you know, we're going to get back to -- we keep
     
    24 coming back to the same thing. My cost estimates
     
    KEEFE REPORTING COMPANY 128

     
     
     
     
     
    1 are not intended to be detailed. I don't -- I
     
    2 don't have estimates of the engineering man hours
     
    3 in there. The total cost might be higher. It
     
    4 might be lower. These are not intended to be
     
    5 detailed costs. And the air pollution control
     
    6 industry and these engineers at these power
     
    7 plants are smart guys. They know how to do this
     
    8 stuff, and they know how to do it right.
     
    9 MR. HARRINGTON: That's why Presque
     
    10 Isle happened; right?
     
    11 DR. STAUDT: Well, sometimes the
     
    12 operators make mistakes.
     
    13 MR. HARRINGTON: But if -- This is a
     
    14 hypothetical. If a significant portion of EGUs
     
    15 in Illinois had to install a TOXECON system --
     
    16 HEARING OFFICER TIPSORD: Mr.
     
    17 Harrington, we're losing you.
     
    18 MR. HARRINGTON: If a significant
     
    19 number of the EGUs in Illinois had to install a
     
    20 TOXECON system, do you have an opinion as to the
     
    21 availability of the engineering talent to do the
     
    22 design on all these systems within the schedule
     
    23 established by the Illinois rule?
     
    24 DR. STAUDT: Well, you say a
     
    KEEFE REPORTING COMPANY 129

     
     
     
     
     
    1 significant number?
     
    2 MR. HARRINGTON: Yes.
     
    3 DR. STAUDT: Well I -- Do you have --
     
    4 MR. HARRINGTON: It's a hypothetical.
     
    5 DR. STAUDT: Hypothetical, what's a
     
    6 significant number? I think two is a significant
     
    7 number and obviously I believe that's --
     
    8 MR. HARRINGTON: Well, if I said half
     
    9 or 80 percent?
     
    10 DR. STAUDT: Well, first of all, I
     
    11 think if you said 80 percent, or even -- I know
     
    12 one of the questions here we're going to get to
     
    13 is all of the units. That's a -- First of all,
     
    14 it's completely so remote that it's, you know,
     
    15 when I thought about -- when I read that question
     
    16 about what if all the units had to install
     
    17 mercury control -- install TOXECON systems, I was
     
    18 thinking, you know, it's like I'm more concerned
     
    19 about being hit by a giant astroid, I mean, you
     
    20 know, that's so remote. It's a ridiculous
     
    21 question.
     
    22 But having said that, this is an
     
    23 industry that installed just in 2003 over 40,000
     
    24 megawatts of SCR. At the same time it was
     
    KEEFE REPORTING COMPANY 130

     
     
     
     
     
    1 brought on line for that -- for coal about an
     
    2 equal number of gas-fired SCRs. And this is an
     
    3 industry that has been able to respond to these
     
    4 challenges. It's an industry with companies like
     
    5 GE, Siemens, Alstom, some of the biggest
     
    6 companies in the world. And if -- if all of a
     
    7 sudden there's a demand, there will be a supply.
     
    8 MR. HARRINGTON: Nothing further.
     
    9 HEARING OFFICER TIPSORD: Question 40.
     
    10 DR. STAUDT: Section 8.4.5.4 of the
     
    11 technical support document states at pages 142
     
    12 and 143 -- excuse me. "Section 8.4.5.4 of the
     
    13 technical support document at pages 142 and 143
     
    14 makes reference to the build up -- excuse me --
     
    15 of carbon on duct surfaces. Could not that build
     
    16 up interfere with the operation of the facility?"
     
    17 Utility boilers already accumulate fly
     
    18 ash which includes carbon on internal duct
     
    19 surfaces and you can -- there normally is a lot
     
    20 more fly ash collecting on the duct surfaces than
     
    21 there is in -- then there would be -- ever would
     
    22 be activated carbon. So you go to, it's the
     
    23 second to last page of this Exhibit 52 --
     
    24 HEARING OFFICER TIPSORD: Uh-huh.
     
    KEEFE REPORTING COMPANY 131

     
     
     
     
     
    1 DR. STAUDT: -- you look at Figure
     
    2 8.16, that's estimated carbon content and fly ash
     
    3 for different coals and injection rates. What
     
    4 this shows is for different injection rates, and
     
    5 look -- the figure we're looking at typically for
     
    6 a Powder River Basin coal injection rate of about
     
    7 3 pound per million ACF. And this data was
     
    8 actually taken from Sorbent Technologies -- this
     
    9 is from the EPA. Oh, that's right. This is from
     
    10 the EPA, USEPA report. Okay. But it shows, you
     
    11 know, basically a 3 pound per million ACF one
     
    12 and-a-half percent to the particulate loading in
     
    13 the duct work is going to be from activated
     
    14 carbon.
     
    15 That means that 98.5 percent of the
     
    16 particles in there of the dust flying around in
     
    17 there is fly ash, so, yeah, there's a little bit
     
    18 going in there but there's a lot more other stuff
     
    19 flying around so it doesn't, you know, I don't
     
    20 see it making a difference.
     
    21 HEARING OFFICER TIPSORD: Question 41.
     
    22 DR. STAUDT: 41, Could not the build
     
    23 up of carbon also occur in the ESP?" Well, could
     
    24 the build up of carbon -- while it's collected in
     
    KEEFE REPORTING COMPANY 132

     
     
     
     
     
    1 the ash -- in the hopper, once it's collected, it
     
    2 goes down to the hoppers and then it's evacuated.
     
    3 And I'm not sure that's -- in a properly operated
     
    4 designed ESP, the carbon basically would be
     
    5 removed, but it's also -- but number 1, there's
     
    6 an awful lot of carbon, in most cases there's
     
    7 more carbon in the fly ash already because
     
    8 without the -- without the additional activated
     
    9 carbon that's injected because some portion of
     
    10 the coal -- some portion of the coal doesn't
     
    11 burn. We don't get -- we would like to have 100
     
    12 percent perfect combustion of the coal but some
     
    13 portion of it doesn't and it's -- and it's not
     
    14 unusual to have a few percent of the fly ash be
     
    15 carbon. And sometimes, you know, I've seen, you
     
    16 know, 10, 20, even 30 percent of the fly ash is
     
    17 carbon. So more often than not there's more
     
    18 carbon in that fly ash before you even add the
     
    19 activated carbon.
     
    20 HEARING OFFICER TIPSORD: Question 42.
     
    21 MR. HARRINGTON: Could we read that
     
    22 last answer back?
     
    23 (The Reporter read from the record as
     
    24 follows: 41, Could not the build up
     
    KEEFE REPORTING COMPANY 133

     
     
     
     
     
    1 of carbon also occur in the ESP?"
     
    2 Well, could the build up of carbon --
     
    3 while it's collected in the ash -- in
     
    4 the hopper, once it's collected, it
     
    5 goes down to the hoppers and then
     
    6 it's evacuated. And I'm not sure
     
    7 that's -- in a properly operated
     
    8 designed ESP, the carbon basically
     
    9 would be removed, but it's also --
     
    10 but number 1, there's an awful lot of
     
    11 carbon, in most cases there's more
     
    12 carbon in the fly ash already because
     
    13 without the -- without the additional
     
    14 activated carbon that's injected
     
    15 because some portion of the coal --
     
    16 some portion of the coal doesn't
     
    17 burn. We don't get -- we would like
     
    18 to have 100 percent perfect
     
    19 combustion of the coal but some
     
    20 portion of it doesn't and it's -- and
     
    21 it's not unusual to have a few
     
    22 percent of the fly ash be carbon.
     
    23 And sometimes, you know, I've seen,
     
    24 you know, 10, 20, even 30 percent of
     
    KEEFE REPORTING COMPANY 134

     
     
     
     
     
    1 the fly ash is carbon. So more often
     
    2 than not there's more carbon in that
     
    3 fly ash before you even add the
     
    4 activated carbon.)
     
    5 HEARING OFFICER TIPSORD: Anything
     
    6 further? Question 42.
     
    7 DR. STAUDT: The question 42, "With a
     
    8 build up of carbon in the ducts and the ESP, is
     
    9 there not an elevated risk of fire in the duct
     
    10 work or ESP?" No. Keep in mind that the coal
     
    11 doesn't burn completely. I think we discussed
     
    12 this. There's already carbon in there. There's
     
    13 no increased likelihood of fire over what you
     
    14 already -- of what already -- what you already
     
    15 have.
     
    16 MR. NELSON: If I could elaborate on
     
    17 one thing. Activated carbon in the production of
     
    18 activated carbon, they start with coal. The
     
    19 first step is to carbonize it, which
     
    20 devolatilizes it, which makes it no longer
     
    21 explosive, whereas, coal dust, for example, there
     
    22 are concerns about that. It's not a concern of
     
    23 activated carbon because the volatiles are
     
    24 already gone. It will burn because it's carbon
     
    KEEFE REPORTING COMPANY 135

     
     
     
     
     
    1 if there's a flame and you get it burning, but
     
    2 it's much, much safer, for example, than you hear
     
    3 about coal explosions and things at the power
     
    4 plant. That's not an issue with activated
     
    5 carbon.
     
    6 HEARING OFFICER TIPSORD: Question 43.
     
    7 DR. STAUDT: "Did you prepare table
     
    8 8.1 of the technical support document dealing
     
    9 with sorbent injection field demonstrations?"
     
    10 Yes. Is it correct that of the 41 studies listed
     
    11 here, only nine were on PRB coal -- "Is this
     
    12 correct of the 41 studies listed here, only nine
     
    13 were on PRB coal?" I counted 13 on PRB, and some
     
    14 show up in the table that subbituminous --
     
    15 subbituminous -- PRB is a type of subbituminous
     
    16 coal and the subbituminous coal, things show --
     
    17 the tests shown here is subbituminous and we're
     
    18 PRB coals. Also, there are about 10 on lignite
     
    19 which has many of the same issues regarding
     
    20 sorbent injection as PRB except lignite is
     
    21 actually slightly more difficult.
     
    22 The purpose of this table was really
     
    23 to show how much testing there has been on such a
     
    24 wide variety of coals and boiler configurations.
     
    KEEFE REPORTING COMPANY 136

     
     
     
     
     
    1 This table shows a lot of activity and, frankly,
     
    2 it's only a part of the total activity associated
     
    3 with mercury control technology. It's all the
     
    4 work that's been going on with scrubbers and
     
    5 other things, so the industry has been pretty
     
    6 active.
     
    7 44(a) -- or 44, "As to each of such
     
    8 demonstrations, state your knowledge at the time
     
    9 your testimony was prepared as to each of the
     
    10 following elements: A, Is the size of ESP and
     
    11 the length of time of the study; the maximum,
     
    12 minimum and mean removal rate achieved on each;
     
    13 the method used for measuring mercury in the
     
    14 emissions; the method used for measuring mercury
     
    15 in the coal charge to the furnaces; the length of
     
    16 each study; statistical method used to
     
    17 predict/analyze the data resulting from the study
     
    18 and predict future removal rates; whether the
     
    19 conditions upon which the study was run are
     
    20 comparable to those conditions that would be
     
    21 expected in a year-round operation under normal
     
    22 operating conditions; as to the Presque Isle
     
    23 study with a TOXECON system, please describe the
     
    24 current status of that study and whether there
     
    KEEFE REPORTING COMPANY 137

     
     
     
     
     
    1 have been any significant problems with the
     
    2 study."
     
    3 Well, I think we can -- we've already
     
    4 talked about "H", okay. The size of the ESP and
     
    5 length of time of the study. Now a couple of
     
    6 things, first, I'm not sure if it makes sense to
     
    7 go through every one of these studies because I
     
    8 didn't use those studies. As I indicated
     
    9 earlier, most -- that table was not -- was put
     
    10 together to show the amount of activity but --
     
    11 but I'll be happy to talk about the -- the -- the
     
    12 test, provide the data on the test that I used to
     
    13 form my opinions relative to Illinois coal.
     
    14 MR. HARRINGTON: That would be
     
    15 appropriate.
     
    16 DR. STAUDT: Okay. And -- Okay.
     
    17 Let's talk about -- First of all, you folks
     
    18 understand now what an ESP is, how it works?
     
    19 Okay. We got this -- There's SCA, size of ESP.
     
    20 ESPs are -- the size is represented in specific
     
    21 collection area.
     
    22 HEARING OFFICER TIPSORD: Microphone.
     
    23 DR. STAUDT: Sorry. The size is
     
    24 represented to the specific collection area. And
     
    KEEFE REPORTING COMPANY 138

     
     
     
     
     
    1 -- and I think that was discussed earlier by Sid
     
    2 by what that means. It's basically the -- how
     
    3 many square feet of collection surface are in the
     
    4 ESP relative to the amount of gas that was
     
    5 flowing through it. It's one of the many, many
     
    6 things that affect the performance of, you know,
     
    7 determine the performance of an ESP, but I think
     
    8 we've got more questions about SCA and I'll go
     
    9 into that later.
     
    10 I'll give you the numbers: Meramec
     
    11 was a 30-day test. The Meramec, that's
     
    12 M-E-R-A-M-E-C, 30-day test, PRB fired, 140
     
    13 megawatts and the SCA of the ESP is 320. St.
     
    14 Clair, that's DTE St. Clair, 30-day test, fires
     
    15 mostly PRB, about 85 percent is 160 megawatts
     
    16 with an SCA of ESP equal to 700. The Pleasant
     
    17 Prairie was actually a slipstream so the -- the
     
    18 measurements actually taken were prior to -- with
     
    19 halogenated sorbents were prior to -- to a --
     
    20 there was tests. They were full scale tests done
     
    21 with untreated sorbents but the test with
     
    22 halogenated sorbents were slipstream. So
     
    23 Pleasant Prairie fires PRB of 600 megawatts.
     
    24 MR. HARRINGTON: How were --
     
    KEEFE REPORTING COMPANY 139

     
     
     
     
     
    1 DR. STAUDT: The test results on
     
    2 Figure 8.10, those were slipstream tests that
     
    3 were shown.
     
    4 HEARING OFFICER TIPSORD: He was
     
    5 asking I think about the rates.
     
    6 MR. HARRINGTON: You said Pleasant
     
    7 Prairie, I missed how long the test was?
     
    8 DR. STAUDT: That was a short -- that
     
    9 was a slipstream, so it probably went a few days.
     
    10 That was a short-term test.
     
    11 HEARING OFFICER TIPSORD: Mr. Forcade?
     
    12 MR. FORCADE: Was Pleasant Prairie a
     
    13 pilot scale or full scale?
     
    14 DR. STAUDT: I mentioned it was a
     
    15 slipstream which would be a pilot scale. The
     
    16 test results -- there was a full scale test using
     
    17 untreated carbon, okay. There was a full scale
     
    18 test to Pleasant Prairie using untreated carbon.
     
    19 That was -- that showed -- that's when people
     
    20 discovered that on western coals, untreated
     
    21 carbon wasn't particularly effective at getting
     
    22 high levels of mercury removal.
     
    23 Just to go back and close the loop on
     
    24 Pleasant Prairie, people went back with -- with a
     
    KEEFE REPORTING COMPANY 140

     
     
     
     
     
    1 slip -- doing a slipstream test and that test
     
    2 produced -- produced 90 percent removal on a
     
    3 slipstream test using halogenated sorbents, so
     
    4 rather than go back and do a whole -- a whole
     
    5 full scale test, which is costly, they went back
     
    6 with the halogenated sorbents to see how it would
     
    7 go -- perform at the same site where they had so
     
    8 much trouble with the untreated sorbents.
     
    9 HEARING OFFICER TIPSORD: Mr. Forcade?
     
    10 MR. FORCADE: Were any other tests in
     
    11 Table 8.1 pilot studies?
     
    12 DR. STAUDT: I would have to look at
     
    13 table -- at the table. 8 -- well, actually 8.1
     
    14 -- these are -- 8.1, that table is all field --
     
    15 full scale tests, okay, but with Pleasant
     
    16 Prairie, I'm not using the untreated carbon
     
    17 results to form my opinion. I'm using -- which
     
    18 would -- were done at full scale. I gave you
     
    19 that information because that's one -- I'm giving
     
    20 you the information on the test that performed my
     
    21 post -- Pleasant Prairie is the only slipstream
     
    22 that I'm referring to and that -- the Pleasant
     
    23 Prairie slipstream it does not -- is not shown on
     
    24 Table 8.1, so that probably, you know, that
     
    KEEFE REPORTING COMPANY 141

     
     
     
     
     
    1 probably didn't -- that shouldn't have been
     
    2 included in the answer because you're only asking
     
    3 about things on Table 8.1.
     
    4 HEARING OFFICER TIPSORD: Mr.
     
    5 Harrington?
     
    6 MR. HARRINGTON: Just for
     
    7 clarification, I think we agreed you would talk
     
    8 about those that you relied on --
     
    9 DR. STAUDT: Yeah.
     
    10 MR. HARRINGTON: -- that are on 8.1
     
    11 are not -- but I'm just wondering that are not --
     
    12 or not didn't rely on makes more sense.
     
    13 DR. STAUDT: Yeah.
     
    14 HEARING OFFICER TIPSORD: Mr. Zabel?
     
    15 CHAIRMAN GIRARD: Dr. Staudt, I have a
     
    16 question in -- are you saying here in Table 8.1
     
    17 you based this information on those four
     
    18 references that you have cited at the top, or did
     
    19 it come from anywhere else?
     
    20 DR. STAUDT: There could -- Did I form
     
    21 my opinions based upon --
     
    22 CHAIRMAN GIRARD: You cited --
     
    23 DR. STAUDT: Yes, yes, those are
     
    24 references.
     
