SO3 Mitiation Guide

SO3 Mitigation Guide Update
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Technical Report
SO3 Mitigation Guide Update
1004168
Final Report, March 2004
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iii
REPORT SUMMARY
This report is an updated guide for control of gas phase sulfuric acid emissions. The guide
updates overviews of available control processes and covers new processes. In addition, the
guide summarizes process economics and includes a cost worksheet calculation methodology.
Background
During the combustion of sulfur-containing fossil fuels, a percentage of the SO2 formed is
further oxidized to SO3. As the flue gas cools across the air heater, this SO3 combines with flue
gas moisture to form vapor-phase and/or condensed sulfuric acid. Sulfuric acid in flue gas has
long been known to cause a variety of plant operation problems such as air heater plugging and
fouling, back-end corrosion, and plume opacity. The retrofit of hot-side selective catalytic
reduction (SCR) units for NOX control on a large number of coal-fired units over the past few
years has significantly increased interest in sulfuric acid controls. SCR retrofits can exacerbate
all of the issues related to sulfuric acid in flue gas, as oxidation of SO2 to SO3 across SCR
catalysts can more than double flue gas SO3/sulfuric acid concentrations.
This guide is an update to the SO3 Mitigation Guide published in October of 1994 (EPRI report
TR-104424). As described above, new drivers have arisen for implementing controls since the
guide’s original publication; and there has been a significant amount of recent development of
SO3/sulfuric acid control technology. The primary purpose of this updated guide is to describe
the options currently available for coal-fired plants to reduce plume opacity and corrosion
problems caused by flue gas sulfuric acid.
Objectives
To develop an SO3 mitigation guide that incorporates all of the most recent information and
process economics to allow informed evaluation of the mitigation options.
Approach
The updated guide discusses the development and commercialization of new SO3 control
technologies. It presents new performance data for technologies covered in the original guide
along with a summary of the data presented in the original guide. The guide makes an economic
comparison of currently available SO3 control options for an example plant, including a
sensitivity analysis of the effects of varying the assumptions for the example plant. The guide
includes a workbook that enables the user to perform a simplified, preliminary investigation of
the costs for implementing these technologies at a coal-fired plant. The guide also includes a list
of contacts for vendors of SO3/sulfuric acid control technologies.
v
Results
Previous technologies concentrated mainly on additive injection upstream of the particulate
collection device. Current processes include additives that are injected with the fuel, in the
furnace, and upstream of the air preheater. Much of the impetus for these new processes is the
desire to mitigate the acid formed by oxidation of SO2 across the selective catalytic reduction
NOx control system. To keep costs down, the new processes also strive to control sulfuric acid at
much lower molar ratios of additive to SO3 than the previous processes; however, the cost on a
$/ton basis can be high for many of the additives. In addition, transport costs can significantly
impact the process economics. Cost worksheets are included in the guide to assist in developing
more realistic evaluations of specific applications.
EPRI Perspective
Increasingly, the major concern with sulfuric acid control has been associated with SO3
generated across a newly installed SCR where sulfuric acid concentrations may double and lead
to visible plumes. A significant variety of new control processes are available to choose from.
These processes are summarized in this report. It is likely that the most useful part of the report
will be the economics and the costing worksheets. These will be useful as a screening
methodology for companies considering application of a sulfuric acid control process.
Keywords
Sulfuric acid
SO3
Emission control
vi
EPRI Licensed Material
ABSTRACT
During the combustion of sulfur-containing fossil fuels, a percentage of the SO2 formed is
further oxidized to SO3. As the flue gas cools across the air heater, this SO3 combines with flue
gas moisture to form vapor-phase and/or condensed sulfuric acid. Sulfuric acid in flue gas has
long been known to cause a variety of plant operation problems such as air heater plugging and
fouling, back-end corrosion, and plume opacity. The retrofit of hot-side selective catalytic
reduction (SCR) units for NOX control on a large number of coal-fired units over the past few
years has significantly increased interest in sulfuric acid controls. SCR retrofits can exacerbate
all of the issues related to sulfuric acid in flue gas, as oxidation of SO2 to SO3 across SCR
catalysts can more than double flue gas SO3/sulfuric acid concentrations.
This guide is an update to the EPRI SO3 Mitigation Guide (TR-104424) published in October of
1994. Since the guide’s original publication, new drivers have arisen for implementing controls,
as described above. Accordingly, there has been a significant amount of recent development of
SO3/sulfuric acid control technology. The primary purpose of this updated guide is to describe
the options currently available for coal-fired plants to reduce plume opacity and corrosion
problems caused by flue gas sulfuric acid.
In this updated guide, the development and commercialization of new SO3 control technologies
are discussed. For technologies covered in the original guide, new performance data are
presented along with a summary of the data presented in the original guide. An economic
comparison of SO3 control options currently available is performed and discussed for an example
plant. A number of sensitivity cases for variations in the example plant assumptions are also
included. A workbook is included with the guide that enables the user to perform a simplified,
preliminary investigation of the costs for implementing these technologies at the user’s coal-fired
plant. Finally, a list of contacts for vendors of SO3/sulfuric acid control technologies is included.
vii
CONTENTS
1 INTRODUCTION ....................................................................................................................1-1
Guide Organization ...............................................................................................................1-2
Mechanism for SO3 Formation ..............................................................................................1-2
Factors Influencing SO3 Formation .......................................................................................1-3
Fuel Type and Sulfur Content...........................................................................................1-3
Boiler Oxygen Concentration............................................................................................1-4
Boiler Design and Operating Temperatures .....................................................................1-4
Chemical Composition of Fuel Ash ..................................................................................1-5
Effect of SCR on SO3 Formation ......................................................................................1-5
Impacts of Flue Gas SO3 .......................................................................................................1-6
Plume Opacity ..................................................................................................................1-6
Corrosion ..........................................................................................................................1-9
Overview of Mitigation Options............................................................................................1-10
2 OVERVIEW OF SO3 CONTROL TECHNOLOGIES...............................................................2-1

Chemical Methods.................................................................................................................2-1
Fuel Additives ...................................................................................................................2-1
Furnace Mg(OH)2 Injection ...............................................................................................2-2
Post-Combustion Injection of MgO...................................................................................2-5
SBS Injection ....................................................................................................................2-6
Ammonia Injection ............................................................................................................2-8
Configuration of Ammonia Injection System ................................................................2-9
Performance Data for Ammonia Injection ..................................................................2-10
Impacts on ESP Performance....................................................................................2-11
Impacts on Waste Disposal Options ..........................................................................2-11
Impacts of Ammonia Injection on FGD Systems .......................................................2-12
Ammonia Injection Safety Concerns..........................................................................2-12
Dry Sorbent Injection Upstream of ESP .........................................................................2-13
ix
Solid Waste Impacts of Dry Sorbent Injection............................................................2-14

Lime Injection with Flue Gas Humidification...................................................................2-15
Physical Methods ................................................................................................................2-19
Fuel Blending..................................................................................................................2-19
Wet Electrostatic Precipitator .........................................................................................2-20
Condensing Air Heater ...................................................................................................2-25
3 EXAMPLE ECONOMICS FOR SO3 CONTROL TECHNOLOGIES .......................................3-1

Results and Discussion .........................................................................................................3-3
Heat and Material Balance Estimate Results ...................................................................3-3
Capital Cost Estimates ...................................................................................................3-11
Summary of Operating and Capital Cost Estimates for Control Technologies ...............3-21
Discussion of First-Year Cost Estimate Results .............................................................3-27
Cost Estimate Sensitivity Cases..........................................................................................3-31
Effect of Delivered Reagent Cost ...................................................................................3-31
Effect of Control Technology Operating Period ..............................................................3-33
Effects of New Versus Retrofit Installation .....................................................................3-35
Conclusions – Example Economics ....................................................................................3-37
4 SO3 CONTROL PROCESS ECONOMICS WORKBOOK OVERVIEW .................................4-1

Worksheet 1 ..........................................................................................................................4-2
Worksheet 2 ..........................................................................................................................4-2
Worksheets 3 Through 5 .......................................................................................................4-3
Fuel Blending Worksheet .................................................................................................4-3
Injection/Additive Technologies Worksheet......................................................................4-3
Fuel Additive ................................................................................................................4-4
Mg(OH)2, MgO, SBS, Dry Hydrated Lime, and Sodium Bicarbonate Injection ............4-4
Ammonia Injection .......................................................................................................4-5
Humidification with Lime Injection................................................................................4-5
Wet ESP Worksheet.........................................................................................................4-5
Worksheet 6 ..........................................................................................................................4-6
Worksheet 7 ..........................................................................................................................4-6
5 SO3 CONTROL TECHNOLOGY VENDORS..........................................................................5-1

Vendors of Coal Additives .....................................................................................................5-1
x
Vendors of Sorbent Injection Technologies...........................................................................5-1

Vendors and Engineers/Constructors of Ammonia Injection Systems ..................................5-2
Vendors of Wet Electrostatic Precipitators ............................................................................5-4
Vendor of Condensing Air Heater .........................................................................................5-5
A APPENDIX — MEASURING SO3 CONCENTRATIONS IN FLUE GAS X ........................... A-1

EPA Method 8 ...................................................................................................................... A-1
Acid Dew Point Measurement .............................................................................................. A-1
Strengths ......................................................................................................................... A-2
Weaknesses .................................................................................................................... A-2
Controlled Condensation System Method............................................................................ A-2
Other SO3 Measurement Methods ....................................................................................... A-6
Laboratory and Field Testing of CCS Method ...................................................................... A-6
Results for Sampling Downstream of Wet FGD.......................................................... A-7
Results for Upstream of Particulate Control Device.................................................... A-7
B APPENDIX — ESTIMATING FLUE GAS SO3 CONCENTRATIONS................................... B-1

Existing Sulfuric Acid Emissions Estimating Tools............................................................... B-1
EPA Guidance ................................................................................................................. B-1
The Southern Company Services Engineering Estimation Tool...................................... B-2
Discussion of Current Estimating Methods Relative to Field SO3 Measurement Data......... B-2
EPA Guidance ................................................................................................................. B-3
The Southern Company Services SO3 Estimation Tool .................................................. B-4
Review of F1 Fuel Impact Factors .............................................................................. B-4
Review of F2 Technology Impact Factors................................................................... B-6
Review of Overall Predictions ................................................................................... B-10
Summary of Review of the Southern Company Estimating Method ......................... B-10
C APPENDIX — SO3 CONTROL PROCESS COST ESTIMATING WORKSHEETS.............. C-1

Worksheet 1 — User Inputs ................................................................................................. C-2
Worksheet 2 — Calculation of Baseline SO3 Emissions .................................................... C-10
Worksheet 3 — Fuel Blending Economics ......................................................................... C-15
Worksheet 4 — Economics of Injection Technologies ....................................................... C-23
Reagent Costs............................................................................................................... C-24
Transportation Costs ..................................................................................................... C-25
xi
Delivered Cost Calculations .......................................................................................... C-27

OmniClearTM Addition to the Fuel .................................................................................. C-27
Magnesium Hydroxide (Boiler Injection) – for plants without SCR ................................ C-30
Magnesium Hydroxide Furnace Injection + Lime Injection Upstream of ESP ............... C-34
MgO Powder (Injection Upstream of Air Heater) ........................................................... C-41
SBS (Injection at Air Heater Inlet).................................................................................. C-43
SBS (Injection at CSESP Inlet)...................................................................................... C-46
Ammonia (Injection upstream of ESP) .......................................................................... C-48
Dry Hydrated Lime Injection (upstream of ESP)............................................................ C-50
Humidification + Hydrated Lime Injection ...................................................................... C-52
Lime and Sodium Bicarbonate Mixture.......................................................................... C-55
Worksheet 5 — Wet ESP Economics - Capital and Annual Costs..................................... C-58
Worksheet 6 — Boiler Efficiency Savings Calculations...................................................... C-61
Worksheet 7 — Summary of Economic Evaluation............................................................ C-66
xii
LIST OF FIGURES
Figure 1-1 Effect of SO3 and H2O Levels on Sulfuric Acid Dew Point Temperature ..................1-7
Figure 1-2 Estimated Stack Plume Opacity Due to Sulfuric Acid Mist Emissions, Showing
the Effect of Stack Diameter ..............................................................................................1-8
Figure 1-3 Estimated Stack Plume Opacity Due to Sulfuric Acid Emissions, Showing the
Effect of Acid Mist Mean Droplet Diameter for a 25-ft (7.6-m) Diameter Stack..................1-9
Figure 2-1 ECTC Performance Data for Dry Sorbent Injection for SO3 Control.......................2-14
Figure 2-2 ECTC Data for Hydrated Lime Injection with Flue Gas Humidification for SO3
Control..............................................................................................................................2-17
Figure 2-3 Effect of Flue Gas Humidification on ESP Operating Current for Dry Injection
of Hydrated Lime Upstream of Humidification Nozzle......................................................2-17
Figure 2-4 Effect of Sorbent Injection with Humidification Water in Restoring ESP
Performance Compared to Humidification Alone .............................................................2-18
Figure 3-1 Baseline and Post-SCR SO3/Sulfuric Acid Concentrations for Hypothetical
Plant ...................................................................................................................................3-1
Figure 3-2 Illustration of Potential SO3/Sulfuric Acid Control Options........................................3-3
Figure 3-3 Summary of First-year Capital Recovery and Non-labor Operating Costs by
SO3/Sulfuric Acid Control Technology for Achieving the Lower Removal Percentage
Target...............................................................................................................................3-24
SO3/Sulfuric Acid Control Technology for Achieving the Higher Removal
Percentage Target ...........................................................................................................3-24
Figure 3-5 Effect of Sorbent Delivered Price Variations on Control Technology Cost
Estimates (includes reagent, utility and capital recovery costs) .......................................3-33
Percentage Target (12-month operating period)..............................................................3-34
Figure 3-7 Comparison of First-year Capital Recovery and Non-labor Operating Costs by
Percentage Target (5-month vs. 12-month operating period) ..........................................3-35
Percentage Target (New plant, 12-month operating period) ............................................3-36
Figure 3-9 Comparison of First-year Capital Recovery and Non-labor Operating Costs by
Percentage Target ...........................................................................................................3-36
xiii
Figure A-1 Controlled Condensation System (CCS) Sampling Train ...................................... A-3
Figure A-2 Controlled Condensation System (CCS) Thimble Holder ...................................... A-4
Figure A-3 Controlled Condensation System (CCS) Condenser ............................................. A-4
xiv
LIST OF TABLES
Table 2-1 Full-scale Ammonia Injection Experience for SO3 Control.......................................2-11

Table 3-1 Summary of SO3 Control Technology Performance Data Sources, and
Reagents and Utilities Required.........................................................................................3-4
Table 3-2 Assumptions Made for Heat and Material Balances for Model Plant.........................3-6
Table 3-3 Summary of SO3 Control Performance Estimates for Lower Percentage
Control Target (return to pre-SCR stack sulfuric acid concentrations)...............................3-7
Table 3-4 Summary of Bases for Consumables Quantity Estimates for Candidate
SO3/Sulfuric Acid Control Technologies.............................................................................3-8
Table 3-5 Summary of SO3 Control Technology Heat and Material Balances for Lower
Control Percentage Target (return to pre-SCR stack sulfuric acid concentration,
operating 5 months /year) ..................................................................................................3-9
Table 3-6 Summary of SO3 Control Performance Estimates for Higher Percentage
Control Target (3 ppmv at stack with SCR in Service) .....................................................3-12
Table 3-7 Summary of SO3 Control Technology Heat and Material Balances for Higher
Percentage Control Target (3 ppmv at stack with SCR in service, operating 5
months /year) ...................................................................................................................3-13
Table 3-8 Summary of SO3 Control Technology Capital Cost Estimates for the Lower
Sulfuric Acid Removal Percentage Target – All Values in $1000 ....................................3-16
Table 3-9 Summary of SO3 Control Technology Capital Cost Estimates for the Higher
Sulfuric Acid Removal Percentage Target – All Values in $1000 ....................................3-18
Table 3-10 Summary of SO3 Control Technology First-year Reagent and Utility Cost
Estimates for the Lower Target Sulfuric Acid Removal Percentage (return to pre-
SCR stack concentrations, operation 5 months per year) – All Values in $1000 .............3-22
Table 3-11 Summary of SO3 Control Technology First-year Reagent and Utility Cost
Estimates for the Higher Target Sulfuric Acid Removal Percentage (3 ppmv at stack
with SCR in service, operation 5 months per year) – All Values in $1000 .......................3-23
Table 3-12 Factors Used to Generate Annual Reagent and Utility Costs................................3-25
Table B-1 Fuel Impact Factors for the Southern Company Estimating Method....................... B-5
Table B-2 Comparison of Fuel Impact Factors Used in the Southern Company
Estimating Method and Those Determined Experimentally .............................................. B-5
Table B-3 Summary of F2 Technology Impact Factors Used in the Southern Company
Estimating Method ............................................................................................................ B-7
Table B-4 Comparison of Technology Impact Factors Used in the Southern Company
Estimating Method and Those Determined Experimentally .............................................. B-8
Table B-5 Comparison of Estimating Method Predictions versus Measured Values for
Sulfuric Acid Emissions................................................................................................... B-11
xv
1
INTRODUCTION
During the combustion of sulfur-bearing fossil fuels, a percentage of the SO2 formed is further
oxidized to SO3. As the flue gas cools across the air heater, this SO3 combines with flue gas
moisture to form vapor-phase and/or condensed sulfuric acid (H2SO4). Because sulfur in this
oxidation state (+6) can exist in flue gases either as SO3 or sulfuric acid depending on
temperature, the terms are sometimes used interchangeably in the industry, and within this
report.
Controls for the removal of SO3 and/or sulfuric acid from flue gases on coal-fired generating
units are becoming of increased interest to energy companies. Sulfuric acid in flue gas has long
been known to cause a variety of plant operation problems such as air heater plugging and
fouling, back-end corrosion, and plume opacity. Within the past several years, sulfuric acid has
become reportable as a Toxic Release Inventory species, and has become important in permitting
new plants since it can potentially result in acid aerosol and/or condensable emissions The
retrofit of hot-side selective catalytic reduction (SCR) units for NOX control on a large number of
coal-fired units over the past several years has been a significant driver for developing and
installing sulfuric acid controls. SCR retrofits can exacerbate all of the issues related to sulfuric
acid in flue gas, as oxidation of SO2 to SO3 across SCR catalysts can more than double flue gas
SO3/sulfuric acid concentrations.
This guide is an update to the EPRI SO3 Mitigation Guide (TR-104424) published in October of
1994. Since the guide’s original publication, new drivers have arisen for implementing controls,
as described above. Accordingly, the state of the art for SO3/sulfuric acid controls has changed
significantly. The primary purpose of this updated guide is to describe the options currently
available for coal-fired plants to reduce plume opacity and corrosion problems caused by flue gas
sulfuric acid.
In this updated guide, the development and commercialization of new SO3 control technologies
are discussed. For technologies covered in the original guide, new performance data, where
available, are presented along with a summary of the data presented in the original guide. An
economic comparison of SO3 control options currently available is performed and discussed for
an example plant. A number of sensitivity cases for variations in the example plant assumptions
are also included. A workbook is included with the guide that enables the user to perform a
simplified, preliminary investigation of the costs for implementing these technologies at the
user’s coal-fired plant. Finally, a list of contacts for vendors of SO3/sulfuric acid control
technologies is included.
1-1
Introduction
Guide Organization
The format of this guide is as follows:
• The remainder of Section 1 describes the formation of SO3 in coal-fired boilers, its
conversion to vapor phase and condensed sulfuric acid, and the impacts of SO3 on the plant.
• Section 2 provides an overview of SO3 control technologies for coal-fired power generating
plants. For each technology, a process overview and discussion of commercial/demonstration
experience is provided. Vendors that provide a particular control technology are listed later,
in Section 5.
• Section 3 presents process economics for a number of control technologies. Annual reagent
and utility operating costs and installed capital costs are compared for the technologies, based
on calculations performed for a model plant.
• Section 4 describes a workbook that allows report users to develop preliminary process
economics for their particular plant circumstances. Users can estimate the annual operating
costs and capital installations costs for a range of technology options. The actual workbook is
attached to the end of this report as an appendix.
• Section 5 provides a list of SO3 control technology vendors, including contact information.
There are also three appendices, including:
• Appendix A provides an overview of the methods available for measuring SO3
concentrations in flue gases, and a discussion of their relative strengths and weaknesses.
• Appendix B discusses methods available for estimating SO3 concentrations in coal flue gases
at various points in the flue gas path.
• Appendix C provides the actual SO3 control cost estimating worksheets that are described in
Section 4.
The remainder of this section describes the parameters that affect SO3 formation and the effects
of SO3 on plume opacity and corrosion.
Mechanism for SO3 Formation

Most fossil fuels contain sulfur in some form, which is oxidized during combustion to form
sulfur dioxide (SO2). A small fraction of the SO2 is further oxidized to form sulfur trioxide
(SO3). The accepted mechanism for SO3 formation is a collision of an SO2 molecule with a free-
radical oxygen atom and a “third body” to produce SO3.1 At flame temperatures (~2500ºF),
thermodynamic equilibrium calculations show that about 99.9% of the total sulfur should be
present as SO2. For temperatures below 700ºF, the equilibrium shifts such that 99.9% of the total
sulfur should be present as SO3. In practice, however, the SO3 concentration is limited to less
than about 3% of the total sulfur because the generation rate of free-radical oxygen atoms is very
slow below temperatures of about 1500ºF.
1
Hunter, S.C. and P.K. Engel. “Sulfur Oxides Emissions from Boilers, Turbines, and Industrial Combustion
Equipment,” in Workshop Proceedings on Primary Sulfate Emissions from Combustion Sources, Volume 2:
Characterization, Southern Pines, NC, April 24-26, 1978.
1-2
Introduction
Downstream of the furnace, as the flue gas cools in the air heater to about 500°F and lower, the
SO3 reacts with water vapor to form vapor-phase sulfuric acid (H2SO4). It is common to refer to
sulfur in this oxidation state (+6) as SO3 even though it is actually present as vapor-phase and/or
condensed H2SO4 at temperatures below approximately 500ºF (i.e., in the air heater and downstream).
This guide typically uses the term SO3 when discussing flue gas conditions upstream of the air
heater and sulfuric acid when downstream. However, in general discussions where the location
in the flue gas path is not specified, the two terms are sometimes used interchangeably.
Factors Influencing SO3 Formation
The reaction mechanism discussed above for SO3 formation implies that high sulfur fuels will
always produce higher flue gas SO2 and SO3 concentrations than lower sulfur fuels. Although
this is certainly the case for SO2, the formation of SO3 does not depend solely on the fuel sulfur
content. The SO3 concentration in a flue gas depends on the type of fuel, the oxygen
concentration in the furnace, the boiler design and operation, and the chemical composition of
the fuel ash.2 For pulverized coal-fired boilers, which are the primary focus of this guide, about
0.5 to 1.5% of the sulfur is typically oxidized to SO3.3,4
Fuel Type and Sulfur Content
SO3 can be formed in significant concentrations by combustion of either coal or oil fuels. For a
given fuel sulfur content, coal-fired flue gases generally contain less SO3 than flue gases from oil
firing. This is because coal contains more ash but less vanadium than oil. Fuel ashes, which are
alkaline compared to sulfuric acid, will adsorb flue gas SO3 and thereby reduce the flue gas SO3
concentration. Oil contains very little ash, so essentially none of the SO3 formed is removed from
the flue gas by the ash.
Some fuel oils contain high concentrations of vanadium (>100 ppm), which catalyze the
reactions that form SO3. Combustion of these oils produces much higher flue gas SO3
concentrations than fuel oils that contain smaller amounts of vanadium. For example, Dietz5
reported flue gas SO3 concentrations of 8 and 18 ppmv for fuel oils containing 200 and 600 ppm
vanadium, respectively, even though the fuel sulfur level was approximately 2.4 wt.% for both
fuel oils.
2
Homolya, J.B., and J.L. Cheney. “An Assessment of Sulfuric Acid and Sulfate Emissions from the Combustion of
Fossil Fuels,” in Workshop Proceedings on Primary Sulfate Emissions from Combustion Sources, Volume 2:
3
Howes, J.E. “Sulfur Oxide Measurements of Utility Power Plant Emissions,” in Workshop Proceedings on
Primary Sulfate Emissions from Combustion Sources, Volume 2: Characterization, Southern Pines, NC, April 24-
26, 1978.
4
Dahlin, R.S., and T.D. Brown. “Control of Acid Mist Emissions from FGD Systems,” Presented at the 1991 SO2
Control Symposium, Washington, D.C., December 3-6, 1991.
5
Dietz, R.N., R.F. Wieser, and L. Newman. “Operating Parameters Affecting Sulfate Emissions from an Oil-Fired
Power Plant,” in Workshop Proceedings on Primary Sulfate Emissions from Combustion Sources, Volume 2:
1-3
Introduction
Although the flue gas SO3 concentration depends on many variables, it is common to estimate
the flue gas SO3 concentration from the flue gas SO2 concentration. For example, a typical
bituminous coal containing 2.5% sulfur that is fired with 30% excess air would yield a flue gas
SO2 concentration of about 1600 ppmv (wet) and would be expected to contain a flue gas SO3
concentration of 8 to 24 ppmv (wet). This range of SO3 concentrations assumes that between
0.5% and 1.5% of the total sulfur will be converted to SO3 and remain in the vapor phase. For
Western coals that produce highly alkaline fly ashes, the flue gas SO3 concentration may be
lower than these predictions because the fly ash removes most of the SO3 from the flue gas.
Boiler Oxygen Concentration
For oil-fired units, several studies have shown that SO3 concentrations can be reduced by
operating at very low levels of excess air in the furnace. Low excess air reduces SO3 formation
by reducing the amount of free-radical oxygen atoms in the gas. As an example, Dietz, et al,
showed that the SO3 concentration increased from 7 ppmv to almost 40 ppmv as the furnace
oxygen concentration increased from 0.4% to 2.7% during the combustion of a high-sulfur, high-
vanadium oil (2.1% S, 390 ppm V).5 These data suggest that operation at a low excess air may be
the best SO3 mitigation option for oil-fired units, assuming that complete combustion of the oil is
possible at the very low excess air levels. Literature data indicate that these operating conditions
should be feasible since some oil-fired power plants routinely operate at furnace oxygen
concentrations of about 0.2% to control the formation of SO3. The utility engineer needs to
decide if this is an appropriate option for his/her power plant.
Coal is a slow burning fuel, and it cannot be completely combusted at very low oxygen
concentrations. Therefore, operation at very low excess oxygen concentrations is not an option.
Staged-combustion of coal would theoretically be able to reduce SO3 formation in a manner
similar to the use of low-NOx burners for reducing NOx formation. However, the system would
have to be operated such that minimal O2 was present when the temperature was at or above
1500ºF to minimize the formation of the oxygen free-radical atoms. It is not likely that complete
combustion of the coal would occur while operating within these limits. This precludes using
staged combustion to reduce SO3 concentrations in coal-fired gas streams.
Boiler Design and Operating Temperatures
Boiler design can also influence the conversion of SO2 to SO3. For example, because SO3 is
formed at typical superheater gas temperatures and because the formation mechanism is
dependent on a “third body”, the superheater surface area affects the conversion of SO2 to SO3
(i.e., the superheater surface can act as the “third body”). Higher surface areas should produce
higher SO3 concentrations, all other parameters being equal. Burdett6,7 reports that older and
smaller oil-fired units have smaller specific superheater surface areas and produce lower SO3
concentrations compared to larger modern units (500 MW+). For oil-fired units burning high-
6
Burdett, N.A., B.J. Gliddon, and R.C. Hotchkiss. “Magnesium Additive Performance In Oil Fired Boilers –
Kinetics of the MgO/SO3 Reaction,” Combustion Science and Technology, 23, pp. 103-112, 1980.
7
Burdett, N.A. “The Kinetics of the Reaction Between Gas Phase SO3 and Particulate MgO,” Journal of the
Institute of Energy, 54 (421), December 1981.
1-4
Introduction
vanadium-content fuels, the effect of superheater surface area becomes even more important
because the superheater surfaces become enriched with catalytically active vanadium, increasing
the formation of SO3. The vanadium also increases the corrosion rates for the superheater tubes.
Therefore, magnesium compounds are commonly added to the oil to reduce both the corrosivity
and catalytic activity of the vanadium on superheater tubes.
The furnace temperature does not directly affect the flue gas SO2/ SO3 equilibrium because SO2
is the thermodynamically favored species at all furnace temperatures. However, higher furnace
temperatures increase the concentration of oxygen free radicals. Therefore, higher furnace
temperatures may increase the amount of SO3 formed in the superheater section. That is, as the
gas is cooled in the superheater, SO3 forms because it becomes the thermodynamically favored
species. The SO3 formation rate is limited by the concentration of free-radical oxygen atoms,
which are only produced at high temperatures. When the flue gas is quickly cooled, relatively
high concentrations of the free-radical oxygen atoms are present and will react with SO2 to form
SO3. Therefore, high furnace temperatures and faster gas cooling rates should increase the
formation of SO3 in the flue gas for otherwise constant conditions.
Chemical Composition of Fuel Ash

