EPRI Impact of Air Emissions Controls On Coal Combustion Products

Impact of Air Emissions Controls on
Coal Combustion Products
E c o n o m ize r
F u rn a c e
E c o n o m ize r
A s h C o lle c tio n
F G D A b s o rb e r
A ir H e a te r
P artic u la te
C o lle c to r
B o tto m
A s h /S la g
C o lle c tio n
F ly As h
C o lle c tio n
F G D G yp s u m
C o lle c tio n
S tac k
Impact of Air Emissions Controls on

Coal Combustion Products
1015544
Technical Report, October 2008
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Ameren Corporation
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Project Manager
P. Pike
EPRI Project Manager

K. Ladwig
ELECTRIC POWER RESEARCH INSTITUTE

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CITATIONS
This report was prepared by
URS Corporation
P.O. Box 201088
Austin, TX 78720
Principal Investigators
G. Blythe
J. Paradis
This report describes research sponsored by the Electric Power Research Institute (EPRI) and
Ameren Corporation.
The report is a corporate document that should be cited in the literature in the following manner:
Impact of Air Emissions Controls on Coal Combustion Products. EPRI, Palo Alto, CA: 2008.
1015544.
iii
REPORT SUMMARY
Coal combustion products (CCPs) have been extensively studied and well characterized over the
last 30 years. However, new air emissions control technologies at power plants will change the
characteristics of some existing CCPs. These changes may affect the selection of appropriate
management methods for high-volume CCPs with respect to both disposal and use. This report
examines evolving air emissions controls and their likely impact on CCPs.
Background
Extensive environmental characterization of the four high-volume CCPsfly ash, bottom ash,
boiler slag, and flue gas desulfurization (FGD) solidsextends back to the 1970s, and
accelerated following the initial enactment of the Resource Conservation and Recovery Act
(RCRA) governing nonhazardous and hazardous waste disposal. While a significant database has
been accumulated during this time period, recent changes in air emissions controls are resulting
in changes to CCP engineering and environmental characteristics. Combined with tightening
regulation of trace constituents such as mercury and arsenic, these changes have the potential to
impact disposal practices and potential use opportunities.
Objectives
To summarize power plant environmental control systems, the most significant likely changes in
CCP characteristics resulting from these technologies, and potential impacts on CCP
management.
Approach
Researchers evaluated the range of air emissions control technologies currently being considered
for power plants. These were grouped as controls on nitrogen oxides (NOX), sulfur
trioxide/sulfuric acid (SO3/H2SO4), and mercury. These technologies are described, and their
potential impacts on the four high-volume CCPs are discussed. In addition, ancillary solid wastes
arising from the generation and management of coal combustion products are described.
Results
NOX control consists primarily of four technology types: furnace combustion modifications,
which for the purposes of this report include the use of low-NOX burners; rich reagent injection
(RRI), which is implemented in the furnace; selective noncatalytic reduction (SNCR), which is
implemented in the upper furnace; and selective catalytic reduction (SCR), which is
implemented between the economizer and air heater. The primary impacts of these control
technologies are an increase in unburned carbon, which can have an adverse impact on fly ash
use in concrete, and addition of ammonia to the fly ash.
Increased ammonia could cause odor issues that affect both ash use and disposal operations,
although there are methods available to mitigate this problem.
SO3 is formed in the furnace and in downstream SCR systems, and the most tangible
manifestation of the resulting sulfuric acid in the flue gas is stack plume visibility. Consequently,
SO3 controls can be implemented anywhere in the flue gas path from the furnace to just upstream
of the stack. The most common technologies for mitigating SO3 plumes involve addition of alkali
materials, such as magnesium compounds, sodium carbonate, trona, lime, limestone, ammonia,
or sodium bisulfite, in the flue gas. The primary impacts on the fly ash are increases in alkali
content, increases in pH, and addition of soluble salts of sodium, magnesium, calcium, and
sulfate. These could render the ash unusable in concrete due to the higher alkali content, and may
require additional ash pond treatment and disposal site engineering measures due to the higher
soluble salt content and changes in trace constituent mobility at the higher pH.
Mercury removal can affect both fly ash and FGD solids. Mercury captured in the fly ash is
relatively stable at normal temperatures and is not expected to pose a significant environmental
or use concern. However, the use of activated carbon may affect the ability to use the ash in
concrete due to greater need for air-entraining agents. Alternatives are non-carbon sorbents,
treated carbon sorbents, and fly ash beneficiation to remove or passivate the carbon.
Additionally, re-release of mercury at high temperatures in cement kilns may limit fly ash use in
some cement applications. Mercury also may be captured in the FGD system. Research is
currently underway on the partitioning of mercury in the absorber and on evaluating the effect of
increased mercury concentrations on FGD solids used in wallboard and agricultural applications.
EPRI Perspective
Both power plant control technologies and environmental regulations are continually evolving. A
key component of EPRIs research is to understand the impact of emerging control technologies
on CCP characteristics, and to develop methods to preserve or enhance CCP management
opportunities. This information can be used by power companies to make informed decisions
with respect to implementation of control technologies, to assess the impacts that they will have
on CCP management, and to assess alternative CCP management strategies.
Keywords
Coal combustion products
Characterization
Use
Disposal
Emissions controls
vi
CONTENTS
1 INTRODUCTION ....................................................................................................................1-1
2 HIGH-VOLUME COAL COMBUSTION PRODUCTS ............................................................2-1
Fly Ash ..................................................................................................................................2-2
Flue Gas Conditioning for Fly Ash Capture ......................................................................2-3
Fly Ash Resistivity Conditioning...................................................................................2-3
Fly Ash Cohesivity Conditioning ..................................................................................2-4
Bottom Ash............................................................................................................................2-5
Boiler Slag .............................................................................................................................2-5
FGD Solids ............................................................................................................................2-6
Wet FGD Systems............................................................................................................2-6
Inhibited or Low Natural Oxidation FGD Systems .......................................................2-8
Forced Oxidation or High Natural Oxidation Systems .................................................2-9
Dry FGD Systems...........................................................................................................2-11
Spray Drying Systems ...............................................................................................2-11
Dry Injection Systems ................................................................................................2-12
Furnace Sorbent Injection (FSI) Systems ..................................................................2-12
References ..........................................................................................................................2-13
3 NOX CONTROL TECHNOLOGY ............................................................................................3-1
Combustion Modifications/Low-NOX Burners ........................................................................3-1
Technology Description ....................................................................................................3-1
Impact on CCPs ...............................................................................................................3-1
Rich Reagent Injection (RRI).................................................................................................3-2
Impact on CCPs ...............................................................................................................3-2
Selective Non-Catalytic Reduction (SNCR) ..........................................................................3-3
vii
Impact on CCPs ...............................................................................................................3-3

Selective Catalytic Reduction (SCR).....................................................................................3-5
Impact on CCPs ...............................................................................................................3-5
References ............................................................................................................................3-6
4 SO3 CONTROL TECHNOLOGY.............................................................................................4-1
Fuel Additives........................................................................................................................4-2
Impact on CCPs ...............................................................................................................4-3
Furnace Injection of Magnesium-Based Sorbents ................................................................4-3
Impact on CCPs ...............................................................................................................4-4
Magnesium Oxide Injection Upstream of the Air Heater .......................................................4-5
Impact on CCPs ...............................................................................................................4-5
TM
CleanStack Condensing Air Heater ....................................................................................4-6

Impact on CCPs ...............................................................................................................4-7
Sodium Based Sorbent (SBS) Injection ................................................................................4-8
Impact on CCPs ...............................................................................................................4-9
Ammonia Injection at the Air Heater Outlet .........................................................................4-10
Technology Description ..................................................................................................4-10
Impact on CCPs .............................................................................................................4-12
Dry Sorbent Injection at the Air Heater Outlet .....................................................................4-12
Hydrated Lime Powder Injection.....................................................................................4-12
Technology Description .............................................................................................4-12
Impact on CCPs.........................................................................................................4-13
Trona Injection................................................................................................................4-14
Impact on CCPs.........................................................................................................4-15
Wet ESP..............................................................................................................................4-15
Technology Description ..................................................................................................4-15
Impact on CCPs.........................................................................................................4-16
viii
References ..........................................................................................................................4-16
5 MERCURY REMOVAL...........................................................................................................5-1
Mercury Co-Removal with Fly Ash ........................................................................................5-1
Combustion Modifications ................................................................................................5-1
Technology Description ...............................................................................................5-1
Impact on CCPs...........................................................................................................5-3
Activated Carbon Injection (ACI) ......................................................................................5-3
Impact on CCPs...........................................................................................................5-4
Toxecon and Toxecon II ................................................................................................5-6

Impact on CCPs...........................................................................................................5-7
Non-Carbon Sorbent Injection ..........................................................................................5-8
Impact on CCPs...........................................................................................................5-8
Mercury Co-Removal with FGD By-Products........................................................................5-8
Chemical Addition.............................................................................................................5-9
Impact on CCPs.........................................................................................................5-10
Mercury Oxidation Catalysts...........................................................................................5-11
Impact on CCPs.........................................................................................................5-12
Other Mercury Oxidation Technology.............................................................................5-12
Scrubber Additives .........................................................................................................5-13
Impact on CCPs.........................................................................................................5-13
Mercury Co-Removal in Wet ESPs .....................................................................................5-14
References ..........................................................................................................................5-14
6 ANCILLARY SOLID WASTES ASSOCIATED WITH THE GENERATION AND
MANAGEMENT OF COAL COMBUSTION PRODUCTS .........................................................6-1
Fabric Filters .........................................................................................................................6-1
Spent Selective Catalytic Reduction (SCR) Catalysts...........................................................6-1
Mercury Oxidation Catalysts .................................................................................................6-2
ix
Urea Wastes .........................................................................................................................6-2

FGD Wastewater Treatment Wastes ....................................................................................6-3
Wastewater Treatment Solids ..........................................................................................6-3
Spent Carbon Filtration Beds ...........................................................................................6-4
Demolition Materials..............................................................................................................6-4
References ............................................................................................................................6-5
LIST OF FIGURES
Figure 2-1 Typical Coal-Fired Power Plant Layout ...................................................................2-1

