1
ILLINOIS POLLUTION CONTROL BOARD
2
3
4
5
6
7
8
TRANSCRIPT OF PROCEEDINGS held
9
in the above-entitled cause before Hearing
10
Officer Marie E . Tipsord, called by the
11
Illinois Pollution Control Board, pursuant
12
to notice, taken before Cheryl L .
13
Sandecki, CSR, RPR, a notary public within
14
and for the County of Lake and State of
15
Illinois, at the James R . Thompson Center,
16
100 West Randolph, Assembly Hall, Chicago,
17
Illinois, on the 16th day of August, A.D.,
18
2006, commencing at 1 :30 p .m .
19
20
21
22
23
24
Page 661
August 16th, 2006
IN THE MATTER OF :
)
)
PROPOSED NEW 35 ILL
. ADM .
) R06-25
CODE 225 CONTROL OF EMISSIONS
)
(Rulemaking-Air)
)
FROM LARGE COMBUSTION SOURCES
)
(MERCURY),
)
Page 662
1
A P P E A R A N C E S :
2
SCHIFF, HARDIN, LLP,
3 6600 Sears
Chicago,
Tower
Illinois 60606
4
(312)
BY :
258-5646
MS . KATHLEEN C
. BASSI
5
MR .
MR .
STEPHEN J .
SHELDON A .
BONEBRAKE
ZABEL
6
Appeared on behalf of the Dynegy
7
and Midwest Generation ;
8
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
9
1021 North Grand Avenue East
P .O . Box 19276
10
Springfield, Illinois
62794-9276
(217) 782-5544
11 BY : MR . JOHN J
. KIM
MR . CHARLES E . MATOESIAN
12
- AND -
13
AYRES LAW GROUP
14
1615 L Street, N .W .
Suite 1350
15
Washington, DC 20036
(202) 452-9200
16 BY
: MR . RICHARD E
. AYRES
17
Appeared on behalf of the IEPA
;
18
19
20
21
22
23
24
Page 663
1
A P P E A R A N C E S : (Continued)
2
ENVIRONMENTAL LAW PROGRAM,
3
CHICAGO LEGAL CLINIC
205 West Monroe Street
4 Fourth Floor
Chicago, Illinois 60606
5
(312) 726-2938
BY : MR . KEITH I . HARLEY
6
7 SORBENT TECHNOLOGIES CORPORATION
1664 East Highland Road
8 Twinsburg, Ohio 44087
(330) 425-2354
9 BY : MR . SID NELSON JR .
10
McGUIRE, WOODS
11
77 West Wacker Drive
Suite 4100
12 Chicago, Illinois 60601-1815
(312) 849-8100
13
BY : MR . JEREMY R . HOJNICKI
14
15
ILLINOIS POLLUTION CONTROL BOARD
:
16
Ms .
Marie Tipsord, Hearing Officer
17 Ms .
Mr .
Andrea S
. Moore, Board Member
G
. Tanner Girard, Acting Chairman
18
Mr . Anand Rao, Senior Environmental
Scientist
19 Mr .
Mr .
Nicholas J
. Melas, Board Member
Thomas Fox, Board Member
20 Mr .
Thomas Johnson, Board Member
21
22
23
24
1
HEARING OFFICER TIPSORD : Let's go
2
ahead and go back on the record
. I
3
believe we are at question 40 unless --
we
4 were going to give you guys the break at
5
lunch to look at the table . Do you have
6
any questions on Exhibit 85, is it?
7
MR
. AYERS : I think we will get to
8
it .
9
HEARING OFFICER TIPSORD
: You will
10 get to it later on in the context of the
11
questions .
12
Okay . Then we will go to question
13
40 .
14
MR . CICHANOWICZ
: Question 40, is it
15 your opinion that an air pollution control
16 technology should not be deployed until
17
such a point that the utility industry
18
determines that there is sufficiently
19
little risk of there being problems with
20
the technology?
21
Environmental controls should be
22
deployed with the risks and uncertainties
23
are commensurate with other factors that
24
determine utility station reliability
. My
Page 664
1 understanding
of utility plant equipment
2
evolution is that devices such as burners,
3
pulverizers, feedwater heaters, condensers
4 and other equipment that are
5
first-of-a-kind designs require one year
6
of commercial operation prior to being
7
designated as a commercial development
.
8
In the same manner, I believe one
9 year of continuous operation with sorbent
10
injection and other controls should be a
11
prerequisite before broad application .
12
Question 41 --
13
HEARING OFFICER TIPSORD : Mr . Ayers
14
has some follow-up
.
15
MR . AYERS : In light of your answer,
16
Mr . Cichanowicz, that there should be a
17
year -- you testified there should be
18 demonstrations of a year for every
19
application, what would motivate power
20
plants to do those kinds of long-term
21 testing? Why would they want to certify a
22
technology that is only then likely to be
23
imposed upon them with the cost of money?
24
MR . CICHANOWICZ : Well, I feel this
Page 665
1
is ground we have gone over before
. It is
2
to respond to a regulation .
3
MR . AYERS
: I think it is a little
4
different
. You are talking about they are
5
doing a lot of work ahead of time, a lot
6
of testing and a lot of trying out the new
7
technology before we move to regulation
.
S
And I have said, it is true, we have asked
9 questions about what drives innovation
10
before . I think it is a slightly
11
different question
.
12
If you are a utility and you think
13
that the rule is that a one-year
14
demonstration is the minimum, why would
15
you do that?
16
MR . CICHANOWICZ
: Why would you do
17
what?
18
MR . AYERS
: Why would you run a
19 one-year demonstration if you knew that
20
the regulatory agency wouldn't act without
21 a one-year demonstration? Why would you
22
put yourself in that position? Why would
23 you invest money in developing the
24
technology?
Page 666
1
MR . CICHANOWICZ
: I'm
sorry,
2
Mr . Ayers, I don't see why this is any
3
different than what we have talked before .
4
I am happy to go over it again with you .
5
But the question was are -- the
6
question was directed to the risks . And
7
there are certain levels of risks of new
8
technologies, regardless of whether they
9
are for environmental control or
10 performance improvement .
11
And all I am saying is that
12
conventional industry practice from most
13
of the boiler manufacturers I spoke to
14
says they want about a year under their
15 belt before they offer something
16
commercially . All I am saying is not
17 every mercury technology, but certainly
18
some of the ones we are talking about,
19 would benefit from one year of operation
20
so you actually learn performance
21
capabilities .
22
MR . AYERS : Let me rephrase it . Do
23 you think that mercury regulation like the
24 one that is under consideration by the
Page 667
1
board
should be held hostage to one-year
2
demonstrations?
3
MR . ZABEL
: I think that's your
4
characterization, not his, Mr
. Ayers .
5
MR . AYERS : That's my
6
characterization
.
7
MR . CICHANOWICZ : I think the
8
regulation should be dependent upon
9
reliable, informed data
. And today,
10 despite the very impressive work that has
11
been done, except for the Gaston
12
application, which ran for, we spoke about
13
it yesterday, 12 months, all of the data
14
that's available is parametric data,
15
short-term data of hours or these 30-day
16
tests, which are a very important percent
.
17
So that's all the data that is available
.
18
And I think that's --
I think that's
19
--
it's difficult to design a regulation
20
in my opinion based on that data because
21
we still haven't had a chance for the
22
impacts to play out .
23
MR
. AYERS
: What role, if any, do
24 you think that public health concerns
Page 668
Page 669
1 should play in this kind of decision of
2
when to deploy a new technology?
3
MR . CICHANOWICZ
: Well, you know
4
that's completely outside of my still set,
5 Mr . Ayers .
6
MR . AYERS
: Well, you have said that
7
you think it should await long
8
demonstrations until those in the power
9
industry are comfortable with the
10 technology
. I am raising the point if
11
there are other considerations there
.
I
12 want to ask about that
.
13
MR . CICHANOWICZ : Are you asking?
14 Do you want me to answer?
15
MR . AYERS
: Please do answer .
16
MR
. CICHANOWICZ : I am sorry, I am
17
having a hard time hearing the end of your
18
sentence .
19
MR . AYERS
: If you would like to
20
answer about the role you see for public
21
health considerations, please do
.
22
MR . CICHANOWICZ
: I don't have an
23
opinion .
24
HEARING OFFICER TIPSORD : Okay .
1
Mr . Harley, you had a question?
2
MR . HARLEY
: In follow-up to your
3
response about the need for a period of
4
time for technologies to be fully
5
developed before implementation, you are
6
familiar with the provisions of the
7 proposed rule which indicate that the
8
compliance date is more than a year away,
9
aren't you?
10
MR . CICHANOWICZ
: Yes .
11
MR
. HARLEY : The compliance date, in
12
fact, is three years away, if the rule
13
were finalized according to the schedule
14
that the agency is proposing?
15
MR
. CICHANOWICZ : Yes .
16
MR . HARLEY
: And during that
17
three-year period of time, there would be
18
36 months of opportunity for utility
19
companies --
effected utility companies to
20
perfect the technology to the best they
21
could to employ an output standard, a
22
90 percent standard, to take advantage of
23
the opportunity to average units, to opt
24
into the TTBS
. And if it is a feature of
Page 670
1
the final rule, to take advantage of the
Page 671
2 multi-pollutant strategy
.
3
MR . CICHANOWICZ : Is that a
4
question?
5
MR . HARLEY : It was a question .
All
6
of those things could take place within
7 that three-year period of time?
8
MR . CICHANOWICZ
: Well, that
9 presumes -- I guess that presumes success,
10 doesn't it?
11
MR . HARLEY : It presumes that there
12
is a much longer period of time that you
13 are imposing as an impediment of this rule
14 being finalized .
15
MR . ZABEL : That is a
16 mischaracterization .
17
MR . HARLEY : There is more than one
18 year . There is three years .
19
HEARING OFFICER TIPSORD : Thank you .
20 Mr . Nelson?
21
MR . NELSON : Sid Nelson . Are you
22 aware of any utilities other than the
23 TOXECON at Gaston that have done an ESP
24 standard sorbent injection demonstration
1
for a year period yet?
2
MR . CICHANOWICZ : No .
3
MR . NELSON : Are you aware of any
4 that have volunteered or have plans for a
5 year demonstration of the standard ESP
6
duct injection mercury control?
7
MR . CICHANOWICZ : No .
8
MR . NELSON : If the utility industry
9 has had a couple years seeing these
10 mercury regulations perhaps coming and if
11
it is so critical to have this year, in
12 addition to the experience with unburned
13
carbon, don't you think that it would
14 behoove them in their own best interests
15
if it is so critical to have voluntarily
16
done one of these right now or at least
17
offer to do them in the future?
18
MR . CICHANOWICZ : Perhaps . It's a
19
general question .
20
MR . NELSON : Would it be more
21
consistent to think that all these 30-day
22
tests, okay, are sufficient -- let me
23
rephrase the question .
24
If, in fact, all these 30-day tests
Page 672
1
are
sufficient to demonstrate this, would
2
that be more consistent with the
3
observation that a whole year doesn't
4
really have much value or would that be
5
less consistent with the view that a whole
6
year is so critical?
7
MR . CICHANOWICZ
: Well, the one year
8
--
the reason why that time period is
9
important is because, remember, coal has a
10
lot of trace elements in it
. And the
11
concentration is quite loaf
. And it just
12
takes time for a lot of these trace
13
elements to accumulate to a certain level
14
within a certain site
.
15
You are tired of hearing about
16
hot-side ESPs . But it took a year for the
17
sodium to deplete in the layer adjacent to
18
the emitting electrode
. With scrubbers,
19
the high chloride content of the sorbents
20
takes a year
. It takes long periods of
21
time to accumulate
. And again in the late
22
'70s burning of high chloride coals, it
23
took awhile to understand the corrosion
24
problems because it requires time for
Page 673
1
those
things to accumulate
.
2
That's the purpose
of the
time
3
constant . So
I don't see how adding
4
together consecutive 30-day demonstrations
5
addresses that issue
.
6
MR . NELSON
: Do the hot-side ESPs
7
today meet the particular requirements
8
that they are required to meet?
9
MR . CICHANOWICZ
: A lot of hot-side
10
ESPs have been replaced and converted to
11
cold-side
. Some, at least Gaston, is
12
augmented with a fabric filter
. Some have
13
been augmented with the cold-side
. Others
14
--
and I don't know the fraction, if they
15
are still operating
use, essentially --
16
I understand they come down and basically
17
water wash the electrodes at three-point
18
intervals to remove the layer of ash
19
that's adhered to the emitting electrode
.
20
That's the problem .
21
So they work, but they are far from
22
ideal
. And everybody I know has not
23
walked, run from them
. That's why
24
Pleasant Prairie is what it is today
.
Page 674
1
Because the designers -- the design for
2
that was initially a hot-side unit . And
3
when all these problems came up, the low
4 NOx burner and the owners decided to go to
5
the cold-side . That is why the duct work
6
is so convoluted .
7
MR . NELSON : But today, in fact,
8
about ten percent of the ESPs in the power
9
industry are hot-sided, right?
10
MR . CICHANOWICZ : That is correct .
11 And they absorb operating maintenance
12
issues that they would prefer not to .
13
MR
. NELSON
: Last question, given
14
all the 30-day test runs that have been
15 done already and all the ones that are
16
planned for the next two years as well, on
17
all the different configurations and all
18
the different coal types, would it be fair
19
to say with respect to major air pollution
20 control for utilities that this is by far
21 the most pretested technology compared to
22 SCR or SNCR or low NOx burners, compared
23
to the major hot-side ESPs, that this is
24 by far the most pretested technology that
Page 675
1
this country has ever seen?
2
MR . CICHANOWICZ : Well, as I said
3
earlier, six or seven conferences a year,
4
you can be a pro going to all of them
. So
5
there is a lot of data and there is a lot
6
of work, yes .
7
HEARING OFFICER TIPSORD : Okay .
8
Mr . Harley had his hand up
.
9
MR . HARLEY : Just very quickly, are
10
you familiar with the provisions of the
11
Illinois Environmental Protection Act,
12
Illinois Administrative Code that allow
13
any person to seek to amend, remove or
14
propose a rule before the Illinois
15
Pollution Control Board?
16
MR . CICHANOWICZ : No, Mr . Harley, I
17
am not .
18
MR . HARLEY : So you are not familiar
19 with the process that could take place any
20
time within the three years before these
21
rules become effective that any party
22
could appear before this Board and present
23
evidence to this Board that, in fact, the
24
rule that had been finalized was not
Page 676
1
justified?
2
MR . ZABEL : I think he answered that
3
question with the prior one .
4
MR . HARLEY : Thank you .
5
HEARING OFFICER TIPSORD : Mr . Ayers?
6
MR . AYERS : Just a couple questions .
7
I want to try to sum up on your question
8
of the one-year demonstration, if I may .
9
MR . CICHANOWICZ : Please .
10
MR . AYERS : Is it correct then to
11
say that your feeling is that the industry
12
-- you yourself and probably the industry
13 would be much more comfortable with
14 meeting a mercury regulation like the one
15 under consideration here if you had some
16
test -- and I won't specify how many --
17 that had been run for a year or more?
18
MR . CICHANOWICZ : Yes . If those
19
tests addressed the issues of concern for
20
the state or rule, yes .
21
MR . AYERS : Granted . But is it also
22
fair to say when the Board -- when the
23
Board considers this proposal, it needs to
24
consider factors or it may consider
Page 677
1
factors that go beyond those of whether
2
the utility industry is comfortable with
3
the technology because of its
4
responsibility for public benefit?
5
MR . ZABEL : I believe that's a
6
question that goes to the Act and he
7
already stated he isn't familiar with it .
8
But you can go ahead and answer it,
9
if you can .
10
MR . CICHANOWICZ : I understand that
11
the needs of the power industry aren't the
12
only issues that will be addressed .
13
HEARING OFFICER TIPSORD : Question
14
No . 41 .
15
MR . CICHANOWICZ : In section 3 .3 of
16 your testimony, you mentioned that the
17
Franken plant in Germany installed in 1987
18
to '89 was the first to achieve 90 percent
19
reduction
. Okay . That's a statement, not
20
a question . Question A, were not the
21
German plants subject to a specific
22
emission limit that could be complied with
23
through SCR with lower than 90 percent
24
removal in most cases?
Page 678
1
The German plants were required to
2
reduce NOx to the equivalent of
3
approximately 100 ppm without the ability
4
to average emissions over several units at
5
one station . The Franken plant is a
6
wet-bottom boiler that generated
7
significant NOx of over 1,000 ppm and thus
8
required in excess of 90 percent NOx
9
reduction to achieve the 100 ppm limit .
10
Question B, what motivation would a
11 plant have to operate a higher removal
12
rate which would incur more ammonia cost
13
and risk higher ammonia slip?
14
Given the fixed unit specific limit
15 of 100 ppm the higher NOx removal compared
16
to an average of 83 percent was not an
17
option for the owner but a requirement to
18
comply .
19
C, since there is not a citation
20
here, what is your source for this
21
information on German plants?