    KEEFE REPORTING COMPANY 142

     
     
     
     
     
    1 CHAIRMAN GIRARD: I can find three of
     
    2 those in the list of references in the back, but
     
    3 I don't find Kang (phonetic) at all, so we need a
     
    4 full reference on that.
     
    5 DR. STAUDT: Okay.
     
    6 CHAIRMAN GIRARD: But the other three
     
    7 all appear to be conference presentations, is
     
    8 there a report somewhere and how would we access
     
    9 it?
     
    10 DR. STAUDT: There are reports on all
     
    11 of the department -- I assume that most of these
     
    12 are Department of Energy tests, demonstrations
     
    13 and they would -- you'd have to go to DOE's
     
    14 Website to get the -- the information on all of
     
    15 these. Those reports are available at DOE's
     
    16 Website. I haven't read the final reports on
     
    17 each one of these tests, but I have shown on
     
    18 Table 8.1 but I've read the conference papers --
     
    19 the conference papers and in some cases the
     
    20 project -- the DOE project reports on some of the
     
    21 tests that I -- I reference here, that I used to
     
    22 form my opinions I should say.
     
    23 CHAIRMAN GIRARD: Well, Mr. Kim, is it
     
    24 possible to get a citation for that Website to
     
    KEEFE REPORTING COMPANY 143

     
     
     
     
     
    1 get us to these sources, please.
     
    2 MR. KIM: We'll try and get that for
     
    3 you, yes.
     
    4 CHAIRMAN GIRARD: Okay.
     
    5 HEARING OFFICER TIPSORD: Mr.
     
    6 Harrington?
     
    7 MR. HARRINGTON: Have you finished
     
    8 your list? I have three: Meramec, St. Clair,
     
    9 Pleasant Prairie.
     
    10 DR. STAUDT: Yeah, there's -- well,
     
    11 there's Stanton 1 and Stanton 10. Those are
     
    12 actually north coal lignite and which is 170
     
    13 megawatts, and that's and that's --
     
    14 MR. HARRINGTON: Which one is that?
     
    15 DR. STAUDT: Stanton 1. Oh, that's
     
    16 subbituminous, that's right. I have -- Somewhere
     
    17 in here I have the STA of Stanton 1. You may
     
    18 have it. Stanton 10 is 70 megawatts. It
     
    19 actually has a Spray Dryer Absorber, so what they
     
    20 did with that testing -- there's a piece of -- a
     
    21 duct work before the Spray Dryer Absorber and
     
    22 before the fabric filter and Spray Dry Absorber
     
    23 after the boiler. At Stanton 10 they injected
     
    24 the sorbent and they injected into the duct work
     
    KEEFE REPORTING COMPANY 144

     
     
     
     
     
    1 because with an ESP the capture is done what we
     
    2 call in flight. You inject the sorbent and it
     
    3 interacts with gas, captures the gaseous mercury,
     
    4 you know, at a later particulate removal device,
     
    5 that sorbent with the mercury on it is removed.
     
    6 So the actual removal of mercury from the gas
     
    7 stream occurs without an ESP, okay. You
     
    8 really -- the gas -- the ESP actually later just
     
    9 grabs the sorbent once the mercury has been
     
    10 removed from the gas stream.
     
    11 So Stanton 10 there isn't even an ESP
     
    12 in the testing because they measure upstream from
     
    13 the injection point, and they measured mercury
     
    14 downstream the injection point and they got high
     
    15 removal rates. So there isn't an ESP at Stanton.
     
    16 Laramie River, 550 megawatts, that's lignite that
     
    17 has an SCA of 599, 600.
     
    18 HEARING OFFICER TIPSORD: Mr.
     
    19 Harrington?
     
    20 MR. HARRINGTON: I realize it's
     
    21 getting late but I might have missed something.
     
    22 At Stanton 10 there was no ESP to particulate
     
    23 removal?
     
    24 DR. STAUDT: There -- No, the test --
     
    KEEFE REPORTING COMPANY 145

     
     
     
     
     
    1 the test was conducted full scale. It was --
     
    2 just measured -- you were measuring in the duct,
     
    3 in the same duct that the injection occurs at an
     
    4 upstream -- the measurement was occurred at an
     
    5 upstream point and the downstream point while the
     
    6 sorbent was being injected prior to reaching the
     
    7 Spray Dryer Absorber. Now -- So there wasn't an
     
    8 ESP, but what's important is mercury removal when
     
    9 you have an ESP. Their mercury is removed from
     
    10 the gas in flight, okay. There's -- The gas --
     
    11 the mercury is in the gas phase --
     
    12 HEARING OFFICER TIPSORD: I appreciate
     
    13 you wanting to talk to us but when you turn to
     
    14 us, you turn away from the microphone.
     
    15 DR. STAUDT: Oh, I'm sorry. The
     
    16 mercury exists in the gas phase and the sorbent
     
    17 is used to draw the mercury out of the gas phase.
     
    18 That's the purpose of the sorbent. And then the
     
    19 mercury is on the sorbent and then it's captured
     
    20 by an ESP. So the actual removal of mercury from
     
    21 the gas phase occurs what we call in flight. It
     
    22 doesn't -- With an ESP it doesn't occur in ESP.
     
    23 The ESP just grabs the sorbent and takes the
     
    24 sorbent out, okay. So that shows that the --
     
    KEEFE REPORTING COMPANY 146

     
     
     
     
     
    1 frankly, this whole notion of -- is SCA
     
    2 important? Not in terms of removing the mercury
     
    3 from the gas phase, okay. That's all this talk
     
    4 about SCA and size of the ESP doesn't matter.
     
    5 The mercury is removed from the gas phase prior
     
    6 to entering that ESP.
     
    7 MR. HARRINGTON: Mercury is removed
     
    8 from the -- Back up. We're dealing with three
     
    9 types of mercury: Flue gas, particulate,
     
    10 elemental --
     
    11 HEARING OFFICER TIPSORD: Mr.
     
    12 Harrington, you need to move closer to the
     
    13 microphone.
     
    14 MR. HARRINGTON: Am I correct that the
     
    15 three types of mercury in the gas stream:
     
    16 Elemental --
     
    17 DR. STAUDT: Oxidized.
     
    18 MR. HARRINGTON: Oxidized?
     
    19 DR. STAUDT: And particulate.
     
    20 MR. HARRINGTON: And particulate. So
     
    21 when the sorbent absorbs the mercury, it's still
     
    22 -- until that sorbent is taken out of the gas
     
    23 stream, the mercury is still there. It's just
     
    24 changed form, am I correct?
     
    KEEFE REPORTING COMPANY 147

     
     
     
     
     
    1 DR. STAUDT: It's converted to
     
    2 particulate mercury.
     
    3 MR. HARRINGTON: Converted to
     
    4 particulate mercury. So it's not removed. It's
     
    5 converted, changed in form. And then that form
     
    6 has to be removed in the gas stream in order to
     
    7 achieve mercury removal?
     
    8 DR. STAUDT: Well, that -- that's
     
    9 true.
     
    10 MR. HARRINGTON: So when you say they
     
    11 measured mercury upstream and downstream of the
     
    12 point of injection, what mercury were they
     
    13 measuring?
     
    14 DR. STAUDT: They were measuring
     
    15 gaseous mercury, total oxidized, and elemental.
     
    16 MR. HARRINGTON: But not particulate?
     
    17 DR. STAUDT: Not particulate. Which
     
    18 we know that whether you use an ESP or a fabric
     
    19 filter you want to catch the particulate. That
     
    20 is not -- Removing particulate mercury is easy.
     
    21 It's already -- it's already occurring without
     
    22 any -- that's the co-benefit removal that we talk
     
    23 about with existing ESPs in fabric filters.
     
    24 HEARING OFFICER TIPSORD: Ms. Bassi,
     
    KEEFE REPORTING COMPANY 148

     
     
     
     
     
    1 follow-up?
     
    2 MS. BASSI: With respect to Stanton 10
     
    3 on Table 8.1, which is what we're talking about;
     
    4 correct?
     
    5 DR. STAUDT: That is correct.
     
    6 MS. BASSI: Stanton 10 is listed
     
    7 twice, one time -- and the second time it
     
    8 indicates the Cold-Side ESP. And I thought you
     
    9 said there was not an ESP at Stanton 10, did I
     
    10 mishear you?
     
    11 DR. STAUDT: Oh, yeah, that -- that
     
    12 was basically the -- what I call the simulated --
     
    13 it's an in flight removal when I say -- they
     
    14 don't have a Cold-Side ESP but that's the data I
     
    15 was referring to -- that citation is what the
     
    16 second to last one in Table 8.1, that is -- that
     
    17 is a -- what I would call maybe a simulated
     
    18 Cold-Side ESP because it was -- was -- what is
     
    19 really in flight removal.
     
    20 HEARING OFFICER TIPSORD: Ms. Bassi?
     
    21 MS. BASSI: I would like to go back to
     
    22 Mr. Harrington's question and your answer -- more
     
    23 specifically your answer to it. I think what I
     
    24 heard you say is, is that you don't catch the
     
    KEEFE REPORTING COMPANY 149

     
     
     
     
     
    1 elemental mercury and you don't catch the gaseous
     
    2 -- or the RGMs, all you catch is the particulate
     
    3 mercury but those other two species of mercury
     
    4 are changed to particulate mercury; is that
     
    5 correct?
     
    6 DR. STAUDT: No, I think you're -- I'm
     
    7 not sure what you're saying. Let me explain to
     
    8 you what happens.
     
    9 MS. BASSI: I wasn't either.
     
    10 DR. STAUDT: All right. The mercury
     
    11 exists in the gas stream normally in three forms:
     
    12 An elemental form, an oxidized form, and a
     
    13 particulate form. Normally the only kind that
     
    14 are -- that can be removed is particulate mercury
     
    15 is that basically particulate means it's already
     
    16 attached to the fly ash, okay. It's already
     
    17 solids in there -- there's already solids in
     
    18 there and it's already attached to the fly ash.
     
    19 And we have particulate removal devices on all
     
    20 the boilers that take that fly ash, capture that
     
    21 fly ash so that particulate removal -- that
     
    22 particular mercury rather is already removed.
     
    23 That's what we call a co-benefit removal. The
     
    24 trick is removing the oxidized and elemental.
     
    KEEFE REPORTING COMPANY 150

     
     
     
     
     
    1 If you have an Wet FGD system, the
     
    2 oxidized mercury, most of it gets captured pretty
     
    3 well. Elemental mercury you have to convert it
     
    4 to another form to capture it.
     
    5 Now what sorbent does is sorbent
     
    6 enables you to turn that oxidized and that
     
    7 elemental mercury into particulate mercury. So
     
    8 essentially what you're doing, that oxidized
     
    9 mercury and that elemental mercury that exists in
     
    10 the gas phase, they get attached to the carbon,
     
    11 okay, that you inject, the activated carbon. And
     
    12 then that activated carbon is just with -- with
     
    13 the 98 -- 98.5, you know, percent of the other
     
    14 material, that's solid material, gets captured
     
    15 along with all that fly ash in an ESP or fabric
     
    16 filter. So, you know, the carbon -- the carbon
     
    17 grabs at the remaining -- those gaseous forms of
     
    18 the mercury, turns them into particulate and then
     
    19 the ESP catches them.
     
    20 MS. BASSI: As the carbon is grabbing
     
    21 the elemental gaseous -- and RGM, is there a
     
    22 chemical reaction that occurs to turn them into
     
    23 the particulate form of mercury?
     
    24 (Cell phone rings.)
     
    KEEFE REPORTING COMPANY 151

     
     
     
     
     
    1 MS. BASSI: Do you want me to repeat
     
    2 the question?
     
    3 DR. STAUDT: Repeat the question,
     
    4 please.
     
    5 MS. BASSI: Okay. What I want to know
     
    6 is, is there a chemical reaction or some -- I
     
    7 think chemical reaction is probably the right
     
    8 term, that occurs that turns the elemental and
     
    9 the oxidized mercury into particulate mercury
     
    10 when it -- when the carbon is -- when it's
     
    11 exposed to the carbon?
     
    12 DR. STAUDT: It's called
     
    13 Chemisorbtion, C-H-E-M-I-S-O-R-B-T-I-O-N.
     
    14 MS. BASSI: Okay. So there's not --
     
    15 there's not really then -- they aren't altered in
     
    16 their species from elemental to particulate, it's
     
    17 just that the carbon causes it to stick?
     
    18 DR. STAUDT: It gets bound in a --
     
    19 with a chemical -- there is a chemical reaction
     
    20 but chemically bound to the carbon.
     
    21 MS. BASSI: Is it elemental mercury
     
    22 still?
     
    23 DR. STAUDT: No, it's not elemental.
     
    24 It's particulate mercury.
     
    KEEFE REPORTING COMPANY 152

     
     
     
     
     
    1 MS. BASSI: So there is a reaction and
     
    2 it does change it's species?
     
    3 DR. STAUDT: Yes.
     
    4 MS. BASSI: Is that correct?
     
    5 DR. STAUDT: Yes.
     
    6 MS. BASSI: Thank you.
     
    7 HEARING OFFICER TIPSORD: Mr. Forcade?
     
    8 MR. FORCADE: Dr. Staudt, I believe
     
    9 you mentioned that most of the tests that were
     
    10 run were run either supervised by or sponsored by
     
    11 the Department of Energy?
     
    12 DR. STAUDT: Yes.
     
    13 MR. FORCADE: How would you summarize
     
    14 the Department of Energy's view on halogenated
     
    15 activated carbon injection? Would they describe
     
    16 it as a promising but not demonstrated technology
     
    17 or have they described it as a -- would they
     
    18 describe it as a promising but not demonstrated
     
    19 technology or would they describe it as a
     
    20 demonstrated technology that should be employed
     
    21 quickly?
     
    22 DR. STAUDT: I really don't know
     
    23 exactly what they -- what their position is so --
     
    24 HEARING OFFICER TIPSORD: Anything
     
    KEEFE REPORTING COMPANY 153

     
     
     
     
     
    1 further? All right. Then I think we're ready
     
    2 too move on, but quite frankly, did we get all of
     
    3 45 or did we get caught in the middle of 44?
     
    4 MR. HARRINGTON: I think we were
     
    5 caught in the middle of 44, unfortunately.
     
    6 HEARING OFFICER TIPSORD: Hold on.
     
    7 Ms. Tickner?
     
    8 MS. TICKNER: I guess maybe I just had
     
    9 one follow-up or I missed it. On 8.1 I think Dr.
     
    10 Staudt only describes the test he relied on for
     
    11 the PRB coal, was he going to talk about the
     
    12 testing he relied for high sulfur coal?
     
    13 DR. STAUDT: Well, for high sulfur
     
    14 coal -- let me talk about bituminous coals in
     
    15 general as opposed to high sulfur because as I
     
    16 mentioned in my testimony there isn't good data
     
    17 on high sulfur bituminous coal, and I'm not --
     
    18 there isn't good information on high sulfur
     
    19 bituminous coal so -- but for the low to medium
     
    20 --
     
    21 HEARING OFFICER TIPSORD: Dr. Staudt,
     
    22 you're turning away from the microphone.
     
    23 DR. STAUDT: I don't -- None of these
     
    24 tests were high sulfur bituminous coals, okay, at
     
    KEEFE REPORTING COMPANY 154

     
     
     
     
     
    1 least high sulfur in the respect that we have
     
    2 high sulfur here in Illinois. And as I
     
    3 mentioned, they're really only -- they're four
     
    4 small Meredosia units and there is the -- and
     
    5 possibly Hutsonville that are high sulfur. There
     
    6 are a couple of low to medium sulfur units and
     
    7 units that I would say are comparable to those
     
    8 units would be the Allen, Monroe, and Lausche all
     
    9 are bituminous. Allen is 165 megawatts with an
     
    10 SCA of ESP is 460. Monroe is 785 megawatts. It
     
    11 burns 60/40 bituminous PRB blend but has similar
     
    12 SO2 emissions as -- as some of the -- as some of
     
    13 the medium -- low to medium sulfur bituminous
     
    14 units here in Illinois, and its ESP has an SCA of
     
    15 258. Lausche is a bituminous unit, actually a
     
    16 fairly small, 18 megawatts with an SCA of 370.
     
    17 Lausche is probably the -- of those three the
     
    18 highest sulfur and certainly had probably higher
     
    19 SO3 levels than the others.
     
    20 MS. TICKNER: And what level of SO2
     
    21 would that be?
     
    22 DR. STAUDT: At Lausche about 1,000
     
    23 PPM as I recall, 1,500 PPM. So as I indicated,
     
    24 for the very high sulfur unit I, you know, there
     
    KEEFE REPORTING COMPANY 155

     
     
     
     
     
    1 isn't a good test data on sorbent injection.
     
    2 MS. TICKNER: Are you aware that there
     
    3 are couple of permanent (phonetic) units that
     
    4 aren't constructed yet that have way higher
     
    5 levels of SO2 than we're talking about here?
     
    6 DR. STAUDT: Well, I'm aware there are
     
    7 -- there are new -- new construction units
     
    8 proposed, is that what you're --
     
    9 MS. TICKNER: Yes.
     
    10 DR. STAUDT: I don't know the details
     
    11 of those new construction units but I have been
     
    12 told based upon the equipment that I'm told that
     
    13 they are going to have -- they, you know, it's
     
    14 hard to imagine -- my understanding is that the
     
    15 -- if we're talking about the -- it will have wet
     
    16 -- it will have these -- will have SCR and Wet
     
    17 FGD and I would expect that they would get --
     
    18 with a modern, you know, modern SCR and Wet FGD
     
    19 and possibly even more controlled beyond that if
     
    20 -- I know some may have Wet ESP, they're going to
     
    21 get -- going to comply with the rule. It's hard
     
    22 for me to imagine a scenario were they don't.
     