Figure 2-2 Typical Dewatering System for Low Oxidation FGD System...................................2-9
Figure 2-3 Typical Dewatering System for Forced Oxidation Wet FGD..................................2-10
Figure 3-1 Illustration of Typical Locations for NOX Control Technologies................................3-2
Figure 4-1 Typical Locations for Installation of SO3 Control Technologies ...............................4-2
Figure 4-2 Example Process Flow Diagram for Furnace Injection of Magnesium
Hydroxide Slurry.................................................................................................................4-4
Figure 4-3 Illustration of a CleanStack Installation....................................................................4-7
Figure 4-4 Simplified Process Flow Diagram for the SBS Injection Process ............................4-8
Figure 4-5 Simplified Process Flow Diagram for Ammonia Injection (typical).........................4-11
Figure 4-6 Simplified Process Flow Diagram for Hydrated Lime Powder Injection.................4-13
Figure 5-1 Illustration of where Mercury Control Technologies are ..........................................5-2
Figure 5-2 Photograph of an ACI System, Showing the Activated Carbon Storage Silo
(Center of Photo)................................................................................................................5-4
Figure 5-3 Illustration of the Toxecon Process Concept ...........................................................5-6
Figure 5-4 Illustration of the Toxecon II Process Concept ........................................................5-7
Figure 5-5 Example Mercury Oxidation Catalyst Block...........................................................5-11
Figure 5-6 Example Mercury Oxidation Pilot-Scale Catalyst Module (0.5 MW)......................5-12
xi
LIST OF TABLES
Table 2-1 Sorbents and Products of Wet and Dry FGD Systems .............................................2-7
xiii
1
INTRODUCTION
High-volume coal combustion products (CCPs)fly ash, bottom ash, boiler slag, and flue gas
desulfurization (FGD) solidshave been generated at power plants for decades and are well
characterized. Utility CCP managers understand the characteristics of these high-volume CCPs
and how they impact selection of the most appropriate management methods. However, new air
emissions control technologies at power plants will change the characteristics of some existing
CCPs. These changes may affect the selection of appropriate management methods for highvolume CCPs with respect to both disposal and use. In addition, appropriate management
methods have to be determined for any new, lower-volume CCPs generated as a result of these
air emissions controls.
The objective of this report is to summarize possible modifications to power plant environmental
control systems, including new technologies; the possible changes in characteristics of CCPs
resulting from those modifications; and potential impacts on CCP management.
This report is organized into six sections, including this introduction. Section 2 describes the four
high-volume CCPsfly ash, bottom ash, boiler slag, and FGD solids. A general description is
provided for each, including where in the boiler or flue gas path it is produced, physical and
chemical characteristics, and typical management practices.
Sections 3 through 5 describe air emissions control technologies that may impact one or more of
the four high-volume CCPs, or that may produce new, lower-volume CCPs. Each technology is
described in terms of where in the boiler or flue gas path it is applied, its principle of operation,
what impacts it may have on any of the four high-volume CCPs, and whether or not it will
produce a new CCP stream. Where possible, the potential changes in high-volume CCP quantity
or composition are briefly described. Section 3 describes nitrogen oxides (NOX) control, Section
4 describes sulfur trioxide (SO3)/sulfuric acid (H2SO4)control, and Section 5 describes mercury
(Hg) control.
Section 6 describes ancillary solid wastes arising from the generation and management of coal
combustion products.
1-1
2
HIGH-VOLUME COAL COMBUSTION PRODUCTS
According to the American Coal Ash Association (ACAA), high-volume CCP production for
2006 totaled over 124 million tons, with approximately 54 million tons being used in a variety of
construction and manufacturing applications (ACAA, 2007). High-volume CCPs are broken
down into four main types: fly ash, bottom ash, boiler slag, and FGD solids. Each of these
categories is defined by where the product is removed from the system, as well as its physical
properties, chemical composition, and uses. Each is briefly described below. A typical power
plant layout and the locations of solids collection are shown in Figure 2-1.
Economizer
Furnace
Economizer
Ash Collection
FGD Absorber
Air Heater
Particulate
Collector
Bottom
Ash/Slag
Collection
Fly Ash
Collection
FGD Gypsum
Collection
Stack
Figure 2-1
Typical Coal-Fired Power Plant Layout
Other solids are currently generated at some plants as a result of specific air pollution control
technologies installed and operating at those plants. These include spent catalysts, spent FGD
wastewater treatment media, and other maintenance and demolition materials associated with
CCP collection and management. These wastes are addressed in Section 6 of this report.
2-1
High-Volume Coal Combustion Products
Fly Ash
Fly ash is part of the non-combustible portion of coal that, due to its small size, is entrained with
the flue gas after combustion. It is carried along with the flue gas until it drops out or is removed
by a particulate control device.
A small percentage of fly ash drops out in the economizer section of the boiler, which is the last
convection section in the boiler before entering the air heater. Particulate control devices to
remove the remaining fly ash from the flue gas include cold- or hot-side ESPs, fabric filters, and
wet particulate scrubbers. These particulate control devices are capable of removing over 99% of
fly ash in a flue gas stream. Cold-side ESPs are the most common particulate control device in
existing plants and are located downstream of the air heater. They typically operate at
temperatures of 275F to 325F. Hot-side ESPs are located upstream of the air heater and are
typically operated at temperatures around 700F. ESPs remove fly ash using an electrostatic
charge between discharge electrodes and metal collection plates. The electrostatic charge causes
the migration of fly ash to the plates. A rapping system removes the fly ash from the plates into a
hopper system below for collection of the fly ash. Fabric filters are always located downstream
of the air heater because of limitations on bag fabric operating temperatures. Fabric filters collect
fly ash from the flue gas on the bag surface as the gas stream passes through the bags. The bags
are periodically cleaned with a reverse flue gas flow, shaking of the bags, or with a pulse of
compressed air, and the collected fly ash falls into a hopper below each bag compartment. Wet
particulate scrubbers are also located downstream of the air heater. They rely on high-energy
collisions between fly ash particles and scrubber slurry droplets to capture the fly ash in the
droplets. The fly ash is removed by blowing down a portion of the scrubber recirculating slurry
to a dewatering system.
Fly ash is a fine powdery material, comprised mostly of silica, alumina, iron, calcium, other
alkaline earth metals, sulfate, and a number of trace metals (EPRI, 1987). It is tan to gray in
color, and made up of silt- to clay-sized spherical particles, making it similar in feel to talcum
powder. Because of these properties fly ash is a relatively valuable commodity. Fly ashes contain
a high proportion of silica and alumina, and exhibit cementitious properties in the presence of
water and calcium hydroxide (pozzolanic properties), which make them useful as a substitute for
portland cement in concrete products. In fact, some properties of concrete made with fly ash can
exceed those of concrete made with only portland cement. Some fly ash is also used directly as
raw feed in the production of portland cement.
Because of its composition and size distribution, fly ash is also useful as filler in asphalt, road
bases, and soil and waste stabilization. It also has wide application as a structural fill to support
land development, and as a mine fill to reclaim surface mines, reduce subsidence in deep mines,
and help control acid mine drainage. In plants that have wet FGD systems that produce a calcium
sulfite sludge, fly ash is sometimes mixed with the FGD solid, lime, and other pozzolanic
material to form a stabilized material for landfill, or for use as structural fills or mine fills.
2-2
Fly ash generally must be collected and handled dry to be used in high-value applications such as
cement replacement. Fly ash that is collected dry and then transported by a wet sluice system,
and fly ash that is removed in a wet particulate scrubber rather than an ESP or baghouse, is
transported as a wet slurry that is managed in an ash pond, with more limited reuse possibilities.
Fly ash is the highest-volume CCP, with more than 72 million tons produced in 2006 (ACAA,
2007). Nearly 45 percent of the fly ash was utilized, with concrete products and cement
representing the most important application, at over 19 million tons.
A small portion of the fly ash consists of hollow spheres, called cenospheres, that float in ash
ponds and are easily harvested and used in a variety of high-value applications. Approximately
11 million pounds of cenospheres were harvested and sold in 2006 (ACAA, 2007).
Flue Gas Conditioning for Fly Ash Capture
Flue gas conditioning (FGC) is typically implemented to modify fly ash properties so as to
improve collection by cold-side ESPs. Two different types of conditioning are typically
employed. One is to lower fly ash resistivity (a measure of its ability to accept an electrical
charge) and the other is to make the ash more cohesive, such as to avoid re-entrainment losses of
low-resistivity material. Each type of conditioning is briefly discussed below.
Fly Ash Resistivity Conditioning
Fly ash resistivity conditioning is often required when units designed for high-sulfur coal are
switched to lower sulfur, compliance coals. Fly ash itself is composed of minerals containing
silica, alumina, iron, and calcium, among other species. These minerals typically have an
inherently high resistivity, which can limit ESP performance. However, in high-sulfur coals, the
ash resistivity is modified by the presence of SO3 and moisture in the flue gas. These two vaporphase species combine to form vapor-phase sulfuric acid, which adsorbs to the fly ash particles.
The adsorption of sulfuric acid results in a lower resistivity layer at the particle surface, which
improves ESP performance. With lower-sulfur coals, and particularly with alkaline ashes, this
effect is greatly diminished, and ESP performance may be poor because of high ash resistivity.
One solution is to inject SO3 into flue gases that have inherently low SO3 concentrations. Several
different approaches are employed to produce the SO3, such as burning elemental sulfur,
oxidizing pure SO2 at high temperature across a catalyst, or passing a small amount of hot flue
gas across a catalyst to convert its SO2 content to SO3.
Although most resistivity conditioning systems involve injection of SO3 into the flue gas, in
some circumstances the ash resistivity is modified just by evaporating water into the flue gas
between the air heater and ESP. This lowers the flue gas temperature and increases its relatively
humidity. In these cases adsorption of humidity and/or dilute sulfuric acid from the flue gas is
adequate to lower the ash resistivity.
2-3
Resistivity conditioning systems typically have only minor impacts on the fly ash, increasing the
fly ash sulfate and/or moisture content by small percentages. An exception is for plants that use
(or will use) activated carbon to remove mercury in the flue gas by injecting the carbon into the
flue gas upstream of the ESP. In this case, SO3 injected for resistivity conditioning can adsorb on
the carbon and make the carbon less effective at adsorbing mercury, such that greater carbon
injection rates are required. Thus, SO3 injection can indirectly cause an increase in the ash carbon
content for plants that also inject activated carbon for mercury control. This effect is discussed
further in the section on mercury control technology.
Fly Ash Cohesivity Conditioning
In some cases fly ash has a resistivity that is low enough for the particles to accept a charge and
migrate to the collecting plates, but too low to result in strong clamping forces to hold the
particles to the plates. In such cases ESP performance is limited by particle re-entrainment off of
the plates and back into the flue gas stream. Re-entrainment losses can occur during plate
rapping, or can occur just because of the viscous forces of flue gas flowing past the particles on
the plates.
One way to reduce re-entrainment losses is to make the fly ash more cohesive, so that collected
particles tend to stick to one another rather than be held in place only by electrostatic forces. A
common way to achieve this is to inject ammonia into the flue gas in approximately a 1:1 molar
ratio compared to the flue gas SO3 content. The SO3 content can be due to SO3 injection, or due
to the native flue gas SO3 concentration. This type of conditioning is commonly called dual
conditioning because both SO3 and ammonia are involved. By adding ammonia in a 1:1 molar
ratio, the reaction product is ammonium bisulfate (NH4HSO4), also known as ABS, which has a
melting point of 296oF and thus tends to be sticky at cold-side ESP collection temperatures. If the
ammonia injection rate is not carefully controlled and the ammonia-to-SO3 molar ratio
approaches 2:1, the reaction product is ammonium sulfate ((NH4)2SO4), which is stable up to
455oF and does not increase fly ash cohesivity.
Dual conditioning can affect fly ash disposal or reuse, depending on the amount of ammonia
added to the fly ash. Ammonia concentrations up to about 250 ppm have been observed in fly
ash due to FGC (EPRI, 2001). If the fly ash is wetted (e.g., wet sluicing) the ammonium salts
will dissolve. Under alkaline conditions some ammonium ion converts to ammonia, which can
then be released into the atmosphere. Under more acidic conditions, the ammonium ion remains
in the water phase. Ammonia injection for FGC should not have any effects on downstream byproducts (e.g., FGD gypsum) unless the ammonia injection rate exceeds a 2:1 molar ratio
compared to SO3 in the flue gas.
The effects of ammonia injection on fly ash and FGD solids are discussed in more detail in
Sections 3 and 4 under ammonia-based systems for NOX control and ammonia injection for SO3
control, respectively.
Other proprietary additives have been developed that are not based on ammonia injection to
improve ash cohesivity. The impacts of these additives on ash disposal or reuse are not well
documented in the public domain.
2-4
Bottom Ash
Bottom ash is the non-combustible part of coal that, due to its larger size, does not get entrained
with the flue gas after combustion. Instead, bottom ash collects on the furnace walls or in ash
hoppers at the bottom of the furnace. Like fly ash, bottom ash is comprised mostly of silica,
alumina, iron, calcium, other alkaline earth metals, sulfate, and trace metals.
Bottom ash is produced from boilers that operate with their furnace temperatures generally
below the ash fusion temperature. The ash fusion temperature is the point where the ash mineral
matter begins to melt. The ash fusion temperature is different for every fuel and depends on the
concentrations of typical coal ash components; however, the range of melting points for typical
coal ash components is between 1610F and 5070F (Singer, 1991). If the furnace operates at
temperatures below the ash fusion temperature, the bottom ash remains as a solid-phase material
and is relatively porous and free flowing. Bottom ash is a product of dry bottom boilers, which
infers that the bottom ash comes out as a dry (not molten) free-flowing solid material.
Bottom ash has an angular and porous surface, with grain sizes ranging from fine sand to fine
gravel. It can be used as an aggregate in road construction material. Because of its relatively
wide size distribution, it generally does not need to be blended with fine aggregates to meet
gradation requirements. But due to its high surface porosity, it is less durable than conventional
aggregate material and is mostly used in base and shoulder rather than wearing surface mixtures.
It also finds considerable use in concrete and structural fill applications, soil stabilization, snow
and ice control on roads, and blasting grit/roofing granules.
Total production of bottom ash in 2006 was nearly 19 million tons (ACAA, 2007). About 45% of
this total was used, with structural fills, road base, concrete products, and cement production
accounting for more than half of the applications.
Mill rejects are a special class of CCP that are often managed with bottom ash at power plants.
Mills are used for coal size reduction prior to injection into the furnace. Mill rejects are hard rock
fragments, minerals, etc., that cannot be pulverized to the desired size, and are therefore rejected
from the mills. The term pyrites is often used interchangeably with mill rejects, although not
all mill rejects contain pyrite. Characterization data and guidance for the management of mill
rejects was published in a report jointly sponsored by EPRI and the Utility Solid Waste
Activities Group (USWAG) (EPRI, 1999).
Boiler Slag
Boiler slag is, like bottom ash, part of the non-combustible part of coal that due to its larger size
does not get entrained with the flue gas after combustion. In contrast to bottom ash, boiler slag is
produced from boilers that operate their furnace above the ash fusion temperature. If the furnace
operates at temperatures well above the ash fusion temperature, the portion of the ash not
entrained in the flue gas comes out of the bottom of the boiler as a molten mass.
2-5
Boiler slag is a product of primarily older, higher-temperature coal furnaces. Higher furnace
temperatures have fallen out of favor because these high temperatures also favor the formation of
NOX in the flue gas.
Boilers that produce slag are often of the cyclone firing configuration, and are often called slag
tap or wet bottom boilers. In cyclone boilers, the coal feed to the cyclone burners or barrels is
relatively coarse. This results in less of the ash getting entrained with the flue gas and in
production of boiler slag as the majority ash product. In contrast, pulverized coal boilers (most of
which are dry bottom) typically produce more fly ash than bottom ash.
The molten slag is periodically drawn from the bottom of the furnace and is quenched with
water, which causes it to fracture and form pellets. These pellets are hard and angular, with a
glassy appearance similar to obsidian.
Boiler slag, once quenched, is a durable material that is resistant to surface wear, which makes it
desirable for asphalt and roofing applications. It also permanently maintains its black color,
another desirable quality for asphalt. Boiler slag is marketed under the name Black Beauty.1
The supply of boiler slag is diminishing, though, as the older boilers that produce this slag are
being phased out of service.
The total quantity of boiler slag produced in 2006 was about 2 million tons (ACAA, 2007). Most
(83 percent) of this material was used, primarily for blasting grit or roofing granules.
FGD Solids
FGD solids are produced by the removal of SO2 from the flue gas. Because there are many
different types of FGD processes available, different types of FGD solids are produced, varying
from wet sludges to dry powders. In this section, the types of solid FGD materials produced are
described. Since SO2 control will increase substantially over the next ten to twenty years, a
relatively detailed discussion of FGD systems and their solid products is provided.
FGD systems can generally be categorized as wet or dry. Wet FGD systems are often called
scrubbers, and contact the flue gas with an aqueous slurry or solution. The solid produced is
typically in the form of slurry that must be dewatered. As might be expected, dry FGD systems
produce a dry product that does not require dewatering. The primary dry FGD technologies
include the spray drying process, which typically uses slaked lime (Ca(OH)2) as the reagent, and
true dry injection processes, which generally use powdered sodium-based alkalis as a reagent.
There are several variations on spray drying technology, such as circulating fluid bed absorbers,
but these produce solids that are very similar to those from spray drying.
Wet FGD Systems
Most wet scrubbers use slaked lime or limestone (CaCO3) as the alkaline reagent. Some limebased FGD systems use lime with a high magnesia (MgO) content; the high magnesia content
1
Registered trademark of Reed Minerals
2-6
leads to increased liquid-phase alkalinity in the scrubber, and can enhance SO2 removal.
Magnesia-enhanced limes are called Mg-lime in this report.
The FGD solid is either calcium sulfite hemihydrate (CaSO3H2O), gypsum (CaSO42H2O), or
a mixture of the two. Table 2-1 shows the primary sorbents and products for wet and dry FGD
systems.
Table 2-1
Sorbents and Products of Wet and Dry FGD Systems
Process
Wet
Dry (Spray Dryer)
Oxidation Mode
Inhibited Oxidation
Natural Oxidation
Forced
Oxidation
Natural Oxidation
Primary Sorbents
Lime,
Mg-Lime,
Limestone
Lime,
Mg-Lime,
Limestone
Limestone, Lime
(some low-sulfurcoal systems)
Lime,
Alk. Fly Ash,
Na-alkali
Calcium Sulfite
Hemihydrate
Calcium Sulfite
Hemihydrate +
FGD Gypsum
Primary Products
CaSO3H2O
CaSO3H2O +
CaSO42H2O
FGD Gypsum
CaSO42H2O
Calcium Sulfite
Hemihydrate +
Gypsum + Fly Ash
+ unspent sorbent
CaSO3H2O +
CaSO42H2O + Fly
Ash
The design and operation of the wet FGD system determine which type of solid is formed.
Calcium sulfite hemihydrate would be the only solid product formed in the absence of oxygen in
the flue gas. However, since all flue gases have some oxygen content, a portion of the sulfite is
oxidized to the sulfate form. If the oxidation is less than 15%, all of the sulfate gets incorporated
into the calcium sulfite crystal lattice. So even though the solids might contain up to 15% sulfate,
they look and behave as 100% calcium sulfite hemihydrate. As the oxidation exceeds 15%,
gypsum begins to form as a separate solid phase.
FGD systems tend to be most reliable if they operate such that they produce all calcium sulfite
hemihydrate (including up to 15% sulfate) or all gypsum. Thus, it is most desirable to control the
sulfite oxidation at 15% or less, or near 100%. Some FGD systems naturally operate in these
regimes, but most require that the oxidation percentage be controlled, either by inhibiting or
forcing oxidation. Each oxidation percentage control approach is discussed below.
Some wet FGD systems use performance additives to enhance the amount of liquid-phase
alkalinity available in the scrubbing slurry. Typical additives include adipic acid, dibasic acid
(DBA, a by-product that is a mixture of adipic, glutaric, and succinic acids), formic acid, sodium
formate, and magnesium. Most of these additives can be used in either inhibited or forced
oxidation FGD systems, but magnesium (e.g., Mg-lime) is generally used only in inhibited or
low natural oxidation systems, as magnesium sulfite is the alkaline species formed in the FGD
2-7
liquor at high magnesium concentrations. In an in situ forced oxidation system (forced

oxidation within the FGD reaction tank) this sulfite would all become oxidized to the sulfate
form and there would be no benefit from the magnesium. These performance additives can
impact the solid by-products from wet FGD system, either directly through their presence (e.g.,
organic material content of the dewatered by-product) or potentially by modifying the solid byproduct crystal habit and/or dewatering properties (Radian, 1995).
Inhibited or Low Natural Oxidation FGD Systems
Inhibited oxidation systems generally add sodium thiosulfate or elemental sulfur (which reacts
with sulfite to form thiosulfate) to the FGD system. The thiosulfate ion acts as a sulfite oxidation
inhibitor. Some high-sulfur FGD systems naturally operate at low sulfite oxidation percentages.
The ratio of sulfur dioxide to oxygen in the flue gas is important in controlling oxidation
percentages, so high-sulfur systems tend to operate at lower natural oxidation percentages than
low-sulfur systems.
Low oxidation systems produce calcium sulfite hemihydrate, mixed with a small amount of
excess lime or limestone and some inert material (fly ash and inert minerals from the dissolved
lime or limestone) as the absorber slurry. The blow down slurry from the absorber vessels is
usually dewatered in thickeners followed by a centrifuge or vacuum filter, although some
systems blow down directly from the absorbers to a pond. In plants that have dewatering
equipment, the water separated from the solids is usually returned to the FGD absorbers.
Even though many inhibited (or low natural oxidation) systems have two stages of dewatering,
the by-product still contains 30 to 40% moisture. The resulting wet sludge is thixotropic and
difficult to handle, so it is often mixed with fly ash, lime, and sometimes other additives in a pug
mill to produce a relatively dry, stabilized material. This stabilized mixture, sometimes referred
to as fixated scrubber sludge, is often landfilled, but can also be used as structural fill or mine
fill. A typical low oxidation dewatering system is shown in Figure 2-2.
There are relatively few established uses for calcium sulfite hemihydrate. In 2006, 16 million
tons of calcium sulfite hemihydrate were produced, and only 0.9 million tons (6 percent) were
used (ACAA, 2007). It is unlikely that many new inhibited or low natural oxidation systems will
be installed, while it is likely that some of the existing units will be converted to forced
oxidation.
2-8
Figure 2-2
Typical Dewatering System for Low Oxidation FGD System
Forced Oxidation or High Natural Oxidation Systems