The SO3 concentration in a flue gas also can be affected by the chemical composition of the fly
ash. For example, it is well known that coals with highly alkaline fly ashes produce lower flue
gas SO3 concentrations. The SO3 formed in the furnace/superheater may react with the alkaline
fly ash entrained in the gas stream or the formation of SO3 may be inhibited by alkaline fly ash
deposits on the superheater tubes. Fly ashes with high iron contents can increase flue gas SO3
concentrations because the fly ash acts as a “third body” in the formation mechanism for SO3.4,8
Effect of SCR on SO3 Formation

Many plants have or will be installing a selective catalytic reduction (SCR) process to reduce
NOX emissions. In the SCR process, ammonia and NOX react across a catalyst to form nitrogen
and water. The catalyst material typically contains vanadium pentoxide and titanium; some
catalysts also include minor percentages of molybdenum and/or tungsten. Of these metals,
vanadium is believed to be the most active for oxidizing SO2 to SO3.9
For a given catalyst, conversion to sulfuric acid is proportional to catalyst volume and inversely
proportional to flue gas flow rate through the SCR.10 The proportionality constant depends upon
temperature, oxygen content, and SO2 concentration. Oxygen and SO2 concentrations have a
lesser effect than temperature. Testing across a German “DeNOX” (SCR) unit showed an SO2
conversion of 3.3% when the exit temperature was 752°F. When the exit temperature was
decreased to 698°F, the SO2 conversion rate decreased to 1.3%.10
8
Jones, C. and W. Ellison. “SO3 tinges stack gas from scrubbed coal-fired units,” Power, pp. 73-75, July/August
1998.
9
Pritchard, Scott, Cormetech. Telephone conversation with Katherine Dombrowski, 01 December 2003.
10
Gutberlet, Dr. Heinz, Hans-Ulrich Hartenstein, and Anthony Licata, “SO2 Conversion Rate of DeNOX Catalysts –
Effects on Downstream Plant Components and Remedial Measures,” paper presented at the EPRI-DOE-EPA
Combined Utility Air Control Symposium: The Mega Symposium, Atlanta, GA, August 16-20, 1999.
1-5
Introduction
The conversion of SO2 to SO3 can be minimized by catalyst design. The conversion rate is
typically given as a performance guarantee by the catalyst vendor. A target conversion below 1%
is common.11 However, actions that limit SO2 oxidation may adversely affect NOx reduction.
Reduction in the amount of vanadium in the catalyst is the primary method for reducing SO2
oxidation. NOX molecules react with vanadium within the first 50-100 µm of the surface, while
SO2 reacts with vanadium throughout the bulk of the catalyst9. Therefore, limiting the vanadium
to the surface of the catalyst can reduce SO2 oxidation while still maintaining NOX reduction.
For SCRs operating in a high dust environment at temperatures above 700°F, a bulk vanadium
content of 0.5% is the practical lower limit. For SCRs that operate at lower temperatures (i.e., in
the low 600°F range), the bulk vanadium content may be as low as 0.1-0.2%.9
A small amount of ammonia slip (typically 0-2 ppm, but could be as high as 10 ppm) can be
included in the SCR outlet gas. For plants burning medium- to high-sulfur coals, this ammonia
can react with SO3 to form ammonium bisulfate due to capillary condensation which can blind
the catalyst surface. Ammonium bisulfate can also deposit downstream in the air heater. The
minimum operating temperature for the SCR is typically set based on the fuel sulfur content and
economizer outlet SO3 concentration to avoid blinding the catalyst surface. Ammonia slip is
typically controlled to 2 ppm or less to minimize air heater plugging.
Impacts of Flue Gas SO3
Flue gas SO3 affects power plant operation because it can lead to plume opacity and/or corrosion
problems. The opacity and/or corrosion problems can be severe, even though the SO3
concentration in the flue gas is very low (typically less than 30 ppm for plants without SCR). The
severity of the problems depends on the plant configuration and operating conditions, as
described below.
Plume Opacity
Plume opacity can be caused by the emissions of fly ash, colored gases such as nitrogen dioxide
(NO2), and/or condensed sulfuric acid droplets. The contributions of fly ash and colored gases to
plume opacity have been described elsewhere.12 The following text describes the predicted
effects of condensed sulfuric acid droplets on stack plume opacity.
When flue gas is rapidly cooled below the sulfuric acid dew point temperature, vapor-phase SO3
condenses to form small droplets of condensed sulfuric acid. Figure 1-1 shows that the sulfuric
acid dew point temperature depends on the SO3 and water vapor concentrations in the flue gas:
higher concentration of either species raises the acid dew point temperature. The curves are
11
Muzio, L., M. McDaniel, J. Stallings. White Paper: SCR Application in the Utility Industry: Application to Coal-
Fired Boilers and Balance of Plant Issues. MI-111270, EPRI, September 1998.
12
Damle, A.S., D.S. Ensor, and L.E. Sparks. “Prediction of the Opacity of Detached Plumes Formed by
Condensation of Vapors,” Atmospheric Environment, Vol. 18, No. 2, pp. 435-444, 1984.
1-6
Introduction
based on correlations by Banchero and Verhoff.13 Not shown in the figure is the effect of flue gas
pressure. It is the partial pressure of SO3 and water vapor in the flue gas rather than the
concentration per se that impacts the acid dew point. The curves in Figure 1-1 are based on a flue
gas pressure of 1 atmosphere, which is typical for plants located near sea level.
320
310
Sulfuric Acid Dew Point (°F)
300
290
280
270
14% H20
260
12% H20
10% H20
250
8% H20
240
6% H20
230
220
0 10 20 30 40 50 60
SO3 Concentration (ppm)
Figure 1-1
Effect of SO3 and H2O Levels on Sulfuric Acid Dew Point Temperature
Sulfuric acid droplets are frequently formed in wet scrubbers used for SO2 and/or particulate
control as the flue gas is rapidly quenched to the water dew point temperature, which is well
below the sulfuric acid dew point temperature. The resulting sub-micron-diameter acid droplets
are not efficiently removed by either the scrubber or the mist eliminators because of their small
size. Since the FGD system is installed after the particulate control device, there is nothing
downstream to collect the acid droplets that penetrate the system. Consequently, the droplets
increase the plume opacity.
The condensed droplets scatter light efficiently because their average diameter (0.1 to 1.0 µm) is
near the wavelength of visible light (0.4 to 0.7 µm). The emission of such droplets can result in a
visible plume (commonly a bluish-white or brown plume, depending on the relative positions of
the plume, the sun, and the viewer). This visible plume can cause plants to become non-
compliant with respect to plume opacity even though they remain in compliance with respect to
particulate emissions and in-duct or in-stack opacity as measured by a transmissometer. Figure 1-
2 shows model predictions that indicate high plume opacity can be expected even with low
13
Pierce, Robert R., “Estimating Acid Dewpoints in Stack Gases.” Chemical Engineering. April 11, 1977, pp 125-
128.
1-7
Introduction
concentrations of sulfuric acid droplets in the stack gas, particularly for larger units with greater
stack diameters. For example, flue gas sulfuric acid concentrations of only about 10 ppmv can
result in plume opacities greater than 40% with a 25-ft (7.6-m) diameter stack (approximately a
500-MW unit).
100
Stack Diameter
14 ft
25 ft
80 42 ft
Predicted Plume Opacity (%)
60
40
20
0
0 5 10 15 20 25 30 35 40 45
Flue Gas SO3 Concentration (ppm)
Figure 1-2
Estimated Stack Plume Opacity Due to Sulfuric Acid Mist Emissions, Showing the Effect of
Stack Diameter
Note: 1 ft = 0.30 m
The mean particle size of the condensed droplets also impacts the resulting plume opacity. This
effect is shown in Figure 1-3 for the 25-ft (7.6-m) diameter stack. A typical mean droplet
diameter for acid mist droplets formed in wet FGD absorbers is 0.3 µm, but under some
conditions larger droplets can be formed. The model predictions shown in Figure 1-3 illustrate
that if 0.7 µm mean diameter droplets are formed rather than 0.3 µm droplets, the impact of a
given sulfuric acid concentration in the stack flue gas is much greater (nearly 60% at 10 ppmv
rather than 40%).
1-8
Introduction
100
Acid Mist Mean Particle Diameter
0.1 micron
0.3 micron
80
0.7 micron
Predicted Plume Opacity (%)
60
40
20
0
0 5 10 15 20 25 30 35 40 45
Flue Gas SO3 Concentration (ppm)
Figure 1-3
Estimated Stack Plume Opacity Due to Sulfuric Acid Emissions, Showing the Effect of
Acid Mist Mean Droplet Diameter for a 25-ft (7.6-m) Diameter Stack
Plume opacity problems can also occur for plants without wet scrubbing systems when the
sulfuric acid vapor condenses as the plume cools below the sulfuric acid dew point temperature.
Because acid is not condensed in the stack gases, the measured stack opacity is much lower than
the observed plume opacity. The visual opacity is commonly referred to as a “detached plume”,
since it forms after the flue gas has left the stack.
Corrosion
Sulfuric acid in flue gas has an elevated dew point relative to that of the flue gas moisture alone
(e.g., approximately 220°F to 320°F for sulfuric acid versus less than 140°F for moisture alone),
or even compared to other acid gas species. Due to the vapor-liquid equilibrium relationship for
sulfuric acid in water, relatively concentrated acid can condense from flue gas containing ppm
concentrations of sulfuric acid vapor.
Consequently, it is possible to condense concentrated sulfuric acid at cold spots on the air heater
baskets or anywhere downstream in the flue gas path. This condensation can lead to corrosion of
mild steel surfaces in the air heater, ESP, or ductwork. Some utilities have experienced severe
ductwork and stack liner corrosion caused by condensed sulfuric acid vapor, even though the
SO3 concentrations in their flue gases were only 20 to 30 ppmv.
Downstream of an FGD system, the flue gas temperature is much lower and the gas is typically
saturated with water. Because the FGD outlet gas contains some SO2, SO3, and HCl, and the flue
gas is saturated with moisture, corrosion downstream of the scrubber may not be entirely due to
SO3.
1-9
Introduction
For oil-fired units, SO3 can also cause corrosion in the furnace and superheat sections of the
boiler. Therefore, corrosion inhibitors have been added to many fuel oils. The additives, which
are often magnesium based, coat the surface of the superheater tubes to protect them from SO3
corrosion. The coating also reduces the amount of SO3 that forms by tying up active vanadium
sites as unreactive magnesium vanadates.
Sulfuric acid corrosion will not occur when the temperatures of all steel components are above
the sulfuric acid dew point temperature. In practice, this can be accomplished by raising the air
heater outlet temperature, ensuring that the ducts are well insulated, and/or by reducing the
vapor-phase sulfuric acid concentration.
Raising the air heater outlet temperature reduces the thermal efficiency of the power plant and
might be an expensive option.14 Also, this option might not solve downstream plume opacity
problems because the flue gas will still be cooled below the sulfuric acid dew point temperature
in a FGD system, or possibly in the plume of plants without an FGD system.
Lowering the vapor-phase SO3 concentration reduces the potential for corrosion by decreasing
the sulfuric acid dew point temperature. For example, lowering the flue gas SO3 concentration
from 20 ppm to 2 ppm reduces the sulfuric acid dew point temperature from about 285ºF to
about 250ºF. These data imply that one could greatly reduce or eliminate the corrosion rate for a
steel with a surface temperature of 255ºF by reducing the flue gas SO3 concentration from 20 to
2 ppm.
Overview of Mitigation Options
Several options will be described in this guide for reducing the SO3 concentration of a flue gas.
These options can be divided into two general areas: physical and chemical options. The physical
options include: fuel blending, wet electrostatic precipitators, and condensing air heaters. The
chemical options involve blending alkaline additives with the coal fired or injecting water and/or
different alkaline materials into the flue gas to react with the vapor phase sulfuric acid. The
resulting salts are then removed by the plant’s existing particulate control device. The alkaline
materials considered in this guide include magnesium hydroxide, magnesium oxide, sodium
bisulfite, ammonia, hydrated lime, sodium bicarbonate, partially calcined dolomite and others.
14
Cowdrick, D.A. “Acid Dew Point Experience in Big Bend Unit 4 Precipitators, Fans, and Ductwork,”
Southeastern Electric Exchange 1986 Annual Conference of the Engineering and Operations Division and the Real
Estate Section, Kissimmee, FL, April 9-11, 1986.
1-10
2
OVERVIEW OF SO3 CONTROL TECHNOLOGIES
This section discusses a range of SO3 mitigation options available for coal-fired power plants.
Some of these options are currently used at full-scale, while others have only been demonstrated
in short-term tests at pilot or full scale. The options are categorized as either chemical or physical
methods. The chemical methods involve the injection of alkaline materials with the fuel, into the
furnace or into the flue gas, in some cases along with flue gas humidification. The physical methods
include coal switching or blending, wet electrostatic precipitation, and condensing air heaters. A
cost evaluation of many of these methods is provided in the following section of this report.
Chemical Methods
Sulfuric acid vapor can be removed by injecting a variety of alkaline materials into the furnace or
into the flue gas downstream of the furnace. The reaction products are solid salts that can be
removed along with the fly ash by the existing particulate control device. The following text
discusses the injection of different alkaline materials into the furnace or flue gas for SO3 control.
Fuel Additives
Fuel additives have long been used as an approach for SO3 mitigation, particularly for oil-fired
units. The additives typically include some form of magnesium oxide or magnesium hydroxide.
In oil-fired units, the magnesium-based additives appear to 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 through gas-solid reactions. Additives injected into the furnace
typically become “dead burned” or sintered by the high temperatures to which they are exposed
as they pass through the flame zone, and thus less reactive with the SO3 formed.
FirstEnergy tested dolomite as a fuel additive at their Bruce Mansfield Plant in a DOE and EPRI
co-funded project.15 Although relatively high SO3 removal percentages of greater than 90% were
achieved, the dolomite injection rates required were very high. To achieve 90% SO3 removal, the
estimated molar ratio of calcium plus magnesium alkali injected with the coal was between 0.6:1
and 0.7:1, compared to the coal sulfur content. Compared to the uncontrolled SO3 levels (rather
than the coal sulfur) the molar ratio required for 90% removal was approximately 40:1. On a
mass basis, the amount of dolomite injected represented as much as of 15% of the coal flow. At
such high injection rates, impacts on slagging and fouling in the furnace, and impacts on
downstream particulate control equipment became an issue.
15
Sulfuric Acid Removal Process Evaluation: Short-term Results, EPRI, Palo Alto, CA:2001. 1003980.
2-1
Overview of SO3 Control Technologies
Omni Materials, Inc., of Mt. Carmel, Illinois has developed a proprietary fuel additive for coal-
based applications, OmniClearTM. Based on information provided in company literature, the
additive is apparently ground dolomite (75% minus 200 mesh) that is partially calcined, then
treated with a coating that helps prevent dead burning.16
The company literature reports the results of a full-scale test on a plant with an SCR and firing
approximately a 3% sulfur coal (5 lb SO2/MM Btu). An additive rate of approximately 0.5 to 1.0
wt% of the coal feed rate reportedly lowered SCR outlet SO3 concentrations from 50 to 65 ppm
to about 5 ppm at the ESP outlet. This equates to approximately 90 to 92% SO3 removal.
However, since no ESP outlet concentration data were reported for without the additive, it is not
clear what percentage of the reported removal was attributable to the additive (i.e., some removal
would be expected across the air heater and ESP without the additive). This injection rate is
equivalent to a molar ratio of calcium plus magnesium alkali to coal sulfur of about 0.08:1 to
0.16:1. Compared to the uncontrolled SCR outlet SO3 concentrations, the molar ratio of calcium
plus magnesium in the additive to flue gas SO3 was approximately in the range of 4:1 to 8:1.
These rates are about 10% of the dosage rates in the FirstEnergy dolomite tests described above.
The company literature reports no adverse effects on slagging in the furnace, and no adverse
effects on the ESP used for particulate control.
Furnace Mg(OH)2 Injection

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 co-funded by EPRI has focused on the injection of
magnesium hydroxide slurries into coal-fired furnaces to achieve 90+% removal of furnace-
formed SO3. The technology has been or is being installed for SO3 control on at least three large
coal-fired units with SCR in recent years.
Magnesium hydroxide is typically fed as a slurry into the upper furnace, where temperatures are
lower, to prevent dead-burning of the sorbent.17 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 thereby unlikely to form hard deposits in the boiler. The magnesium sulfate solids
are removed in the downstream particulate control device.
The presence of MgO in the boiler may modify coal fusion temperatures and slag properties,
making slag deposits more friable.18 However, magnesium hydroxide is typically injected high in
the furnace (across from the pendant superheat tubes), so this benefit may not be significant
given the lower gas temperatures in this region. Long-term tests at FirstEnergy’s Mansfield Plant
and AEP’s Gavin Plant showed no measurable impact on slagging in the upper furnace.17
16
“OmniClear, A new alternative for sulfur trioxide control.” Document provided by Omni Materials, Inc.,
Maysville, KY, 2003.
17
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.
18
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.
2-2
Besides removing SO3, injection of magnesium compounds may provide additional benefits by
inactivating certain metal compounds commonly found in flue gas. For example, magnesium-
based compounds may remove arsenic, which is a known vapor phase SCR catalyst poison.18 It
is also postulated that magnesium oxide can form a film on the furnace internals and thereby
prevent iron oxides from catalyzing SO2 to SO3.18
In oil-fired burners, the presence of magnesium oxide reduces the catalytic oxidation activity of
vanadium in the oil. Coal contains little vanadium, so this benefit will not be realized in coal-
fired power plants. However, the effect of magnesium on vanadium-based SCR catalyst activity
might be questioned. No adverse effects on SCR performance were seen in an EPRI-sponsored
23-day-long injection test at AEP’s Gavin Plant nor in coupon tests at BMP.17
Furnace injection can have an advantage over downstream injection technologies for plants that
have SCR systems, by lowering flue gas SO3 concentrations at the SCR inlet. This may allow the
SCR to operate at lower unit load and correspondingly reduced SCR inlet flue gas temperature
without condensing ammonium bisulfate in catalyst pores. However, furnace injection of
Mg(OH)2 appears to be relatively ineffective at removing SCR-formed SO3 from the flue gas.17
For plants without SCR, furnace Mg injection is capable of high SO3 removal percentages, but
SO3 removal may be limited by the performance of downstream cold-side ESPs. At high SO3
removal percentages, the loss of sulfuric acid conditioning of fly ash particles appears to cause
high resistivity conditions that limit ESP performance. With or without SCR, furnace injection
should lower the flue gas acid dew point, which may allow the plant to operate at lower air
heater outlet flue gas temperatures and realize heat rate improvements. Most coal-fired power
plants have steam or glycol heaters to preheat the ambient combustion air going to the air
heaters. The amount of preheat is adjusted to control the air heater outlet air and flue gas
temperatures. For bituminous coal plants, the air heater outlet flue gas temperature is typically
controlled to minimize adverse effects of sulfuric acid condensation, such as plugging and/or
corrosion in the air heater, or downstream corrosion. Lowering the flue gas SO3 concentration
upstream of the air heater, such as by furnace Mg injection, may allow the plant to lower the air
heater outlet temperature. This is typically implemented by reducing the amount of steam used to
preheat the combustion air to the air heater (or to heat the glycol solution). Reduced steam
consumption for combustion air preheat can improve the overall plant heat rate.
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. Commercial magnesium hydroxide can
be purchased for about $220/dry ton ($242/metric ton) f.o.b. the manufacturer’s plant,19 while
byproduct magnesium hydroxide can be produced for about $67/ton ($74/metric ton) (not
including capital cost recovery).18 Commercial magnesium hydroxide for furnace injection is
produced by precipitation from magnesium chloride, which produces a finer particle size than the
alternative production route of pressure slaking magnesium oxide.
19
VanOverschelde, Dan, Martin Marietta Specialty Chemicals, telephone conversation with Katherine Dombrowski.
13 November 2003.
2-3
The production of magnesium hydroxide from Thiosorbic lime was developed by Carmeuse, in
conjunction with EPRI, the Ohio Coal Development Office, and a utility.20 Thiosorbic lime is
magnesium-enhanced, containing 2-8 wt% MgO and 83-91 wt% CaO. Operation of the FGD
absorber with the magnesium-enhanced lime causes magnesium salts (MgSO4 and MgCl2) to
form in the FGD wastewater. When the byproduct from this type of FGD system is forced
oxidized, after the gypsum is recovered the remaining liquor can be further processed by lime
addition to precipitate a mixture of magnesium hydroxide and gypsum particles. The Mg(OH)2,
which has a particle diameter of 3 microns, is separated from the gypsum (average particle
diameter of 60 microns) with a hydroclone. The byproduct magnesium hydroxide contains 20%
suspended solids, of which at least 65% is Mg(OH)2.20 The equipment needed for the byproduct
magnesium hydroxide production system includes an agitated tank where the lime slurry and
FGD process liquid are mixed, hydroclones, a thickener, and a storage tank.
A project co-funded by DOE/NETL, EPRI, FirstEnergy Corporation, Tennessee Valley