    23 MS. TICKNER: Would you be surprised
     
    24 that vendors weren't willing to guarantee 90
     
    KEEFE REPORTING COMPANY 156

     
     
     
     
     
    1 percent removal for mercury on that unit with all
     
    2 that equipment?
     
    3 DR. STAUDT: You know, I don't get
     
    4 involved in -- guarantees are negotiated and they
     
    5 -- there are lots of -- I used to sell the
     
    6 equipment so I know a lot about how the whole
     
    7 guarantee negotiation process goes and, you know,
     
    8 it's usually -- it's not a simple negotiation.
     
    9 But I can't speak to what would happen on a
     
    10 particular unit, what companies are willing to
     
    11 guarantee.
     
    12 MS. TICKNER: Thank you.
     
    13 HEARING OFFICER TIPSORD: Ms. Bassi?
     
    14 MS. BASSI: Would Mr. Nelson guarantee
     
    15 that?
     
    16 DR. STAUDT: That question, I assume,
     
    17 is for Mr. Nelson?
     
    18 MS. BASSI: Yes, sir.
     
    19 MR. NELSON: I have some questions on
     
    20 guarantees that I can explicitly address. Since
     
    21 we don't make scrubbers, I'm not willing to
     
    22 guarantee scrubbers. Scrubber guarantees are a
     
    23 little more different in the sense that they're
     
    24 large capital equipment. And if you're getting
     
    KEEFE REPORTING COMPANY 157

     
     
     
     
     
    1 89 percent or 85, it may be very expensive if
     
    2 you're making big physical changes to get 90.
     
    3 Where Sorbent Technology, it just really means
     
    4 you usually have to inject a little more sorbent
     
    5 than you thought. So it does not surprise me
     
    6 that B & W or Alstom are not going to -- are
     
    7 going to be problematical in making those
     
    8 guarantees particularly since what's the
     
    9 utilities alternative. They only -- the
     
    10 guarantee is really kind of you only do what you
     
    11 have to do to get the order.
     
    12 MR. HARRINGTON: One point of
     
    13 suggestion the record might be unclear, are we
     
    14 talking about the test on maybe -- Put this way.
     
    15 Talking about the mercury removal, we talked
     
    16 about the fact that mercury that's elemental or
     
    17 the reactive gas or oxidized, as you called it,
     
    18 is captured on the activated carbon, you're not
     
    19 suggesting that 100 percent of it would be
     
    20 captured and -- on the activated in any case, are
     
    21 you? I mean, no matter what process it is,
     
    22 you're not capturing 100 percent of the mercury,
     
    23 the gaseous and elemental mercury on the
     
    24 activated carbon or halogenated activated carbon?
     
    KEEFE REPORTING COMPANY 158

     
     
     
     
     
    1 DR. STAUDT: Of the mercury that is
     
    2 captured, basically if 90 percent -- if you get
     
    3 90 percent removal of the gaseous form of
     
    4 mercury, okay, overall, that 90 percent is
     
    5 occurring prior to the perforation plate of the
     
    6 ESP. Once it gets into the field, once it enters
     
    7 that first field, almost most of the carbon gets
     
    8 removed, okay, and so I don't know how it's
     
    9 getting -- if you pull the carbon out of the gas
     
    10 stream, it can't be removing the mercury that's
     
    11 in the gas stream.
     
    12 MR. HARRINGTON: Well, I was saying --
     
    13 maybe put it another way. Just taking the
     
    14 activated carbon -- the halogenated activated
     
    15 carbon injection system before the ESP in a
     
    16 particular device, mercury coming in to that
     
    17 treatment system will be in the three forms that
     
    18 we discussed; correct?
     
    19 DR. STAUDT: Mercury coming into?
     
    20 MR. HARRINGTON: The treatment system.
     
    21 Where ever you inject the activated carbon?
     
    22 DR. STAUDT: It would be -- Yeah, in
     
    23 the three forms.
     
    24 MR. HARRINGTON: And the purpose of
     
    KEEFE REPORTING COMPANY 159

     
     
     
     
     
    1 injecting the halogenated activated carbon or
     
    2 plain activated carbon is to capture the
     
    3 elemental mercury and the gaseous mercury onto
     
    4 the activated carbon?
     
    5 DR. STAUDT: Well, the elemental and
     
    6 the oxidized which are both gaseous.
     
    7 MR. HARRINGTON: Yeah, both on the
     
    8 activated carbon before it goes into particulate
     
    9 removal system?
     
    10 DR. STAUDT: That's correct.
     
    11 MR. HARRINGTON: Some elemental and
     
    12 reactive gaseous mercury is going to go -- is not
     
    13 going to be captured in that process; is that
     
    14 correct?
     
    15 DR. STAUDT: In which process? Prior
     
    16 to the ESP?
     
    17 MR. HARRINGTON: Prior to the ESP or
     
    18 after the ESP? When you go through that whole
     
    19 treatment, some gas is going to come out the
     
    20 other side?
     
    21 DR. STAUDT: Well, look. When you say
     
    22 that there's 90 percent removal of that, and
     
    23 that's what we're talking about, 90 percent
     
    24 removal of that gaseous -- if you're removing 90
     
    KEEFE REPORTING COMPANY 160

     
     
     
     
     
    1 percent of the gaseous mercury, which actually
     
    2 means you're removing more than 90 percent of the
     
    3 total mercury, okay, because -- because it's that
     
    4 particulate mercury that's being captured anyhow.
     
    5 When you're removing 90 percent of that gaseous
     
    6 mercury, there is that 10 percent you don't catch
     
    7 and that's --
     
    8 MR. HARRINGTON: I just wanted to make
     
    9 that obvious and that's when you go through --
     
    10 DR. STAUDT: That's going to go right
     
    11 through.
     
    12 MR. HARRINGTON: And some of the
     
    13 particulate mercury that started out in the
     
    14 system is going to go through as well?
     
    15 DR. STAUDT: Very, very little.
     
    16 HEARING OFFICER TIPSORD: Mr. Romaine,
     
    17 you have something to add?
     
    18 DR. STAUDT: ESP is pretty efficient.
     
    19 You know, for a fabric filter it's virtually
     
    20 none. But an ESP in particular, you know, we're
     
    21 talking about ESPs here because on fabric filter
     
    22 some of the removal does occur on the filter, but
     
    23 on the -- within the particulate removal device,
     
    24 but an ESP all the capture occurs before the
     
    KEEFE REPORTING COMPANY 161

     
     
     
     
     
    1 perforation goes to the ESP.
     
    2 MR. HARRINGTON: I don't think we're
     
    3 arguing or betting the point. I think there was
     
    4 -- some people thought there was a misimpression
     
    5 on the record that everything was captured on the
     
    6 carbon. I know that wasn't your intent to say
     
    7 that. We just wanted to clarify the record.
     
    8 MR. ROMAINE: To clarify that comment
     
    9 -- on Mr. Staudt's comment, the assumption that
     
    10 USEPA has made in CAMR is that it's not necessary
     
    11 to quantify particulate matter emissions coming
     
    12 out of the stack. The emissions monitoring
     
    13 that's required on CAMR and proposed rule simply
     
    14 goes after these uncaptured gaseous mercury.
     
    15 MR. HARRINGTON: So let's make clear
     
    16 then that the intent of the Illinois rule based
     
    17 on what you've just said is to have -- you're
     
    18 going to have a sampling device which is only
     
    19 going to measure the gaseous mercury coming out
     
    20 the control system?
     
    21 DR. STAUDT: I can't speak to the
     
    22 intend of the Illinois rule.
     
    23 HEARING OFFICER TIPSORD: Mr. Romaine
     
    24 can answer that question.
     
    KEEFE REPORTING COMPANY 162

     
     
     
     
     
    1 MR. ROMAINE: That is the monitoring
     
    2 methodology that USEPA has developed, and I saw
     
    3 Mr. Nelson nodding his head conferring that.
     
    4 MR. HARRINGTON: Well, I think the
     
    5 record should be clear that's -- that's the
     
    6 monitoring system, but it also means that for the
     
    7 future there is no intent that any particulate
     
    8 mercury comes out of the control system, if there
     
    9 is any, is going to be accounted for as being
     
    10 uncaptured or 90 percent system or accounted to
     
    11 the .008?
     
    12 DR. STAUDT: Just as a clarification,
     
    13 right now there already may be some sort of
     
    14 particulate matter that may escape the ESP, but
     
    15 keep in mind, there's already mercury on your fly
     
    16 ash as it is, particularly if you have -- so
     
    17 you're not really changing anything.
     
    18 MR. HARRINGTON: No, I -- we don't
     
    19 have -- we don't have a debate on that point, but
     
    20 I'm getting back to Mr. Romaine's point, the 90
     
    21 percent capture is not talking about the
     
    22 particulate mercury?
     
    23 MR. ROMAINE: That's correct. And in
     
    24 terms of addressing the particulate matter, LUST
     
    KEEFE REPORTING COMPANY 163

     
     
     
     
     
    1 will have programs and future discussions will be
     
    2 addressing additional control methods for
     
    3 particular to that method.
     
    4 MR. HARRINGTON: I understand there
     
    5 will be particulate control programs. We
     
    6 understand that. But I think the rule should be
     
    7 clear as to what it is for limiting and measuring
     
    8 coming out because we know test methods are
     
    9 changed and there is our famous incredible
     
    10 evidence rule of about what you're measuring
     
    11 coming out, so the rule should be very clear
     
    12 about that. And sorry I'm lecturing but I'm just
     
    13 trying to make sure the record is clear.
     
    14 HEARING OFFICER TIPSORD: Let's take a
     
    15 break.
     
    16 (A short break was taken.)
     
    17 MR. HARRINGTON: I was going back to
     
    18 44(c) which we haven't -- we've never answered
     
    19 the question.
     
    20 MS. MOORE: Okay.
     
    21 MR. HARRINGTON: And in light of Mr.
     
    22 Romaine's clarification of the monitoring, which
     
    23 I probably should have realized but perhaps
     
    24 didn't, I think 44(c) becomes a more important
     
    KEEFE REPORTING COMPANY 164

     
     
     
     
     
    1 question given than what I originally thought of.
     
    2 What measurement methods were used to determine
     
    3 removal rates while inlet and outlet for the test
     
    4 that you're relying on the -- for the ones that
     
    5 you're relying on?
     
    6 HEARING OFFICER TIPSORD: Again, for
     
    7 the record we really have gone afield, referring
     
    8 to the demonstration catalog table at 8.1 on page
     
    9 125 of the TSD; is that correct?
     
    10 MR. HARRINGTON: Correct. And then by
     
    11 agreement we limited to those tests.
     
    12 Demonstrations that the witness relied upon.
     
    13 HEARING OFFICER TIPSORD: Correct.
     
    14 Thank you.
     
    15 DR. STAUDT: Well, my understanding on
     
    16 most of these they used continuous mercury
     
    17 monitors for most of the tests. I can't speak to
     
    18 the details on each one. But, again, they were
     
    19 done by the U.S -- these were -- tests were
     
    20 supervised U.S. Department of Energy.
     
    21 MR. HARRINGTON: Do you know -- you
     
    22 don't know what continuos emission monitors they
     
    23 used?
     
    24 DR. STAUDT: On ADA they used a
     
    KEEFE REPORTING COMPANY 165

     
     
     
     
     
    1 monitor of -- test by ADA used monitors from
     
    2 Thermal Electron Corporation. Sid can speak to
     
    3 the ones that are -- that are done on the test
     
    4 that he was involved with.
     
    5 MR. HARRINGTON: Yes, please.
     
    6 MR. NELSON: We actually, in our
     
    7 programs, we measure mercury four different ways.
     
    8 You want to measure it as many ways as you can.
     
    9 From day to day we use the continuous mercury
     
    10 monitors. Ours are called Sir Galahads. It's
     
    11 actually serial numbers one and two of a new unit
     
    12 that is going to be marketed by GE. It comes out
     
    13 of Brittain. We also use particularly more
     
    14 recently usually every day or every other day we
     
    15 will do a sorbent trap called -- used to be
     
    16 called Method 324. It's now appendix K, an
     
    17 alternative scheme that Electric Power Research
     
    18 Institute, EPRI, uses. DOE requires us to
     
    19 occasionally do a more elaborate method that
     
    20 gives you just a snapshot called the Ontario
     
    21 Hydro Method, and we have a contract that will
     
    22 come in and do that. We actually have an outside
     
    23 firm in our DOE programs do our continuous
     
    24 mercury monitors because we don't want to look
     
    KEEFE REPORTING COMPANY 166

     
     
     
     
     
    1 like we're biased in doing measurements. And,
     
    2 finally, and the thing I have the most faith in
     
    3 is we take those fly ash samples every day, the
     
    4 long-term ones, as well as sampling the mercury
     
    5 in the coal and that way we can get what we call
     
    6 a mass balance to know how much mercury is coming
     
    7 into the plant, how much is mercury is going out
     
    8 the stack, how much we're actually taking out in
     
    9 the sorbent that isn't a fly ash, and we can kind
     
    10 of sum it all up and figure out where everything
     
    11 goes. It's a real good way to make sure you're
     
    12 getting the mercury removals that you think you
     
    13 are.
     
    14 MR. HARRINGTON: With respect to
     
    15 measuring the mercury in the flue gas either
     
    16 before or after treatment, do you use continuous
     
    17 emission monitors such as Sir Galahad or the
     
    18 others you mentioned, do those sample only the
     
    19 gaseous mercury?
     
    20 MR. NELSON: The Ontario Hydro Method
     
    21 gives you a particulate but the continuous
     
    22 mercury monitors can measure gas phase. Same
     
    23 with the Method 324.
     
    24 MR. HARRINGTON: So when somebody says
     
    KEEFE REPORTING COMPANY 167

     
     
     
     
     
    1 they removed 90 percent mercury in the gas, the
     
    2 assumption -- in the flue gas, you have to know
     
    3 what test they're using before and after the
     
    4 treatment in order to know what that 90 percent
     
    5 is of?
     
    6 MR. NELSON: Yeah. The particulate
     
    7 associated mercury -- we call it particulate
     
    8 associated mercury rather than particulate
     
    9 mercury. It's not -- the mercury is in different
     
    10 forms. The mercury -- Once it's burned in the
     
    11 boiler, it only is there in gas phase. It's
     
    12 either in oxidative state or it's an elemental
     
    13 state. It's only a gas phase. That native
     
    14 removal what we call it, that's that accidental.
     
    15 You'll notice, for example, on the one exhibit of
     
    16 St. Clair, there's actually two numbers here. It
     
    17 says the 30-day average removal due to the
     
    18 sorbent is 91 percent whereas the 30-day average
     
    19 is 94 percent.
     
    20 It is important to kind of distinguish
     
    21 between these two numbers. At some plants where
     
    22 you do have high accidental removal or
     
    23 particulate phase removal, that difference in 3
     
    24 percent, the way to think about it is that this
     
    KEEFE REPORTING COMPANY 168

     
     
     
     
     
    1 plant, if we don't have any sorbent injection on,
     
    2 will get out 20 or 30 percent of the mercury
     
    3 without even trying and that's absorbed on the
     
    4 unburned carbon that's in the fly ash. So the
     
    5 way to think about this is when we injected the
     
    6 sorbent, we got 90 percent of -- 91 percent of
     
    7 the gas phase mercury that was there when we
     
    8 injected the sorbent and then the unburned carbon
     
    9 that was already there gets another 20 or 30
     
    10 percent of what's leftover. So in that case it's
     
    11 20 or 30 percent of 10 percent or 2 or 3 percent,
     
    12 so that's the difference between 91 and 94. When
     
    13 you look at these numbers and you look at how
     
    14 much is removed, we always report the mercury
     
    15 removal due to the sorbent because that's
     
    16 something you can generalize going from plant to
     
    17 plant whereas each plant is going to have
     
    18 anywhere from zero percent of native removal to
     
    19 as high as 95 percent without any sorbent
     
    20 injection. So it is important to distinguish to
     
    21 say exactly what you're talking about. Is it
     
    22 removal due to your sorbent or whatever technique
     
    23 you're doing or is it total, you know, and you're
     
    24 taking credit for what the plant is doing even
     
    KEEFE REPORTING COMPANY 169

     
     
     
     
     
    1 without you?
     
    2 HEARING OFFICER TIPSORD: I would note
     
    3 for the record Mr. Nelson was referring to
     
    4 Exhibit 49.
     
    5 MR. HARRINGTON: Now when you say you
     
    6 get 90 percent removal on certain tests and
     
    7 expect to get that in the future with the
     
    8 technologies we've talked about, are you talking
     
    9 about 90 percent removal of the gaseous mercury?
     
    10 And let me ask Mr. Staudt -- Dr. Staudt this
     
    11 question because I want to clarify what the 90
     
    12 percent is of.
     
    13 DR. STAUDT: Well, if you're getting
     
    14 -- Yes. I mean, you can see 90 percent of the
     
    15 gaseous mercury. For example, let me just, you
     
    16 know, to clarify this. If you have, let's say,
     
    17 we've heard about co-benefit removal. The
     
    18 co-benefit removal is basically how much the
     
    19 mercury, as you mentioned, some mercury gets
     
    20 attached to the fly ash. And it's, say -- and
     
    21 just to make the math easy. Let's assume that 50
     
    22 percent of the mercury that goes into -- is in
     
    23 the coal gets attached to the fly ash. So you
     
    24 get a 50 percent co-benefit removal. To get to a
     
    KEEFE REPORTING COMPANY 170

     
     
     
     
     
    1 total of 90 percent removal, all you have to do
     
    2 is remove 80 percent of the remaining 50 percent
     
    3 to get to a total 90 percent removal. So if
     
    4 you're -- the -- actually it's good when you have
     
    5 a lot of mercury on the particulate already
     
    6 because then you don't have to -- you don't have
     
    7 to inject as much sorbent to get 90 percent total
     
    8 for the -- for the amount that's in the coal
     
    9 because already -- already a lot of that mercury
     
    10 -- that mercury from the coal is already going to
     
    11 be pulled out from the ESP. You're just going
     
    12 after what the -- part that's remaining part.
     