Forced oxidation systems pump air into the absorber reaction tank (often called the mix tank or
recycle tank) through distribution devices, typically called spargers. This increases the effective
oxygen-to-SO2 ratio, and is controlled to achieve essentially 100% sulfite oxidation. Some very
low-sulfur coal FGD systems also achieve 100% or nearly 100% oxidation without forced
oxidation systems.
The product resulting from forced oxidation systems is a relatively pure gypsum, referred to as
FGD gypsum. FGD gypsum settles and dewaters much more effectively than calcium sulfite
hemihydrate or calcium sulfite hemihydrate/gypsum mixtures (FGD systems with 15% to 90%
sulfite oxidation). While inhibited oxidation or low natural oxidation FGD systems tend to have
thickeners for primary dewatering, forced oxidation systems generally have hydrocyclones for
primary dewatering and centrifuges, vacuum drums, or vacuum belt filters for secondary
dewatering. A typical forced oxidation wet FGD dewatering system is shown in Figure 2-3.
2-9
Figure 2-3
Typical Dewatering System for Forced Oxidation Wet FGD
FGD gypsum can be dewatered to produce a moist (7 to 12% moisture) but free-flowing solid
that is easily handled. FGD gypsum is a high-value product that is most often used as feedstock
for wallboard production, or less commonly as a soil amendment. In 2006, over 12 million tons
of FGD gypsum were produced, and 79% of that total was used, primarily as feedstock for
wallboard manufacture (ACAA, 2007); FGD gypsum represents approximately 30% of the U.S.
wallboard plant feedstock. Since limestone forced oxidation systems will be the dominant SO2
control technology over the next two decades, the production of FGD gypsum is expected to
increase substantially.
FGD gypsum used for wallboard production typically has relatively strict product specifications
imposed by the wallboard manufacturers. Specifications include free moisture content, gypsum
purity, particle size distribution, and maximum combustibles, chloride, total soluble salt, and/or
ammonia content. Washing is often required during the secondary dewatering step to meet
chloride and ammonia specifications.
Some power plants are not located near wallboard plants and cannot cost effectively ship their
FGD gypsum to a wallboard plant, or produce FGD gypsum that may not meet wallboard
specifications. Such gypsum may be landfilled after dewatering, or it may be stacked. FGD
systems that use a gypsum stack typically do not have primary or secondary dewatering, but send
their absorber blow down to a landfill area where the solids settle to a relatively low free
moisture content and the water is reclaimed to return to the FGD system, or is treated and
2-10
discharged. This area is managed so that with time, the settled gypsum level raises above grade,
producing a stack of settled gypsum solids.
Most wet scrubbers are preceded by an ESP or baghouse for primary particulate control.
However, some older wet scrubbers, built in the 1970s and 1980s, are used for primary
particulate control instead of an ESP or baghouse. These scrubbers typically operate at high
pressure drop (15 to 25 in. H2O) to provide the energy required for efficient particle collection.
These scrubbers may or may not have lime or limestone added to result in high SO2 removal
efficiency as well. Those that do add an alkaline reagent to produce a mixture of fly ash and
calcium sulfite hemihydrate and/or gypsum. The absorber slurry is typically either blown down
to a pond, or dewatered and the dewatered solids are sent to a landfill.
Dry FGD Systems
Dry FGD technologies include spray drying, which typically uses slaked lime as the reagent, and
true dry injection systems, which most often use powdered sodium-based alkalis as a reagent.
These FGD systems produce a dry product that does not require dewatering.
In 2006, an estimated 3.6 million tons of solids were produced by dry scrubbers (EPRI, 2007).
Only about 9 percent were used, with mining applications accounting for most of the utilization
(ACAA, 2007).
Spray Drying Systems
Spray dryer-based FGD is the most common dry FGD technology used in the U.S. However, it
is somewhat of a misnomer to call this technology dry since a slaked-lime-based aqueous
slurry is actually fed to the absorber(s). The slurry is finely atomized in the absorber, and heat
from the flue gas evaporates all of the moisture to produce a dry (typically less than 1%
moisture) solid product.
In most spray dryer FGD systems, the spray dryer vessel is located upstream of the primary
particulate control device (fabric filters are most commonly used due to their SO2 removal
benefits compared to an ESP). Thus, the spray-dried by-product is mixed with the normal fly ash
produced by the unit. It is possible to put a small ESP upstream of the spray dryer vessels to
collect most of the fly ash, retaining it as a high-value product, but this configuration is rarely
used in the U.S. (EPRI, 2007).
The spray drying process solid is a mixture of calcium sulfite hemihydrate, gypsum, excess
slaked lime, and calcium carbonate, and it is most commonly captured along with fly ash in
either an ESP or fabric filter. The solids collected at the bottom of the spray dryer contain
approximately 70% fly ash, 13% calcium sulfite, 7% gypsum, 5% unreacted lime, and 5% water.
The solids collected in the particulate control device contain approximately 72% fly ash, 15%
calcium sulfite, 9% gypsum, 1% unreacted lime, and 3% water (EPRI, 2007). For some lowsulfur-coal applications, the amount of fly ash in the solid can exceed the amount of calciumbased salts. It generally produces a high pH when wetted due to the excess slaked lime and the
alkaline nature of the fly ash (when the process is applied to western coal). The dry product is
2-11
mostly landfilled, but can see limited use in waste stabilization, road base, or solidification
applications.
Most spray dryer FGD systems have what is called a two point solids discharge, as some solids
drop out at the bottom of the spray dryer vessel while the majority are entrained with the flue gas
leaving the vessel and collected in the fabric filter or ESP. The solid material that drops out at the
bottom of the spray dryer tends to be wetter and coarser than the solids collected in the fabric
filter or ESP. The two streams are generally combined when sent to disposal or reuse.
Some spray dryer FGD systems employ some percentage of recycle of the spray-dried solids
with the fresh hydrated lime slurry feed to the atomizers. This recycle improves overall lime
utilization and improves slurry drying characteristics. In systems that employ recycle, it is
generally the fabric filter or ESP catch solids that are recycled, not the spray dryer dropout
material, which is more difficult to handle.
Dry Injection Systems
Although not widely used, there are some plants that employ truly dry FGD processes,
employing dry injection of finely ground sodium alkali, such as trona (sodium sesquicarbonate),
into the flue gas between the air heater and ESP or fabric filter. Dry injection processes are
sometimes mass transfer limited for SO2 removal. Thus, an excess of the sodium-based alkali is
often injected to increase the particle surface area available for absorbing and reacting with flue
gas SO2.
The dry injection by-product is typically a mixture of sodium sulfate and excess sodium alkali,
usually in the form of sodium carbonate. This material is collected along with fly ash in either an
ESP or a baghouse. Because of the highly water-soluble sodium salts present, dry injection solids
are mostly landfilled and not reused. Because an excess of water-soluble, alkaline reagent is
typically injected, ponding of the solid by-product is typically not practical. Leachates from
landfilling of this material can be very alkaline and have high dissolved salt content.
Furnace Sorbent Injection (FSI) Systems
Another dry FGD technology that was developed in the 1970s and 1980s involves injection of
limestone or hydrated lime into the upper furnace; this process is often called furnace sorbent
injection. The injected sorbent is collected along with the fly ash in the existing ESP or fabric
filter. The technology is rarely applied in the U.S. today, but may see increased usage in the
future on small boilers if the value of SO2 allowances remains high. The utilization of the
injected calcium-based sorbents is typically low (10 to 25%), so a large excess of reagent is
required. Thus, the technology typically adds a significant amount of calcium sulfate, calcium
carbonate, lime (CaO), and/or hydrated lime (Ca(OH)2) to the fly ash stream, and results in a
solid that produces a high pH when wetted.
2-12
References
ACAA, 2007. 2006 Coal Combustion Product (CCP) Production and Use Survey. American
Coal Ash Association. www.ACAA-USA.org, 2007.
EPRI, 1987. Chemical Characterization of Fossil Fuel Combustion Wastes. EPRI, Palo Alto,
CA: 1987. EA-5321.
EPRI, 1999. Guidance for Comanagement of Mill Rejects at Coal-Fired Power Plants. EPRI,
Palo Alto, CA: 1999. TR-108994.
EPRI, 2001. Characterization of Ammonia Leaching from Coal Fly Ash. EPRI, Palo Alto, CA:
2001. 1005163.
EPRI, 2007. A Review of Literature Related to the Use of Spray Dryer Absorber Material:
Production, Characterization, Utilization Applications, Barriers, and Recommendations. EPRI,
Palo Alto, CA: 2007. 1014914.
Radian, 1995. The Effects of Flue Gas Desulfurization (FGD) Additives on Solid By-Products.
EPRI, Palo Alto, CA: 1995. TR-102367.
Singer, 1991. Combustion Fossil Power. Combustion Engineering, Inc., Connecticut.
2-13
3
NOX CONTROL TECHNOLOGY
NOX control technology consists primarily of four technology types: furnace combustion
modifications, which for the purposes of this report include the use of low-NOX burners; rich
reagent injection (RRI), which is implemented in the furnace; selective non-catalytic reduction
(SNCR), which is implemented in the upper furnace; and selective catalytic reduction (SCR),
which is implemented between the economizer and air heater. Figure 3-1 illustrates where in the
flue gas path each of these technologies would typically be located. The technologies and their
impacts on coal combustion products are discussed below.
Combustion Modifications/Low-NOX Burners

Technology Description
Combustion modifications and/or low-NOX burners control the formation of NOX during the fuel
combustion process, generally by limiting the availability of oxygen as fuel nitrogen is released.
They typically involve some form of staged combustion, wherein certain areas of the furnace
operate fuel rich, then additional air is added to complete combustion. Overfire air (OFA), or
separate overfire air (SOFA), is often added above the burner level to stage combustion
conditions.
A challenge that sometimes limits the effectiveness of combustion modifications and low-NOX
burners is to lower NOX emissions while still ensuring complete fuel combustion. Increased flue
gas carbon monoxide (CO) concentrations and/or increased loss on ignition (LOI) in the fly ash
can result from low-NOX firing conditions.
Impact on CCPs
The primary impact of low-NOX burners to the CCPs is higher LOI levels in the fly ash. Higher
LOI adversely affects the air-entraining properties of concrete made with the fly ash, which can
in turn adversely affect fly ash sales for concrete if the LOI exceeds ASTM C-618 specification
(6 percent LOI) or contractual limits due to increased need for air entraining. Higher carbon
content may also slightly increase the concentration of some trace elements in the fly ash due to
its greater adsorption capacity, but also may reduce their leachability.
Because combustion modifications and low-NOX burners impact firing conditions in the furnace,
it is also possible that bottom ash characteristics could be slightly altered.
3-1
NOX Control Technology
Economizer
SNCR
Combustion
Modifications,
RRI
SCR
Furnace
Air Heater
Particulate
Collector
FGD Absorber
Stack
Figure 3-1
Illustration of Typical Locations for NOX Control Technologies
Finally, as the LOI content of the fly ash increases, it is possible that unburned carbon can
penetrate a cold-side ESP, as the carbon has a low electrical resistivity and has a tendency to be
re-entrained. Consequently, this technology could lead to an increase in the amount of carbon
captured in the wet FGD system and increase the carbon content of a gypsum by-product.
Rich Reagent Injection (RRI)

RRI involves injecting urea or ammonia into fuel-rich portions of the furnace to reduce NOX
formation. The technology was originally developed for NOX control for cyclone-fired coal
boilers, but can be applied to other boiler types. It involves staged combustion and overfire air as
the means of producing a fuel-rich zone in the furnace. The technology can be combined with
low-NOX burners and/or with SNCR, which is discussed in the next subsection, to result in
greater overall NOX reduction.
Impact on CCPs
RRI technology would primarily impact the fly ash, where it would have similar impacts as
described above for combustion modification/low-NOX burners. Although the RRI technology
also involves injecting urea or ammonia into the furnace, these are reportedly destroyed at high
efficiency within the furnace so ammonia slip is essentially zero. Thus, little or no contamination
of the fly ash with ammonia is expected if RRI alone is implemented on a unit (RJM, 2007).
3-2
Selective Non-Catalytic Reduction (SNCR)

SNCR is used to chemically reduce NOX formed in the furnace, by oxidation/reduction reactions
between ammonia and NOX within a certain temperature range. The name for this technology
comes from the fact that the ammonia reactions are selective for NOX in the target temperature
range, but no catalyst is used. SNCR is typically implemented in the upper furnace. Urea is often
used as the ammonia source, as urea decomposes to form ammonia at elevated temperatures.
Urea is often preferred over pure ammonia because of health and safety issues associated with
handling ammonia, and the fact that the trajectory and penetration of urea injected as an aqueous
solution into an upper furnace can be better controlled than when injecting gaseous ammonia.
Chemical equations showing the conversion of urea to ammonia and the reduction of NOX by
ammonia are shown below (Bhattachara at al., 2003).
NH2CONH + (1+x)H2O NH4COONH2 + (x)H2O 2 NH3 + CO2 + (x)H2O

4 NO + 4 NH3 + O2 4 N2 + 6 H2O
2 NO2 + 4 NH3 + O2 3 N2 + 6 H2O
Because SNCR relies solely on gas-phase reactions (no catalyst is used), an excess of
urea/ammonia is typically required to get higher NOX reduction levels (e.g., 40 to 60% NOX
reduction levels). While most of the excess ammonia is destroyed at upper furnace temperatures,
ammonia slip (excess ammonia in the flue gas leaving the economizer of the boiler) is
common with SNCR installations. It is generally desirable to control ammonia slip to 2 ppm or
less in the flue gas entering an air heater, to avoid excessive formation of ABS within the air
heater and resulting air heater pressure drop increases. However, many SNCR applications
exceed this level of ammonia slip.
Impact on CCPs
The biggest issue for ammonia injection is its effect on fly ash disposal/reuse; it will not affect
bottom ash or boiler slag. Ammonia can be collected as ABS with the fly ash in the downstream
particulate control device, or even penetrate the particulate control device and impact the FGD
system. At 2 ppm of ammonia slip, the ABS formed would amount to about 300 ppm as
ammonia (NH3) if it all reports to the fly ash. Since many SNCRs exceed 2 ppm slip, higher
ammonia concentrations on fly ash can be expected. Ammonia concentrations as high as 900
ppm have previously been reported (EPRI, 2001). At this ammonia concentration there may be
issues with ammonia in fly ash in some disposal settings and reuse applications. In general, fly
ashes from subbituminous coals (e.g., Powder River Basin) adsorb less ammonia than fly ashes
3-3
from bituminous coals (EPRI, 1999). Ammonia that is not adsorbed on the fly ash in a system
that has no FGD system will exit the unit out the stack.
Ammonia can be released in vapor form if the fly ash is contacted with water, especially when
the ash pH is naturally alkaline (pH > 7.0). Ammonia odors will result if alkaline ash is sluiced
to an open pond or if dry ash is wetted in uncovered portions of a landfill. Ammonia vapor will
also be released if the fly ash is used as an admixture for cement or concrete, or if the ash is
mixed with FGD by-products and lime for stabilization, due to high pH conditions in both of
these applications. Also, if caustic is added to a pond or landfill leachate to raise its pH to within
the range allowed by the plant NPDES permit, a substantially higher ammonia vapor pressure
could result in the vicinity of the caustic addition. The amount of ammonia released and the odor
level in any of these scenarios depend on the amount of ammonia adsorbed on the ash and the
pH.
Several methods have been advanced for the beneficiation of ammoniated fly ash for eventual
use. These include chemical treatment using the Ammonia Slip Mitigation (ASM) technology
(EPRI, 2005a) and removal using humid air (EPRI, 2002).
Ammonia salts are highly soluble and are readily released to the water phase as ammonium ion.
As much as 70 percent of the ammonia adsorbed to the fly ash is released almost immediately on
contact with water in batch leaching tests (EPRI, 2001). Ash sluiced to ponds will have relatively
low ammonia concentrations (<10 ppm) due to the large volume of sluice water, and the ponds
are effective at removing ammonia through biologic uptake and volatilization (EPRI, 2003). In
landfills, the much lower volumes of contact water from rainfall can result in much higher
ammonium concentrations in solution, again depending on the initial adsorbed ammonia and the
pH (EPRI, 2001).
The presence of the ammonia can also impact the leaching of trace constituents from the fly ash
to some degree, by altering the solution pH or by complexing with some of the metals.
Depending on the direction of the pH change, leaching of some trace constituents may increase,
while others may decrease. Ammonia complexation is only likely to significantly affect metals
concentrations at alkaline pH and very high ammonia levels (>1000 mg/L), much higher than
would occur in a ponded environment (EPRI, 2005b; Wang et al., 2007; EPRI, 2008). These high
concentrations potentially may be attained in localized areas of a landfill for short periods for fly
ash exposed to very high ammonia slip levels, but are not expected to be typical.
Most of the ammonia slip is expected to be retained in the fly ash, however some may also be
captured in the FGD solids. This situation is more likely when ammonia is used for SO3
mitigation. The impact of ammonia on FGD solids will be discussed in more detail in the next
section under SO3 control.
3-4
Selective Catalytic Reduction (SCR)

