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Good morning, Mr. Chairman. My name is Richard Miller, Sales Manager for Fabric Filters
and FGD Systems at Hamon Research-Cottrell (HRC) located in Somerville, New
Jersey. For the past 25 years, I
have been serving the air pollution control industry in various technical
and managerial roles, with a specialty in fabric filter particulate removal
systems. In addition, I have served
as Fabric Filter Committee Chairman for the Institute of Clean Air
Companies (ICAC) for the past 5 years and have authored dozens of technical
papers and conducted numerous technical presentations during my career
period.
I wish to take a few moments to share a little history
about the company I work for. Dr.
Frederick Cottrell who was the inventor of the first industrial
electrostatic precipitator originally founded research-Cottrell in 1907. To support scientific research, Dr. Cottrell
co-founded the non-profit Research Corporation in 1912. Forty years later, the Research
Corporation gave birth to Research-Cottrell, which is now known as Hamon
Research-Cottrell. To this date,
our company continues the tradition of engineering excellence by designing,
building, and servicing high quality air pollution control systems for the
various industries and electric utilities of the world.
Our products range from particulate control devices such
as electrostatic precipitators (ESP’s) and fabric filter systems (FF’s),
also known as baghouses, to flue gas de-sulfurization (SO2)
systems, including both Wet FGD and Dry FGD type systems, Nitrogen Oxide
(NOx) reduction systems and other supporting technologies such as U2A
which is primarily designed to generate on-site ammonia from urea for SCR
type NOx reduction systems. All of
these technologies are designed to meet both current and hopefully future
air pollution control legislations.
We are but one of several highly skilled organizations in our
industry who have developed air pollution control technologies designed to
achieve the same goals. Currently
HRC does not design or manufacture any type of CO2 control
technologies so I therefore will not address this pollutant in my
testimony. I do wish, however to
address the issue of mercury control for the remainder of this testimony.
SUMMARY
As testified by the Mr. Jeff Smith,
Executive Director of ICAC during his previous testimony on November 15,
2001, I believe the air pollution control industry currently has the
existing technologies required to achieve NOx, SO2, and Mercury reduction
levels as proposed under Senator Jefford’s bill (S. 556), and the required
resources to further develop and deliver this technology within the time
frame outlined under this bill.
This is consistent with the past history of the air pollution
control industry to develop the technologies required to achieve emission
control technologies regulated since the first Clean Air Act was
enacted. Whether particulate
emissions, sulfur dioxide, nitrous oxide, mercury or fine particulate (PM
10 or 2.5) removal, we have found ways to meet the challenges established
by regulations. These include the
challenge of making it both technically feasible as well as economically
available.
Effective mercury reduction has been measured and shown
to occur naturally to various degrees across existing air-pollution control
devices, and removal rates in excess of the ultimate goal of 90% reduction
have been achieved across the entire train of existing emissions control devices or better stated as being from the coal
pile to stack. ICR Emission summary
data gathered by EPA, and made available to the public from dozens of
electric utility power stations and firing various type of coal types,
shows that even without additional control devices or enhancements, natural
mercury removal rates are currently being accomplished with removal levels
anywhere from zero to as high as 97%+.
This data shows that it is easier to remove mercury from Eastern
Bituminous coals than it is from Western Sub-Bituminous or even worse from
poorer grade fuels such as lignite.
The success of many of these sites
depends upon many variables, including; type of coals, operating
temperatures, and especially which type of air pollution control devices
are present. Most existing power
stations have ESP’s for removal of particulates, while a smaller but
growing number of plants have fabric filter systems installed. Additionally, some of these
installations have also installed SO2 scrubbing systems and SCR systems,
which can all jointly or independently help in the removal of mercury from
the gas stream. So the control of
multi-pollutants which requires many of these existing devices to be
installed at the same time, can and do help together in reaching the goals
of this bill. The best removal rates appears to be from fabric filter
systems which generally remove a greater amount of particulates than
electrostatic precipitators can by filtering the ash across a synthetic,
high temperature filter media.
For those existing plants that have
electrostatic precipitators installed, even if they do not currently
provide effective mercury reduction levels, there does exist commercially
available technology that has been proven to enhance these devices in the
removal of total particulates and recently demonstrated mercury emissions
with proven removal levels of 80 to 90+ percent. This technology is called COHPAC, which stands for a COmpact
Hybrid PArticulate Control technology, which was originally developed by the
Electric Power Research Institute (EPRI) in 1991 as a multi-pollutant
control device. It involves the
joining or marriage of both ESP and high velocity pulse jet type fabric
filter technologies, with the fabric filter portion acting as a final
collection polishing device.
To date, significant improvements
in the removal of particulates have been demonstrated at four existing coal
fired power plant sites, as well as two refuse fired combustors utilizing
this hybrid technology.
Additionally, under an existing DOE/NETL sponsored test program which
is being implemented by ADA-ES and co-sponsored by several electric utility
generators, EPRI, as well as Hamon Research-Cottrell, it has been shown
that on an existing utility coal-fired boiler that utilizes this COHPAC
technology, with the simple addition of a dry sorbent such as pulverized
activated carbon (PAC), an aging hot-side electrostatic precipitator can
effectively achieve reduction levels of 80 to 90%. ICR data has shown that Hot-Side
precipitator particulate collection devices, due primarily to the high flue
gas temperature range they normally operate at, have shown to provide
little if any natural mercury collection.