    13 MR. HARRINGTON: Just for
     
    14 clarification, with respect to subbituminous
     
    15 coal, Powder River Basin coal that's typically
     
    16 used here, the removal on the fly ash is much
     
    17 less than it is on bituminous?
     
    18 DR. STAUDT: That's correct.
     
    19 MR. HARRINGTON: And 20 percent or
     
    20 less would not be uncommon?
     
    21 DR. STAUDT: Oh, that's correct. And
     
    22 in my, you know, and actually I'm presuming that
     
    23 in nearly every case for the PRB units that
     
    24 there's no co-benefit.
     
    KEEFE REPORTING COMPANY 171

     
     
     
     
     
    1 MR. HARRINGTON: Okay. I think that
     
    2 should be clear. But in terms of the 90 percent
     
    3 removal on subbituminous coal, we're talking
     
    4 about looking at gaseous mercury in before the
     
    5 treatment after gaseous mercury out after the
     
    6 treatment essentially ignoring particulate on
     
    7 both ends?
     
    8 DR. STAUDT: No. I mean, basically
     
    9 the -- if you're capturing -- when we look at 90
     
    10 percent removal by sorbent, okay, the sorbent
     
    11 doesn't remove -- doesn't remove mercury that's
     
    12 already been on fly ash. So it's basically --
     
    13 when I talk about 90 percent removal attributed
     
    14 to the sorbent is 90 percent of -- it's really
     
    15 you're comparing gaseous mercury prior to
     
    16 treatment to the gaseous mercury after treatment.
     
    17 MR. HARRINGTON: For clarification if
     
    18 we have a rule that says when you take out 90
     
    19 percent mercury when you measure it coming out of
     
    20 the system should be gaseous mercury ignoring any
     
    21 particulate?
     
    22 DR. STAUDT: Well, anything having to
     
    23 do with how the rule requires people to measure
     
    24 mercury, that's, you know, maybe Chris.
     
    KEEFE REPORTING COMPANY 172

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: I believe
     
    2 Chris Romaine answered that question yet a couple
     
    3 of times.
     
    4 MR. HARRINGTON: Well, he answered in
     
    5 terms of the specified in some of the test
     
    6 methods, but Ontario Hydro is one of the
     
    7 reference methods that measured particulate.
     
    8 HEARING OFFICER TIPSORD: All right.
     
    9 Go ahead, Mr. Romaine.
     
    10 MR. ROMAINE: I'm simply going to
     
    11 respond by saying that the rule does not require
     
    12 90 percent control. Nothing in this rule says 90
     
    13 percent control. If in terms of how compliance
     
    14 is determined, it has a provision that requires
     
    15 that the amount of emissions be no more than 10
     
    16 percent of the mercury going into the unit. So
     
    17 think about it in terms of the other part of the
     
    18 equation. The emission can be no more than 10
     
    19 percent of what you started with. Maybe it's
     
    20 gaseous mercury coming out of the stack.
     
    21 MR. HARRINGTON: Gaseous mercury. In
     
    22 test methods that you've specified would be
     
    23 gaseous mercury would not include particulate; is
     
    24 that correct?
     
    KEEFE REPORTING COMPANY 173

     
     
     
     
     
    1 MR. NELSON: If I can clarify, Ontario
     
    2 Hydro which measures the particulate, all the
     
    3 Ontario Hydro methods that I've seen where they
     
    4 sampled after the particulate removal device,
     
    5 there's never any mercury in those unless it's a
     
    6 bad sample.
     
    7 MR. HARRINGTON: Are you aware -- Go
     
    8 ahead.
     
    9 MR. ROMAINE: I wanted to clarify.
     
    10 Obviously the rule starts out with a 90 percent
     
    11 reduction requirement. But that's partly the
     
    12 reason why the rule very quickly goes to specific
     
    13 methodology for how emissions are calculated
     
    14 which take the input mercury and calculate
     
    15 allowable emission rate that is 10 percent of the
     
    16 input mercury.
     
    17 MR. HARRINGTON: And that outlet
     
    18 mercury is going to be measured using methods
     
    19 that only measure gaseous mercury?
     
    20 MR. ROMAINE: That is the nature of
     
    21 continuous monitoring method.
     
    22 MR. HARRINGTON: And no other method
     
    23 will be applied?
     
    24 MR. ROMAINE: We have not specified
     
    KEEFE REPORTING COMPANY 174

     
     
     
     
     
    1 using another method.
     
    2 MR. HARRINGTON: And the record can be
     
    3 clear and maybe the opinion that's what we're
     
    4 talking about. But are you aware, Dr. Staudt, of
     
    5 a system where the mercury measurement of 90
     
    6 percent number, or removal number we've spoken
     
    7 of, it has been based on measuring the mercury in
     
    8 the coal versus the mercury in the discharge from
     
    9 in the plant?
     
    10 DR. STAUDT: It would -- it would
     
    11 actually be easy -- it actually is easier to get
     
    12 to -- because you're starting out with more in
     
    13 the coal, so the highest amount of mercury starts
     
    14 out in the coal so if you're starting out at a
     
    15 higher level, it's actually easier to get down to
     
    16 10 percent of that higher level. So the way the
     
    17 Illinois rule is written, if you're comparing it
     
    18 90 percent to what the outlet is or the
     
    19 uncontrolled outlet, that is actually much more
     
    20 stringent than 90 percent of the coal -- much
     
    21 more stringent than what the Illinois rule
     
    22 requires which is, you know, emitting no more
     
    23 than 10 percent of the mercury that goes into the
     
    24 plant.
     
    KEEFE REPORTING COMPANY 175

     
     
     
     
     
    1 MR. HARRINGTON: Are you aware of any
     
    2 sampling that has been done to make that
     
    3 demonstration?
     
    4 DR. STAUDT: I don't know if that
     
    5 sampling has been done.
     
    6 MR. HARRINGTON: Thank you.
     
    7 HEARING OFFICER TIPSORD: Was that D?
     
    8 MR. HARRINGTON: Yes, I think that
     
    9 takes care of D.
     
    10 HEARING OFFICER TIPSORD: And E, the
     
    11 length of each study that you relied upon.
     
    12 MR. HARRINGTON: That, I believe, has
     
    13 been answered.
     
    14 HEARING OFFICER TIPSORD: And F.
     
    15 MR. HARRINGTON: F.
     
    16 DR. STAUDT: Okay. I can't comment on
     
    17 the statistical methods others may or may not
     
    18 have used. I think the -- but you have -- you
     
    19 have -- the best fit curves with the -- with this
     
    20 Exhibit 52. So if you want to look at what I
     
    21 have done, I can't speak to what other people
     
    22 have done.
     
    23 MR. HARRINGTON: Maybe you can correct
     
    24 me or if I'm -- it's outside both our areas of
     
    KEEFE REPORTING COMPANY 176

     
     
     
     
     
    1 expertise then we can just go on. But my
     
    2 understanding is when you take a set of data you
     
    3 want project future performance from that data,
     
    4 there's appropriate statistical methods to
     
    5 analyze it, simply drawing the curve tells you
     
    6 what you did have but is not a reliable method of
     
    7 predicting what you get in the future based on
     
    8 that same data. Do you understand?
     
    9 DR. STAUDT: Perhaps you can give me
     
    10 -- describe some more and give me an example.
     
    11 MR. HARRINGTON: Well, for example,
     
    12 when analyzing in the water program when setting
     
    13 effluent limits, they develop a statistical
     
    14 method that's projected future limitations saying
     
    15 it will achieve 95 percent, no more than 5
     
    16 percent of the future samples will exceed this
     
    17 value with a 99 percent confidence. It's a much
     
    18 more elaborate statistical method, which I can't
     
    19 apply but I understand what the purpose is,
     
    20 because it takes into account the variability of
     
    21 the data, the amount of data you have against the
     
    22 amount of data you will have in the future in
     
    23 order to determine that. And I'm wondering if
     
    24 you know of any such kind of statistical method
     
    KEEFE REPORTING COMPANY 177

     
     
     
     
     
    1 that was applied to any of the data you're
     
    2 relying on?
     
    3 DR. STAUDT: Well, the curve that you
     
    4 have -- have it shows the -- the correlation and
     
    5 -- are squared. And from that you can develop --
     
    6 you can develop confidence intervals.
     
    7 MR. HARRINGTON: But you have not done
     
    8 so and are not aware of anyone else who has done
     
    9 so; is that correct?
     
    10 DR. STAUDT: Well, I can't speak to
     
    11 what anyone else may have done.
     
    12 MR. HARRINGTON: I'm not saying you
     
    13 can say they did or didn't. I'm just saying --
     
    14 DR. STAUDT: But you can see what I've
     
    15 done and --
     
    16 MR. HARRINGTON: Okay. Thank you.
     
    17 HEARING OFFICER TIPSORD: G.
     
    18 DR. STAUDT: "Whether the conditions
     
    19 upon which the study was run are comparable to
     
    20 those conditions that would be expected in a
     
    21 year-round operation under normal operating
     
    22 conditions." In my -- Based upon what I have
     
    23 seen, yes.
     
    24 MR. HARRINGTON: Well, for example,
     
    KEEFE REPORTING COMPANY 178

     
     
     
     
     
    1 were these samples run in severe winter weather?
     
    2 DR. STAUDT: Well, to my understanding
     
    3 they were using -- in most cases they were using
     
    4 continuous monitors.
     
    5 MR. HARRINGTON: If you run a 30-day
     
    6 sample, when would -- a 30-day trial, typically
     
    7 when would that have been run?
     
    8 DR. STAUDT: I don't know. I -- It
     
    9 would have been run -- would have been run over a
     
    10 30-day period but I'm not sure what you're trying
     
    11 to get at.
     
    12 MR. HARRINGTON: You don't know
     
    13 whether it was run in June or in January in this
     
    14 unit, for example?
     
    15 DR. STAUDT: Well, one thing that's
     
    16 very important to keep in mind, if you take a
     
    17 look at Figure 8.10 of the data, one thing you
     
    18 will find is these are units that have different
     
    19 units and in all but one case they're all burning
     
    20 PRB coal, and different places in the country,
     
    21 different SCA, ESPs, and they all get pretty
     
    22 close to the same result. So when you get a
     
    23 series of data like that and over and over you go
     
    24 test here, you test there, you test someplace
     
    KEEFE REPORTING COMPANY 179

     
     
     
     
     
    1 else looking at, you know, boilers that, say,
     
    2 have certain characteristics you look for certain
     
    3 characteristics, PRB coal, Cold-Side ESP, what
     
    4 have you, and you get pretty much the same
     
    5 results time and time again, it gives you a
     
    6 pretty good level of confidence that in the
     
    7 future on a similar unit with those similar
     
    8 characteristics you will get pretty similar
     
    9 results.
     
    10 HEARING OFFICER TIPSORD: Ms. Bassi?
     
    11 MS. BASSI: Intuitively it would seem
     
    12 that units would operate differently in summer
     
    13 than in winter, and I think that the question is:
     
    14 Have these over the gamut of -- at least over the
     
    15 gamut of the test that you relied on, do they
     
    16 reflect different seasons of the year, different
     
    17 -- different extreme weather conditions?
     
    18 DR. STAUDT: Well, they also -- well,
     
    19 I don't know about --
     
    20 MS. BASSI: Just yes or no or I don't
     
    21 know.
     
    22 DR. STAUDT: Very different locations
     
    23 too.
     
    24 MS. BASSI: Fine. But what about --
     
    KEEFE REPORTING COMPANY 180

     
     
     
     
     
    1 DR. STAUDT: Different climates.
     
    2 MS. BASSI: -- what about seasons?
     
    3 DR. STAUDT: I don't know about the
     
    4 seasons, what time of year they were run.
     
    5 HEARING OFFICER TIPSORD: Mr. Forcade?
     
    6 MR. FORCADE: Are we going to get the
     
    7 reports on these and, if so, would they have the
     
    8 date of the test?
     
    9 DR. STAUDT: I am quite certain that
     
    10 your experts there have the information. They're
     
    11 cited in the TSD. These are all things that have
     
    12 been presented at places like the mega symposium
     
    13 and are available on the DOE Website?
     
    14 MR. FORCADE: I'm interested what's in
     
    15 the record here. Are the reports that
     
    16 substantiate the tests you're relying on going to
     
    17 be produced into the record here? I believe the
     
    18 answer to that earlier was yes.
     
    19 DR. STAUDT: We have the Website
     
    20 location.
     
    21 MR. FORCADE: Well, I believe both I
     
    22 and Dr. Girard asked for the reports.
     
    23 MR. KIM: I'm sorry. We have been
     
    24 looking for a Website address or a complete copy
     
    KEEFE REPORTING COMPANY 181

     
     
     
     
     
    1 of the reports, and we have not been able to find
     
    2 them yet. So we'll probably talk with Dr. Staudt
     
    3 a little more and see if we can get some more --
     
    4 if we can find them, we will provide them but
     
    5 thus far we haven't been able to find them. And
     
    6 I haven't had a chance to talk about this with
     
    7 Dr. Staudt after we come back because we have
     
    8 been looking. Whatever information he has used
     
    9 to base his opinions and prepare the information
     
    10 to the extent it's not already provided, we will
     
    11 provide. It's just -- To be honest, we thought
     
    12 we had everything that was relied upon. If there
     
    13 is something that was missed or something that
     
    14 goes beyond that which we submitted to, we're
     
    15 going to try as hard as we can to get that.
     
    16 HEARING OFFICER TIPSORD: I think the
     
    17 concern is if I may, Mr. Forcade, I think the
     
    18 concern here is not necessarily just what Dr.
     
    19 Staudt relied upon, but he is reporting results
     
    20 that we don't have all the information now on the
     
    21 results and he's used the results to form his
     
    22 opinions. He's given us more detail on the
     
    23 actual things he's relied upon, but we do have
     
    24 results here that have been presented as part of
     
    KEEFE REPORTING COMPANY 182

     
     
     
     
     
    1 the TSD which presumably supports the rule that
     
    2 we don't have enough information on.
     
    3 MR. KIM: Right. But I believe that
     
    4 his testimony, and again, he can correct me if
     
    5 I'm wrong, I think with the exception of one of
     
    6 the four studies that was listed, his information
     
    7 was based upon slides and so forth that we have
     
    8 provided. So up until now we have given
     
    9 everything that we had that he has used with the
     
    10 exception of this one report to base -- to base
     
    11 the preparation of the TSD. But having said
     
    12 that, you know, if there are full reports and if
     
    13 Dr. Staudt has additional information that goes
     
    14 beyond what we provided, we'll definitely try to
     
    15 track it down and get it as soon as we can.
     
    16 HEARING OFFICER TIPSORD: Thank you.
     
    17 MR. KIM: If we have it, we'll get it
     
    18 to you.
     
    19 MR. NELSON: If I can just interject
     
    20 on the seasonal data, I can only speak for
     
    21 Sorbent Technologies. But these were some of the
     
    22 questions I was asked, it might be better to talk
     
    23 about them here. The Lausche demonstration in
     
    24 that list, the Duke Power Cliffside and the Duke
     
    KEEFE REPORTING COMPANY 183

     
     
     
     
     
    1 Power Allen were all done in the winter, oh, as
     
    2 well as the Progress Lee, so those were done in
     
    3 the very cold weather. The Duke Power Buck, my
     
    4 company did in the spring time. The fall was
     
    5 Duke -- the fall Detroit-Edison St. Clair was
     
    6 done in the fall. Great River Energys Stanton 1
     
    7 was done in the fall and we did one that isn't
     
    8 reported here. It was a fabric filter mercury
     
    9 reenforced steel plant was in the fall. In the
     
    10 summertime was we did one at Public Service of
     
    11 New Hampshire and our upcoming one that we begin
     
    12 next month or in July at Crawford here in the
     
    13 Chicago area will be the summer. That's my
     
    14 company. I know ADAS and URS similarly. We
     
    15 don't restrict them. We just do them, you know,
     
    16 any time a year because they're operating any
     
    17 time of year.
     
    18 HEARING OFFICER TIPSORD: Ms. Bugel?
     
    19 MS. BUGEL: Mr. Nelson, in your
     
    20 experience with those studies, does the weather
     
    21 affect the performance of sorbent?
     
    22 MR. NELSON: The weather does not
     
    23 affect the performance of the sorbent. There's
     
    24 no reason to believe that it would.
     
    KEEFE REPORTING COMPANY 184

     
     
     
     
     
    1 MR. KIM: Going back to the studies,
     
    2 as I said, we will make every effort we can. We
     
    3 would certainly welcome, if for some reason
     
    4 someone else has though studies, we would be more
     
    5 than happy for them to provide them as well but
     
    6 we will -- we will try and find them.
     
    7 HEARING OFFICER TIPSORD: Thank you,
     
    8 Mr. Kim. We ready to go to H. I'm sorry. Mr.
     
    9 Zabel?
     
    10 MR. ZABEL: Simple question, Doctor,
     
    11 the Table 8.1 under equipment, some of them you
     
    12 list as CS ESPs and some of them you list as
     
    13 simply C-ESP, what's the difference?
     
    14 DR. STAUDT: There shouldn't be a
     
    15 difference. That's probably a typo.
     
    16 MR. ZABEL: They all coincide?
     
    17 DR. STAUDT: Let me take a look just
     
    18 to make sure.
     
