MATS Compliance Initiative at Grant Town Power Plant

Background Information Grant Town looked at requirements of MATS and learned early on in that process that Acid Gas emissions were likely our biggest hurdle to overcome Stack testing confirmed HCl emissions were some 12x higher than the proposed limit in MATS – lb/mmBTU versus the limit of lb/mmBTU Typical SO 2 emissions average 0.5 – 0.55 lb/mmBTU thus requiring a 90% SO 2 removal efficiency per requirements of the WVDEP air permit. In order to comply with the surrogate HCl limit, SO 2 emissions would need to be reduced to less than 0.20 lb/mmBTU – excess of 96% SO 2 removal Staff was not initially sure that additional limestone injection alone would meet the surrogate limit

Initial Testing Series of three test periods using additional limestone injection to meet HCL surrogate have been run – latest during CEMS RATA testing of 2014 Consistently have met surrogate limit with no observed detriments to boiler operation in the short term i.Limestone Feed System able to keep pace with increased input – appears input increases about % to meet lower SO 2 limit ii.Ash systems able to handle additional loading without limitation iii.Limestone processing system capable of additional production to meet increased demand – increased run time from a average of 10 hours per day to approximately 12 hours per day iv.With limited test intervals, boiler tube erosion rates have not been quantified, though certainly would increase with additional limestone feed

Initial Reactions Even though additional limestone feed had proven compliance to the HCl surrogate was possible, several items needed to be considered moving forward with this option: a.Reliability of the current limestone feed system and limestone processing system to meet boiler production demands b.Cost of supply of additional limestone and could the current supplier meet those levels of supply c.Erosion impacts on the boiler tubing – in particular the combustor waterwalls d.Other operational impacts Baghouse bag life Wear and tear on ash handling systems Expense of additional limestone processing

Thoughts for Alternative Compliance Options In 2010, Grant Town had been approached by EnviroResolutions to test a “hybrid” scrubber design that had been developed for control of particulates from diesel powered ships in the marine industry EnviroResolutions had tested their concept scrubber on a biomass fired facility and found that by varying the solution of the scrubber medium significant reductions in SO 2 could be achieved Looking to test on a coal fired facility for proof of concept and that SO 2 emissions could be reduced enough to prove the technology as a viable alternative to conventional post-combustion control technologies Grant Town agreed to test pilot scale system – thought at that time the system might offer more economic approach to SO 2 control

EnviroResolution Pilot Scale Unit

Pilot Scale Test Slip stream of flue gas taken from Boiler B to the pilot scale unit – approximately 1.5% of total boiler combustion gas flow – about 2,000 ACFM SO 2 measurements taken at inlet and outlet to the test unit to verify reduction Three test runs using hydrated lime as the scrubbing fluid Results indicated high levels of SO 2 removal a)Average SO 2 in to test unit – 157 ppm b)Average SO 2 out from test unit – 1.32 ppm c)Average Removal Efficiency – 99.2% Results confirmed that the technology was likely a good fit for additional SO 2 control – considered as an option for CAIR/CSAPR compliance at that time but not implemented

EnviroResolutions and MATS Compliance As more became know with the MTAS program, EnviroResolutions was approached by Grant Town to consider their system as an alternative to provide control for Acid Gas Emissions Options considered included a modular approach to control emissions from one boiler or a slip stream of both boilers to reduce SO 2 to the HCl surrogate Initial design concept was to reduce SO 2 emissions just low enough to meet MATS Modelling lead us to believe the entire SO 2 scheme could be realized using the EnviroResolutions system Entered into agreement with EnviroResolutions to complete additional modeling, economic analysis and independent third party feasibility study to determine if the technology was viable for a CFB application

EnviroResolutions and MATS Compliance Issues with combining cooled stack gas from the scrubber outlet back with the uncooled gas from the other boiler/remaining from the slipstream led to a change in the conceptual design Current concept has a total of 6 scrubber modules to provide 100% SO 2 control Modeling and analysis of our current limestone supply would indicate that it would be acceptable for the scrubbing fluid for the system – current processing system could be used to grind the raw limestone to a size consist suitable for mixing for the scrubber Significant reduction in the amount of limestone consumed to meet compliance versus the amount required to meet the MATS HCl surrogate

Preliminary Design

Concerns with Current Design Concept Beyond proof of concept – items to consider moving forward: Will the CFBs be able to maintain steaming rate if limestone is no longer added to the combustor Disposal of the scrubber residual sludge could present an issue with ash disposal i.Storage of residuals during periods when ash is not being unloaded ii.Impact of residual on ash stream quality – beneficial reuse status impacts – modeled but not physically proven iii.Stability concerns for ash disposal areas Affordability of the project if economic justification proves beneficial Impacts to other CFB/IPP operators

Current Status Grant Town obtained an extension of the MATS compliance deadline from WVDEP moving our compliance date until April 16, 2016 MPR Associates currently finalizing initial draft of the feasibility study review for proof of concept Detailed economic analysis to be completed once feasibility study report finalized and pricing proposals are firmed up Considering/pursuing other post combustion scrubber options as well i.MHPSA Post Combustion Controls ii.CBPGA Post Combustion Controls

Potential GHG Impact Although not fully quantified at the time of this presentation, the scrubber could offer potential reductions in the emissions of CO 2 given the reduction in the amount of limestone required for SO 2 compliance. More research and modeling will need to be completed to fully understand the potential benefits of CO 2 reduction

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