811
    1
    ILLINOIS POLLUTION CONTROL BOARD
    2
    August 17th, 2006
    3
    IN THE MATTER OF:
    )
    4
    )
    PROPOSED NEW 35 ILL. ADM.
    ) R06-25
    5
    CODE 225 CONTROL OF EMISSIONS )
    (Rulemaking-Air)
    )
    6
    FROM LARGE COMBUSTION SOURCES )
    (MERCURY),
    )
    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 17th day of August, A.D.,
    18
    2006, commencing at 9:00 a.m.
    19
    20
    21
    22
    23
    24
    812
    1
    A P P E A R A N C E S:
    2
    SCHIFF, HARDIN, LLP
    3
    6600 Sears Tower
    Chicago, Illinois 60606
    4
    (312) 258-5646
    BY: MS. KATHLEEN C. BASSI
    5
    MR. STEPHEN J. BONEBRAKE
    MR. SHELDON A. 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
    813
    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
    77 West Wacker Drive
    11
    Suite 4100
    Chicago, Illinois 60601-1815
    12
    (312) 849-8100
    BY: MR. JEREMY R. HOJNICKI
    13
    14
    15
    ILLINOIS POLLUTION CONTROL BOARD:
    16
    Ms. Marie Tipsord, Hearing Officer
    Ms. Andrea S. Moore, Board Member
    17
    Mr. G. Tanner Girard, Acting Chairman
    Mr. Anand Rao, Senior Environmental
    18
    Scientist
    Mr. Nicholas J. Melas, Board Member
    19
    Mr. Thomas Fox, Board Member
    Mr. Thomas Johnson, Board Member
    20
    21
    22
    23
    24
    814
    1
    HEARING OFFICER TIPSORD: Good
    2
    morning, ladies and gentlemen. This is
    3
    day four. And we are continuing with the
    4
    testimony of Mr. Cichanowicz. And I
    5
    believe we are on question No. 62. Does
    6
    anybody have any preliminary matters
    7
    before we start?
    8
    MR. ZABEL: No.
    9
    HEARING OFFICER TIPSORD: I do want
    10
    to remind everyone we have a board meeting
    11
    here in Chicago today. So we will go
    12
    until 10:30. And at 10:30 we will break
    13
    and we will come back at 1:00. And if it
    14
    is okay with everybody, we are going to
    15
    come back at
    16
    1:00 o'clock. If we can do a break around
    17
    quarter to 3:00 or so, then we might go
    18
    until 5:30 tonight depending upon where a
    19
    natural break might occur. But to give
    20
    you a heads up, 5:30 may be where we go.
    21
    MR. ZABEL: I am worried about the
    22
    travel schedules of some of our witnesses.
    23
    If we go an extra half hour, that might
    24
    help.
    815
    1
    HEARING OFFICER TIPSORD: With that
    2
    in mind question, No. 62. And I remind
    3
    you you are still under oath.
    4
    MR. CICHANOWICZ: Question 62, you
    5
    state on page 34 of your testimony that
    6
    public pronouncements by suppliers of
    7
    bromine that 100 percent price increases
    8
    in bromine are possible further suggest
    9
    that prices may not be stable. It should
    10
    be noted there is only one source of
    11
    bromine in U.S., saline aquifers in
    12
    Arkansas, so transportation and supply
    13
    conditions could be constrained. What is
    14
    the basis for this statement that
    15
    transportation could be constrained?
    16
    The availability of any bulk
    17
    material at a single source can lead to
    18
    bottlenecks in supply unless a wide
    19
    variety of transportation options are
    20
    available. Given the coal transportation
    21
    bottlenecks experienced in the U.S. in
    22
    2005 and 2006, particularly with small
    23
    generators that are captive to a single or
    24
    limited number of transportation sources,
    816
    1
    it is important to ensure that multiple
    2
    transportation options are open to bromine
    3
    suppliers.
    4
    HEARING OFFICER TIPSORD: Will we
    5
    have follow-up, Mr. Ayers?
    6
    MR. AYERS: Yes. Mr. Cichanowicz,
    7
    are you an expert in the area of bromine
    8
    manufacture and the transportation?
    9
    MR. CICHANOWICZ: No.
    10
    MR. AYERS: So what is the basis for
    11
    your statement that prices will increase
    12
    by a hundred percent.
    13
    MR. CICHANOWICZ: There was a couple
    14
    of quotes or statements that I basically
    15
    pulled off the Internet with some
    16
    representatives of some companies
    17
    basically stating that the price
    18
    escalation could be on the way.
    19
    MR. AYERS: Are you sure it was for
    20
    bulk purified bromine rather than bromine
    21
    derived chemicals such as fire retardants,
    22
    which have seen substantial increases?
    23
    MR. CICHANOWICZ: My understanding
    24
    was it was for bulk bromine.
    817
    1
    MR. AYERS: Thank you.
    2
    HEARING OFFICER TIPSORD: Mr. Nelson?
    3
    MR. NELSON: Sid Nelson. Are you
    4
    aware that Dow Chemical produces bromine
    5
    in Michigan.
    6
    MR. CICHANOWICZ: No.
    7
    MR. NELSON: How many major bromine
    8
    suppliers are there in the U.S.?
    9
    MR. CICHANOWICZ: I don't know how
    10
    many there are. The basis of my statement
    11
    is on -- with my knowledge or information
    12
    that the sources -- the majors sources of
    13
    bromine are in two adjacent counties in
    14
    Arkansas. And that's the basis of it.
    15
    MR. NELSON: There are multiple
    16
    suppliers that get bromine from that
    17
    deposit; is that correct? It is not just
    18
    one producer?
    19
    MR. ZABEL: I am objecting. He is
    20
    testifying.
    21
    HEARING OFFICER TIPSORD: Mr. Zabel,
    22
    if he is that correct we -- and Ms. Bassi
    23
    has been guilty of that as well.
    24
    MS. BASSI: Sorry.
    818
    1
    HEARING OFFICER TIPSORD: In
    2
    fairness --
    3
    MR. ZABEL: I will object to her
    4
    next time.
    5
    HEARING OFFICER TIPSORD: In
    6
    fairness.
    7
    MR. CICHANOWICZ: Yes, I believe
    8
    there are multiple suppliers of bromine.
    9
    MR. NELSON: Thank you.
    10
    MR. AYERS: I have a further
    11
    follow-up.
    12
    HEARING OFFICER TIPSORD: Mr. Ayers?
    13
    MR. AYERS: We have an exhibit that
    14
    we would like to introduce, which would be
    15
    106.
    16
    HEARING OFFICER TIPSORD: I have
    17
    before me a document titled "Bromine Data
    18
    in Thousand Metric Tons of Content Unless
    19
    Otherwise Noted" prepared by Phyllis A.
    20
    Lyday.
    21
    MR. AYERS: Yes.
    22
    HEARING OFFICER TIPSORD: No other
    23
    information on who --
    24
    MR. AYERS: Madam Chairwoman, this
    819
    1
    is from the U.S. Geological Survey. It
    2
    says USGS.gov. And on the other side at
    3
    the bottom you see the citation "U.S.
    4
    Geological Survey, Mineral Commodity
    5
    Summaries 2006."
    6
    HEARING OFFICER TIPSORD: I have the
    7
    two-sided bromine and then the second.
    8
    MR. AYERS: Yes.
    9
    HEARING OFFICER TIPSORD: The first
    10
    one is pages 40 and 41.
    11
    MR. AYERS: Of the U.S. Geological
    12
    Survey, Mineral Commodity Summaries,
    13
    January 2006.
    14
    HEARING OFFICER TIPSORD: If there
    15
    is no objection, we will mark this as
    16
    Exhibit 106. Seeing none, it is
    17
    Exhibit 106.
    18
    MR. AYERS: According to the page
    19
    that says bromine at the top -- well, the
    20
    one that says Phyllis Lyday at the bottom,
    21
    page 40, what happened the price trend
    22
    since 2001 for bromine?
    23
    MR. CICHANOWICZ: It has gone up
    24
    from 67 to 81.
    820
    1
    MR. AYERS: And it has gone up all
    2
    years.
    3
    MR. CICHANOWICZ: Yes.
    4
    MR. AYERS: And wasn't the 2002
    5
    price higher than the price in 2005?
    6
    MR. CICHANOWICZ: Yes.
    7
    MR. AYERS: According to this
    8
    report, bromine is available in the U.S.
    9
    from Michigan as well as Arkansas and
    10
    abroad from Israel and other countries; is
    11
    that correct?
    12
    MR. CICHANOWICZ: I haven't read it,
    13
    but it looks like the first paragraph says
    14
    that.
    15
    MR. AYERS: Thank you. Would you be
    16
    concerned that we are running out of
    17
    bromine if you looked at this chart?
    18
    MR. CICHANOWICZ: No. I'm not
    19
    concerned we are running out of bromine
    20
    and the annual production is on this
    21
    chart. Yes, that's in excess of 200,000
    22
    tons per year. And when you look at the
    23
    amounts, it is basically not very much.
    24
    If you take the amount of activated carbon
    821
    1
    -- halogenated carbon and put it into the
    2
    precipitators in Illinois at the TTBS
    3
    level, you get a plus one percent of the
    4
    annual production.
    5
    So in terms of magnitude, it's not.
    6
    But my concern was on transportation. And
    7
    I say that because, you know, the power
    8
    industry always seems to be the guy at the
    9
    end of the transport sector that gets the
    10
    fuzzy angle all the time. The coal
    11
    deliveries are always made because of
    12
    limited transportation. Tromine is a
    13
    compound in Wyoming that some people are
    14
    using sparingly and perhaps may evolve
    15
    into FGD control. And the transport
    16
    distances are great.