    19 MR. ZABEL: Sure.
     
    20 DR. STAUDT: Yeah. That would be cold
     
    21 -- where it says -- on the second page CE-ESP and
     
    22 independent, those are all Cold-Side ESPs.
     
    23 HEARING OFFICER TIPSORD: Mr.
     
    24 Bonebrake?
     
    KEEFE REPORTING COMPANY 185

     
     
     
     
     
    1 MR. BONEBRAKE: One other follow up.
     
    2 Figure 8.10 which we were talking about a minute
     
    3 ago --
     
    4 DR. STAUDT: Yes.
     
    5 MR. BONEBRAKE: -- it refers to in
     
    6 flight mercury?
     
    7 DR. STAUDT: That's correct.
     
    8 MR. BONEBRAKE: And just in keeping
     
    9 with the distinction, we've been discussing
     
    10 between reactive, between gaseous and particulate
     
    11 mercury, does Figure 8.10 then depict reductions
     
    12 in gaseous mercury without regard to particulate
     
    13 mercury?
     
    14 DR. STAUDT: That's correct. It's not
     
    15 -- particulate mercury is already removed so
     
    16 there's not -- by the particulate controlled
     
    17 device so kind of meaningless to talk about it.
     
    18 HEARING OFFICER TIPSORD: Moving on, I
     
    19 believe we answered 8 -- or H. I'm really going
     
    20 back. Question No. 45.
     
    21 DR. STAUDT: 45, well, we talked about
     
    22 which ones I used to formulate my opinions
     
    23 relative to Illinois rules. "Which of these
     
    24 units do you believe is representative of normal
     
    KEEFE REPORTING COMPANY 186

     
     
     
     
     
    1 operating conditions on facilities in Illinois
     
    2 including the size of ESPs and the use of gas
     
    3 conditioning?" The -- I mean, I can -- the test
     
    4 data shown in Figures 8.10 and 8.11 and the other
     
    5 data such as DT Monroe, which I think we'll
     
    6 probably provide, and the testing with fabric
     
    7 filters or TOXECON, were used to reach my
     
    8 conclusions on sorbent removal. It is my
     
    9 understanding that gas conditioning was in
     
    10 surface at Monroe during testing and no effect
     
    11 was observed.
     
    12 I don't have information regarding the
     
    13 use of gas conditioning at the other sites.
     
    14 However, I -- SO3 conditioning can potentially
     
    15 have an impact on performance, and I'm sure we're
     
    16 going to talk more about that soon. The ESP, in
     
    17 my opinion, as I discussed the role that plays in
     
    18 removing of mercury, its only role is to capture
     
    19 the -- capture the particulate mercury once the
     
    20 sorbent has captured the gaseous mercury. So in
     
    21 my opinion ESP size is not a limit on mercury
     
    22 capture.
     
    23 HEARING OFFICER TIPSORD: Question No.
     
    24 46, I believe, we've answered about the length of
     
    KEEFE REPORTING COMPANY 187

     
     
     
     
     
    1 the study and your opinions, so let's go to.
     
    2 DR. STAUDT: 47, "When dealing with
     
    3 new technology, isn't the minimum of one year of
     
    4 full scale operation necessary to project future
     
    5 performance?" I did not agree with that. Over
     
    6 100,000 megawatts of utility coal capacity has
     
    7 been retrofitted with -- over 100,000 megawatts
     
    8 of utility coal capacity has been retrofitted
     
    9 over the last 10 years, and 10 years ago we had a
     
    10 lot less data on U.S. coals with SCR and U.S.
     
    11 coal than we currently have regarding the use of
     
    12 mercury sorbent on U.S. coal. SCR is also a form
     
    13 or complex retrofit than what we are talking
     
    14 about here with far bigger risks due to the high
     
    15 expense and use of catalyst that has to work
     
    16 inside the duct work for many years, you know, in
     
    17 contrast of that, the sorbent only has to work
     
    18 for a few seconds until it gets captured so I
     
    19 don't see -- I don't agree with that statement.
     
    20 HEARING OFFICER TIPSORD: Mr. Zabel?
     
    21 MR. ZABEL: Was the data on SCRs on
     
    22 foreign coal?
     
    23 DR. STAUDT: The data -- the data was
     
    24 on foreign -- there was data on foreign coal.
     
    KEEFE REPORTING COMPANY 188

     
     
     
     
     
    1 MR. ZABEL: So when you say there was
     
    2 no data on U.S. coal, doesn't mean there was no
     
    3 data?
     
    4 DR. STAUDT: Well, if -- there was
     
    5 plenty -- I can tell you 10 years ago there was
     
    6 plenty of complaining by the utility industry
     
    7 that SCR was unproven on U.S. coals.
     
    8 MR. ZABEL: All I'm asking is your
     
    9 statement suggested there was no data on SCRs at
     
    10 the time that we installed wasn't quite accurate
     
    11 except when you limit it to U.S. coal; isn't that
     
    12 correct?
     
    13 DR. STAUDT: Well, my statement was
     
    14 correct.
     
    15 MR. ZABEL: As you limit it to U.S.
     
    16 coals?
     
    17 DR. STAUDT: My statement was correct
     
    18 as I stated.
     
    19 MR. ZABEL: You were not trying to
     
    20 imply that there was --
     
    21 DR. STAUDT: My statement was correct
     
    22 as stated.
     
    23 MR. ZABEL: I asked you another
     
    24 question. Read it back, ma'am.
     
    KEEFE REPORTING COMPANY 189

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: You can't
     
    2 speak over each other. The court reporter can't
     
    3 take that down.
     
    4 DR. STAUDT: I did not intend to imply
     
    5 that there was no data on SCRs.
     
    6 MR. ZABEL: Good, then there was data
     
    7 as you said?
     
    8 DR. STAUDT: There was data on SCR.
     
    9 MR. ZABEL: Is there data on mercury
     
    10 controls on foreign controls?
     
    11 DR. STAUDT: No. Because there hasn't
     
    12 been any testing to -- there hasn't been any
     
    13 requirement for mercury controls on foreign coal.
     
    14 MR. ZABEL: Maybe my question wasn't
     
    15 clear. Has there been any use of sorbent
     
    16 injection in foreign countries on foreign coal?
     
    17 DR. STAUDT: I'm not aware of any.
     
    18 HEARING OFFICER TIPSORD: Question No.
     
    19 48.
     
    20 DR. STAUDT: 48, "You previously
     
    21 stated that SO3 in the flue gases would interfere
     
    22 with mercury removal from halogenated powder
     
    23 activated carbon; is that correct?" Well, I
     
    24 acknowledge that there is a potential for there
     
    KEEFE REPORTING COMPANY 190

     
     
     
     
     
    1 to be, and I don't know -- I don't remember
     
    2 saying exactly what you have in that question.
     
    3 MR. HARRINGTON: I refer to the
     
    4 technical report you prepared during the public
     
    5 meetings when you talked about in the discussion
     
    6 was at public meetings where there was discussion
     
    7 of the impact SO3 originating from the coal, not
     
    8 SO3 injection, as interfering with halogenated
     
    9 activated carbon and potentially doing so?
     
    10 DR. STAUDT: Well, I don't remember
     
    11 exactly what I said but I do acknowledge that SO3
     
    12 can have an adverse impact on the performance of
     
    13 halogenated carbon in some cases.
     
    14 MR. HARRINGTON: Thank you.
     
    15 HEARING OFFICER TIPSORD: Question No.
     
    16 49.
     
    17 DR. STAUDT: 49, "Are you familiar
     
    18 with the use of sulfur tri-oxide as a gas
     
    19 conditioner prior to Coal-Side ESPs where
     
    20 facilities have been converted from high sulfur
     
    21 bituminous coal to low sulfur Powder River Basin
     
    22 coal (PRB)?" Yes. 50, "Are you familiar with
     
    23 the impact of such treatment on the performance
     
    24 of halogenated activated carbon?" I think we've
     
    KEEFE REPORTING COMPANY 191

     
     
     
     
     
    1 already answered that.
     
    2 MR. HARRINGTON: Well, are you aware
     
    3 of any data showing the impact of SO3
     
    4 conditioning?
     
    5 DR. STAUDT: I have seen data, but I
     
    6 don't recall exactly the test results, but I've
     
    7 -- I have seen data.
     
    8 MR. HARRINGTON: You don't -- do you
     
    9 recall whether it had a significant impact on
     
    10 removal?
     
    11 DR. STAUDT: In some -- yeah, in some
     
    12 cases it did.
     
    13 MR. HARRINGTON: By significant,
     
    14 perhaps as low as 50 percent removal as opposed
     
    15 to --
     
    16 DR. STAUDT: Perhaps. Perhaps. I
     
    17 don't recall exactly.
     
    18 MR. HARRINGTON: Okay. Thank you.
     
    19 HEARING OFFICER TIPSORD: Question No.
     
    20 51.
     
    21 DR. STAUDT: 51, "What would you
     
    22 expect the impact of such treatment on the
     
    23 performance of halogenated activated carbon to
     
    24 be?" You wouldn't want to inject these together
     
    KEEFE REPORTING COMPANY 192

     
     
     
     
     
    1 or inject the sorbent downstream of SO3 because it
     
    2 could possibly hinder mercury capture as you
     
    3 point out. However, if the halogenated carbon
     
    4 can be introduced upstream of the SO3, any adverse
     
    5 effect may be avoided. In fact, what -- after I
     
    6 finish my answer, I think Sid has some -- some
     
    7 information to share with you. Some -- some
     
    8 Illinois units are likely to have adequate duct
     
    9 length to do that and avoid interference, others
     
    10 may not. However, in these cases there are
     
    11 alternatives to SO3 conditioning that are
     
    12 effective in a similar cost.
     
    13 MR. HARRINGTON: Due to -- What
     
    14 alternatives are those?
     
    15 DR. STAUDT: There are chemicals that
     
    16 are available from ADA. There are chemicals I'm
     
    17 told a company called Benetech and others.
     
    18 Basically these are alternative flue-gas
     
    19 conditioning chemicals that are not sulfur based
     
    20 and so -- and work -- work equally effectively.
     
    21 MR. HARRINGTON: Are you personally
     
    22 aware of those?
     
    23 DR. STAUDT: I am personally -- When
     
    24 you say personally aware, in what respect?
     
    KEEFE REPORTING COMPANY 193

     
     
     
     
     
    1 MR. HARRINGTON: Well, I mean, have
     
    2 you ever -- have you seen data on their
     
    3 application and the types of facilities that
     
    4 operate in Illinois with SO3 conditioning?
     
    5 DR. STAUDT: Well, most of the
     
    6 facilities that they -- you would see data on,
     
    7 you would -- would be at similar facilities as
     
    8 Illinois people who shipped it from high sulfur
     
    9 to low sulfur coal. So, yes. I'm also aware
     
    10 it's my understanding that Midwest Generating
     
    11 uses an alternative approach.
     
    12 HEARING OFFICER TIPSORD: Question 52.
     
    13 DR. STAUDT: "How does the size of
     
    14 ESPs on Illinois coal-fired power plants compare
     
    15 to those in the studies referred to in the
     
    16 technical support document?" If you're referring
     
    17 to the size of ESP in terms of specific
     
    18 collection area, some of the Illinois --
     
    19 MR. HARRINGTON: That's correct.
     
    20 DR. STAUDT: Okay. Okay. Some of the
     
    21 ESPs are smaller than those in tests discussed in
     
    22 the TSD, some were of similar size.
     
    23 HEARING OFFICER TIPSORD: 53.
     
    24 DR. STAUDT: "How would you expect
     
    KEEFE REPORTING COMPANY 194

     
     
     
     
     
    1 that to impact mercury removal?" I do not expect
     
    2 ESP sites --
     
    3 HEARING OFFICER TIPSORD: Slow down.
     
    4 DR. STAUDT: Sorry. I do not expect
     
    5 ESP sites to have an adverse effect on
     
    6 halogenated sorbent performance at a properly
     
    7 designed, operated and maintained ESP, even a
     
    8 small one such as some of the Illinois units.
     
    9 The capture of gaseous mercury by the sorbent
     
    10 occurs before the ESP. ESP's role is only to
     
    11 capture the small amount of sorbent along with
     
    12 the tons and tons of fly ash that the ESP
     
    13 normally catches.
     
    14 MR. HARRINGTON: Would you expect the
     
    15 condition of carbon to have any impact on the
     
    16 compliance with particulate and opacity standards
     
    17 on the small ESPS?
     
    18 DR. STAUDT: There is a possibility
     
    19 that it could, but I haven't seen any evidence to
     
    20 see -- to show that it does have an impact. I
     
    21 haven't seen any data. I've seen test results on
     
    22 ESPs as small as a 144 SCA that is 144 and I am
     
    23 not -- I don't believe that the data shows any --
     
    24 any impact.
     
    KEEFE REPORTING COMPANY 195

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: Ms. Bugel?
     
    2 MS. BUGEL: Dr. Staudt, is there --
     
    3 hypothetically speaking, I know your expert
     
    4 opinion is that there shouldn't be an impact.
     
    5 But hypothetically speaking, if there is an
     
    6 impact on particulate matter or opacity, is there
     
    7 a mechanism in the rule to address such an
     
    8 impact?
     
    9 DR. STAUDT: Well, there is a TTBS,
     
    10 okay. If somebody does have a problem getting --
     
    11 if somebody does have a problem due to whether,
     
    12 it's SO3 conditioning or some other reason, some
     
    13 reason they have an emission -- emission problem
     
    14 that -- that may be -- may occur after they start
     
    15 sorbent injection, yes, there is a mechanism that
     
    16 TTBS will provide them what we might call a soft
     
    17 landing.
     
    18 HEARING OFFICER TIPSORD: And for the
     
    19 court reporter you said a couple of times TTBS.
     
    20 MR. HARRINGTON: We have a series of
     
    21 questions on that so I'll postpone any questions
     
    22 on that until we get to those questions.
     
    23 HEARING OFFICER TIPSORD: Thank you.
     
    24 We ready to go to question 54 then?
     
    KEEFE REPORTING COMPANY 196

     
     
     
     
     
    1 DR. STAUDT: 54, "Can you state from
     
    2 your own knowledge or based upon information that
     
    3 you have reviewed what the expected mercury
     
    4 removal will be from facilities with ESPs similar
     
    5 in size to those in Illinois and sulfur tri-oxide
     
    6 conditioning following installation of
     
    7 halogenated activated carbon injection prior to
     
    8 the ESPs?" I believe that most units in -- most
     
    9 units with SO3 conditioning can address their
     
    10 concern through location of the sorbent injection
     
    11 through upstream of the SO3 injection or
     
    12 alternatively by changing to another gas
     
    13 conditioning method. The few that may have
     
    14 difficulty and need more time can use the TTBS.
     
    15 One thing that may be useful is Sid Nelson can
     
    16 talk about the -- he did some tests that -- that
     
    17 -- on units that had SO3 conditioning.
     
    18 MR. NELSON: I have about six or eight
     
    19 questions that deal with this so I thought I'd
     
    20 like to delay it until we can kind of address it
     
    21 more.
     
    22 DR. STAUDT: Okay.
     
    23 HEARING OFFICER TIPSORD: 55.
     
    24 DR. STAUDT: "Can you state what the
     
    KEEFE REPORTING COMPANY 197

     
     
     
     
     
    1 effect of the smaller ESPs common in Illinois
     
    2 facilities would be?" I'm not concerned about
     
    3 the small ESPs except where ESPs may already be
     
    4 very marginal. There are a lot of things besides
     
    5 -- besides collection area that effect the
     
    6 performance of an ESP. I'll go through a few of
     
    7 them. Some of them is hopper depth, the design
     
    8 of the hopper. The gas -- the particulate they
     
    9 drop from the plates, they collect in these
     
    10 hoppers, and I've seen people where they change
     
    11 to a different coal and the hoppers weren't deep
     
    12 enough. There are things like if you are -- if
     
    13 your fields are misaligned, if it's an old unit,
     
    14 there's a good chance fields are misaligned.
     
    15 There are problems where if you haven't
     
    16 refurbished your ESP in a while, you may have
     
    17 cracked insulators and you get poor performance
     
    18 in that reason. And the other thing that happens
     
    19 a lot of these units were built a long time ago
     
    20 before we had really good computation of fluid
     
    21 dynamic and the flows into them can be highly
     
    22 skewed. And, finally, in many cases there's a
     
    23 lot of carbon already going into these ESPs just
     
    24 from the coal already, the coal that doesn't
     
    KEEFE REPORTING COMPANY 198

     
     
     
     
     
    1 burn, so there's a lot of factors besides people
     
    2 focus on collection area, all other things being
     
    3 equal, I'm sure it's better to have more
     
    4 collection area but there are a lot of other
     
    5 factors that play into how an ESP performs.
     
    6 HEARING OFFICER TIPSORD: Question 56.
     
    7 DR. STAUDT: 56, "Is it true that you
     
    8 have no data which to predict mercury removal
     
    9 with halogenated activated carbon, I assume
     
    10 that's what HAC means, injection from smaller
     
    11 ESPs on Illinois coal-fired power plants either
     
    12 with or without sulfur tri-oxide conditioning?"
     
    13 It is true that there is no data that
     
    14 I am aware for injecting sorbent before ESPs with
     
    15 an SCA less than 144, and some units in Illinois
     
    16 are as small as 100 or about 100. I think one of
     
    17 them my understanding might be 99. But lack of
     
    18 data neither proves or disproves anything since
     
    19 there is no data for an ESP as small as the
     
    20 smallest ones in Illinois. There may be a risk,
     
    21 okay, but I think the risk is small and it can be
     
    22 addressed by TTBS. Question 57.
     
    23 HEARING OFFICER TIPSORD: Could you
     
    24 identify yourself?
     