Authority, American Electric Power and Carmeuse NA was undertaken to test the effectiveness
of calcium and magnesium based sorbents in one- to two-week furnace injection tests at
FirstEnergy’s Bruce Mansfield Plant (BMP).21 Commercially produced magnesium hydroxide
and byproduct magnesium hydroxide, along with dolomitic reagents were tested for furnace
injection. A Mg:SO3 ratio of 7:1 was required for 90% SO3 removal with the byproduct
Mg(OH)2, while molar ratios of 12:1 and 14:1 were required for 90% removal with commercial
Mg(OH)2. The lower molar ratios required for the byproduct magnesium hydroxide were
attributed to testing that reagent with injection at a higher elevation in the furnace, where dead-
burning of the sorbent was less likely to occur.
After completing the four one- to two-week tests, byproduct magnesium hydroxide slurry was
tested for a longer term (up to 23 days) in full-scale tests on two different units.17 In the second
longer-term test, commercial magnesium hydroxide slurry was also tested. The first long-term
test was conducted on FirstEnergy’s BMP Unit 3, and the second test was conducted on AEP’s
Gavin Plant, Unit 1. The Gavin Plant testing provided an opportunity to evaluate the effects of
sorbent injected into the furnace on SO3 formed across an operating SCR reactor.
The long-term test results show that injecting either slurry could achieve up to 70-75% overall
sulfuric acid removal. At BMP, the overall removal with byproduct magnesium hydroxide was
limited by the need to leave sufficient concentrations of SO3/sulfuric acid in the flue gas to
maintain acceptable electrostatic precipitator (ESP) particulate control performance. At Gavin
Plant, the overall sulfuric acid removal with both the byproduct and commercial sorbents was
limited because furnace-injected sorbent was found to be relatively ineffective at removing SO3
formed downstream, across the SCR system.
The long-term tests determined balance-of-plant impacts from slurry injection, including impacts
on boiler back-end temperatures and pressure drops, SCR catalyst properties, ESP performance,
20
Benson, L.B., K.J. Smith, R.A. Roden, E. Loch, and J. Potts. “Control of Sulfur Dioxide and Sulfur Trioxide
Using By-Product of a Magnesium-Enhanced Lime FGD System,” paper presented at the Combined Power Plant
Air Pollutant Control Mega Symposium, Washington, D.C., 19-22 May 2003.
21
Blythe, G., R. McMillan, J. Davis, M. Lamison, R. Rhudy, J. Beeghly, L. Benson, and E. Goetz. “Furnace
Injection of Alkaline Sorbents for Sulfuric Acid Control,” paper presented at the US EPA/DOE/EPRI Combined
Power Plant Air Pollutant Control Symposium, The Mega Symposium, Chicago, IL, 20-23 August 2001.
2-4
removal of other flue gas species, and flue gas opacity. For the most part the balance-of-plant
impacts were neutral to positive, although adverse effects on ESP performance became an issue
during the BMP test.
The Mg(OH)2 injection technology has been implemented at full scale at AEP’s Gavin Plant22
and installation is under way at Cinergy’s Zimmer Station.20 In both of these cases furnace
injection of magnesium hydroxide has been or will be coupled with injection of hydrated lime
downstream of the air heater.
Zimmer Station is a 1400 MW unit that burns bituminous coal with 3.5-4% sulfur. Currently, 1%
oxidation of SO2 to SO3 occurs in the furnace, and the installation of an SCR is expected to
contribute an additional 1% oxidation. Byproduct magnesium hydroxide formed from the
Thiosorbic lime FGD system will be injected in the furnace at a Mg:SO3 molar ratio of up to 8:1
to achieve 90% removal of furnace-generated SO3. Dry hydrated lime will be injected at the air
heater outlet at a molar ratio of up to 7.7:1 to achieve 90% removal of SCR-generated SO3.
Estimated costs are $5.4 million in capital costs to install the magnesium hydroxide production
system and operating costs of $67/ton Mg(OH)2 ($74/metric ton).20 The Zimmer installation is
expected to be completed during the first quarter of 2004, with injection beginning with the 2004
ozone season.23 No additional details are available for the Gavin installation.
Post-Combustion Injection of MgO
Magnesium oxide powder reacts with flue gas SO3 to form magnesium sulfate, which can be
removed in a downstream particulate control device. Magnesium oxide has been used as a fuel
oil additive and flue gas additive in oil-fired units, and to a lesser extent in coal-fired power
plants. Magnesium oxide can be injected into the furnace or post-combustion; however, this
discussion is focused on injection downstream of the economizer and/or SCR and upstream of
the air heater. When the MgO is injected upstream of the air heater, back-end corrosion
protection benefits are obtained. Furthermore, heat rate improvements may be achieved because
the air heater may be able to operate at a lower outlet temperature. ESP performance problems
can occur when the SO3 removal is high, though, due to the high resulting particulate matter
resistivity.
Martin Marietta produces magnesium oxide from magnesium hydroxide, which is precipitated
from an underground brine solution. The approximate product cost for MgO is $400/dry ton
($440/metric ton) f.o.b. Manatee, Michigan. Martin Marietta has participated in several full-scale
tests of post-combustion MgO injection at coal- and oil-fired power plants. In recent tests the
MgO has been injected before the air heater. Most of these tests lasted for only 1-2 days and
occurred on units ranging in size from 120 MW to 850 MW.24 Martin Marietta company
literature presents results from two of these tests.25 In one case MgO was injected at an
MgO:SO3 molar ratio of 0.5:1 to achieve 50-60% SO3 reductions at the ESP/stack. In the second
22
Duellman,D.M., Erickson, C.A., Licata, T. “Operating Experience with SCR’s and High Sulfur Coals and SO3
Plumes; paper presented at the ICAC NOx Forum, Houston, TX 2002.
23
Smith, Kevin, Carmeuse NA, telephone conversation with Katherine Dombrowski. 11 November 2003.
24
Schmidtchen, Paul, Martin Marietta Specialty Chemicals, Email to Katherine Dombrowski. 31 October 2003.
25
Martin Marietta Specialty Chemicals promotional sheet for Utilimag 40.
2-5
case from Martin Marietta promotional literature, the MgO:SO3 injection rate was 1.3:1 and
resulted in a 27% decrease in SO3 levels. The authors of this report speculate that the lower SO3
removal and sorbent utilization in the second case may be the result of injecting at the ESP inlet
rather than the air heater inlet, thereby reducing the residence time of the MgO sorbent in the flue
gas. According to a Martin Marietta representative, averaging the SO3 reductions measured in all
of the recent tests shows 65% reduction at a 1.5:1 to 2:1 molar ratio of MgO: SO3. The average
reflects tests on both coal- and oil-fired units, although reportedly most of the tests were on coal-
fired units.24 In a few isolated tests, removals as high as 80-92% were achieved; however,
Marietta does not believe this high removal percentage is typically achievable. Furthermore, ESP
operational problems were encountered at one test site when the SO3 removal target was
surpassed. Increasing the molar ratio to 2.5-3:1 does not provide much additional removal for the
cost of the sorbent.24 It is believed that duct geometry and residence time limits the achievable
removal.
As a general rule of thumb, Martin Marietta estimates that an MgO:SO3 molar ratio of 1-1.5:1
can achieve 65% or greater removal for inlet SO3 levels of 20-25 ppmv, while a higher molar
ratio of 1.5-2:1 may be necessary to achieve the same removal for inlet SO3 levels of 8-12
ppmv.24 This observation agrees with earlier EPRI SO3 control research, which found SO3
removal by gas/solid mass transfer to be more dependent on the sorbent surface area per unit
volume than on the injected stoichiometry. Thus, at lower uncontrolled SO3 concentrations, it
should take higher Mg:SO3 molar ratios to achieve a given removal percentage.
Martin Marietta is reportedly under contract to provide product for a full-scale installation at one
oil-fired unit and is negotiating a proposed contract at a coal-fired unit.
SBS Injection
The SBS injection process, which is patented by Codan Development LLC, injects a clear,
aqueous solution of sodium bisulfite (SBS) and/or sodium sulfite into the flue gas upstream of
the air heater at low reagent feed ratios (for example, near stoichiometric amounts) for selective
removal of SO3. Sodium bisulfite can react with flue gas SO3 or H2SO4 to form sodium sulfate
according to the following overall reactions:
SO3 + 2NaHSO3 → Na2SO4 + 2SO2 + H2O
H2SO4 + 2NaHSO3 → Na2SO4 + 2SO2 + 2H2O
Initially it was thought that sodium sulfate was the primary reaction product between sodium
bisulfite and SO3 or H2SO4. However, there is increasing evidence that other sodium species may
be formed, with sodium to SO3 reaction stoichiometries closer to 1:1 (e.g., sodium bisulfate
[Na2SO4]).
Sodium bisulfite represents the reaction product of a number of sodium-based alkalis with SO2;
consequently, it cannot further react with flue gas SO2 and is selective for SO3 (or H2SO4) over
SO2. Sodium sulfite, however, is alkaline with respect to SO2, and can react with SO2 to form
sodium bisulfite:
2-6
SO2 + Na2SO3 + H2O → 2NaHSO3
The bisulfite formed can then react with flue gas SO3 or H2SO4 according to the previous overall
reactions. Alternately, sodium sulfite may react directly with flue gas SO3 or H2SO4 to form
sodium sulfate or other sodium salts.
The SO3 or H2SO4 removal capability of the SBS process is thus controlled by the amount of
sodium bisulfite/sodium sulfite relative to the amount of SO3 present in the flue gas. The
residence time available for reaction, the SBS solution droplet size/surface area, and parameters
that affect gas/droplet mixing such as the number and location of injection nozzles also influence
system performance. Flue gas temperature affects droplet drying time and most likely also
affects chemical reaction rates. Another parameter that may affect SO3 or H2SO4 removal is the
ratio of sodium bisulfite to sodium sulfite in the SBS solution, as the two may react with flue gas
SO3 or H2SO4 at different rates. Also, if there is significant stratification of SO3 concentrations in
the flue gas at the location where the SBS solution is injected, this can affect SO3 removal
performance.
The SBS reagent can be commercially available sodium bisulfite, commercially available sodium
sulfite, or byproducts that are typically a mixture of these two species. The reagent can be
received as a clear solution (typically 25 to 30 wt% suspended solids) or as a dry powder. The
dry powder must be mixed with softened plant water to obtain the desired reagent concentration.
Since this process could be applied upstream of the plant air heater, it offers a potential for
operating at lower flue gas exit temperatures from the air heater, allowing improvements to the
plant heat rate. The process could also reduce corrosion in the air heater and downstream
equipment.
EPRI sponsored an evaluation of the process through a series of parametric tests and a long-term
test at Vectren’s A.B. Brown Unit 2.26 Unit 2 is a 265 gross MW unit equipped with an ESP and
a wet FGD absorber, but no SCR. The SBS injection location was at the economizer outlet. A
two-week parametric test was conducted in December 2001. The test evaluated effects of
variables such as the molar ratio of sodium alkali injected to flue gas SO3, the number of
injection lances and dual fluid injection nozzles in service, nozzle atomizing air pressure, SBS
solution weight % solids and pH. Over the range of variables tested, none other than the molar
ratio of sodium alkali to flue gas SO3 measurably impacted SO3 removal performance. Flue gas
concentrations of approximately 25 to 30 ppmv at the Unit 2 economizer outlet were consistently
reduced to 1 to 3 ppmv downstream of the ESP when injecting SBS at Na:SO3 mole ratios in the
range of 1.5:1 to 2:1. The long-term test was conducted from May 2002 to August 2002. During
the long-term test, the process was observed to continuously reduce or eliminate plume opacity,
and sulfuric acid concentrations measured in the ESP outlet flue gas typically remained less than
2 ppmv.
The most significant balance-of-plant effect observed during the long-term test was a buildup of
sodium-based salts and fly ash on the floor of the economizer outlet duct just downstream of
26
Results of Full-Scale Testing of Sodium Bisulfite Injection for Flue Gas Sulfuric Acid Control. EPRI, 1004167,
December 2002.
2-7
SBS injection nozzles and lances. The buildup appeared to be caused predominantly by nozzle
and lance operation upsets, which were a result of the design, construction, and operation of the
lances. Based on these results, a number of steps were taken in other demonstrations in an
attempt to eliminate duct buildup. These steps include switching to softened water to dilute the
concentrated SBS solution, to avoid calcium sulfite scaling in the feed piping, lances and
nozzles. Other changes included evolutionary modifications to the design, materials of
construction and fabrication of the lances and nozzles.
The SBS injection process has not been observed to adversely affect ESP performance even
when removing sulfuric acid down to less than 2 ppmv at the ESP outlet. This is apparently
because the sodium salts formed by this process condition fly ash resistivity in a manner similar
to conditioning by sulfuric acid. Other anticipated impacts, such as on air heater, were observed
to be minor during the A.B. Brown tests. The fly ash sodium content increased by up to 1.5 wt%
as Na2O at the highest injection rates.
Two commercial installations of the SBS injection process went into service in the spring of
2003, at FirstEnergy’s BMP and TVA’s Widows Creek Fossil Plant, and operated during the
“ozone season” of 2003. The two installations represent approximately 2300-MW of installed
capacity. These two commercial installations have reportedly seen tendencies for solids
deposition on air heater surfaces when injecting upstream of the air heater at conditions where
the SO3 is not removed at high efficiency (i.e., when more than 5 ppmv remains the in the flue
gas upstream of the air heater). These conditions include injecting at low localized or overall
Na:SO3 mole ratios and/or limited flue gas residence time (e.g., less than ~1 second) before the
air heater. The deposits apparently result because of reactions between the SBS byproduct solids
and remaining sulfuric acid that condenses within the air heater. Because of this, the SBS
injection process would likely only be installed upstream of the air heater if high removal
efficiency (~90% or greater SO3 removal) can be achieved, ensuring low remaining sulfuric acid
concentrations in the air heater inlet flue gas. For lower removal percentages, the process would
more likely be installed between the air heater and ESP. Also, these two commercial installations
have observed that regular maintenance of the injection nozzles and lances is required to avoid
solids deposition in the ductwork.
Neither of the two commercial installations sell their fly ash. It is not certain what, if any, impact
the addition of 1 to 2% sodium as Na2O in the fly ash would have on the salability of the fly ash
from plants that use the SBS process.
Ammonia Injection
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. It has also been tested and/or used commercially for the express
purpose of sulfuric acid control at a number of plants. One vendor reports installation of
ammonia injection at 21 units worldwide for the express purpose of acid dew point/SO3 plume
reduction.27
27
“Exhibit C14: Equipment Installation List Anhydrous Ammonia.” List prepared by Wahlco, Inc., Santa Ana, CA.
2-8
Ammonia can be injected between the air heater and ESP at NH3:SO3 molar ratios of 1:1 to 2:1
to achieve 95+% removal of sulfuric acid. Plants that have SCR systems already have a supply of
ammonia on site. The biggest issues in employing ammonia injection are the its effect on fly ash
disposal/reuse and the safe handling/storage of the reagent.
Ammonia reacts with sulfuric acid vapor by the following reactions:
NH3 (gas) + H2SO4 (gas) → NH4HSO4 (solid or liquid)
2 NH3 (gas) + H2SO4 (gas) → (NH4)2SO4 (solid)
These reactions are very fast and proceed to completion for flue gas temperatures of less than
400°F. The reaction products are either ammonium bisulfate (reaction 1), ammonium sulfate
(reaction 2), or a mixture of the two products. Because ammonium bisulfate has a relatively low
melting point (296°F), 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 (455°F).
The relative extent of 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 ammonium bisulfate is 1:1. Higher ratios will produce more ammonium sulfate and less
ammonium bisulfate, but will not substantially improve the 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 ammonium bisulfate 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 ammonium
bisulfate. Therefore, the optimum ratio is site specific.
Ammonium bisulfate and ammonium sulfate are unstable at typical air heater inlet flue gas
temperatures. Therefore, ammonia injection would not be practical for plants with hot-side ESPs.
Even for plants with cold-side ESPs, the ammonia should be injected downstream of the air
heater to avoid possibly fouling the air heater surfaces by various ammonium salts.
Configuration of Ammonia Injection System
Most of the ammonia injection systems operating at utility power plants were installed to
improve particulate matter removal, not to reduce SO3 concentrations. However, there are no
substantial differences between the systems installed for enhancing particulate removal and those
installed for reducing SO3 concentrations. In fact, operation of either system should reduce flue
gas SO3 concentrations and may enhance particulate matter removal.
In a typical ammonia injection system, ammonia is vaporized and then diluted with air to achieve
a mixture of 2 to 7% ammonia in air. This mixture is injected into the flue gas downstream of the
air heater. Anhydrous ammonia, aqueous ammonia (i.e. a solution of ammonia in water), or urea
can be used as the ammonia source. Most plants employing ammonia conditioning use
anhydrous ammonia as the starting reagent. Anhydrous ammonia is generally more cost-effective
2-9
than aqueous ammonia. Many plants that have SCR installed use urea as the ammonia source
because of community concerns over the storage of large quantities of anhydrous ammonia on
site. In these plants, a slipstream of the urea to ammonia product can be diverted to the air heater
outlet duct for SO3 control. For example, AEP’s Amos Station and Mountaineer Stations utilize
their SCR urea conversion systems to generate ammonia gas for their flue gas conditioning
systems.28 Urea is generally non-toxic and comes in solid cryastalline form which is dissolved in
water before it is injected.
The injection location must be upstream of the particulate removal device in order to remove the
solid reaction products from the flue gas. The flue gas temperature at the point of injection
should be above the sulfuric acid dew point to achieve good gas-gas reaction between the
ammonia and the sulfuric acid vapor.
The 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. High
velocities of up to 300 ft/sec may be necessary when injecting NH3 upstream of ESPs to achieve
penetration of the reagent into the flue gas and to prevent condensation of reagent in the probe.29
The number of nozzles will depend on the size of the plant, the vendor, the flue gas flow rate,
and the duct geometry. Because of temperature stratification across the duct, the size of nozzle
openings should compensate for the change in temperature and volume of NH3 along the length
of the probe. To improve gas mixing, the injection nozzles are normally positioned at various
levels in the duct. Vendors with experience in achieving good gas distribution should be
consulted when planning an ammonia injection system. A list of vendors is provided in Section
5; however, this list may not be all-inclusive and does not constitute an endorsement of any of
the listed vendors.
Performance Data for Ammonia Injection
Ammonia injection for SO3 reduction has been demonstrated at several full-scale, coal-fired
utility power plants30,31,32. Table 2-1 summarizes these plants and their operating conditions.
These results were presented in the 1994 SO3 Mitigation Guide. Each plant had a different reason
for investigating SO3 removal. The reasons included reducing corrosion, reducing the emissions
of acid particulate matter, reducing plume opacity, and improving ESP performance. For all
systems, the removal of sulfuric acid was 95% or better. These removals were achieved for SO3
concentrations of up to 22 ppm using NH3:SO3 molar ratios of 1.4 to 2.0. The high removal
levels significantly reduced the sulfuric acid dew point, indicating a substantial reduction in the
corrosion potential. In one case, the dew point was reduced from 280-285°F to less than 200°F.
28
Fox, George; Wahlco, Inc., letter to Katherine Dombrowski. 12 November 2003.
29
Makansi, Jason. “Ammonia: It’s coming to a plant near you,” Power. May 1992.
30
DeFries, T.H., L.O. Edwards, W.D. Balfour. “New York State Electric and Gas Somerset Station Unit 1 Ammonia
Injection Tests,” Research Project 2250-3, EPRI Report, Vol. I, October 22, 1987.
31
Thompson, C.M., A.F. Jones, and W.D. Balfour. “Monitoring Effects of Ammonia Injection at Tampa Electric
Company Big Bend Unit 4 for the Period November 1985 to February 1986,” Research Project 2250-3, Draft
Technical Note Prepared for Electric Power Research Institute, 06 January 1987.
32
Dismukes, E.B., J.P. Gooch, G.H. Marchant, Jr., and E.C. Landham, Jr. “Studies of Flue Gas Conditioning,”
Proceedings of Conference on Electrostatic Precipitator Technology for Coal-Fired Power Plants, Nashville, TN,
July 14-16, 1982.
2-10
The high SO3 removal levels also reduced the plume opacity by reducing the emissions of
condensed sulfuric acid droplets. As an example, at Detroit Edison, ammonia injection reduced
the stack particulate emissions by 40% because most of the emissions without ammonia injection
were sulfuric acid droplets.
Table 2-1
Full-scale Ammonia Injection Experience for SO3 Control
NH3
Coal SO3 Injection Reduction
Sulfur Concen- Concen- SO3 in Stack
Capacity Content tration tration Removal Particulate
Utility Plant (MW) (%) (ppmv) (ppmv) (%) Matter (%)
Tampa Big Bend 450 2.2-3.4 20 30 95+ Not

Electric Unit 4 reported
NYSEG Kintigh 643 2.8 4 8 95 85

Station
Not Not 400 - 22 30 95+ Not

published published reported
Detroit Monroe 750 2 2-5 8 95+ 40

Edison
Impacts on ESP Performance
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 and a reduction in fly ash re-entrainment upon
rapping. The space charge increases because the reaction of ammonia with SO3 produces a large
number of small solid particles that enter the ESP along with the existing fly ash. Fly ash re-
entrainment decreases because of the formation of the “sticky” ammonium bisulfate solids.32
Several utilities reported an increase in ESP sparking when injecting ammonia at high rates to
effect SO3 control. These problems occurred in the first few fields of the ESP and were caused
by higher space charge with ammonia injection. The problems were minimized by tuning the
ESP (e.g., by adjusting the spark rate controllers).
Impacts on Waste Disposal Options
Most of the injected ammonia is converted to ammonium bisulfate or sulfate, which is collected
along with the fly ash in the particulate control device. Ammonia will be released if the collected
solids are contacted with water, especially when the pH is alkaline (pH > 7.0). Alkaline
conditions are common for plants that use lime to stabilize the fly ash/FGD solids mixture.
Ammonia vapor will also be released if the fly ash is used as an admixture for cement or
concrete, again because of high pH conditions. Generally, the release of ammonia from the solids
is not a health concern but it may be irritating to plant operators and/or concrete handlers.
2-11
Release of ammonia odors can result if the ash is sluiced to an open pond, or if dry-handled fly
ash is not quickly covered. Even if airborne releases of ammonia are not a concern, ammonia in
fly ash can cause water quality issues. If the fly ash is handled dry and disposed of in a landfill,
there is typically a leachate and runoff collection system to handle rainfall on the disposal area.
With significant quantities of water-soluble ammonium salts in the fly ash, dissolved ammonia
could limit the ability to discharge this leachate without treatment. For plants that sluice their fly
ash to a pond and reuse or discharge the pond water, the ammonium ion present in the water
would also likely require some form of water treatment.
The biggest issue for ammonia injection is its effect on fly ash disposal/reuse. Ammonia slip
from SCR systems can result in small quantities of ammonia in the fly ash, but also using
ammonia for sulfuric acid control can increase the amount in fly ash more than tenfold.
Ammonia injection may decrease the sale price of a utility’s fly ash, or in some cases, it may
prohibit selling fly ash. The literature documents one utility injecting ammonia that was still able
to sell fly ash for use in cement production, but the ash was used in a different, less economically
attractive way.31 With ammonia present, the fly ash had to be fed to the cement kiln, instead of
being added directly to the concrete. The fly ash was substituted for some of the clay that was
normally added to the kiln. With this change the fly ash had a lower value than when it was
added directly to the concrete.
Wahlco reports that use of ammonia conditioning at United Kingdom’s National Power Abethaw
Station Unit 7 resulted in the release of ammonia from ash used as a cement additive.33 Wahlco
indicates that the nuisance smell was short in duration, making the cement usable in outdoor
conditions, but rendering it possibly unusable for indoor applications
Impacts of Ammonia Injection on FGD Systems
Ammonia addition to the flue gas produces ammonium sulfate/bisulfate, most of which is
removed in the particulate control device. Unreacted ammonia and product solids that penetrate
the particulate control device can potentially be removed by the FGD liquor and may influence
FGD operations. Little data have been published about the influence of ammonia injection on
FGD system operation. Data from a long-term test of ammonia injection at one coal-fired utility
showed that ammonia injection did not cause any operating problems or affect either the FGD
system’s SO2 removal performance or limestone consumption rate.31
Ammonia Injection Safety Concerns
Ammonia vapor in low concentrations can be irritating to plant personnel and at higher
concentrations it can be deadly. The risks associated with ammonia storage and injection should
be considered carefully before installing an ammonia injection system. The use of aqueous
ammonia reduces the level of risk because of the lower ammonia vapor pressure. However, the
quantity of material to be stored and the shipping costs are greater.
33
Wahlco Environmental Systems, Inc. “Environmental Effects of Ammonia Injection into the Flue Gas of National
Power, Aberthaw Power Station, Unit #7” 07 October 1996.
2-12
Large ammonia storage tanks will need to be installed at the plant. For example, at one 450-MW
plant, the anhydrous ammonia consumption rate at full-load was about 1200 lb/day (0.55 metric
ton/day). Therefore, this plant needed a 10-ton (9-metric ton) anhydrous ammonia storage tank in
order to have a 15-day supply of ammonia. For an aqueous ammonia system, a larger tank would
be needed. The large ammonia tanks may trigger the OSHA review under 29 CFR 1910 (Process
Safety Management of Highly Hazardous Chemicals).
Dry Sorbent Injection Upstream of ESP
Dry sorbent injection for SO3 removal has been extensively tested at the pilot scale by EPRI, and
is part of the SO3 mitigation measures installed or being installed at Gavin and Zimmer. Dry
sorbents remove SO3 by a gas-solid reaction. The sorbent is pneumatically injected upstream of
the existing particulate control device. The reaction products and any unreacted sorbent are
removed along with the fly ash by the particulate control device.
An effective sorbent must possess two qualities: the sorbent particle size must be small (high
geometric surface area per unit mass) and the reaction rate between the sorbent and SO3 must be
very fast. When these criteria are met, the SO3 removal is limited only by the diffusion rate of
SO3 from the bulk gas to the surface of the sorbent particles. Sorbents can include calcium-
based, sodium-based, and magnesium-based materials. This section focuses on lime injection,
with results of other materials included for comparison.
Figure 2-1 presents the SO3 removal results for dry sorbent injection of various calcium- and
sodium-based materials. These data are from pilot scale tests conducted by EPRI at the
Environmental Control Technology Center (ECTC) in the early 1990s.34 Calcium-based sorbents
include dolomitic reagents (discussed earlier) and lime (Ca(OH)2). The only sodium-based
sorbent tested as the ECTC was sodium bicarbonate. The data showed that the hydrated limes
were the most reactive of the tested sorbents. Sodium bicarbonate was less reactive than the
hydrated limes, primarily because the sodium bicarbonate tested had a much larger average
particle size (38 µm vs. 6 µm). Previous results from the ECTC showed that sodium bicarbonate
was just as reactive as hydrated lime when the two sorbents had similar particle size
distributions.35 The SO3 removal levels obtained for limestone and MgO injection were much
lower than those for hydrated lime injection, even though the sorbents had similar particle size
distributions. For all of the dry sorbents tested, high injection rates were required to achieve high
removal efficiencies. For example, 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 rate corresponds to
Ca:SO3 molar ratios of approximately 8:1 to 17:1, many times the stoichiometric amount.
34
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.
35
Peterson, J.R., G. Maller, A.D. Burnette, and R.G. Rhudy. “Pilot Scale Evaluation of Sorbent Injection to Remove
SO3 and HCl,” paper presented at the SO2 Control Symposium, Washington, D.C., 03-06 December 1991.
2-13
100
90
80
70
SO3 Removal (%)
60
50
40
Chemstar Lime
Mississippi Lime
30
Thiosorbic Lime
Sodium Bicarbonate
20
Limestone - Regular Grind
Limestone - Fine Grind
10
MgO
0
0 1 2 3 4 5 6 7 8
Sorbent Injection Rate (lb/hr/kacfm)
Figure 2-1
ECTC Performance Data for Dry Sorbent Injection for SO3 Control
During the 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.35 The ESP outlet mass
emissions increased accordingly.
As in the SBS injection process, dry injecting sodium-based material was not observed to cause
ESP problems, so a blend of hydrated lime and sodium bicarbonate was tested. Dry injection of
the sorbent blend provided good SO3 removal without causing operating problems in the ESP.34
For the ECTC test conditions, a blend of 20% sodium bicarbonate with 80% hydrated lime
appeared to be the optimum sorbent from a cost and performance standpoint. The optimum blend
ratio may be site specific.
Solid Waste Impacts of Dry Sorbent Injection
Dry sorbent injection affects the disposal of solid wastes in two ways. First, sorbent injection
increases the amount of particulate matter collected by the particulate control device. The plant’s
landfill life is correspondingly shortened. For example, at a sorbent injection rate of 4
lb/hr/kacfm, sufficient for about 80% to 90+% SO3 removal, and for a typical bituminous coal
(7% ash in the coal, 30% excess air for combustion), the amount of solids removed by the ESP
would increase by about 25% compared to normal operation.
2-14
Dry sorbent injection may also increase the leachability of the collected particulate matter in the
landfill. Sodium salts are very water soluble, so sodium bicarbonate may increase the
leachability of sodium, sulfates, chlorides, and other species from the ash in a landfill. The
impact may be severe enough to require re-permitting of the landfill and/or lining the landfill to
avoid discharging soluble species to the water table.
Dry sorbent injection might also limit the use of fly ash for admixtures to cement and concrete
because substantial amounts of unreacted sorbent will be present in the fly ash, particularly if
sodium-based sorbents or sorbent blends are used.
The dry hydrated lime technology is being installed and/or has been in operation at two coal-
fired installations, Cinergy’s Zimmer Station and AEP’s Gavin Plant, both in conjunction with
furnace magnesium hydroxide slurry injection. The dry hydrated lime is injected at the air heater
outlet. A design Ca:SO3 molar ratio of 7.7:1 is targeted at Zimmer to achieve 90% removal of
SCR formed SO3.
Lhoist reported the use of a high-specific-surface-area hydrated lime (Spongiacal Lime) for SO3
control upstream of a wet FGD system in Germany.36 However, this application is on a relatively
low sulfur coal and the plant is equipped with a gas-to-gas heat exchanger, which lowers the
FGD inlet flue gas temperature. Based on a review of the results in the Lhoist paper, it appears
that the gas-to-gas heat exchanger is dropping the flue gas below its sulfuric acid dew point, such
that the acid is being condensed by the heat exchanger and neutralized by the lime, rather than
being removed by the hydrated lime strictly through gas/solid reactions. The Lhoist process
therefore is more appropriately considered to be a variation on the lime injection/flue gas
humidification process described below.
Lime Injection with Flue Gas Humidification
Testing in 1992/1993 at the ECTC investigated flue gas humidification with alkali addition to
determine if high SO3 removals could be obtained without causing operational problems in the
ESP. In this technology the flue gas is partially humidified and cooled to below its acid dew
point. The sulfuric acid is removed by condensing large acid droplets that can be collected in a
cold-side ESP or wet scrubber. Alkali is injected to neutralize the sulfuric acid droplets formed,
so they are less corrosive to ductwork and ESP collecting plates. The calcium-based alkali
increases the fly ash resistivity, which counteracts the decrease in resistivity caused by
humidification, and thereby mitigates any potential ESP performance problems. Flue gas
humidification reduces the waste disposal impacts of sorbent injection because, for a given SO3
removal level, the amount of sorbent required is much lower when the flue gas is humidified.
36
Pettiau, X. and A. Laudet, “Improved SO3 Removal Using Spongiacal Dry Lime Injection,” poster paper
presented at the Combined Power Plant Air Pollutant Control Mega Symposium, Washington, D.C., 19-22 May
2003.
2-15
A number of options are possible for flue gas humidification downstream of the air heater. One
is for humidification and alkali injection upstream of an ESP. The flue gas can be humidified and
dry hydrated lime powder injected separately, or lime slurry can be injected in one step. EPRI
tested both configurations and obtained similar removal results.37
Figure 2-2 shows the effect of humidification on SO3 removal with hydrated lime injection. For
these tests, hydrated lime was injected as a dry powder into the flue gas upstream of a
humidification nozzle. The humidification cooled the gas from 307°F to either 260°F or 280°F.
Humidification greatly increased the SO3 removal and lowered the amount of reagent needed to
achieve a given SO3 removal. For example, to achieve 80% SO3 removal, the dry sorbent
injection process required a sorbent injection rate of 4 lb/hr/kacfm. The required rate dropped to
2 lb/hr/kacfm when the flue gas was humidified to 280°F. No sorbent at all was required to
achieve 80% SO3 removal when the flue gas was humidified to 260°F.
Most of the increase in SO3 removal was due to cooling of the flue gas below the acid dew point
temperature. Below this temperature, sulfuric acid will condense on any available surface.
Because fly ash and sorbent are dispersed in the flue gas, the sulfuric acid tends to condense on
these particles. In other words, the increase in SO3 removal with flue gas humidification is
primarily due to the humidification process, not to combined effects of humidification and
sorbent injection. However, the injection of calcium-based sorbents along with humidification
appears to be important for two reasons: to neutralize condensed acid to minimize corrosion in
the ductwork and ESP, and to help maintain the ash resistivity in the ideal range, as discussed
below.
Data in Figure 2-3 show that during dry sorbent injection, flue gas humidification increased the
operating current in the first field of the ESP compared that during dry injection without
humidification. Several ESP outlet mass loading tests confirmed that the particulate control
efficiency was better with flue gas humidification than with dry sorbent injection alone.
37
SO3 Mitigation Guide. EPRI, TR-104424s. October 1994.
2-16
100
90
80
70
SO3 Removal (%)
60
50
40
30
20 Humidify to 260°F
Humidify to 280°F
10
No Humidification (307°F)
0
0 1 2 3 4 5 6
Figure 2-2
ECTC Data for Hydrated Lime Injection with Flue Gas Humidification for SO3 Control
45
40
Operating Current, ESP First Field (mA)
35
30
25
20
15
10
No Humidification (307oF)
Humidify to 280oF
5
Humidify to 260oF
0
0 1 2 3 4 5 6
Figure 2-3
Effect of Flue Gas Humidification on ESP Operating Current for Dry Injection of Hydrated
Lime Upstream of Humidification Nozzle
2-17
However, the ECTC results also showed that flue gas humidification alone (no alkaline reagent
injection) degraded overall ESP performance, apparently because the humidification and
resulting sulfuric acid condensation lowered the ash resistivity below the ideal range. At low
resistivity, ESP performance is limited by re-entrainment of particles that are not held tightly to
collecting plates by electrostatic forces.
Further testing determined that injection of calcium- or magnesium-based alkalis along with
humidification could restore baseline (no humidification) ESP performance. This is apparently
because the condensed sulfuric acid reacts with the calcium or magnesium alkalis to form higher
resistivity salts whereas the condensed acid alone greatly reduces the fly ash particle resistivity.
This effect is illustrated in Figure 2-4, which shows that injecting limestone with the
humidification water at a rate of 1.4 lb/hr/kacfm, rather than water alone, could restore ESP
performance to baseline (no humidification) performance.
An alternate configuration for the flue gas humidification/alkali injection process might be to
humidify the flue gas between the ESP and wet FGD, with water alone or with an alkaline slurry,
relying on the FGD absorber to remove the sulfuric acid and/or calcium or magnesium sulfate
droplets formed. The Chemical Lime Company has reportedly conducted short-term tests with
injection of hydrated lime slurry in the inlet duct of a full-scale FGD absorber. However, no
results have been published from these tests. A potential problem with alkaline slurry injection
upstream of the FGD is whether the slurry particles would be scrubbed at high enough efficiency
to avoid particulate emission increases.
0.1
Baseline ESP Operation