    17
    And it is not so much price, but it
    18
    is bottlenecks in supply. And it was the
    19
    only purpose for pointing this out. If
    20
    there are alternative sources in Michigan,
    21
    that's great.
    22
    MR. AYERS: We have a second item
    23
    that we -- I think it was handed out --
    24
    which says "Mineral Information Institute"
    822
    1
    at the top.
    2
    HEARING OFFICER TIPSORD: Yes. And
    3
    this we will mark as Exhibit 107 if there
    4
    is no objection. Seeing none, it is
    5
    Exhibit 107.
    6
    MR. AYERS: The first sentence after
    7
    the sources, I take it you agree with the
    8
    sentence that bromine sources are --
    9
    MR. ZABEL: I am sorry, Mr. Ayers, I
    10
    cannot hear you.
    11
    MR. AYERS: This is not usually a
    12
    problem. Under the word sources --
    13
    MR. CICHANOWICZ: Sources or world
    14
    resources?
    15
    MR. AYERS: No, just sources, you
    16
    may have already answered this question.
    17
    I just wanted you to look at the first
    18
    sentence there and read that and let us
    19
    know whether you agree with it. But I
    20
    think you said you agree with it, that the
    21
    resources are basically unlimited.
    22
    MR. CICHANOWICZ: I accept the first
    23
    statement on that paragraph.
    24
    MR. AYERS: That's all my questions.
    823
    1
    HEARING OFFICER TIPSORD: Mr. Nelson?
    2
    MR. NELSON: Just one quick
    3
    question. Is there a need for the power
    4
    plant to actually get bromine or would the
    5
    bromine go to the carbon producer, which
    6
    would brominate the carbon and the
    7
    distribution would simply be bulk trucks
    8
    to the various utilities.
    9
    MR. CICHANOWICZ: I am worried about
    10
    the fact that, yes, the producers are the
    11
    ones who are having a problem. But you
    12
    know it -- it always ends up in the lap of
    13
    the guy who is trying to make it.
    14
    MR. NELSON: Is it quite possible to
    15
    actually put the brominate production
    16
    facilities in Arkansas or Michigan?
    17
    MR. CICHANOWICZ: I imagine so.
    18
    MR. ZABEL: I believe he answered 63
    19
    in response to Mr. Ayres.
    20
    MR. AYERS: Yes, I think that's
    21
    right.
    22
    HEARING OFFICER TIPSORD: Question
    23
    64.
    24
    MR. CICHANOWICZ: If it is only a
    824
    1
    few percent, won't any cost impact from
    2
    the price changes you predict for bromine
    3
    be fairly muted?
    4
    Yes, the cost may be muted. But
    5
    again my concern was for the limited
    6
    physical source in transportation
    7
    constraints. And with multiple suppliers
    8
    and sources, that is mitigated as well.
    9
    MR. AYERS: I think question 65 has
    10
    been asked and answered.
    11
    HEARING OFFICER TIPSORD: Okay.
    12
    Question 66.
    13
    MR. CICHANOWICZ: On page 36 of your
    14
    testimony, you state that "the role of
    15
    coal blending on mercury removal
    16
    performance of ACI with an ESP can be
    17
    inferred by comparing data from Ameren's
    18
    Meramac and Detroit Edison's Monroe
    19
    Station. Both of the tested units
    20
    featured ESPs of similar SCA but fired
    21
    different fuels. Meramac exclusively
    22
    fires PRB, while Monroe fires PRB with a
    23
    40 percent blend of bituminous coal. Does
    24
    this demonstrate that fuel characteristics
    825
    1
    play a very significant role in
    2
    performance?
    3
    Yes, these results show that fuel
    4
    type is important.
    5
    MR. AYERS: I think Nos. 67 and 68
    6
    have been responded to by the tables and
    7
    exhibits that have been provided
    8
    yesterday.
    9
    HEARING OFFICER TIPSORD: Which were
    10
    85, 86 and 87 I believe?
    11
    MR. AYERS: Yes, that's right. But
    12
    we do have some questions that go to that.
    13
    Mr. Cichanowicz, yesterday you
    14
    testified that larger ESPs were associated
    15
    with longer lengths of ductwork, did you
    16
    not?
    17
    MR. CICHANOWICZ: My statements in
    18
    the satellite images suggest that large
    19
    ESPs tend to have longer inlet ductwork.
    20
    MR. AYERS: That's why you speculate
    21
    that while ESP size does not seem to
    22
    significantly impact the mercury removal
    23
    in the ESP, the longer duct runs
    24
    associated with ESP may; is that right?
    826
    1
    MR. CICHANOWICZ: The longer duct
    2
    runs associated with larger ESPs may,
    3
    that's correct.
    4
    MR. AYERS: And you testified that
    5
    you had no specific data from Illinois or
    6
    elsewhere to support this speculation,
    7
    correct?
    8
    MR. CICHANOWICZ: That's correct. I
    9
    do not have quantitative data defining
    10
    ductwork runs and dimensions.
    11
    MR. AYERS: Are you aware of the
    12
    review of plant layouts conducted by the
    13
    Illinois EPA for this proceeding?
    14
    MR. CICHANOWICZ: I did not review
    15
    it.
    16
    MR. AYERS: Are you aware that
    17
    Waukegan 17 has an ESP with an SCA of
    18
    about 131, a small SCA?
    19
    MR. CICHANOWICZ: I believe that was
    20
    one of the images from yesterday.
    21
    MR. AYERS: Do you know what the
    22
    approximate length of the duct between the
    23
    air preheater and the ESP at Waukegan 17
    24
    was found to be by Illinois EPA?
    827
    1
    MR. CICHANOWICZ: No, I do not.
    2
    MR. AYERS: Would a hundred feet
    3
    seem possible?
    4
    MR. CICHANOWICZ: That would sound
    5
    like a longer number than I would expect.
    6
    But I did not go to the plant.
    7
    MR. AYERS: Do you know what the SCA
    8
    is for Will County No. 4 for that ESP?
    9
    MR. CICHANOWICZ: No.
    10
    MR. AYERS: Or what the approximate
    11
    length of the duct is between the air
    12
    preheater and the ESP in Will County 4?
    13
    MR. CICHANOWICZ: No, I do not.
    14
    MR. AYERS: Would 80 feet seem
    15
    possible?
    16
    MR. CICHANOWICZ: It would seem
    17
    longer than I would expect from my
    18
    experience. But I have not been to the
    19
    site.
    20
    MR. AYERS: Is the Will County 4
    21
    than a larger boiler than Waukegan 17?
    22
    MR. CICHANOWICZ: From memory I
    23
    can't reflect that.
    24
    MR. AYERS: Is it a newer ESP than
    828
    1
    Waukegan?
    2
    MR. CICHANOWICZ: I don't know.
    3
    MR. AYERS: Did you know that
    4
    Hennipen 2 with ESP with SCA of 125 has
    5
    about 100 feet of ductwork between the air
    6
    preheater and the ESP?
    7
    MR. CICHANOWICZ: No.
    8
    MR. AYERS: So isn't it really true
    9
    that the length of the ductwork is
    10
    determined entirely by site specific
    11
    characteristics and can't be related to
    12
    ESP size?
    13
    MR. CICHANOWICZ: I would have to
    14
    review the results of the Illinois study
    15
    before I can come to a conclusion like
    16
    that.
    17
    MR. AYERS: But the results as we
    18
    have discussed them, they would be
    19
    inconsistent with the hypothesis that you
    20
    advanced in your testimony, though,
    21
    correct?
    22
    MR. CICHANOWICZ: If those results
    23
    held up and I were to review them, they
    24
    would be somewhat inconsistent.
    829
    1
    MR. AYERS: Can we turn to
    2
    figure 5-2?
    3
    MR. GIRARD: Mr. Ayers, before you
    4
    do that, could I just ask a question? It
    5
    probably goes to the agency. If there is
    6
    a study of Illinois power plants that has
    7
    a spreadsheet with ESP size and duct
    8
    length and other information, is that in
    9
    the record already?
    10
    MR. KIM: I believe the document --
    11
    John Kim for the Illinois EPA. I believe
    12
    the document that has the information that
    13
    we are referring to is the document that
    14
    was provided in two forms to the Board,
    15
    one in a redacted form for security
    16
    reasons and one in a complete form for
    17
    public viewing.
    18
    The document that is -- that has
    19
    been requested to be withheld from public
    20
    view has I believe those figure -- the
    21
    relevant figures, schematics and distances
    22
    that we are making reference to.
    23
    HEARING OFFICER TIPSORD: And that
    24
    was in the post-hearing comment provided
    830
    1
    to the Board and it is being held
    2
    confidential in our clerk's office.
    3
    MR. KIM: That's correct.
    4
    MR. GIRARD: So the information is
    5
    on a plant-by-plant basis rather than
    6
    being on some spreadsheet where you have
    7
    pulled it all together?
    8
    MR. KIM: That's correct. The
    9
    manner in which that was compiled, my
    10
    understanding is -- I think we testified
    11
    to this at the first hearing -- was that
    12
    copies I believe had already been provided
    13
    to the utilities shortly after the
    14
    Illinois EPA inspectors compiled the
    15
    information. It was just the complete
    16
    report itself was not provided to the
    17
    board until the post-hearing comment
    18
    period.
    19
    MR. GIRARD: Thank you.
    20
    MR. AYERS: We would like to turn to
    21
    figure 5-2 if we might.
    22
    HEARING OFFICER TIPSORD: And,
    23
    Mr. Ayers, you are going to be specific --
    24
    MR. AYERS: Yes, 5-2. I'm sorry I
    831
    1
    think one of the views used was
    2
    Exhibit 87.