    KEEFE REPORTING COMPANY 199

     
     
     
     
     
    1 MR. WANNINGER: Kent Wanninger,
     
    2 W-A-N-N-I-N-G-E-R. It's not on that list. Kent
     
    3 Wanninger, is that better, Midwest Generation.
     
    4 You mentioned one unit as small as 144 SCA was
     
    5 tested?
     
    6 DR. STAUDT: Yes.
     
    7 MR. WANNINGER: What plant was that?
     
    8 DR. STAUDT: I think it was Yates 1 or
     
    9 Yates 2.
     
    10 MR. WANNINGER: Yates 1. Do you know
     
    11 if they experienced any carbon carryover from the
     
    12 ESP on that test?
     
    13 DR. STAUDT: Well, there are two
     
    14 tests. There -- the Yates 2, which is the one on
     
    15 the scrubber. The Yates 1 they didn't show --
     
    16 there didn't show any, but Yates 2 there was some
     
    17 discussion of the possibility of carbon carry.
     
    18 Now I've examined that report and I think we
     
    19 probably want to enter it as an exhibit. I've
     
    20 examined that data in pretty good detail. There
     
    21 -- they have -- that unit has extremely LOI, I
     
    22 mean, on the order of about 15 percent already,
     
    23 and so lots of carbon is already in that ash.
     
    24 HEARING OFFICER TIPSORD: LOI?
     
    KEEFE REPORTING COMPANY 200

     
     
     
     
     
    1 DR. STAUDT: Loss on ignition.
     
    2 HEARING OFFICER TIPSORD: Thank you.
     
    3 DR. STAUDT: And one thing for sure
     
    4 that unit has -- it was having problems -- it was
     
    5 having problems before that test and it was
     
    6 having -- before that was ever tested it was
     
    7 having problems after that testing. And one
     
    8 thing I will acknowledge, I don't believe that
     
    9 adding carbon will make a lousy, you know, a poor
     
    10 performing ESP necessarily work better. But with
     
    11 Yates they took a marginally ESP, tested it and
     
    12 they found low and behold we still had problems.
     
    13 MR. WANNINGER: Did they experience
     
    14 that on both units?
     
    15 DR. STAUDT: According to the -- the
     
    16 smaller unit, the one that was 144 FCA, the
     
    17 results presented at, I believe, the 2004 mega
     
    18 symposium said they found no evidence of any
     
    19 emissions problems associated with carbon
     
    20 injection. That was the smaller one which I
     
    21 think is the Yates 1. Yates 2, which is the
     
    22 larger the two, has SCA of 175. That's upstream
     
    23 of a -- of a jet bubbling reactor, a scrubber.
     
    24 That one there was some discussion of maybe they
     
    KEEFE REPORTING COMPANY 201

     
     
     
     
     
    1 had some arcing but I've looked at the arcing
     
    2 issue. I looked at the raw data. They had
     
    3 arcing problems before they ever injected any
     
    4 sorbent. There was an issue about -- there was
     
    5 concern about they found that -- they found that
     
    6 during a period of time they did find elevated
     
    7 inerts, what they thought were elevated inerts,
     
    8 in their -- in their jet bubbling reactor.
     
    9 Well, if you look at the data, it
     
    10 shows that there are times when they're injecting
     
    11 it's low and times they're injecting -- they're
     
    12 not injecting it's high. It's basically there's
     
    13 really no consistency to the data. You don't
     
    14 derive -- you don't -- there's no correlation
     
    15 really. If you look at there's also some
     
    16 discussion I know about the Yates. There are
     
    17 people who said that, you know, discussed the
     
    18 arcing. We discussed -- oh, there's emissions
     
    19 and then if you look -- if you plot the data, if
     
    20 you look at the data they show, there's basically
     
    21 no correlation between the increased injection
     
    22 rate. They measure the emissions downstream of
     
    23 the ESP even at very high injection rate,
     
    24 sometimes they're above the baseline, sometimes
     
    KEEFE REPORTING COMPANY 202

     
     
     
     
     
    1 below the baseline and, in fact, they took four
     
    2 data points to establish a baseline, okay. They
     
    3 took 20 data points during the testing. Of the
     
    4 20 they had a range of the baseline -- of that
     
    5 baseline they were six data points above the
     
    6 baseline range, six data points below the
     
    7 baseline range and eight data points within the
     
    8 baseline range and with no -- no correlation, you
     
    9 know, so I look at that and I say, well, that
     
    10 doesn't lead me to any conclusion to sorbent
     
    11 injection. So there's really no correlation
     
    12 there.
     
    13 Basically they have ESP. They got
     
    14 the, you know, they had some problems with it.
     
    15 They tested it and low and behold still had
     
    16 problems. That's my read on Yates.
     
    17 HEARING OFFICER TIPSORD: You said
     
    18 that you have the data on Yates and will provide
     
    19 it?
     
    20 DR. STAUDT: Yeah. I think that's
     
    21 part of the DOE report. I can provide that
     
    22 information.
     
    23 HEARING OFFICER TIPSORD: Thank you.
     
    24 DR. STAUDT: Quarterly DOE report.
     
    KEEFE REPORTING COMPANY 203

     
     
     
     
     
    1 HEARING OFFICER TIPSORD: Thank you.
     
    2 MR. WANNINGER: And that is the
     
    3 smallest SCA unit that you've seen data tested
     
    4 on?
     
    5 DR. STAUDT: That's the smallest I'm
     
    6 aware of.
     
    7 MR. WANNINGER: I know what you're
     
    8 saying. I think you're saying the results were
     
    9 inconclusive?
     
    10 DR. STAUDT: Yeah. I'd say
     
    11 inconclusive except that it showed you're not
     
    12 going to get better performance, you know, your
     
    13 problems aren't going to go away if you have a
     
    14 bad ESP.
     
    15 MR. WANNINGER: Thank you.
     
    16 HEARING OFFICER TIPSORD: Thank you.
     
    17 Are we ready to go to question 57. Thanks.
     
    18 DR. STAUDT: 57, "Based upon your
     
    19 knowledge of the treatment technologies and your
     
    20 familiarity to the extent you are familiar with
     
    21 Illinois coal-fired power plants, could you
     
    22 advise a client in Illinois to rely upon
     
    23 halogenated activated carbon injection prior to
     
    24 ESP as a technology to achieve compliance with
     
    KEEFE REPORTING COMPANY 204

     
     
     
     
     
    1 the proposed Illinois regulation?" I don't have
     
    2 any utility clients in Illinois. I guess I'm
     
    3 probably not enduring myself to them at this
     
    4 point so, but -- but if I did have utility
     
    5 clients in Illinois, what I would advise them
     
    6 would depend upon their circumstances. If
     
    7 injection of halogenated activated carbon
     
    8 upstream of an ESP seems like the least expensive
     
    9 approach to their circumstances, that's what I'd
     
    10 recommend. But there might be -- but I would not
     
    11 tell them not to explore other alternatives but I
     
    12 would if it was -- if I thought the -- it was the
     
    13 least expensive approach for their circumstances,
     
    14 I would recommend it.
     
    15 MR. HARRINGTON: Would you do so in
     
    16 order to comply with this regulation in
     
    17 confidence that it would achieve compliance?
     
    18 DR. STAUDT: Again, that depends upon
     
    19 their circumstances as I -- with the Meredosia
     
    20 units, they would -- they would -- the four small
     
    21 Meredosia units, I would say those guys, they're
     
    22 good candidates for the TTBS, okay, but there are
     
    23 other people who I feel are -- are likely to be
     
    24 based upon the information I have I believe are
     
    KEEFE REPORTING COMPANY 205

     
     
     
     
     
    1 likely to be in very good shape if they use
     
    2 halogenated activated carbon.
     
    3 HEARING OFFICER TIPSORD: Question No.
     
    4 58.
     
    5 DR. STAUDT: 58, "With reference to
     
    6 page 153 of the technical support document, could
     
    7 provide/explain the data and source used for the
     
    8 five year coal use?" The -- the data I think we
     
    9 talked about the coal use data early on. That's
     
    10 where I got the data from the Illinois EPA. "Was
     
    11 the coal used projected to a future date? If so,
     
    12 what was the projected year and what were the
     
    13 assumption used in the projection methodology?"
     
    14 I assume that future use would reflect the
     
    15 average of the three highest of the past five
     
    16 years. So basically I went back to the last five
     
    17 years, took the three highest values, took the
     
    18 average and that's what I projected for future
     
    19 use.
     
    20 HEARING OFFICER TIPSORD: C.
     
    21 DR. STAUDT: C, "Was the data in Table
     
    22 8.5 used to estimate the mercury in coal in Table
     
    23 8.6? If so, our computations yield 170,352
     
    24 ounces. If different data was used, what was the
     
    KEEFE REPORTING COMPANY 206

     
     
     
     
     
    1 heat and mercury content of coal used?" I
     
    2 calculated it using that information but based
     
    3 upon the PPM of milligrams per kilogram and the
     
    4 tons used, so you might get a slightly different
     
    5 number if you calculated using heating value, so,
     
    6 you know, I got about 168,000 the other way. You
     
    7 got about 170,000 and they're relatively close.
     
    8 And the difference in whether you use the data
     
    9 there for the heating value method or using PPM
     
    10 that might explain the difference.
     
    11 HEARING OFFICER TIPSORD: Question No.
     
    12 59.
     
    13 DR. STAUDT: All right. 59, "With
     
    14 reference to page 156 of the technical support
     
    15 document, by unit, what are coal types
     
    16 (bituminous, subbituminous) you're assuming
     
    17 Illinois units will be burning in 2009? By unit,
     
    18 what are the 2009/10 control configuration (SO2
     
    19 NOx and PM controls) you are assuming? What is
     
    20 the level of co-benefits are you assuming for the
     
    21 2009/10 control configurations (in pounds) and
     
    22 the removal efficiencies of these control
     
    23 configurations? D, Are you assuming that all
     
    24 units, except Waukegan 7 and Will County 3, can
     
    KEEFE REPORTING COMPANY 207

     
     
     
     
     
    1 achieve 90 percent Mercury removal through ACI?
     
    2 And, E, In the analysis of CAMR 2010, did you
     
    3 employ the Phase 1 CAMR unit allocations and
     
    4 allow for system-wide trading? Also, are you
     
    5 assuming the most cost-effective method of
     
    6 compliance under CAMR in 2010 is to install
     
    7 control technologies on all but six of Illinois
     
    8 coal unit?" All right. 59A, B, and C all
     
    9 involve data. I'm not sure how you want to do
     
    10 this so I'll leave it up to the Board if you want
     
    11 to go down unit by unit and provide this
     
    12 information or if it's better to produce a table
     
    13 or something like that. It's up to you folks.
     
    14 HEARING OFFICER TIPSORD: It's up to
     
    15 Mr. Harrington.
     
    16 MR. HARRINGTON: I think a table would
     
    17 probably be easiest for everyone in this if
     
    18 that's acceptable.
     
    19 DR. STAUDT: I can produce a table,
     
    20 not this very minute, but I will get it to you.
     
    21 So that's A, B and C. D, "Are you assuming that
     
    22 all units except Waukegan 7 and Will County 3 can
     
    23 achieve 90 percent mercury removal through ACI?"
     
    24 I'm assuming that they all can comply that this
     
    KEEFE REPORTING COMPANY 208

     
     
     
     
     
    1 is -- this is the -- this table is really the way
     
    2 of estimating costs. And my assumption is this
     
    3 is what it will cost and many of them may get the
     
    4 90 percent removal and the -- but they will
     
    5 comply using at those -- at those costs and that
     
    6 may be 90 percent mercury removal through ACI or
     
    7 in other cases there are others that may be using
     
    8 in co-benefit removal. As I mentioned earlier,
     
    9 the only unit -- the units that I do have, I'm
     
    10 not sure if they will able to make 90 percent are
     
    11 the four small Meredosia units which are high
     
    12 sulfur and -- and also assuming if Hutsonville
     
    13 continues to burn high sulfur coal, they may not
     
    14 be able to achieve 90 percent in the manner
     
    15 that's assumed in the TSD.
     
    16 HEARING OFFICER TIPSORD: Excuse me.
     
    17 We have a follow-up.
     
    18 MS. RAHILL: Katie Rahill for Kincaid.
     
    19 When you were coming up with these costs in Table
     
    20 8.7, did you consider TTBS in the cost --
     
    21 DR. STAUDT: Any cost -- any cost
     
    22 associated with the TTBS, is that what you're
     
    23 saying?
     
    24 MS. RAHILL: Well, right. The
     
    KEEFE REPORTING COMPANY 209

     
     
     
     
     
    1 question that you were just responding to was
     
    2 whether or not all the units could comply with 90
     
    3 percent given the cost?
     
    4 DR. STAUDT: It's my, you know, except
     
    5 -- except for the four Meredosia units and the
     
    6 Hutsonville, when I put this together, I was --
     
    7 when I put it together, I was originally
     
    8 expecting Meredosia and Hutsonville to be able to
     
    9 possibly meet 90 percent. Since, of course, and
     
    10 we're going to get into all the discussions I'm
     
    11 sure about revisions to my testimony, so we can
     
    12 go into that later. But it was my expectation
     
    13 that -- that other -- it was my expectation that
     
    14 people would be able to comply in the manner
     
    15 shown. Now whether that was 90 percent or -- or
     
    16 -- or the emissions based the -- output based
     
    17 standard or somebody is getting 89 percent or
     
    18 somebody else has higher -- is over 90 percent
     
    19 and averaging, that was my -- I did assume that.
     
    20 I didn't -- at the time I put the TSD together,
     
    21 there was not a temporary technology based
     
    22 standard so there wasn't any -- I wouldn't factor
     
    23 the cost in anyhow.
     
    24 HEARING OFFICER TIPSORD: And then E
     
    KEEFE REPORTING COMPANY 210

     
     
     
     
     
    1 was the analysis.
     
    2 DR. STAUDT: In the -- Yeah. Okay.
     
    3 No, I did not, although, CAMR allows trading.
     
    4 I'm assuming that the allowances will probably
     
    5 reflect a price close to what it costs to control
     
    6 a PRB unit with halogenated sorbent or higher,
     
    7 and we're going to have more -- we do have more
     
    8 questions on this. My personal view and that of
     
    9 most others including EPA allowances at for --
     
    10 HEARING OFFICER TIPSORD: You have to
     
    11 slow down especially when you're reading.
     
    12 DR. STAUDT: Oh. My personal view of
     
    13 allowances prices, at least initially, and the
     
    14 EPA apparently shares my view will be much more
     
    15 expensive than the cost that I estimate for
     
    16 controlling PRB fired units with halogenated
     
    17 carbon. So as a result I don't -- I don't expect
     
    18 that there's going to be a lot of savings through
     
    19 buying allowances, and we're going to talk about
     
    20 this in the morning so -- 60 -- 68, "With
     
    21 reference to page 157 of the technical support
     
    22 document, What is the basis of your statement
     
    23 ".....it is reasonable to say that the cost of
     
    24 allowances should be somewhat higher than the
     
    KEEFE REPORTING COMPANY 211

     
     
     
     
     
    1 cost and the market for producing allowances."
     
    2 Well, the basis of that statement is
     
    3 that the cost of allowances should be greater
     
    4 than the cost of -- the cost to produce the
     
    5 allowances from the least expensive marginal
     
    6 units to control, otherwise, there would be no
     
    7 incentive to produce the allowances or sell them.
     
    8 According to DOE's information and the
     
    9 information from other sources, units burning
     
    10 western coal are among the least expensive units
     
    11 to reduce mercury from using sorbent injection.
     
    12 Okay. "Are not allowance prices based
     
    13 upon the marginal cost of control, not
     
    14 incremental cost of control as displayed in Table
     
    15 8.19?" Allowance prices are sold at a price that
     
    16 the market will bear. Experience has shown that
     
    17 the market price of allowances tends to be at
     
    18 least as expensive and often more expensive than
     
    19 the typical cost of control. For example, in
     
    20 1999 the OTC NOx allowances started trading at
     
    21 about $3,000 a ton and reached a peak of $7,600 a
     
    22 ton although the cost to produce these reductions
     
    23 were low NOx burners were widely believed to be
     
    24 in the range of a few hundred dollars.
     
    KEEFE REPORTING COMPANY 212

     
     
     
     
     
    1 Similarly, the 2003 Sip, S-I-P, call NOx
     
    2 allowances were $5,000 per ton for several months
     
    3 and peaked at $8,000 per ton, although the cost
     
    4 to create these allowances with SCR was generally
     
    5 viewed to be much less.
     
    6 HEARING OFFICER TIPSORD: Could I make
     
    7 a point of clarification? The question refers to
     
    8 allowances based on -- based upon the marginal
     
    9 cost, not incremental cost as displayed in Table
     
    10 8.19, I believe that's Figure 8.19 on page 159.
     
    11 DR. STAUDT: 61.
     
    12 HEARING OFFICER TIPSORD: Yes. Ms.
     
    13 Bassi?
     
    14 MS. BASSI: If allowances cost more
     
    15 than it would -- than control, why would people
     
    16 pay those prices?
     
    17 DR. STAUDT: Well, it's -- well, it's
     
    18 a good question. First of all, there are people
     
    19 who have a bad -- a misunderstanding of what
     
    20 those prices should be. In other cases people
     
    21 get in a bind and need to buy the allowances and
     
    22 their choice can be, well, we either buy the
     
    23 allowances or we don't run. And so all of a
     
    24 sudden the value of those allowances goes up --
     
    KEEFE REPORTING COMPANY 213

     
     
     
     
     
    1 goes up quickly. There are a lot of reasons why
     
    2 people -- people pay -- spend over the cost, but
     
    3 by and large it's smarter if -- if you're doing
     
    4 your -- if you're calculating what it's going to
     
    5 cost to use a control, it's a good idea to put in
     
    6 controls.
     