22
This information is based on a
23
personal visit and discussion with the
24 operators at Franken in Germany and
Page 679
1
accompanied by representatives of the
Page 680
2 catalyst supplier, which was Siemens,
in
3 June of 1998 and follow-up meetings in
4
2001 and 2002 .
5
42, in the second paragraph on
6 page 21 of your testimony, you describe a
7 plant that had an S03 plume
. Which plant
8 are
you referring to?
9
American Electric Power's Gavin
10 Station .
11
HEARING OFFICER TIPSORD : Mr . Ayers?
12
MR . AYERS
: Was this plant not
13 equipped with a wet FGD system downstream
14
of the SCR?
15
MR . CICHANOWICZ : A wet FGD system?
16
MR . AYERS
: Downstream of the SCR?
17
MR . CICHANOWICZ : Yes, it was .
18
MR . AYERS
: Does a wet scrubber play
19 a role in S03 plumes?
20
MR . CICHANOWICZ : A wet scrubber can
21
play a role in S03 plumes, yes .
22
MR . AYERS : In your opinion was the
23 SCR supplier at fault for the plume?
24
MR
. CICHANOWICZ : In my opinion the
1
catalyst that was
installed at Gavin had
2
too high of an S02 to S03 conversion rate
.
3
And I don't know if it was the catalyst
4
supplier, the process supplier or anybody
5
else, but the specification for 502, S03
6 had not been properly considered in that
7
design
.
8
MR . AYERS
: This is a kind of
9
situation which occurs and you have
10 referred to this kind of problem in your
11
testimony . In your view who was in the
12
best position to foresee and prevent this
13
kind of problem from arising?
14
MR . CICHANOWICZ : Who was in the
15
best position foreseeing to prevent that?
16
MR . AYERS : Yes .
17
MR . CICHANOWICZ : People writing the
18
specification or preparing the design
.
19
MR . AYERS : And those were?
20
MR . CICHANOWICZ
: I don't know . It
21 might have been AEP . It could have been
22
the supplier . I was not -- I was not
23
involved in that particular project, so I
24
don't know
.
Page 681
1
MR . AYERS : Wouldn't the supplier
2
write the specification
-- I'm sorry .
3
Wouldn't
the buyer, who is American
4
Electric Power, been the one to
5
essentially specify what the unit should
6
look like and what it should do?
7
MR . CICHANOWICZ
: That's true . But,
8
you know, a lot of times the suppliers
9
come to the utilities and say fear not,
10
you don't need your expertise, you have
11
us
. A lot of the suppliers offer the
12
option that all they have to do is be
13
hired and there will be a no-risk
14
solution .
15
And again I am not privy to the
16
conversations that went on between them
.
17
But all I can say is that the catalyst
18
that was consulting in that process, the
19
buyer of S02, S03 conversion was
20
appropriate .
21
MR . AYERS
: Well, AEP didn't want to
22
create an S03 problem . So were they not
23
in position to prevent that by the way
24
they described the work they wanted done?
Page 682
1
MR . ZABEL :
I think he testified and
2
answered that question . He doesn't know
.
3
MR . AYERS : I'm not sure what the
4
answer was, if there was an answer .
5
HEARING OFFICER TIPSORD : I was
6
going to say could you -- I agree, I am
7
not sure I followed what the answer was
8
either .
9
MR
. CICHANOWICZ : But my point is
10
that I don't know who wrote the
11
specification
. And with evolving
12
technology, a lot of times basically the
13
supplier is in a stronger position than
14
when the owners write the specification .
15
For example, if I was writing the
16
specification for ACI, I would have put in
17
provisions to make sure it didn't trip and
18
create excess particulate matter through
19
the breakthrough in the sorbent . But
20
every supplier, as you probably heard so
21
far, would take responsibility for it, but
22
it doesn't always work out that way .
23
MR
. AYERS : I bring it up because
24 your testimony seems to suggest that the
Page 683
1
difficulties of this
sort, that happen in
2
the development of technologies, should
3
shape the public policies that are
4
adopted
. And I want to put that as a
5
question .
6
Do you think that taking Gavin, as
7
an example, that the law should have made
8
allowances for those failures or should it
9
insist on compliance and place the burden
10 on the company to make sure that failures
11
like that don't occur?
12
MR . CICHANOWICZ : Well, is the
13 burden on the company or is it on the
14
supplier, I'm not sure
. Again, I wasn't
15
privy to all those that went out -- to
16
those specifications that went out .
17
HEARING OFFICER TIPSORD : If I may,
18
Mr . Ayers, I think the question is whether
19 or not whoever was responsible for the
20
problem --
21
MR . CICHANOWICZ : Yes .
22
HEARING OFFICER TIPSORD : -- that
23
ultimately the company is the one who has
24
to pay the fine, at least in Illinois .
Page 684
1
MR . CICHANOWICZ :
Okay .
2
HEARING OFFICER TIPSORD : But I
3
think the question is is it your position
4
-- is it your testimony that the law
5
should be written to make allowances for
6
those types of failures?
7
MR . AYERS : Yes .
8
MR . CICHANOWICZ : I think with an
9
evolving technology, there has to be the
10
flexibility to accommodate that there is
11
going to be these kind of events . And
12
there needs to be some flexibility built
13
in .
14
MR . AYERS : Will you acknowledge
15 then the incentives change when you do
16
that, the incentives if the compliance is
17
required are to take whatever steps are
18
needed? And if the law makes allowances,
19 then the incentives to do that become much
20
less, isn't that correct?
21
MR . CICHANOWICZ : That is true, the
22
incentives become less .
23
MR . AYERS : Could we talk some more
24
about your discussion of FGD systems? Can
Page 685
1
you
tell me
what an FGD system costs for a
2
power plant of 500 megawatts, let's say,
3
in rough terms?
4
MR . CICHANOWICZ : This is a new
5
plant or a retrofit?
6
MR
. AYERS
: Both, if you can do
that .
8
MR . CICHANOWICZ : Well, I think new
9 plants, when you start with the green
10
fields with nothing there but dirt, is
11 probably, you know, a couple hundred
12
dollars kilowatt in today's market . I
13
think when you look at the retrofit costs
14 may go up considerably from that to three
15
to $400 a kilowatt . And that is just
16 based on press releases that you can pull
17
up off the Internet .
18
MR
. AYERS : What would that
19
translate to in terms of dollars for a 500
20 megawatt plant?
21
MR . CICHANOWICZ : Well, it is about
22
a hundred million if it is $200 a
23
kilowatt, right .
24
MR . AYERS : And twice that for
Page 686
1
retrofit?
2
MR . CICHANOWICZ
: Yes .
3
MR .
AYERS : How long does
it take to
4
build an FGD system?
5
MR . CICHANOWICZ
: Well, first of
6
all, I want to acknowledge this, the
7
construction and time lines are a little
8
out of my skill set . I will be happy to
9
answer these, as best I can
. But there
10
are people that know a lot more about this
11
than me that are scheduled to testify
.
12 And I would --
any conflict in testimony I
13
would defer to them
.
14
MR . AYERS
: All I would like is a
15
rough formed estimate .
16
MR . CICHANOWICZ
: I believe it is --
17
the question like everything else, what's
18
the scope, where do you begin
. I think
19
the number of 18 or 20 or 22-months is
20
about right
. But I hear owners say that's
21
unrealistic because it is going to take
22
12 months to get the permit .
23
So if you were to exclude the issues
24
of permitting, I think 18, 20, 22 months
Page 687
1 is
probably about the number that you are
2
seeing . And it depends
. If it is a
3
custom design, it is probably closer to
4
24
. If it is like what Duke Power has
5
done and essential design modules that fit
6
into all of their plants, it is going to
7
be less
. It is less engineering and they
8
can set it up easily .
9
MR . AYERS
: Two to three years might
10
be a pretty good estimate as a rule of
11
thumb?
12
MR
. CICHANOWICZ : Yes .
13
MR . AYERS
: And would you also agree
14
that the scrubber process chemistry is
15
very complicated? If I remember, I
16 believe in the days when people described
17 putting a scrubber on a power plant as
18
adding a chemical factory to a generating
19
plant .
20
MR . CICHANOWICZ
: Well, I described
21
earlier my first years at EPRI, I didn't
22
work in the FGD processor, but my
23
colleagues did, and there were six or
24
seven of them that for five years did
Page 688
1 nothing but try to unravel the intricacies
2
of the chemistry
.
3
MR . AYERS : So considering the cost
4
and complexity of the new FGD system, the
5
time it takes to build it, if somebody had
6 a new FGD design, a new and improved FGD
7
design, wouldn't it take several years and
8
an awful lot of money to demonstrate that?
9
MR . CICHANOWICZ
: Well, not
10
necessarily
. There is actually -- I guess
11
it depends on what you mean by new design
.
12 Alstom has a new reactor design that they
13
are marketing that actually came out of a
14
system built in a plant someplace where
15
they basically rebuilt an existing system
16
into a new contactor
. And those people
17
were able to market it through Alstom
.
18
And I would --
I don't know to what
19
extent orders for that units have been
20
placed
. But it may or may not, depending
21
on the experience factor
.
22
MR . AYERS : It is likely the test of
23
a new FGD system would cost two orders of
24 magnitude or more than the test that ACI
Page 689
1
systems that are going on now, wouldn't
Page 690
2 you say?
3
MR . CICHANOWICZ
: A test, I guess it
4
depends on what you mean by a test . You
5 know, the scrubber chemistry we are pretty
6 comfortable with . It's getting the mass
7 transfer over the amount of pressure drop
8 that you want to expend . So I don't know
9
what you mean by test . Can you help me?
10
MR
. AYERS
:
Let's do it historically
11 then . How long did it take us to
12
understand that chemistry and how much
13 money was invested in understanding that?
14
MR . CICHANOWICZ : It took at least
15 ten years .
16
MR . AYERS
: And multiple hundreds of
17 millions or billions?
18
MR
.
CICHANOWICZ : Well, not
19 billions . But multiple hundreds of
20 millions .
21
MR . AYERS : And the ACI
22 demonstrations and tests by comparison are
23 at least two orders of magnitude level
24 drop?
Page 691
1
MR . CICHANOWICZ
: Well, yes, but it
2 is a differing --
3
MR . AYERS : It is a different
4 technology .
5
MR . CICHANOWICZ : The FGD was a
6
capital intensive device
. And the reagent
7
cost was lost in the noise of the capital .
8
Here it's the inverse
. It's the
9
reagent cost that drives the process
.
10
MR . AYERS
: But the entire capital
11
and reagent posture are still a couple of
12
orders of magnitude lower than they are
13
for FGDs, right?
14
MR . CICHANOWICZ
: Well, if you are
15 -- it depends
. If it is just putting
16
sorbent into an ESP that you are
17
comfortable is going to sustain the
18
injection rate, it is lower
.
19
MR . AYERS
: Can we talk about SCRs
20
for a moment?
21
MR
. CICHANOWICZ : Please .
22
MR
. AYERS
: Would you have similar
23
statements about SCR, that the systems are
24
relatively costly and take a relatively
1
long time to build?
2
MR . CICHANOWICZ : I think the -
3
they don't cost as much as an FGD . And I
4
don't think they take quite as long to
5
install
. Instead of the 18 to 24 months,
6
you are probably looking at, you know,
7
shaving at least three for four months off
8
that .
9
MR . AYERS : Still if it is --
10
similarly, if you had a new design or a
11
new process, catalytic process that you
12 wanted to test, you would be talking about
13
a substantial lead time before you could
14
demonstrate that ; isn't that correct?
15
MR . CICHANOWICZ
: A new catalytic
16
process? You mean if it is a different
17
catalyst, it is probably -- no . In fact,
18
I am involved in programs right now where
19 we are trying to develop alternative
20
catalysts and it is splitting into the
21
existing reactor . But if it is a complete
22
new process, then yeah .
23
MR . AYERS : I don't want to try to
24
be a process chemist, because I am not . I
Page 692
1
am basically saying if you -- if you had a
2
new selective catalytic mousetrap that you
3 needed to demonstrate that was different
4
from what we have seen, wouldn't we be
5
talking about lead times that would
6
stretch out over two, three years before
7 you -- before you would see the results of
8
the test to find out whether that
9 mousetrap worked?
10
MR . CICHANOWICZ : Perhaps on that
11 order
. It is not months ; it's multiple
12
years .
13
MR . AYERS : And you would say the
14
same kind of thing for ESPs or fabric
15
filters or any other large piece of
16
equipment, that these control equipment
17
that these units use, tests of new units
18 would take a lot of money and a lot of
19
time?
20
MR . CICHANOWICZ : Depending on the
21 diversion of the new technology from
22
what's in the mainstream, yes
. I want to
23
be real careful because I don't want to
24
over generalize .
Page 693
1
MR . AYERS : Understood .
Small
2
innovations
probably don't do this .
3
I wanted to get to this question
.
4 Would you agree that the sorbent injection
5
system where a new fabric filter is not
6
installed, we are excluding TOXECON, is
7
considerably less expensive than an SCR or
8
any of these other systems?
9
MR . CICHANOWICZ
: Yes . If we are
10
talking about sorbent injection systems,
11
yes .
12
MR . AYERS
: And it takes
13
substantially less time to build?
14
MR . CICHANOWICZ
: Agreed, yes .
15
MR . AYERS : So would it be fair to
16
say that some of the impediments to
17 development and testing of scrubbers and
18
SCR units and some of the other
19
technologies do not exist to the same
20
extent with respect to the ACI technology?
21
MR
. CICHANOWICZ
: Because the need
22
for the regulation is already there, I
23
don't know
.
24
MR . AYERS : No
. I am just asking
Page 694
1 whether the
impediments were much
larger
2
in the case of those
large complicated,
3
sometimes chemically complicated
systems
4
as
compared with this relatively
5
uncomplicated system
.
6
MR . CICHANOWICZ
: Well, mechanically
7
it is certainly uncomplicated
. But we
8
would like to --
we want the one year of
9
testing to make sure that we can say that,
10
make that statement with certainty
. But
11
it is a less complicated system,
12
certainly
.
13
MR . AYERS
: Comparatively, it is
14
certainly less .
15
MR
. CICHANOWICZ : Right .
16
MR
. AYERS : Are you aware of any
17
other industrial uses of activated carbon
18
injection?
19
MR
. CICHANOWICZ
: Oh, I think it is
20 used a lot at the water treatment and in
21
waste-to-energy facilities
.
22
MR
. AYERS
: Waste-to-energy
23
facilities?
24
MR
. CICHANOWICZ
: For mercury
Page 695
Page 696
1
control in waste-to-energy facilities
2 mostly in Europe .
3
MR
. AYERS : Air pollution?
4
MR
. CICHANOWICZ : Yes .
5
MR . AYERS
: Is there an EPA
6
requirement on this?
7
MR . CICHANOWICZ
: I actually don't
8 know . There probably is
.
9
MR . AYERS : Do you know how many
10
incinerators or waste-to-energy plants
11 have installed ACI?
12
MR . CICHANOWICZ : No, I don't
.
13
MR . AYERS
: Is it a substantial
14
number? Dozens would you say?
15
MR
. CICHANOWICZ : No
. It might be
16 more than that
. Dozens, yes
. But again
17
we are talking about a different --
18
HEARING OFFICER TIPSORD
: Excuse me,
19
just a point of clarification .
I thought
20
I understood you to say most of the
21
waste-to-energy facilities that have
22
installed ACI are European
. Did I hear
23 that correctly?
24
MR
. CICHANOWICZ
: I said that, but I
1
didn't mean to
exclude there are some in
2
the U.S . This database of applications is
3
not something I look
at
a
lot,
so
I am
4
guessing .
5
HEARING OFFICER TIPSORD : I wanted
6
to clarify it wasn't exclusively European .
7
MR . CICHANOWICZ : No, it is not
8
exclusively European .
9
MR . AYERS : Did you say that the
10
chemical composition of fly ash and flue
11
gas from a waste incinerator is more or
12
less variable than that of a coal fired
13
boiler that tends to fire a particular
14
coal?
15
MR . CICHANOWICZ
: It is probably
16 more desirable simply because the mercury
17
comes from a lot of things that go in in
18
large pieces . So I think -- again this is
19
out of my skill set
. But my understanding
20 has been that mercury content is much more
21
highly desirable . But also the flue gas
22
chloride is so much higher in the
23
incinerator . And the sulfur is low . And
24
there is other differences as well,
Page 697
1
particular
loading as well .
2
MR . AYERS :
Do you think then that
3
the experience with municipal waste
4
incinerators is helpful or not helpful in
5
dealing with issues in implementing ACI in
6
the power industry?
7
MR . CICHANOWICZ
: I think it is
8
certainly helpful to a point, helpful to a
9 point of understanding
. I think it has
10 been key to getting us as far as we have
11 gotten
. But there is a limit because of
12
the gas composition .
13
MR
. AYERS : And compared, for
14
example, to FGD, there was no similar
15 technology experienced with that kind of
16
system when you first started work and you
17
tried to put those units onto power
18
plants ; is that correct?
19
MR
. CICHANOWICZ
: I believe that's
20
true, yes .