    3
    HEARING OFFICER TIPSORD: Which is
    4
    figure 5-2 in additional data, Exhibit 87?
    5
    MR. AYERS: Yes. Mr. Cichanowicz,
    6
    would it be fair to say that the data in
    7
    this figure provides the basis for your
    8
    hypothesis that ESP size could be related
    9
    to mercury removal?
    10
    MR. CICHANOWICZ: The data in this
    11
    figure plus again my observations of the
    12
    inlet ductwork for some of the modified
    13
    ESPs and looking at other demonstrations,
    14
    again that is the basis.
    15
    MR. AYERS: So could we go through
    16
    in some -- question 69 and some of the
    17
    additional questions that we would like to
    18
    ask all address the data represented in
    19
    this table. We would like to go through
    20
    that in some detail. I think a way to
    21
    start is just for you to answer question
    22
    69 and then we will go from there.
    23
    MR. CICHANOWICZ: 69, you state on
    24
    page 38 of your testimony that "in
    832
    1
    summary, although figure 5-2 mixes
    2
    variables on one chart, sorbent type,
    3
    duration of test, mass injection rate and
    4
    ESP design, the resultant trend suggests
    5
    that major ESP upgrades are required to
    6
    derive 90 percent mercury removal." Does
    7
    that statement take into consideration
    8
    these and other critical factors such as
    9
    fuel type?
    10
    No. The plot represented in
    11
    figure 5-2 represents a global overview of
    12
    the results achieved in a large number of
    13
    demonstrations, displayed according to one
    14
    ESP design feature.
    15
    Question A, do you agree that sulfur
    16
    and coal type have significant effects on
    17
    mercury capture?
    18
    Yes, coal type and sulfur content
    19
    are important in determining mercury
    20
    capture.
    21
    Question B, does this figure in any
    22
    way distinguish those effects from others?
    23
    No.
    24
    Question C, do not bituminous coals
    833
    1
    tend to have higher sulfur levels than PRB
    2
    coals? Yes.
    3
    D, if so, do bituminous coals not
    4
    achieve as much removal at the same
    5
    sorbent rate?
    6
    The relationship between coal type,
    7
    sorbent type and mercury removal is
    8
    application specific. It is generally
    9
    true that as sulfur content of coals
    10
    increases, as it does with bituminous
    11
    coals, with all factors being equal, the
    12
    higher SO3 generated by combustion will
    13
    restrict Hg removal compared to a
    14
    subbituminous, particularly a PRB, coal.
    15
    E, do you agree that sulfur and coal
    16
    type have significant effects on the
    17
    sizing of an ESP? All factors being
    18
    equal, yes.
    19
    F, does this figure in any way
    20
    distinguish those effects from others?
    21
    No, it does not.
    22
    G, are not the ESP --
    23
    MR. AYERS: I would like to
    24
    interject at this point with a question.
    834
    1
    MR. CICHANOWICZ: Pardon?
    2
    MR. AYERS: I am sorry, may I
    3
    interject a question at this point? Would
    4
    the fuel type term determine whether or
    5
    not halogenated or other sorbents were the
    6
    best ones to use? I should say would the
    7
    fuel type?
    8
    MR. CICHANOWICZ: Yes, they would.
    9
    MR. AYERS: Okay. Thank you.
    10
    MR. CICHANOWICZ: G, are not the
    11
    ESPs designed for bituminous coals
    12
    generally smaller than those for PRB
    13
    coals? All factors being equal, yes.
    14
    MR. AYERS: Now, could I ask a few
    15
    questions to follow up on that? This
    16
    focuses on the data points in the table.
    17
    First, are data points 4, 8 and 12, which
    18
    are in the bottom middle, if you will of
    19
    the chart, close together, are they the
    20
    results of tests with untreated carbon on
    21
    western coals?
    22
    MR. CICHANOWICZ: Test 4 is Leland
    23
    Olds.
    24
    MR. AYERS: Leland Olds is 4.
    835
    1
    Pleasant Prairie is 8. And Coal Creek is
    2
    12.
    3
    MR. CICHANOWICZ: If you don't mind,
    4
    I would like to read through just to make
    5
    sure.
    6
    MR. AYERS: Sure, of course.
    7
    MR. CICHANOWICZ: Four is Leland
    8
    Olds lignite fired and that is not a
    9
    halogenated sorbent test. Eight is
    10
    Pleasant Prairie, PRB coal. That is not
    11
    halogenated sorbent. Twelve is Coal
    12
    Creek. It's a TOXECON, which is a little
    13
    bit different than a conventional ESP and
    14
    North Dakota lignite that is not a
    15
    halogenated sorbent.
    16
    HEARING OFFICER TIPSORD: Does that
    17
    mean it is not treated -- it is not a
    18
    treated carbon sorbent?
    19
    MR. CICHANOWICZ: My answer is it is
    20
    not treated. Correct.
    21
    HEARING OFFICER TIPSORD: Then I
    22
    have a question before we go any further.
    23
    Yesterday I asked you if the legend that
    24
    was on Exhibit 86 carried to 87 and you
    836
    1
    indicated that was correct. It looks to
    2
    me that a pink box is indicated as a
    3
    treated carbon sorbent.
    4
    MR. CICHANOWICZ: Okay. That's my
    5
    mistake. That's my mistake. What I had
    6
    meant was the descriptors and the numbers
    7
    were the same. I incorrectly answered
    8
    your question yesterday, Madam Chairwoman.
    9
    HEARING OFFICER TIPSORD: So the
    10
    little box with pink in it does not mean
    11
    the same thing on Exhibit 87 that it means
    12
    on Exhibit 86?
    13
    MR. CICHANOWICZ: I regret to inform
    14
    you that's true. I can -- I can fix that
    15
    legend and make it clear.
    16
    HEARING OFFICER TIPSORD: Okay.
    17
    That would be helpful.
    18
    MR. CICHANOWICZ: Because otherwise
    19
    you are lost.
    20
    HEARING OFFICER TIPSORD: As I was,
    21
    obviously, by my questions.
    22
    MR. ZABEL: We can file a corrected
    23
    version of Exhibit 87.
    24
    HEARING OFFICER TIPSORD: Great,
    837
    1
    thank you.
    2
    MR. AYERS: If halogenated carbon
    3
    had been used on these units so that they
    4
    were correctly taken, would you have
    5
    expected a higher removal than what you
    6
    see here?
    7
    MR. CICHANOWICZ: Yes, I would have
    8
    expected a higher removal.
    9
    MR. AYERS: Don't points 4, 4-B and
    10
    4-C, which are all for the same Leland
    11
    Olds plant, do you see them there, I think
    12
    4 is probably incorrectly pink. But then
    13
    4-B and 4-C go up a straight line because
    14
    the straight line is the indicator of the
    15
    SCA -- the size of the SCA of the ESP.
    16
    But you see the first four at about
    17
    67 percent, second one a little under 80
    18
    and the last one at 93?
    19
    MR. CICHANOWICZ: Yes.
    20
    MR. AYERS: So do those demonstrate
    21
    the point about sorbent injection --
    22
    halogenated sorbent injection pretty
    23
    clearly?
    24
    MR. CICHANOWICZ: Well, 4-B -- again
    838
    1
    I need to see it and read it. Leland
    2
    Olds, that uses a treated sorbent. And
    3
    4-C I believe is the Alstom Mer-Cure. And
    4
    that is a treated sorbent.
    5
    MR. AYERS: So looking at that and
    6
    the points that we were looking at before,
    7
    you can conclude that the points No. 4, 8
    8
    and 12 would be considerably higher up if
    9
    there -- they were treated rather than
    10
    untreated sorbents.
    11
    MR. CICHANOWICZ: Treated sorbents
    12
    will increase mercury removal, yes.
    13
    MR. AYERS: Okay. Now let's look at
    14
    Nos. 12 and 17. Twelve is Coal Creek and
    15
    17 is Independence. Do you have those?
    16
    MR. CICHANOWICZ: Yes, I do.
    17
    MR. AYERS: Those are TOXECON II
    18
    units, are they not?
    19
    MR. CICHANOWICZ: Yes, they are.
    20
    MR. AYERS: So we know that's still
    21
    under development unlike -- unlike the
    22
    sorbent injection upstream of the ESP?
    23
    They have a different type of injection
    24
    system, do they not?
    839
    1
    MR. CICHANOWICZ: It is a different
    2
    injection system and the technology is
    3
    still developing.
    4
    MR. AYERS: Now, points 5 and 16,
    5
    Lausche and Conesville --
    6
    MR. CICHANOWICZ: Yes.
    7
    MR. AYERS: -- those are high sulfur
    8
    coals, are they not?
    9
    MR. CICHANOWICZ: Those are high
    10
    sulfur coals.
    11
    MR. AYERS: And we know the
    12
    condition of high sulfur is difficult and
    13
    that probably explains the low mercury
    14
    reduction, correct?
    15
    MR. CICHANOWICZ: It would be a
    16
    contributing factor, yes.
    17
    MR. AYERS: Now looking at Nos. 2,
    18
    14, 6 and 15, that's Monroe, Lee, Allen
    19
    and Yates 6 --
    20
    MR. CICHANOWICZ: Repeat those
    21
    please, two?
    22
    MR. AYERS: Yes. Number 2, Monroe;
    23
    No. 14, Lee; No. 6, Allen; and No. 15
    24
    Yates 6 --
    840
    1
    MR. CICHANOWICZ: Yes.
    2
    MR. AYERS: -- these are all
    3
    bituminous units, correct?
    4
    MR. CICHANOWICZ: Yes.