    7 HEARING OFFICER TIPSORD: Ms. Bassi?
     
    8 MS. BASSI: What creates the
     
    9 allowances that could be sold?
     
    10 DR. STAUDT: Those -- Basically those
     
    11 are -- what creates the allowances are reduction
     
    12 in emissions and those -- those don't come out of
     
    13 thin air. Someone has to generate those
     
    14 allowances.
     
    15 MS. BASSI: Does that mean then that
     
    16 someone has over control?
     
    17 DR. STAUDT: Well, you have to define
     
    18 what you mean by over control?
     
    19 MS. BASSI: Has someone controlled to
     
    20 a point that they -- that they have been allotted
     
    21 more allowances than they must surrender in order
     
    22 to be in compliance?
     
    23 DR. STAUDT: Well, the allowances --
     
    24 the allowance -- someone who controls to a point
     
    KEEFE REPORTING COMPANY 214

     
     
     
     
     
    1 where they have more -- they have more allowances
     
    2 than they need to use can choose to either,
     
    3 depending upon the particular scenario, they may
     
    4 be able to bank them or they may be able to sell
     
    5 them, but that's where the allowances come from,
     
    6 yes.
     
    7 MS. BASSI: Thank you.
     
    8 HEARING OFFICER TIPSORD: Mr. Zabel?
     
    9 MR. ZABEL: With that said, do you
     
    10 have any training as an economist?
     
    11 DR. STAUDT: Yes. I have a -- hold
     
    12 Charter Financial Analyst designation.
     
    13 MR. ZABEL: It wasn't listed in your
     
    14 estimate. Where did you obtain that?
     
    15 DR. STAUDT: It's administered by the
     
    16 CFA Institute and it's a three year program that
     
    17 many portfolio managers have at places like
     
    18 Fidelity and Goldmans (phonetic).
     
    19 MR. ZABEL: Which gives it
     
    20 investments.
     
    21 DR. STAUDT: Yes, investments and
     
    22 economics.
     
    23 MR. ZABEL: And in answering question
     
    24 6, it appears you were reading from something in
     
    KEEFE REPORTING COMPANY 215

     
     
     
     
     
    1 part; is that correct?
     
    2 DR. STAUDT: Excuse me?
     
    3 MR. ZABEL: It appeared when you were
     
    4 answering Question No. 6 --
     
    5 DR. STAUDT: These are my notes.
     
    6 MR. ZABEL: Okay. Did you have help
     
    7 in preparing those notes?
     
    8 DR. STAUDT: No.
     
    9 MR. ZABEL: Now let me ask you: Is
     
    10 there factors that would go into the cost of an
     
    11 allowance other than the cost of control?
     
    12 DR. STAUDT: The cost -- the price for
     
    13 allowances are base -- Do you want the cost or
     
    14 the price per allowance?
     
    15 MR. ZABEL: Price.
     
    16 DR. STAUDT: The price of allowances
     
    17 are based upon what the market is willing to pay.
     
    18 MR. ZABEL: And what determines that
     
    19 price?
     
    20 DR. STAUDT: What -- what -- what
     
    21 buyers and sellers are willing to agree on.
     
    22 MR. ZABEL: And one of the things that
     
    23 would be whether they could obtain the allowances
     
    24 by putting it in control, would it not?
     
    KEEFE REPORTING COMPANY 216

     
     
     
     
     
    1 DR. STAUDT: That would be a factor.
     
    2 MR. ZABEL: But there's a stickiness
     
    3 to that, is there not, a timing problem?
     
    4 DR. STAUDT: If you could elaborate
     
    5 what you mean by timing problem.
     
    6 MR. ZABEL: If I need the allowances
     
    7 today, it's probably pretty hard to build a
     
    8 scrubber on an SCR today?
     
    9 DR. STAUDT: That's correct.
     
    10 MR. ZABEL: That's a factor that goes
     
    11 into the market for allowances, does it not?
     
    12 DR. STAUDT: Yes, it is.
     
    13 MR. ZABEL: And that price, that
     
    14 availability of allowances are -- gives the
     
    15 source, does it not, the flexibility to decide if
     
    16 or when to build the control?
     
    17 DR. STAUDT: Well, how a company those
     
    18 -- the ability to participate in allowance market
     
    19 does give them some level of flexibility, that's
     
    20 correct.
     
    21 DR. ZABEL: Thank you.
     
    22 HEARING OFFICER TIPSORD: Mr.
     
    23 Harrington?
     
    24 MR. HARRINGTON: Do I understand you'd
     
    KEEFE REPORTING COMPANY 217

     
     
     
     
     
    1 be saying that in the context of the mercury role
     
    2 and CAMR role, that it is less expensive to
     
    3 people who put their controls in and to buy
     
    4 allowances?
     
    5 DR. STAUDT: It's my expectation that
     
    6 allowance prices will be high enough so that
     
    7 utilities in Illinois, many of them will likely
     
    8 install sorbent injection anyhow. I don't think
     
    9 they're going to be -- I don't think they're
     
    10 going to be available at a low cost.
     
    11 MR. HARRINGTON: So obviously the
     
    12 implication of what you said is that under the
     
    13 Federal CAMR rule people will have incentive to
     
    14 put in these controls regardless of whether the
     
    15 Illinois rule is adopted?
     
    16 DR. STAUDT: The -- Essentially you
     
    17 would only be required -- Basically all somebody
     
    18 would do is control up to a certain point under
     
    19 CAMR. They may install these controls. They may
     
    20 or may not use them. They -- they would not use
     
    21 them to the extent -- I don't expect that they
     
    22 would use them to the extent that they will be
     
    23 required under the Illinois rule to get the kind
     
    24 of reductions in mercury emissions that the
     
    KEEFE REPORTING COMPANY 218

     
     
     
     
     
    1 Illinois rule would provide.
     
    2 MR. HARRINGTON: You would expect them
     
    3 to install controls on all or most facilities to
     
    4 some level?
     
    5 DR. STAUDT: Well, let me -- I think
     
    6 that there are many units that would. There are
     
    7 some units that wouldn't. What a company
     
    8 specifically does is up to them. In looking at
     
    9 these cost estimates, I came up with what -- what
     
    10 the cost would be for under a certain cost to
     
    11 comply with the Illinois rule under a certain
     
    12 scenario. Frankly, there are possibilities that
     
    13 might actually cost less to -- cost less than
     
    14 what I predict based upon someone may have more
     
    15 co-benefit removal than I anticipated or someone
     
    16 may, unbeknownst to me, may decide to install a
     
    17 scrubber and then get more co-benefit removal.
     
    18 As far as CAMR is concerned, Illinois
     
    19 -- Illinois units, the PRB units, are uniquely
     
    20 inexpensive to control relative to certain
     
    21 bituminous units with the halogenated sorbent, so
     
    22 that in a sense that's the -- sets the marginal
     
    23 -- that's -- those -- that sets the margin, so
     
    24 you know those are the marginal sources -- the
     
    KEEFE REPORTING COMPANY 219

     
     
     
     
     
    1 marginal sources, the price on the market has to
     
    2 exceed the cost to produce them.
     
    3 HEARING OFFICER TIPSORD: Ms. Bassi?
     
    4 MS. BASSI: Did I understand you to
     
    5 say that the PRB units are uniquely inexpensive
     
    6 to control with ACI?
     
    7 DR. STAUDT: They are inexpensive to
     
    8 control with ACI.
     
    9 MS. BASSI: Okay. And following along
     
    10 with the train of thought, if the cost of control
     
    11 is less than the cost of an allowance or
     
    12 allowances, would there not be an incentive then
     
    13 for Illinois units to control in excess of what's
     
    14 necessary for them to comply with an allotment?
     
    15 DR. STAUDT: Perhaps.
     
    16 MS. BASSI: So that they can sell
     
    17 their allowance?
     
    18 DR. STAUDT: Perhaps they could.
     
    19 MS. BASSI: To those eastern companies
     
    20 that have all that bituminous coal?
     
    21 DR. STAUDT: You know, you're --
     
    22 you're hypothesizing -- you're looking, you know,
     
    23 creating a hypothetical scenario and, you know,
     
    24 all I can say is perhaps but perhaps not.
     
    KEEFE REPORTING COMPANY 220

     
     
     
     
     
    1 Companies are going to make their own decisions.
     
    2 MS. BASSI: Of course.
     
    3 DR. STAUDT: You know, apparently the
     
    4 companies here, they may not -- the opinions
     
    5 expressed here that it's not that inexpensive, I
     
    6 think. They may not agree with me, but it's my
     
    7 opinion that it is inexpensive so they may choose
     
    8 a different path.
     
    9 MS. BASSI: That's true. I was asking
     
    10 if this scenario is a perhaps and I think you
     
    11 said it is?
     
    12 DR. STAUDT: Yes.
     
    13 MS. BASSI: Thank you.
     
    14 CHAIRMAN GIRARD: I have a question,
     
    15 Dr. Staudt, listening to what you're saying,
     
    16 would there then be a financial incentive for the
     
    17 rest of the Illinois power plants that use
     
    18 bituminous coal to make a switch to the PRB
     
    19 subbituminous coal?
     
    20 DR. STAUDT: Well, it's not as simple
     
    21 as that because people also have to comply with
     
    22 the Clean Air Interstate rule and some people may
     
    23 choose to install scrubbers and SCR. And if you
     
    24 do that, then -- the mercury in my opinion, the
     
    KEEFE REPORTING COMPANY 221

     
     
     
     
     
    1 cost of mercury controls are a drop in the bucket
     
    2 compared to NOx and SO2. And I think people --
     
    3 people's decisions on -- on mercury will probably
     
    4 fall out of what they do regarding NOx and SO2
     
    5 because they may decide to put in scrubbers and
     
    6 SCR and then, you know, and if once they do that,
     
    7 they may choose to switch to bituminous coal.
     
    8 There are a lot of factors. People can behave in
     
    9 different ways. And when I made my estimate, you
     
    10 know, not being able to predict all the -- all
     
    11 the things that these, you know, these power
     
    12 plants and power companies have a lot to consider
     
    13 in terms of how they operate their plant.
     
    14 Basically I assume that a certain configuration
     
    15 or the configuration basically wouldn't change,
     
    16 but perhaps they will, perhaps they will add
     
    17 scrubbers to some of these that I didn't
     
    18 anticipate.
     
    19 CHAIRMAN GIRARD: Thank you.
     
    20 HEARING OFFICER TIPSORD: Question --
     
    21 Ms. Bugel?
     
    22 MS. BUGEL: Dr. Staudt, do you know
     
    23 which units in Illinois are burning bituminous
     
    24 coal?
     
    KEEFE REPORTING COMPANY 222

     
     
     
     
     
    1 DR. STAUDT: Well, yes. Yeah, I have
     
    2 an understanding of which ones burn bituminous.
     
    3 MS. BUGEL: And the -- which ones
     
    4 already have control configurations that will
     
    5 bring them close to the 90 percent or even in
     
    6 excess of 90 percent?
     
    7 DR. STAUDT: Well, the one -- the ones
     
    8 listed as co-benefit in -- I guess the table --
     
    9 the Table 8.9 or 8.10. So it's my expectation
     
    10 that Duck Creek, Dallman, Marion -- the two
     
    11 Marion units through co-benefit will be able to
     
    12 get all or, you know, nearly all the way to
     
    13 compliance with the mercury rule.
     
    14 MS. BUGEL: And are there other units
     
    15 which there are already plans in development to
     
    16 add control systems that would also provide
     
    17 co-benefit?
     
    18 DR. STAUDT: Yes. It's my
     
    19 understanding that -- some of the Dynegy units
     
    20 are -- have consent -- my understanding is some
     
    21 of the Dynegy units, Baldwin, Vermilion, and
     
    22 Havana have -- are under consent to create and
     
    23 install fabric filters and possibly, I don't
     
    24 know, perhaps SO2 controls at Baldwin. I'm not
     
    KEEFE REPORTING COMPANY 223

     
     
     
     
     
    1 sure.
     
    2 MS. BUGEL: With those -- because of
     
    3 that and because of Dr. Girard's question, would
     
    4 there be any incentive then to switch to
     
    5 subbituminous coal because it's easier to control
     
    6 mercury?
     
    7 DR. STAUDT: Well, those -- Baldwin
     
    8 already burns subbituminous coal.
     
    9 MS. BUGEL: I wasn't trying to limit
     
    10 my questions to the ones that are burning
     
    11 bituminous coal.
     
    12 DR. STAUDT: I think Vermilion is the
     
    13 only one that's burning bituminous, if I'm not
     
    14 mistaken. Let me check that.
     
    15 MS. BUGEL: But my question was
     
    16 regarding all of the units that you previously
     
    17 listed that burn bituminous coal and also have --
     
    18 DR. STAUDT: The ones that already --
     
    19 the ones that already have co-benefit, you know,
     
    20 with a lot of NOx and SO2 reduction, there would
     
    21 be no incentive for them to go to subbituminous
     
    22 coal.
     
    23 MS. BUGEL: And what are the remaining
     
    24 units that -- that burn bituminous coal don't
     
    KEEFE REPORTING COMPANY 224

     
     
     
     
     
    1 have NOx or SO2 controls that are bringing them
     
    2 close to the 90 percent and would then be -- need
     
    3 to put on ACI or some other control to meet the
     
    4 mercury rule?
     
    5 DR. STAUDT: The question again.
     
    6 MS. BUGEL: When -- We've already
     
    7 listed off a bunch of units that burn bituminous
     
    8 coal and where there would be co-benefits that
     
    9 would bring them close. What are the remaining
     
    10 units that bring bituminous coal that are pretty
     
    11 far off the mark in terms of the 90 percent rule?
     
    12 DR. STAUDT: There are a couple of
     
    13 them, but not -- not a lot. There are, you know,
     
    14 most -- most -- the large majority of capacity in
     
    15 Illinois burns Powder River Basin coal.
     
    16 MS. BUGEL: Okay. Thank you.
     
    17 HEARING OFFICER TIPSORD: Mr. Zabel?
     
    18 MR. ZABEL: Just to be clear, Dr.
     
    19 Staudt, when you said there would be no incentive
     
    20 for the ones currently burning bituminous coal to
     
    21 go to subbituminous coal, I assume you were
     
    22 referring to environmental regulatory incentive,
     
    23 not necessarily coal price?
     
    24 DR. STAUDT: Yeah, based upon -- based
     
    KEEFE REPORTING COMPANY 225

     
     
     
     
     
    1 upon environmental.
     
    2 MR. ZABEL: Just so the record is
     
    3 clear, the price of coal could affect that
     
    4 irrespective of the environmental regulation?
     
    5 DR. STAUDT: Yes. If coal prices drop
     
    6 for PRB, there might be an incentive to switch.
     
    7 HEARING OFFICER TIPSORD: Question 61.
     
    8 DR. STAUDT: 61, "With reference to
     
    9 page 159 of the technical support document, what
     
    10 is the basis for the statement "...the 2018 CAMR
     
    11 limit is roughly equal to the requirements with
     
    12 the proposed rule, incremental cost will be
     
    13 negligible for 2018 compliance." Well, the 2018
     
    14 CAMR limit is equal to about 20 thousand ounces,
     
    15 it's -- which is close to the 10 percent
     
    16 estimated 170,000 ounces in Illinois coal. Of
     
    17 course, that 170,000 ounces doesn't include any
     
    18 allowances for growth or -- or new capacity. So
     
    19 if you provide for new generation and growth,
     
    20 CAMR will actually require over 90 percent
     
    21 removal or alternatively purchase of a similar
     
    22 number of allowances. And again, as I go back, I
     
    23 -- allowances by and large, they don't come for
     
    24 free, and frequently they're not even cheap and
     
    KEEFE REPORTING COMPANY 226

     
     
     
     
     
    1 the -- the units in Illinois, I think, are in a
     
    2 good position to control mercury inexpensively
     
    3 and at a cost that's below what I expect the
     
    4 allowance prices to be at.
     
    5 HEARING OFFICER TIPSORD: Dr. Staudt,
     
    6 I may have misunderstood, and heaven knows it's
     
    7 late I'm misunderstanding a lot anyway, you say
     
    8 the 2018 CAMR limit is how much?
     
    9 DR. STAUDT: About -- It's about
     
    10 20,000 -- the allocation from EPA is about 20,000
     
    11 ounces.
     
    12 HEARING OFFICER TIPSORD: And that's
     
    13 relatively close to the 170?
     
    14 DR. STAUDT: No. It's relatively
     
    15 close to 10 percent --
     
    16 HEARING OFFICER TIPSORD: Okay.
     
    17 DR. STAUDT: -- of the 170,000.
     
    18 HEARING OFFICER TIPSORD: Thank you.
     
    19 DR. STAUDT: Thank you for helping me
     
    20 clarify that.
     
    21 HEARING OFFICER TIPSORD: I didn't
     
    22 think my math was that bad, but it's late.
     
    23 DR. STAUDT: 61(b), Is it not true
     
    24 that both rules are entirely different from the
     
    KEEFE REPORTING COMPANY 227

     
     
     
     
     
    1 points of measurement of emissions to required
     
    2 reduction levels, as well as, CAMR is market
     
    3 based cap -- There's a lot of questions here.
     
    4 The points of measurement of emissions as far as
     
    5 I know the Illinois rule uses -- uses the same
     
    6 CAMR measurement requirement, measurement methods
     
    7 so I don't know about that. As well -- The
     
    8 required reduction levels that would be true.
     