21
MR . AYERS
: It would appear that you
22 have a leg up here compared to some of
23
those previous examples that you cited?
24
MR
. CICHANOWICZ
: I think that's a
Page 698
1
fair statement .
2
MR . AYERS : Could we turn to the
3
SNCR technology? Are you familiar with
4
that technology, selective noncatalytic
5
reduction?
6
MR
. CICHANOWICZ : Yes .
7
MR . AYERS
: In terms of cost and
8
complexity, would you say that is more
9
like an FGD system or more like a sorbent
10
injection system?
11
MR . CICHANOWICZ
: I would say it is
12
more like a sorbent injection system
.
13
MR . AYERS
: Was the first commercial
14
SNCR system from a coal-fired boiler
15
installed at what was then called the New
16 England Power Company's Salem Harbor
17
Station around 1993?
18
MR
. CICHANOWICZ
: I think that's
19
about right
. But there might have been
20
one or two preceding it in '91 I believe
.
21
I'm recollecting Wisconsin Electric's
22 Valley Station tried something around that
23
time
. But I don't think that's far off
.
24
MR . AYERS
: Do you recall the Valley
Page 699
Page 700
1 Station?
2
MR . CICHANOWICZ : I thought there
3 was something called the Valley Station in
4 the Wisconsin Electric System . But I
5 can't remember if it was '91 or '94 .
6
MR . AYERS : Could that have been a
7
trial rather than a commitment to install
8 for good?
9
MR . CICHANOWICZ : It could have
10 been, yes .
11
MR . AYERS
: Is it not correct to say
12 that the Salem Harbor SNCR continues to
13
operate and the plant currently relies on
14 them to keep NOx emissions in check?
15
MR . CICHANOWICZ
: I believe that's
16 true . I haven't spoken to anyone there
17 for a long time . But I believe it is
18 still operating .
19
MR . AYERS : So you would say that so
20 far as we can tell, the installation is a
21 success?
22
MR . CICHANOWICZ : Yes .
23
MR . AYERS : When that unit was
24 installed, were there any coal-fired SNCR
1
systems operating for over
a year at a
2
time on any kind of test basis or any
3
other basis?
4
MR . CICHANOWICZ
: You really are
5 testing my memory
. Why didn't you make
6
this a question? I have all this stuff in
7
my office
.
8
I don't remember . There was a lot
9
of activity going on around that time
.
10 And I know Salem Harbor was a key point
.
11
I just can't remember exactly if there
12
were any preceding or not on coal
.
13
MR . AYERS
: But you don't recall any
14
one-year tests prior to this installation?
15 None that stick in your mind?
16
MR . CICHANOWICZ
: Correct .
17
MR . AYERS
: We have a couple of
18
exhibits that we would like you to look
19
at, if I may
.
20
MS . BASSI
: May I do a follow-up?
21
HEARING OFFICER TIPSORD
: You sure
22
can .
23
MS . BASSI : Mr
. Cichanowicz, what
24 was the level of NOx removal required at
Page 701
1
Salem Harbor, if you can recall?
2
MR
. CICHANOWICZ : I don't know at
3
Salem Harbor
. But selective noncatalytic
4
reduction --
and we had big debates about
5
this --
the numbers were anywhere from 20
6
to 40 percent removal
. The issue was
7
ammonia slip
. And I don't know what the
8
Salem Harbor came in at
. I am thinking a
9
paper presented at a conference in 1995 by
10 a guy named Staudt
. See, I remember your
11
papers
. I think it was 28 percent
. But
12
the author is here, and he will correct
13
me .
14
MR . STAUDT
: Actually, I presented
15
another paper .
16
MR . CICHANOWICZ
: But they were on
17
the order of
--
20 to 40 percent was on
18
the order of the numbers people were
19
expecting .
20
MR
. AYERS
: We understand it's less
21
effective in that sense of technology than
22
SCR
. But we are looking at it in terms of
23
its similarity to what we are considering
24
now .
Page 702
Page 703
1
As I said, we have two exhibits we
2 would like to look at
.
3
HEARING OFFICER TIPSORD
: I have
4
been handed "Post Combustion NOx Control
5
for Coal-Fired Utility Boilers" authored
6
by Hoffman, Johnson, Nalco Fuel Tech of
7
Naperville, Illinois, and "Cost
8
Effectiveness of NOx Control Retrofit at
9
Salem Harbor Station
."
10
The first document "Post Combustion
11
NOx Control" I will mark as Exhibit 98,
if
12 there is no objection
. Seeing none, we
13
will mark that as Exhibit 98
. And the
14
second one we will mark as Exhibit 99,
if
15
there is no objection .
Seeing none,
16 that's Exhibit 99
.
17
MR . CICHANOWICZ :
Mr . Ayers, you are
18
toying with me
. Because I am reaching for
19
validity in my memory and you have it on
20
paper in front of you
.
21
MR . STAUDT
: I wanted to tell you
22
you would find out in a minute
.
23
MR . AYERS
: Could you look at the
24
fourth page of Exhibit 98
.
1
MR . CICHANOWICZ : Who is the lead
2
author?
3
MR
.
AYERS : They are not numbered,
4
so it is the fourth .
5
HEARING OFFICER TIPSORD : 98 is
6
"Post Combustion NOx Control," Hoffman .
7
MR . AYERS : Hoffman is 98 .
8
HEARING OFFICER TIPSORD : And 99 is
9
the "Cost Effectiveness of NOx Control
10
Retrofit" at Salem Harbor .
11
MR . GIRARD
: Could I ask a quick
12
clarifying question?
13
HEARING OFFICER TIPSORD : Sure .
14
MR . GIRARD : Mr . Ayers, on
15
Exhibit 98, what is the date of that? Is
16
this a presentation? I am not finding
17
everything I need for a reference .
18
MR . AYERS : It was published -- it
19
was a paper presented at the 1993 EPRI EPA
20 NOx control symposium in a place called
21
Val Harbour, Florida, May 24 through 27 .
22
Could I direct you to the fourth
23
page there? In the middle of that first
24
full paragraph, there is a sentence which
Page 704
1
begins "NEPCO selected unit No
. 2 ." Would
2
you read that?
3
MR
. CICHANOWICZ : "NEPCO selected
4
unit No
. 2 at the Salem Harbor Station for
5 demonstration that is currently undergoing
6
long-term characterization
. NEPCO's
7
demonstration was divided into two phases :
8
A short-term optimization/parametric
9
phase, five weeks, followed by a long-term
10
assessment phase, two to three months
."
11
MR . AYERS : And would you take a
12
look at Exhibit No
. 99, page 3? And at
13
the top of the page, could you read those
14
two sentences?
15
MR
. CICHANOWICZ : Page 3, "In
16
November 1992," is that it?
17
MR . AYERS : Yes .
18
MR . CICHANOWICZ
: "In November 1992
19 New England Power and the Massachusetts
20 Department of Environmental Protection
21
agreed to establishing goals for reducing
22
NOx emissions
. The document established
23
goals for reducing NOx levels in units 1,
24
2 and 3 and proposed technology
Page 705
1
combinations to achieve the goals . The
2
proposed NOx control technologies were low
3
NOx burners, LNBs, and SNCR ."
4
MR . AYERS : And could you read the
5
last sentence at the bottom of that page?
6
MR . CICHANOWICZ : "Completed in
7
early 1993, the successful unit 2 SNCR
8 demonstration was followed by commercial
9 contracts to NFT for NOxOUT systems to be
10
installed on units 1, 2 and 3 . With
11
installation by New England Power, all
12
three systems were operational by
13
August 1st, 1993 ."
14
MR . AYERS : So doesn't this mean
15
that the utility tested this system for
16
less than a year and then installed the
17
new technology at full scale in three
18
units?
19
MR . CICHANOWICZ : Well, first of
20
all, number one, these units are small .
21
Salem Harbor units are 90 megawatts, 9-0 .
22
So I think the whole paradigm on how to
23
evaluate things for a small unit are
24
different than on a larger unit .
Page 706
1
Second of all, the concern with
2
SNCR, as I remember, was simply the
3
ability to get NOx removed without
4
generating residual ammonia . And it was a
5 matter of matching the injection to a very
6 narrow window in the furnace
.
7
The downside, that is risks that
8
have to be incurred by the utility if
9
there was a problem with this, was
10 generating excess ammonia, which you could
11 pretty much correct that by just cranking
12
down the ammonia injection .
13
So my point is it was a fairly safe
14
system . And that if you had a problem,
15 you could crank down on the ammonia and
16
essentially restore the residual level of
17
ammonia so it didn't contaminate or damage
18
the fly ash .
19
With electrostatic precipitation,
20
you know, again, we are talking about the
21
accumulation of ash on a collecting plate
22
and as --
I don't want to keep going back
23
to this the hot-side ESP takes a very long
24
period of time for a very thin layer of
Page 707
1
ash adjacent to the plate to change its
2
electrical characteristics to the point
3
where it essentially rendered the --
4
caused significant operating problems .
5
And with the sorbent injection is
6
the concern it will do the same . We are
7
talking about things that are going to
8
take a long time . You know, the time
9 constant for accumulation and completion
10
of these trace species is very different
11
than what happened in the SNCR .
12
So you are right, it took less time .
13
But it was a different technology . It had
14
I think some exit ramps .
15
MR . AYERS : There was an emission,
16
though, that had to be met?
17
MR . CICHANOWICZ : Yes, there was .
18
MR . AYERS
: So you couldn't crank
19 back on the ammonia too far .
20
MR . CICHANOWICZ : Well, you could .
21 But you have to push your low NOx burners
22
a little further and risk more carbon
.
23
MR . AYERS
: Could I ask you to take
24
a look at page 5 of Exhibit 99 for a
Page 708
Page 709
1 moment?
2
MR . ZABEL : Which exhibit,
3 Mr . Ayers?
4
MR . AYERS : 99 . And could you read
5 the first statement under conclusions of
6 this paper?
7
MR . CICHANOWICZ : Under conclusions?
8
HEARING OFFICER TIPSORD : Yes .
9
MR . CICHANOWICZ : "New England
10 Power, Salem Harbor Station, has a NOx
11 emission rate goal of 0 .33 pounds per
12 million BTU for units 1, 2 and 3 . These
13 pulverized coal, PC, fired units have been
14 retrofitted and operated to achieve these
15 goals in combinations of combustion and
16 post-combustion NOx control technology as
17 follows ." Would you like me to read the
18 matrix that beings here?
19
MR . AYERS
: Not beyond the colon .
20
MR . CICHANOWICZ : Okay .
21
MR . AYERS : So you agree this
22 statement states that the SNCR technology
23
is installed and operating on the Salem
24
Harbor units and meeting an emission
1
standard?
2
MR . CICHANOWICZ
: Yes .
3
MR .
AYERS : To your knowledge, are
4
there other SNCR systems operating on
5
coal-fired units in the
U.S .?
6
MR . CICHANOWICZ
: Yes, there are .
7
MR . AYERS
: Didn't several other
8
coal-fire utilities install this
9
technology within a few years, again
10 without a lengthy demonstration program?
11
MR . CICHANOWICZ : Well, yes
. But
12
the -- my recollection is that all of the
13
SNCR units are still relatively small on
14
the order of a couple hundred megawatts of
15
capacity .
16
Personally, one of my consulting
17
assignments was working with PSE&G Mercer
18
helping them on one-eighth of a unit
. And
19
I know we looked at that
.
20
But I don't think --
the largest
21
SNCR installation I can think of is not
22
above a couple hundred megawatts capacity
.
23
MR . AYERS
: Would there be other
24
reasons that might explain that, like it
Page 710
1
might
be more economical to use an SCR
2 unit on your large units?
3
MR . CICHANOWICZ : Well, I don't know
4
if it is economical
. I just think what we
5
found was -- actually, what a number of
6
researchers found was that as you got
--
7
as you went up in generating capacity, the
8
-- you know, the challenges of mixing
9 became to the point where you weren't able
10 to get the reagent mixed up within a short
11 period of time
. And you would be
12
restricted in terms of NOx removal .
13
So I don't know if it was
14
economical . I think for large units
15
people haven't had the confidence to go to
16
extremely high -- they go to very large
17
to very large generating units with SNCR .
18
I believe Duke Powers Marshall
19
Station, which is four or 500 megawatts,
20 has SNCR . But you are only asking about
21
18 percent, 20 percent NOx removal .
22
So again you can --
23
MR . AYERS : Doesn't TBA have some
24
SNCR units as well?
Page 711
1
MR . CICHANOWICZ : TBA has probably
2
one of everything .
3
MR
. AYERS : More than one of
4
everything .
5
MR
. CICHANOWICZ : They probably do .
6
I just -- you know, they probably do
.
7
MR . AYERS : And the PSE&G Station
8
has SNCR too, right?
9
MR
. CICHANOWICZ : Yes .
10
MR . AYERS : And that is a large
11
station, 600 megawatts or something like
12
that?
13
MR . CICHANOWICZ
: I don't know . I
14
don't think Hudson has SNCR . I believe
15 Mercer had SNCR because I helped them with
16
it and they have since gone to SCR . I
17
don't believe that Hudson has SNCR . I
18
don't believe it does .
19
MR . AYERS : But you can summarize
20
this discussion by saying that SNCR is a
21 technology that was deployed with much
22
less than a full-year demonstration or
23
multiple full-year demonstrations in
24
commercial use and has been successful
Page 712
1
based on what we know at this point,
2
couldn't you?
3
MR . CICHANOWICZ
: Yes . But, you
4
know, it is a different process
. And so I
5
don't know that --
although that is
6
informative and helpful, I don't know how
7
relevant it is to activate coal injection
.
8
MR . AYERS
: Of course each process
9
is different
. But SNCR certainly
-- isn't
10
it more like ACI than it is like scrubbers
11
and SCR in the sense of being simpler,
12
simpler installed, simpler equipment, et
13
cetera .
14
MR . CICHANOWICZ
: In general, yes .
15
MR . AYERS
: Thank you .
16
MR . ZABEL
: I have a couple of
17
follow-ups .
18
HEARING OFFICER TIPSORD
: Yes,
19
Mr
. Zabel .
20
MR
. ZABEL : Mr
. Cichanowicz,
21
Exhibit 99 on page 3, the first sentence
22
Mr
. Ayers had you read refers to goals for
23
reducing NOx emissions, does it not? The
24
sentence you read refers, as I said, to
Page 713
1
goals for reducing NOx emissions
; is that
2
correct?
3
MR . CICHANOWICZ
: The document
4
established goals for reducing NOx levels .
5
MR . ZABEL
: And in the second
6
bullet, does it not also refer to a goal
7
of 0
.33 pound per million BTU limit
8
emission?
9
MR . CICHANOWICZ : Yes . "Subsequent
10 to the SNCR demonstration, LNBs would be
11 installed with a NOx goal of 0 .33 pounds
12
per million BTU
."
13
MR . ZABEL : And on page 5 in the
14
conclusion he had you read into the
15
record, does it not refer again to an
16
emission rate goal in the first line?
17
MR . CICHANOWICZ : Yes, it does,
18
emission rate goal .
19
MR . ZABEL : Can you tell from that
20
whether this effort -- and this is a 1994
21
paper for the installation of SNCR at
22
Salem -- was to meet a command and control
23
objective or an experimental objective?
24
MR . CICHANOWICZ : I guess I can't
Page 714
Page 715
1 tell the difference .
2
MR . ZABEL : Thank you .
3
MR . AYERS : Mr . Cichanowicz, would
4
you look at the second bullet on page 5?
5
HEARING OFFICER TIPSORD
: On
6 Exhibit 99?
7
MR . AYERS : On Exhibit 99,
second
8 bullet . Would you agree that it says
9 there that these units are expected to
10
meet a state NOx RACT minimum of
11 0 .45 pounds per million BTUs?
12
MR
. CICHANOWICZ : Let me read this
13 carefully . "Baseline NOx emission rates
14 for these units were about one pound per
15 million BTU . With LNB on unit one and
16 LNB/OFA on unit No . 3, these units are
17
expected to meet state RACT, reasonably
18 available control technology, limits of
19 0 .45 pounds per million BTU ." What does
20 it mean by these units are expected?
21
MR . AYERS : Doesn't that sound like
22 a regulatory requirement to you?
23
MR . ZABEL : Well, I would point out
24 the number in the first bullet was much
1
lower for the goals . But I think this
2
illustrates one of the problems I raised
3
earlier, not allowing the witness to read
4
an entire document and we don't want to
5
take the time -- this one is very short, I
6
admit -- presents these kinds of problems
7
taking things out of context .
8
MR . AYERS : I don't see there is any
9
problem here at all . I don't see any
10
inconsistency between 0 .5 parts per
11 million BTUs emission standard and the
12
goal of 0 .33 .
13
MR . ZABEL
: But we don't know that
14
the SNCR wasn't designed to do better than
15 was necessary under the RACT . And the
16
report may well say that if we read the
17
entire thing .
18
My problem here, Mr . Ayers, is you
19
want to put this into evidence, you should
20
have called a witness with it and you
21
should ask for another hearing . You are
22
trying to put in evidence in
23
cross-examination . It seems to be a
24
somewhat inappropriate approach .