    5
    MR. AYERS: And we know that
    6
    bituminous units are harder to control
    7
    than western coals due to the sulfur,
    8
    correct?
    9
    MR. CICHANOWICZ: That is true, yes.
    10
    MR. AYERS: So the fact that those
    11
    four plants, Nos. 2, 14, 6 and 15, are a
    12
    little lower in removal than the western
    13
    coal units with halogenated sorbents, but
    14
    still get 85 percent or better, is related
    15
    to the fuel and not the ESP size, correct?
    16
    MR. CICHANOWICZ: Well, actually
    17
    Monroe is a blend of PRB. It is
    18
    60 percent PRB and 40 percent bituminous
    19
    coal. So I would be a little careful in
    20
    generalizing in saying it is a bituminous
    21
    coal. But it does have a fair amount of
    22
    bituminous in it.
    23
    MR. AYERS: Do you know what the SO2
    24
    level is in that blended coal?
    841
    1
    MR. CICHANOWICZ: No, I do not.
    2
    MR. AYERS: Would it be a surprise
    3
    if it were over 1.25 pounds per million
    4
    BTU?
    5
    MR. CICHANOWICZ: Well, it is
    6
    combined. So it should be low.
    7
    MR. AYERS: But you do agree in
    8
    general that of these four units they are
    9
    higher sulfur units and that the higher
    10
    sulfur increases the difficulty of
    11
    achieving mercury reduction?
    12
    MR. CICHANOWICZ: That is correct,
    13
    yes.
    14
    MR. AYERS: If there were a
    15
    relationship between ESP size and mercury
    16
    removal, you would expect Monroe 2 to have
    17
    lower than Allen 6, wouldn't you? I am
    18
    sorry, Monroe point No. 2 to have lower
    19
    than Allen point No. 6? Do you see that
    20
    points No. 2 and 6 on the figure are both
    21
    at 85 percent removal even though the SCA
    22
    of point No. 2 is under 300 and that of
    23
    point No. 6 is well over 400, perhaps 500?
    24
    MR. CICHANOWICZ: Well, to the
    842
    1
    extent that you can make a single point
    2
    comparison, you know, perhaps. But, you
    3
    know, again it is two points. And as I
    4
    have always said, there is things that
    5
    could be associated with other factors
    6
    other than SCA. And I don't know enough
    7
    about Allen and Monroe itself to be able
    8
    to line up all those factors.
    9
    MR. AYERS: But other things being
    10
    equal, you would expect that trend to show
    11
    if the hypothesis were correct, right?
    12
    MR. CICHANOWICZ: Yes.
    13
    MR. AYERS: The fact that 2-D,
    14
    Monroe with the SCR is a little lower than
    15
    2, Monroe with the SCR bypass is no
    16
    surprise, right?
    17
    MR. CICHANOWICZ: Well, 2-D is
    18
    different in a -- that's a 30-day test.
    19
    It was the only 30-day test left under
    20
    Monroe. So what was the question again?
    21
    MR. AYERS: The question was since
    22
    2-D was Monroe with the SCR operating and
    23
    2 was Monroe with the SCR bypass, it's no
    24
    surprise that 2 shows higher removal than
    843
    1
    2-D, isn't that right, due to the
    2
    oxidation of SO2, SO3 in an SCR unit?
    3
    MR. CICHANOWICZ: But with what we
    4
    are -- perhaps. But also 2-D was a 30-day
    5
    test that was run at the end of a
    6
    parametric test and 2 was the results of a
    7
    series of parametric tests.
    8
    MR. AYERS: Is there any reason why
    9
    you expect that to be different, though?
    10
    Any reason that would be commensurate with
    11
    the known effects of having the SCR unit
    12
    on and the oxidizing effect of the SCR
    13
    unit?
    14
    MR. CICHANOWICZ: I want to explain
    15
    that there is -- we are changing two
    16
    things at once, 30-day test at 2-D versus
    17
    short-term performance tests at 2 and the
    18
    role of SCR. And the 30-day test and the
    19
    short-term tests, the results -- you know,
    20
    the results were different because they
    21
    are different test medians.
    22
    So we are changing two things at
    23
    once. But I will say that with the role
    24
    of SCR, basically, I would expect to have
    844
    1
    an impact, yes.
    2
    MR. AYERS: So you would expect that
    3
    to be a factor.
    4
    MR. CICHANOWICZ: Yes.
    5
    MR. AYERS: Brayton Point and Salem
    6
    Harbor, and I don't have -- are they on
    7
    this table or figure? I think they are
    8
    not.
    9
    MR. CICHANOWICZ: Brayton is point 7
    10
    and it is on the table.
    11
    MR. AYERS: And Salem Harbor?
    12
    MR. CICHANOWICZ: That is 9.
    13
    MR. AYERS: Okay. They are also
    14
    bituminous and had 90 percent removal.
    15
    This was with the benefit of the high
    16
    carbon fly ash, correct?
    17
    MR. CICHANOWICZ: The benefit of
    18
    high carbon fly ash?
    19
    MR. AYERS: For mercury removal.
    20
    MR. CICHANOWICZ: The issue is the
    21
    high carbon fly ash.
    22
    MR. AYERS: Take out all the
    23
    modifiers. But the carbon, no doubt,
    24
    played a role in this?
    845
    1
    MR. CICHANOWICZ: I believe it did,
    2
    yes.
    3
    MR. AYERS: So with the exception of
    4
    Yates 1 -- Yates, which is point No. 1, we
    5
    can pretty much explain the relationship
    6
    between all these points with factors
    7
    other than ESP size; isn't that correct?
    8
    MR. CICHANOWICZ: I wouldn't say you
    9
    can explain away all the differences. I
    10
    have just said that I believe all the
    11
    things that have been stated are true, and
    12
    they are certainly factors. Okay. But I
    13
    don't know that that explains away all of
    14
    the differences. It might, but I don't
    15
    know that that's the case.
    16
    MR. AYERS: But you have agreed that
    17
    each of these factors would alter the way
    18
    these points show on this stable?
    19
    MR. CICHANOWICZ: I completely
    20
    agree, yes.
    21
    MR. AYERS: And if altered in that
    22
    way, they would -- this figure would tend
    23
    to show very little, if any, relationship,
    24
    isn't that correct, between the mercury
    846
    1
    removal and SCA?
    2
    MR. CICHANOWICZ: It depends on the
    3
    extent that those factors play out. If
    4
    they played out 100 percent, as you
    5
    described them to be, the answer would be,
    6
    yes, there would be no relationship. But
    7
    we don't know that. And that's the
    8
    purpose of the additional demonstrations.
    9
    MR. AYERS: Well, we do know from
    10
    looking at 4, 4-B and 4-C, you can see in
    11
    that the clear impact of halogenated
    12
    sorbents. And 4-C lines up with 11, even
    13
    though the SCA is far less and probably
    14
    maybe a third as big. I am trying to read
    15
    the log scale here.
    16
    MR. CICHANOWICZ: Treated sorbents
    17
    make a difference in Leland Olds, correct.
    18
    MR. AYERS: Okay. Thank you.
    19
    HEARING OFFICER TIPSORD: Are you
    20
    ready then for question 70?
    21
    MR. AYERS: No, I am sorry, we
    22
    aren't.
    23
    MR. CICHANOWICZ: That's okay. I
    24
    thought when you said thank you that you
    847
    1
    were done.
    2
    MR. AYERS: We would like to show
    3
    you exhibit -- an exhibit presented at the
    4
    2003 EPA, EPRI, DOE combined power plant
    5
    air pollution symposium. It was the mega
    6
    symposium as we discussed yesterday.
    7
    HEARING OFFICER TIPSORD: I have
    8
    been handed a document entitled "Results
    9
    of Activated Carbon Injection Upstream of
    10
    Electrostatic Precipitators for Mercury
    11
    Control" by Starns, Bustard, Durham,
    12
    Martin, Schlager, Sharon Sjostrom, Charles
    13
    Lindsey and Brian Donnelly. If there is
    14
    no objection, I will mark this as
    15
    Exhibit 108. Seeing none, it is
    16
    Exhibit 108.
    17
    MR. AYERS: Mr. Cichanowicz, on
    18
    page 34 of your testimony, you describe
    19
    modifications to Brayton Point unit 1, is
    20
    that correct?
    21
    MR. BONEBRAKE: Madam Hearing
    22
    Officer, just as a point of clarification,
    23
    I don't see a date on this exhibit. Is
    24
    there one, Counsel? Or do we know
    848
    1
    otherwise what the date of this is?
    2
    MR. AYERS: We do know what the date
    3
    is.
    4
    MR. STAUDT: It is 2003.
    5
    MR. AYERS: 2003. It is the 2003
    6
    conference.
    7
    MR. STAUDT: We have the disk right
    8
    here.
    9
    MR. BONEBRAKE: We wanted to know
    10
    what the date was.
    11
    MR. AYERS: We can get it for you if
    12
    you would like.
    13
    MR. BONEBRAKE: 2003 is fine. I
    14
    wanted clarification on the date.
    15
    MR. ZABEL: What page did you want
    16
    him to reference?
    17
    MR. AYERS: 34.
    18
    MR. CICHANOWICZ: I'm sorry, is it
    19
    table 5-2?
    20
    MR. AYERS: No. What we are looking
    21
    at is a description of modifications to
    22
    Brayton Point unit 1.
    23
    MR. CICHANOWICZ: On page 34?
    24
    MR. AYERS: I'm sorry, I think we
    849
    1
    have the wrong article.
    2
    MR. STAUDT: It is 37 -- no. Yeah,
    3
    37.
    4
    MR. AYERS: It is page 37. And this
    5
    is a table about ESP modifications and
    6
    upgrades, demonstration units.
