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
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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
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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.
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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
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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
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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?
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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
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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
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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.
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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
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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 --
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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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
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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
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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
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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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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.
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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
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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
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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 --
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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
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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
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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.
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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
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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
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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 --
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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 --
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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?
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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,
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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
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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.
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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.)
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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.
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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
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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
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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
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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
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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?
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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
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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
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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.
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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
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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
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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
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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
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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
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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.
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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.
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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?
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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
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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.
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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
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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,
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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
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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 --
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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
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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
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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
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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.
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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?
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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
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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
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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.
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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.
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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
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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
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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
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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?
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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
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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.
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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?
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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
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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
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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?
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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?
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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 --
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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
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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
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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?
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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
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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
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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
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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.
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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
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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?
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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