Page 716
Page 717
1
MR . AYERS : I think you are --
2
HEARING OFFICER TIPSORD : Gentlemen,
3 gentlemen .
4
MR
. ZABEL : It bears --
5
HEARING OFFICER TIPSORD :
One at a
6 time .
7
MR . ZABEL : All I am trying to show
8 is the difficulty of using a piecemeal
9 document that way to try and establish
10 some evidentiary point hereafter .
11
MR . AYERS : We sat quietly all
12
morning and watched you introduce new
13 evidence into the record . And I don't
14 think you are in much of a position to
15 complain about that .
16
MR . ZABEL
: I did introduce it . I
17
didn't do it by cross-examination . You
18 are here to cross-examine --
19
MR . AYERS : Still --
20
HEARING OFFICER TIPSORD : Gentlemen,
21 the document is in the record
.
The
22 document speaks for itself .
23
I would note that it is at least my
24 recall that in Springfield when the
1
agency's witnesses were
on, there was more
2
than one occasion --
and I am not saying
3
it was you Mr . Zabel -- but there was more
4
than one occasion when the members of the
5
industry handed piecemeal pieces of
6 material to the point where the Board had
7
to specifically ask for the entire
8
document, we weren't even given the entire
9
document a time or two .
10
So I understand your problem . But I
11
think the document speaks for itself, and
12
I think we need to move on .
13
I believe we are at question 43
.
14 And I am hoping that we knocked off some
15
of these questions when we were discussing
16
this stuff .
17
MR . CICHANOWICZ
: I don't know .
18
HEARING OFFICER TIPSORD
: I think we
19
did
. I think some of these talk about
20
cost of SCR and that down the line
.
21
Question 43 .
22
MR . CICHANOWICZ
: On page 21 you
23
describe experience with ash plugging at
24
Southern Company's Plant Bowen
. What
Page 718
1
company was responsible for the design and
2
construction of the SCR at Plant Bowen?
3
The Bowen SCR equipment was designed
4
and constructed by several organizations
.
5 The catalyst and design for the process
6
conditions was provided by Cormetech
. The
7
flow modeling that defines the mixing
8 uniformity of ammonia and flue gas
9 velocity and temperature by Mitsubishi
10
Heavy Industries
; and the reactor designed
11 by the owner, which is Southern Company
.
12
Question 44, regarding --
13
MR
. AYERS : Madam Chairman?
14
HEARING OFFICER TIPSORD
: Excuse me,
15
Mr
. Ayers has follow-up .
16
MR
. AYERS : I want to follow up on
17
that
. I heard most of what you said,
18 although I am having trouble when you are
19
reading, it is hard to speak into the mic
.
20
MR
. CICHANOWICZ : You wore me out on
21
the last exchange .
22
MR . AYERS : But my follow-up
23
question is who is responsible for this
24
large particle ash problem, is it the
Page 719
1
was it the US EPA, was it the contractors,
2 was it Southern Company? Who was
3
ultimately in charge of it?
4
MR . CICHANOWICZ : Well, all I know
5
is I started working on SCR in 1979 . And
6
I probably have been to Europe eight times
7
with leading utility fact-finding missions
8
scoring the visibility of SCR before it
9
was deployed in the U
.S . And in those
10
eight trips, there was one plant
-- I
11
repeat, there was one plant where the
12
owner said we are having a little bit of a
13
problem with these large ash particles and
14
we don't know where they come from, they
15
block the catalyst, but we don't know what
16
to do about it . Everybody else didn't
17
seem to have a problem .
18
We deployed the technology in the
19
U .S . And for reasons that some very good
20
people I know still can't figure out, we
21
seem to be able to generate these large
22
particles that block up a lot of
23
catalysts . So in my opinion it was one of
24
those uncertainties that you have when you
Page 720
1
transfer
technology .
2
The initiative
was straightforward
.
3
It was 30,000,
40,000 megawatts of
SCR in
4
Germany . We should be beyond that
. So I
S
don't believe anybody was responsible . I
6 have my theories why LPA is generated, but
7
that's not what's of interest
.
8
But the point is this is an example
9 of whenever you change the paradigm in
10 which technology works, you may get
11
different results .
12
MR . AYERS
: Wasn't the Southern
13
Company responsible since they were
14
responsible for compliance by the plant?
15
MR
. CICHANOWICZ : Let's put it this
16 way, when Bowen came down after 69 days of
17
operation, it was they who basically had
18
to scramble, take down the plant and try
19
to find replacement power while we're
20 having the catalysts cleaned and how to
21
figure out how to wrestle with this
22
problem
.
23
HEARING OFFICER TIPSORD
: Question
24
44?
Page 721
1
MR . CICHANOWICZ : Regarding
2
section 3
.3 .2 of your testimony, you note
3
the risks associated with rising costs
4
when demand rises . Would not that argue
5
for moving early to get entry-level
6
prices?
7
Possibly . The price as demand
8
increases will depend on the relative
9
forces of supply and demand and the
10 equipment inventory required to achieve
11
the regulation .
12
Question 45
--
13
HEARING OFFICER TIPSORD : Mr . Ayers?
14
MR . AYERS : One follow-up . Even if
15
the cost of sorbent injection systems
16
increased from $2 .50 per kilowatt the IEPA
17
used to, say, $10 a kilowatt at a capital
18
recovery rate of 14 percent and a capacity
19
factor of about 70 percent, what impact
20 would that difference have on generating
21
cost measured in dollars per megawatt hour
22
and how does that compare to the wholesale
23
price of electricity in Illinois?
24
MR . CICHANOWICZ : Ann Smith left
Page 722
1
yesterday . I am kidding
. It's a small
2
impact . It's a small impact
. It's a
3
small impact because it is a low capital
4
cost .
5
MR . AYERS : Thank you .
6
HEARING OFFICER TIPSORD
: Question
7
No
. 45?
8
MR . CICHANOWICZ
: On page 22 of your
9
testimony, you note that SCR catalyst cost
10 has dropped due to competition . That was
11
a statement, not a question
. Question A,
12
do you believe that all of those
13
competitors in the SCR catalyst business
14 would have been attracted to the U.S .
15 market had very few SCRs built in the
16
U .S .?
17
No
. The decrease in cost and
18 participation by suppliers was driven by
19
the anticipated demand in SCR
20
installations in response to the mid 1990s
21
SIP-Call .
22
Question B, is it possible that a
23 similar impact could happen for mercury
24
sorbent as a result of a rule that creates
Page 723
1
a market for mercury sorbent?
2
It is possible, but there may be
3
differences in the factors affecting the
4
supply of carbon-derived sorbent and SCR
5
catalyst that could change the outcome .
6
SCR catalyst is a highly engineered,
7 precisely manufactured, high value-added
8 material
. The production and manufacture
9
evolved from relatively small quantities
10 during an evolving market in Japan in the
11
late '70s, ultimately to a large market in
12
the U .S . and the world .
13
The introduction of several
14
world-class technology companies as major
15 players into the market did contribute to
16
the significant decrease in catalyst unit
17
cost
. The case for activated carbon may
18
be different as the present production
19
capacity reportedly starts from a
20
worldwide overcapacity, which may limit
21
price decreases .
22
Question C, does not sorbent have a
23 much bigger impact on cost of generation
24
than capital cost in cases when sorbent is
Page 724
1
injected upstream of an ESP?
2
Depending on the capital cost of
3
retrofitting ACI to an ESP and any
4
modifications to the ductwork or ESP to
5
alleviate operating problems, sorbent may
6
dictate cost
. If ACI truly requires only
7
installing the injection equipment 2 to $4
8
a kilowatt based on estimates by the
9
Institute of Clean Air Companies and
10
technology providers, for 4 to $21
11
kilowatt based on the DOE, that means
12
sorbent costs will drive ACI Hg removal
13
costs . If ESP upgrades or ductwork
14
modifications are required, the sorbent
15
cost will be significant but perhaps not
16
the major contributor .
17
Question 46, on page 25 of your
18
testimony there is an equation . From what
19 document was this equation taken from?
20
The equation describing the overall
21
correlation of Hg removal with coal
22
properties was reported in the initial
23
report by EPRI evaluating the ICR data and
24
also in a technical paper to the 2001 Mega
Page 725
Page 726
1
Symposium entitled "Estimating Total and
2
Speciated Mercury Emissions from the U .S .
3 Coal-Fired Power Plants" by Paul Chu, et
4 al
. The equation is contained in the
5 latter reference and figure five in that
6 reference graphically depicts the Hg
7 removal .
8
Question 47 --
9
MR . AYERS
:
I am sorry,
10 Mr . Cichanowicz, I have to ask you a
11 couple questions . I would like you to
12 look at another document .
13
HEARING OFFICER TIPSORD : This is
14
Exhibit 100 . I have been handed the "U.S .
15 EPA Research and Development Performance
16 and Cost of Mercury and Multi-Pollutant
17 Emission Control Technology Applications
18 on Electric Utility Boilers ."
19
If there is no objection, I will
20
mark this as Exhibit 100
. Seeing none, we
21 are at Exhibit 100 .
22
MR . AYERS : Would you look at
23 page 19, please?
24
MR . ZABEL
:
Again for the record,
Page 727
1 the witness had an opportunity to read the
2
96 pages that are presented in
3 Exhibit 100 .
4
MR . AYERS : I don't think he will
5 need to .
6
MR . ZABEL : At least, he hasn't had
7 a chance to read it recently, as far as I
8 know .
9
MR . AYERS : In equation one on 19 --
10
MR . CICHANOWICZ : Yes .
11
MR . AYERS : -- does this not show
12 another equation specifically for
13 cold-side ESPs that include both chlorine
14 and S02?
15
MR . CICHANOWICZ : Yes .
16
MR . AYERS : Yours does not include
17 502, is that correct, in your testimony?
18
HEARING OFFICER TIPSORD : It is
19 page 25 of the testimony .
20
MR . CICHANOWICZ : Yes .
21
MR . AYERS : Is that incorrect?
22
MR . CICHANOWICZ : No . The people
23 that put the correlation together had a
24 reason for not including S02 . And I
1
forgot exactly what it was .
2
But they -- work was done by URS
3
Corporation
. And there was something in
4
the correlation where they felt it
5
correlated better without looking at the
6
S02 because they specifically called that
7
equation out differently than all the
8
other equations
.
9
Absent the cold-side ESP, the
10
equation looks like the one that is in
11
this document .
12
MR . AYERS
: Don't the papers that
13 you mention all have the sulfur component
14
in that equation?
15
MR . CICHANOWICZ : All of the
16
correlations that were produced in EPRI's
17
analysis of the ICR data use chlorine and
18
S02 except for cold-side ESP
.
19
MR
. AYERS : I think it is the other
20
way around, only the cold-side ESP
.
21
MR . CICHANOWICZ
: Okay . All the
22
equations have both S02 and chloride
23
except for the cold-side ESP, which just
24
has chloride
.
Page 728
Page 729
1
MR . AYERS
: Which paper are you
2 looking at?
3
MR . CICHANOWICZ :
I'm looking at my
4 testimony on page 25 .
5
MR . AYERS : Right .
Do you have Paul
6 Chu's paper here?
It's one of the papers
7 you referred to
.
8
MR
. CICHANOWICZ :
It should be .
9
MR . AYERS :
Do you have it right
10 here?
Could you take a look at it?
11
MR . CICHANOWICZ : If I typed it
12 wrong, I typed it
wrong . It came from
13
that document .
14
MR . AYERS :
We have it here in
15 electronic form
.
16
17
(Short pause in
18
proceedings
.)
19
MR .
CICHANOWICZ : The answer is I
20
can't tell you
. I took the data from the
21
reference that was in the CD
. I just
22
typed it wrong .
23
MR . AYERS
: Okay .
So it should have
24
the sulfur component?
1
MR .
CICHANOWICZ : It should .
It is
2
a matter of me not being able to type
.
3
MR . AYERS
: So if you had a power
4
river basin derivative-based coal that had
5
an S02 emission rate of about 0
.4 pounds
6
per million BTUs, would include that
7
sulfur term result in a higher or lower
8
estimated mercury capture rate?
9
MR
. CICHANOWICZ : Compared to what?
10
MR . AYERS : Compared to not having
11
that term in the equation
. In other
12 words, compared to the equation in your
13
testimony, wouldn't the equation with the
14
S02 term --
how would the equation with
15
the S02 term affect the predicted mercury
16
capture for a PRB coal with an emission
17
rate of, say, 0
.4 pounds per million BTUs
.
18
MR
. CICHANOWICZ
: Well, the equation
19
in my testimony is wrong
. So you are
20
asking me --
I don't know why you are
21
MR . AYERS : You agreed to that
. I
22
will rephrase it .
23
What's the effect of that change on
24
the 0 .4 pound coal?
Page 730
1
MR . CICHANOWICZ : I don't know . I
Page 731
2
have to punch in numbers and see . I don't
3 know .
4
MR . AYERS : Wouldn't 0 .4 be in the
5 denominator of the equation?
6
MR . CICHANOWICZ : Yes .
7
MR . AYERS : So wouldn't that
8 inevitably result in a bigger number as a
9 result of the equation?
10
MR . CICHANOWICZ : Yes
.
11
MR . AYERS : So it would -- would
12 result in a higher estimated mercury
13 capture rate, correct?
14
MR . CICHANOWICZ : Yes
. But again if
15 -- if this is the ICR data, I really don't
16 know why we are talking about it . We have
17 much more recent data . And I will answer
18 your question . Yes .
19
MR . AYERS : It was introduced in
20 your testimony or the subject was
21 introduced,
so we had to check it .
22
If I may follow up slightly on it,
23 doesn't that mean that the PRB units we
24 just discussed, doesn't that mean that the
1
PRB units, which are most of the units in
2
Illinois, would be under predicted by the
3
equation that was in your testimony?
4
MR
. CICHANOWICZ : Yes . But I don't
5 know why we are talking about the equation
6
in my testimony because I said it is in
7
error and it was an example .
8
MR . AYERS
: I guess we are talking
9
about it because it was there
. We have to
10
ask about it .
11
And wouldn't that also make the cost
12
estimate for control for those units
13
higher --
wouldn't the estimate of the
14
cost of control for these units be lower
15
if you used the S02 term?
16
MR
. CICHANOWICZ : Yes . But that --
17
I don't know why we keep talking in
18
circles
. That equation is not used for
19 anything but as part of an introductory
20 background
. It was not used in any of the
21
calculations that were done .
22
MR
. AYERS : Let me try to sum it up
.
23
Is it fair to say that chlorine and S02
24
are both important to this equation?
Page 732
1
MR . CICHANOWICZ : Yes .
2
MR .
AYERS : And higher sulfur is bad
3
for mercury removal and higher chlorine is
4
good, assuming that higher removals are
5 what we want?
6
MR . CICHANOWICZ : I think in general
7
that's what we believe, higher sulfur is
8
bad .
9
MR . AYERS : That's what the equation
10
says .
11
MR . CICHANOWICZ : Yes .
12
MR . AYERS : Is the carbon content of
13
ash also called LOI important also?
14
MR
. CICHANOWICZ : Yes, it is .
15
MR . AYERS : And temperature?
16
MR . CICHANOWICZ : Yes, it is .
17
MR . AYERS : And I assume, as you
18
describe in your testimony, you think size
19
of ESP is important?
20
MR . CICHANOWICZ : I think it could
21
be a factor .
22
MR . AYERS : Do you think it is a
23
factor or could be a factor?
24
MR . CICHANOWICZ : I think it could
Page 733
Page 734
1 be a factor .
2
MR . AYERS : Thank you . On page 25
3 you also state "data from commercial-scale
4 tests that suggests mercury removal is
5 influenced by SCA, which may be consistent
6
with fundamental analysis that suggests
7 mass transfer between particles and flue
8
gas is favorably affected by large SCA,
9 Clack 2006 ."
10
MR . CICHANOWICZ : Yes .
11
MR . AYERS : Do you see that
12 reference?
13
MR
. CICHANOWICZ : Yes .
14
MR . AYERS : What data from
15 commercial-scale test are you referring to
16 in that statement?
17
MR . CICHANOWICZ : Well, that
18 statement is based on the exhibit that I
19 had proposed earlier .
20
MR . AYERS : Would that be figure
21 5 .2?
22
MR . CICHANOWICZ : Yes . Basically,
23 what I said was that -- from figure 5 .2,
24 yes .
1
MR . AYERS :
Could we stop here for a
2 break?
3
HEARING OFFICER TIPSORD
: Sure .
4
Let's take a break
. Come back in about
5
ten minutes .
6
MR . AYERS
: Thank you .
7
(Short recess taken
.)
8
HEARING OFFICER TIPSORD : Mr . Ayers,
9 are we ready to move on to question 47?
10
MR
. AYERS : I think we are .
11
HEARING OFFICER TIPSORD
: Okay .
12
Question 47
.
13
MR . CICHANOWICZ
: Please provide
14
your source --
15
MR . AYERS
: I'm sorry, I apologize .
16
No, we are not
.
17
HEARING OFFICER TIPSORD
: Okay .