Like SNCR, SCR chemically reduces NOX formed in the furnace by oxidation/reduction
reactions with ammonia, but with SCR this occurs in the presence of a catalyst. The catalyst
provides active surface area on which these reactions can take place, so nearly equimolar
quantities of ammonia are added compared to the amount of NOX in the flue gas. The catalysts
typically are made of a ceramic material that includes titanium oxide as a carrier and a vanadium
oxide as the active species. Some catalysts also use an oxide of tungsten as part of the active
species. Catalysts are most commonly installed in a honeycomb or plate configuration (DOE,
1997).
The catalytic reactions proceed most rapidly at temperatures in the range of 600oF to 750oF, so
SCR reactors are typically installed between the economizer and air heater (Figure 3-1).
Ammonia slip remains an issue with SCR, but most well-controlled SCR systems limit ammonia
slip to less than 2 ppm in the air heater inlet flue gas. Ammonia slip tends to increase with the
age of the catalyst.
Impact on CCPs
The impacts of ammonia injection on CCPs will be similar to those previously described for
SNCR systems. However, since SCR systems generally are well controlled and have much lower
slip than SNCR systems, the fly ash contains much less ammonia. Accordingly, the adverse
impacts on fly ash are less. As previously noted, at 2 ppm of ammonia slip, the ABS formed
would amount to about 300 ppm as ammonia (NH3) if it all ends up in the fly ash. Most SCRs
operate at 2 ppm or less slip. Concentrations less than 100 ppm ammonia in fly ash have been
previously reported for operating SCR facilities (EPRI, 2001). Even at this ammonia
concentration there may be issues with ammonia in fly ash in some reuse applications.
Speciation of mercury has been shown to be affected by the SCR catalyst (Lee et al., 2004), and
other redox sensitive constituents (As, Cr, Se) may also be affected. Speciation changes may
affect their capture on CCPs. For example, elemental mercury can be oxidized to ionic mercury,
increasing its capture in wet FGD systems. The combination of SCR and wet FGD is likely to
play a significant role in mercury capture. This is discussed in more detail in Section 5 under
mercury co-removal with FGD solids. Changes in the capture and leaching characteristics of
other redox sensitive elements are unlikely to significantly change the overall character of the
CCPs from a disposal perspective, but may be important in the treatment of ash pond discharge
waters due to differences in treatability of the different species. Recent leaching research
suggests that the release of chromium from fly ash may be increased by SCR operation (EPA,
2008).
3-5
References
Bhattacharya et al., 2003. Urea to Ammonia (U2A) systems: Operation and Process
Chemistry. Combined Power Plant Air Pollutant Control symposium. Washington D.C, 2003.
DOE, 1997.
www.fossil.energy.gov/programs/powersystems/publications/Clean_Coal_Topical_Reports/topic
al9.pdf, July 1997.
EPA, 2008. Characterization of Coal Combustion Residues from Electric Utilities Using Wet
Scrubbers for Multi-Pollutant Control. F.Sanchez, D. Kosson, R. Keeney, R. Delapp, L. Turner,
and P. Kariher. EPA/600/R-08/077. 2008.
EPRI, 1999. Investigation of Ammonia Adsorption on Fly Ash and Potential Impacts of
Ammoniated Ash. EPRI, Palo Alto, CA: 1999. TR-113777.
EPRI, 2001. Characterization of Ammonia Leaching from Coal Fly Ash. EPRI, Palo Alto, CA:
2001. 1005163.
EPRI, 2002. Novel Ash Beneficiation Processes for Managing Unburned Carbon and Ammonia.
EPRI, Palo Alto, CA: 2002. 1004395.
EPRI, 2003. Fate of Ammonia in Ash Ponds; Site F Pilot Field Studies. EPRI, Palo Alto, CA:
2003. 1005410.
EPRI, 2005a. Ammonia Removal from Fly Ash: Process Review; Headwaters Ammonia Slip
Mitigation (ASM) Technology. EPRI, Palo Alto, CA: 2005. 1010381.
EPRI, 2005b. Effects of Ammonia on Trace Element Leaching from Coal Fly Ash. EPRI, Palo
Alto, CA: 2005. 1010063.
EPRI, 2008. The Effect of Ammonia on Mercury Partitioning in Fly Ash. EPRI, Palo Alto, CA:
2008. 1014014.
Lee et al., 2004. Lee, CW, Srivastava, RK, Ghorishi, SB, Hastings TW, and Stevens, FM. 2004.
Investigation of Selective Catalytic Reduction Impact on Mercury Speciation under Simulated
NOx Emission Control Conditions. J. Air & Waste Manage. Assoc. 54:15601566.
RJM, 2007. www.RJM.com/pdf/richreagent.pdf
Wang, 2007. Wang, J, Wang, T, Mallhi, H, Liu, Y, Ban, H, Ladwig, K. 2007. The Role of
Ammonia on Mercury Leaching from Coal Fly Ash. Chemosphere, in press.
3-6
4
SO3 CONTROL TECHNOLOGY
Coal combustion results in the liberation of sulfur primarily as sulfur dioxide, SO2. Sulfur
trioxide (SO3) and/or sulfuric acid (H2SO4) is present in the flue gas from coal firing because of
the further oxidation of a small percentage of the coal sulfur (typically 0.5 to 1.5%) to SO3 rather
than SO2. As the flue gas cools across the air heater, the SO3 combines with flue gas moisture to
form gas-phase sulfuric acid. At the inlet to a wet FGD absorber, a sub-micron diameter sulfuric
acid mist is formed when the flue gas is humidified and cooled, which causes the gas-phase
sulfuric acid to rapidly condense. This sub-micron acid mist behaves like small particles rather
than as a gas in the wet absorber, and is not removed at high efficiency. The mist that exits the
scrubber very effectively scatters light, which leads to visible plume opacity (sometimes referred
to as blue plume). Other adverse effects can result from having SO3/sulfuric acid in the flue gas,
such as ESP and duct corrosion, air heater plugging, or the need to increase air heater outlet gas
temperatures to avoid such problems.
Plume opacity issues due to SO3 mist have increased recently due to the installation of SCRs.
Over the past decade, a number of coal-fired generating units have retrofitted SCR systems in
their boiler flue gas path for NOX control. SCR catalysts are oxidation catalysts (the injected
ammonia is oxidized, which correspondingly chemically reduces NOX species), and can oxidize
other flue gas species such as SO2 and mercury. Typically, 0.5 to 1.5% of the flue gas SO2 is
oxidized to SO3 across an SCR catalyst. The retrofitting of SCR systems can therefore
significantly increase flue gas SO3 concentrations at the air heater inlet due to further oxidation
of flue gas SO2 across the SCR catalysts.
Wet FGD systems generally condense all of the SO3/sulfuric acid in a flue gas, making it more
visible. After SCR and wet FGD systems have been retrofitted on units currently firing
compliance coals, it may be cost effective to switch from low-sulfur to higher-sulfur coal. With
the resulting increase in flue gas SO2 concentrations, along with SCR catalysts to oxidize a
portion of the SO2 to SO3 and wet scrubbers to condense sulfuric acid mist, many units may
experience a stack gas opacity increase, and sulfuric acid controls may be required. A number of
units have already experienced these issues and have installed some form of SO3 control. This
section describes currently available technologies and the effects of SO3 controls on coal
combustion products.
As described above, SO3 is formed in the furnace and in downstream SCR systems, and the most
tangible manifestation of sulfuric acid in the flue gas is stack plume visibility. Consequently, SO3
controls can be implemented anywhere in the flue gas path from the furnace to just upstream of
the stack. Figure 4-1 shows a number of SO3 control technologies, and illustrates where in the
flue gas path they are likely to be implemented. Each of these technologies is described in the
following subsections. The technologies are discussed below in approximately the same order as
they are shown in the flue gas path illustration in Figure 4-1.
4-1
SO3 Control Technology
- SBS Injection?
Furnace
Mg
Injection
Economizer
- Mg Injection
- SBS Injection
- Hydrated Lime Injection
- Condensing Air Heater
Furnace
Air Heater
- Fuel
Additives
Wet ESP
Particulate
Collector
- Ammonia Injection
- Hydrated Lime Injection

- SBS Injection
- Trona Injection
FGD Absorber
Stack
Figure 4-1
Typical Locations for Installation of SO3 Control Technologies
Fuel Additives
Fuel additives have long been used as an approach for SO3 mitigation for oil-fired units. The
additives typically include some form of magnesium oxide or magnesium hydroxide. In oil-fired
units, the magnesium-based additives primarily prevent SO3 formation by tying up vanadium in
the ash in the form of unreactive magnesium vanadates. Fuel additives have typically been less
effective on coal-fired units, where the primary control mechanism appears to be removal of SO3
after it is formed, through gas-solid reactions. These additives are typically added to the coal
from a storage silo as the coal is conveyed to the bunkers. Since the additives are injected into
the furnace with the fuel they can become dead burned or sintered by the high temperatures to
which they are exposed, and thus less reactive with the SO3 formed. The injected sorbent is
collected in the ESP or baghouse along with the fly ash. A portion of the additive may end up in
the bottom ash stream.
One proprietary fuel additive for coal-based applications is OmniClearTM. Based on information
provided in company literature, the additive appears to be ground dolomite (MgCO3CaCO3),
sized to 75% minus 200 mesh, that is partially calcined then treated with a coating that helps
prevent dead burning (OmniClear, 2003). The company literature reports an additive rate for a
3% sulfur coal application of approximately 0.5 to 1.0 wt% of the coal feed rate.
4-2
Impact on CCPs
For a coal with 3% sulfur and 8% ash, and assuming a dry-bottom boiler with 80% of the ash
leaving as fly ash, the additive rate above would correspond with an 8% to 17% increase in the
amount of fly ash if it all reports to the fly ash rather than bottom ash. The added material would
be a mixture of calcium and magnesium oxides, carbonates, and sulfates. Because a considerable
excess of the alkaline additive is generally required, if the fly ash is disposed of in a pond or
landfill, the pH of ash pond water or landfill leachates may be increased if this technology is
implemented. The higher pH would also affect the leachability of trace constituents, possibly
increasing leachability of some (e.g., oxyanions) and decreasing others (e.g., trace metals). The
increased alkalis could also affect the use of the ash in concrete.
No effects on downstream solids, such as FGD gypsum, are expected. Injection of the additives
at high rates can adversely affect cold-side ESP performance, due to two effects. One is that the
magnesium- and calcium-based materials tend to have a high electrical resistivity, and the other
is that the removal of SO3 from the flue gas stream tends to increase fly ash resistivity. These
effects could lead to fly ash and spent sorbent carryover into the FGD system. However, it is
most likely that particulate emission and opacity limits would require that injection rates be
lowered before such carryover from the ESP got to a level that could impact FGD solids.
Furnace Injection of Magnesium-Based Sorbents

As mentioned above, magnesium hydroxide or magnesium oxide has been injected into the
furnaces of oil-fired power plants and, to a lesser extent, coal-fired power plants to achieve
moderate levels of SO3 control for many years. More recent testing has focused on the injection
of magnesium hydroxide slurries into the upper regions of coal-fired furnaces to achieve 90+%
removal of furnace-formed SO3. The technology has been installed for SO3 control on at least
two large coal-fired units with SCR.
In this technology, magnesium hydroxide is typically fed as a slurry into the upper furnace,
where temperatures are lower, to prevent dead burning of the sorbent (EPRI, 2002). When
magnesium hydroxide slurry is injected into the furnace, the water evaporates and leaves a solid
MgO particle. The MgO solid reacts with SO3 in the gas phase to form magnesium sulfate
(MgSO4). Magnesium sulfate is water soluble and therefore unlikely to form hard deposits in the
boiler. The magnesium sulfate solids are removed along with fly ash in the downstream
particulate control device. Figure 4-2 is an example process flow diagram for how magnesium
hydroxide injection in the furnace would typically be implemented.
4-3
Filter
Blower
LIC
Storage
Tank
Day
Tank
LIC
Atomizing
Air
PI
Truck
or Barge
Unloading
M
Moyno Pump
PI
FI
VFD
FIC
Unit
Load
Injection
Lance
1 of 12 per unit
Figure 4-2
Example Process Flow Diagram for Furnace Injection of Magnesium Hydroxide Slurry
Adding MgO in the boiler may modify coal ash fusion temperatures and slag properties, making
slag deposits more friable (Benson, 2003). One vendor reports that they have optimized furnace
injection of magnesium sorbents by the use of computational fluid dynamics (CFD) modeling to
target injection towards key spots in the upper furnace. They call this technology targeted infurnace injection (TIFI) 2 . They claim that they can reduce boiler slagging and fouling as well
as effectively control stack gas SO3 concentrations (Fuel Tech, 2007).
Impact on CCPs
Magnesium hydroxide slurry is available as a commercial product, or it can be produced on site
at plants equipped with a Thiosorbic lime FGD system. Required sorbent injection rates will
depend on the coal sulfur, percent SO3 removal required, and whether or not the injection
locations have been optimized. For a 3% sulfur coal, the amount of fly ash collected could
increase by 2 to 8%. The increased mass in the fly ash would consist of a mixture of magnesium
oxide, sulfate, and carbonate if commercial magnesium hydroxide is used. If by-product
magnesium hydroxide is used, the amount in the fly ash would be increased by about one-third.
The increased mass would be due to gypsum impurities in the magnesium hydroxide.
Because a considerable excess of the alkaline additive is generally required, the pH of ash pond
water or landfill leachates would likely increase if this technology is implemented on a unit that
disposes of its ash. The higher pH would also affect the leachability of trace constituents,
possibly increasing leachability of some (e.g., oxyanions) and decreasing others (e.g., trace
TIFI is a trademark of Fuel Tech.
4-4
metals). The increased alkalis could also affect the use of the ash in concrete. Little, if any, of the
material injected into the upper furnace should end up in the bottom ash or boiler slag.
No effects on downstream solids, such as FGD gypsum, are expected. Injection of magnesium
hydroxide slurries at very high rates can adversely affect cold-side ESP performance, as
described above, which could lead to fly ash and spent sorbent carryover into the FGD system.
However, it is more likely that sorbent injection rates would be controlled at lower rates to avoid
exceeding particulate emissions and opacity limits, and thus would not impact FGD solids.
Magnesium Oxide Injection Upstream of the Air Heater

Magnesium oxide or magnesium hydroxide slurry can be injected into the furnace as described
above or post-combustion; this discussion is focused on injection downstream of the economizer
and/or SCR and upstream of the air heater.
Three versions of magnesium alkali injection upstream of the air heater for SO3 control are under
development or are being applied commercially. Each is described below.
One version uses a highly reactive magnesium oxide (MgO) powder that is typically injected
pneumatically into the flue gas upstream of the air heater. Injection rates are generally low,
ranging from about 0.5:1 to 1.5:1 molar ratio of magnesium oxide to SO3 (Martin Marietta,
2003). The MgO reacts with SO3 to form magnesium sulfate.
Another technology, called targeted duct injection (TDI) 3 , injects magnesium hydroxide slurry
into the flue gas downstream of the SCR but upstream of the air heater. The technology vendor
reports that through a combination of TIFI (discussed earlier) and TDI if needed, treatment rates
to produce a clear stack range from about 2 to 6 lb of sorbent injected per ton of coal fired in the
unit treated (Schulz, 2006).
A DOE co-sponsored pilot-scale evaluation used by-product magnesium hydroxide slurry
injection upstream of an air heater, combined with low air heater exit temperatures, to achieve as
high as 80% mercury capture. The by-product magnesium hydroxide slurry was previously
described in the furnace injection discussion. As part of this testing, it was determined that by
o
operating with an air heater outlet temperature as low as 220 F along with injecting the byproduct magnesium hydroxide, nearly complete capture of the flue gas SO3 was achieved as well
(Winschel, 2005).
Impact on CCPs
Implementation of any of these three technologies would increase the fly ash mass rate by about
2 to 5%. The added material would be a mixture of magnesium sulfate, carbonate and hydroxide.
3
TDI is a trademark of Fuel Tech.
4-5
The bottom ash should be unaffected by this technology, or any of the post-combustion
technologies discussed later in this subsection. Because an excess of the alkaline additive is
generally required, if the fly ash is disposed of in a pond or landfill, the pH of ash pond water or
landfill leachates may be increased if this technology is implemented. The higher pH would also
affect the leachability of trace constituents, possibly increasing leachability of some and
decreasing others. The increased alkalis could also adversely affect the use of the ash in concrete.
As with the previous magnesium-injection technologies discussed earlier, no effects on
downstream by-products such as FGD gypsum are expected. Injection of magnesium oxide or
magnesium hydroxide slurries at high rates can adversely affect cold-side ESP performance,
which could lead to fly ash and spent sorbent carryover into the FGD system. However, it is
likely that sorbent injection rates would be controlled at lower rates to avoid exceeding
particulate emissions and opacity limits and would not impact FGD solids. Also, in the case of
the DOE-cosponsored technology, the lower air heater outlet temperature would tend to offset
adverse effects of the sorbent injection due to the decreased gas volume and increased gas
relative humidity.
CleanStackTM Condensing Air Heater 4