    7
    MR. CICHANOWICZ: Yes.
    8
    MR. AYERS: You state in your
    9
    testimony that the first ESP at Brayton
    10
    Point has an SCA of 156. And the second
    11
    -- and that's newer ESP -- has an SCA of
    12
    403, didn't you?
    13
    MR. CICHANOWICZ: Yes.
    14
    MR. AYERS: And these ESPs are
    15
    connected in series with the gas passing
    16
    through the smaller ESP and then passing
    17
    through the larger ESP; is that correct?
    18
    MR. CICHANOWICZ: That is correct.
    19
    MR. AYERS: We have -- if you will
    20
    look now at figure 2 on page 5 of
    21
    Exhibit 16?
    22
    MR. ZABEL: Which exhibit?
    23
    HEARING OFFICER TIPSORD: 108,
    24
    Exhibit 108.
    850
    1
    MR. AYERS: Figure 2 on page 5 of
    2
    Exhibit 108, which is an isometric view of
    3
    the ESP arrangement at Brayton Point
    4
    No. 1?
    5
    MR. CICHANOWICZ: Yes.
    6
    MR. AYERS: Do you see the various
    7
    locations for mercury CEMS that are
    8
    identified on that?
    9
    MR. CICHANOWICZ: Yes.
    10
    MR. AYERS: Do you agree that this
    11
    arrangement permits measurement of mercury
    12
    removal across either ESP or both ESPs?
    13
    MR. CICHANOWICZ: Yes.
    14
    MR. AYERS: Please now look at
    15
    figure 3 on page 8 of the paper. Do you
    16
    agree that this figure shows the mercury
    17
    removal trends across the second ESP?
    18
    MR. CICHANOWICZ: Yes.
    19
    MR. AYERS: From this figure could
    20
    you state approximately the level of
    21
    mercury removal across the second ESP when
    22
    no sorbent is being injected? In other
    23
    words, the, quote, native removal?
    24
    MR. CICHANOWICZ: Well, with no
    851
    1
    sorbent injected, it looks like it is
    2
    zero.
    3
    MR. AYERS: Would you agree then
    4
    that this establishes that no mercury
    5
    removal occurs across the second ESP when
    6
    there is no sorbent being injected? I
    7
    think you have answered that?
    8
    Now, if you would look at table 3,
    9
    which is, I believe, on the previous page,
    10
    page 7, do you agree that this table shows
    11
    the average native mercury removal across
    12
    both ESPs of more than 90 percent?
    13
    MR. CICHANOWICZ: Well, I am looking
    14
    to make sure it says both ESPs.
    15
    Location 1, location 4. Well,
    16
    figure 2 doesn't indicate numbers on the
    17
    locations. I'm looking at the column on
    18
    the left of table 3. And it is comparing
    19
    location 1 versus location 4. And those
    20
    are certainly, you know, 90 percent,
    21
    91 percent-type numbers. But it's
    22
    location 1 versus location 4.
    23
    HEARING OFFICER TIPSORD: I agree
    24
    with you it is not readily apparent that
    852
    1
    this is both sources.
    2
    MR. ZABEL: I don't think he can
    3
    answer the question, Mr. Ayres, without
    4
    it. Maybe if he read the entire paper,
    5
    that will become clear.
    6
    MR. AYERS: We will try to locate
    7
    the locations of that.
    8
    HEARING OFFICER TIPSORD: It is not
    9
    clear.
    10
    MR. AYERS: I may come back to that.
    11
    But if we can take a moment to look?
    12
    HEARING OFFICER TIPSORD: Let's go
    13
    forward for now.
    14
    MR. AYERS: Fine. That would move
    15
    us to question 70.
    16
    MR. HARLEY: Before we move on, may
    17
    I ask a question?
    18
    HEARING OFFICER TIPSORD: Yes.
    19
    MR. HARLEY: Good morning,
    20
    Mr. Cichanowicz. A series of just two or
    21
    three questions, could you describe the
    22
    physical characteristics of ductwork at a
    23
    coal-fired electric generating unit?
    24
    MR. CICHANOWICZ: The physical
    853
    1
    characteristics?
    2
    MR. HARLEY: Yes. We are all
    3
    talking about ductwork as if we know what
    4
    it is. But for purposes of the record, it
    5
    might be helpful to actually describe what
    6
    is ductwork at a coal-fired power plant.
    7
    MR. CICHANOWICZ: That is a very
    8
    good suggestion. Basically, the ductwork
    9
    allows the flue gas to transit from point
    10
    A to point B. But the particular flavor
    11
    of ductwork we are concerned with is from
    12
    the last heater exchanger in which you
    13
    have a chance to recover heat, known as
    14
    the air chamber, to the inlet of the ESP.
    15
    And the rule of thumb is you try to
    16
    keep those velocities at about 40 or
    17
    45 feet per second. Because if you go
    18
    less than that, then the ash particles
    19
    have a habit of dropping out and
    20
    collecting on the bottom of the ductwork.
    21
    So the ductwork is designed to -- at
    22
    that location to feature about 40 to
    23
    45 feet per second. And there is a whole
    24
    series of rules where making turns, like
    854
    1
    everything else, you need to be careful of
    2
    something to reduce maldistribution of low
    3
    carbon. But that's basically what it is.
    4
    MR. HARLEY: What is a duct? Is it
    5
    a contained sheet metal unit? Is that
    6
    what we are talking about?
    7
    MR. CICHANOWICZ: Yeah, it is
    8
    basically a pipe, so to speak, or a large
    9
    duct like you might see in an air
    10
    conditioning system but it is made out of
    11
    much heavier steel and depending on the
    12
    sulfur fuel can be built of materials to
    13
    resist corrosion from SO3 that could can
    14
    contaminate.
    15
    MR. HARLEY: Generally speaking, is
    16
    it impossible to retrofit additional
    17
    ductwork on existing coal-fired power
    18
    plants?
    19
    MR. CICHANOWICZ: No. It is done
    20
    all the time. It is just a matter of
    21
    cost. Usually at that location it is
    22
    access. It is the reason why you couldn't
    23
    see the ductwork in the satellite images
    24
    yesterday is because most of it is buried
    855
    1
    under the boiler house. And when people
    2
    do retrofits back there, you have to take
    3
    apart the boiler house.
    4
    MR. HARLEY: So for each operator
    5
    who might choose to have additional
    6
    ductwork, there would be site specific
    7
    factors that they would have to take into
    8
    account before adding this ductwork?
    9
    MR. CICHANOWICZ: Yes.
    10
    MR. HARLEY: Do you have an opinion
    11
    on the relative cost between installing
    12
    additional ductwork by contrast to
    13
    installing a larger ESP unit?
    14
    MR. CICHANOWICZ: No, I don't. It
    15
    is very site specific. And those kinds of
    16
    analyses are things I don't normally do.
    17
    So all I know it is very hard to
    18
    generalize because they are site specific.
    19
    MR. HARLEY: Thank you.
    20
    MR. AYERS: Can we go back to the
    21
    Brayton Point that we were just
    22
    discussing.
    23
    HEARING OFFICER TIPSORD: You know
    24
    what, when you tilt your head down, we
    856
    1
    can't hear you at all.
    2
    MR. AYERS: I'm sorry. It is hard
    3
    to consult your notes and look up at the
    4
    same time.
    5
    Let's go back to table 3 --
    6
    HEARING OFFICER TIPSORD: Of
    7
    Exhibit 108?
    8
    MR. AYERS: -- of Exhibit 108 on
    9
    page 7. The column that's marked location
    10
    gives two -- there are two rows to show
    11
    outputs from measurements at those
    12
    locations. The first one is labeled
    13
    inlet, is it not, inlet location 1?
    14
    MR. CICHANOWICZ: Yes.
    15
    MR. AYERS: And the outlet -- the
    16
    second one is labeled outlet location 4?
    17
    MR. CICHANOWICZ: Yes.
    18
    MR. AYERS: If you could turn back
    19
    to the schematic on page 5 of this
    20
    exhibit, could you identify where the
    21
    inlet and outlet would be on that
    22
    schematic?
    23
    MR. CICHANOWICZ: Well, I would have
    24
    to know inlet to what, outlet to what.
    857
    1
    MR. AYERS: But we are measuring
    2
    mercury. So presumably it is inlet to the
    3
    precipitators and outlet from the
    4
    precipitators, isn't it?
    5
    MR. CICHANOWICZ: Well, I
    6
    understand. If we are -- if the -- if I
    7
    take the statement to mean Brayton Point
    8
    Unit 1 meaning the whole unit, then -- I
    9
    still can't tell. I can guess and say it
    10
    is the -- it is -- the inlet would be the
    11
    Hg S-CEMS following the air heater and the
    12
    outlet would be the Hg S-CEMS at the exit
    13
    of the second ESP. I can guess and say
    14
    that.
    15
    MR. AYERS: Certainly you would
    16
    think that inlet and outlet would mean
    17
    outlet would be at the end of the
    18
    precipitator train and inlet would be at
    19
    the beginning of it, would you not?
    20
    MR. CICHANOWICZ: Yes.
    21
    MR. AYERS: And we talked earlier
    22
    about the lack of any removal of sulfur in
    23
    -- I'm sorry, mercury in the second
    24
    precipitator, didn't we? You testified to
    858
    1
    --
    2
    MR. CICHANOWICZ: Yes.
    3
    MR. AYERS: -- that after looking at
    4
    the exhibit? So if table 3 shows that
    5
    90.8 percent of the mercury is being
    6
    removed, then it must be being removed in
    7
    the first precipitator, is that not
    8
    correct?