18
MR . AYERS
: We do have some
19
additional questions, the follow-ups on
20
46 .
21
On page 25 of your testimony,
22
Dr
. Cichanowicz, you raised the issue of
23
size of the ESP
. I know it is in various
24
places throughout your testimony
. We
Page 735
1 would like
to ask you some questions that
2
relate to the assertion that ESP size
3
could have an effect on mercury removal .
4
I think the place to start is we have a
5
couple of exhibits we would like to take a
6
look at . And could we do now Exhibit 101?
7
This is a paper by Sjostrom and others at
8
a 2001 Mega Symposium in Chicago .
9
HEARING OFFICER TIPSORD
: For the
10
record, it is "Mercury Removal Trends in
11
Full-Scale ESPs and Fabric Filters ." If
12
there is no objection, we will mark this
13
as Exhibit 101 . Seeing none, it is
14
Exhibit 101 .
15
MR . GIRARD : Mr . Ayers, could you
16
repeat the conference where it was
17
presented?
18
MR . AYERS : It is colloquially
19
called the Mega Symposium . It is an EPA,
20 DOE and EPRI sponsored symposium that
21 occurs regularly to talk about these kind
22
of pollution control issues . I can't be
23
more specific than that . But it is
24
basically a combined utility air pollution
Page 736
1
control symposium .
2
MR . GIRARD : And
this was the 2001?
3
MR .
AYERS : 2001, yes . Have you had
4
a chance to look at that?
5
MR . CICHANOWICZ : The whole paper or
6
is there a specific item?
7
MR . AYERS
: I wanted to make sure
8
you were ready
.
9
MR . CICHANOWICZ
: Yes .
10
MR . AYERS
: Do you know any of the
11
authors of this paper?
12
MR . CICHANOWICZ
: I think I know in
13
one way, shape or form all of them
.
14
MR . AYERS
: And in your opinion, are
15 they knowledgeable people?
16
MR . CICHANOWICZ
: Extremely .
17
MR . AYERS
: Could I direct you to
18
page 11 of this paper, the fourth bullet
19 point on page 11
. Could you read that
20
fourth bullet point .
21
MR
. CICHANOWICZ : "The size of the
22
cold-side ESP, SCA, correlates with higher
23
mercury removal in cold-side ESPs on
24
lignite coals
. Although this correlation
Page 737
1
appears to be significant, the highest
2
level of mercury removal in this subset
3
was seven percent . For subbituminous
4
coals, there appears to be an inverse
5 correlation between SCA and mercury
6
removal . The smaller the SCA, the higher
7
the removal
. It is expected that other
8
factors are contributing because it is
9
unlikely that this is a true correlation ."
10
MR
. AYERS : So would you agree that
11
these authors conclude that other factors
12
than ESP size are influencing mercury
13
capture -- or let me restate that . That
14
ESP size is not a factor in determining
15 mercury capture?
16
MR . CICHANOWICZ : I'd point out that
17
this paper was presented in 2001, which
18
means the data was generated before that .
19
So, yes, that's what that bullet suggests ;
20
but that was, you know, quite sometime
21
ago .
22
MR . AYERS : Okay . Could you look at
23
page 12? There is a table there, table
24
six . And could you tell me which factors
Page 738
1
on this table had the highest correlation
2 with mercury capture for bituminous or
3
subbituminous fuels?
4
MR . CICHANOWICZ : Well, for the
5
cold-side ESP, the LOI and the mercury on
6
the sampling filter, the subbituminous on
7
the inlet temperature and the LOI .
8
MR . AYERS : And LOI was important
9 for bituminous and subbituminous?
10
MR . CICHANOWICZ : Yes .
11
MR . AYERS : Is LOI an indication of
12 how much carbon is in the fly ash?
13
MR . CICHANOWICZ : Yes, it is .
14
MR . AYERS : Does it make sense that
15 LOI would have a high correlation with
16 mercury capture?
17
MR . CICHANOWICZ : I believe so
.
18
MR . AYERS : Why would that be?
19
MR . CICHANOWICZ : Well, because the
20
carbon generated in the flame, even though
21
it is not as attractive as manufactured
22
sorbent in mercury will still do some
23
attracting
.
24
Can I read a bullet to you from this
Page 739
1
paper? Do
I
get
to do that?
2
MR . AYERS :
You are the witness .
3
MR . CICHANOWICZ : Above that is the
4
statement, the first bullet says "flue gas
5
conditioning with S03 was used on three of
6
the five cold-side ESPs for boilers
7 burning subbituminous coals . The use of
8
S03 conditioning did not appear to
9
influence mercury removal ." That was
10
then, this is now . I appreciate the
11
statements, but it is a 2001 paper .
12
MR . AYERS
: Could you look at the
13
conclusion on page 14? Do any of those
14
conclusions state that ESP size as
15
indicated by SCA has a significant effect
16
on mercury capture?
17
MR . CICHANOWICZ : From this paper,
18
none of the conclusions state that, that's
19
correct .
20
MR . AYERS : On page 25, you cite a
21
reference of Clack 2006 .
22
MR . CICHANOWICZ : Yes .
23
MR . AYERS : Is that a paper or a
24
communication or what?
Page 740
1
MR . CICHANOWICZ : That was a
Page 741
2
technical paper presented at the --
I said
3 there is six or seven mercury conferences
4 a year .
The first one is January in
5 Tucson . It is very popular . Dr . Clack
6 presented a paper there and the
7 proceedings I believe I submitted in the
8
file where he describes some mathematical
9 modeling that he did looking at mass
10 transfer and its enhancements within an
11
ESP and the possible impacts on mercury
12 removal .
13
MR . AYERS
: So you cite this to
14 indicate or suggest that mass transfer is
15 favorably affected by large SCA in your
16 testimony?
17
MR . CICHANOWICZ : Well, I cite it
18 because his modeling showed that, in fact
19 -- well, let me back up .
20
The thought used to be that the cake
21 collected on the plate would provide some
22 mercury capture . And he did some modeling
23 to show that the cake that resides on the
24 plate provides little or no capture . And
Page 742
1 any capture that is provided in the ESP is
2 in the -- is when the particle migrates
3 from the
-- from the field once it accepts
4 a charge to the plate . And he went into
5 some analysis to show that
. And one of
6 the observations was that with a higher
7 SCA ESP this effect would be greater . I
8 only cited it just to show that people
9 have been thinking about this for a while .
10
MR . AYERS : Do you have the Clack
11
paper with you? If you don't, we do and
12
we can share it with you .
13
MR . CICHANOWICZ : I don't have the
14 piece of paper with me . But it was on the
15 disk
that
I
sent you .
16
MR . AYERS : We have it on paper .
It
17 might be helpful to talk from that
.
18
HEARING OFFICER TIPSORD : Just a
19
point of clarification for the record,
20 this is included on the CD-rom .
21
MR . CICHANOWICZ : Yes .
22
MR . AYERS
: Yes . It was placed in
23 the record .
24
HEARING OFFICER TIPSORD : Actually,
1
for ease of the record since we are going
2 to be looking at this and you are going to
3
ask specifically, I am going to give this
4
an exhibit number as well because it will
5
be much easier in the transcript if this
6 has an exhibit number . So we are going to
7
mark this as Exhibit 102 if there is no
8
objection . Seeing none, this is
9
Exhibit 102 . This is not a part --
10
MR . AYERS : That's a separate
11
exhibit . We don't know whether this is on
12
the disk .
13
HEARING OFFICER TIPSORD : Okay . I
14 have been handed a PowerPoint slide
15
presentation titled "Mass Transfer
16
Limitations to Mercury Capture within
17
Electrostatic Precipitators
." I am going
18
to mark this as Exhibit 103, if there is
19
no objection . Seeing none, it is
20
Exhibit 103 .
21
MR . AYERS : Mr
. Cichanowicz, would
22
you characterize this paper, this first
23 paper by Herek Clack as a theoretical
24
calculation of potential mass transfer
Page 743
1
rather than actual measurements?
2
MR . CICHANOWICZ : Oh, yes . That is
3
completely correct
.
4
MR . AYERS : And it focuses on gas
5 particle mass transfer and makes a number
6
of simplifying assumptions in order to aid
7
in the thinking, correct?
8
MR . CICHANOWICZ : Yes .
9
MR . AYERS : And it includes -- among
10
the assumptions that go into the
11
calculations are that the sorbent
12
particles are treated as perfect mercury
13
sinks having unlimited mercury capacity
14
and maintaining a mercury concentration at
15
their surface that is identically zero,
16
correct?
17
MR . CICHANOWICZ : That is correct,
18
yes .
19
MR . AYERS : Are you aware of any
20
sorbent material that has such
21
characteristics as has having unlimited
22 mercury capacity?
23
MR . CICHANOWICZ : I think
24
Mr . Nelson's does
.
Page 744
Page 745
1
MR . AYERS : But he is not letting
2
on .
3
MR . CICHANOWICZ : But outside of
4 Mr . Nelson, I am not aware of material
5 with those characteristics .
6
MR . AYERS : And are you aware of any
7
material that has such characteristics of
8 maintaining a mercury concentration at
9 their surface that is identically zero?
10
MR
. CICHANOWICZ : No, I'm not .
11
MR . AYERS : And are you aware of any
12 sorbent that acts as a perfect mercury
13 sink .
14
MR . CICHANOWICZ : No .
15
MR . AYERS : So would you say that
16 Dr . Clack's estimates are realistic or
17 theoretical? Or would they provide an
18 upper bound -- an upper limit to the
19 mercury uptake that you would calculate
20 from this kind of
21 a --
22
MR . CICHANOWICZ : They might provide
23 a number . And in referencing Dr . Clack's
24 work, I use the word fundamental analysis,
1 which
in my paradigm means exactly this
2
and no more than that .
3
MR . AYERS
: So any projections he
4 made about mercury capture in this paper
5 would have to be a greater than what would
6
be expected in the real ESPs, correct?
7
MR . CICHANOWICZ
: Well, I don't know
8
that he --
depending on the analysis
9
perhaps . But, yes, there was a lot of
10
theoretical assumptions brought into the
11
analysis .
12
MR . AYERS
: If you could look at the
13
abstract at the front of the paper,
14
page 1, he addresses the question of
15 absorption by the dust cake in the
16
sentence that begins "an often unstated
17
presumption
. . ." It says that
" . . .is that
18 mercury capture within an ESP is the
19
result of adsorption by dust cake
20
collected on the ESP plate electrodes
.
21
This presentation summarizes recent mass
22
transfer analyses that refute this
23
hypothesis and show that in most cases the
24
mass transfer potential and thus potential
Page 746
1
for mercury oxidation and or adsorption is
2
generally less than 20 to 30 percent of
3
the gas-phase mercury ."
4
Is that a correct reading of what he
5
states as his conclusions in the abstract?
6
MR . CICHANOWICZ : It is correct . I
7
don't know if the -- yes, it is correct .
8
Yes .
9
MR . AYERS : So would you agree with
10 his statement that mercury capture by this
11 mechanism appears to be fairly limited?
12
MR . CICHANOWICZ : Mr . Ayers, we
13
didn't have to go through all of this to
14
get me to say that . Because there is a
15
later question that I say I believe with
16
what Dr . Staudt said in Springfield that
17
most of it takes place in the ductwork .
18 And I only put this in here to show that
19
fundamentally there are good people
20 thinking about how to engage the
21 precipitator to extract mercury removal .
22
I actually -- I am glad I read this
23
again on the plane on the way here
. But
24 what triggered my interest was under
Page 747
1
conclusions is that the -- about halfway
2
through the -- under conclusions there the
3
statement that begins "by comparison"
4 and again he is comparing the mass
5 transfer on the plate to what happens when
6
the particles move across the ESP -- "the
7
conducted mass transfer analysis of
8 mercury uptake on suspended particles
9
during the collection within the ESP
10
showed a far greater potential for mercury
11
capture
." And I understand the word
12
potential .
13
The other thing is he uses the word
14
in-flight differently . He uses the word
15
in-flight as motion of the particle in the
16
ESP . And I believe most everybody else
17
uses it in the ductwork .
18
MR . AYERS : In terms of the
19 phenomenon, it doesn't make any difference
20 whether it is in the ductwork or the ESP,
21
correct?
22
MR . CICHANOWICZ : That's correct,
23
yes . That is correct .
24
MR . AYERS : So again staying on
Page 748
1
page 8 in the
conclusions, so you agree
2 with that conclusion that you read about
3
mercury uptake during -- the conclusion
4
you just read out loud?
5
MR . CICHANOWICZ : Yes, I do agree .
6
MR
. AYERS : Now, could we look at
7
the Exhibit 103 I think it is, which is a
8
slide presentation by Professor Clack .
9 And you have to look at the fifth slide
.
10 They are not numbered, "Maximum PM and Hg
11
Removal within ESPs ."
12
Do you agree that this slide shows
13
the results of the connective mass
14
transfer calculation from different
15
particle sizes and ESP energy levels?
16
MR . CICHANOWICZ : Yes .
17
MR . AYERS
: Looking at the figure on
18
the right for ten microgram particles
19
micron, I am sorry, you see that the
20 performance can be pretty good, close to
21
80 percent removal or 20 percent of the
22
inlet fraction in the best case at energy
23
levels of 200 kilovolts per meter?
24
MR
. CICHANOWICZ : Yes .
Page 749
1
MR . AYERS : At 600 the removal is
2
only about 20 percent, correct .
3
MR . CICHANOWICZ
: At 600 what?
4
MR . AYERS : 600 kilovolts per meter?
5
MR . CICHANOWICZ : Yes .
6
MR . AYERS : Would you agree that the
7
figure shows that most of the capture
8
occurs within the first two seconds or
so
9
at an energization level of 200 kilovolts
10 per meter and within a fraction of a
11
second at 600 kilovolts based on this
12
presentation?
13
MR . CICHANOWICZ : Yes
. That's what
14
it shows .
15
MR . AYERS : So any capture beyond
16
that mechanism is pretty limited, beyond
17
the two seconds, I'm sorry?
18
MR . CICHANOWICZ : That's correct,
19
within the
-- within the ESP, yes .
20
MR . AYERS : Do you know what a
21
typical energization level is for an ESP?
22
MR . CICHANOWICZ : I believe it is
23
about 150 kilovolts per meter . No, that's
24
not right . I believe it is
-- I believe
Page 750
1 it is about 300 .
Page 751
2
MR . AYERS : About
300 . According to
3 his paper on page 6 -- you said around
4 300
. On page 6 of his paper, doesn't it
5 say "considered in figure three on the
6
right are the peak enhancement factors at
7 RED equals 2,000 achievable by the
8
weakest, 340 kilovolts per meter, and
9 strongest, 403 kilovolts per meter,
10 electrical fields for a representative ESP
11 geometry ."
12
So if a typical ESP has an
13
energization around 340 to 400 kilovolts
14 per meter, we would expect to capture
15 between somewhere between the 600
16 kilovolts per meter line and the 200
17 kilovolts per meter line on figure four,
18 correct --
19
MR . CICHANOWICZ : Yes .
20
MR . AYERS :
in the other Clack
21 presentation .
22
So perhaps at a typical energization
23
level, we might see the mercury removal
24
from this effect around 40 to 60 percent
Page 752
1 for the ideal super duper sorbent within
2 maybe a second or so, would that be
3 correct?
4
MR . CICHANOWICZ : In general, yes .
5
MR . AYERS : And you probably get
6 less removal with a real sorbent that has
7 limited sorbent capacity that is sort of
8 Sid Nelson's special, right? Correct?
9
MR . CICHANOWICZ : Well, I think so
.
10 But, you know, we are assigning a lot of
11 attributes to this study to a full-scale
12 plan .
But all things being the same, yes .
13
MR . AYERS : So looking at the
14 figure, in summary, after about two
15 seconds in the best case, best case being
16 the best removal case, there appears to be
17
little additional mercury removal, agreed?
18
MR . CICHANOWICZ : Within the ESP
19 based on this analysis, yes
.
20
MR . AYERS : And in every case there
21 is very little additional mercury removal
22 after time shorter than two seconds or
23 less in this chart?
24
HEARING OFFICER TIPSORD : Excuse me,
1
Mr . Cichanowicz, you nodded your head .
2
MR . CICHANOWICZ : Yes
.
3
MR . AYERS : Would you expect that
4
for a real sorbent that was injected
5 upstream of the ESP somewhere in the duct
6
and, therefore, had a chance to absorb
7
some mercury there, that the threshold
8 would be -- would likely be reached even
9
sooner than two seconds?
10
MR . CICHANOWICZ
: Depending on the
11
mixing perhaps .
12
MR . AYERS : And let me start on a
13
little different direction here . Would
14 you agree that the smallest ESP in
15
Illinois has an SCA of around a hundred
16
square feet per thousand per ACFM?
17
MR . CICHANOWICZ : I think that's
18
about right, yes .
19
MR . AYERS : We have a couple more
20
things for you to look at .
21
HEARING OFFICER TIPSORD : This
22 document I have been handed is "The Use of
23
Treatment Time and Emissions Instead of
24
SCA and Efficiency for Sizing
Page 753
1
Electrostatic Precipitators" by Robert A .