Water Only
ESP Outlet Emissions (lb/MM Btu)
Limestone Slurry
Mg(OH)2 Slurry
0.01
0.001
0 0.5 1 1.5
Figure 2-4
Effect of Sorbent Injection with Humidification Water in Restoring ESP Performance
Compared to Humidification Alone
2-18
If water alone were injected to humidify the flue gas between the ESP and wet FGD absorber, it
is not certain that the process would be effective, as there would be very few particles available
on which sulfuric acid could condense and grow large enough to be collected in the scrubber.
PreussenElektra (now E.ON) reported the use of humidification (water only) just upstream of a
wet FGD absorber in Germany as a means of reducing outlet SO3 concentrations, but reported
performance data only for low inlet sulfuric acid concentration conditions.38
Physical Methods
Some plants may not wish to employ chemical methods for reducing their flue gas SO3
concentrations because of safety, corrosion, or cost concerns. These utilities may wish to
consider one of the physical methods listed below.
Fuel Blending
Low-sulfur coal blending or switching lowers the SO2 content of the flue gas, which reduces the
concentration of SO3 produced in the furnace and across an SCR catalyst. Although reducing
sulfur content is generally expected to reduce the SO3 concentration, changes in the sulfur
content may not result in directly proportional changes in SO3 concentration. Therefore, the
effectiveness of fuel blending on SO3 mitigation can be difficult to predict.
However, in the absence of performance data, a simple approach for estimating the effect of
blending in a lower sulfur coal is to assume a constant percent conversion of SO2 to SO3, with
the resulting SO3 concentration reduction being linearly proportional to the reduction in sulfur
content of the blend. Proprietary data from one plant has shown that when blending with Powder
River Basin coal, the reduction in economizer outlet SO3 concentration was greater than the
percent reduction in coal sulfur, though. At that plant, when the percentage of PRB coal in the
blend exceeded a threshold value, the SO3 concentration decreased to zero. In this case, the
presence of alkaline ash from the PRB coal apparently adsorbed the SO3 formed. The actual
realized SO3 reductions will depend upon the specific characteristics of the coals being fired and
the design of the boiler in which the coal blend is fired.
Switching to low-sulfur coal sometimes adversely affects the ESP performance. Generally, low-
sulfur coals produce high resistivity fly ashes that are difficult to collect with cold-side ESPs.
Switching fuels can also affect boiler operation. Boiler efficiency may change and slagging
problems or corrosion problems may result.
The ability to implement fuel blending and its cost effectiveness can be very site specific. For
example, the ability to blend or switch to low-sulfur coal can be limited by issues such as long-
term coal contracts, coal mill capacity, furnace slagging and fouling tendencies, and ESP
performance. Blending can also require room for multiple coal piles and the ability to prepare
38
Gutberlet, Dr. Heinz, Hans-Ulrich Hartenstein, and Anthony Licata, “SO2 Conversion Rate of DeNOX Catalysts –
Effects on Downstream Plant Components and Remedial Measures,” paper presented at the EPRI-DOE-EPA
Combined Utility Air Control Symposium: The Mega Symposium, Atlanta, GA, August 16-20, 1999.
2-19
coal blends in the coal yard, on conveyors, and/or in bunkers. If low-sulfur-coal firing is feasible,
though, it can result in other benefits such as making more SO2 allowance tons available and
reducing associated FGD costs due to lower limestone usage. Fuel blending may also allow
lower air heater outlet flue gas temperatures, which can result in plant heat rate improvements.
Notwithstanding capital expenses that may be required, the economics of coal blending are
mostly driven by the delivered cost differential between the current coal and the low-sulfur coal.
Changes in delivered fuel price of a few cents per million Btu can change the annual costs for
this control option by several hundred thousand dollars or more.
Wet Electrostatic Precipitator
Electrostatic precipitation is a well-established method for collecting fine particulate matter in

many different industrial applications; however, sulfuric acid control on 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.
The collection efficiency of a wet or dry ESP tends towards a minimum value for particles in the
size range from about 0.2 to 1 micron.39,40 Penetration of particles in this size range may be five
to ten times the overall penetration rate for a high efficiency ESP collecting fly ash.41,42 The
particle size dependence of ESP performance is important with respect to opacity problems
because the particle size range that is most difficult to collect is roughly the same size range that
most effectively causes opacity by scattering visible light. Sulfuric acid mist is in this submicron
size range, and it is typically not collected by dry ESPs. Furthermore, at typical cold-side ESP
flue gas temperatures in the range of 300oF or greater, most or all of the sulfuric acid present in
the flue gas remains in the gas phase; thus, it is not collected by electrostatic forces.
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. Operating power within a wet ESP can be as high as 2000
watts/kcfm, while that of a dry ESP is limited to 100-500 watts/kcfm.43 Wet ESPs can remove
other flue gas components that contribute to plume opacity including fine fly ash particles,
unburned carbon or soot, and when installed downstream of wet FGD, scrubber carryover.
Removal of the latter can be a benefit in controlling droplet rainout from wet stacks. Dust
resistivity problems typically encountered with dry ESPs are eliminated with a wet ESP since the
water-saturated condition renders all particles generally conductive.
39
A.C. Stern (ed.). Air Pollution, 3rd Edition, Vol. IV, NY: Academic Press, 1977.
40
M.W. McElroy, et al. “Size Distribution of Fine Particles from Coal Combustion,” Science, Vol. 215, January,
1982
41
Economics of Fabric Filters Versus Precipitators. EPRI, FP-775, June, 1978.
42
E. Baake. “Wet Electrostatic Precipitator for Control of Submicron Particulate.” In Fine Particle Technology,
APCA Reprint Series, Air Pollution Control Association, Pittsburgh, PA, 1975.
43
Altman, R., W. Buckley, I. Ray. “Wet electrostatic precipitation demonstrating promise for fine particulate
control.” Power Engineering, January 2001.
2-20
ESP performance, as described by the Deutsch equation, is dependent on the collection area of
the ESP, the effective migration velocity of a particle, and the volume of gas being treated. The
migration velocity is a function of the particle size, particle charge, gas properties, and the
electrical field strength of the ESP. The effective migration velocity includes the predictable
effects of particle charge and field strength; also included are the effects of sneakage and re-
entrainment.
Sneakage is the passage of untreated gas through the ESP via gaps between the collecting plates
and the ash hoppers or the charging electrode supports. Re-entrainment is the process by which a
portion of the collected material is re-suspended in the gas when the collected material is
removed from the plates by rapping. Re-entrainment is not an issue for wet ESPs since the
collected material is removed in liquid stream.
There are two ways to deliver the irrigation water to a wet ESP. In the first method, which is
more commonly employed, 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. The blow down
goes to either the FGD system or a separate system for treatment. In a second irrigation method,
the plates are washed by a flowing film of water created by condensing water from the flue gas.
Condensation of flue gas moisture results from cooling the collecting electrode surface with a
continuously recirculated stream of water. The cooling water does not come into contact with the
condensed water. Condensed moisture is collected, treated, and typically recycled back to the
pre-scrubbing section of the wet ESP. A condensing ESP can reduce the use of fresh makeup
water and minimize the treatment of recycled liquid.43
Wet ESPs are designed in two different configurations: plate precipitators with horizontal or
vertical gas flow and tubular precipitators with vertical gas flow. The plate-type ESP is the
familiar version that is used for fly ash collection. In the tubular ESP, the gas passes through a
bundle of vertical parallel tubes instead of between parallel plates. The charging electrode
extends the length of the tube centerline. The tubular configuration is more easily washed than
the plate configuration and eliminates gas sneakage because all of the gas passes through the
tubes. For a given collection efficiency, the tubular precipitator can be operated at twice the gas
velocity as a plate precipitator of equal length. It also has a smaller footprint than the plate
precipitator.44
The plate-type ESP can be installed at the back end of a dry ESP for a final polishing of the gas.
Humidification of the flue gas in the wet field condenses sulfuric acid so that it can be removed
by electrostatic forces. EPRI pilot-scale test results have shown that sulfuric acid collection
efficiencies of 60 to 70% or greater are possible for last-field retrofits of dry ESPs, depending on
the outlet flue gas temperature.45 To achieve high sulfuric acid removal efficiencies (>80%), a
multi-stage wet ESP would more likely be installed downstream of the wet FGD absorber or
possibly installed inside the absorber vessel as a replacement for the chevron-style mist
eliminator.
44
Reynolds, J., W. Buckley, and I. Ray. “Advances in wet electrostatic precipitation technology at fossil fuel power
plants for multi-pollutant control,” paper presented at the Institute of Clean Air Companies (ICAC) Forum 2003:
Multi-Pollutant Emission Controls & Strategies. Nashville, TN, 12-15 October 2003.
45
Monroe, L.S. and K.M. Cushing. Wet Electrostatic Precipitator Addition to the Outlet of a Marginal Dry ESP.
Final Report for EPRI Contract WO3453-04. Palo Alto, CA. 1996
2-21
Since wet ESPs are typically installed at or near the end of the flue gas path, they address only
plume opacity and particulate emissions and provide no upstream benefits for air heater outlet
temperatures or duct corrosion.
While wet ESPs offer high collection efficiencies for sulfuric acid mist as compared to dry ESPs,
there are potential problems associated with their operation. A wet ESP generates an aqueous
waste that must either be treated separately or added to the FGD system. Adding this 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. Recirculated spray water can become supersaturated with low solubility
compounds that can plate out inside the precipitator. On scrubbed units, because the wet ESP
would remove both sulfuric acid and calcium-based scrubber carryover, careful control of the
water chemistry is needed to avoid gypsum scale formation on collector plates and/or blow down
piping. The same is true if calcium-based reagents are used to neutralize the collected acid in the
recirculating water used to wet the plates. EPRI has prepared a conceptual design of water
treatment systems for wet ESPs.46
The presence of water in the ESP enhances latent corrosion problems, requiring the use of higher
alloys. Choices for material of construction include alloys such as 316, 904L, 6% molybdenum
alloys, and C276. The use of 316 typically requires alkali makeup to control the pH of the
recirculating wash water. Over the last ten years, operational experience with these materials in
wet ESPs constructed for coal fired power plants have shown good corrosion resistance.47,48,49
An alternative to metal-based collecting plate construction is the membrane-based wet ESP

technology is being developed by a collaboration of Ohio University, Southern Environmental,
and Croll-Reynolds.44,50 A corrosion resistant fabric membrane is used as the collecting plate.
The membrane is cleaned by dripping a flushing liquid over the membrane. Once the membrane
is saturated with the liquid, a layer of water flows down the membrane surface. Capillary action
provides for distribution of the washing water in both the vertical and horizontal directions,
allowing for even distribution. The membrane material could be potentially advantageous for its
better corrosion resistance, lower cost, and lower density than stainless steel or higher alloys.
Corrosion resistance has been tested primarily at the laboratory scale with acid immersion tests.
Testing began in 2003 under a DOE NETL grant for comparison of metallic- and membrane-
based wet ESP technology in a pilot unit at FirstEnergy’s Bruce Mansfield Plant.50
46
Patel, D.V., et al. Water Treatment for Wet Electrostatic Precipitators, Conceptual Design, EPRI, Palo Alto, CA:
1997. TR-108926.
47
Staehle, R.C., R.J. Triscori, G. Ross, K.S. Kumar, and E. Pasternak. “The past, present, and future of wet
electrostatic precipitators in power plant applications,” paper presented at the Combined Power Plant Air Pollutant
Control Mega Symposium, Washington, D.C., 19-22 May 2003.
48
Kumar, K.S., A. Mansour. “Wet ESP for controlling sulfuric acid plume following an SCR system,”paper
presented at the Institute of Clean Air Companies (ICAC) Forum 2002: Cutting NOX. Houston, TX, 12-13 February
2003.
49
Pontbriand, M.W., R.J. Keeth, R.S. Blagg. “Performance of a Full-scale Wet Electrostatic Precipitator,” paper
presented at PowerGen 2002, Orlando, FL, 10-12 December 2002.
50
Caine, J., D.J. Bayless, J. Reynolds. “Comparison of metallic vs. membrane based wet ESP technology for PM2.5,
SO3 mist and mercury control at a coal-fired power plant,” paper presented at the Combined Power Plant Air
Pollutant Control Mega Symposium, Washington, D.C., 19-22 May 2003.
2-22
Based on data gathered from vendors, the cost of wet ESP installations can span a large range,
from $20/kW to upwards of $90/kW, depending upon configuration and the required sulfuric
acid control efficiency. High removal efficiencies typically require multistage precipitators.
Downstream of an existing wet FGD, high capital costs can result because of the lack of
available real estate, making for a difficult retrofit in an existing vessel and/or at an elevated
location. Capital costs should be lower for a new FGD installation, where the wet FGD can be
included as an integral part of the design and installation.
A wet ESP sized to achieve 90% control of sulfuric acid mist at the scrubber outlet would
consume less than 0.1% of the station’s gross output.48
While wet ESP technology has been used in other industries over the past century, its application
in pollution control for power plants has been fairly recent. Full-scale implementation of wet
ESP has occurred at a handful of sites, and pilot and full-scale demonstrations are in progress for
the further development of the technology.
A wet ESP has been in operation since 1986 at AES Deepwater, a 155 MW petroleum coke fired
cogeneration plant in Pasadena, Texas. Because of the high vanadium content of the petroleum
coke fired, the flue gas contained high SO3 concentrations. Only 20-30% of this sulfuric acid was
captured by the wet FGD system, so a wet ESP was installed downstream of the wet FGD. The
upflow system using plate-type collectors47 was designed for 98.9% removal of fine particulate
and sulfuric acid mist.48 The WESP was originally built with plates made of reinforced thermoset
plastic and discharge electrodes made of C-276. The plates were originally designed for
continuous irrigation, but the maintenance costs increased to a point where the plates and
discharge electrodes were replaced with 6% molybdenum alloy. The washing of the plates was
reduced to only once a shift. As of 2003, no corrosion was observed with the new plates. Water
usage for the wet ESP is reportedly 4 gal/kacf.48
Xcel Energy’s Sherbourne County Station retrofitted wet ESPs starting in 1998 to reduce stack
opacity from 40% down to 10%. Sherbourne County Station consists of two 750 MW units
which burn subbituminous coal with 20% CaO in the fly ash. The CaO absorbs SO3 in the flue
gas, so little or no SO3 is present in the flue gas. Therefore, the internals of the wet ESP were
constructed of 304L rather than a more expensive alloy. Each ESP module must be taken off-line
once a year for a thorough high-pressure wash to remove scale formed from the calcium in the
flyash.47 While this experience is not directly applicable to SO3 mitigation, it does highlight a
scaling problem that could occur in wet ESPs installed downstream of a wet scrubber.
A wet ESP is being installed on top of a new wet FGD absorber at New Brunswick Power’s
Coleson Cove Station.51 Coleson Cove burns Orimulsion, which has a high sulfur and vanadium
content. The unit is expected to be operational by September 2004. It is designed to control
sulfuric acid emissions below 5 ppmvd at 3% O2. A mist eliminator will be placed after the
WESP to capture re-entrained droplets generated during flushing cycles. The collecting plates in
51
Staehle, Richard C., Ronald J. Triscori, K. Sampath Kumar, Gary Ross, and Randy Cothron. “Wet Electrostatic
Precipitators for High Efficiency Control of Fine Particulates and Sulfuric Acid Mist,” paper presented at the
Institute of Clean Air Companies (ICAC) Forum 2003: Multi-Pollutant Emission Controls & Strategies. Nashville,
TN, 12-15 October 2003.
2-23
the first field will be constructed of C276; downstream plates and the high voltage systems will
be constructed of 6% molybdenum alloy. Estimated costs for a similar wet FGD/WESP
integrated system range from $20/kW to 40/kW for the WESP portion. The lower end of this
cost estimate is for a WESP with one field and a collection efficiency of 50%. The upper end of
the range is for a three-field WESP with >90% collection efficiency.
A full-scale wet ESP was installed at a coal gasification facility in North Dakota following a site
demonstration of the concept with slipstream pilot tests.49 The wet ESP treats the equivalent of
400 net MWe of flue gas. It is designed for horizontal flow, with four cells in parallel, each
consisting of three fields in series. Internal gas flow baffles were installed to minimize sneakage.
The WESP uses recycled water. Each collecting field has its own water washing system, so that
upstream fields which have the highest collected particulate matter can be washed more often.
More fresh makeup water is used on the last field, to avoid high particulate matter carryover to
the stack. Approximate capital cost to build the unit was $90/kw. The authors assert that their
costs are higher than other published costs due to inclusion of balance-of-plant tie ins and
equipment, the interest accrued during construction, and home office and subcontracted
engineering costs. Operating costs are estimated at $715,000/ year and include the power for
pumps, fans compressors, the power consumption by ID fans to overcome the WESP pressure
drop of 0.5” w.g, maintenance labor and materials, and steam for HVAC. No labor costs are
included in this value as no personnel were added for operation. Water costs are not included
because the WESP wastewater is sent to the FGD as makeup water. The authors state that the
system uses 150 gpm of makeup water and 1300 kW of power, which equates to 0.13 gal/kacf
and 1.1 watts/cfm.
A tubular wet ESP was pilot-tested using a slipstream of flue gas from FirstEnergy’s Bruce
Mansfield Station. The tests were performed in September 2001. With one field in operation,
76% removal of SO3 was achieved. Retrofitting the unit to a two-field configuration increased
the SO3 removal to 92%.44
Croll-Reynolds designed a last field retrofit to a dry ESP at Mirant’s Dickerson Station.44 The
project was co-funded by EPRI and a number of member utilities. The purpose of the system was
to control particulate matter, not SO3. However, this case is the only published attempt of a full-
scale, last-field retrofit of a dry ESP in a U.S. utility application. Testing of the full-scale
demonstration was carried out in 2000-2001. The retrofitted ESP consisted of two dry fields and
one wet field. Opacity was decreased to 10%. However, this technology was not implemented
due to mechanical problems that limited power input to the wet field and resulted in carryover of
wet droplets to the unit ID fans.52 Croll-Reynolds reports that the mechanical problems have
since been overcome in a slipstream, pilot-scale, horizontal plate wet ESP.43
52
Guidelines for Implementing Wet Electrostatic Precipitator: Test Report, EPRI, Palo Alto, CA, Kentucky
Utilities, Ghent, KY, American Electric Power, Columbus, OH, FirstEnergy Corporation, Akron, OH, Cinergy,
Cincinnati, OH, Mirant, Upper Marlboro, MD, and Tennessee Valley Authority, Chattanooga, TN: 2001. 1004607.
2-24
Condensing Air Heater
In the air heater, the primary mechanism for the reduction of gas phase SO3 is the condensation
of SO3/H2SO4 onto ash particles. Condensation occurs when the local temperature is less 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 the submicron ash
particles.53
Marsulex Environmental Technology, in conjunction with EERC and Alstom Power Air
Preheater Company, is developing a process which will enable the air heater to operate with a
lower exit temperature, with the intent of achieving high sulfuric acid capture and improving the
plant heat rate.53 Operation at a lower exit temperature will force the condensation of the sulfuric
acid in the cold end of the air heater, thereby reducing downstream corrosion. To operate at a
reduced exit temperature, the air heater would be upgraded to employ acid-resistant porcelain
enamel for the cold-end baskets. Injection of micronized limestone would neutralize the
condensed acid. The utility would buy limestone ground to 100-mesh and then micronize it to a
2- 4-µm median diameter with a jet pulverizer.54
No full-scale implementation work has been carried out to date. The design work has been at the
proof-of-concept level. Marsulex has declined to provide information for this update. Contact
information for Marsulex is provided in Section 5.
53
Hamel, B., R. Rhodes, S.A. Benson, D.P. McCollor. “The role of combustion air preheater in an effective
multipollutant control strategy,” US EPA/DOE/EPRI Combined Power Plant Air Pollutant Control Mega
Symposium, Washington, D.C., 19-22 May 2003.
54
Martin, Cameron, ADA Environmental Solutions. Telephone conversation with Katherine Dombrowski. 22
October 2003.
2-25
3
EXAMPLE ECONOMICS FOR SO3 CONTROL
TECHNOLOGIES
As part of this project, cost estimates were prepared for applying a number of sulfuric acid
control technologies to a hypothetical or example power plant. The plant consists of a single,
500-MW unit located in the Midwest, and firing a 3.5% sulfur bituminous coal. The plant is
retrofitting an SCR system for NOX control, and currently has a cold-side ESP for particulate
control and a wet FGD system for SO2 control. The FGD system uses limestone reagent and
produces wallboard grade gypsum, which is sold as a byproduct. The fly ash is handled dry, and
either sold as a byproduct or disposed of in a landfill. During the “ozone season,” all of the fly
ash is typically sold.
The plant has a wall-fired, pulverized coal boiler that typically converts 1% of the coal sulfur to
SO3. The SCR catalyst guarantee is for no more than 0.75% conversion of SO2 to SO3 across the
installed catalyst layers. Figure 3-1 summarizes the assumed baseline SO3/sulfuric acid
concentrations at various locations in the flue gas path, both with and without the SCR in line.
9.5 ppm baseline

21 ppm w/SCR
Stack
SCR
53 ppm w/SCR 19 ppm baseline
31 ppm 42 ppm w/SCR Absorber
Economizer Air Heater
Outlet
ESP
25 ppm baseline ID/Booster Fans