    9
    MR. CICHANOWICZ: I don't know.
    10
    Because I believe it -- is the fly ash
    11
    carbon content in this paper?
    12
    HEARING OFFICER TIPSORD: If I may,
    13
    Mr. Ayers, I am not sure what you are
    14
    trying to get to. But we are asking an
    15
    awful lot of questions about what this
    16
    paper says and asking him to review it on
    17
    the spot. I think the paper speaks for
    18
    itself.
    19
    If you have a specific point you are
    20
    trying to get to, that's fine.
    21
    MR. AYERS: I do.
    22
    HEARING OFFICER TIPSORD: Like I
    23
    say, continuing to ask him to draw
    24
    conclusions from a paper he hasn't read I
    859
    1
    think is a little unrealistic. The paper
    2
    does speak for itself. If you have a
    3
    specific point --
    4
    MR. AYERS: I do. Is it not true
    5
    that -- well, let me put it this way.
    6
    Does this example, this plant, not
    7
    indicate that the increased -- that
    8
    increasing the size of the precipitator in
    9
    this case by adding a whole new
    10
    precipitator at the end of the train does
    11
    not increase mercury removal?
    12
    MR. ZABEL: I think I am going to
    13
    make the objection that actually you just
    14
    did. There are five locations on this
    15
    diagram for mercury monitors. They are
    16
    not identified. He has testified as to
    17
    what figure 3 shows. Unless we can really
    18
    read through this whole thing and identify
    19
    where those are and what the conditions of
    20
    data in table 3 was, was the FGD on, was
    21
    it off during the testing, the things he
    22
    asked him about on figure 3, I think it is
    23
    really unfair to ask him that question
    24
    without the opportunity to study the
    860
    1
    table.
    2
    HEARING OFFICER TIPSORD: I will
    3
    give you an opportunity to respond to
    4
    that, Mr. Ayers.
    5
    MR. AYERS: I think we will pass on
    6
    this and come back to it if we have a
    7
    chance. We have had a chance to read it
    8
    and they have.
    9
    HEARING OFFICER TIPSORD: We will
    10
    end questioning for now.
    11
    MR. AYERS: Yes.
    12
    HEARING OFFICER TIPSORD: Question
    13
    70.
    14
    MR. CICHANOWICZ: As far as you
    15
    know, is an even, parallel and somewhat
    16
    laminar flow important for good ESP
    17
    performance?
    18
    Well-behaved flow entering an ESP is
    19
    desired to improve particulate removal
    20
    performance.
    21
    A, if so, do you know why? A
    22
    quiescent, low turbulence flow does not
    23
    interfere with the migration velocity of a
    24
    charged particle in transit to the
    861
    1
    collecting plate and also minimizes any
    2
    possible re-entrainment of the particles
    3
    into the flue gas stream.
    4
    Question 71, don't ESP suppliers --
    5
    MR. AYERS: I am sorry, I do have
    6
    one question.
    7
    HEARING OFFICER TIPSORD: Okay.
    8
    MR. AYERS: Is grade entrainment a
    9
    reason why maximizing laminar flow is
    10
    considered important?
    11
    MR. CICHANOWICZ: Well, I don't know
    12
    that the flow is actually laminar. I
    13
    didn't calculate the number.
    14
    MR. AYERS: As a principal, though?
    15
    MR. CICHANOWICZ: As a principal,
    16
    what you don't want is turbulent
    17
    aggressive flow adjacent to the layer of
    18
    ash that is collected on the plate because
    19
    it will pull the ash back through the flue
    20
    gas stream.
    21
    71, don't ESP suppliers install
    22
    devices to attempt to achieve these flow
    23
    conditions?
    24
    Yes. Various baffle-plate or
    862
    1
    perforated plates or turning vanes are
    2
    used to effect good flow distribution.
    3
    72, do you think that TOXECON II
    4
    possibly disturbs this flow field within
    5
    the ESP by blowing carbon right into the
    6
    middle of it?
    7
    The injection of carbon and the
    8
    carrier air may distort the flow profile
    9
    within the middle of an ESP.
    10
    73, in light of the fact that the
    11
    Monroe ESP was smaller than the effective
    12
    ESP, open parenthesis, what remained after
    13
    sorbent injection, close parenthesis, at
    14
    Coal Creek's TOXECON II site and no
    15
    problems were cited at Monroe, is it
    16
    likely that problems at Coal Creek's
    17
    TOXECON II test were a result of
    18
    challenges with the TOXECON II technology
    19
    and not an ESP limitation that would exist
    20
    if sorbent were injected upstream of the
    21
    ESP?
    22
    Yes, it is possible that that is
    23
    true.
    24
    74, on page 40 of your testimony you
    863
    1
    state "carbon, like any other solid, can
    2
    accumulate within the ductwork or internal
    3
    surfaces of the ESP and influence the
    4
    electrical properties. Specifically,
    5
    erratic electrical behavior was witnessed
    6
    at Yates due to shortening of current over
    7
    insulators. And deposits on insulators at
    8
    Coal Creek may have contributed to the T/R
    9
    set failure. This problem, which perhaps
    10
    contributed to a compromise in ESP
    11
    performance at both sites, may not be a
    12
    fatal law. But additional tests to
    13
    evaluate new insulator designs or cleaning
    14
    equipment is required." Wasn't the Coal
    15
    Creek test a TOXECON II test where carbon
    16
    is injected into the middle of the ESP
    17
    rather than upstream of the ESP? Yes.
    18
    MR. AYERS: I am sorry, could I
    19
    follow up?
    20
    HEARING OFFICER TIPSORD: Yes.
    21
    MR. AYERS: Your answer was yes?
    22
    MR. CICHANOWICZ: Yes, my answer was
    23
    yes.
    24
    MR. AYERS: So that's different from
    864
    1
    injecting the sorbent into the ductwork at
    2
    a point upstream of the ESP hardware where
    3
    it has additional time to mix and flow
    4
    more smoothly through the ESP; is that
    5
    right?
    6
    MR. CICHANOWICZ: That's a different
    7
    application, yes.
    8
    MR. AYERS: But it is a different
    9
    situation?
    10
    MR. CICHANOWICZ: Yes.
    11
    MR. AYERS: Is the TOXECON II a
    12
    technology that's considered still under
    13
    development?
    14
    MR. CICHANOWICZ: In my opinion,
    15
    yes.
    16
    MR. AYERS: So let's focus for a
    17
    minute on the simpler technology, just
    18
    injecting sorbent upstream. Even without
    19
    sorbent injection for mercury control, is
    20
    there a lot of carbon in some fly ash?
    21
    MR. CICHANOWICZ: Well, as we
    22
    discussed with the good Mr. Nelson
    23
    yesterday, carbon can vary from --
    24
    generally people like to have it less than
    865
    1
    five percent. And those cases are
    2
    successful in having it less than five
    3
    percent, in many cases less than two and
    4
    three percent.
    5
    MR. AYERS: If I'm not mistaken,
    6
    your testimony did not discuss any data
    7
    from any other plant besides Yates 1 that
    8
    had a small ESP where sorbent injection
    9
    upstream of the ESP allegedly showed
    10
    problems; is that correct?
    11
    MR. CICHANOWICZ: That is what the
    12
    -- yes, that is the only item in
    13
    testimony, absent the introduction of the
    14
    Conesville data yesterday with the
    15
    Exhibit 5-2.
    16
    MR. AYERS: Referring to the
    17
    paragraph -- I'm sorry, is that -- I am
    18
    sorry, that's your question.
    19
    MR. ZABEL: No, it is yours. It was
    20
    his to answer.
    21
    MR. AYERS: It was an earlier
    22
    question.
    23
    MR. CICHANOWICZ: So what am I
    24
    doing?
    866
    1
    HEARING OFFICER TIPSORD: 75.
    2
    MR. AYERS: Go ahead with 75.
    3
    MR. CICHANOWICZ: Referring to
    4
    paragraph on page 11 of the paper entitled
    5
    "Sorbent Injection for Mercury Control
    6
    Upstream of Small SCA ESPs" by Dombrowski
    7
    that is referenced in the TSD --
    8
    MR. AYERS: If it would be helpful,
    9
    since this is a document that was in the
    10
    TSD, you may not have it right in front of
    11
    you, we can distribute this document
    12
    again. Maybe you have had a chance to
    13
    consult with it already. I don't know. I
    14
    do want to ask some follow-up questions.
    15
    So you may want to --
    16
    MR. CICHANOWICZ: Then why don't you
    17
    distribute.
    18
    MR. AYERS: Thank you. It is No. 9.
    19
    TSD.
    20
    HEARING OFFICER TIPSORD: Document
    21
    No. 9 in what part of the TSD, the
    22
    appendices?
    23
    MR. KIM: I think it is a reference
    24
    document.
    867
    1
    HEARING OFFICER TIPSORD: It is in
    2
    the big box, then I don't have a copy of
    3
    it. That's okay.
    4
    MR. KIM: Big box document No. 9.
    5
    MR. AYERS: You can go ahead and if
    6
    you can answer questions A and B now,
    7
    Mr. Cichanowicz.
    8
    MR. CICHANOWICZ: As you can
    9
    imagine, I read this paragraph and I have
    10
    an answer for you. But I did want the
    11
    document to be in front of me.
    12
    Does this indicate any problem from
    13
    carbon injection during this test?
    14
    No. But the observation is based on
    15
    single-point measurements of particulate
    16
    matter emissions which do not present a
    17
    complete picture of particulate matter
    18
    emissions.