2
Mastropierto
. If there is no objection, I
3
will mark this as Exhibit No
. 104 . Seeing
4
none, it is Exhibit 104 .
5
MR . AYERS : As you can see from the
6
cover of this document, Mr . Mastropierto
7
is product director for ESPs at the
8
Research-Cottrell Company, which makes
9
ESPs for electric power plants .
10
What is of interest to us in this
11 paper is with regard to what we have been
12
discussing about Professor Clack's paper
13
as a simple way to estimate the treatment
14
time for an ESP that is offered on page 4
15
of this paper . We have circled or
16 highlighted, but you may not be able to
17
see that well . We have highlighted an
18
equation that Mastropierto provided . And
19
Dr
. Staudt used a little math that you are
20
free to review to estimate the frequent
21 time for an ESP with an SCA of a hundred
22
square feet per thousand ACFM .
23
HEARING OFFICER TIPSORD : Excuse me,
24
Mr . Ayers, for point of clarification and
Page 754
1
make sure that the record
is clear, on
2
page 4 then these what
appear to be
3
handwritten notes are not a part of the
4
article, but rather Dr . Staudt's
5
calculation?
6
MR . AYERS
: Correct .
7
HEARING OFFICER TIPSORD : Thank you .
8
MR . CICHANOWICZ
: So you are waiting
9
for me to concur?
10
MR . AYERS : I wanted to give you a
11
chance to look back
. Are you ready for a
12
question?
13
MR
. CICHANOWICZ : Yes .
14
MR . AYERS : It's a single question
.
15 Would you agree using this equation the
16
estimated treatment time for such an ESP
17 with nine-inch plate spacing would be
18
about 2 .25 seconds or longer than that if
19
the plate spacing were wider?
20
MR . CICHANOWICZ : Well, I am trying
21
to back out what the velocity and the
22
precipitator was . And I don't see from
23
this method of calculation . So I will
24
accept these calculations at the moment as
Page 755
Page 756
1 they are
. But I do need to review this in
2
some detail .
3
MR . AYERS
: Okay . Let's give you
4
something else to look at, second paper by
5
Dr . Mastropierto .
6
HEARING OFFICER TIPSORD
: This one
7
is titled "Achieving Low Particulate
8
Emissions with Electrostatic
9 Precipitators
." This will be Exhibit 105
.
10
MR . AYERS
: And can you look at
11
figure one on page 5? I'm sorry .
12
MR . ZABEL : What was your reference,
13 Mr . Ayers?
14
MR . AYERS : Page 5,
figure one in
15
the second paper
. Figure one shows
16 treatment times for ESPs built in
17 different times .
What is the lowest
18
treatment time you can see on this figure?
19
MR . CICHANOWICZ
: Two to four
20 seconds .
21
MR . AYERS : Now,
going back to
22
Professor Clack's slide presentation that
23
we were looking at earlier
--
24
HEARING OFFICER TIPSORD : Which is
1
Exhibit 103?
2
MR . AYERS : Yes, "Maximum PM and Hg
3
Removal," Exhibit 103 . If you look there
4
for where the curve of the removal is at
5
about two seconds, which was the lowest
6
treatment time in the Mastropierto paper,
7
isn't it true that there is little or no
8
additional mercury capture even in the
9 best case with the super duper sorbent
10
that they are using here after two
11
seconds?
12
MR
. CICHANOWICZ : Yes .
13
MR . AYERS : So all the action
14 happens in the first two seconds or much
15
less -- or in much less time in most
16
cases?
17
MR . CICHANOWICZ : Yes .
18
MR . AYERS : So doesn't this suggest
19 that any amount of mercury capture that is
20 going to happen in an ESP through this
21 mechanism will be complete within a 100
22
SCA ESP?
23
MR . CICHANOWICZ : Well, we are --
24
within the ESP, within the ESP, we --
Page 757
1
there will be --
the removals are such
2
that most of
it occurs up
front, that's
3
correct, within the
ESP .
4
MR .
AYERS : Why are you qualifying
5
it?
6
MR . CICHANOWICZ
: Well, because it's
7
--
the whole process as I --
when I put
8
the chart up --
and that was one of the
9
reasons for going through the
--
one of
10 the reasons for going through the
11
satellite images this morning is that it's
12
more than just the ESP
. It is basically
13
the sorbent --
it is basically the inlet
14
ductwork as well
.
15
MR . AYERS
: If some of the reaction
16
were occurring in the inlet ductwork also,
17
then wouldn't the effective plate size
18 need to be even smaller in order to
19
achieve the removal of most of the
20 mercury?
21
MR
. CICHANOWICZ
: Well, that depends
22
on the mixing that you get in the inlet
23
ductwork .
24
MR . AYERS
: If the sorbent were in
Page 758
1 the ductwork and it
were
taking up some of
2
the mercury there, then wouldn't the time
3
to the end of that take-up process be
4
shorter once it was in the ESP because
5 some of the mercury was already adsorbed?
6
MR . CICHANOWICZ : Yes . But again we
7
are talking about -- we are taking one
8
piece out and, essentially, not looking at
9
the whole package . Okay . There is mixing
10
of the sorbents in the ductwork . And
11 again we are just right now talking about
12
mercury removal . We are not really
13
talking about the fact that the ESP has to
14
respond to the sorbent that's injected and
15
make sure that it basically prevents a
16 breakthrough . We have just talked about
17 mercury removal .
18
MR . AYERS : But do I take
-- you are
19 not changing your view, though, what these
20
tables say? You agree that within the
21
ESP, the take-up of mercury would be,
22
essentially, complete within two or
23
slightly more than two seconds?
24
MR . CICHANOWICZ : And, Mr
. Ayers,
Page 759
1 there is a question that we may get to
2 next week at this rate where I am asked
3
bluntly that
. And I say most of it
--
4 most of the uptake is in the ductwork and
5
the inlet system . I say that very
6
bluntly .
7
MR . AYERS : Okay .
8
HEARING OFFICER TIPSORD : And when
9
we get there, we can skip that question,
10 which is exactly what happened in
11
Springfield . We got off on these things
12 and then hopefully we go through very
13
quickly and say we have addressed that
.
14
And we will do that .
15
Mr . Nelson, do you have a question?
16
MR . NELSON : Just to summarize then,
17
if it takes place in the ductwork and we
18
stipulate that very little of it is
19
even theoretically, according to Clack,
20 takes place on the plates and the measure
21
of the plates is the SCA, that's the
22
collection area, the specific collection
23
area, then I believe you are changing your
24
testimony from the written testimony . In
Page 760
1
the written testimony,
don't you testify
2
that all the small SCAB in Illinois are
3 not going
to
see the
same
removal rate
as
4
these large ones, correct? And now
5
MR . CICHANOWICZ : I think in my --
6
MR . NELSON : -- am I interpreting it
7
correctly for you to say, no, all the
8
removal takes place and it really doesn't
9 matter how large the SCA, how large the
10
collection area is?
11
MR . CICHANOWICZ : No . My testimony
12
is there may be a relationship between
13 mercury removal and SCA depending upon an
14
envelope of parameters . Okay . That was
15 the purpose of the images this morning .
16
It is not just the ESP . It is everything
17
else that goes around it .
18
MR . NELSON : But again, just to
19
summarize, if Clack says theoretically
20
very little removal takes place on the
21
collection area, would you submit then
22 that your graphs that you passed out this
23 morning that show on the X axis specific
24
collection area is largely, but not
Page 761
Page 762
1 completely, irrelevant as far as mercury
2 capture is concerned?
3
MR . CICHANOWICZ : When you -- ESPs
4 of larger SCA may have other things about
5 them that are desirable for mercury
6
removal . Okay .
7
MR . NELSON : Such as what?
8
MR . CICHANOWICZ : Such as,
9
basically, the inlet ductwork arrangement
10 and the ability to get sorbent in quickly
11 and get it mixed up .
12
Clack's analysis is for applying the
13
process condition of the ESP and not
14 within the ductwork . And so it applies to
15 within the ESP .
16
And, further as I said, we talked
17
this morning about the role of carbon,
18
activated carbon versus carbon generated
19 in combustion . Basically, the size of the
20
SCA is important to ensuring that there
21 will not be breakthrough of the sorbent
22 that's injected . So it's the whole
23 package .
24
MR . NELSON
: Opacity or particulate
1
is a separate issue that I think we are
2 going to address . But right now what you
3
testified to this morning dealt with
4 mercury removal . And did you show any
5
data that said small SCA ESPS get less
6 mercury removal, all other things being
7
equal? Did you present or are you aware
8
of any data to that effect?
9
MR . CICHANOWICZ : The data that I
10
showed this morning didn't have all other
11
things being equal . The data I showed
12
this morning was a graph of figure 5-2
13
that laid out the results of the function
14
of the SCA .
15
MR . NELSON : And did any of that
16
data show, particularly for subbituminous
17
coals like in Illinois, that small SCA
18
ESPS have lower mercury performance, any
19
measurements at all?
20
MR . CICHANOWICZ : What do you mean?
21
MR . NELSON : Could you point to a
22
single measurement of the subbituminous
23
coal in an ESP that shows lower mercury
24
sorbent performance in small SCA ESPS?
Page 763
1
MR . CICHANOWICZ : All the data, as I
2
have said, are
not
directly noncomparable .
3 And a couple of PRB units basically all
4
show about the same removal .
5
MR
. NELSON : I will refer you to
6 Exhibit 88 this morning on the second
7
smallest ESP in Illinois from Crawford .
8
There it did look like high removals were
9
achieved at an SCA of 119, correct?
10
MR
. CICHANOWICZ : You know, I can --
11 until that data could be reviewed and
12
discussed, it is hard for me to react to
13
it, Mr . Nelson . You know that .
14
MR . NELSON : Theoretically according
15
to Clack, there should be no relationship
16 between mercury removal and the specific
17
collection area in ESPs, correct?
18
MR . CICHANOWICZ
: In the analysis
19
that he did, basically, there is no
20
relationship .
21
MR . NELSON
: Thank you .
22
HEARING OFFICER TIPSORD : Are we
23
ready for question 47?
24
MR . AYERS
: I think we are .
Page 764
Page 765
1
HEARING OFFICER TIPSORD
: Question
2 47 .
3
MR . ZABEL : Do you have something,
4 Mr . Ayers?
5
HEARING OFFICER TIPSORD : No . He
6
was getting ready to read the question .
7
MR . CICHANOWICZ : Please provide
8 your source for figure
4-1
.
9
Figure 4-1 is based on the Energy
10 Information Agency's Form 767, which
11
contained design information on the ESP,
12 including collecting plate surface area
13 and the actual flue gas flow rate at the
14 ESP . However, the data file as obtained
15 by EIA is out of date, as it does not
16 reflect ESP upgrades . The curve in
17 figure 4-1 is based on an updated national
18
ESP database that I have maintained over
19 five years with Mr . James Marchetti . We
20
update this file as we become informed of
21 ESP upgrades through discussions with
22 owners or technical papers .
23
HEARING OFFICER TIPSORD : Question
24 48 .
1
MR . CICHANOWICZ : Regarding
2
figure 4-1, is the range in ESP size at
3
least in part due to coals burned in the
4
U .S .?
5
HEARING OFFICER TIPSORD
: Due to
6
different coals .
7
MR . CICHANOWICZ : Due to different
8
coals burned in the U
.S . This is a
9
statement preceding a series of questions .
10
A, would ESPs designed for high sulfur
11 bituminous coals be smaller than for
12
medium sulfur bituminous --
13
HEARING OFFICER TIPSORD : 48 was the
14
question . Regarding figure 4-1, is the
15
range in ESP size, at least in part, due
16
to different coals burned in the U .S .?
17
MR . CICHANOWICZ : Yes
. Would ESPs
18
designed for high sulfur bituminous coals
19 be smaller than for medium sulfur
20
bituminous coals, all else being equal?
21
All other factors being equal,
22
higher sulfur bituminous coals will
23
require smaller ESPs than medium sulfur
24
bituminous coals .
Page 766
1
Question B, would ESPs designed for
2
low sulfur coals, especially PRB coals, be
3
larger than for medium sulfur coals, all
4
else equal?
5
All other factors being equal, lower
6
sulfur bituminous coals and in particular
7
PRB coals will require larger ESPs
.
8
Question C, so would you agree that
9
the tendency, therefore, would be that
10
ESPs designed for PRB coals would
11 generally be larger than those designed
12
for bituminous coals, especially high
13
sulfur coals, all else equal, correct?
14
Yes .
15
Question D, and that is why several
16
Illinois units firing PRB fuel use S03
17
conditioning to make the ESP act as if
18
it's a higher sulfur coal as it was
19
originally designed for?
20
Yes . The use of S03 conditioning
21
reduces ash, electrical resistivity to be
22 on the order of the same as a medium high
23
sulfur coal and thus allow the particle to
24
allow a charge and also to prevent
Page 767
1
back-corona, which is a particle collage
2
of the electric field that will reduce ESP
3
efficiency .
4
Question 49, please describe the
5
specifics for each of the units in figure
6
4 .2 of your testimony : A, plant name and
7
unit number ; B, percent FGD gas bypass, if
8
any ; C, coal type
; D, FGD type, limestone
9
forced oxidation, limestone natural
10
oxidation, magnesium enhanced lime, lime
11
spray drier fabric filter, et cetera ; E,
12
percent S02 removal by the FGD ; F,
13
particulate control device, ESP, fabric
14
filter, et cetera .
15
I do not have access to the details
16
of the units represented in figure 4-2 .
17
The complete technical presentation as
18
delivered to the Electric Utilities
19 Environment Conference in January of 2006
20
is included in references .
21
HEARING OFFICER TIPSORD : We didn't
22
hear all that .
23
MR . CICHANOWICZ
: I do not have
24
access to the details of the units
Page 768
Page 769
1 represented in figure 4-2 . The complete
2
technical presentation as delivered to the
3 Electric Utilities Environment Conference
4 in January of 2006 is included in the
5 references .
6
HEARING OFFICER TIPSORD : The CDs,
7 which are Exhibit 96?
8
MR . CICHANOWICZ : Yes . Question 50 .
9
MR . AYERS :
I'm sorry
.
That answer
10 requires further questions .
So the
11 information in question is not on the
12 disks supplied to the Illinois EPA this
13 morning ; is that right?
14
MR . CICHANOWICZ : That information
15 is not available to me . It's part of an
16 EPRI program and they have not released
17 the sites, at least that I know .
18
MR . AYERS : So you don't know what
19 units these are that are referred to in
20
the table?
21
MR . CICHANOWICZ
: That is correct .
22
MR . AYERS : Isn't it rather
23 difficult for us or the board then to
24 understand what to make of those if we
Page 770
1 don't even know what plants they are or
2 how they were chosen? Don't we need to
3
understand items A through F in order to
4 make sense of this figure?
5
MR . CICHANOWICZ : Having the
6 information about the stations would be
7 more helpful . But it wasn't available to
8 me .
9
MR . AYERS : I think I go further
10 than that and say it isn't helpful at all
11
since we don't know what it is . I think
12 we would like to have that data excluded
13 if we can't figure out where it comes
14 from .
15
HEARING OFFICER TIPSORD : Is that a
16 motion?
17
MR . AYERS : That's a motion .
18
MR . ZABEL : I believe such motions
19 have to be in writing, if my recollection
20
is correct, Madam Hearing Officer
.
21
HEARING OFFICER TIPSORD : It is
22 already entered as an exhibit . I don't
23 know that they have to be in writing to
24 exclude
--
1
MR . ZABEL : You
insisted
in
that
2
case on our exclusion of Dr . Keeler's
3
including Steubenville
.
4
HEARING OFFICER TIPSORD : I asked it
5
to be simply because I felt it was --
6 needed to be briefed by everyone .
7
In this case I think it is safe to
8
say we are going to include this
9
information . The Board is perfectly
10
capable of examining it for what it's
11
worth .
12
MR . ZABEL : My response is it
13
doesn't have the specific data . Mr . Ayres
14
Is quite right . It is not available to
15
the author . It represents certain results
16
from certain utilities . It has whatever
17
credibility we give to an expert who has
18
presented it at the conference and for
19
whatever that data is worth .
20
Mr . Ayers is certainly competent on
21
it to comment on his closing comments, as
22
is everyone else .
23
HEARING OFFICER TIPSORD : And the
24 board can also examine the CD and look at
Page 771
Page 772
1 the reference material from
2 Mr . Cichanowicz . But we are not going to
3 exclude it .
4
MR . AYERS : Let me ask one further
5 question --
6
HEARING OFFICER TIPSORD : You can
7 ask, certainly .
8
MR . AYERS : -- on this point . We
9 listed six factors in which -- for which
10 we requested information . Isn't it true
11 that each of those six factors could have
12 an impact on the removal rate of the
13 plants in question in this figure?
14
MR . CICHANOWICZ : Yes, that is true,
15 they can have an impact .
16
MR . AYERS : So without knowing about
17
those factors in each of the plants,
it is
18 very difficult to draw any conclusion,
19 isn't it?