    9 There are different reduction -- the reduction
     
    10 requirements are different than the Illinois
     
    11 rule. CAMR is market based. CAMR is market
     
    12 based. The Illinois rule -- the question says
     
    13 the Illinois rule is commanded and control. I
     
    14 would, you know, I don't know what you mean by
     
    15 command and control, but it's more of a --
     
    16 basically it sets -- it sets emission
     
    17 limitations. It's more of a specific emissions
     
    18 limitation requirement. So I would agree with
     
    19 most of that assuming that you meant by command
     
    20 and control being -- having emissions
     
    21 requirements, specific emissions requirements.
     
    22 But I wouldn't agree with the measurement of
     
    23 emissions because my understanding is that both
     
    24 rules have the same measurement -- be the same
     
    KEEFE REPORTING COMPANY 228

     
     
     
     
     
    1 emission measurement method.
     
    2 HEARING OFFICER TIPSORD: Mr.
     
    3 Harrington?
     
    4 MR. HARRINGTON: What the question was
     
    5 referring to obviously is the 90 percent
     
    6 requirement for measuring mercury in coal to the
     
    7 mercury emitted from power plants, particular
     
    8 measurement for the method for the 90 percent,
     
    9 where CAMR has -- just sets emission limit by
     
    10 plant by allowance?
     
    11 DR. STAUDT: Well, you know, I think
     
    12 maybe if you want to go against the details what
     
    13 the differences are with the rules, maybe
     
    14 somebody from the Agency can speak to the details
     
    15 on how the rules differ.
     
    16 MR. ROMAINE: Your comment is correct,
     
    17 that sources that elect to comply by means of
     
    18 control efficiency or input base limit would also
     
    19 have to determine the uncontrolled emission, the
     
    20 amount of mercury going into a unit. If the
     
    21 source elects to comply with the Alpha-based
     
    22 standard, the monitoring requirements would be
     
    23 identical. CAMR requires similar monitoring of
     
    24 emissions. In that regard CAMR requires
     
    KEEFE REPORTING COMPANY 229

     
     
     
     
     
    1 monitoring of people that both under comply and
     
    2 over comply and certainly addresses the same
     
    3 range of control performance for mercury control
     
    4 measures as is being addressed in the proposed
     
    5 rule.
     
    6 MR. HARRINGTON: I think the overall
     
    7 burden of the question is intended to ask
     
    8 whether, in fact, the two rules are sufficiently
     
    9 different in the comparison you drew on page 159
     
    10 of the technical support document really does not
     
    11 holdup.
     
    12 DR. STAUDT: I assume that's a
     
    13 statement?
     
    14 MR. HARRINGTON: That's a statement.
     
    15 But my point is do you agree with that statement?
     
    16 DR. STAUDT: No, I don't.
     
    17 HEARING OFFICER TIPSORD: Question No.
     
    18 62.
     
    19 DR. STAUDT: 62, With reference to
     
    20 page 195 of the technical support document, A,
     
    21 has Illinois prepared a projection of -- Illinois
     
    22 has prepared a projection of mercury emissions
     
    23 from coal-fired EGUs for CAMR from 2010 to 2020.
     
    24 Could you provide the unit specific data -- has
     
    KEEFE REPORTING COMPANY 230

     
     
     
     
     
    1 Illinois -- excuse me.
     
    2 MR. HARRINGTON: You inverted has
     
    3 Illinois prepared a projection.
     
    4 DR. STAUDT: Oh, has Illinois
     
    5 projected --
     
    6 MR. MATOESIAN: It's a typo?
     
    7 MR. HARRINGTON: It's a typo. "Has
     
    8 Illinois prepared a projection of mercury
     
    9 emissions from coal-fired EGUs for CAMR from 2010
     
    10 to 2020?"
     
    11 DR. STAUDT: Aside from what's in the
     
    12 TSD, I don't know -- I don't know if the Agency
     
    13 has done anything different.
     
    14 HEARING OFFICER TIPSORD: Mr. Ross,
     
    15 can you answer that question? They've pointed
     
    16 their fingers at you.
     
    17 MR. ROSS: Jim Ross. I think we did
     
    18 address this question earlier. It's discussed in
     
    19 Section 10 of the technical support document
     
    20 where, yes, we did project an emissions reduction
     
    21 that occurred as a result of Illinois rule up to
     
    22 2018, and they are in the area, I think, in
     
    23 between 700 and 900 pounds of mercury per year.
     
    24 MR. HARRINGTON: Did you prepare a
     
    KEEFE REPORTING COMPANY 231

     
     
     
     
     
    1 similar projection for CAMR?
     
    2 MR. ROSS: Well, the CAMR has capped.
     
    3 I think the caps are 1.5 something tons per year
     
    4 and, of course, CAMR being a cap-and-trade
     
    5 program -- CAMR being a cap-and-trade program,
     
    6 those reductions aren't guaranteed since you can
     
    7 bank or purchase allowances. So under Illinois
     
    8 programs, the emissions are guaranteed to occur
     
    9 in Illinois and at every power plant under a
     
    10 cap-and-trade program, they are not. This is
     
    11 something we discussed in detail. Hot spots,
     
    12 local impacts.
     
    13 HEARING OFFICER TIPSORD: I would
     
    14 point out, and I apologize for interrupting,
     
    15 there's a Figure 10.1 on page 196 of the TSD that
     
    16 shows the current projected mercury emissions for
     
    17 coal-fired power plants and has CAMR budget draft
     
    18 on that. Ms. Tickner?
     
    19 MS. TICKNER: Just one follow-up. I
     
    20 guess does that include the proposed plans that
     
    21 are already permitted in that schedule?
     
    22 MR. ROSS: If you could clarify the --
     
    23 MS. TICKNER: You're showing mercury
     
    24 emissions out into the future. I'm asking are
     
    KEEFE REPORTING COMPANY 232

     
     
     
     
     
    1 you --
     
    2 MR. ROSS: No. That's only for the
     
    3 existing EGUs in Illinois.
     
    4 MS. TICKNER: Is it your assumption
     
    5 that the caps will still be in place, Illinois
     
    6 will still have a fixed amount of tons of mercury
     
    7 that can be emitted in a year regardless of
     
    8 whether they're trained or not?
     
    9 MR. ROSS: Not under the Illinois
     
    10 rule. In fact, those emissions could increase as
     
    11 generation increases in Illinois.
     
    12 MS. TICKNER: So you think that EPA --
     
    13 USEPA is going to allow the state to emit more
     
    14 than the amounts that have been allocated?
     
    15 MR. ROSS: Absolutely not. And we're
     
    16 discussing that issue with Illinois EPA.
     
    17 However, we believe the difference in emissions
     
    18 is significant in particular up to 2018. If you
     
    19 can refer to the Figure 10.1, you will see the
     
    20 gap in emissions. It's above 3,000 pounds per
     
    21 year all the way up to 2018, where Illinois' rule
     
    22 would take the level of emission down below
     
    23 1,000, so there's a significant margin there.
     
    24 MR. MATOESIAN: I believe you meant we
     
    KEEFE REPORTING COMPANY 233

     
     
     
     
     
    1 are referring to the USEPA?
     
    2 MR. ROSS: Yeah.
     
    3 MS. TICKNER: So I guess your
     
    4 assessment is that any future growth can fit
     
    5 under that cap?
     
    6 MR. ROSS: That's our position, yes,
     
    7 but we are discussing that with EPA but, yeah,
     
    8 the margin there is substantial. And again, that
     
    9 is a cap and those reductions under a
     
    10 cap-and-trade program don't necessarily need to
     
    11 occur. You can bank or purchase allowances and,
     
    12 therefore, not reduce emissions.
     
    13 MR. AYRES: This relates to something
     
    14 --
     
    15 HEARING OFFICER TIPSORD: Excuse me.
     
    16 You need to identify yourself.
     
    17 MR. AYRES: Richard Ayres.
     
    18 HEARING OFFICER TIPSORD: And I remind
     
    19 you your under oath.
     
    20 MR. AYRES: I am indeed. This relates
     
    21 to part of my testimony yesterday of what's shown
     
    22 here, I think, is the cap level in 2018 for CAMR.
     
    23 As you recall, I said EPA itself projected that
     
    24 the national level -- the -- the actual reduction
     
    KEEFE REPORTING COMPANY 234

     
     
     
     
     
    1 by 2020 would be about 50 percent from current
     
    2 levels and that, of course, is because of
     
    3 banking, so I think this -- this chart actually
     
    4 suggests that emissions will be much lower in
     
    5 2018 in Illinois than can reasonably be expected
     
    6 under the CAMR kind of program.
     
    7 HEARING OFFICER TIPSORD: Mr.
     
    8 Harrington?
     
    9 MR. HARRINGTON: I'm just trying to
     
    10 follow-up. Am I correct IEPA did not perform a
     
    11 modeling allocation of the Illinois CAMR cap to
     
    12 the various Illinois facilities?
     
    13 MR. ROSS: Not to my knowledge. We
     
    14 did not perform that exercise, no.
     
    15 MR. HARRINGTON: Thank you.
     
    16 HEARING OFFICER TIPSORD: I think that
     
    17 answers the rest of your answer 62.
     
    18 MR. HARRINGTON: I think it does.
     
    19 HEARING OFFICER TIPSORD: 63.
     
    20 DR. STAUDT: "Please describe your
     
    21 familiarity with techniques for sampling of coal
     
    22 and deriving a statistically reliable sample for
     
    23 daily mercury content in coal-fired boiler?" My
     
    24 expertise is control technology, not measurement
     
    KEEFE REPORTING COMPANY 235

     
     
     
     
     
    1 sampling methods so I really -- I think we've
     
    2 talked about measurement and sampling before, and
     
    3 I think I made that same point.
     
    4 HEARING OFFICER TIPSORD: 64.
     
    5 DR. STAUDT: 64.
     
    6 MR. HARRINGTON: I think that -- I
     
    7 think his answer basically covers up through 68
     
    8 unless somebody else has a follow-up. He's not
     
    9 familiar with that.
     
    10 HEARING OFFICER TIPSORD: Wonderful.
     
    11 68.
     
    12 DR. STAUDT: 68.
     
    13 MR. HARRINGTON: 69.
     
    14 DR. STAUDT: "Earlier I asked about
     
    15 your familiarity with the design, construction
     
    16 and installation of pollution control equipment.
     
    17 Please describe the variables you expect to deal
     
    18 with in installing halogenated powder activated
     
    19 carbon at the Illinois facilities." The
     
    20 variables associated with sorbent injection
     
    21 systems are largely associated with the injection
     
    22 system. Most of the other equipment is skid
     
    23 mounted. The gas flow rate and level of control
     
    24 will determine the feed rate and thus the size of
     
    KEEFE REPORTING COMPANY 236

     
     
     
     
     
    1 the storage silo and the sorbent conveying
     
    2 equipment. With regard to the injection system,
     
    3 it would normally be -- it would be normally --
     
    4 and I would recommend a flow -- computation of
     
    5 flow model to ensure that you have good
     
    6 distribution that would be used to determine the
     
    7 best -- best approach for injection.
     
    8 HEARING OFFICER TIPSORD: 70.
     
    9 DR. STAUDT: "In your estimates of
     
    10 cost, does that include the design and
     
    11 installation of the technology or only purchase?"
     
    12 The estimates are intended to be all
     
    13 inconclusive, but as I mentioned these -- the
     
    14 biggest costs of a sorbent injection system, of
     
    15 running sorbent injection system, is the sorbent.
     
    16 The equipment even -- even -- I know some people
     
    17 will disagree with the estimates that were used,
     
    18 but even if I'm off by a factor of two in the
     
    19 total economics, it doesn't really make a
     
    20 difference. It's really the sorbent that drives
     
    21 the cost.
     
    22 HEARING OFFICER TIPSORD: 71.
     
    23 DR. STAUDT: 71, "Would you be
     
    24 surprised if those numbers were twice what you
     
    KEEFE REPORTING COMPANY 237

     
     
     
     
     
    1 estimated, just for the installation of the
     
    2 sorbent injection system?" Perhaps. If people
     
    3 have done estimates and I haven't -- that I
     
    4 haven't looked at, I'm not going to criticize
     
    5 them. But as I said before, even if you double
     
    6 the cost from what I estimated, the economics
     
    7 doesn't change significantly.
     
    8 MR. HARRINGTON: I think 72 and 73
     
    9 have been answered.
     
    10 DR. STAUDT: 74, "Assuming that the
     
    11 Sorbent Technologies were not sufficient to
     
    12 achieve a 90 percent reduction, would you agree
     
    13 that the TOXECON array of sorbent injection
     
    14 followed by a baghouse is the most logical way to
     
    15 achieve those reductions based upon present
     
    16 knowledge and information? If not, please
     
    17 describe what the alternatives would be, how much
     
    18 they would cost, and how long they would take to
     
    19 install."
     
    20 Okay. First, there is an output base
     
    21 limit that can be used and there's also averaging
     
    22 that can help to a degree. So if you can't
     
    23 achieve 90 percent, there are -- there are other
     
    24 ways to address -- address compliance with the
     
    KEEFE REPORTING COMPANY 238

     
     
     
     
     
    1 emission standards. If -- But to address your
     
    2 hypothetical question, if compliance with the
     
    3 emission requirements is a rule were not possible
     
    4 through injection upstream of an ESP, although I
     
    5 believe it is, TOXECON is one option.
     
    6 Other options include methods to
     
    7 enhance co-benefit removal and reduce the amount
     
    8 of mercury reduction that is necessary from the
     
    9 sorbents. These things there are -- I'm going to
     
    10 list a couple of things that may or may not be,
     
    11 you know, applicable at any particular site but
     
    12 there are things like coal blending, switching
     
    13 combustion controls. People have found that
     
    14 actually stage combustion actually helps.
     
    15 Another is the use of chemical additives that
     
    16 have been shown to further improve the
     
    17 performance of sorbent such as those used in
     
    18 Alstom's mercury technology. In the -- that --
     
    19 that Exhibit 52, on the last page of Exhibit 52
     
    20 there is a -- there is a chart -- there is -- is
     
    21 a chart that shows the kind of -- the kind of
     
    22 improved removals that they have been able to
     
    23 achieve using the mercury, and they have
     
    24 different types of chemicals called MercClean
     
    KEEFE REPORTING COMPANY 239

     
     
     
     
     
    1 (phonetic) 4, 5, 6. These are all proprietary
     
    2 approaches, and you can see they can get even
     
    3 better removal efficiency and the cost will vary
     
    4 by facility but will be far less than the cost of
     
    5 a TOXECON, although somebody might eventually
     
    6 choose a TOXECON.
     
    7 You know, another is Min Plus, which
     
    8 is technology that showed high removals at a
     
    9 Richmond, Indiana, power plant. The injection
     
    10 system cost is about $35 a kilowatt because it
     
    11 also includes a below NOx combustion retrofit.
     
    12 So I understand sorbent cost for Min Plus is on
     
    13 the same range of the carbon sorbent and that the
     
    14 ROFA, R-O-F-A, system, it comes with a Min Plus
     
    15 injection also reduces NOx.
     
    16 In addition, I understand that other
     
    17 companies are developing and testing mineral
     
    18 based sorbents and they're testing them even here
     
    19 in Illinois that may offer advantages to
     
    20 halogenated carbon sorbents. So the bottom line
     
    21 is there are many approaches that might be used
     
    22 to achieve 90 percent or the output based limit
     
    23 without halogenated carbon or in addition to
     
    24 halogenated carbon that are not costly as TOXECON
     
    KEEFE REPORTING COMPANY 240

     
     
     
     
     
    1 so --
     
    2 HEARING OFFICER TIPSORD: Follow-up.
     
    3 MR. HARRINGTON: Can I have a moment,
     
    4 please?
     
    5 HEARING OFFICER TIPSORD: Sure. While
     
    6 Mr. Harrington is taking that moment, I want to
     
    7 note for the record that we have reserved
     
    8 questions to Ameren, the general questions 41,
     
    9 42, and 43, and indicated that Mr. Porter would
     
    10 be answering those questions. I talked to Mr.
     
    11 Kim at a break, and I think it's probably more
     
    12 appropriate for Dr. Staudt and Mr. Ross to
     
    13 address. I don't want them to get lost in the
     
    14 record. They will be answered, but we felt that
     
    15 they be more directed to the IEPA than the
     
    16 technology. Mr. Harrington, did you have any
     
    17 follow-up on question 75?
     
    18 MR. HARRINGTON: No.
     
    19 HEARING OFFICER TIPSORD: You may
     
    20 certainly go back, but the hour of seven o'clock
     
    21 has arrived and I thank you all for your
     
    22 patience. I thank you all, even though there are
     
    23 donuts left, we're going home tonight. I'll see
     
    24 you all tomorrow at 9 a.m.
     
    KEEFE REPORTING COMPANY 241

     
     
     
     
     
    1 (Hearing recessed at 7 p.m.)
     
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    KEEFE REPORTING COMPANY 242

     
     
     
     
     
    STATE OF ILLINOIS
     
    COUNTY OF FAYETTE
     
     
     
    C E R T I F I C A T E
     
     
     
    I, BEVERLY S. HOPKINS, a Notary Public
     
    in and for the County of Fayette, State of
     
    Illinois, DO HEREBY CERTIFY that the foregoing
     
    242 pages comprise a true, complete and correct
     
    transcript of the proceedings held on June 21st,
     
    2006, at the Illinois Pollution Control Board,
     
    1021 North Grand Avenue East, Springfield,
     
    Illinois, in proceedings held before Hearing
     
    Officer Marie E. Tipsord, and recorded in machine
     
    shorthand by me.
     
    IN WITNESS WHEREOF I have hereunto set
     
    my hand and affixed by Notarial Seal this 25th
     
    day of June, 2006.
     
     
     
    _____________________________
    Beverly S. Hopkins, CSR, RPR
    Notary Public, Fayette County
    CSR License No. 084-004316
     
     
     
     
     
     
    KEEFE REPORTING COMPANY 243

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