    19
    B, could you please read the fourth
    20
    bullet under conclusion on page 12? Does
    21
    this indicate any problem from carbon
    22
    injection during this test? I will read
    23
    that fourth bullet. The fourth bullet
    24
    states "carbon injection caused no
    868
    1
    significant increase in ESP outlet
    2
    particulate concentration in unit 1 or 2
    3
    as measured by a single-point EPA Method
    4
    17."
    5
    I wish to note, again these results,
    6
    based on a single-point method acquired by
    7
    Method 17 are inadequate to characterize
    8
    any change in PM emissions. Specifically,
    9
    a single-point Method 17 measurement would
    10
    not comprise an adequate compliance test.
    11
    More meaningful results are shown in
    12
    figure 3-31 on page 3-52 of the quarterly
    13
    report from April to June of 2005, which
    14
    shows the variability in PM emissions on a
    15
    pounds per million BTU basis, the standard
    16
    to which the unit is held accountable to.
    17
    The upper right-hand corner of the figure
    18
    is entitled Method 17 traverse data, as
    19
    this data were obtained with a four-point
    20
    traverse and would comprise a compliance
    21
    test.
    22
    So, basically, it's a single-point
    23
    test. And if single-point tests were
    24
    adequate for compliance, it wouldn't be a
    869
    1
    requirement for traversing the data. The
    2
    data in this paper was the result of a
    3
    screening study conducted early. After
    4
    the screening study, the owner operated a
    5
    longer term test where they were able to
    6
    have the time to conduct a multi-point
    7
    traverse data. And that data I think does
    8
    indicate there are particulate problems.
    9
    MR. STAUDT: Could you read back the
    10
    cite citation ?
    11
    MR. CICHANOWICZ: It is the
    12
    quarterly report from April to June 2005.
    13
    MR. STAUDT: Page and figure,
    14
    please?
    15
    MR. CICHANOWICZ: Page 3-52,
    16
    figure 3-31.
    17
    MR. AYERS: Which unit has the
    18
    smaller ESP, Yates unit 1 or unit 2?
    19
    MR. CICHANOWICZ: I don't have the
    20
    SCAs in front of me. I don't know. It is
    21
    in the report. I don't know them offhand.
    22
    MR. AYERS: I think it is in the
    23
    paper. I believe you will find it on
    24
    table 1, page 4 of the exhibit we
    870
    1
    introduced.
    2
    MR. CICHANOWICZ: Yates 2 has the
    3
    smaller ESP.
    4
    MR. AYERS: And no problems are
    5
    reported in this paper in the unit 2 ESP,
    6
    even though this is smaller than unit 1;
    7
    is that correct?
    8
    MR. ZABEL: Again we are back to
    9
    asking questions about what's in a report
    10
    that the witness hasn't read, at least not
    11
    recently.
    12
    HEARING OFFICER TIPSORD: He was
    13
    specifically asked questions on his
    14
    report. We are looking at the Dombrowski
    15
    paper. He was specifically asked
    16
    questions on it, so I would expect him to
    17
    be familiar with it.
    18
    MR. ZABEL: Right. But he is asking
    19
    what it says in general and he hasn't read
    20
    it today. To recall that -- I am happy to
    21
    let the witness answer if he recalls. But
    22
    I want the record to recognize he isn't
    23
    reading it today.
    24
    HEARING OFFICER TIPSORD: Yes,
    871
    1
    absolutely. Agreed. And, Mr. Ayers, it
    2
    would be helpful if you could point him to
    3
    the information that you are asking him
    4
    about. If you are asking him about
    5
    something that's in the report, you can
    6
    tell him where you are looking. That
    7
    would be helpful. You are going to have
    8
    to be a little more specific because we
    9
    are taking a lot of time looking for
    10
    references that you guys are asking about.
    11
    So you should be able to find it easily.
    12
    MR. ZABEL: The prepared question
    13
    asked him to look at one paragraph. He
    14
    had 99 questions to answer. If he would
    15
    have read every reference in the 99
    16
    questions, we wouldn't have had him on the
    17
    stand until Christmas.
    18
    HEARING OFFICER TIPSORD: I
    19
    understand.
    20
    MR. AYERS: No reported -- the
    21
    question I was asking is whether there
    22
    were no reported problems on either unit 1
    23
    or unit 2. And that goes back to the
    24
    conclusion which you read earlier I
    872
    1
    believe.
    2
    MR. ZABEL: I think that question
    3
    was asked and answered.
    4
    MR. AYERS: Asked and answered.
    5
    Let's discuss the issue related to
    6
    long-term tests at Yates. Is it your
    7
    testimony that the injection of activated
    8
    carbon is responsible for several problems
    9
    in the operation of the ESP?
    10
    MR. CICHANOWICZ: My testimony is
    11
    that sorbent injection can induce higher
    12
    particulate matter through break-through
    13
    of sorbent.
    14
    MR. AYERS: And you, specifically
    15
    speaking, include Yates?
    16
    MR. CICHANOWICZ: Yes.
    17
    MR. AYERS: Would you begin then to
    18
    discuss this issue starting with question
    19
    76?
    20
    MR. CICHANOWICZ: 76, according to
    21
    the report titled "Sorbent Injection for
    22
    Small Esp Mercury Control in Low Sulfur
    23
    Eastern Bituminous Coal Flue Gas,
    24
    Quarterly Technical Progress Report,
    873
    1
    April 1 to June 30, 2005," the Yates ESP
    2
    has a design basis flow rate of 490,000
    3
    ACFM at a treatment rate of 17 pounds per
    4
    million ACF, roughly the highest injection
    5
    rate experienced at Yates 1. How much
    6
    carbon is being introduced to the gas
    7
    stream per hour? Approximately
    8
    500 pounds.
    9
    HEARING OFFICER TIPSORD: I have a
    10
    point of clarification. I'm sorry. The
    11
    paper referenced in this question is this
    12
    a quote from Mr. Cichanowicz' testimony or
    13
    is this another paper that is found
    14
    elsewhere in the record?
    15
    MR. AYERS: This is from the
    16
    paper --
    17
    HEARING OFFICER TIPSORD: The
    18
    Dombrowski paper?
    19
    MR. CICHANOWICZ: No.
    20
    HEARING OFFICER TIPSORD: The title
    21
    is different?
    22
    MR. AYERS: Yes, not Dombrowski. It
    23
    is Exhibit 71 from the first hearing.
    24
    HEARING OFFICER TIPSORD: And then
    874
    1
    we are on 76 A.
    2
    MR. CICHANOWICZ: A, how much at
    3
    around six pounds per million ACF,
    4
    approximately 176 pounds.
    5
    Question 77, according to 2004
    6
    EIA Form 767 data submitted by the plant
    7
    owner, the average heating value of the
    8
    fuel was about 12,400 BTUs per pound and
    9
    the average ash was about 11.4 percent.
    10
    Using this or other information you may
    11
    have from the owner, please make a rough
    12
    estimate of how much fly ash enters the
    13
    Yates ESP each hour at full load. If you
    14
    relied on other information from the plant
    15
    owner, please describe the information.
    16
    Ash loading entering the ESP is
    17
    estimated to be 7,355 pounds per hour,
    18
    assuming a plant generating capacity of
    19
    100 megawatts, heat rate of 10,000 BTUs
    20
    per kilowatt hour at 100 percent capacity
    21
    factor.
    22
    78 --
    23
    HEARING OFFICER TIPSORD: Excuse me,
    24
    I am going have to ask, when we have
    875
    1
    something referenced in the question, this
    2
    is a part of the record, is it not?
    3
    MR. AYERS: Exhibit 71?
    4
    HEARING OFFICER TIPSORD: According
    5
    to the 2004 EIA Form 767?
    6
    MR. ZABEL: For the record that is
    7
    the Energy Information Agency, which is a
    8
    division of the Department of Energy. It
    9
    is a published and publicly available
    10
    document.
    11
    HEARING OFFICER TIPSORD: Thank you.
    12
    MR. AYERS: Could you turn your
    13
    attention to the report "Sorbent Injection
    14
    for Small Esp Mercury Control and Low
    15
    Sulfur Bituminous Coal Flue Gas Quarterly
    16
    Technical Progress Report, April 1 to
    17
    June 30, 2005"?
    18
    MS. BASSI: Is that Exhibit 71?
    19
    MR. AYERS: I believe that's
    20
    Exhibit 71, yes. Would you turn to
    21
    page 3-9 of that document?
    22
    MR. BONEBRAKE: What page did you
    23
    say?
    24
    MR. AYERS: 3-9. And if you would
    876
    1
    read the last paragraph on that page.
    2
    MR. CICHANOWICZ: "There was no
    3
    apparent increase in the carbon content of
    4
    the ESP ash as measured by percent LOI for
    5
    the activated carbon injection tests
    6
    compared to baseline tests. As shown in
    7
    figure 3-10, the mercury content of both
    8
    the bottom ash and the ESP fly ash samples
    9
    were directly related to LOI percent of
    10
    the ash."
    11
    MR. AYERS: Is it possible in that
    12
    statement it would be likely that there
    13
    was no apparent increase in property
    14
    content of the ESP fly ash because the
    15
    carbon already in the fly ash so far
    16
    exceeded the amount of carbon being added?
    17
    MR. BONEBRAKE: I'm sorry, was the
    18
    question is it possible or is it likely?
    19
    I couldn't tell which of the questions --
    20
    MR. AYERS: I will settle for
    21
    likely. Is it likely? I used both.
    22
    MR. CICHANOWICZ: It is possible. I
    23
    would have to calculate -- do a mass
    24
    calculation to say it is likely. But it
    877
    1
    is certainly possible.
    2
    MR. AYERS: According to table 3-8
    3
    of the Yates report on page 3-12, would
    4
    you agree that the LOI of that plant is in
    5
    the range of ten percent or so, sometimes
    6
    more?