48 ppm w/SCR
Figure 3-1
Baseline and Post-SCR SO3/Sulfuric Acid Concentrations for Hypothetical Plant
3-1
Example Economics for SO3 Control Technologies
The concentrations in the figure assume approximately 6 ppmv of SO3/sulfuric acid removal
each across both the air heater and ESP and 50% removal of sulfuric acid mist across the FGD
absorber, for both cases. The 6-ppmv removals across the air heater and ESP correspond with
about 20% removal across each device under baseline (pre-SCR) operation, which is consistent
with the averages for the field CCS data summarized in Appendix B of this report. It was
assumed that the removal mechanism across these devices is adsorption on fly ash, and that the
amount adsorbed is more a function of fly ash surface area than SO3 concentration. With these
assumptions, a similar quantity of SO3 should be adsorbed whether the SCR is in service or not.
The removal across the FGD absorber was assumed to be by physical collection, so the removal
percentage was assumed to be independent of sulfuric acid mist concentration. The 50% removal
percentage is also consistent with the average for the field CCS data reported in Appendix B.
The objective of applying controls would be to restore the stack sulfuric acid concentration to the
pre-SCR value of 9.5 ppmv (dry basis) from the projected value of 21 ppmv with the SCR in
service. A sensitivity case also looks at costs for achieving a higher level of SO3 control, down to
3 ppmv (dry basis) or less at the stack. This lower concentration should be adequate to result in a
clear stack, or low stack plume opacity (at least due to the sulfuric acid mist contribution to
plume opacity) under most conditions. The SCR is assumed to operate only during the “ozone
season,” from May 1 through September 30, and it was assumed the sulfuric acid controls will
only be required to operate during that time period as well. Other sensitivity cases consider both
a new and retrofit plant installation where the SCR and SO3 controls operate year-round.
A number of potential sulfuric acid controls were considered for this hypothetical plant. The
technologies include:
• Fuel switching/blending with low sulfur coal;
• Fuel additive (OmniClearTM);
• Furnace injection of byproduct magnesium hydroxide slurry (byproduct Mg);
• Furnace injection of commercial magnesium hydroxide slurry (commercial Mg);
• MgO powder (Utilimag 40) injection between the SCR and air heater;
• SBS solution injection between the SCR and air heater (higher SO3/sulfuric acid removal
percentage) or between the air heater and ESP (lower removal percentage);
• Ammonia injection between the air heater and ESP;
• Dry hydrated lime powder injection between the air heater and ESP (lower SO3/sulfuric acid
removal percentage), or injection of a dry hydrated lime/sodium bicarbonate powder blend
(higher removal percentage);
• Flue gas humidification with hydrated lime powder injection between the air heater and ESP;
and
• Wet ESP retrofit, either as a last field conversion of the existing dry ESP (lower SO3/sulfuric
acid removal percentage) or between the FGD absorber outlet and stack (higher removal
percentage).
3-2
Figure 3-2 illustrates the gas path for the plant and indicates where in the gas path these
candidate SO3/sulfuric acid control technologies would be installed. Note that for the lower
removal percentage target, the SBS injection process was assumed to be installed between the air
heater and ESP, and the wet ESP was assumed to be implemented as a last field conversion of
the existing ESP. For the higher removal percentage target, the SBS injection process would be
installed between the SCR and air heater, and the wet ESP would be implemented as a retrofit
between the FGD absorber and stack.
- Byproduct
Mg Injection
- Commercial To
Mg Injection Wet ESP Stack
SCR
- Fuel - MgO Injection
Switch Wet ESP
- SBS Injection
- Fuel Air Heater conversion
Economizer
Additive
Outlet
ESP
FGD Absorber
- SBS Injection
ID/Booster Fans
- Hydrated Lime Injection
- Ammonia Injection
- Humidification with Alkali Injection
Figure 3-2
Illustration of Potential SO3/Sulfuric Acid Control Options
As a first step in developing cost estimates for the various potential sulfuric acid controls, heat
(enthalpy) and material balance calculations were conducted to estimate the expected SO3/
sulfuric acid control performance of each technology, and to estimate reagent and utility
consumption rates. Table 3-1 summarizes, in general, the sources of performance information for
each technology used as the basis for these estimates and the operating cost considerations for
each. To be able to conduct heat and material balance calculations, a number of assumptions had
to be made about existing plant conditions such as unit capacity factor and coal composition.
These assumptions are summarized in Table 3-2.
Results and Discussion
Heat and Material Balance Estimate Results

Table 3-3 summarizes the projected SO3 removal performance of each technology with the SCR
operating, and Table 3-4 summarizes the bases used for estimating reagent and other
consumables quantities for achieving these SO3 removal levels. Table 3-5 summarizes the
corresponding heat and material balance results. Table 3-3 and Table 3-5 represent predicted
results only for the lower sulfuric acid removal percentage target, to restore the stack sulfuric
acid concentration to the pre-SCR value. Table 3-4 shows performance estimate bases for both
removal percentage targets.
3-3
Table 3-1
Summary of SO3 Control Technology Performance Data Sources, and Reagents and Utilities Required
Furnace Ammonia Humidification Hydrated Lime

Injection of Injection and Lime Injection
Byproduct or MgO Injection Between Air Injection Between Air
Fuel Commercial Downstream Heater and Between Air Heater and
Switch/Blend Fuel Additive Mg of SCR SBS Injection ESP Heater and ESP ESP Wet ESP
Performance Material balance Omni Materials EPRI/DOE data Vendor data Vendor/EPRI Vendor/EPRI EPRI ECTC data EPRI ECTC EPRI
Data Source calculations literature data data data (Chemstar data/vendor
Lime) contacts
TM
Reagent Reduced FGD OmniClear Byproduct or MgO powder Sodium Ammonia Hydrated lime Hydrated lime FGD
2
Used limestone reagent Commercial Mg sulfite/bisulfite from SCR powder powder limestone
consumption slurry solution, FGD system
1
limestone
Plant Water None None Dilution of None Diluting None Flue gas None Washing
Use commercial concentrated humidification ESP
slurry solution plates/tubes
(softened water)
Compressed None Pneumatic Atomization air Pneumatic Atomization air Pneumatic Atomization air, Pneumatic None
Air Use conveying air conveying air conveying air pneumatic conveying air
conveying air
Major Power None Truck Air Air blower Air Air blower, Air compressors, Air blower T/R set
Consumers unloading air compressors, compressors, heater pumps, air input power
blower pumps pumps blower
Waste Potentially CaSO4 and MgSO4, mixed MgSO4, mixed Na2SO4, mixed (NH4)2SO4, CaSO4, excess CaSO4, excess CaSO4,
Disposal/ reduced fly ash MgSO4, mixed with fly ash with fly ash with fly ash; NH4HSO4, lime mixed with lime mixed with increased
Byproduct production; with fly ash CaSO4 mixed with fly fly ash fly ash FGD
Stream reduced FGD (increased FGD ash gypsum
2
gypsum gypsum production
1
production production)
3-4
Table 3-1 (continued)
Ammonia Humidification Hydrated Lime

Furnace Injection and Lime Injection
Furnace Injection of MgO Injection Between Air Injection Between Air
Fuel Injection of Commercial Downstream Heater and Between Air Heater and
Switch/Blend Byproduct Mg Mg of SCR SBS Injection ESP Heater and ESP ESP Wet ESP
Boiler Increase due to Increase due Decrease due Increase due Decrease due to None None None None
Efficiency lowered SO3 to SO3 removal to water to SO3 removal water
Impacts concentration upstream of air evaporated in upstream of air evaporated
upstream of air heater furnace, heater upstream of air
heater increase due to heater, increase
SO3 removal due to SO3
upstream of air removal
heater upstream of air
heater (only
when injecting
upstream of air
heater)
SO2 Reduced SO2 None None None None None None None None
Allowance emissions due to
Impacts lower coal sulfur
NOX None were None were None were None None None None None None
Removal evaluated evaluated evaluated
Impacts
1
The reaction of SBS or sodium sulfite to remove SO3 and form sodium sulfate releases an equal molar amount of SO2 into the flue gas, that must be scrubbed in
the FGD absorber.
2
Sulfuric acid collected will end up in the FGD liquor, requiring additional FGD limestone for neutralization.
3-5
Table 3-2
Assumptions Made for Heat and Material Balances for Model Plant
Parameter Value
Unit Load (gross MW) 500
Gross Plant Heat Rate (Btu/hr/KW ) [kcal/hr/KW] 9200 [2320]
Capacity Factor (%) 85
Flue Gas Flow Rate (acfm at economizer outlet) 2.07 x 106 [3.52 x 106]
[actual m3/hr]
Coal Sulfur Content (%) 3.5
Flue Gas SO2 Content (ppmv wet at economizer 2790

outlet)
Furnace Conversion of SO2 to SO3 (mole %) 1.0
Conversion of SO2 to SO3 Across SCR Catalyst 0.75

(mole %)
NOx Season Duration (months/yr) 5
Target Stack Sulfuric Acid Concentration (ppmv, dry basis):
For lower SO3 removal percentage target 9.5 (return to pre-SCR conditions)
For higher SO3 removal percentage target 3.0 (assumed value corresponding to “clear” stack)
3-6
Table 3-3
Summary of SO3 Control Performance Estimates for Lower Percentage Control Target (return to pre-SCR stack sulfuric acid
concentrations)
Furnace Hydrated
Injection of SBS Ammonia Humidification Lime
Omni- Byproduct MgO Injection Injection & Lime Injection
TM
Fuel Clear or Injection Between Air Between Injection Between
Switch/ Fuel Commercial Downstream Heater & Air Heater Between Air Air Heater
Blend Additive Mg of SCR ESP & ESP Heater & ESP & ESP Wet ESP
Stack Sulfuric Acid 9.5 9.5 9.5 9.5 9.5 - 9.5 9.5 9.5
Concentration
(ppmv)
SO3/Sulfuric Acid - 55 75 55 55 - 55 55 55
Removal at Point of
Implementation (%)
Sulfuric Acid - 4.0 3.2 4.0 3.6 - 3.6 3.6 1.6

Removal Rate, lb-
mole/hr
Note: 1 lb-mole/hr = 454 g-mole/hr
3-7
Table 3-4
Summary of Bases for Consumables Quantity Estimates for Candidate SO3/Sulfuric Acid Control Technologies
Bases for Consumables Quantity Estimates
Technology 9.5 ppmv at Stack 3.0 ppmv at Stack
Fuel Blending 32% low-sulfur (0.5 wt%) coal 87% low-sulfur (0.5 wt%) coal
OmniClearTM Fuel Additive Additive added to coal at 0.5 wt% dosage Additive added to coal at 1.0 wt% dosage
(equivalent to 4:1 (Ca+Mg):SO3 mole ratio) (equivalent to 8:1 (Ca+Mg):SO3 mole ratio)
Byproduct or Commercial Mg(OH)2 Injection in 3.6:1 Mg:SO3 mole ratio (based on SCR 7.5:1 Mg:SO3 mole ratio (based on SCR
Furnace outlet) outlet) plus hydrated lime injection at 1.8
lb/hr/kacfm
MgO Powder Injection Upstream of Air Heater 2.0 moles Mg injected per mole SO3 removed 2.5 moles Mg injected per mole SO3 removed
SBS InjectionTM Upstream of Air Heater 1.0 moles Na injected per mole SO3 removed 1.8 moles Na injected per mole SO3 removed
NH3 Injection Upstream of ESP Not estimated at lower removal percentage 2.0 moles NH3 injected per mole SO3
removed
Humidification/Lime Injection Upstream of ESP Humidification to 293oF (145oC), hydrated Humidification to 275oF (135oC), hydrated
lime injection at 0.5 lb/hr per kacfm lime injection at 1 lb/hr per kacfm (equivalent
(equivalent to 1.7:1 Ca:SO3 mole ratio) to 3.4:1 Ca:SO3 mole ratio)
Hydrated Lime Injection Upstream of ESP Hydrated lime injection at 1.3 lb/hr per kacfm 80% hydrated lime/20% sodium bicarbonate
(equivalent to 4.5:1 Ca:SO3mole ratio) blend injection at 3.4 lb/hr per kacfm
(equivalent to 11:1 (Ca+Na):SO3 mole ratio)
Wet ESP Electric power at 320 W/kacfm, water at 0.25 Electric power at 320 W/kacfm, water at 0.25
gal/kacf, last field conversion of dry ESP gal/kacf, new wet ESP between wet FGD and
stack
3-8
Table 3-5
Summary of SO3 Control Technology Heat and Material Balances for Lower Control Percentage Target (return to pre-SCR stack
sulfuric acid concentration, operating 5 months /year)
SBS Ammonia Humidifi- Hydrated

Furnace Furnace MgO Injection Injection cation & Lime
Omni- Injection Injection Injection Between Between Lime Injection
TM
Fuel Clear of By- of Down- Air Air Injection Between
Switch/ Fuel product Commer- stream Heater & Heater & Between Air Air Heater Wet
Blend Additive Mg cial Mg of SCR ESP ESP Heater & ESP & ESP ESP
Percent Low Sulfur Coal Fired 32 - - - - - - - - -

(heat input basis)
Reagent Used (lbs/hr, [gpm]) - 1900 [15] [5] 330 230 - 820 2200 190
Reagent Used (tons/yr)1 -16,000 3000 13,000 2400 510 350 - 1300 3400 300
Plant Water Use (gpm) 0 0 0 2 0 5 - 24 0 600
Compressed Air Use (scfm) 0 0 240 90 0 110 - 520 0 0
Pneumatic Air Use (scfm) 0 3800 0 0 2000 0 - 4800 13,000 0
Add’l Fly Ash Mass (tons/yr) -3400 3200 2600 1700 1100 490 - 1600 3700 0
Add’l Gypsum Produced -30,000 0 0 0 0 960 - 0 0 460

(tons/yr)
Additional SO2 Allowances 420 0 - - - - - - - -

(tons/yr)
Net Boiler Efficiency 0.3 0.3 0.1 0.2 0.3 0 - 0 0 0

Improvement (%)2
Increase in ESP Inlet Mass -7.7 7.4 4.6 2.5 2.6 1.1 - 3.7 8.5 -
Loading (%)
1
Includes weight of water and impurities shipped with slurry reagents.
2
Boiler efficiency improvement is based on avoiding the need to raise the air heater outlet temperature with the SCR operating due to the elevation of the flue
gas acid dew point at higher SO3 concentrations.
Note: 1 gpm = 3.8 l/min, 1 lb/hr = 0.45kg/hr, 1 ton/yr = 0.91metric ton/yr, 1 scfm = 1.6 Nm3/hr.
3-9
The results in Table 3-5 include rates for reagent consumption, usage of plant water, compressed air for
dual-fluid nozzle atomization and for pneumatic transport, and increased waste disposal/fly ash sales
quantities. For the fuel switch case, the table shows the percentage of the boiler heat input that would have
to be supplied by low-sulfur coal (assumed to be Powder River Basin coal) to achieve the stack sulfuric
acid concentration target. Also for this case, the table indicates the additional SO2 allowances that would
result (assuming constant percent SO2 removal across the FGD system but a lower inlet SO2), and the
corresponding decrease in the amount of gypsum byproduct. This could be a factor if a plant is under
contract to supply gypsum to a wallboard plant and has a minimum contract amount to supply annually.
Two other rows of information are included in the table. One is an estimated net boiler efficiency
improvement for technologies that remove SO3 upstream of the air heater. Flue gas acid dew
point elevation due to the higher SO3 concentrations downstream of an SCR system would likely
require the air heater exit flue gas temperature to be increased to avoid corresponding increases
in acid deposition and/or cold-end corrosion. Technologies that remove SO3 upstream of the air
heater could allow this air heater outlet temperature elevation to be avoided, with an associated
benefit to the plant heat rate. A factor of 1% improvement in plant efficiency per 40oF (22oC) of
avoided increase in air heater outlet temperature was used to quantify this benefit. In calculating
the benefit, it was assumed that the plant air heater outlet flue gas temperature would not be
lowered below the current (pre-SCR) value due to heat transfer area limitations. Consequently,
no additional benefit was included for technologies that might be able to lower the air heater inlet
SO3 concentration below pre-SCR values.
When figuring the cost benefits of avoiding this potential boiler efficiency loss later in this
section, the net benefit had to also consider heat rate penalties associated with technologies that
inject water-containing slurries or solutions upstream of the air heater. The injected water enters
the furnace or economizer outlet gas as a liquid at ambient temperature, and leaves after heat
recovery in the air heater as vapor at approximately 300oF (150oC). The enthalpy increase for
this water comes at the expense of increased coal firing. The efficiency improvement values
shown in Table 3-5 are net after penalties associated with this water addition, and such penalties
are included in operating cost estimates presented later in this section.
The last row of the table shows the estimated increase in particulate loading to the ESP, for the
technologies that involve SO3 or sulfuric acid removal upstream of the ESP. This provides an indicator
of the potential impacts of the technology on ESP operation and particulate emissions compliance.
As can be seen in Table 3-5, one technology was not estimated for the lower SO3 removal
percentage. Ammonia injection can cause operating problems if controlled to lower removal
percentages. If ammonia is added at sub-stoichiometric rates, so as to achieve only the 55% sulfuric
acid removal required to meet the lower removal percentage target, the byproduct would all be
ammonium bisulfate (NH4HSO4). Ammonium bisulfate is a sticky and corrosive solid that would likely
cause ESP operating and maintenance problems. Instead, ammonia would typically be added at higher
NH3:H2SO4 mole ratios, in the range of 1.5 to 2.0, so as to form predominantly ammonium sulfate
[(NH4)2SO4] which is less sticky and less corrosive. When injected at these mole ratios, 90 to 95%
sulfuric acid removal would be expected.
Similar heat and material balance calculations were made for the higher sulfuric acid control
percentage target, down to 3 ppmv or less in the stack flue gas. Table 3-6 summarizes the
3-10
SO3/sulfuric acid removal performance of each technology for the higher sulfuric acid removal
percentage target and Table 3-7 summarizes the corresponding heat and material balance results.
The form of these tables is similar to Table 3-3 and Table 3-4, respectively. Two technologies,
byproduct Mg injection and commercial Mg injection in the furnace, were not estimated to be
able to achieve the higher sulfuric acid removal percentage (down to 3 ppmv at the stack)
independently. A second technology would have to be installed downstream to achieve the
higher overall removal target. Two U.S. power plants have operated or are planning to operate
with a combination of Mg injection in the furnace and hydrated lime injection between the air
heater and ESP to achieve relatively high overall SO3/sulfuric acid control efficiencies when
operating an SCR.55 Consequently, this combination of control technologies was included for
economic evaluation for the higher removal percentage case.
Based on the heat and material balance results shown in Table 3-7, three technologies may not be
viable for some plants at the higher removal percentage target, because of the large sorbent
quantities estimated for injection to achieve 3 ppmv at the stack. These technologies include the
two furnace Mg injection technologies combined with downstream injection of hydrated lime,
and duct injection of a hydrated lime/sodium bicarbonate blend. These technologies or
technology combinations were estimated to increase the mass loading to the ESP by 17 to 21%.
At these injection rates, it is possible that a small or moderately size ESP would not be able to
maintain particulate emissions compliance because of the inlet mass loading increase. For
furnace injection of magnesium hydroxide combined with hydrated lime injection, increased
particle resistivity may also limit the performance of smaller ESPs under these conditions.
Also, for reasons described previously in this section, the SBS injection, ammonia injection and wet ESP
options were evaluated at 90 to 91% sulfuric acid removal even though material balances indicated a
slightly lower percentage was needed to achieve the 3 ppmv sulfuric acid target. For these technologies
the estimated stack sulfuric acid concentration was between 2 and 3 ppmv (dry basis).
Capital Cost Estimates

The performance estimates and heat and material balances discussed above formed the basis for
capital cost estimates for eight of the ten technologies under consideration:
• OmniClearTM fuel additive,
• Byproduct Mg injection in the furnace,
• Commercial Mg injection in the furnace,
• MgO powder injection downstream of the SCR,
• SBS solution injection downstream of the SCR, or between the air heater and ESP,
• Ammonia injection between the air heater and ESP,
• Flue gas humidification with hydrated lime injection between the air heater and ESP, and
• Hydrated lime powder or hydrated lime/sodium bicarbonate blend injection between the air
heater and ESP.
55
3-11
Table 3-6
Summary of SO3 Control Performance Estimates for Higher Percentage Control Target (3 ppmv at stack with SCR in Service)
Furnace Hydrated
Injection of Lime/
Byproduct Sodium
or Bicarbonate
Commercial Ammonia Humidification Blend
Omni- Mg/ MgO SBS Injection & Lime Injection
TM
Fuel Clear Hydrated Injection Injection Between Injection Between Air
Switch/ Fuel Lime Downstream Downstream Air Heater Between Air Heater &
Blend Additive Injection of SCR of SCR & ESP Heater & ESP ESP Wet ESP
Stack Sulfuric Acid 3.0 <51 7.2/3.02 3.0 2.2 2.4 3.0 3.0 2.1
Concentration
(ppmv)
SO3/Sulfuric Acid - 861 90/633 86 91 90 86 86 90

Removal at Point of
Implementation (%)
Sulfuric Acid - 6.31 5.6 6.3 6.7 5.9 5.6 5.6 2.6
Removal Rate, lb-
mole/hr
1
Company literature provides performance and cost data for reducing stack sulfuric acid concentration to a “<5 ppm level.” For the purposes of this evaluation, it
was assumed that <5 ppm would be equivalent to the 3 ppm concentration target for the other technologies.
2
First number is the projected stack concentration with furnace Mg injection only, second number reflects hydrated lime injection between air heater and ESP in
combination with furnace Mg injection.
3
First number reflects percentage removal of furnace-formed SO3, second number reflects percentage removal of sulfuric acid in the air heater outlet flue gas.
Note: 1 lb-mole/hr = 454 g-mole/hr
3-12
Table 3-7
Summary of SO3 Control Technology Heat and Material Balances for Higher Percentage Control Target (3 ppmv at stack with
SCR in service, operating 5 months /year)
Furnace Furnace Humidifi- Hydrated

Injection Injection cation & Lime/
of of Ammonia Lime Sodium
Byproduct Commer- MgO SBS Injection Injection Bicarb.
Omni- Mg/ cial Mg/ Injection Injection Between Between Blend
TM
Fuel Clear Hydrated Hydrated Down- Down- Air Air Injection
Switch/ Fuel Lime Lime stream stream Heater & Heater & Between Wet
Blend Additive Injection Injection of SCR of SCR ESP ESP AH & ESP ESP
Percent Low Sulfur Coal Fired (heat 87 - - - - - - - - -

input basis)
Reagent Used (lbs/hr, [gpm]) - 3800 [30] + 3000 [11] + 3000 640 750 180 1600 5700 310
Reagent Used (tons/yr)1 -51,000 6000 26,000 + 4900 + 990 1160 280 2500 8800 490
4600 4600
Plant Water Use (gpm) - - 0 4 - 15 - 62 - 330
Compressed Air Use (scfm) - - 490 190 - 370 - 1400 - -
Pneumatic Air Use (scfm) - 7700 18,000 18,000 3900 - 1300 9900 33,000 -
Waste Disposal Mass (tons/yr) -11,000 6200 9800 8000 2000 1500 45,0003 3100 9400 -
Additional Gypsum Produced (tons/yr) -99,000 - - - - 1800 0 0 0 750
Additional SO2 Allowances (tons/yr) 1400 - 0 0 0 0 0 0 0 -
Net Boiler Efficiency Improvement (%)2 0.3 0.3 0.3 0.3 0.3 0.1 0 0 0 -
Increase in ESP Inlet Mass Loading (%) -26 14 21 17 4.7 3.4 2.7 7.1 21 -
1
Includes weight of water and impurities shipped with slurry reagents.
2
Efficiency improvement based on avoiding need to raise air heater outlet temperature with the SCR operating due to elevated flue gas acid dew point.
3
Represents loss of fly ash sales of 100% of fly ash production.
Note: 1 gpm = 3.8 l/min, 1 lb/hr = 0.45kg/hr, 1 ton/yr = 0.91 metric ton/yr, 1 scfm = 1.6 Nm3/hr.
3-13
Capital cost estimates were also developed for the wet ESP cases but based solely on general
budgetary cost factors. For the wet ESP, a cost factor of $35/kW was used for a last-field dry
ESP conversion for the lower SO3 removal case, and a factor of $55/kW for standalone wet ESP
retrofit downstream of the wet FGD absorber for the higher removal percentage. The capital
costs for a wet ESP retrofit can be very site specific, depending on the difficulty of the retrofit
and materials of construction selection, and could vary by ±50% or greater from these estimates
for a specific circumstance.
No capital costs were estimated for fuel switching. Again, the capital cost requirements for this
technology can be very site specific. Some plants may be able to blend low sulfur coals with
little or no capital requirements, while other plants may require extensive revisions such as new
coal blending conveyors, increased mill capacity, soot blower upgrades, and/or unit de-rating.
For the eight technologies listed above, the heat and material balance results were used to
develop budgetary capital cost estimates. The approach taken was to identify major equipment
such as silos, tanks, pumps, and air compressors, and estimate their size based on the material
balance calculation results. Storage silos or tanks were generally sized for 15-day storage at full
load, and at the corresponding SO3/sulfuric acid removal target. Most technologies were also
assumed to have a day tank or silo near the unit, sized for 24 hours of capacity at full load for the
SO3/sulfuric acid removal target being evaluated. Pumps, blowers, and air compressors were also
sized based on the material balance results for full load operation. Once sized, the major
equipment purchase costs were estimated based on recent data for purchases, or quotations from
URS project and proposal files.
Spreadsheets were then used to develop an overall project cost estimate. Piping costs were based
on estimated piping run lengths and standardized per-foot cost estimates for each pipe size and
material (carbon steel or 300-series stainless steel). Instrumentation requirements were based on
typical process flow diagrams for each technology. Other items such as motor controls and
valves were estimated from the number of major equipment items and piping requirements.
Standard factors were used for developing estimates for process design, detailed design and
procurement, installation labor, construction management, commissioning, startup and training,
etc. Labor rates were based on union labor in the Midwest.
An estimate of this type is typically regarded as having an accuracy of ±25%. However, for these
particular estimates, the accuracy is more likely in the range of ±30 to 50% for a variety of
reasons, including:
• Major equipment item costs were interpolated based on previous cost data rather than
soliciting vendor quotes for each specific equipment item;
• Assumptions were made regarding redundancy, instrumentation requirements and control
approach that might change during a detailed design effort; and
• The exact placement of and the retrofit difficulty for each equipment item could not be
determined given that the plant represents a hypothetical case.
3-14
This level of accuracy should be adequate for comparing the cost-effectiveness of candidate
control technologies though, particularly considering that the uncertainties listed above should
apply to each of the technology options.
Table 3-8 summarizes the capital cost estimates for the lower SO3/sulfuric acid removal
percentage target of returning the stack sulfuric acid concentration to pre-SCR levels. Table 3-9
summarizes the capital cost estimates for achieving the higher SO3/sulfuric acid removal
percentage target. The following paragraphs describe salient features of each of the estimates.
OmniClearTM Fuel Additive. For the OmniClear additive, the vendor provided cost factors of
$1.3/kW for the lower removal percentage case and $2.0/kW for estimating capital costs.56
However, to ensure that this technology was compared on an equitable basis with other
technologies, the capital costs were estimated using the same spreadsheets. This ensured that the
same assumptions were applied for days of reagent storage on site, engineering and labor rates,
project scope, contingencies, overheads, etc. The fuel additive injection system was assumed to
include a truck unloading station, a 15-day pneumatic storage silo with dust collector, and
gravimetric feeder. The additive would be dosed onto the coal belt at the appropriate rate on an
intermittent basis, only during the periods when coal is being fed to the bunkers on the unit.
Additional measures may also be required to avoid fugitive dust emissions from the coal belt
after the addition of the 75% minus 200 mesh OmniClearTM additive, but such measures were not
included in the capital cost estimate spreadsheet. The resulting capital cost estimates were higher
than would calculated from the vendor supplied factors, at approximately $2.4/kW for the lower
removal percentage case and $2.8/kW for the higher removal percentage.
Byproduct or Commercial Mg Injection in the Furnace. Byproduct Mg slurry would be received

in truckload quantities and stored in a 320,000-gallon (1200-m3) storage tank. Due to the large
size of this tank and the assumed proximity of the model plant to the byproduct Mg source, the
same tank size was assumed for both removal percentage cases. This lowers the effective days of
storage to 7 for the higher removal case compared to 15 for the lower removal. For either case, a
day tank closer to the unit would be sized for 24 hours’ usage of the byproduct slurry.
56
3-15
Table 3-8
Summary of SO3 Control Technology Capital Cost Estimates for the Lower Sulfuric Acid Removal Percentage Target – All Values
in $1000
SBS Humidifica- Hydrated