20
MR . CICHANOWICZ : Well, it basically
21 represents -- it represents what people
22 have observed in fuel tests with the role
23 of SCR influencing mercury removal . And
24 it was the range of results that have been
1
observed and reported . I will turn over
2 what has been reported in technical
3
literature . And for a number of reasons,
4
the details on those sites are not
5
something that I can access to bring into
6
a public forum .
7
MR . AYERS : Well, I sympathize with
8
you about that . But I think that a table
9
like us this that's shorn of names and
10
shorn of all the relevant factors that
11
influence those outcomes just doesn't mean
12 very much
. And I won't say anything more
13
than that in support of my rejected
14
motion .
15
MR . ZABEL : Are we on 50?
16
HEARING OFFICER TIPSORD : I think we
17
are on question 50 .
18
MR . CICHANOWICZ : Regarding your
19
statement on the last paragraph of page 24
20
of your testimony pertaining to mercury in
21
gypsum, question A --
22
HEARING OFFICER TIPSORD : Excuse me,
23
that is page 28 of your testimony .
24
MR . CICHANOWICZ : On page 28, thank
Page 773
1
you, of your
testimony pertaining to
2 mercury in gypsum, Question A, do you
3
agree that the mercury is going into the
4
gypsum today at plants with FGD,
5
regardless of any requirement to control
6
mercury? Yes
.
7
Question B, is not the major issue
S whether or not the wallboard manufacturing
9
process drives off some part of the
10 mercury when the gypsum is heated? Yes
.
11
C, is that what --
12
HEARING OFFICER TIPSORD
: Hang on a
13
second . Mr . Ayers lost his place . 50-A
14
was yes .
15
MR . AYERS : And 50-B?
16
HEARING OFFICER TIPSORD
: Was yes .
17
And we are on 50-C .
18
MR . CICHANOWICZ : 50-C, is that why
19
U .S . Gypsum's program is funded by DOE?
20
I'm not aware of the rationale for DOE's
21
funding various mercury technologies other
22
than the desire to prove and commercially
23
demonstrate control technology . I do
24
concur that the presently funded program
Page 774
1
by U .S . Gypsum is addressing these issues
.
2
MR . AYERS
: May I ask one follow-up
3
on that? If in the process of making
--
4 of gypsum wallboard making, some mercury
5
was driven off in that heating process
.
6
Couldn't that be addressed through a vent
7
system on the wallboard plant with a
8
carbon filter?
9
MR . CICHANOWICZ
: Probably .
10
Perhaps, yes .
11
MR
. AYERS : Thank you .
12
HEARING OFFICER TIPSORD
: 50-D .
13
MR . CICHANOWICZ
: Question D, what
14
percent of Illinois coal capacity has wet
15
FGD?
16
About six percent or 1,000 megawatts
17
of coal capacity is equipped with wet FGD
.
18
Question 51, on page 30 of your
19 testimony you describe experience with FGD
20
additives in improving mercury capture
.
21
That's a statement .
22
51-A, are wet FGD systems effective
23
in capturing elemental mercury? No .
24
Generally oxidized mercury, primarily as
Page 775
1
mercuric chloride, is the most easily
2
removed form of mercury in flue gas
.
3
Elemental Hg is not captured to any
4
significant degree .
5
Question B, so without something to
6
oxidize the elemental mercury such as an
7
SCR catalyst or an oxidizing reagent,
8 would you expect elemental mercury to be
9
captured in a wet FGD?
10
No . Generally elemental mercury
11
will not be captured in a wet FGD
12
environment
.
13
Question C, is being B&W's additive
14
an oxidant designed to promote oxidation
15
or is it designed to shift sulfite
16
chemistry to avoid conversion of oxidized
17
mercury, which can be captured, to
18
elemental mercury, which is not captured?
19
My understanding is that B&W's
20
additive prevents the re-emission of
21
oxidized mercury as elemental mercury .
22
Question 52, you indicate in
23
table 5-1, the Zimmer Station has a
24
thiosorbic lime FGD system with ex-situ
Page 776
1
oxidation . Question A, is the process
2
chemistry with regard to sulfites
3
different at a scrubber of this type?
4
Yes .
5
Question B, how many scrubbers of
6
this type currently are in Illinois or are
7
likely to be installed? None at present .
8
Question 53, did Endicott Station or
9
Zimmer have an SCR to increase the level
10
of oxidized mercury?
11
No means to increase mercury
12
oxidation was present at either station .
13
Question A, how many wet FGD systems
14
are there in Illinois that do not have an
15
SCR upstream? None . All are equipped
16
with SCR .
17
Question 54 --
18
MR . AYERS
: Sorry, may I ask a
19
follow-up?
20
HEARING OFFICER TIPSORD
: Mr . Ayers .
21
MR . AYERS : Based on what you just
22
said, would you expect that the units in
23
Illinois with FGD would provide higher
24
mercury removal than shown in table 5-1?
Page 777
1
MR . CICHANOWICZ : Yes, I would,
2
except for maybe Dominion, which I have
3
listed as greater than 90 percent .
4
MR . AYERS : Dominion was one I was
5
going to raise . Did this test of
6
Dominion's Mt . Storm Plant with the SCR in
7
service achieve 90 percent or better
8 mercury removal with and without the
9
additive?
10
MR . CICHANOWICZ : I believe it was
11
90 percent without the additive . And the
12
additive had a small effect . But I
13
believe it was 90 percent without the
14
additive .
15
MR . AYERS : Is this testing with the
16
SCR in operation at that plant far more
17
relevant to Illinois units in light of the
18
configuration of Illinois units that are
19 equipped to have FGD based on what you
20
said?
21
MR . CICHANOWICZ : That configuration
22 is relevant . But the oxidation of mercury
23 that we will derive from an SCR appears to
24
depend upon a number of factors such as
Page 778
1
coal
chlorine --
2
HEARING OFFICER TIPSORD : Could you
3
speak up? We have the garage door
4
opening .
5
MR . CICHANOWICZ : I am sorry . The
6
oxidation of mercury across an SCR will
7 depend on a number of factors including
8
the chloride content of the coal . And I
9
do need to point out that we are still
10 understanding exactly this mechanism and
11
what the longevity of the effect might be .
12
So results from Dominion are certainly
13
encouraging . But to know whether you are
14
going to get 90 percent removal or not,
15 you need to look at the coal chloride
16
content . And we need to have a little bit
17 better understanding of how the mercury
18
oxidation provided by the catalyst will
19
change with time, if it does change with
20
time .
21
MR . AYERS : That was not the
22
question I was getting at . Let me put it
23
a different way . Given that the Mt . Storm
24
Plant had an SCR -- had an FGD and that
Page 779
1 the plants
that you mentioned in figure
2
5 .1 do not, with the exception of the
3
Storm, then isn't the Dominion Mt . Storm
4 plant a much more relevant comparison for
5
a state which has every unit with a
6
scrubber led by an SCR?
7
MR . CICHANOWICZ
: Yes, it is .
8
MR . AYERS : Okay . Thank you .
9
HEARING OFFICER TIPSORD : Question
10
54 .
11
MR . CICHANOWICZ : As far as you
12
know, is the testing of oxidizing
13
chemicals limited to the work you have
14
described?
15
Other means to oxidize mercury for
16
removal in an FGD are the subject of
17
research including oxidizing agents such
18 as magnesium chloride presently being
19
explored by the University of North
20
Dakota .
21
Question 55, on page 31 of your
22
testimony, you mention that dry FGD
23 process conditions prevent high mercury
24
removal . Do you mean for both bituminous
Page 780
1
and PRB/lignite coals
or just for
PRB and
2
lignite
coals?
3
The influence of
dry FGD conditions
4
on mercury removal depends on the coal
5
type
. Both the ICR data and the recent
6
tests by Consol show that for bituminous
7
coals dry FGD followed by a fabric filter
8 provides conditions that promote mercury
9
removal
. With PRB coals, dry FGD can
10
neutralize what little chloride is
11
introduced with the coal and inhibit
12
mercury removal
.
13
Question 56, regarding the fuel
14
additive KNX you state on page 32 that at
15
Laramie Station, quote, based on
16
short-term, e .g
. several hours tests
17
greater than 90 percent capture was noted
.
18
Extended tests are necessary,
19
approximately one year, to verify that
20
this level of Hg capture can be sustained
21
considering boiler and equipment
22
reliability
. What is the basis of this
23
statement?
24
The composition of the additive KNX
Page 781
1
is maintained proprietary . If halogens or
2
sodium-based compounds are the key
3
additives that are used to promote the
4
ability of injected sorbent to retain
5 mercury, the role of these added compounds
6
on boiler performance should be explored .
7
Introducing halogens into the fireside of
8
a boiler requires precautions to ensure
9 that corrosion is not induced by secondary
10
compounds generated by the halogens . It
11
is true that boilers have successfully
12
fired high chloride coals and also coals
13 with sodium content, but form and impact
14
of these compounds must be understood .
15
MR . AYERS : Could I?
16
HEARING OFFICER TIPSORD : Go ahead,
17
Mr . Ayers .
18
MR . AYERS : I have to ask a
19
follow-up on that
. Your statement on
20 page 32 that is quoted here in the
21
question stating that extended tests are
22
necessary to verify that this level of
23
mercury capture can be sustained . Is that
24
your opinion or an official finding? It
Page 782
1
is a bit hard to tell from the way it's
2
phrased .
3
MR . CICHANOWICZ : Well, I guess it's
4 my opinion because the additive is
5
proprietary . I think -- I know I am told
6
that if you sit down and are considering
7 being a purchaser, that they may reveal it
8
to you
.
9
But the point is that when you are
10
adding compounds on the fireside of the
11
boiler, you just need to be careful that
12
you don't interfere with the performance
13
of the boiler
. It is true that the
14
industry has successfully fired high
15
chloride coals for many years . And they
16
have fired coals with sodium content .
17
So whatever they have in there might
18
be actual . But I think what has to happen
19
is that the details of the additive need
20
to be explored to make sure there aren't
21
any impacts on the boiler .
22
And, as I said before, maybe a year
23
is the typical type of time that people
24
feel comfortable with
.
Page 783
Page 784
1
MR . AYERS : So you say approximately
2 a year . Would six months be adequate?
3
MR
.
CICHANOWICZ : Perhaps .
4
MR . AYERS : Do you know if there is
5 any test of this sort of planned here?
6
MR . CICHANOWICZ :
I think there
7 might be . I think that Alstom is
8 marketing this pretty heavily . And there
9 may be some people that are talking to
10 them about it . But that type of
11 information certainly is hard to come by
.
12
MR . AYERS : All right . Thank you .
13
HEARING OFFICER TIPSORD
: Question
14 57 .
15
MR .
CICHANOWICZ
:
On page 32 of your
16 testimony, section 5 .3 is entitled
17 "Sorbent Injection Within ESPs
."
Aside
18 from TOXECON II did you not intend to say
19 sorbent injection upstream of ESPs? Yes .
20
HEARING OFFICER TIPSORD : Question
21 58 .
22
MR . CICHANOWICZ : On page 32 of your
23
testimony, you state historically for any
24
environmental control maximizing residence
1
time for
contacting with reagent and
2
absorption/reaction promotes efficient
3
removal
. It is anticipated a large ESP
4 with extended lengths of inlet ductwork
5
and generous collecting plate surface area
6
will promote mercury removal while smaller
7
ESPs with limited surface area and inlet
8
ductwork residence time offer limited
9 mercury removal
.
10
Question A, are you stating that
11
carbon is a reagent? No, carbon is not a
12
reagent .
13
The purpose of this sentence is to
14
show that any environmental process
15 benefits by maximizing the contacting time
16 and mixing between a reagent or a sorbent
17
and also maximizing the residence time for
18
reaction and material collection
.
19
Reagent-based environmental controls, such
20
as limestone or lime-based wet FGD,
21
lime-based dry FGA ammonia or urea for SCR
22
and SNCR all exhibit similar tendencies
.
23
All things being equal, greater residence
24
time for mixing and providing for a large
Page 785
1
reaction vessel promote the removal of S02
2
or NOx depending on the process
. The
3
relationship between mercury and flue gas
4
and sorbent is anticipated to be similar .
5 The highest mercury removal will be
6
attained with generous time for contacting
7
and mixing and time for absorption
.
8
Question B, can you describe the
9 difference between a reagent and a
10
sorbent?
11
A sorbent is a material that has the
12
capacity to either absorb or adsorb
13
another material or compound . A reagent
14
is a substance used in a chemical reaction
15
to detect, analyze or produce another
16
substance .
17
MR . AYERS
: My question is this . We
18
are now moving into the area of ESP
19 performance, which you devote quite a lot
20
of your testimony to . So these questions,
21
obviously, all relate to that .
22
The first question is, so would you
23
agree with most chemical engineers that
24
sorbents are largely mass transfer limited
Page 786
Page 787
1 rather than being limited by both chemical
2 kinetics as well as mass transfer as is a
3 reagent like ammonia in an SCR?
4
MR . CICHANOWICZ : Yes .
5
MR . AYERS
: So it stands to reason
6 that mixing is the most important step,
7 correct .
8
MR . CICHANOWICZ : I believe so .
9 Yes .
10
MR . AYERS : And whatever you do to
11 improve mixing will improve performance?
12
MR . CICHANOWICZ
:
Yes .
13
MR . AYERS : Don't power plants
14 already use mixing devices to speed up
15 mixing?
16
MR . CICHANOWICZ
:
In many
17 applications, yes .
18
MR . AYERS : Okay . Thank you .
19
HEARING OFFICER TIPSORD :
Question
20 59 .
21
MR . CICHANOWICZ : The second
22 sentence, it is anticipated a large ESP
23 with extended lengths of inlet ductwork
24 and generous collecting plate surface area
1
will promote mercury removal while smaller
2
ESPs with limited surface area and inlet
3
ductwork residence time offer limited
4 mercury removal .
5
Question A, what is the basis for
6
this statement?
7
Large ESPs are generally accompanied
8
by extended inlet ductwork, which
9
frequently, but not always, is included as
10
part of an ESP replacement . Further,
11
large ESPs, of course, are built on large
12
plants which are less space constrained
13
than small units and the ductwork layout
14 may be more generous .
15
Question B
--
16
MR . AYERS : Could I ask a question
17
about that?
18
HEARING OFFICER TIPSORD : Sure .
19
MR . AYERS : Then I take it from what
20
you said that this passive forum, it is
21 anticipating that? It means that you
22
anticipate that ; is that correct? Or you
23
believe that or you opine that?
24
MR . CICHANOWICZ : I'm sorry, I need
Page 788
1
to
see the words .
2
MR . AYERS : It is in question 59 .
3 Do you see you use this very passive
4
construction, and I wanted to know who was
5
anticipating?
6
MR . CICHANOWICZ : It's my opinion .
7
MR . AYERS : Okay . So it is your
8
opinion, you are not presenting it as an
9
established fact that's widely accepted?
10
MR
. CICHANOWICZ
: That's true .
11
MR . AYERS : Is it your opinion --
12 and I think you have actually expressed
13
yourself on this question -- that mercury
14
capture occurs to a significant degree on
15
the surface of the ESP plates?
16
MR . CICHANOWICZ : Well, that's
17
question B . That's the next question .
18
MR . AYERS : Your version and mine
19
look a little different . Fine, if that's
20
question B, please answer that question
.
21
MR . CICHANOWICZ : My question B is,
22
is it your opinion that mercury capture
23
occurs to a significant degree on the
24
surface of ESP plates?
Page 789
Page 790
1
No . I concur that most mercury
2 capture occurs prior to migration of the
3 sorbent to the ESP plates with the bulk of
4 the mercury removal achieved in the
5 ductwork .
6
Question 60, is your theory --
7
HEARING OFFICER TIPSORD : Excuse me,
8 Mr . Harley had a follow-up .
9
MR . HARLEY : You testified that a
10 smaller facility may be constrained
11
because of ductwork
--
just may not be
12 able to provide a physical location for
13 all the necessary ductwork for the
14 residence time to maximize the
15 effectiveness of a sorbent ; is that
16 correct?
17
MR . CICHANOWICZ : Yes .
18
MR . HARLEY : Would a 90 megawatt
19 facility be generally regarded as a
20 smaller facility?
21
MR . CICHANOWICZ : Yes .
22
MR . HARLEY : Thank you .
23
HEARING OFFICER TIPSORD :
Question
24 No . 60 .
1
MR . CICHANOWICZ :
Is it your theory
2
that ESP size
plays
a
significant role in
3
influencing mercury capture based on any
4
other sources or information than the
5
references you have cited in figure 5-2 .?
6
First, please understand that I
7
offer figure 5-2 as an anecdotal
8
relationship, not a theory, as I clearly
9
stated in the overview to my testimony .
10
Figure 5-2 is simply a representation of
11
mercury removal for different ESP sizes
12
and, as we have discussed, is compounded
13 by other variables such as sorbent
14
injection rate and type, coal type, ESP
15
temperature, et cetera .