    7
    MR. CICHANOWICZ: Yes.
    8
    MR. AYERS: Isn't that significantly
    9
    higher than the amount of carbon from
    10
    activated carbon?
    11
    MR. CICHANOWICZ: Yes, it is.
    12
    MR. AYERS: So is it possible that
    13
    the carbon from fly ash caused any
    14
    problems that may have been experienced?
    15
    MR. CICHANOWICZ: It's possible that
    16
    the carbon in the ash is responsible for
    17
    some of the ESP data, yes.
    18
    MR. AYERS: Thank you. Question 78.
    19
    HEARING OFFICER TIPSORD: Okay,
    20
    question 78.
    21
    MR. CICHANOWICZ: You state on
    22
    page 40 of your testimony "first, the PM
    23
    emissions standards for Yates are well
    24
    below the Georgia limit of 0.2 pounds per
    878
    1
    million BTU. The owner frequently
    2
    operates these units at less than 0.10
    3
    pounds per million BTU, which typifies PM
    4
    limits in other regions of their system,
    5
    open parenthesis, for example, Alabama
    6
    requires a PM limit of 0.10 pounds per
    7
    million BTU, close parenthesis. Data
    8
    presented in the quarterly report to the
    9
    DOE summarizing these results, Richardson,
    10
    2005, shows baseline PM emissions less
    11
    than 0.10 pounds per million BTU." Is
    12
    this report by Richardson the sole source
    13
    of your statement or there other sources?
    14
    My understanding of the PM emission
    15
    standards for Yates units 1 to 4 and how
    16
    the standards compare to other units in
    17
    the Southern Company System was conveyed
    18
    to me in a July 20th telephone
    19
    conversation with Mr. Mark Berry of
    20
    Southern Company, the staff engineer in
    21
    charge of ACI testing.
    22
    Question 79 --
    23
    MR. AYERS: I'm sorry, I have some
    24
    follow-up questions on this. There is a
    879
    1
    scrubber after the ESP at this plant, is
    2
    there not?
    3
    MR. CICHANOWICZ: On unit 1 there
    4
    is.
    5
    MR. AYERS: And the emission limits
    6
    apply to stack emissions. And the PM
    7
    emissions of concern for compliance are at
    8
    stack and after the scrubber, isn't that
    9
    correct?
    10
    MR. ZABEL: That is a legal
    11
    question, but I will let the witness
    12
    answer, if he knows.
    13
    MR. CICHANOWICZ: Well, the PM
    14
    limits that were described to me were
    15
    basically as measured at the exit of the
    16
    ESP with Method 17 that's shown in the
    17
    figure.
    18
    MR. AYERS: Figure 3-31 of the
    19
    long-term test report on page 3-52 shows
    20
    Method 17 particulate measures at the ESP
    21
    outlet planted against carbon injection
    22
    rate. We are still looking at Exhibit 71.
    23
    MR. CICHANOWICZ: Okay. Thank you.
    24
    MR. AYERS: So that figure shows
    880
    1
    particulate measures at the ESP outlet
    2
    plotted against carbon injection rate,
    3
    correct?
    4
    MR. CICHANOWICZ: That is correct.
    5
    MR. AYERS: Now, the baseline range
    6
    is where there is no sorbent being
    7
    injected and we compare the results of
    8
    testing of the sorbent with the baseline,
    9
    correct?
    10
    MR. CICHANOWICZ: Correct.
    11
    MR. AYERS: Could you state how many
    12
    sorbent test points lie above the baseline
    13
    range?
    14
    MR. CICHANOWICZ: I count six.
    15
    MR. AYERS: And how many sorbent
    16
    test points lie below the baseline range?
    17
    MR. CICHANOWICZ: I count six.
    18
    MR. AYERS: And how many sorbent
    19
    test points lie within the baseline range?
    20
    MR. CICHANOWICZ: I count seven or
    21
    eight.
    22
    MR. AYERS: Would you agree that the
    23
    test measurements show more scatter in the
    24
    baseline measurements both above and below
    881
    1
    the baseline?
    2
    MR. CICHANOWICZ: I would state that
    3
    -- and this is what I was told my Mark
    4
    Berry, that they did not have exceedences
    5
    or they did not have PM emissions above
    6
    the 0.10 level until they injected
    7
    activated carbon. And certainly there is
    8
    a lot of variability in this.
    9
    Dr. Staudt testified to this in
    10
    Springfield, and it's still true. There
    11
    is much data above as below. But it
    12
    doesn't detract from the fact that until
    13
    activated carbon was used, this type of --
    14
    when they had done PM emissions, they had
    15
    not seen this type of variability. And
    16
    when you look at the baseline data,
    17
    granted there is three or four points, but
    18
    it is within the range they are used to
    19
    seeing.
    20
    MR. AYERS: This is commentary that
    21
    is based on a conversation with someone
    22
    outside the room? Yes?
    23
    MR. CICHANOWICZ: Yes.
    24
    MR. AYERS: Do you know when the
    882
    1
    baseline measurements were taken relative
    2
    to the tests with sorbent?
    3
    MR. CICHANOWICZ: My understanding
    4
    was that the long-term tests, they -- the
    5
    data was taken basically at the -- at the
    6
    same time that they were conducting the
    7
    parametric variations. That is what
    8
    distinguished the tests in this report,
    9
    that's different from what's in the mega
    10
    symposium paper, is that these tests were
    11
    long term. They allowed time for the
    12
    system to come to equilibrium and they
    13
    took the time to do the traverse.
    14
    What Mark told me -- and again this
    15
    is based on a telephone conversation --
    16
    was that they rushed through the early
    17
    parametric test for the reason of getting
    18
    data for the paper that you handed out and
    19
    they didn't take the time to do full
    20
    traverse measurements. They were just
    21
    trying to get a sense for what the mercury
    22
    removal would be as a function of sorbent
    23
    because they had a deliverable.
    24
    But once that was done, the next
    883
    1
    phase of testing was more relaxed and they
    2
    had the time to do the full traverse.
    3
    MR. AYERS: So it is your
    4
    understanding that baseline measurements
    5
    and the test measurements were taken at
    6
    the same time?
    7
    MR. CICHANOWICZ: Yes.
    8
    MR. AYERS: Could you turn to
    9
    page 334 of the same exhibit, 3-34. And
    10
    read bullet No. 8.
    11
    MR. ZABEL: Do you want him to read
    12
    it or read it into the record?
    13
    MR. AYERS: I think read it into the
    14
    record, if you would.
    15
    MR. CICHANOWICZ: "Method 17
    16
    traverses were conducted in the ESP outlet
    17
    duct to quantify ESP outlet particulate
    18
    emissions. A handful of the data
    19
    collected exceeded the baseline, open
    20
    parenthesis, no injection, close
    21
    parenthesis. ESP outlet emissions
    22
    measured in three method 5 traverses from
    23
    spring 2004. Furthermore, a few data
    24
    points exceeded the compliance limit for
    884
    1
    Yates unit 1, open parenthesis,
    2
    0.24 pounds per million BTU, close
    3
    parenthesis. However, the unit itself was
    4
    in compliance because the downstream PBR
    5
    removed the broken-through particulate
    6
    matter, open parenthesis, see next section
    7
    for further discussion, close
    8
    parenthesis."
    9
    MR. AYERS: That's sufficient, I
    10
    think. Doesn't that say that the baseline
    11
    tests were taken in the spring of 2004
    12
    over six months earlier than the tests
    13
    with the sorbent in November 2004 or
    14
    January 2005?
    15
    MR. CICHANOWICZ: That is what that
    16
    says.
    17
    MR. AYERS: Now, could you turn to
    18
    page 2-16 of the same document? And read
    19
    the second to last paragraph. You don't
    20
    need to read it into the record.
    21
    MR. CICHANOWICZ: I'm sorry, you
    22
    want me to read it into the record or not?
    23
    MR. AYERS: You don't need to read
    24
    it into the record. But I just wanted to
    885
    1
    ask you, does that say that the Method 17
    2
    traverses for the long-term test with the
    3
    sorbent were conducted during the week of
    4
    November 30th and December 7th of 2004?
    5
    MR. CICHANOWICZ: That is what that
    6
    says, yes.
    7
    MR. AYERS: So these tests that were
    8
    compared to the February baseline were
    9
    actually done in December, correct?
    10
    MR. CICHANOWICZ: That's what the
    11
    report says, yes.
    12
    MR. AYERS: Is there a possibility
    13
    then that the conditions are not quite the
    14
    same as the baseline conditions in
    15
    February of 2004 and the conditions under
    16
    the -- during the test in December of
    17
    2004?
    18
    MR. CICHANOWICZ: That's possible,
    19
    yes.
    20
    MR. AYERS: For example, there might
    21
    be differences in the fuel that would
    22
    affect the performance?
    23
    MR. CICHANOWICZ: Yes.
    24
    MR. AYERS: Thank you.
    886
    1
    HEARING OFFICER TIPSORD: That was
    2
    question 78. I would like to go a little
    3
    bit longer to try to get through this
    4
    paper. So we will see how we do. I will
    5
    try not to break you off in the middle,
    6
    but let's go to question 79.
    7
    MR. AYERS: We have quite a few
    8
    questions on this. I think it will take
    9
    awhile.
    10
    HEARING OFFICER TIPSORD: All right.
    11
    We better take a break. We will come back
    12
    at 1:00 o'clock.
    13
    (Whereupon the
    14
    proceedings in the
    15
    above-entitled cause
    16
    were adjourned until
    17
    August 17, 2006, at
    18
    9:00 a.m.)
    19
    20
    21
    22
    23
    24
    887
    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
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