In the air heater, the primary mechanisms for the reduction of gas-phase SO3 are the adsorption
and condensation of SO3/H2SO4. Condensation occurs when the temperature is lower than the
dew point of sulfuric acid, which could occur in the cold end of a regenerative air heater. The
sulfuric acid condenses both on ash particles in the flue gas and on cold air heater surfaces.
Modeling by the University of North Dakota Energy and Environmental Research Center
(EERC) has shown that sulfuric acid condensation occurs primarily on sub-micron-diameter ash
particles (Hamel, 2003).
CleanStack is a process that will enable the air heater to operate with a lower exit temperature,
achieving high sulfuric acid capture and improving the plant heat rate. Injection of micronized
limestone provides additional surface area for acid condensation, and helps neutralize the
condensed acid. Coarsely ground limestone is micronized to a 2- to 3-micron median diameter
with a jet pulverizer as it is injected (Bowes, 2006). Figure 4-3 illustrates a typical micronized
limestone grinding and injection system.
A full-scale implementation of the technology has reportedly been conducted on one of two air
heaters on a 350-MW unit (Bowes, 2006). Micronized limestone was injected at a rate of 500
lb/hr upstream of the air heater. Assuming the unit was operating near full load and that one-half
of the flue gas was treated, this injection rate corresponds with approximately a 6% increase in
the fly ash mass rate. The added material would be a mixture of excess limestone (CaCO3) and
calcium sulfate (CaSO4), and any impurities in the limestone.
CleanStack is a trademark of Marsulex Inc.
4-6
Impact on CCPs
Because an excess of the alkaline additive is generally required, the pH of ash pond water or
landfill leachates may be increased if this technology is implemented. However, because the
excess reagent will be calcium carbonate rather than stronger alkalis like hydroxides or oxides,
the pH should not rise much above 8. This could affect the leachability of some metals, but to a
lesser degree than technologies using the stronger alkalis.
Figure 4-3
Illustration of a CleanStack Installation
Although the calcium-based sorbent would be expected to have a high resistivity, and removal of
SO3 from the flue gas also increases ash resistivity, the lowered air heater exit temperature
should tend to offset adverse effects on cold-side ESP performance. Therefore, this technology
may not have an adverse effect on ESP performance and consequently on the FGD solids.
4-7
Sodium Based Sorbent (SBS) Injection

The SBS Injection process injects a clear, aqueous solution of sodium bisulfite [SBS] (NaHSO3),
sodium sulfite (Na2SO3), and/or sodium carbonate (Na2CO3) into the flue gas. The injection
location can be either upstream of the air heater (typically between an SCR and the air heater) or
downstream of the air heater (between the air heater and cold-side ESP). Upstream injection is
preferred by the process developers (Moser, 2007). Development work is also underway to
determine if the SBS Injection process could be implemented upstream of an SCR. Figure 4-1
shows the typical SBS Injection process locations in the flue gas path, including possible
injection upstream of an SCR.
The reagent is injected as a solution through an array of air-atomized nozzles, and is fed at
relatively low molar feed ratios, typically not much more than the theoretical amount required to
react with all of the SO3 in the flue gas. The reaction products are salts containing sodium and
sulfate, and are collected along with fly ash in the cold-side ESP, baghouse or other particulate
control device. Figure 4-4 is a typical process flow diagram for the process.
INJECTION AIR:
PLANT AIR OR
COMPRESSOR
SBS DILUTION WATER
FILTER
(SOFTENED)
SOLIDS
WETTING
PUMP
DILUTION
WATER
TANK
DUPLEX
STRAINER
DILUTION
WATER
PUMP
DE
FE
HOPPER
TRUCK
REAGENT
SOLUTION
STORAGE
TANK
FLUE GAS
FE
INJECTION
FEED
PUMP
Figure 4-4
Simplified Process Flow Diagram for the SBS Injection Process
4-8
INJECTION
LANCES
Initially it was thought that sodium sulfate (Na2SO4) was the primary reaction product. However,
it is apparent that other sodium species are formed with sodium to SO3 molar ratios closer to 1:1
(e.g., sodium bisulfate [NaHSO4], which is sticky like ABS). In installations where injection
occurs upstream of the air heater, the molar ratio of sodium in the reagent to SO3 in the flue gas
is controlled near 2:1. This typically ensures high SO3 removal efficiency and facilitates the
formation of sodium sulfate as the primary by-product.
The SBS reagent can consist of commercially available sodium carbonate, sodium bisulfite, or
sodium sulfite, or a by-product that is typically a mixture of sodium bisulfite and sulfite. The
reagent can be received as a clear solution (typically 25 to 30 wt% dissolved solids) or as a dry
powder. The dry powder must be mixed with softened plant water to obtain the desired reagent
concentration.
One additional benefit is possible when using the SBS process to remove SO3 at high efficiency
upstream of the air heater, on plants equipped with SCR. It may be possible to operate an SCR at
higher ammonia slip without ABS formation in the air heater if the SO3 concentration is
controlled to very low levels (e.g., 2 ppmv or less). Once the ammonia concentration is higher
than the SO3 concentration in the flue gas entering the air heater, ammonium sulfate rather than
ABS forms. Higher ammonia slip can produce benefits such as allowing for longer catalyst life
and/or higher NOX reduction percentages. However, operating in this mode would likely increase
the ammonia concentration found in the fly ash.
Another benefit the vendor claims is that by removing SO3 upstream of the air heater, unburned
carbon in the fly ash can more effectively adsorb mercury. Adsorption of mercury by unburned
carbon in the ash appears to occur as the flue gas is cooled in the air heater. SO3 is known to
compete with mercury for adsorption sites on unburned carbon in fly ash. Thus, the mercury
content of the fly ash may be increased if the SBS process is installed upstream of the air heater.
Impact on CCPs
The SBS injection process adds about 2 to 4 wt% to the fly ash mass collected in the particulate
control device, as sodium sulfate. This corresponds with about 1 to 2 wt% added to the fly ash
when reported as Na2O. The SBS process has been installed on 9600 MW of electric generating
capacity (Moser, 2007), with 2680 MW coming on line in 2008 (Gray, 2008). Some of these
installations sell their fly ash but most do not. It will be plant specific as to what, if any, impact
the addition of approximately 1 to 2% sodium as Na2O in the fly ash has on the reuse of the fly
ash from plants that use the SBS process. There is a supplementary optional chemical
requirement in ASTM C-618 for use of Type C and Type F fly ash in concrete that limits
available alkalis, as equivalent Na2O, to 1.5 wt%. It is possible that SBS injection could cause
this specification to be exceeded.
Because the SBS process typically is operated with high utilization of the injected alkali reagent,
there should not be much excess alkali added to the fly ash. Thus, SBS injection should not
increase ash pond water or landfill leachate pH to the extent of other sorbent injection
technologies that operate with a large excess of reagent. The sodium in the reagent will be very
4-9
water soluble, so using the SBS process would likely increase the sodium and sulfate content of
ash pond discharge water or landfill leachate.
The SBS injection process uses sodium-based sorbents, and sodium can be used to condition fly
ash resistivity in cold-side ESP applications, so no adverse effects on ESP performance are
expected. Therefore, no impacts of the SBS process are expected downstream of the particulate
control device, such as on wallboard-grade gypsum products.
Ammonia Injection at the Air Heater Outlet

Ammonia injection is commonly used along with native or injected SO3 in dual-flue gas
conditioning systems for improved cold-side ESP performance, due to the cohesive properties of
the ammonium salts that form. This process was described in Section 2. It has also been tested
and/or used commercially for the express purpose of sulfuric acid control at a number of plants.
Ammonia is injected between the air heater and ESP at NH3:SO3 molar ratios of 1:1 to 2:1 to
achieve 90+% removal of sulfuric acid. Plants that have SCR systems already have a source of
ammonia on site. The biggest issues in employing ammonia injection are its effect on fly ash
disposal/reuse and the safe handling/storage of the reagent. The latter is less of an issue for plants
where an existing urea-to-ammonia system for the SCR would be used for ammonia supply.
Figure 4-5 is a simplified process flow diagram for an ammonia injection system. Ammonia/air
mixtures are normally piped to an injection manifold where they are introduced into the flue gas
duct via injection probes located just downstream of the air heater. The injection location is
between the air heater and the particulate removal device.
4-10
Air Filter
Blower
Unit
Load
Injection Air Heater
NH3 from
U2A System
FIC
1 per unit
Air Heater
1 of 2 per unit
ESP
Figure 4-5
Simplified Process Flow Diagram for Ammonia Injection (typical)
Ammonia reacts very quickly with sulfuric acid vapor at flue gas temperatures less than 400F.
The reaction products are either ABS, ammonium sulfate, or a mixture of the two products.
Because ABS has a relatively low melting point (296F), it can be present as either a solid or a
liquid when collected by the particulate control device. The low melting point makes the product
stickier compared to ammonium sulfate, which has a much higher melting point (455F).
The relative formation of the two products depends on the ratio of injected ammonia to sulfuric
acid vapor. The minimum molar ratio of NH3:SO3 required to remove almost all of the SO3 as
ABS is 1:1. Higher ratios will produce more ammonium sulfate and less ABS, but will not
substantially improve SO3 removal. In practice, the molar ratio of injected ammonia to SO3 is
usually maintained between 1.0 and 2.0, depending on the particular site. Some plants operate at
low ratios and produce mainly ABS in order to increase the cohesivity of their fly ash and
minimize ammonia consumption costs. Other plants operate at higher ratios to avoid ash
handling problems caused by the stickier ABS. Therefore, the optimum ratio is site specific.
The ammonia injection rate should not exceed two times the molar SO3 rate in the flue gas
because of the potential to form ammonium bisulfite through reaction with flue gas SO2. This can
form as a sub-micron particle that, like condensed sulfuric acid mist, can penetrate FGD
absorbers and produce a visible plume. Alternately, excess ammonia can be absorbed by the
FGD system, leading to elevated ammonia concentrations in the FGD liquor and possible
ammonia contamination of gypsum by-product. This effect is discussed further below.
The published literature shows that the ESP collection efficiency generally improves or stays the
same when ammonia is injected into the flue gas. The impacts of ammonia injection on the ESP
include an increase in space charge effects, but a reduction in fly ash re-entrainment upon
rapping. The space charge increases because the reaction of ammonia with SO3 produces a large
4-11
number of small solid particles that enter the ESP along with the existing fly ash. Fly ash reentrainment decreases because of the formation of sticky ABS solids.
Impact on CCPs
The impact of ammonia on fly ash was previously discussed in the section on SCRs and SNCRs
for NOX control. However, while ammonia slip from SCR systems can result in small quantities
of ammonia in the fly ash, using ammonia for sulfuric acid control can increase the amount in fly
ash more than tenfold compared to injection of ammonia for SCR operation only.
Most of the injected ammonia is converted to ABS or ammonium sulfate, which is collected
along with the fly ash in the particulate control device. Ammonia injection for SO3 control on a
plant with an SCR and firing a 3% sulfur coal would increase the fly ash mass rate by about 2 to
3%, and would add 0.5 to 1% ammonia to the ash. These higher ammonia concentrations could
significantly increase the potential impacts on ash discussed for SCRs and SNCRs in Section 3.
Little data have been published about the influence of ammonia injection on FGD system
operation. However, as described above there is some concern that ammonia slip past the ESP
will be removed in a downstream FGD system and will build in concentration over time. This
could cause an issue with the ammonia content in wallboard-grade gypsum. A simple mass
balance calculation was used to predict these levels for a high-sulfur coal case. With 10 ppm of
ammonia slip past the ESP, even assuming the gypsum is washed as it is dewatered (90%
efficiency) and that the wash water is purged from the FGD system, ammonia levels could be as
high as 40 ppm in gypsum produced from a 3% sulfur coal.
Dry Sorbent Injection at the Air Heater Outlet