Injection Ammonia tion & Lime Lime Wet ESP
Omni- Furnace Furnace MgO Between Injection Injection Injection Between
TM
Fuel Clear Injection of Injection of Injection Air Between Between Air Between FGD
Switch/ Fuel Byproduct Commercial Downstream Heater & Air Heater Heater & Air Heater Absorber
Blend Additive Mg Mg of SCR ESP & ESP ESP & ESP & Stack
Procurement and Construction:
Material - 490 1,120 770 1,130 800 - 1,540 1,820 -
Labor - 260 570 560 760 710 - 1,140 1,000 -
Total Material - 750 1,690 1,330 1,890 1,510 - 2,680 2,820 -

and Labor
Process Design - 50 100 80 110 90 - 160 170 -

and Project
Management
Detailed Design - 120 270 210 300 240 - 430 450 -

& Procurement
Construction - 30 100 100 100 100 - 100 100 -

Management
Commissioning, - 10 20 20 20 20 - 20 20 -
Startup, and
Operator
Training
Subtotal - 960 2,180 1,740 2,420 1,960 - 3,390 3,560 -
3-16
SBS Humidifica- Hydrated

Injection Ammonia tion & Lime Lime Wet ESP
Omni- Furnace Furnace MgO Between Injection Injection Injection Between
TM
Fuel Clear Injection of Injection of Injection Air Between Between Between FGD
Switch/ Fuel Byproduct Commercial Downstream Heater & Air Heater Air Heater Air Heater Absorber
Blend Additive Mg Mg of SCR ESP & ESP & ESP & ESP & Stack
Project Fee - 140 340 270 370 690 - 510 530 -
Project Cost with - 1,100 2,520 2,010 2,790 2,650 - 3,900 4,090 -
Fee
Contingency - 110 250 200 280 270 - 390 410 -
Total Estimated - 1,210 2,770 2,210 3,070 2,920 - 4,290 4,500 17,500
Project Cost
3-17
Table 3-9
Summary of SO3 Control Technology Capital Cost Estimates for the Higher Sulfuric Acid Removal Percentage Target – All
Values in $1000
Furnace Hydrated
Injection Furnace Lime/
of Injection of Ammonia Humidifica- Sodium
Byproduct Commercial Injection tion & Lime Bicarb. Wet ESP
Omni- Mg + Mg + MgO SBS Between Injection Blend Between
TM
Fuel Clear Hydrated Hydrated Injection Injection Air Between Injection FGD
Switch/ Fuel Lime Lime Downstream Downstream Heater & Air Heater Between Absorber
Blend Additive Injection Injection of SCR of SCR ESP & ESP AH & ESP & Stack
Procurement and Construction:
Material - 600 3,090 2,760 1,190 1020 520 1,770 2,320 -
Labor - 260 1,580 1,560 770 730 380 1,140 1,010 -
Total Material - 860 4,670 4,320 1,960 1,750 900 2,920 3,330 -
and Labor
Process Design - 50 290 270 120 100 50 180 200 -

and Project
Management
Detailed Design - 140 740 690 310 280 150 470 535 -
& Procurement
Construction - 30 100 100 100 100 100 100 100 -

Management
Commissioning, - 10 20 20 20 20 20 20 20 -
Startup, and
Operator
Training
Subtotal - 1,090 5,820 5,400 2,510 2,250 1,220 3,680 4,190 -
3-18
Furnace Hydrated
Injection Furnace Lime/
of Injection of Ammonia Humidifica- Sodium
Byproduct Commercial Injection tion & Lime Bicarb. Wet ESP
Omni- Mg + Mg + MgO Between Injection Blend Between
TM
Fuel Clear Hydrated Hydrated Injection SBS Injection Air Between Injection FGD
Switch/ Fuel Lime Lime Downstream Downstream Heater & Air Heater Between Absorber
Blend Additive Injection Injection of SCR of SCR ESP & ESP AH & ESP & Stack
Project Fee - 160 870 810 380 790 180 550 630 -
Project Cost - 1,250 6,690 6,210 2,890 3,040 1,400 4,230 4,820 -
with Fee
Contingency - 130 670 620 290 300 140 420 480 -
Total - 1,380 7,360 6,830 3,180 3,340 1,540 4,650 5,300 27,500
Estimated
Project Cost
3-19
For commercial Mg, the storage tank would be much smaller, at 50,000 gallons (160 m3) for the
lower removal percentage target and 100,000 gallons (320 m3) for the higher removal target.
Provisions were included to dilute the concentrated slurry from 58 wt% in the storage tank to
about 30 wt% for injection, just prior to pumping makeup slurry to the day tank.
For both technologies, it was assumed that the injection lances would be installed through
existing view port openings in the furnace walls; no waterwall modifications were included. It is
possible that the removal efficiency and/or reagent utilization for the two furnace injection
technologies could be improved by computational fluid dynamics (CFD) modeling to optimize
injection locations. However, such improvements would come with additional costs to conduct
the CFD model study and the costs (and potentially increased boiler outage time) associated with
adding new waterwall penetrations.
Neither of the furnace Mg injection technologies were estimated to be able to achieve the 3 ppmv
sulfuric acid target with the SCR in service. Consequently, the capital costs shown for these
technologies in Table 3-9 include costs for a downstream hydrated lime powder injection system.
MgO Injection. The estimate is based on truck unloading of MgO powder into a storage silo.
Adjacent to the unit would be a 24-hr day silo and pneumatic injection equipment for each of
two duct runs.
SBS Injection. The estimate is based on truck unloading of sodium sulfite powder, wetting it to
form a solution, and pumping the concentrated solution to a storage tank. From the storage tank
the concentrated solution would be diluted with water and pumped to nozzle arrays on each of
two duct runs on the unit. A dedicated compressor, with spare, would provide atomizing air to
the nozzles.
Ammonia Injection. Ammonia would be supplied by the existing ammonia feed system for the
SCR, which assumes that system has adequate capacity. Anhydrous ammonia would be mixed
with pre-heated air, then pneumatically conveyed into the two duct runs via injection grids.
Humidification with Lime Injection. The humidification water would be plant water, fed through
a booster pump and fine particle filter. Atomizing air would be provided by a dedicated
compressor and spare. Hydrated lime would be received by truck or rail and stored in a large
silo. A day silo near the unit would be equipped with a weigh belt to meter the solids to each air
heater outlet duct and a pneumatic air blower, with spare, to inject the powder.
Hydrated Lime Powder Injection. Hydrated lime would be received by truck or rail and stored in
a large silo. A day silo near the unit would be equipped with a weigh belt to meter the solids to
each air heater outlet duct and a pneumatic air blower, with spare, to inject the powder.
For the higher sulfuric acid removal percentage case, it was assumed that a blend of
approximately 80% hydrated lime and 20% sodium bicarbonate powder would be injected so as
to minimize adverse effects on the resistivity of the fly ash/sorbent mixture collected in the ESP.
For the capital equipment, it was assumed that hydrated lime and sodium bicarbonate would be
received in truckload quantities and stored separately in bulk pneumatic silos. The two reagents
would be blended in the appropriate ratio as the day silo is filled. From the day silo forward, the
system be identical to the system for injecting hydrated lime only.
3-20
Capital cost estimates are also shown in Table 3-8 and Table 3-9 for wet ESP technology based
on general installed cost factors provided by system vendors. The following describes the
assumptions associated with these capital cost estimates.
Wet ESP. The capital cost factor of $35/kW for the lower removal percentage case is based on a
last-field conversion of the existing dry ESP, and using 316 alloy. The factor of $55/kW for the
higher removal percentage assumes the addition of a new wet ESP downstream of the wet FGD
absorber, and the use of duplex stainless steel alloy. A conservative estimate based on the use of
the higher alloy was employed because the wet ESP would be situated downstream of the wet
scrubber and chloride-containing FGD liquor could be carried up into the acidic environment.
Summary of Operating and Capital Cost Estimates for Control Technologies
The reagent and utility consumption estimates from Table 3-5 and Table 3-7, and the amortized
capital cost estimates from Table 3-8 and Table 3-9 were combined to generate annual cost
estimates for each of the technologies. These estimates were not “levelized” to reflect escalation
and discount rates, but instead represent first-year costs. Nor do they include operating labor, or
maintenance labor and materials. For most of the technologies, there is not a good experience
basis for estimating these values, so such an estimate would be based on a percentage of capital,
reagent, and/or utility costs, and would not help differentiate the projected costs of technologies.
Table 3-10 summarizes the operating and capital costs for each technology for returning the
stack sulfuric acid concentration to pre-SCR values. Table 3-11 shows the operating and capital
costs for each technology for the higher sulfuric acid removal percentage target of 3 ppmv or less
at the stack. The reagent and utility consumption values in the two tables are based on operating
the technologies at the target SO3 control level from May 1 to September 30 each year (the ozone
season). Note that for all cases except ammonia injection and wet ESP, it was assumed that the
control technology would not adversely affect fly ash sales. Thus, for all of the sorbent injection
technologies other than ammonia injection, the additional mass of solids collected in the ESP
during sorbent injection actually results in a credit for increased fly ash sales. Whether or not the
addition of the calcium-, magnesium-, or sodium-based salts to the fly ash would impact fly ash
sales would need to be determined on a site-specific basis.
The cost estimates are also summarized in Figure 3-3 for the lower removal target and Figure 3-4
for the higher removal targets. The cost estimate for ammonia injection is included in Figure 3-3,
even though it was estimated for achieving the higher removal percentage target only.
3-21
Table 3-10
Summary of SO3 Control Technology First-year Reagent and Utility Cost Estimates for the Lower Target Sulfuric Acid Removal
Percentage (return to pre-SCR stack concentrations, operation 5 months per year) – All Values in $1000
Humidifi-
cation Hydrated
SBS Ammonia and Lime Lime
MgO Injection Injection Injection Injection
Omni- Furnace Furnace Injection Between Between Between Between
TM
Fuel Clear Injection of Injection of Down- Air Air Air Air Last Field
Switch/ Fuel Byproduct Commercial stream of Heater Heater Heater Heater Wet ESP
Blend Additive Mg Mg SCR and ESP and ESP and ESP and ESP Conversion
Reagent Cost (122) 297 137 288 203 110 - 95 254 2

(Savings)
Reagent Shipping (included) (included) 76 172 37 (included) - (included) (included) (included)
Technology License - - - - - 100 - - - -

Fee
Plant Water - - - - - 2 - 2 - 44
Auxiliary Power - 24 6 2 12 3 - 43 81 76
Fuel Cost (Savings) 847 (39) (12) (31) (41) - - - - -
SO2 Allowance Credit 62 - - - - - - - -
Waste Disposal Cost 159 (9) (8) (5) (3) (6) - (5) (11) (2)
(Ash/Gypsum Value)
Total Net Non-labor 822 273 199 426 207 209 - 135 324 120
Operating Cost
Capital Recovery - 182 415 332 460 438 - 644 675 2625
Cost
Total Annual 822 455 614 758 667 647 - 779 999 2,745
Operating and (operating
Capital Cost cost only)
3-22
Table 3-11
Summary of SO3 Control Technology First-year Reagent and Utility Cost Estimates for the Higher Target Sulfuric Acid Removal
Percentage (3 ppmv at stack with SCR in service, operation 5 months per year) – All Values in $1000
Furnace Humidifi- Hydrated

Injection Furnace cation Lime/
of Injection of Ammonia and Lime Sodium
Byproduct Commercial MgO SBS Injection Injection Bicarb. Wet ESP
Omni- Mg + Mg + Injection Injection Between Between Injection Between
TM
Fuel Clear Hydrated Hydrated Down- Down- Air Air Between FGD
Switch/ Fuel Lime Lime stream stream Heater Heater AH and Absorber
Blend Additive Injection Injection of SCR of SCR and ESP and ESP ESP and Stack
Reagent Cost Savings) (407) 595 626 937 397 357 84 191 915 4
Reagent Shipping (included) (included) 157 354 72 (included) (included) (included) (included) (included)
Technology License - - - - - 100 - - - -

Fee
Plant Water - - - - - 7 - 5 - 24
Auxiliary Power - 47 121 114 24 9 13 93 210 42
Fuel Cost (Savings) 2,434 (41) (14) (23) (41) (11) - - - -
SO2 Allowance Credit 208 - - - - - - - - -
Waste Disposal Cost 530 (18) (29) (24) (15) (13) 310 (9) (28) (4)
(Ash/Gypsum Value)
Total Net Non-labor 2,350 583 861 1358 445 449 407 280 1097 66
Operating Cost
Capital Recovery Cost - 207 1,104 1,025 477 502 232 698 795 4,125
Total Annual 2,350 790 1,965 2,383 922 951 639 978 1,892 4,191
Operating and (operating
Capital Cost cost only)
3-23
2500
2,745
Capital Recovery
2000 Reagent and Utility Costs

Annual Cost ($1000)
1500
1000
500
0
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Figure 3-3
Summary of First-year Capital Recovery and Non-labor Operating Costs by SO3/Sulfuric
Acid Control Technology for Achieving the Lower Removal Percentage Target
2500
Capital Recovery 4,191
Reagent and Utility Costs
2000
Annual Cost ($1000)
1500
1000
500
0
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Figure 3-4
Acid Control Technology for Achieving the Higher Removal Percentage Target
3-24
The factors used to develop costs from the consumption rates summarized previously (in Table
3-5 and Table 3-7) are shown in Table 3-12. The reagent costs are based either on f.o.b quotes
from vendors and an assumed shipping distance at an average shipping cost as shown in the
table, or typical delivered costs for the Midwest. Plant water, softened water, auxiliary power,
and fuel costs are also “typical” values taken from previous economic evaluations conducted by
URS for power plants east of the Mississippi River.
Table 3-12
Factors Used to Generate Annual Reagent and Utility Costs
Factor Value Used
OmniClearTM fuel additive, 75% minus 200 mesh, delivered from Omni 100 [110]
Materials ($/ton) [$/metric ton]
Byproduct Mg(OH)2 slurry, delivered from Midwest supplier ($/dry ton of 151 [166]
pure Mg(OH)2, shipped at 18% solids, 65% purity in solids, assumed
50-mile delivery distance) [$/metric ton]
Commercial Mg(OH)2 slurry, delivered from Manistee, MI ($/dry ton 334 [367]
Mg(OH)2, shipped at 58 wt% solids, 100% purity in solids, assumed
600-mile delivery distance) [$/metric ton]
Utilimag 40 MgO powder, delivered from Manistee, MI ($/dry ton MgO, 472 [464]
assumed 600-mile delivery distance) [$/metric ton]
Sodium Sulfite, delivered from Green River, WY ($/dry ton available Na 300 [330]
as Na2SO3) [$/metric ton]
Ammonia, delivered from existing plant system ($/ton) [$/metric ton] 300 [330]
Hydrated Lime, delivered from Midwest location ($/ton) [$/metric ton] 75 [83]
Truck Transit Costs ($/ton-mile) [$/metric-ton-km] 0.12 [0.08]
Plant Water Cost ($/1000 gal) [$/m3] 0.40 [1.52]
Plant Softened Water Cost ($/1000 gal) [$/m3] 2.30 [8.72]
Plant Auxiliary Power ($/kwh) 0.032
Plant Fuel Costs ($/MM Btu) [$/106 kcal] 1.04 [0.26]
Plant Low-sulfur Fuel Cost ($/MM Btu) [$/106 kcal] 1.24 [0.31]
Gypsum Byproduct Value ($/wet ton, f.o.b. plant) [$/metric ton] 5.00 [5.50]
Fly Ash Sales Value ($/ton, f.o.b. plant) [$/metric ton] 3. 00 [3.30]
Incremental Landfill Disposal Costs ($/ ton) [$/metric ton] 4. 00 [4.40]
Annual Capital Recovery Factor 0.15
3-25
The values for gypsum byproducts, fly ash byproduct sales, and incremental landfill disposal
costs represent the nominal averages (rounded to the nearest whole dollar) for power plants with
medium- and high-sulfur-coal limestone forced oxidation FGD systems, as reported on their
2001 Form EIA-767. Capital cost recovery values are based on an annual recovery factor of 0.15,
which nominally represents an 8% discount rate and a 10-year book life.
For the lower sulfuric acid control percentage, four control options had projected reagent, utility,
and capital recovery costs in the range of $460,000 to $670,000 annually per unit (five including
ammonia injection at the higher removal level). The four include the fuel additive, furnace
injection of byproduct Mg, MgO powder injection, and SBS InjectionTM.
The differences between the projected costs of these four control options are not great relative to
the level of uncertainty for these estimates. For example, if these annual cost estimates are
assumed to have an uncertainty of ±25%, the “error bars” (not shown in Figure 3-3) for these
four (or five including ammonia injection) lower cost options would substantially overlap. This
suggests that a more detailed analysis would be required to determine the most cost effective
control option for this application.
Three other control options were estimated to be somewhat more expensive, in the range of
$760,000 to $820,000 annually. These include low-sulfur coal blending, commercial Mg
injection in the furnace, and humidification with hydrated lime injection between the air heater
and ESP. Recall that the costs for fuel blending with low-sulfur coal disregard any potential
capital modifications that may be required by the plant. Significant capital modification
requirements could make this option less attractive. Also, its ranking is based almost entirely on
an assumed value for the fuel cost differential. This cost differential could vary widely from the
assume value of $0.20/MM Btu.
The remaining technologies for which costs were developed at the lower removal percentage
include dry hydrated lime powder injection upstream of the ESP and a wet ESP retrofit to the last
field of the existing dry ESP. These two options appear to be less cost effective, with annual
costs projected at $1.0 and $2.8 million, respectively. However, the wet ESP comparison is
skewed by the assumption that the control technologies will only operate five months out of the
year, and the relatively high capital recovery factor (10-year recovery). Both of these
assumptions favor low capital cost control options such as fuel blending or sorbent injection.
This effect is further discussed below.
The estimated costs for the higher sulfuric acid removal percentage, as shown in Table 3-11 and
Figure 3-4, show ammonia injection as a potentially low cost technology, with projected first-
year costs of $640,000, followed by the OmniClearTM fuel additive at $790,000 annually. Three
other technologies, MgO powder injection, SBS injection and humidification with hydrated lime
injection, show somewhat higher annual projected costs between $920,000 and $980,000. Again,
if these annual cost estimates have an uncertainty of ±25%, the error bars for these five
technologies would overlap.
3-26
Four other technologies show considerably higher first-year operating costs of $1.9 to $2.4
million. These include fuel switching; the two furnace injection technologies, which were
combined with hydrated lime injection between the air heater and ESP for this estimate; and
hydrated lime/sodium bicarbonate blend injection alone. Note that the latter three technologies
might adversely affect the base plant ESP performance due to the addition of relatively large
quantities (17 to 21% of the base fly ash loading) of particulate matter to the ESP inlet flue gas.
The wet ESP retrofit downstream of the wet FGD system shows the highest first-year cost of
over $4 million. However, as mentioned above, the wet ESP comparison is skewed by the
assumption that the control technologies will only operate five months out of the year and the
relatively high capital recovery factor (10-year recovery). Both assumptions favor low capital
cost control options.
Discussion of First-Year Cost Estimate Results
For the lower sulfuric acid removal percentage target, seven technologies were estimated to be
able to achieve that target with first-year, non-labor costs in the range of approximately $460,000
to $820,000. An eighth technology, ammonia injection, was estimated to be able to achieve the
higher removal percentage at a cost in the same range. For the higher removal percentage, five
technologies (including ammonia injection) were estimated to achieve that level of performance
with first-year, non-labor costs in the range of about $640,000 to $980,000.
However, the results of this economic comparison are highly dependent on assumptions made
about performance, cost and technical issues regarding the potential control technologies. The
following describes the factors that affect the ranking of each of the technologies in terms of cost
effectiveness:
Fuel Blending/Fuel Switch. The cost effectiveness of this technology is very dependent on the
cost differential between the normal plant fuel and low-sulfur coal. At the assumed differential of
$0.20 per million Btu [$0.050/106 kcal] used for this evaluation, fuel blending/switching was
cost competitive with several of the injection technologies at the lower SO3 removal target, but
less competitive at the higher target. But, some plants may be able to purchase low-sulfur coals
at little or no cost premium relative to their current fuel. At a $0.10 per million Btu [$0.025/106
kcal] or lower differential, fuel switching could be cost effective for achieving the higher sulfuric
acid control percentage target as well. This assumes minimal capital cost requirements to be able
to blend and fire the low-sulfur coal.
OmniClearTM Fuel Additive. The costs for this technology are driven primarily by the delivered
cost of the reagent, as the estimated capital costs are relatively low. However, the performance of
this technology was based on a very limited amount of vendor-supplied data. More data are
needed, particularly for high removal percentages and preferably measured by a third party, to be
able to use these performance and cost estimates with confidence.
3-27
The costs for this technology will be dependent on the distance from the source of this reagent to
the candidate plant, although the vendor states that it can be delivered to a “typical” Midwestern
plant site for $100/ton. Also, based on results from a DOE/EPRI co-funded demonstration of
injecting magnesium hydroxide into the furnace for SO3 control, the ability to achieve high SO3
control efficiencies with this technology (less than 5 ppm sulfuric acid at the ESP outlet) may be
limited by adverse effects on ESP operation, particularly for plants with small ESPs.57
Furnace Injection of Byproduct Mg. The costs for this technology are driven by the delivered
cost of the byproduct Mg reagent. Since this material is not currently produced for byproduct
sales, there is not a well-established price. Also, the delivered cost is very dependent on the
shipping method and distance, since the slurry is typically produced at a relatively low purity and
solids content. Rail or barge delivery, closer distances, or production on site will make this
technology more cost effective, while greater distances with truck delivery will increase the
estimated cost.
This technology alone was not estimated to achieve the higher sulfuric acid control percentage
target for a plant with an SCR, based on the results of full-scale testing at Gavin Plant as
described in Section 2. For this example, furnace injection was combined with downstream
hydrated lime injection to achieve the higher control percentage target. However, for a plant that
does not have an SCR but must control sulfuric acid concentrations in the stack flue gas, furnace
Mg injection technology could potentially achieve high control efficiency. The BMP data
described in Section 2 suggest that in a plant without an SCR, the control efficiency would only
be limited by potential adverse impacts on the ESP, where a cold-side ESP is used as the plant’s
primary particulate control device.
Also, even for plants that have an SCR, there are other potential benefits from byproduct Mg
injection to remove the SO3 formed in the furnace at high efficiency. In plants that cycle in load,
SCR operation may be limited at low load by the potential for forming ammonium bisulfate salts
on active catalyst sites, or economizer bypass ducts or economizer tube bundle removal may be
required to maintain high SCR inlet flue gas temperatures at low load. Byproduct Mg injection to
remove up to 90% of the furnace-formed SO3 might allow SCR operation at low unit load
without having to resort to economizer bypass or surface area removal. These potential benefits
were not considered in this economic evaluation, but could make furnace Mg injection a
favorable control technology for some plants.
Furnace Injection of Commercial Mg. The comments about this technology are similar to those
for byproduct Mg above. Since magnesium hydroxide slurry is produced in only a limited
number of locations, the cost effectiveness of this technology will be highly dependent on the
proximity of the candidate plant to a source of this material.
57
Sulfuric Acid Removal Process Evaluation: Long-term Results, EPRI, Palo Alto, CA, U.S. Department of Energy,
Columbus, OH, and FirstEnergy, Shippingport, PA: 2002. 1004165.
3-28
MgO Injection Downstream of the SCR. This technology appears to be cost effective based on
the economics presented above. However, the performance of this technology was based on a
very limited amount of vendor-supplied data. Furthermore, the performance required to achieve
the higher removal percentage target (86% SO3 removal) may be a “stretch” for this technology
based on discussions with the vendor, who was more comfortable with removal percentages in
the range of 60 to 70%. More data are needed, particularly for higher uncontrolled SO3
concentrations, higher removal percentages, and preferably measured by a third party, to be able
to use these performance and cost estimates with confidence.
As for the magnesium hydroxide slurry injection processes, the costs for this technology will be
dependent on the distance from the source of this reagent to the candidate plant. Also, the ability
to achieve high SO3 control efficiencies with this technology may be limited by adverse effects
on ESP operation.
SBS InjectionTM. The biggest issue for estimating the cost of this technology is the delivered cost
of the reagent, which will be a function of f.o.b. price, distance and delivery method (truck, rail
or barge). Also, this is the only proprietary technology evaluated in this section (other than those
that are based on a proprietary sorbent or additive), so the cost estimate includes an annual
technology license fee ($0.20 per kW of generator capacity) not included for the other processes.
Ammonia Injection. This process may not be applicable to many plants because of impacts of the
ammonium salts on byproduct reuse or disposal. The economics presented in Table 3-11
consider the loss of fly ash sales revenue and costs for landfill disposing of the ammonia-
containing fly ash. However, neither potential costs associated with treating ammonia-containing
landfill runoff or leachate nor costs associated with avoiding nuisance odors during fly ash
handling were considered. These potential costs could make the application of ammonia
injection for sulfuric acid control more expensive to implement than is estimated in Table 3-11.
Also, other plant configurations would not likely be compatible with ammonia injection for
sulfuric acid control. Plants with FGD systems that produce a calcium sulfite byproduct and that
mix ash with the byproduct for stabilization, would not likely be able to employ ammonia
injection for sulfuric acid control due to the potential for ammonia off-gassing from the mixture,
particularly if lime is also added. Similarly, plants that use wet scrubbers for particulate control,
or that sluice and/or pond dispose of fly ash would likely find ammonia injection incompatible
with their plant configuration.
Humidification and Lime Injection. The costs for this technology are based on pilot-scale test
results from nearly a decade ago. No full-scale results were available on which to base
performance or cost estimates.
Notwithstanding the lack of full-scale data, the costs for applying this technology will vary
significantly depending on the configuration in which it is implemented. If the humidification
and lime injection could be implemented by injecting slaked lime or ground limestone slurry into
the duct, reagent costs could be reduced by avoiding having to procure and ship hydrated lime
powder. Capital costs would be reduced by eliminating the need for a separate humidification
system and a powder handling and injection system. Also, if this technology were implemented
3-29
between an ESP and wet scrubber, the excess reagent would be carried into the FGD system and
should reduce FGD reagent consumption. However, slurry injection is seen as posing a greater
risk for the deposition of wet solids in the duct than is dry powder injection, and injecting
upstream of the wet scrubber requires that the lime or limestone particles be removed in the FGD
system at high efficiency.
Hydrated Lime Powder Injection. The performance and cost estimates for this technology are
also based on decade-old pilot-scale results. There is anecdotal information that others have
tested hydrated lime powder injection at full scale and seen lower lime injection rates to achieve
a given level of sulfuric acid removal than are predicted from the EPRI ECTC average results.
However, the full-scale results are not well documented and/or were not available to serve as the
basis for performance estimates for this technology. To address this issue, these economics used
the ECTC data for the highest performance hydrated lime tested there (Chemstar) rather than
average performance as the basis for lime injection performance estimates.
These cost estimates were based on using commercially available hydrated lime as the sorbent. It
might be possible to lower the reagent costs by hydrating less expensive quicklime on site,
although capital costs would increase to add the hydrator and associated equipment. Benson, et
al55 state that on-site hydration could allow the production of a higher specific surface area
hydrate that might also reduce the amount required to achieve a given sulfuric acid removal
level. These two effects could lower the cost of hydrated lime injection technology from what
was estimated here.
The ability to achieve the higher sulfuric acid control percentage target remains in question for
plants that would inject hydrated lime powder upstream of ESP particulate collectors. Removal
of sulfuric acid from the flue gas and the injection of calcium-based solids could significantly
degrade ESP performance. Dry injection of a blend of calcium and sodium-based sorbents, as
was tested by EPRI at the ECTC, was assumed for the high removal percentage case to
overcome adverse effects on ash resistivity, although at a higher overall sorbent cost.37 However,
there is still the issue as to whether a small to medium size ESP and its existing ash handling
system could handle the estimated 20% increase in ESP inlet particulate mass loading.
Wet ESP. Wet ESP retrofit costs will be very site specific, depending on the retrofit difficulty,
the required level of sulfuric acid mist control, and the materials of construction. Wet ESP
capital costs should be considerably lower for a new installation than for a retrofit. Regardless of
this potential variation, the wet ESP option is the most capital-intensive control technology
considered in this evaluation. However, the cost effectiveness of a wet ESP would be much more
attractive in a situation where sulfuric acid mist control is needed year-round, rather than just
during the ozone season, and in a new plant where lower capital costs and longer capital
recovery periods would be expected.
Wet ESP technology offers an advantage over the other technologies because it can also control
fine fly ash or carbon particulate that may contribute to elevated plume opacity. However, since
a wet ESP would be installed at or near the end of the flue gas path, it would not address
upstream impacts of elevated SO3/sulfuric acid concentrations such as air heater plugging or
corrosion.
3-30
Wet ESP technology is the most mature of the control options considered, but is not well
demonstrated for the situation at the example plant. Only one full-scale, last-field dry ESP
conversion has been demonstrated in the U.S., at the Mirant Dickerson station, which fires
medium-sulfur coal, and this demonstration was met with a number of technical difficulties. For
the higher sulfuric acid control percentage, no existing full-scale wet ESP demonstrates all of the
example plant criteria: high-sulfur coal firing, SCR in service, installation downstream of a wet
lime or limestone FGD system, and high required sulfuric acid control percentage. Only one
existing U.S. installation comes close to demonstrating these criteria, at AES’ Deepwater plant.
Cost Estimate Sensitivity Cases
As mentioned above, the relative cost effectiveness of SO3/sulfuric acid control technologies is
impacted by a number of parameters. Comparison of the cost estimates presented in Table 3-10
with those in Table 3-11 illustrates the effect of one parameter, the require SO3/sulfuric acid
removal percentage. However, many of the assumptions made to develop these cost estimates
also impact the results. This subsection presents the results of sensitivity cases run to show how
three parameters – delivered sorbent costs (for sorbent additive/injection technologies), months
per year of control system operation, and new versus retrofit applications – impact the relative
economics of SO3 control. Sensitivity cases for each of these parameters are presented and
discussed below.
Of course, additional parameters impact the relative economics of SO3 control, such as the size
of the plant being controlled, what type of existing control device is used for particulate control,
whether the plant has an FGD system and what reagent is used, whether or not the plant sells its
fly ash and/or FGD byproduct, and many others. It is beyond the scope of this guide to show cost
sensitivities to all of these parameters, even though many of them can significantly impact SO3
control economics. The reader can use the SO3 control cost workbooks described in Section 4
and attached in Appendix C to develop initial cost estimates that are more specific to a particular
plant’s circumstances.
Effect of Delivered Reagent Cost
The estimated costs for most of the additive or injection technologies are largely driven by
delivered sorbent cost, as the capital costs for these technologies are relatively low (less than
$10/kW). There is uncertainty in the delivered costs of all of these sorbents. Since the sorbents
are typically available at a discrete number of locations and the distance between those locations
and the candidate plant could vary over a wide range, transportation costs could be quite
variable. Furthermore, transportation costs on a ton-mile basis will vary significantly depending
on whether truck, rail or barge delivery is employed.
The f.o.b. price of the sorbents could also vary significantly. The factors that drive the costs of
several potential sorbents are described below:
OmniClearTM fuel additive – This sorbent/fuel additive is currently supplied by only one vendor.
The f.o.b. price of this additive can therefore be influenced by market supply/demand pressures.
3-31
Byproduct Mg – This material is not sold commercially, so the market price per ton is not
established. Some plants would be able to produce this material internally from their FGD
byproduct, but many would have to purchase this material from a third party. Carmeuse has
estimated the production cost at $67/ton ($74/metric ton) of pure magnesium hydroxide, but this
does not include capital recovery or any profit.55
MgO Powder – The Utilimag 40 sorbent used as the basis for this evaluation is supplied by only
one vendor. The f.o.b. price can therefore be strongly influenced by market supply/demand
pressures.
SBS – Either sodium sulfite or sodium bisulfite, or a blend of the two, could be used as the
reagent for this technology. Either could be procured as a byproduct or as a technical grade
chemical. Also, for this reagent shipping could be as a concentrated solution or as a dried
powder. Depending on which reagent source and form is employed, the f.o.b. and delivered cost
of this reagent could vary by hundreds of dollars per ton.
Ammonia – Both ammonia and urea are commodity chemicals used in high volumes in the U.S.
The costs for these reagents are driven by supply and demand pressures, and by the price of raw
materials, and can fluctuate over a wide range.
Hydrated Lime – Hydrated lime is available from a number of suppliers throughout the Midwest.
Depending on the plant size and hydrated lime requirements, and distances from suppliers, it
may be more cost effective to purchase quicklime and hydrate it on site. While a delivered price
of $75/ton ($83/metric ton) was used as the basis for these cost estimates, quicklime can be
purchased for about $50/ton ($55/metric ton) and contains about 30% more alkali on a molar
basis, making it about half the cost of hydrated lime on a molar basis. Plants that use lime or
magnesium-enhanced lime as an FGD reagent on site already may have a long-term contract for
quicklime and have presumably negotiated a competitive delivered price. However, using
quicklime to produce hydrated lime on site requires additional capital investment and operating
and maintenance labor, which will offset some of the savings.
Given these issues, it is quite possible that the costs of any of the sorbents considered could vary
over a range of ±50% from the values used as the basis for the cost estimates presented in Table
3-10 and Table 3-11. Since sorbent costs represent a majority of the injection technology costs,
this could greatly influence the annual reagent, utility, and capital cost recovery estimates. Figure
3-5 illustrates the effects of delivered sorbent cost, over the range of ±50% of the values
presented in Table 3-12, for the higher sulfuric acid removal percentage case.
For all of the sorbent injection technologies except ammonia injection and humidification with
hydrated lime injection, the sorbent delivered cost variations produce a wide range in the
technology cost estimates. The ammonia injection costs are mostly driven by the assumption of
lost fly ash sales, and the humidification with lime injection costs are mostly driven by capital
costs.
3-32
3500
-50% Reagent Cost
Annual Cost ($1000) 3000 Estimated Reagent Cost
+50% Reagent Cost
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Figure 3-5
Effect of Sorbent Delivered Price Variations on Control Technology Cost Estimates
(includes reagent, utility and capital recovery costs)
The results in Figure 3-5 show that among the five candidate sorbent injection technologies that
were estimated to have lower annual costs earlier in this section, an increase in sorbent cost for
one coincident with a decrease for another could markedly change the ranking of injection
technology costs. This illustrates that, before selecting an SO3 control technology for a particular
plant, it would be best to have the delivered sorbent cost established to a relatively high
confidence level.
Effect of Control Technology Operating Period
The control technology cost estimates presented earlier in this section were based on the
assumption that the SCR on the example plant would operate only during the 5-month ozone
season, and that the control technology would operate only during that period as well. However,
some plants will have to operate their SCR year-round, and/or will have to operate their SO3
control technology year-round once installed. A change to year-round operation will improve
the relative economics of technologies whose costs are driven mostly by capital recovery (e.g.,
wet ESP) and could erode the economics of technologies whose costs are driven mostly by
reagent and/or utility costs (e.g., fuel switch/blend or fuel additive).
Figure 3-6 shows the annual cost estimates for the candidate control technologies for the higher
sulfuric acid removal percentage, assuming the SCR and SO3 control technology operate 12
months per year. Two simplifying assumptions were made in generating these 12-month per year
costs. One is that the SCR operates year-round. The analysis would be more complex if the SCR
operated 5 months while the control technology operated 12 months, as there would be different
baseline SO3 concentrations and different SO3 removal percentage requirements for the two
3-33
periods of the year. The second simplifying assumption was that the plant’s fly ash is sold year-
round. Again, the analysis would be more complex if the ash is only sold for part of the year,
particularly for the ammonia injection case where the cost estimate is largely driven by the
impacts of lost fly ash sales.
5000
5640 Capital Recovery
4500
4000
Annual Cost ($1000)
3500
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Figure 3-6
Acid Control Technology for Achieving the Higher Removal Percentage Target (12-month
operating period)
The annual cost estimates illustrated in Figure 3-6 can be compared to those in Figure 3-4 to see
the effect of 12-month versus 5-month operation on the relative economics of the SO3 control
technologies at the higher removal percentage. This comparison is made in Figure 3-7. As
expected, the relative ranking of the fuel switch/blend case erodes for 12-months operation and
the relative ranking of the wet ESP case improves. For the five injection technologies that were
estimated at less than $1 million annually for 5-months operation, ammonia injection remains the
lowest estimated cost option (notwithstanding other balance-of-plant issues) but the relative
rankings of the other four technologies reverse. For example, the more capital intensive
humidification with lime injection process goes from being the most costly of the five to being
the second lowest (behind ammonia injection) for 12-months operation. Conversely, the fuel
additive process goes from being the second least costly to the most costly of the five at 12-
months operation.
3-34
6000
5-mos. Operation
12-mos. Operation
5000
Annual Costs ($1000)
4000
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Figure 3-7
Comparison of First-year Capital Recovery and Non-labor Operating Costs by SO3/Sulfuric
Acid Control Technology for Achieving the Higher Removal Percentage Target (5-month
vs. 12-month operating period)
Effects of New Versus Retrofit Installation
Another assumption used for this evaluation that impacts the relative economics of the candidate
SO3 control technologies is the assumption that the controls are being retrofit to an existing
scrubbed plant. If it is instead a new plant, there are at least two impacts on the cost estimates.
One is that a longer plant life would be assumed and hence a lower capital recovery factor would
be applied. The second is that, for the wet ESP case, the wet ESP design and implementation
could be integrated with the wet FGD absorber, possibly lowering the capital cost. For the other
technologies, the capital costs would not likely change as significantly for a new plant.
Figure 3-8 illustrates first-year annual cost estimates for the candidate SO3 control technologies
for the higher SO3 removal percentage and for 12-months operation (the most likely scenario for
a new plant) with two changes from the estimates shown in Figure 3-6. One is that the capital
recovery factor has been lowered to 0.10 from 0.15 (same discount rate, 20-year versus 10-year
recovery period), and the capital costs for the wet ESP case have been reduced to $35/kW from
$55/kW. Figure 3-9 compares annual cost estimates for all three estimate bases (5-months
operation, 12-months operation, and 12-months operation for a new plant).
3-35
5000
5640 Capital Recovery
4500
4000
Annual Cost ($1000)
3500
3000
2500
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Figure 3-8
Acid Control Technology for Achieving the Higher Removal Percentage Target (New plant,
12-month operating period)
6000
5-mos. Operation
5000 12-mos. Operation
Annual Cost ($1000)
12-mos. Operation, New Plant

