1. Non-mercury HAP March 4, 2002 Washington, D.C. Bill Maxwell US EPA

2. Outline zStatus of non-mercury HAP data zWhat it tells us zWhere we may go from here

3. Estimated Nationwide Emissions Compound zArsenic zCadmium zChromium zLead zManganese zHydrogen chloride zHydrogen fluoride zDioxin * Estimated annual emissions in 1994, 1996 Tons/year* 56 3 62 168 134,000 23,100 0.000121 % of National* 16 2 6 2 7 28 42 2

4. Non-ICR HAP Data zNon-ICR HAP data gathered from yEPRI PISCES data base yDOE test program yIndustry tests zData generally pre-1994 but not always zData include mercury but not speciated zData posted on utility MACT website yIncludes coal, oil, and natural gas data for all data other than that from the ICR

5. What Do the Data Show - Metals? zMetals (As, Be, Cd, Cr, Pb, Mn) from coal yEffectively removed by ESP’s: >92% median removal by control device yEffectively removed by FF’s: >95% median removal by control device yModerately removed by wet FGD’s: ~25-87% median removal by control device yEffectively removed by SDA/FF’s: >90% median removal by control device

6. What Do the Data Show - Acid Gases? zAcid gases (HCl, HF) from coal yPoor control by ESP’s: <6% removal for HCl and HF yModerate control by FF’s: ~44% removal for HCl and 0% removal for HF yModerate control by wet FGD’s: ~80% removal for HCl and ~29% removal for HF yGood control by SDA/FF’s: ~82% removal for HCl and HF

7. What Do the Data Say - Organics? zOrganics (including dioxin) from coal yLittle controlled data available yWhat exists indicates 7-38% dioxin congener removal from ESP yEstimated emissions, even uncontrolled, are very low from coal-fired units

8. What Does This Say to EPA About Coal Non-mercury HAP? zMetals from coal effectively removed by existing PM controls zAcid gases from coal effectively removed by existing scrubber controls zOrganics, including dioxin, from coal are not removed by existing controls…but there does not appear to be a significant problem

9. Mercury Control Retrofit Options ESP Control options** Sorbent Injection (SI) Add CFBA + SI Add FF + SI SDA ESP (or FF) APCD Configuration* No. of Units SI or oxidization + SI Wet FGD Scrubber SI ESP (or FF) Boilers (1,140) PC fired Cyclone Fluid Bed Stoker FF SI 800; 70% 64; 5.6% “Other” units *** 157; 14% 27; 2.4% Coals and Fuels Bituminous Subbituminous Lignite Mixtures Boilers and Fuels 92; 8.1% Scrubber chemistry mods Add SCR + chemistry mods Add reagents, catalysts, or sorbent bed * ESP = electrostatic precipitator; FF = fabric filter; CFBA = circulating fluidized bed absorber; SCR = selective catalytic reduction; SDA = spray dryer adsorber (includes DSI [duct sorbent injection]) ** Selected control options -- other options possible. Flue gas cooling and additional ducting may be used with SI. *** Includes venturi scrubbers, multiclones