Dry sorbent injection upstream of the ESP is part of the SO3 mitigation measures installed at
several plants. Both hydrated lime injection and trona injection are being employed. Dry sorbents
remove SO3 by a gas-solid reaction. The sorbent is pneumatically injected downstream of the air
heater (in most cases) and upstream of the existing particulate control device. The reaction
products and unreacted sorbent are removed along with the fly ash by the particulate control
device. This section describes both hydrated lime (calcium-based) and trona (sodium-based)
sorbent injection.
Hydrated Lime Powder Injection
In this process, dry hydrated lime powder (Ca(OH)2) is injected between the air heater and ESP
or baghouse. Another possible approach is to inject a portion of the hydrated lime upstream of
the air heater. Figure 4-6 is a simplified process flow diagram for hydrated lime injection
between the air heater and an ESP.
4-12
Signal to Storage
Silo Blower/Pump
LIC
Day
Silo
Unit Load
Storage
Silo
LIC
Ratio
Controller
Filter Blower
Filter
Weigh Belt
Blower
M
Driflow Solids Pump
or Equivalent
Truck
Unloading
M
Driflow Solids Pump
or Equivalent
ESP
Air Heater
1 of 2 per unit
Figure 4-6
Simplified Process Flow Diagram for Hydrated Lime Powder Injection
EPRI conducted pilot-scale tests of hydrated lime injection upstream of an ESP for SO3 control at
the Environmental Control Technology Center (ECTC) in the early 1990s (Peterson, 1993). In
these data, a lime injection rate of 2 to 4 lb/hr/kacfm (depending on the source of lime) was
required to achieve 80% SO3 removal. These injection rates correspond to Ca:SO3 molar ratios of
approximately 8:1 to 17:1, many times the stoichiometric (theoretical) amount. During those
pilot tests, dry injection of calcium-based materials caused the ESP performance to degrade due
to increased resistivity. The lime material coated the collector plates and acted as an insulator,
thereby reducing the current flow from the wires to the plates. Hydrated lime injection caused
strong sparking and reduced the operating current in the ESP.
Some companies have reported the use of a high-specific-surface-area hydrated lime for SO3
control upstream of an ESP, with greatly reduced hydrated lime injection rates compared to
conventional hydrated lime (Nolan, 2006). However, these high-specific-surface-area hydrated
limes have only been tested in short-term tests at full scale in the U.S. Once this sorbent is
available, SO3 removal may be achievable at lower hydrated lime injection rates than were
indicated by the EPRI ECTC data.
Impact on CCPs
Hydrated lime injection affects the fly ash by-product in two ways. First, sorbent injection
increases the quantity of fly ash collected by the particulate control device. For example, at a
sorbent injection rate of 1.5 lb/hr/kacfm, sufficient for about 60% to 70% SO3 removal, and for a
typical bituminous coal (~8% ash in the coal), the amount of solids removed by the ESP would
4-13
increase by about 12% compared to normal operation. This additional 12% of material would be
a mixture of calcium sulfate, calcium hydroxide, calcium carbonate, and calcium sulfite. For
some fly ash reuse scenarios, the additional mass and the addition of hydrated lime (calcium
hydroxide) to the fly ash might be desirable. However, the increased alkalis could also adversely
affect the use of the ash in concrete.
The second effect is for plants that pond or landfill their ash. For a plant that ponds its fly ash,
the presence of a large amount of excess lime in the ash may cause a significant increase in the
sluice and pond water pH, and could require the addition of a large amount of acid to the pond to
lower the discharge water pH into the range required by the plants NPDES permit. The higher
pH sluice water would also affect the leachability of trace constituents, possibly increasing
leachability of some and decreasing others. For plants that landfill their ash, hydrated lime
injection would likely significantly increase leachate pH values, with corresponding change in
leachability of trace constituents. For either situation, because of the excess hydrated lime that
would be present, uncontrolled pH values upwards of 12 are possible. For land disposal, the
additional mass would increase disposal costs and/or shorten landfill life.
No significant impacts on FGD solids are expected from hydrated lime injection. Any excess
lime collected in a wet FGD absorber would tend to be utilized as an FGD reagent, offsetting
some of the normal lime or limestone reagent feed to the absorber. Some testing has been
conducted where the hydrated lime is actually injected between the ESP and wet scrubber, rather
than upstream of the ESP.
Trona Injection
Trona is a hydrated sodium carbonate-bicarbonate compound (Na2CO3NaHCO32H2O). When
injected into the flue gas at air heater exit temperatures, the trona calcines to form soda ash. The
soda ash then reacts with SO3 to form sodium sulfate. The excess sodium carbonate and sodium
sulfate are collected along with fly ash in the ESP or baghouse. The process flow diagram for
trona injection looks similar to that shown above for hydrated lime injection, although additional
measures may be required to ensure the trona stays very dry so it maintains good handling
properties.
As a co-benefit, trona injection can enhance ESP performance. While the benefits of sodium
injection are well known for treating sodium depletion in hot-side ESPs, sodium injection can
also be used as a resistivity conditioning agent in cold-side ESPs. (Peterson, 1993; White, 1974).
The results of short-term trona injection tests conducted at one plant were presented at the Mega
Symposium in September 2004 (Ritzenthaler, 2004). At an injection ratio of about 0.5 lb/hr trona
per 1000 acfm of flue gas, the ESP outlet SO3 concentration was reduced by about 62%.
Reductions in ESP outlet SO3 concentration were increased to about 76% when the injection rate
was increased to about 1.5 lb/hr/1000 acfm. Enhancements such as trona grinding just prior to
injection may be employed to lower sorbent injection rate requirements.
4-14
Impact on CCPs
Similar to hydrated lime, trona injection increases the quantity of ash collected, and can alter the
pH of the ash pond and landfill leachate. The injection rates described above correspond with
approximately a 4% to 12% increase in fly ash mass, respectively, for a typical bituminous coal.
The extra material in the fly ash would be a mixture of sodium sulfate and sodium carbonate, and
would add approximately 1 to 4 wt% sodium to the fly ash.
This additional material could have adverse effects on fly ash disposal and re-use options. The
addition of approximately 1 to 4% sodium as Na2O in the fly ash may negatively affect the
performance of the ash in concrete and concrete product applications. There is a supplementary
optional chemical guideline for available alkalis of 1.5 wt% (as equivalent Na2O) in ASTM
C-618 for Type C and Type F fly ash used in concrete containing reactive aggregates. It is
possible that trona injection could cause this specification to be exceeded.
Because the trona injection process typically requires a significant excess of the injected alkali
reagent to achieve moderate to high SO3 removal levels, there could be a significant excess of
alkali added to the fly ash. Thus, like hydrated lime, trona injection could significantly increase
the pH of ash pond water or landfill leachate in fly ash disposal scenarios. The higher-pH sluice
water would also affect the leachability of trace constituents, possibly increasing leachability of
some and decreasing others. The sodium salts are very water soluble, which will increase the
sodium and sulfate content of ash pond discharge water or landfill leachate.
No impacts on FGD solids would be expected, as excess trona and the sodium sulfate formed
should be collected by an ESP at high efficiency, due to corresponding improvements in ESP
performance during trona injection.
Wet ESP
Electrostatic precipitation is a well-established method for collecting fine particulate matter in
many different industrial applications; however, sulfuric acid control at coal-fired power plants
represents a relatively new application. An electrostatic precipitator works by charging particles
in an electric field and moving them to a surface of opposite charge where they are deposited. In
conventional dry ESPs, the deposited particles are removed by mechanical rapping. In wet ESPs,
the collecting electrode is irrigated with water to remove particulate matter. Wet ESPs are
typically located downstream of a wet scrubber, just before the flue gas goes up the stack;
however, there are some installations where the last field of a dry ESP has been converted to a
wet ESP.
Wet ESP technology solves several limitations on SO3 control encountered by conventional dry
ESPs. The wet environment helps ensure that the sulfuric acid is condensed and collectable by
electrostatic forces, lowers particle resistivity, and allows high power input levels to enhance the
removal of sub-micron-diameter mist. Wet ESPs can remove other flue gas components that
4-15
contribute to plume opacity, including fine fly ash particles, unburned carbon or soot, and wet
FGD scrubber carryover. Particle resistivity problems typically encountered with dry ESPs are
eliminated with a wet ESP since the water-saturated condition renders all particles conductive.
Wet ESPs have also been demonstrated to remove oxidized mercury from flue gas at relatively
high efficiency, and to remove elemental mercury at lower percentages.
There are several ways to deliver the irrigation water to a wet ESP. In the most common method,
a recycled water stream is sprayed onto the plates. Often, the last field of the wet ESP is washed
with fresh water to prevent contaminated water from entering the cleaned gas stream. The plates
are washed either periodically or continuously. A blow down stream is produced from this
recycled water that must be treated.
Impact on CCPs
Since wet ESPs are typically installed at or near the end of the flue gas path after the wet
scrubber, they generally do not impact other CCPs, with the possible exception of FGD gypsum.
A wet ESP generates an aqueous slurry waste that must either be treated separately or added to
the FGD system. This slurry waste would include all of the material collected by the wet ESP
and washed from the plates, including fine particulate matter that penetrates the upstream
particulate collector and wet FGD absorber; sulfuric acid; scrubber carryover slurry; and mercury
captured in the wet ESP. If the slurry is treated separately, a filter cake solid waste is generated
from the wastewater treatment. Adding this slurry stream to the FGD system would consume a
small amount of FGD reagent to neutralize the acid, and would add sulfates and trace metals that
could adversely affect FGD chemistry in low-sulfite oxidation systems. The mercury content of
the FGD solids and/or liquor would also be increased by adding this stream.
References
Benson, 2003. Benson, L.B., K.J. Smith, and R.A. Roden. Control of Sulfur Dioxide and Sulfur
Trioxide Using By-Product of a Magnesium-Enhanced Lime FGD System, paper presented at
the Institute of Clean Air Companies (ICAC) Forum 2003: Multi-Pollutant Emission Controls &
Strategies. Nashville, TN, October 12-15, 2003.
Bowes, 2006. Bowes, Edward, et al. Sulfur Trioxide Reduction Technology Demonstrated at
Dominion Generations Chesterfield Power Station, Paper #25 presented at the Power Plant Air
Pollutant Control Mega Symposium, Baltimore, MD, August 30, 2006.
EPRI, 2002. Sulfuric Acid Removal Process Evaluation: Long-term Results. EPRI, Palo Alto,
CA, U.S. Department of Energy, National Energy Technology Laboratory, Pittsburgh, PA, TVA,
Chattanooga, TN, American Electric Power, Columbus, OH, and FirstEnergy, Shippingport, PA:
2002.1004165.
Fuel Tech, 2007. www.fueltechnv.com, 2007.
Gray, 2008. Conversation with Sterling Gray of URS Corporation on 4/25/08.
4-16
Hamel, 2003. Hamel, B., R. Rhodes, S.A. Benson, D.P. McCollor. The Role of Combustion Air
Preheater in an Effective Multipollutant Control Strategy, paper presented at the U.S.
EPA/DOE/EPRI Combined Power Plant Air Pollutant Control Mega Symposium, Washington,
D.C., 19-22 May 2003.
Martin Marietta, 2003. SO3 Reduction Using Highly-Reactive Magnesium Oxide, case study
available for download at www.magspecialties.com, 2003.
Moser, 2007. Robert E. Moser, SO3s impacts on plant O&M: Part III, POWER magazine,
April 2007.
Nolan, 2006. Paul Nolan, Chemical Lime Company, and Lew Benson, Carmeuse Lime;
presentations made at the DOE-NETL SO3 Control Conference, Pittsburgh, PA, May 18, 2006.
OmniClear 2003. OmniClear, A new alternative for sulfur trioxide control. Document
provided by Omni Materials, Inc., Maysville, KY.
Peterson 1993. Peterson, J.R., A.F. Jones, F.B. Meserole, and R.G. Rhudy. SO3 Removal from
Flue Gas by Sorbent Injection, EPRI HSTC Phase II Test Results, paper presented at the SO2
Control Symposium, Boston, MA, 24-27 August 1993.
Ritzenthaler, 2004. Ritzenthaler, Douglas P. and John Maziuk. Successful Mitigation of SO3
Emissions while Simultaneously Enhancing ESP Operation at the General James M. Gavin Plant
in Chesire, Ohio by Employing Dry Sorbent Injection of Trona Upstream of the ESP. Paper
presented at the US EPA/DOE/EPRI Combined Power plant Air Pollutant Control Symposium:
the Mega Symposium, Washington, D.C., August 30 September 2, 2004.
Schulz, 2006. Personal communication between David White of URS Corporation and Kent
Schulz of Fuel Tech, Inc. May 2006.
White, 1974. White, Harry J. Resistivity Problems in Electrostatic Precipitation, Journal of the
Air Pollution Control Association, Volume 24, No. 4, April 1974, pp. 333-334.
Winschel, 2005. Winschel, R.A., M.L. Fenger, K.H. Payette, and L.A. Brickett. Control of
Mercury Emissions by Absorption on Fly Ash Experimental Results of the Consol/Allegheny
Pilot Plant Program, presentation at the DOE/NETL Mercury Control Technology R&D
Program Review Meeting, Pittsburgh, PA, July 14, 2005.
4-17
5
MERCURY REMOVAL
From the standpoint of impacts on CCPs, mercury removal can take place in four areas:
Co-removal with fly ash, as a result of boiler combustion modifications, injection of carbon5
6
based sorbents (ACI and MerCure ), or injection of non-carbon sorbents (MinPlus ,
7
Amended Silicates , BASF mineral-based sorbents);
Co-removal with wet or dry FGD by-products, due to native FGD removal or because of
add-on mercury oxidation technologies (KNX 8 , mercury oxidation catalysts) and/or wet
FGD mercury re-emission control additives;
Co-removal in a wet ESP, whose mercury-containing by-product stream will either be

combined with the wet FGD by-products or treated as a separate blow down; and/or
Removal in a new, separate CCP stream due to the implementation of EPRI-licensed,

mercury-specific technologies such as Toxecon or Toxecon II9 .
Figure 5-1 is an illustration of where each of these technologies would typically be implemented
in the flue gas path. Like SO3 control, which was discussed in the previous section, mercury
control can be implemented at a wide range of locations in the flue gas path, from the furnace to
just upstream of the stack.
These mercury control technologies are discussed below, including their expected impacts on
other coal combustion products. The technology discussions are divided into the four mercury
removal areas listed above.
Mercury Co-Removal with Fly Ash

Combustion Modifications
The combustion modification process is aimed at modifying the fly ash to make it capable of
physically adsorbing mercury. Adsorption is defined as a process where a gas, vapor, or
dissolved matter is assimilated by the surface of a solid or liquid. To change the fly ash
5
MerCure is a trademark of Alstom.

MinPlus is a trademark of MinPlus.
7
Amended Silicates is a trademark of Amended Silicates, LLC.
8
KNX is a trademark of Alstom.
9
Toxecon and Toxecon II are registered trademarks of EPRI.
6
5-1
Mercury Removal
properties, the combustion properties of the boiler are modified by changing the way the coal is
burned in the furnace. This may include changing excess air levels, modifying the amount of air
and fuel added at different locations in the boiler, and/or varying burner tilt.
Economizer
MinPlus
Injection
Furnace
MerCure
Sorbent
Injection
Combustion
Modifications
Toxecon II
Sorbent
Injection
Air Heater
Wet ESP Coremoval
FGD Absorber
Particulate
Collector
KNX
Injection
-Activated Carbon Injection

-Amended Silicates Injection
-BASF Mineral-based Sorbent Injection
-Mercury
Oxidation
Catalysts
-Toxecon
Installation
-Wet FGD Coremoval

Stack
-Scrubber
Additives
Figure 5-1
Illustration of where Mercury Control Technologies are
Most fly ash is composed of non-combustible minerals that are found in the coal. These minerals
have little capacity to adsorb mercury. Boiler combustion modifications may be used to add
unburned carbon (loss on ignition) to the fly ash. In some flue gases, unburned carbon has the
capacity to adsorb mercury. The unburned carbon, including adsorbed mercury, is subsequently
collected along with fly ash in the particulate control device.
It has previously been observed that, for eastern bituminous coal-fired plants, significant mercury
control can be achieved with fly ash having elevated LOI levels (Lu, 2007). Recent test programs
on plants that fire eastern bituminous and Powder River Basin coal have shown that it is possible
to increase the LOI content of the fly ash and optimize other flue gas variables to enhance
mercury adsorption and capture with the fly ash (Romero, 2005, 2006).
5-2
Impact on CCPs
This technology will primarily impact the fly ash, by increasing the LOI content and the mercury
content. As discussed previously for NOX control, higher LOI adversely affects the air-entraining
properties of concrete made with the fly ash, which can in turn adversely affect fly ash sales for
concrete if the LOI exceeds ASTM C-618 specification (6 percent LOI) or contractual limits due
to increased need for air entraining additives. Higher carbon content may also slightly increase
the concentration of some trace elements in the fly ash due to greater adsorption capacity.
Because combustion modifications impact firing conditions in the furnace, it is also possible that
bottom ash characteristics could be slightly altered.
Finally, as the LOI content of the fly ash increases, it is possible that unburned carbon can
penetrate a cold-side ESP, as the carbon has a low electrical resistivity and has a tendency to be
re-entrained. Consequently, this technology could lead to an increase in the amount of carbon
captured in the wet FGD system and increase the carbon content of a gypsum by-product. This
effect is further discussed in the next subsection.
Activated Carbon Injection (ACI)
ACI is implemented by pneumatically injecting a fine powder of activated carbon into the flue
gas duct upstream of the particulate device. In most cases the carbon is injected between the air
heater and primary particulate control device, although some processes involve carbon injection
between the economizer and air heater. An ACI system typically consists of a storage silo, solids
feeders, blowers, transport lines, and injection lances. Figure 5-2 is a photograph of a temporary
ACI system installed for a month-long full-scale ACI test.
Activated carbon is made from coal, lignite, or other carbon-based material that is processed with
heat and steam to produce a highly porous solid powder that has great capacity for adsorption.
As described above for LOI, mercury in the flue gas can adsorb onto the highly porous carbon
particles, and be collected along with the carbon in the units particulate control device. Several
different types of activated carbon are available, including one being developed specifically for
hot-side ESP applications. Some activated carbons are treated with bromine addition to improve
their performance in flue gas from low-chlorine-content coals, and for other applications.
The performance of ACI for mercury control can be very site specific. Factors such as coal type,
flue gas residence time in ductwork, particulate control device type and size, flue gas
temperature, and concentrations of other species in the flue gas such as hydrochloric acid (HCl)
and SO3 affect the performance of ACI. The type of particulate control device installed on a unit
can, in particular, greatly impact the effectiveness of ACI; ACI is generally more effective with a
fabric filter or baghouse than with an ESP, and generally less effective with a wet particulate
scrubber.
5-3
Mercury Removal
Figure 5-2
Photograph of an ACI System, Showing the Activated Carbon Storage Silo (Center of
Photo)
Impact on CCPs
ACI injection rates are commonly expressed in units of pounds per million actual cubic feet of
flue gas (lb/MMacf) treated. Typical rates range from less than 1 lb/MMacf to upwards of 10
lb/MMacf. For a typical bituminous coal with about 8% ash, and assuming 75-80% of the coal
ash becomes fly ash, these rates correspond with approximately 0.5% to 5% of the fly ash mass
being added as carbon.
Even at the lowest carbon injection rate, fly ash uses for cement replacement/concrete admixture
may be adversely affected, due to the effects of the activated carbon on air entrainment additives
used in concrete. Air entrainment is required to give the concrete adequate freeze/thaw
resilience, and additives are added to concrete to enhance air entrainment. The activated carbon
has an affinity for the additive, so the presence of activated carbon in fly ash can greatly increase
the amount of additive required for the concrete to get an acceptable Foam Index Test score. In
some cases, it may not be possible to use enough of the additive to result in formation of a stable
foam. Even if enough additive can be used to get an acceptable Foam Index Test score, the
variability introduced in how much additive must be used as the activated carbon dosage in the
fly ash varies is undesirable to concrete producers.
5-4
Some activated carbon vendors are developing proprietary technology to passivate sorbents so
they do not significantly impact air entrainment additive requirements (Landreth et al, 2007). If
these passivated sorbents are successfully developed and commercialized, this could remove a
significant disadvantage of ACI for plants that sell their ash for concrete applications. In
addition, methods are being developed to beneficiate fly ash containing activated carbon for use
in concrete by ozonation (EPRI, 2005b) or re-combustion (Cooper, 2007).
The use of fly ash in cement manufacture may be limited if ACI is used for mercury control. The
mercury captured on the activated carbon can be re-released at the high temperatures found in
typical cement kilns. For this reason, EPA is currently considering restricting the use of fly ash
from units using ACI in the manufacture of cement (Barnett, 2007).
Several recent studies have shown that the mercury is relatively stable at ambient temperatures,
and not readily released from the fly ash/activated carbon (EPA, 2006; Gustin & Ladwig, 2004;
EPRI, 2005a; UND EERC, 2007). Therefore the higher mercury concentrations should not
significantly affect the ash from a disposal perspective. In addition to mercury, the activated
carbon may also increase capture of other trace constituents such as arsenic and selenium (EPA,
2006). However, the leaching of these constituents was not found to be directly related to their
total concentration in the fly ash.
Chemically treated (e.g., brominated) carbon contains species such as bromine that could
potentially leach from the fly ash in a landfill situation, or be thermally desorbed at elevated
temperatures. Results of limited testing of ashes from brominated carbon injection trials by the
synthetic groundwater leaching procedure (SGLP) suggest that bromine can be leached from the
ash at high water-to-ash ratios (e.g., ponding) (Sjostrom, 2005a, 2005b). Laboratory testing has
shown little potential for thermal desorption of bromine, though.
Most of the carbon injected into a flue gas is expected to be captured with the fly ash in the ESP
or baghouse. However, ACI could also adversely affect FGD gypsum quality, particularly if the
unit has a relatively small ESP for particulate control. As mentioned above, carbon-based
particles tend to have a low electrical resistivity, which reduces the electrostatic forces that hold
particles to ESP collecting plates. This can lead to rapping and non-rapping re-entrainment losses
that can allow carbon particles to penetrate the ESP and potentially be collected in the wet FGD
absorber. In forced oxidation systems producing wallboard-grade gypsum, such particles can
increase the combustible percentage in the gypsum product. Wallboard manufacturers typically
have very tight limits for combustible content in their gypsum feedstock because much of their
output is for fire code wallboard. One manufacturer reported that their limit on combustibles in
gypsum is 0.2 wt%. For a plant that fires 3% sulfur coal and that injects 10 lb/MMacf of carbon,
it would take a little over 10% of the carbon injected to penetrate the ESP and be collected in the
FGD system to exceed this limit.
5-5
Mercury Removal
Toxecon and Toxecon II