16
Further, I am not the only one who
17
is concerned that mercury removal may be
18
problematic for small SCA ESPs . This was
19
the reason for DOE initiating a second
20
series of sorbent injection demonstrations
21
following upon the early results from
22
Salem Harbor, Brayton Point and Pleasant
23
Prairie . A recent paper -- a recent
24 review paper by Thomas Feely of the DOE
Page 791
1
NETL stated, and I
quote, in
addition
2
Phase II
includes testing sorbents
at
3
several
power plants with either low
4
specific collection area, SCA, measured as
5
square feet collection area per 1,000
6
actual cubic feet per minute of gas flow,
7
close parenthesis, cold-side ESPs or
8
hot-side ESPs, both of which can be
9
difficult ACI applications
.
10
HEARING OFFICER TIPSORD
: Could you
11 repeat the reference again without the
12
quote, just the reference?
13
MR . CICHANOWICZ
: The reference is a
14 review paper by Thomas Feely Lee of the
15
DOE NETL
. And I don't --
it is called out
16
in my testimony, but I don't have the name
17
of it right here .
18
HEARING OFFICER TIPSORD
: Okay, just
19
double-checking .
20
MR . CICHANOWICZ
: I will identify
21
it .
22
HEARING OFFICER TIPSORD
: Mr . Ayers?
23
MR . AYERS : Mr
. Cichanowicz, we
24 previously discussed the paper by
Page 792
1
Professor
Clack that discussed mercury
2
capture in ESPs . And as part of that
3
discussion, you noted that his work shows
4 that mercury capture through convective
5
mass transfer to plates is rather small .
6
And as we discussed, Professor Clack's
7 work shows that the capture of mercury
8
from mass transfer to suspended particles
9
appear to be completed well within the
10
treatment time of even the smallest ESP in
11
Illinois so that there would be no
12
advantage of a large ESP over a small one
13
for mercury capture .
14
Do you have any other mechanisms to
15 offer of why -- that would explain why
16
larger ESPs might be more effective?
17
MR . CICHANOWICZ : Well, as I pointed
18
out, the larger the ESP comes with it, a
19 different ductwork layout that may be more
20 amenable to getting the mixing systems
21
installed and getting the kind of mixing
22
that you need very quickly . So we just
23
simply may need more residence time in
24
which to mix the sorbent . The sorbent, of
Page 793
1
course, has
to mix very quickly . And I
2 agree with everything that has been said
3
that the rate at which the material
4 absorbs mercury is probably not the
5
limiting step . And don't forget
6
Dr
. Clacks assumes and you focused,
7
Mr
. Ayers, on the features of the sorbent,
8 but it also assumed very good disbursement
9
of particles and essentially, basically,
10 good mixing through the uniform
11
distribution through the gas .
12
So the point is the inlet ductwork
13
array could be a factor
. And again
14
Dr
. Staudt three-quarters of the way
15
through his testimony in Springfield
16
talked about the inlet residence time at
17
Meramac as being a factor
. And it is .
18
That's a factor too
. That's on the front
19
end .
20
Now, on the back end we are
21 basically talking about the ESP being able
22 to pick up any residual carbon that may
23
not be collected .
24
MR . AYERS
: Do you have any data
Page 794
1
about the --
to support the
statement that
2
you are making about the ductwork
-- the
3
differences in ductwork between large and
4
small ESPs?
5
MR . CICHANOWICZ
: Well, that was the
6
purpose of those satellite images I showed
7 you this morning
. I don't have data to go
8
in and make measurements and come up with
9
calculated residence time .
10
MR . AYERS
: Those didn't show -- you
11
couldn't have used those pictures to
12
determine
-- to reach a conclusion that
13
large ESP plants have more
-- more --
yes,
14
more effective, more usable, more mercury
15 removing ductwork than the small, could
16 you? I don't see how you could have in
17
any way come to that
--
18
MR
. CICHANOWICZ
: I didn't quantify
19
all the different units
. That is
20
something that ideally could be done
. But
21
we just haven't done it .
22
I have been around I don't know how
23 many hundreds of power plants
. And
24
generally there is not a lot of room
Page 795
1
between the last heat exchanger that's
2
there that recovers
heat in
the
air heater
3
and the inlet ESP, particularly in older
4
plants . They just didn't make them that
5
way . There is not a lot of room .
6
So when I showed the satellite
7
images of the plants that have the newer
8
ESPs, there was a lot of ductwork .
9
St . Clair, Meramac, Brayton Point, they
10
all had some fairly optimizing duct runs .
11 So by looking at it and having been around
12
hundreds of power plants, I feel pretty
13
comfortable that those offer good mixing
14
conditions .
15
Now, when I showed you Will County
16
and some of those, no, I couldn't see what
17
was going on behind the boiler building
.
18 And that work would have to be done .
19
All I am saying is that it is open
20
-- it is an open item .
21
HEARING OFFICER TIPSORD : For the
22
record, the photos we are talking about
23
from this morning are Exhibits 89 through
24
95 .
Page 796
1
MR . AYERS : I
detect a
rather large
2
shift in the view expressed between your
3 testimony and your comments today about
4
the role of the ESP versus the ductwork
5 ahead of the ESP . Would you say that that
6
was true?
7
MR . CICHANOWICZ : No . Let me see if
8
I can find my three-page introduction to
9
my testimony . Well, it is not in the
10
introduction . But inlet ductwork -- we
11
can do a word search on my testimony . And
12
you see it associated perhaps not with
13
every station on the ESP SCA . But you are
14
not suggesting this is the first time I am
15
mentioning it today, Mr . Ayres, because it
16
is in the testimony .
17
MR . AYERS : Wouldn't you have to
18
say, though, based on the fact that the
19
only real evidence offered is the pictures
20
from the sky, that this theory that larger
21 units are more able to capture mercury
22 because of the greater ESP ductwork has to
23
be considered speculation at this point?
24
MR . CICHANOWICZ : Well, you know,
Page 797
1
you are welcome
to -- it
could be, yes, it
2
is speculation
. I mean, I have --
I put
3
up the chart
. And I say this was an
4
anecdotal relationship . And I --
I have
5 not used the word theory
. I have gone out
6 of my way to separate using the word
7
theory with this
.
8
All I'm saying was I laid out the
9
plots and this is what it's suggesting and
10
here are some possible reasons why it
11
might be true
. If you want to call that
12
speculation, that's fine .
13
To an extent, it is . I don't have
14
detailed data
. But again that requires
15
going through all ten plants in Illinois
16
and, essentially, getting in a look at
17 what the inlet ductwork looks like and
18
doing some calculations
. And that hasn't
19
been done .
20
HEARING OFFICER TIPSORD :
21
Mr
. Nelson, you had a question earlier
.
22
Do you still have a question?
23
MR . NELSON : Just quickly
. You
24
mentioned the quote from Mr
. Feely of DOE
Page 798
1 NETL referring to the need to look at a
2
couple of the smaller ESPs in the program
3
of which the Crawford site is one . My
4
question is, he wasn't referring to lower
5
mercury removal in small ESPs, was he?
6
But instead the concern or the possibility
7
was that particulate emissions or opacity
8
increases in smaller ESPs might be
9
something they wanted to look at, would
10
that be what he was referring to?
11
MR . CICHANOWICZ : I don't know,
12
Mr . Nelson . How can it not be the same?
13
Because if you could
--
if you had a
14 particulate matter breakthrough problem
15 not unlike with SNCR, you can cut back on
16
the reagent injection and take a lower
17
mercury removal . It is related .
18
MR . NELSON : I thought that we have
19
established that theoretically higher SCA
20
doesn't give you higher mercury removal .
21
But you can't point to a single piece of
22
data from a low SCA plant that shows lower
23
mercury removal . But it is just
24
conjecture . Don't you think that opacity
Page 799
1
might really be the issue then, not
2
mercury? Aren't they separate issues?
3
MR . CICHANOWICZ : I don't think so
4 because if you have an opacity problem,
5
one means of handling it is to cut down on
6
the sorbent injection mass rate . If you
7
are having problems collecting sorbent
8
that comes in, one possible issue in
9 addition to the other things that you
10
might be able to do is simply to reduce
11
the mass injected . And everybody's curves
12
in the world, including yours, show that
13 mercury removal is proportional to carbon
14
sorbent injection . So I think they are
15
related .
16
MR . NELSON
: I don't want to get
17
ahead of some of the questions . But have
18 you seen any data that show increased
19
opacity, for example, with respect to
20
increased sorbent injection?
21
MR . CICHANOWICZ : Well the most
22
recent ADA quarterly report that is on the
23
website for the Conesville Station reports
24
opacity problems with a couple of
Page 800
Page 801
1
sorbents . And it basically
-- we can have
2
this here tomorrow, if you would like
. It
3
basically states that it sounds like all
4
the others, that some opacity spikes are
5
noted from a sorbent injection . And it is
6
not clear what the sources are
.
7
But the first quarterly report from
8
ADA which is on the website now for
9
Conesville reports opacity problems with
10 two sorbents .
11
MR . NELSON
: And that report is not
12
in the record that you are citing?
13
MR . CICHANOWICZ : I believe it was
14
referenced in the table that I handed out
15
this morning because it was
-- it is a
16 Conesville application
. That came up
17
after I filed my testimony
. Okay . And so
18
it is in the record as part of the table
19
that I submitted and it was on the disk
20
that was submitted .
21
MR . NELSON
: And that plant burns a
22
high sulfur bituminous coal?
23
MR . CICHANOWICZ
: Yes, it does . But
24
your question was, essentially, show me
1 where there has been a sorbent
2 breakthrough problem with the ESP . And
3
that's what I was answering .
4
MR . NELSON : Without seeing the
5
document, I can't comment .
6
HEARING OFFICER TIPSORD : Mr . Ayers?
7
MR . AYERS : Just a follow-up on
8
that . Don't power plants often have
9
opacity problems?
10
MR . CICHANOWICZ : None of my
11
clients .
12
MR . AYERS : You might want to look
13
around the table there .
14
MR . CICHANOWICZ
: From time to time,
15
there is a difference between, you know,
16
an occasional opacity problem and
17
something that's somewhat persistent .
18
MR . AYERS : You know, it sounds
19
like, yes, there have been -- may have
20 been an occasional opacity problem that
21 happened at the time there was a sorbent
22
injection test going on .
23
But without looking at the pattern
24
of capacity violations or exceedences for
Page 802
1 the given unit through the year without
2
the test going on, it is a little hard to
3
say whether it has anything to do with the
4
injection, isn't it?
5
MR . CICHANOWICZ : Yes, that's true .
6 Again I am just reporting that the latest
7 report put on the ADA website or the DOE
8
website for Conesville addressed possible
9
-- not possible -- opacity issues, but
10
wasn't clear what they were attributable
11
to . That was one of the conclusions of
12
the quarterly testing period, that they
13
were going to look at the causes of that .
14
MR . AYERS : It would be a natural
15 human tendency to notice it a lot more at
16 that moment when you thought one of the
17
potential problems here was opacity,
18
wouldn't it?
19
MR . CICHANOWICZ : Repeat that,
20
please .
21
MR . AYERS : Wouldn't it be a natural
22 human tendency to notice the opacity
23 violation that happened at the time you
24
were testing the sorbent injection a lot
Page 803
Page 804
1 more than you noticed the ones that
2 happened at other times because you were
3 looking for it?
4
MR . CICHANOWICZ
: I don't know that
5 that's a qualitative -- that's something
6 that you read on an opacity meter .
7
MR . AYERS : No, it is not something
8 you read on an opacity meter .
9
HEARING OFFICER TIPSORD : Mr . Zabel?
10
MR
. ZABEL
: Do you have a COM on the
11 unit at Conesville, do you know?
12
MR . CICHANOWICZ : I don't know .
13
MR . ZABEL : Would you expect they
14 do?
15
MR . CICHANOWICZ : I would expect
16 they do .
17
MR . ZABEL : And if they had one,
18 they don't have to notice it, the meter is
19 going to record it, will it not?
20
MR . CICHANOWICZ : I believe so, yes .
21
HEARING OFFICER TIPSORD : Okay .
22 Mr . Nelson?
23
MR . NELSON : Sid Nelson, just
24 quickly . At Conesville were they
1
injecting brominated carbon or plain
2
carbon when this happened?
3
MR . CICHANOWICZ
: I cannot remember
.
4
But it is in the quarterly report
.
5
MR . NELSON
: Because it was a high
6
sulfur bituminous coal, would you suspect
7 that it may not have been a brominated
8
carbon?
9
MR
. CICHANOWICZ
: It had a new name
10
Darco Hg with some letters on it I had
11
never seen before
. So I think it is a new
12
special high sulfur .
13
MR . NELSON
: So this is not a
14
commercially available sorbent? Are they
15
testing what they call high S03 sorbents
16
at this plant?
17
MR
. CICHANOWICZ
: I believe that's
18
the first of the exercise, yes
.
19
MR . NELSON
: So this is not a
20
commercially available sorbent that has
21
been tested in all these other plants that
22 have shown opacity?
23
MR
. CICHANOWICZ : It's probably a
24
commercial --
it's probably an
Page 805
1
experimental sorbent and it
probably
2
hasn't been
tested on those fronts .
3
MR
. NELSON
: The injection rate at
4
Conesville when they saw this, is that
5
injection rate much, much higher than is
6
required for 90 percent mercury control at
7
subbituminous plants that you have here in
8
Illinois? Do you recall what the
9
injection rate was when they had the
10
opacity?
11
MR . CICHANOWICZ
: I don't recall it
12
is on the DOE website
. And we can
13
probably access it tonight if you wish
. I
14 meant to have it here as a handout, but we
15
didn't have time to pull it out
.
16
MR . NELSON
: Thank you .
17
HEARING OFFICER TIPSORD
: It would
18 be helpful
. I thought I had understood
19
you to say it is on the CD
. Did I
20
misunderstand that?
21
MR . CICHANOWICZ
: It is on the CD .
22
HEARING OFFICER TIPSORD
: Although
23
we don't physically have a copy, it is in
24
the Board's records
.
Page 806
1
MR .
CICHANOWICZ : Yes .
2
HEARING OFFICER TIPSORD
: Can we get
3
through question 61?
4
MR
. AYERS : We will give it a try
.
5
MR . CICHANOWICZ
: 61, on page 34 you
6
state that at Detroit Edison's Monroe
7 power plant, Hg removal with halogenated
8 AC was less than the measured
-- less than
9
that measured with conventional, with
10 highest removal being approximately
11
83 percent, referencing Sjostrom 2006,
12
slide 24
. Was the 83 percent removal
13
attributable to the sorbent?
14
The Hg removal described is, quote,
15
change in outlet mercury concentration,
16 unquote, which if only vapor phase mercury
17
is measured implies vapor phase mercury
18
removal as a consequence to the sorbent
.
19
However, I was not able to corroborate
20
this statement with data in the quarterly
21
report describing the same text, which
22
reports, quote, vapor-phase mercury
23
removal, unquote, as measured from the ESP
24
inlet to the outlet .
Page 807
1
Figure five in
the quarterly report
2
for April to June 2005 from ADA addressing
3
this test reports these data at a higher
4 mercury removal than the new slide,
5 perhaps accounting for the inherent vapor
6 phase mercury removal across the ESP .
7 That's my read answer to get my thoughts
8
straight .
9
But this data point is the one
10
change that I had this morning in that I
11
did read the slide wrong . It was just the
12
incremental mercury removal, not the total
13 mercury removal
. And I went back to the
14 quarterly report and tried to sort that
15
out . I put new data on the slide which I
16
believe is -- is more representative .
17
But the way it is reported, I am
18
still not sure it is the total mercury
19
removal
. But I did try to correct this .
20
HEARING OFFICER TIPSORD : Okay . A .
21
MR . CICHANOWICZ : According to the
22
next slide in the referenced presentation,
23
that shows the total removal including
24
cobenefit, is total removal close to
Page 808
Page 809
1 90 percent? Yes, it is
. That's the data
2
that I corrected .
3
HEARING OFFICER TIPSORD : It is
4 almost 5 :00 o'clock and it has been a long
5
afternoon . So let's go ahead and recess
6 for today . We will start at 9 :00 a .m
.
7 tomorrow .
We will go from 9 :00 to about
8 10 :30 and recess until 1 :00 clock for a
9 board meeting
.
10
(Whereupon the
11
proceedings in the
12
above-entitled cause
13
were adjourned until
14
August 17, 2006, at
15
9 :00 a.m.)
16
17
18
19
20
21
22
23
24
1
STATE OF
ILLINOIS )
SS :
2 COUNTY OF LAKE
)
3
I, Cheryl L . Sandecki, a Notary
4
Public within and for the County of Lake
5
and State of Illinois, and a Certified
6
Shorthand Reporter of the State of
7
Illinois, do hereby certify that I
8
reported in shorthand the proceedings had
9 at the taking of said hearing and that the
10
foregoing is a true, complete, and correct
11
transcript of my shorthand notes so taken
12
as aforesaid, and contains all the
13
proceedings given at said hearing .
14
15
16
Notary Public, Cook County, Illinois
C .S .R . License No . 084-03710
17
18
19
20
21
22
23
24
Page 810