4000
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Figure 3-9
Comparison of First-year Capital Recovery and Non-labor Operating Costs by SO3/Sulfuric
Acid Control Technology for Achieving the Higher Removal Percentage Target
3-36
The estimates illustrated in Figure 3-8 and Figure 3-9 show that the relative economics of the wet
ESP case greatly improve relative to the sorbent injection technologies. Furthermore, the wet
ESP offers two advantages relative to sorbent injection. One is that the wet ESP will also lower
the emissions of trace metals (e.g., beryllium, lead) present in the fine particulate emitted from
the dry ESP or baghouse, which could help in the permitting of the new coal plant. The second is
that the primary cost driver for the wet ESP case, capital recovery, would be fixed at the outset
whereas the primary cost driver for sorbent injection, delivered sorbent costs, could vary
significantly over the life of the plant.
On the other hand, the sorbent injection technologies that remove SO3 from the flue gas upstream
of the air heater could be exploited to further improve the plant heat rate and to lower costs
associated with corrosion repair in the back end of the plant. Neither of these factors has been
considered here.
Conclusions – Example Economics
The example economics presented in this section show that ammonia injection was projected to
be a low cost technology, but balance-of-plant impacts may preclude its use. OmniClearTM fuel
additive, MgO injection and SBS injection appear to be cost competitive technologies at either
control level, although more data are needed to support the performance estimates used for the
OmniClearTM additive and MgO powder injection at high control efficiencies. Humidification
combined with lime injection may also be a cost-competitive control approach, particularly if the
two steps can be combined by injecting lime or limestone slurry. Variations in delivered sorbent
cost from those assumed for this evaluation could significantly change the relative ranking of the
cost effectiveness of these SO3 control technologies.
Byproduct Mg injection in the furnace can be a cost-effective technology for restoring stack
sulfuric acid mist concentrations to pre-SCR levels. For the example plant, commercial Mg
injection in the furnace was slightly less cost effective. Neither furnace injection technology was
estimated to be capable of achieving the higher sulfuric acid removal percentage target. Although
it would be possible to combine furnace injection with another technology downstream to
achieve less than 3 ppmv of sulfuric acid mist at the stack, the economics of installing two
control technologies in series did not appear to be attractive for the set of assumptions made in
this study.
Fuel switching or blending with low-sulfur coal could be cost effective depending on the cost
differential between the current and low-sulfur coal, and assuming only minimal capital cost
implications. Finally, although wet ESP technology was evaluated at the highest cost in this
comparison, its economics look better if SO3 control is required year-round rather than just
during the ozone season. A longer capital recovery period and wet ESP integration with a new
wet scrubber also make the economics for the wet ESP cases more competitive with the low
capital cost, sorbent injection or additive alternatives.
3-37
The example economics presented here underline two important observations about SO3/sulfuric
acid controls. One is that there is no one “best” control option available. The cost effectiveness
of the various options depend on site specifics such as the location of the plant relative to reagent
sources, coal combustion byproduct reuse and disposal practices, the sulfuric acid mist control
level required, and the extent to which other particulate matter contributes to plume opacity.
Depending on these specifics, one technology may be favored over the others for a particular
plant situation. The cost estimating workbook discussed in Section 4 and included as Appendix
C provides the user with the ability to estimate relative costs for a specific plant’s circumstances.
The second observation is that there are several candidate SO3/sulfuric acid control technologies
for which there is not adequate full-scale demonstration and test data to serve as a basis for
power generators to evaluate control technologies with confidence. For example, the fuel
additive, MgO powder injection and humidification/lime injection technologies (combined or
separately) show promise as being cost effective for some situations, but a well-documented,
full-scale demonstration of each of these technologies is needed.
Finally, it should be noted that the candidate SO3/sulfuric acid control technologies evaluated in
this section should not be considered an all-inclusive list; the technologies evaluated here were
limited to those for which the authors had performance and cost data available. The retrofit of
SCR to plants that fire high-sulfur coal has created a need for retrofit SO3/sulfuric acid controls,
and has spawned the development of new processes. Some processes were not included in this
evaluation because not enough information was available to allow their costs to be estimated
(e.g., the condensing heat exchanger) and there may be others that were not included merely
because the authors of this report are not yet aware of them.
3-38
4
SO3 CONTROL PROCESS ECONOMICS WORKBOOK
OVERVIEW
The example economics shown in Section 3 illustrate that the most cost effective SO3 control
technology can be very site specific, depending on the plant location, existing environmental
controls, disposal or reuse practices for coal combustion byproducts, utility-specific capital
recovery factors, etc. The purpose of the workbook is to allow the reader to calculate the
approximate capital and annual reagent and utility costs associated with each of the possible SO3
control options for a particular plant. The control options that will be covered by this workbook
include wet ESP, fuel blending, fuel additives, and a number of sorbent injection technologies.
The workbook is oriented towards plants that fire eastern bituminous coals, for two reasons. One
is that eastern bituminous coals typically have higher sulfur content than western coals and
generally do not have highly alkaline ash. Thus, eastern bituminous coals are the most likely to
have flue gas SO3/sulfuric acid concentrations high enough to cause plume opacity issues. The
second, and no doubt, related reason is that there are little data available for SO3 control for other
coal types. The workbook considers the effect of Powder River Basin subbituminous coal, but
only as a low-sulfur blending coal, in the context of being implemented as a mitigation
technology.
It is possible that some plants that fire Texas lignite could have high enough flue gas
SO3/sulfuric acid concentrations to cause plume opacity issues, as some could be considered
medium- to high-sulfur coals on the basis of pounds of SO2 produced per million Btu of heat
input. Consequently, the workbook also includes some calculations oriented towards Texas
lignite. However, the user is cautioned that no data were available for evaluating SO3 control
technologies for Texas lignite applications, so there are some technical risks associated with
using the workbook for a Texas-lignite-fired plant.
Completion of the workbook involves three main steps:
Step 1: Enter specific data about plant operations.
Step 2: Estimate (or enter actual values for) flue gas flow rate, SO3 profile across the flue gas
path, and a target stack SO3 concentration.
Step 3: Choose a control option and complete its corresponding worksheet. Sorbent injection
technologies and fuel additives are covered by one worksheet, fuel switching by another , and
wet ESP by a third worksheet. Completing the specified worksheet will estimate capital and
operating costs for the selected technology.
4-1
SO3 Control Process Economics Workbook Overview
Note that the calculations in the worksheets have been simplified from those used to generate the
relative economics presented in Section 3, and even those in Section 3 do not include all of the
details that should be considered in a site-specific engineering evaluation of control technologies.
The results from these worksheets are meant to develop a relative ranking of control options for a
particular plant, based on a limited set of variables that have been identified as significantly
impacting control costs. The initial estimates developed using these worksheets should be useful
for selecting a subset of control options that appear to be more cost effective for a particular
plant.
The use of these worksheets to develop initial estimates does not preclude the need to conduct a
thorough engineering evaluation of control options to select a control technology for
implementation. Such an evaluation should involve developing site-specific capital and delivered
reagent cost estimates, and might involve applying risk factors based on the extent of full-scale,
commercial experience for each technology considered and potential sorbent cost volatility.
The following describes each worksheet in more detail. The actual worksheets are attached at the
end of this document, in Appendix C.
Worksheet 1
The worksheet user enters utility/unit specific parameters in the first step of the process
economics evaluation. Data about the process operation, unit operations, and coal are required. If
the user does not know the specific information requested, the user can consult the provided
look-up tables for suggested values. At the end of the worksheet, flue gas flow rates are
calculated. These calculation results, as well as the line-item inputs, will be used in subsequent
sections.
Worksheet 2
Based on the plant- or company-specific parameters identified in Worksheet 1, Worksheet 2

guides the user to calculate the SO3 concentration profile across the flue gas path of the plant.
Formation of SO3 in the boiler and across the SCR will be based on a constant percent
conversion of SO2 to SO3. The fractional penetration of SO3 across each downstream unit
operation (air heater, ESP, FGD absorber) is quantified with an “F2” factor, which is a concept
based on an engineering design tool from Southern Company, as described in Appendix B.
However, the values provided for the F2 factors are based on previous measurements made at
facilities burning bituminous coal rather than upon the Southern Company values. Because the
measurements often span a large range, the standard deviation for the measurements and the
number of measurements comprising the average are given. The user is urged to apply F2 factors
conservatively (i.e., consider that the actual percentage SO3/sulfuric acid removal across these
devices could be considerably lower than the average of the previous full-scale results presented
in Appendix B). If at all possible, actual plant SO3 concentrations should be measured and used
as the basis for completing these worksheets.
4-2
Once the current stack SO3 concentration is estimated, the user decides on the desired stack SO3
concentration to be achieved.
Worksheets 3 Through 5
The third step of the process economics workbook involves the specific calculations of operating
and capital costs for each of the SO3 removal technologies. The user chooses an SO3 control
option and picks the corresponding worksheet. There are three worksheets corresponding to (a)
fuel blending (b) injection or fuel additive technologies, and (c) wet ESP. The basic design for
each of these worksheets is described in the following paragraphs.
Note that the worksheets have been designed to estimate control technology costs based on a
number of assumptions, typically consistent with those made to develop the example economics
shown in Section 3 of this report. However, the user can typically alter those assumptions as
needed to best fit his or her plant situation. In some cases the worksheet provides an option to
change assumptions, but in other cases the user can use judgment to add, modify or delete a
particular calculation to alter an assumption.
Fuel Blending Worksheet
The capital costs for implementing fuel blending will not be estimated by this worksheet. The
capital costs are site specific and depend upon many factors, such as the plant’s ability to store
multiple coal piles and prepare and convey coal blends.
The operating costs for fuel blending are estimated. The first step in the fuel blending worksheet
is to determine the firing proportions of the current coal and low-sulfur coal. Properties of two
typical low sulfur coals have been identified and can be used for this determination. Alternately,
the user can input the properties of the plant’s choice for a low-sulfur coal. The blending
proportions are arrived at through an iterative process to achieve the desired stack SO3.
The annual operating costs for fuel blending are primarily driven by the difference in cost
between the currently used coal and the low-sulfur coal. The cost differential between the low-
sulfur coal and the currently fired coal must be supplied by the user. Other impacts on the cost
are the generation of SO2 allowances, a reduction in FGD reagent use, a reduction in FGD
byproduct sales, and the costs associated with any changes in ash production and disposal. These
factors are incorporated into the operating cost equation and will be based on the user inputs for
the plant.
Injection/Additive Technologies Worksheet
The injection and/or fuel additive technologies worksheet covers the following:
• OmniClearTM fuel additive;
• Furnace injection of Mg(OH)2 [for plants without SCR];
4-3
• Furnace injection of Mg(OH)2 + dry Ca(OH)2 injection upstream of ESP [for plants with
SCR];
• Injection upstream of air heater of MgO or SBS;
• Injection upstream of particle collection device of MgO, SBS, ammonia, dry hydrated lime,
or hydrated lime and sodium bicarbonate mixture; and
• Humidification with lime injection.
At the beginning of Worksheet 4, the user is asked to determine the delivered cost for each of the
reagents. Suggestions are given for costs and shipping locations to aid in the determination.
However, the user is encouraged to use vendor quotes, where available.
A separate subsection for each technology is provided, each with an associated performance
curve. The user looks up the desired percent SO3 removal on the plot, then finds the required
stoichiometry or injection rate for the chosen injection technology. The relationship between
stoichiometry and SO3 removal is estimated from data available in the literature.
The injection technologies worksheet is divided into subsections, one for each technology. These
subsections calculate the annual operating costs and capital costs. A brief methodology for
calculating these costs for each technology subsection is presented below. More details are
provided in the process economics workbook in Appendix C.
Fuel Additive
The product OmniClearTM is considered as a fuel additive. The performance data, operating
costs, and estimated capital costs for the additive are based on the vendor’s literature.
Mg(OH)2, MgO, SBS, Dry Hydrated Lime, and Sodium Bicarbonate Injection
For the Mg(OH)2, MgO, SBS, and hydrated lime injection technologies, more than 90% of the
annual operating cost is related to the cost of the injected reagent, shipping, supplemental FGD
reagent, and licensing fees (SBS only). The remainder of the costs include, but are not limited to,
water and compressed air supply, and an increase in solids disposal or byproduct sales quantity.
Using the stoichiometry determined from performance curves for each technology and the plant
flue gas generation calculated in Worksheet 1, the yearly reagent use for each technology is
quantified. Typical reagent costs were obtained from vendors and are combined with the reagent
use to calculate the annual reagent cost to the plant. Other costs associated with water, air, etc.
are estimated as a specified fraction of the reagent costs. For injection and SO3 removal upstream
of the plant air heater, the costs of these technologies are estimated to be offset in small part by
boiler efficiency savings (by avoiding having to raise the air heater flue gas outlet temperature
with the SCR operating). The boiler efficiency savings are calculated separately from the annual
operating costs.
4-4
Capital costs are estimated on the basis of the required sorbent or additive injection rate. The
relationships between capital cost and injection rate were developed using the capital cost
estimating spreadsheets described in Section 3.
Ammonia Injection
The primary contributor to the annual operating cost of this technology is the cost to landfill all
of the ash and the loss of fly ash sales (if the plant sells its fly ash). The cost of ammonia reagent
is a lesser, but significant (20%), portion of the cost. Using the plant parameters of load and coal
ash, the amount of ash disposal is estimated. The user then calculates the cost of ash disposal and
losses in fly ash sales (if applicable). Ammonia reagent cost is calculated based on the
stoichiometry and plant size. Incidental expenses (such as air and energy use) are calculated as a
fraction of the reagent costs.
estimating spreadsheets described in Section 3.
Humidification with Lime Injection
The primary operating cost for humidification with lime injection is the lime reagent, although
compressed air supply costs are significant (35%). The air cost factor is based proportionately on
the reagent use.
estimating spreadsheets described in Section 3. The annual capital cost recovery for this
technology is typically greater than the reagent and utility cost.
Wet ESP Worksheet
The first step in the Wet ESP worksheet is to determine whether the utility should install a stand-
alone wet ESP, a last field retrofit on a dry ESP, or a close-coupled FGD/wet ESP. This
determination is based on the SO3 removal efficiency required and the plant configuration. The
capital costs for the wet ESP are calculated based on a determined $/kW factor. Different factors
were determined from a vendor survey.
The costs associated with operating a wet ESP are power, water, and neutralizing agent for the
collected rinse. These costs are proportional to the flue gas flow rate through the wet ESP, and
therefore proportional to the load and capital cost for the wet ESP. The annual operating costs
are estimated as a fixed percentage of the capital cost.
4-5
Worksheet 6
This worksheet guides the user to calculate the boiler efficiency savings that might be gained
from reducing the SO3 concentration upstream of the air heater. A reduced SO3 concentration
results in a lower acid dewpoint. Therefore, the air heater can operate at a lower temperature and
the plant can recover more heat. The boiler efficiency savings might save anywhere between 2 to
10% of the annual operating cost, depending on the technology. Technologies covered in the
Process Economics Workbook that may realize boiler efficiency savings include:
• Fuel Switching;
• Addition of OmniClearTM with the coal;
• Mg(OH)2 injection in furnace;
• MgO injection upstream of air heater; and
• SBS injection upstream of air heater.
Worksheet 7
The user summarizes the annual operating costs, boiler efficiency savings and capital costs
calculated for the various technologies. The user then chooses a capital recovery factor and
calculates the capital recovery for each technology. The annual cost is computed by adding the
annual operating costs and capital recovery, and accounting for any boiler efficiency savings.
4-6
5
SO3 CONTROL TECHNOLOGY VENDORS
This section provides lists of vendors for the various SO3 mitigation options. This list does not
constitute EPRI’s endorsement of any particular technology or vendor, rather, it is intended to
provide the utility engineer with a starting point for help in solving SO3-related problems. This
list was compiled in part with an internet search engine and information from McIlvaine
Company.
Vendors of Coal Additives
OmniClearTM
Omni Materials, Inc.
901 U.S. Highway 68
Woodland Center, Suite 900
Maysville, KY 41056
(606) 564-5008
Vendors of Sorbent Injection Technologies
Lime
Chemical Lime Company
3700 Hulen Street
Fort Worth, TX 76107
(817) 732-8164
Contact: Paul Nolan
Magnesium Hydroxide [Mg(OH)2]

Carmeuse North America Services, Inc.
11 Stanwix Street
11th Floor
Pittsburgh, PA 15222
(412)995-5500
www.carmeusena.com
Contact: Kevin Smith
(412) 777-0715 voice
(412) 777-0727 fax
5-1
SO3 Control Technology Vendors
Magnesium Oxide (MgO)

Martin Marietta Magnesia Specialties, LLC
195 Chesapeake Park Plaza, Suite 200
Baltimore, MD 21220-4201
(800) 648-7400
(410) 780-5500
www.magspecialties.com
Sodium Bicarbonate
Church & Dwight
469 North Harrison Street
Princeton, NJ 18940
(609) 279-7553
Contact: Robert Berube
Sodium Bisulfite (SBS)

Codan Development, LLC
2934 Charros Road
Sandy, UT 84092
Contact: Robert Moser
(831) 438-0866
Sodium Bisulfite (SBS)

URS Corporation [in conjunction with Codan Development, LLC]
P.O. Box 201088
Austin, TX 78720
(512) 454-4797
www.urscorp.com
Contact: Sterling Gray
Vendors and Engineers/Constructors of Ammonia Injection Systems
Babcock & Wilcox

20 South Van Buren Avenue
Barberton, OH 44203-0351
(330) 753-4511
www.babckock.com
Black & Veatch

11401 Lamar
Overland Park, Kansas 66211 U.S.A
(913) 458-2000
www.bv.com
Contact: Joe Plubell
(630) 579-1006
5-2
Chemithon Corporation
5430 West Marginal Way SW
Seattle, WA 98106-1598
(206) 937-9954
www.chemithon.com
Ducon Technologies
19 Engineers Lane
Farmingdale, NY 11735
(631) 694-1700
www.ducon.com
Contact: Bill Papa
Foster Wheeler
Perryville Corporate Park
Clinton, NJ 08809-4000
(908) 730-4000
www.fwc.com
Haldor Topsoe
17629 El Camino Real
Houston, TX 77058
(281) 228-5000
www.haldortopsoe.com
Contact: Fleming Hansen
R.M. Technologies Inc.