EPRI has developed a patented technology that addresses several shortcomings of conventional
ACI for plants currently equipped with an ESP for particulate control. In this process, called
Toxecon, a very compact fabric filter is installed in the flue gas path downstream of an existing
ESP. Activated carbon is injected into the flue gas downstream of the ESP and upstream of this
compact fabric filter. The Toxecon concept is illustrated in Figure 5-3.
The fabric filter serves as a contacting device between the activated carbon and the flue gas, so
less activated carbon may be needed and/or higher mercury removal percentages may be
achieved than through injection upstream of the ESP.
A similar technology, called Toxecon II, offers some of the benefits of the Toxecon process but
at lower capital cost. The intent of Toxecon II is to avoid impacting the bulk of the fly ash from a
unit, by injecting activated carbon into the downstream fields of a multi-field ESP (e.g., injecting
between Fields 2 and 3 of a four-field ESP). The majority of the fly ash, collected in the
upstream fields, would have no carbon content and would not have elevated mercury content.
Economizer
Activated Carbon Injection
Furnace Air Heater

Particulate
Collector
FGD Absorber
Existing ESP
Toxecon
Baghouse
Figure 5-3
Illustration of the Toxecon Process Concept
5-6
Stack
The Toxecon II technology would require that the ash handling system be modified to segregate
the ash from the fields downstream of injection. The Toxecon II process concept is illustrated in
Figure 5-4.
Impact on CCPs
A significant benefit of the Toxecon process is that the fly ash captured by the ESP (about 99
percent) is not affected by carbon injection, and thus fly ash sales are not impacted. However, a
new CCP stream is generated by the process, a small amount of material rich in carbon, mercury,
and fine fly ash particles that have penetrated the ESP. For a 500-MW plant, this stream would
probably amount to 100 to 200 lb/hr (about 800 tons per year). Mercury concentrations in this
material may be in the tens of ppm or higher, and other volatile trace elements may also be
present in higher concentrations than normally found in fly ash. Because of the relatively low
activated carbon injection rate required upstream of a baghouse compared to an ESP, and
because the baghouse should capture activated carbon at high efficiency, no significant impacts
on FGD by-products would be expected.
Boiler
Sorbent
Injection
Re-usable
Fly Ash
Activated
Carbon + Fly
Ash
Figure 5-4
Illustration of the Toxecon II Process Concept
5-7
Mercury Removal
Since Toxecon II involves injection within the ESP, limited residence time is available and
relatively high carbon injection rates may be required, particularly compared to the Toxecon
approach. Thus, using the example of a 500-MW plant, the carbon-rich stream from a Toxecon II
application could be on the order of 500 to 1000 lb/hr (about 4000 tons per year). The material
will be similar to the material from Toxecon, but with a higher fly ash content and lower mercury
concentration. Also, since Toxecon II involves using only part of the ESP to collect the injected
activated carbon, the issue of carbon carryover to the wet FGD system and increased
combustible levels in the FGD gypsum are potential concerns, as described for ACI.
Non-Carbon Sorbent Injection
Because carbon-based mercury sorbents can adversely affect the ability to reuse fly ash for
beneficial use, a number of mineral-based sorbents are under development that should avoid such
impacts on fly ash sales. These sorbents are not yet in wide use and their exact formulations are
considered proprietary information. One such sorbent, MinPlus, is apparently comprised of
calcium-, alumina- and silica-based minerals, and is injected into the upper furnace at injection
rates on the same order of magnitude as those for activated carbon (Biermann, 2006). Another
non-carbon sorbent (Amended Silicates) is a chemically amended silicate substrate that is
injected between the air heater and particulate control device as would be activated carbon, and
at similar feed rates to activated carbon (Butz, 2006). One sorbent developer is investigating
several mineral-based sorbents, including fly ash that has metal sulfides applied through
controlled deposition, and molecular-sieve-type minerals (Tran, 2006). These sorbents are also
injected in the same location and at similar rates compared to how activated carbon is injected
for mercury control.
Impact on CCPs
There has been little published research on the impacts of these alternative sorbents on fly ash.
All three sorbent developers cite test results showing fly ash that includes their spent sorbent
would not be adversely affected for use in concrete, and would readily pass TCLP analyses.
Mercury Co-Removal with FGD By-Products

The effectiveness of mercury co-removal in an FGD system is generally dependent on the
percentage of the mercury in the flue gas that is in an oxidized form. The oxidized form of
mercury is water-soluble and can be removed in wet or dry scrubbers, while the other
predominant form, elemental mercury, is not.
5-8
Several factors influence the percentage of the coal mercury that is in the oxidized form as the
flue gas enters the FGD system. These include:
Coal chloride content higher coal chloride tends to promote mercury oxidation. The
predominant form of oxidized mercury in coal flue gases is believed to be mercuric chloride
(HgCl2). Low-chloride coals such as PRB tend to produce mostly elemental mercury in the
flue gas (except units equipped with reverse-gas baghouses, as mentioned below).
SCR SCR catalysts have been observed to oxidize mercury, particularly for coals that have
significant chloride levels (typically greater than 100 ppm chloride in the coal). Also, it
appears that high SO2 to SO3 conversion SCR catalysts are generally more effective at
oxidizing mercury than low conversion catalysts.
Type of particulate control device in some cases it has been observed that reverse-gas
fabric filters can oxidize a significant percentage of the mercury in the flue gas, even for lowchloride coals like PRB.
Additional technologies have been developed to enhance the percentage oxidation of mercury in
flue gas at the FGD inlet. Several technologies are discussed below.
Mercury captured by wet FGD systems can be found in the liquor, in the FGD solids, or both.
The factors that control how the mercury partitions between phases are not well understood at
this time. In general, mercury in the solid phase tends to be concentrated in fine particles. For
wet FGD systems that have hydrocyclones for primary dewatering, the fine solids in the
overflow stream can have as much as ten times the mercury concentration of the larger particles
in the underflow (EPRI, 2004).
In contrast, since all of the slurry liquor is evaporated in spray-dryer-based dry FGD systems,
in these systems all of the absorbed mercury will be found in the solids stream.
The net capture of oxidized mercury in an FGD system can be limited by liquid-phase reactions
between absorbed oxidized mercury and absorbed sulfur dioxide that cause re-emission of the
mercury. In these reactions, the mercury is chemically reduced to elemental mercury, the
insoluble form, and is released back into the flue gas. One approach for limiting the amount of
re-emission that occurs is to use FGD additives to precipitate absorbed mercury as a fine salt
before it has time to undergo such liquid-phase reactions. This approach is also described below.
Chemical Addition
The effectiveness of this technology is based on increasing the percentage of the mercury in the
flue gas that is in the oxidized form. As described above, eastern coals with higher chlorine
content produce mostly oxidized mercury in their flue gases, while western coals such as PRB,
with low chlorine content, tend to produce mostly elemental mercury. One way to increase the
amount of mercury removed by wet scrubbers is to add halogens such as chlorine or bromine to
the coal to increase the percentage of mercury in the flue gas that is oxidized.
5-9
Mercury Removal
Halogen salts such as calcium chloride (CaCl2) or calcium bromide (CaBr2) can be added to the
coal as a means of supplementing the coal chlorine content. Salts added with the coal or injected
into the furnace decompose at furnace temperatures to form vapor-phase acids (hydrochloric acid
[HCl] or hydrogen bromide [HBr]) in the flue gas. These vapor-phase halogen acids and/or the
small amount of halogens present (Cl2 or Br2) react with elemental mercury to produce oxidized
mercury that can be removed by a downstream wet scrubber.
Results typically show that calcium bromide can be injected at lower rates than calcium chloride
to produce equivalent oxidation percentages. Most full-scale test results have shown that higher
overall levels of mercury oxidation can be achieved with calcium bromide injection and that this
reagent might be more cost effective than calcium chloride injection when the delivered costs of
the salt solutions are considered. A patented bromine addition process goes by the trade name
KNX (Alstom, 2007).
The halogen acids added to the flue gas are scrubbed at high efficiency in wet scrubbers and
form soluble salts that build to high concentrations in wet scrubber slurries. Chloride salts are
known to produce severe pitting corrosion in metallic components unless impervious coatings
are applied or high molybdenum or nickel content alloys are used. Bromine is typically not
present in coal flue gases at significant concentrations, so the long-term effects of bromine
injection on wet scrubber chemistry and wet scrubber materials of construction are not known.
Even for calcium chloride injection, the injection of this salt can greatly increase the chloride
content of the liquor circulating through the wet scrubber.
Impact on CCPs
Halogen injection to enhance mercury oxidation could have effects on both fly ash and FGD
solids such as gypsum. For fly ash, the main impact would likely be an increase in the amount of
mercury removed with the fly ash, as the higher halogen concentrations in the flue gas would
tend to enhance mercury capture by unburned carbon in the fly ash. Significant halogen removal
with the fly ash would not be expected.
For FGD by-products, several effects might be expected. One is that higher mercury
concentrations may result in the FGD liquor, FGD solids, or both. The second is that halogen
concentrations will be increased in the FGD liquor, as described above. This can increase the
amount of halogen material remaining in dewatered products such as gypsum, which may have
specifications by the wallboard manufacturer on the amount of dissolved salts allowed. The
increased halogen concentration may lead to increased liquor blow down rates from the FGD
system to maintain halogen concentrations at manageable levels, which will in turn increase
wastewater treatment requirements and wastewater treatment filter cake volumes (discussed in
Section 6). Materials of construction issues or halogens in gypsum specifications may be the
limiting factor with respect to allowable halogen concentrations.
For spray-dryer-based dry FGD systems, the presence of elevated halogen levels in the flue gas
will alter droplet drying characteristics, due to the deliquescent nature of the calcium salts of
these halogen acids. While SO2 removal performance may be improved, droplet drying will slow
and the spray dryer outlet temperature may have to be raised to compensate. The presence of
5-10
these halogen salts in the FGD solids can alter optimum moisture levels, strength development,
permeability, and leachate characteristics (Blythe, 1985, 1991).
Mercury Oxidation Catalysts
Catalysts are materials that participate in chemical reactions and allow them to proceed more
rapidly, but are not consumed in the reaction. Catalysts can promote the oxidation of elemental
mercury in flue gases from low-chlorine coals such as PRB coal. This increases the percentage of
the mercury in the flue gas that is in the water-soluble oxidized form, and enhances mercury
capture by a downstream wet scrubber.
These oxidation catalysts are typically inserted into the flue gas ducts as honeycomb type
structures with many small passages through which the flue gas flows. This provides a large
surface area to which the catalyst materials are applied and on which the oxidation reactions can
take place. A 500-MW plant could have 3000 to 4000 ft3 of mercury oxidation catalyst installed.
Figure 5-5 shows an individual catalyst block and Figure 5-6 shows an example catalyst module
ready to be installed in a pilot unit. A 200-MW-scale demonstration of the technology has been
installed at a power plant that fires PRB coal in Texas, and has been in operation since May 2008
(Blythe, 2007a).
Figure 5-5
Example Mercury Oxidation Catalyst Block
5-11
Mercury Removal
Impact on CCPs
Because installation is downstream of the ESP or baghouse, oxidation catalysts primarily affect
FGD by-products. Increased mercury concentrations would be expected in the FGD liquor, FGD
solids, or both. It is possible that these catalysts could impact the oxidation of other vapor-phase
metals in the flue gas downstream of the particulate control device, such as arsenic and selenium,
but this has not been measured by the process developers.
Figure 5-6
Example Mercury Oxidation Pilot-Scale Catalyst Module (0.5 MW)
Other Mercury Oxidation Technology

Photochemical Oxidation or PCOTM is an alternate technology that uses ultraviolet light to
selectively oxidize mercury in flue gas (Powerspan, 2007). A pilot-scale evaluation of the
technology is currently being conducted on a unit that fires PRB coal. Like oxidation catalyst
technology, PCO would primarily impact the FGD by-products through increased mercury
concentrations.
5-12
Scrubber Additives
As described earlier in this section, wet scrubbers are capable of capturing the water-soluble
oxidized mercury in the flue gas, but remove little or no elemental mercury. However, the net
removal of oxidized mercury can be limited by a phenomenon called re-emissions, where
oxidized mercury absorbed in the scrubber liquor is chemically converted back to the elemental
form. Since the elemental mercury formed is not water soluble, it is released back into the
scrubber outlet flue gas. Evidence of re-emissions is seen when the elemental mercury
concentration in the flue gas at the outlet of a wet scrubber is higher than the inlet elemental
mercury concentration.
The chemistry of mercury re-emissions in wet scrubbers is not completely understood at this
time. In the future, it may be possible to adjust scrubber operating conditions to eliminate or at
least limit re-emissions. In the interim, an approach identified for controlling re-emissions is to
use scrubber additives.
Additives generally work by rapidly precipitating oxidized mercury from the scrubber liquor as a
solid salt, so it will not react with other liquid-phase species such as absorbed sulfur dioxide and
be converted back to the elemental form. Scrubber additives have been used in Europe to prevent
re-emissions from wet scrubber systems installed on municipal waste burning plants, and have
reportedly been used for this purpose in some coal-fired plants. Limited testing of wet scrubber
additives has been conducted in the U.S. with varied success (Blythe, 2006, 2007b; Ghorishi,
2005). The scrubber additives are generally water soluble and contain some form of sulfur, often
sulfides.
Impact on CCPs
The main impact of scrubber additives will be increased mercury concentrations in the FGD
solids, if the additive is effective. The mercury precipitated with the additive should be
concentrated in fine particles. For plants with hydrocyclones for primary dewatering of the FGD
by-product, it is possible that the FGD gypsum mercury content can be lowered by separating
mercury-rich fines for disposal. It is also speculated that mercury present in gypsum as a
precipitate with a re-emissions additive will be more stable than mercury would be in the
gypsum with no additive, but this has not been substantiated. In one case, gypsum produced from
a power plant using a wet scrubber re-emissions additive was tested at a commercial wallboard
plant, with no adverse effects on the wallboard production process being noted (Sanderson,
2006).
5-13
Mercury Removal
Mercury Co-Removal in Wet ESPs

Wet ESP technology was previously discussed as an SO3 control technology. However, wet ESPs
have also been documented to remove oxidized mercury and even some elemental mercury from
the flue gas treated. The latter is speculated to occur because of oxidation of elemental mercury
due to the corona electrical discharge in the wet ESP. Mercury removed from wet ESPs would be
present in the wastewater from the process, which would either be added to the upstream wet
FGD system or would be treated in a wastewater treatment process.
References
Alstom, 2007. www.alstom.com, 2007.
Barnett, K. 2007. Impacts of Portland Cement NESHAP on Use of Coal Fly Ash.
Biermann, 2006. Biermann, Joep, Brian Higgins, Peter Hoeflich, and Bruce Ramme, Mercury
Reduction in Coal Fired Power Plants using MinPlus Sorbent through Furnace Sorbent
Injection, paper presented at the Power Plant Air Pollutant MEGA Symposium, Baltimore,
MD, August 28-31, 2006.
Blythe, 1985. Blythe, G.M. et al. Field Evaluation of a Utility Spray Dryer System. Electric
Power Research Institute. Report No. CS-3954, May 1985.
Blythe, 1991. Blythe, G.M., L.R. Lepovitz, and C.M. Thompson. Evaluation of a 2.5-MW Spray
Dryer/Fabric Filter SO2 Removal System. Electric Power Research Institute. Report no. GS7449. August, 1991.
Blythe, 2006. Blythe, Gary M. Field Testing of an FGD Additive for Enhanced Mercury
Control, Task 2 and 4 Pilot-scale Test Results. Topical Report. Cooperative Agreement No. DEFC26-04NT42309, URS Corporation, Austin, Texas 78729. May 2006.
Blythe, 2007a. Blythe, Gary, Brice Freeman, Bruce Lani, and Charles Miller. Mercury
Oxidation Catalysts for Enhanced Control by Wet FGD, paper presented at the International
Conference on Air Quality VI, Arlington, VA, September 24-27, 2007.
Blythe, 2007b. Blythe, Gary M. Field Testing of an FGD Additive for Enhanced Mercury
Control, Task 3 Full-scale Test Results. Topical Report. Cooperative Agreement No. DE-FC2604NT42309, URS Corporation, Austin, Texas 78729. May 2007.
Butz, 2006. Butz, James, Thomas Broderick, Craig Turchi, and J. Michael Geers, Trial of
Amended Silicates for Mercury Control at Miami Fort Station, presentation at the
DOE_NETL Mercury Control Technology Conference, Pittsburgh, PA, December 11-13, 2006.
Cooper, L., 2007, Carbon Burnout A State of the Art in Commercial Ash Beneficiation,
World of Coal Ash Conference, May 8-10, 2007, Covington, KY.
5-14
EPA, 2006. Characterization of Mercury-Enriched Coal Combustion Residues from Electric