Even though this power plant was firing an Eastern bituminous coal
which tends to provide greater amounts of natural mercury reduction levels,
the fact that it increased the total reduction levels from 0% to over 90%
is remarkable in itself and demonstrates that it may be possible to achieve
similar results on other fuels where higher initial mercury capture rates
are already present. Additional
longer-term research and demonstrations will need to be conducted in order
to confirm these assumptions.
Even without the addition of the
COHPAC technology, evidence suggests that existing power plants outfitted
with electrostatic precipitators may also benefit from the injection of
activated carbons. Fly ash removal
rates of 50 to 70% can be reasonably expected to be achievable across these
existing devices, while however requiring greater amounts of PAC sorbent
injection levels. Although
achievable, injection rates 10 to 30 times higher than fabric filters alone
or when using COHPAC technology are expected with ESP’s alone. Depending upon the initial cost of the
PAC material, this higher injection feed rate could equate to a significant
increase in annual operating costs of several millions of dollars per
year.
Additional financial penalties to
the utilities may also result due to the potential loss in the
marketability of the ash from the injection of the activated carbon into
either a conventional fabric filter and/or an electrostatic
precipitator. The higher LOI
content of the ash makes in unattractive to market as a concrete
supplement. This results in the
requirement to landfill the entire amount of fly ash, which depending upon
the plants location, could be very expensive, thus potentially losing
additional compensation and increasing the financial cost to the utility to
remove the high mercury levels.
However, with the use of the COHPAC technology, the majority or 96
to 98% of the fly ash is typically removed in the primary ESP particulate
removal device. Only the remaining
2-4 % of the total amount of ash is actually being treated with the
activated carbon. Thus the majority
of the ash could still be sold by the utilities and only the much smaller
percentage of the ash which has now been treated for mercury reduction, can
be disposed into a normal land fill or ash settling pond.
The initial installed cost on a
flange-to-flange basis for the installation of the COHPAC technology
appears to range anywhere from $20 to $30/KW, excluding any additional
costs associated with the possible need for new or improved induced drafts
fans, modified ductwork, additional foundations or engineering and in-house
costs. However, for an example, on
a typical 400 MW size coal-fired boiler facility, the difference in total
annual levelized cost for pulverized activate carbon (PAC) injection to
achieve 80% mercury removal across an existing ESP collector vs either a
conventional fabric filter or COHPAC hybrid removal system is $13.5 Million
vs $2.8 million, with the total injection system capital equipment cost
equaling approximately $940,000
.
CONCLUSION
As an individual who has suffered
with Asthma all his life and having a child who also has the same health
disorder, it is important to me as well as all individuals to have the
cleanest air possible available to us all.
I have strived to achieve this throughout my career through the
advancement of air pollution control technologies. However, without the enforcement
resulting from tougher emission control legislation such as the
multi-pollutant performance based approach reflected in the Jeffords Bill
(S. 556), current emission levels for all pollutants, including mercury,
will not be reduced voluntarily by the electric power producers, nor will
the advancement in pollution control technologies continue with any
speed. Without the additional
enforcement levels provided under this bill, current air pollution levels
will remain as is, as the financial incentives needed to develop and
demonstrate the required mercury control technologies and other pollutant
controls will not be made available to the air pollution control industry.
Today, commercially available, cost effective air-pollution
control technologies have already achieved 90% mercury removal reductions
on certain coals. I am confident
with the initiation of clean air regulations including reasonable deadlines
for compliance; those 90% removal efficiencies can be achieved across a
broad spectrum of available fuels.
The Clean Air Industry has a well-documented history of successful
response to regulatory initiative:
when clear regulations have been enacted; the industry has achieved
the desired results in a cost effective and commercially reasonable
basis.
Failure to implement this legislation because of
incomplete technical data creates the ultimate Catch 22. The Clean Air
Industry cannot reasonably invest in the products or systems that will
achieve the goals of the legislation without the regulatory drivers
creating demand to justify investment but the regulations are being upheld
because the products and systems have not been fully developed.
I am confident the goals can be achieved if the
investment impetus of legislation exists.
We recognize that there is a cost to achieve the
improved air quality, but you must also recognize that this investment has
a high rate of return, not only in improved air quality but also as a
highly efficient economic stimulus to our sluggish economy. Indeed, it is hard to identify a better
government stimulus than air pollution control regulations in Power
Generation. This is because:
·
Cost is widely distributed and incurred by the
entity/person using the power (as opposed to taxing everyone regardless of
use)
·
Electricity costs for the great majority of
individuals and businesses are a small fraction of their operating expense.
·
No risk of negatively impacting United States power
generators because they are free from foreign competition in the U.S. and
they pass the cost on to their customers.
The power is minimal, and can be addressed on case-by-case basis.
·
No increase in government deficit and NO NEW Taxes
·
The money must be spent within the US
·
The liquidity exists in the capital markets to
support this initiative-it just needs a stimulus for release
·
Hundreds and thousands of jobs can be created in
the United States, across a wide variety of businesses, not just for air
pollution control companies like ourselves, but also architect and engineering
companies, fabrication companies, steel companies, instrumentation and
control companies and construction companies and their workers.
Thank you for this opportunity to
testify. I look forward to any
questions you may have.
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