Utilities Using Enhanced Sorbents for Mercury Control. EPA-600/R-06/008.
EPRI, 2004. Mercury Stability in FGD Byproducts. EPRI, Palo Alto, CA: 2004. 1004711.
EPRI 2005a. Mercury in Coal Combustion Products. EPRI, Palo Alto, CA: 2005. 1010061.
EPRI 2005b. Scale-up and Demonstration of Fly Ash Ozonation Technology. EPRI, Palo Alto,
CA: 2005. 1012995
Ghorishi, 2005. Ghorishi, S. Behrooz, Scott Renninger, George Farthing, Chuck Teets, Jeanne
Neureuter, Thomas Hastings, and Chris DiFrancesco. Effects of SCR Catalyst and Wet FGD
Additive on Speciation and Removal of Mercury within a Forced Oxidized Limestone
Scrubber, paper presented at the ICAC Clean Air Technologies and Strategies Conference 05,
Baltimore, MD, March 7-10, 2005.
Gustin & Ladwig, 2004. Gustin, M, Ladwig, K. 2004. An Assessment of the Significance of
Mercury Release from Coal Fly Ash. J of Air & Waste Management, V54, pp. 320-330.
Landreth, R., Nelson, S., Liu, X., Tang, Z., Overholt, A., Brickett, L., 2007, Mercury Reduction
Performance of Concrete-FriendlyTM C-PACTM Sorbent. World of Coal Ash Conference, May
8-10, 2007, Covington, KY.
Lu, 2007. Lu, Yongqi, Massoud Rostam-Abadi, Ramsay Chang, Carl Richardson, and Jennifer
Paradis, Characteristics of Fly Ashes from Full-Scale Coal-Fired Power Plants and Their
Relationship to Mercury Adsorption, Energy & Fuels, 2007, 21, pp. 2112-2120.
Powerspan, 2007. www.powerspan.com, 2007.
Romero, 2005. Romero, Carlos, Harun Bilirgen, Nenad Sarunac, and Edward Levy, Impact of
Modified Boiler Control Settings on Mercury Emissions, presentation at DOE-NETLs Mercury
Control Technology R&D Program Review, Pittsburgh, PA, July 12-14, 2005.
Romero, 2006. Romero, Carlos, Harun Bilirgen, Edward Levy, Atira Mabin, Melanie McCoy,
Robert Serlin and Craig Tylenda, Boiler Optimization for Multi-Pollutant Control: Mercury and
NOX Emissions, paper presented at the Power Plant Air Pollutant MEGA Symposium,
Baltimore, MD, August 28-31, 2006.
Sanderson, 2006. Sanderson, Jessica, Gary M. Blythe, and Mandi Richardson. Fate of Mercury
in Synthetic Gypsum Used for Wallboard Production. Topical Report, Task 6 Wallboard Plant
Test Results, DOE Cooperative Agreement No. DE-FC26-04NT42080, Pittsburgh, PA,
December 2006.
5-15
Mercury Removal
Sjostrom, 2005a. Sjostrom, Sharon. Evaluation of Sorbent Injection for Mercury Control,
Topical Report for Sunflower Electrics Holcomb Station, Reporting Period: October 1, 2003
June 30, 2005. DOE Cooperative Agreement No. DE-FC26-03NT41986, Pittsburgh, PA, June
28, 2005.
Sjostrom, 2005b. Sjostrom, Sharon. Evaluation of Sorbent Injection for Mercury Control,
Topical Report for AmerenUEs Meramec Station Unit 2, Reporting Period: October 1, 2003
September 30, 2005. DOE Cooperative Agreement No. DE-FC26-03NT41986, Pittsburgh, PA,
September 23, 2005.
Tran, 2006. Tran, Pascaline, PhD, Xiaolin Yang, PhD, Larry Shore, PhD, and William Hizny,
FA 100: Mineral Based Mercury Sorbents, paper presented at the Power Plant Air Pollutant
MEGA Symposium, Baltimore, MD, August 28-31, 2006.
UND EERC, 2007. Mercury and Air Toxic Element Impacts of Coal Combustion By-product
Disposal and Utilization. UND EERC, 2007, Grand Forks, ND: 2007.
5-16
6
ANCILLARY SOLID WASTES ASSOCIATED WITH THE
GENERATION AND MANAGEMENT OF COAL
COMBUSTION PRODUCTS
There are several ancillary solid waste streams associated with the generation and management
of high-volume CCPs described in Section 2. This section discusses some of these materials.
Fabric Filters
While coal-fired units have traditionally used ESPs as the primary particulate control device,
more and more plants are being built with or retrofitted with fabric filters (baghouses) for
particulate control. A number of fabric filter configurations are employed, including shakedeflate, reverse-gas, and pulse-jet cleaning styles. Filter bag materials vary with flue gas
conditions and cleaning style, but can include fiberglass and polymers such as PPS (poly phenylene sulfide).
Filter bags fail over time for a variety of reasons, such as excessive bag weight, low permeability
(high pressure drop), and/or loss of physical integrity. Individual failed bags are replaced one at a
time, but eventually a complete bag replacement is required. The frequency of bag replacements
can vary widely with plant conditions, ranging from about once per year to once per decade.
The bags typically develop what is called a permanent dust cake, which is a layer of fly ash
that cannot be cleaned from the bag surface with conventional cleaning techniques. When fabric
filter bags are replaced, the spent bags contain some amount of this permanent dust cake, which
should be very similar in composition to the fly ash. As described above, for most U.S.
applications the bags themselves are primarily made of fiberglass or PPS. Bags taken out of
service are typically disposed of in a landfill or ash pond.
Spent Selective Catalytic Reduction (SCR) Catalysts

SCR catalysts are installed in the flue gas path between the economizer and air heater, to
promote reactions between injected ammonia and flue gas NOX to lower NOX emissions. With
time (typically over several years) they lose their catalytic activity, and must either be
regenerated or replaced for the plant to maintain high NOX removal efficiency. The issue of
whether catalyst regeneration or replacement is more cost effective has not been fully resolved
by U.S. plants that have SCR installed; some utilities have chosen to regenerate while others
have replaced with fresh catalyst. In general, just one of several catalyst layers is regenerated or
replaced at a given time.
6-1
Ancillary Solid Wastes Associated with the Generation and Management of Coal Combustion Products
The SCR catalysts can either be in a honeycomb or parallel plate configuration. The catalysts
contain titanium, vanadium, and sometimes tungsten. The catalysts can also adsorb trace metals
from the flue gas, particularly metals that are volatile at economizer exit temperatures, such as
arsenic, mercury, and selenium. The spent catalysts may also contain fly ash particles that have
deposited over time.
EPRI (2003) provides estimates of the annual volumes of SCR catalysts that will need to be
replaced or regenerated for coal-fired power plants: 17,000 tons of catalyst will need to be
replaced annually by 2010, and 21,000 tons by 2020.
Spent catalysts that are not regenerated can either be disposed of (landfill or incinerator) or
recycled. Recycling options include use in producing new catalysts, recovery of metals, raw feed
to a steel mill, and use as a slag fluidizer additive (EPRI, 2003).
Mercury Oxidation Catalysts

Oxidation catalysts begin service at their maximum mercury oxidation activity, then lose activity
over time due to poisoning effects of other species in the flue gas. With time, the oxidation of
elemental mercury across these catalysts tends to decay. To maintain high oxidation percentages
over time, either a large excess of catalyst, frequent catalyst replacement, or frequent catalyst
regeneration may be required.
Like SCR catalysts, spent mercury oxidation catalysts will eventually have to be replaced.
Depending on what type of catalyst is used, there may be enough precious metal content (e.g.,
gold or palladium) to make it cost effective to recover the metal from the spent catalyst. In this
case, the spent catalyst could have a net positive value. If not, it may have to be disposed of. In
addition to mercury, after thousands of hours of flue gas exposure other metals may be adsorbed
to the catalysts, especially volatile metals like arsenic and selenium. Other than the precious
metals, which provide the active component of the catalyst, these catalysts are made from
cordierite (aluminum magnesium silicate) and gamma alumina.
Urea Wastes
The build-up of wastes in a urea-to-ammonia reactor is highly dependent on the purity of urea
and water that are used in the reactor. Any nonvolatile impurities that enter the reactor will stay
in the reactor until the reactor has a blow down cycle. Operators manage the build-up of
impurities by blowing down the reactor to remove the impurities. Some urea suppliers have
heavy metals in their product, which will build up over time in the reactor. Depending on how
often the reactor is blown down, the buildup of heavy metals can cause the blown down solution
to be classified as a hazardous waste. The level of purity of the urea solution to use in the reactor
is an economic decision: lower purity urea will have a lower purchase price but increased waste
disposal costs (Spencer, 2008).
6-2
FGD Wastewater Treatment Wastes

Wastewater Treatment Solids
Many existing FGD installations do not have wastewater treating systems. For example: 1) FGD
systems in the west often operate with net water evaporation in ponds; 2) many sulfite-producing
FGD systems purge enough water with the calcium sulfite hemihydrate by-product that further
water blow down is not required; and 3) other systems blow down from ponds to surface waters
subject to limited permit requirements on wastewater quality.
However, most new FGD systems produce gypsum, and the amount of water discharged from
the system with the dewatered gypsum is not adequate to control dissolved chloride levels. Thus,
a blow down stream is required to prevent chloride concentrations from building to unacceptable
levels. For new FGD systems, this blow down stream is subject to relatively strict regulations for
parameters such as pH, suspended solids, and dissolved metal concentrations, and wastewater
treatment systems are required.
Before describing this wastewater treatment process, the term blow down must be better
defined for wet FGD applications. There are two streams that are commonly called blow
down. One is from the FGD absorber reaction tank(s). As the scrubber operates, lime or
limestone reagent is continually added and SO2 is removed by forming calcium sulfite
hemihydrate or FGD gypsum solids. With time, the weight percent (wt%) solids level in this
slurry builds. To control this solids level, a portion of the slurry is intermittently or continuously
blown down and replaced with fresh or reclaimed water. In some plants this blow down is sent
directly to a pond or gypsum stack, but in most FGD systems this blow down is sent to the
dewatering system. In the latter case, the absorber blow down is not literally leaving the FGD
system and/or the power plant; only the dewatered solids leave. Most or all of the reclaimed
liquor is returned to the FGD system.
The other type of FGD blow down is the purge to control chlorides and/or gypsum fines. This
blow down is a portion of the liquor (or dilute slurry) produced during product dewatering that is
not returned to the FGD absorbers. Not all FGD system have this blow down stream. For
example, in systems that produce calcium sulfite hemihydrate, enough water may leave the FGD
system with the dewatered by-product (containing 30 to 40% moisture) that chlorides are
naturally controlled to an acceptable concentration. These systems typically would not control
fines either.
The blow down liquor may contain 2-4% or more of dissolved solids. The major components are
calcium, magnesium, sodium, chloride, and sulfate. Trace components include heavy metals
from fly ash and limestone, iron from metallic corrosion and grinding media, and other
chemicals in non-traditional makeup water sources (cooling tower blowdown, landfill leachate,
coal pile runoff, etc.). Minimal amounts of organic compounds are present (other than carboxylic
acids if organic acid performance additives are used), so treatment options typically focus on
physical/chemical technology.
6-3
For systems that do have a chloride and/or fines purge, the first step in wastewater treatment is
typically removal of suspended solids from the blow down stream. These solids include fine
FGD product solids (gypsum or calcium sulfite hemihydrate), fly ash removed by the FGD
systems, and/or fine particles of inert minerals dissolved from the FGD lime or limestone
reagent. A filter press is sometimes used to separate the suspended solids from the liquor.
The standard process for metals reduction is pH adjustment (with slaked lime), precipitation of
metal hydroxides, settling, pH neutralization, and filtration. Metal hydroxide sludge is formed
and removed in clarifiers. One limitation on this technology for FGD liquor is the high
concentration of soluble magnesium often present due to the magnesium content of the lime or
limestone reagent. Above pH 9, magnesium hydroxide (Mg(OH)2) begins precipitating. Although
magnesium is typically not a regulated pollutant, removing it creates a relatively large volume of
poorly dewatering sludge as a CCP from the water treating process.
Sometimes ad hoc treatment is required for specific metals. For example, sulfide-containing
materials are sometimes added in a separate step to precipitate mercury from FGD wastewater.
The solids streams (fine suspended solids, metal hydroxides, and mercury precipitates) derived
from the treatment process may be combined or may be handled separately. Some of the
separated solids can be blended with the gypsum product or can be used in concrete mixes. In
many cases the co-mingled filter cake may be disposed.
There is also a process called Advanced Biological Metals Removal Process (ABMet) 10 that
claims to remove metals, metalloids, nonmetals, and inorganic compounds such as nitrate. The
process uses microbes in a bioreactor to either precipitate elements or destroy contaminants.
Each biological system is specifically designed for the contaminants present (GE Water, 2008).
Spent Carbon Filtration Beds
Carbon filtration beds are used at coal-fired power plants to treat water and wastewater for
soluble organic material. Process water from ponds or lakes is treated before use at the plant, and
wastewater from the plant is treated before discharge into nearby water systems. If the carbon
filtration system is small, carbon is usually landfilled as a non-hazardous waste. Large amounts
of carbon are usually sent back to the vendor for reactivation of the carbon (Behrens, 2008).
Demolition Materials
When pollution control devices are upgraded or replaced there are many components of the
system that are either sold for scrap metal, landfilled, or reused at the power plant. Any metal of
value (e.g., ductwork, ESP collector plates) is usually cut into manageable pieces and sold for
scrap metal (Curry, 2008). Materials such as insulation and fiberglass pipe are landfilled. It is
sometimes required that these materials be washed before disposal if plant solids are still on the
items being disposed of. Some components are saved for possible re-use at the plant, such as
pumps, valves, piping, instrumentation, stairways, and grating. There is usually a lay down
10
ABmet is a registered trademark of GE.
6-4
area at the plant where piping, valves, and other items that can be re-used are stored until the
plant has a need for them.
References
Behrens, 2008. Conversation with Greg Behrens of URS Corporation on 04/25/08.
Curry, 2008. Conversation with Lloyd Curry of FL Smidth on 04/28/08.
EPRI, 2003. Recycling and Disposal of Spent Selective Catalytic Reduction Catalyst. EPRI, Palo
Alto, CA: 2003. 1004888.
GE Water, 2008. www.gewater.com/products/equipment/other_equipment/ABMet.jsp
(4/7/2008).
Spencer, 2008. Conversation with Herbert Spencer on 05/06/08.
6-5
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EPRI Impact of Air Emissions Controls On Coal Combustion Products

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Impact of Air Emissions Controls on

Coal Combustion Products

Impact of Air Emissions Controls on

Technical Report, October 2008

EPRI Project Manager

ELECTRIC POWER RESEARCH INSTITUTE

DISCLAIMER OF WARRANTIES AND LIMITATION OF LIABILITIES

Impact on CCPs ...............................................................................................................3-3

CleanStack Condensing Air Heater ....................................................................................4-6

Toxecon and Toxecon II ................................................................................................5-6

Urea Wastes .........................................................................................................................6-2

Figure 2-1 Typical Coal-Fired Power Plant Layout ...................................................................2-1

High-Volume Coal Combustion Products

High-Volume Coal Combustion Products

High-Volume Coal Combustion Products

High-Volume Coal Combustion Products

High-Volume Coal Combustion Products

Registered trademark of Reed Minerals

High-Volume Coal Combustion Products

Dry (Spray Dryer)

High-Volume Coal Combustion Products

liquor at high magnesium concentrations. In an in situ forced oxidation system (forced

High-Volume Coal Combustion Products

Forced Oxidation or High Natural Oxidation Systems

High-Volume Coal Combustion Products

High-Volume Coal Combustion Products

High-Volume Coal Combustion Products

High-Volume Coal Combustion Products

Combustion Modifications/Low-NOX Burners

NOX Control Technology

Rich Reagent Injection (RRI)

NOX Control Technology

Selective Non-Catalytic Reduction (SNCR)

NH2CONH + (1+x)H2O NH4COONH2 + (x)H2O 2 NH3 + CO2 + (x)H2O

NOX Control Technology

NOX Control Technology

Selective Catalytic Reduction (SCR)

NOX Control Technology

SO3 Control Technology

- Hydrated Lime Injection

SO3 Control Technology

Furnace Injection of Magnesium-Based Sorbents

SO3 Control Technology

TIFI is a trademark of Fuel Tech.

SO3 Control Technology

Magnesium Oxide Injection Upstream of the Air Heater

TDI is a trademark of Fuel Tech.

SO3 Control Technology

CleanStackTM Condensing Air Heater 4

CleanStack is a trademark of Marsulex Inc.

SO3 Control Technology

SO3 Control Technology

Sodium Based Sorbent (SBS) Injection

SBS DILUTION WATER

SO3 Control Technology

SO3 Control Technology

Ammonia Injection at the Air Heater Outlet

SO3 Control Technology

SO3 Control Technology

Dry Sorbent Injection at the Air Heater Outlet

SO3 Control Technology

SO3 Control Technology

SO3 Control Technology