4437 Church Road
Mt. Laurel, NJ 08054
(609) 702-8260 & (856) 914-1860
www.rmtech.net
Turner EnviroLogic
3439 S.W. 11th Street
Deerfield Beach, FL 33442
(800) 933-8385 & (954) 422-9787
www.tenviro.com
Wahlco, Inc.
3600 West Segerstrom Ave.
Santa Ana, CA 92704
(714) 979-7300
www.wahlco.com
5-3
Vendors of Wet Electrostatic Precipitators
Geoenergy®, a division of A.H. Lundberg Assoicates, Inc.

13201 Bel-Red Road
Bellevue, WA 98005-2326
(425) 283-5070
www.lundbergassociates.com
Contact: Steve Jaasund
Alstom Power and Environmental Control Systems

1409 Centerpoint Boulevard
Knoxville, TN 37932
(865) 693-7550
www.alstomenvironmental.com
Babcock & Wilcox

20 South Van Buren Avenue
Barberton, OH 44203-0351
(330) 753-4511
www.babcock.com
Contact: Richard Staehle
(330) 860-2577
rcstaehle@babcock.com
Belco Technologies Corporation

7 Entin Road
Parsippany, NJ 07054
(973) 884-4700
www.belcotech.com
Contact: Nicholas Confuorto
CR Clean Air Technologies

P.O. Box 668
751 Central Avenue
Westfield, NJ 07091
(908) 232-4200
www.croll.com
contact: James Reynolds
jreynolds@croll.com
908-232-4200 x110
5-4
FLS Airtech, Inc.

100 Glenborough Drive
Suite 500
Houston, TX 77067-3611
(281) 539-3400
www.flsairtech-us.com
Contact: Sam Kumar
(281) 539-3448
Hamon Research-Cottrell
58 East Main St.
P.O. Box 1500
Somerville, NJ 08876
(908) 685-4000
www.hamon.com
Mitsubishi Heavy Industries, Ltd. (MHI)

Kobe Shipyard & Machinery Works
1,1, Wadasaki-cho 1-chome, Hyogo-ku
Kobe 652-8585 JAPAN
Contact: Chikayuki Nagata
+81-78-672-5489
chikayuki_nagata@mhi.co.jp
PPC Industries
3000 East Marshall Avenue
Longview, TX 75601
(903) 758-3395
www.ppcbio.com
Contact: Scot Standefer or Ray Willingham
Vendor of Condensing Air Heater
Marsulex Environmental Technologies Inc., LLC

Atlanta, GA
Contact: George Sacco
(770) 335-3559
gsacco@marsulex.com
5-5
A
APPENDIX — MEASURING SO3 CONCENTRATIONS IN
FLUE GAS
This section describes the currently available methods for measuring SO3 concentrations in flue
gas. These methods include EPA Method 8, Acid Dew Point Measurement, and the Controlled
Condensation System (CCS) Method. Alternative methods under development are discussed briefly.
The CCS Method is considered to be one of the best methods for measuring flue gas sulfuric acid
concentrations. However, there are situations where the CCS method may not accurately reflect
the actual flue gas sulfuric acid concentration. The last part of this section summarizes the results
from EPRI-funded laboratory and field studies that investigated the accuracy of the CCS method
under various conditions.
EPA Method 8
Method 8 determines sulfuric acid and sulfur dioxide emissions from a stationary source. Flue
gas is extracted isokinetically and passed through a train containing four impingers. The first
impinger contains 80% isopropanol in water, which absorbs sulfur trioxide. The second and third
impingers contain 3% hydrogen peroxide, which absorbs sulfur dioxide. Silica gel is in the fourth
impinger and is used for moisture determination.
Jaworowski and Mack58 concluded that EPA Reference Method 8 can result in a positive bias for
SO3, as the isoproponal oxidizes a small amount of the SO2 in the sample gas. Because coal-fired
power plants have relatively low SO3 concentrations compared to the amount of SO2, this bias
can be a significant.
Acid Dew Point Measurement

The acid dew point can be used to estimate the concentration of sulfuric acid in the gas if the flue
gas moisture and pressure are also known. LAND Instruments International has designed a
measurement device based on this concept.59 Their acid dew point meter consists of a probe with
a conduction cell on its tip and a control box. The probe is inserted into the flue gas path. The
user controls the amount of cooling air passing over the conduction cell, which in turns controls
the temperature of the conduction cell while it is inserted in the flue gas path. As the temperature
58
Jaworowski, R.J. and S.S. Mack. “Evaluation of Methods for Measurement of SO3/H2SO4 in Flue Gas,” Journal
of the Air Pollution Control Association, January 1979.
59
LAND Instruments International. “Real Time Measurement of SO3 and Condensables as PMfines,” Paper presented
at presented at the Institute of Clean Air Companies’ Forum ’03, Multi-Pollutant Emission Controls & Strategies,
Nashville, TN, October 14-15, 2003..
A-1
Appendix — Measuring SO3 Concentrations in Flue Gas
of the cell drops below the acid dew point of the gas, sulfuric acid begins to condense on its
surface. The condensed sulfuric acid completes a circuit on the conduction cell, allowing for a
current to be measured. As more acid condenses on the cell, the current passing through the
condensate increases. The acid dew point is determined as the temperature at which this current
is measurable and remains constant (i.e. achieves a steady state between condensation and
evaporation of sulfuric acid).
Strengths
Jawoworski and Mack also showed that an acid dew point monitor could provide acceptable
results, but that the dew point monitor needs to be calibrated to the actual flue gas SO3
concentration (e.g., with the CCS method as described below). Once calibrated, this instrument
could provide a way to continuously monitor SO3 in a stack or flue gas duct.
Weaknesses
Solid deposits on the conduction cell will affect the acid dew point reading. The probe must be
periodically cleaned. The flue gas moisture must be known and entered into electronic controls
to allow the estimation of flue gas SO3 concentration from the dew point results.
Perhaps the biggest shortcoming of the acid dew point monitor is that it relies on establishing and
maintaining a thin film of condensed sulfuric acid on the measurement surface to make an
accurate acid dew point measurement. However, with flue gas velocities in ducts and stacks
typically in the range of 50 to 70 ft/sec (15 to 21 m/sec), the flow of flue gas past the
measurement surface can strip condensed acid from the surface. It has been the authors’
experience that acid dew point measurements typically under-predict flue gas SO3/sulfuric acid
concentrations, presumably because of this effect.
Controlled Condensation System Method

The Controlled Condensation System (CCS) method is currently believed to be one of the best
methods for accurately measuring sulfuric acid in flue gas.60,61 Figures A-1 through A-3 illustrate
the equipment used to conduct this measurement method. In the method, a sample of flue gas is
pulled through a quartz-lined probe from the utility duct or stack. Particulate material is removed
from the flue gas sample using a quartz fiber thimble. Both the probe and the thimble are
maintained at approximately 550ºF (288oC) to keep the sulfuric acid in the vapor state. After the
thimble, the flue gas sample passes to a condenser that is maintained about 20ºF (11oC) above
the water dew point of the flue gas, which is well below the sulfuric acid dew point. Sulfuric acid
vapor condenses and collects on the condenser walls. At the completion of a sample run, the
condenser is rinsed with deionized water, and the rinsate is collected and analyzed for sulfate
content. The sulfate content provides a direct measure of the sulfuric acid that was present in the
flue gas sample.
60
Cheney, J. and J. Homolya, “Characterization of Combustion Source Sulfate Emissions with a Selective
Condensation Sampling System,” in Workshop Proceedings on Primary Sulfate Emissions from Combustion
Sources, Vol. 1, Measurements Technology, EPA 600/9-78-020a. NTIS PB287-436.
61
Maddalone, R. and N. Garner. Process Measurement Procedures—H2SO4 Emissions. EPA 600/7-79-156.
A-2
A set of hydrogen peroxide impingers downstream of the condenser coil collects flue gas SO2.
They are analyzed for sulfate content as a direct measure of the SO2 present in the flue gas
sample. These impingers can be analyzed either every run or at the conclusion of a set of runs.
Protective Housing
for SO3/H2SO4
Condenser Thermocouple to
High-Temperature Monitor Exit Gas
Oven for Pyrex Temperature
Probe Thimble Holder
3% H2O2 Dry Impinger
Impingers
Temperature
Sensor
Quartz Liner High-Temperature Condenser Cooling

Probe Liner Liquor Inlet
Thermometer
Dual-Temperature
Controller for
Maintaining Probe and Condenser
Oven Temperature (550°F) Submergible Temperature Silica Gel
Cooling Dessicant
Liquor Outlet Controller and Pump Vacuum
Combination Line
140°F Controlled
Temperature Bath Bypass
Temperature Vacuum
Sensors Valve Gauge
Orifice
Main
Valve
Orifice
Magnehelic Pump
Dry Gas Meter
Figure A-1
Controlled Condensation System (CCS) Sampling Train
A-3
Spring Attachment
Hooks
Stainless Steel
Retaining Spring
18/9 Socket
Joint Thermocouple Well
18/9 Ball
Joint
Gas Gas
Inlet Exit
Standard Taper Quartz Thimble

Pyrex 40/50 with Clamp
Figure A-2
Controlled Condensation System (CCS) Thimble Holder
Glass Wool Plug

to Prevent Carryover
of Condensed Acid
18/9 Socket Joint 18/9 Ball Joint
Gas Gas
Inlet Exit
Cooling Water Cooling Water

Out In
Figure A-3
Controlled Condensation System (CCS) Condenser
A-4
The accuracy of CCS results can be improved by a number of efforts to improve data quality.
These efforts can include sampling at various points (multiple ports and/or depths at each port) at
a given location to ensure that representative sulfuric acid concentrations are sampled, and
measuring the oxygen content of the sample gas exiting the CCS train during each measurement
run. The impinger catch for each series of CCS runs can be analyzed for SO2 and moisture
content to ensure that the sample gas was representative with respect to these parameters. All of
these additional data can be examined for each set of CCS measurements to provide a higher
level of confidence in the results, or to identify results that should be discarded due to
measurable sampling biases.
There are situations in which the controlled condensation technique may not accurately reflect
the actual flue gas sulfuric acid concentration. One is the measurement of sulfuric acid in
locations that have a high particulate material loading. In coal-fired units this would include any
location upstream of the particulate control device (e.g., electrostatic precipitator). In areas of
high particulate loading, the particulate material forms a filter cake on the thimble surface. The
intimate contact between the gas sample and the filter cake could result in sulfuric acid vapor
being adsorbed on the filter cake, even at the filter temperature of about 550ºF (288oC). Removal
of sulfuric acid vapor at the thimble would cause the reported sulfuric acid concentration to be
lower than the actual concentration in the flue gas.
A second concern is where the flue gas temperature is below the acid dew point, such as
downstream of a wet flue gas desulfurization (FGD) system. When the flue gas is below the acid
dew point, sulfuric acid is typically present as a sub-micron-diameter aerosol or mist. In this
situation, for the controlled condensation system to work as designed, the mist must be
evaporated before the gas sample reaches the thimble. A result of failing to evaporate all of the
mist is that the measured sulfuric acid could be biased low.
These situations in which the potential for bias exists were investigated by an earlier EPRI
funded study. The results from this study are discussed later in this section.
Also, E.ON Engineering has developed a revised version of the CCS method, for sampling flue
gases where part or all of the sulfuric acid is already condensed. In their modified method, the
sampling probe is not heated above the sample gas temperature and a small ESP is used to
capture particulate matter and any sulfuric acid mist present in the sample gas. A standard CCS
condenser downstream of the ESP collects any sulfuric acid that remains in the vapor phase. The
two catches (ESP and condenser) are recovered and analyzed for sulfuric acid content, and used
to calculate and report condensed and vapor phase sulfuric acid concentrations.
This method may offer advantages over the standard CCS method in situations where the flue
gas sampled is near its acid dew point temperature, as it can be used to determine if a portion of
the sulfuric acid in the flue gas has already condensed or if it all remains in the vapor phase.
Downstream of a wet FGD system, where all of the sulfuric acid would be known to have
condensed, it is not clear that the E.ON modified method offers an advantage over the standard
method other than it avoids the requirement that all of the acid mist droplets be evaporated in the
sampling probe and thimble holder.
A-5
Other SO3 Measurement Methods
A method was developed in 1994 to measure sulfuric acid vapor using a sampling system similar
to the CCS system but with a sodium chloride impregnated filter or a sodium chloride packed
sampling tube to replace the condenser.62 A potential advantage of this method is that it does not
require a water bath to maintain the condenser temperature at a point 20ºF (11oC) above the
water dew point, which could make the method easier to use in the field than the CCS method.
However, it similarly uses a quartz filter or thimble upstream of the sampling tube. Therefore,
the method does not address potential ash/sample gas interactions at the upstream quartz thimble.
A literature search found a few scoping studies for development of spectroscopic methods, which
primarily examined the low resolution and high resolution infrared spectra of sulfuric acid vapor,
to determine if such methods might be possible. Several of these scoping studies occurred in the
early 1970’s, but recent efforts have involved field trials of a semi-continuous monitor that uses
Fourier Transform Infrared (FTIR) spectroscopy to simultaneously detect flue gas concentrations
of sulfuric acid and other species. One EPRI-funded field trial at Vectren’s A.B. Brown Station
determined that the method detection limits in the presence of typical flue gas interfering species
was between 3 and 4 ppm.63 While this detection limit would be adequate for measuring
uncontrolled concentrations, it would not likely be low enough for feedback control of an SO3
control process aimed at achieving “clear stack” operation. Also, because the method was
evaluated for measuring vapor phase sulfuric acid concentrations and not SO3 concentrations, it
would only be applicable downstream of the plant air heater and could not be used for
monitoring at upstream locations, such as at an SCR outlet or an air heater inlet.
The literature search did not identify any emerging measurement technology that might offer
improved ability to measure SO3 or sulfuric acid concentrations in coal or lignite flue gases.
Consequently, it is the opinion of the authors that the CCS method and the E.ON modified
method remain the best methods for measuring flue gas sulfuric acid concentrations. The
following describes results from previous EPRI-funded testing to determine the potential for
measurement biases in the CCS method.
Laboratory and Field Testing of CCS Method
Because of the desire to accurately measure flue gas sulfuric acid concentrations for TRI
reporting and for plume opacity and corrosion troubleshooting purposes, EPRI funded laboratory
work to determine the magnitude of possible biases on CCS method results.64 For impacts that
appeared to be significant, methods were investigated for improving the measurement technique.
Field measurements were then conducted as a proof of concept for these method improvements.
The field sites included electric utility boilers that fire low-sulfur, Powder River Basin coal,
62
D. Cooper and M. Ferm. “Jaemfoerelse av Maetmetoder foer Bestaemning av SO3-Koncentrationer i Roekgaser”
(Comparison of Measurement Methods for Determination of SO3 Concentrations in Flue Gas). Stiftelsen Foer
Vaermeteknisk Forskning, Stockholm, Sweden. Report No. SVF494, January 1994, Swedish.
63
Hall, S., G. Blythe, J. Camin, W. Gray, C. Laush, and R. Rhudy, "Incorporating FTIR to Conduct H2SO4
Measurements at Power Utilities," paper presented at the EPRI CEM Users Group Meeting, Chicago, IL, May 22-
24, 2002.
64
Flue Gas Sulfuric Acid Measurement Method Improvements, EPRI, Palo Alto, CA: 2001. 1004027.
A-6
medium- to high-sulfur eastern bituminous coals, and Texas lignite. Ultimately, no CCS method
modifications were recommended, but some recommendations were made that could improve the
accuracy of data collected by the method.
The following summarizes those recommendations. Results are summarized based on the
location of concern: sampling downstream of a wet FGD and sampling upstream of a particulate
control device.
Results for Sampling Downstream of Wet FGD
Laboratory and field testing indicated that the CCS method should not have any significant
biases when measuring flue gas sulfuric acid concentrations at the two sampling locations most
relevant for determining sulfuric acid emissions from coal-fired power plants: downstream of a
high-efficiency particulate control device, and downstream of a wet FGD absorber. When
sampling downstream of a wet FGD absorber, a 5-ft (3.0-m) or greater sample probe length
should be used and operated at 550oF. Provisions should be made to ensure that the sampling is
not conducted in an area of the duct or stack experiencing high droplet carryover from the FGD
absorber. These provisions include verifying the moisture content of the flue gas at the planned
sample point prior to conducting CCS measurements, measuring the average flue gas moisture
content during the CCS runs, and timing the CCS runs to avoid sampling during the wash cycle
for the mist eliminator section immediately upstream of the sampling location.
Results for Upstream of Particulate Control Device
Laboratory results identified that a low measurement bias might be encountered when measuring
upstream of a particulate device, either at air heater inlet or air heater outlet temperatures. For
acidic ashes from medium- or high-sulfur coals, the bias could be as much as 20 to 25% low, but
for low-sulfur, alkaline ashes from a Powder River Basin coal, the low bias could be 90% or
greater.
For bituminous coals and for Texas lignite, there was no evidence of improvement in the
measurement when adding an inertial particulate control device upstream of the CCS probe. For
PRB coals, the coal fly ash has such an affinity for flue gas SO3, it does not seem likely that any
SO3 or sulfuric acid would be present in the flue gas at these locations. Improvements to the
method to try to measure gas phase SO3 or sulfuric acid concentrations upstream of particulate
control devices at PRB sites does not seem warranted. It was clear that at the ESP outlet location,
where ash loadings to the CCS thimble were below the level where measurement bias would be
expected, sulfuric acid concentrations were very low at 0.2 ppm or less.
Another situation where measurement biases appear to be possible is upstream of the particulate
control device, at either air heater inlet or outlet temperatures, when alkaline sorbents are
injected into the furnace for sulfuric acid control. The presence of reactive sorbents on the
thimble in the CCS train could cause low biases in the results of a CCS measurement at locations
upstream of the particulate control device. For acidic ash coals, a negative bias in the range of 20
to 40% could be possible, depending on the sorbent and injection rate. In such situations, an
A-7
additional, high-efficiency inertial separation device might be used at the CCS sample probe inlet
to reduce the loading of these materials to the CCS thimble. This upstream inertial separation
approach was evaluated during an EPRI-funded evaluation of SO3 removal upstream of the air
heater by the SBS InjectionTM process at Vectren Corporation’s A.B. Brown Station.65 The
results of that evaluation were inconclusive at to whether the inertial separator improved the
quality of SO3 concentration measurements in the presence of the SBS sorbent.
In general, it is best to evaluate the effectiveness of injected sorbents by measuring sulfuric acid
concentrations downstream of the particulate control device, to avoid the potential for this bias.
65
Results of Full-scale Testing of Sodium Bisulfite Injection for Flue Gas Sulfuric Acid Control, EPRI, Palo Alto,
CA: 2002.
A-8
B
APPENDIX — ESTIMATING FLUE GAS SO3
CONCENTRATIONS
Most coal- and oil-fired electric utility boilers will trigger Toxic Release Inventory (TRI)
reporting for sulfuric acid. TRI reporting will, in turn, require that utilities measure and/or
predict annual sulfuric acid manufacture and emissions rates. This section discusses the
engineering tools available for estimating SO3 concentrations in coal flue gases at various points
in the flue gas path. Included in this discussion are the EPA “guidance” for TRI reporting and the
Southern Company Engineering SO3 Estimation Tool.
These estimating tools and their predictions are compared to SO3 data gathered with the CCS
method at various types of power plants as part of other EPRI projects. The information
presented in this section is based largely on a previous EPRI report, Flue Gas Sulfuric Acid
Measurement Method Improvements.66
Existing Sulfuric Acid Emissions Estimating Tools
The authors are aware of two “models” or estimating tools that exist to allow utilities to estimate
sulfuric acid emissions from coal-fired boilers. One is from EPA guidance to utilities on how to
estimate sulfuric acid emissions for TRI purposes, and the other is a more detailed estimation
method developed by the Southern Company. Each approach is briefly described below.
EPA Guidance
In their guidance document for TRI reporting of sulfuric acid emissions,67 EPA suggests a single
conversion rate for all types of coal, with the rate of sulfuric acid manufacture and emissions
representing 0.7% (on a molar basis) of the total uncontrolled SO2 emissions from a boiler.
Uncontrolled SO2 emissions can be estimated from plant continuous emissions monitoring data,
or from the coal sulfur content and the annual coal tonnage.
While the EPA guidance is rather straightforward, information collected from various projects
suggests that fuel and equipment specifics can greatly impact the percentage of sulfuric acid
formed and/or emitted. The EPA guidance makes no provisions for estimating the impacts of
factors such as fuel type or air emissions control equipment on sulfuric acid emissions.
66
Flue Gas Sulfuric Acid Measurement Method Improvements, EPRI, Palo Alto, CA: 2001. 1004027.
67
US EPA. Emergency Planning and Community Right-to-Know Act – Section 313, Guidance for Reporting Sulfuric
Acid, EPA-745-R-97-007. January 1998.
B-1
Appendix — Estimating Flue Gas SO3 Concentrations
The Southern Company Services Engineering Estimation Tool
In 1998, Southern Company Services proposed a tool for estimating airborne sulfuric acid
manufacture and emissions rates for coal-, oil- or natural gas fired power plants. It determines
the sulfuric acid manufacture rate based on uncontrolled SOX production rates and the fuel type.
The estimation tool then considers the impacts of the boiler air heater and of air emissions
control equipment installed on the unit to determine the fraction of the manufactured sulfuric
acid that is emitted from the stack. Southern Company has updated their estimating approach
several times as more data became available.68,69,70
The Southern Company estimating tool includes factors for the percentage of uncontrolled SOX
that is converted in the boiler to airborne sulfuric acid for a number of boiler and fuel types.
They then include factors for determining how much of this sulfuric acid is emitted based on the
average sulfuric acid removal across downstream equipment. They include removal factors for
air heaters, hot- and cold-side ESPs, fabric filters, wet scrubbers, and spray dryer/fabric filter
combinations. A 2001 update to the estimating method included factors for flue gas conditioning
and NOX controls69. The most recent version of the estimating method was released in March
2003, with factors accounting for the operation of a scrubber in partial bypass mode and an
independent factor (rather than coupling with combustion factor) for SCR catalyst oxidation
rate70.
Discussion of Current Estimating Methods Relative to Field SO3

Measurement Data
The results from the field testing described in Appendix A of this report were used to assess the
accuracy of the existing sulfuric acid emissions estimating methods from EPA and from
Southern Company Services. These field test data were supplemented with results of
measurements made on other recent EPRI projects, and data collected by others and reported in
the literature.71,72,73 These assessments are discussed below.
68
Hardman, R, R. Stacy, E. Dismukes, K. Harrison, and L. Monroe. “Estimating Total Sulfuric Acid Emissions
from Coal-Fired Power Plants.” Revised version of a paper presented at the U.S. Department of Energy, FETC
Conference on Formation, Distribution, Impact, and Fate of Sulfur Trioxide in Utility Flue Gas Streams. Pittsburgh,
PA, revision date September 1998.
69
Monroe, L. “An Updated Method for Estimating Total Sulfuric Acid Emissions from Stationary Power Plants.”
Paper prepared by Southern Company Generation and Electricity Marketing, Birmingham, AL, May 2001.
70
Monroe, L. “An Updated Method for Estimating Total Sulfuric Acid Emissions from Stationary Power Plants.”
Paper prepared by Southern Company Generation and Electricity Marketing, Birmingham, AL, March 2003.
71
Rhudy, R. Sulfuric Acid Measurement, EPRI, Palo Alto, CA, August, 1998. Draft report.
72
Field Evaluation of a Utility Spray Dryer System, EPRI, Palo Alto, CA and the U.S. Environmental Protection
Agency, Research Triangle Park, NC, May 1985. EPRI CS-3954.
73
Blythe, Gary et al. “Furnace Injection of Alkaline Sorbents for Sulfuric Acid Control.” Paper presented at the US
EPA/DOE/EPRI Combined Power Plant Air Pollutant Control Symposium: the Mega Symposium, Chicago, IL,
August 20-23, 2001.
B-2
EPA Guidance
In their guidance document for TRI reporting of sulfuric acid emissions,67 EPA suggests a single
conversion rate for all types of coal, with the rate of sulfuric acid manufacture and emissions
representing 0.7% (on a molar basis) of the total uncontrolled SO2 emissions from a boiler. For
the plants included in the data review, the vast majority of the data show that measured sulfuric
acid emissions are lower than what is suggested by this guidance.
For example, for wall- or tangentially-fired units firing eastern bituminous coal, the data review
of 34 measurements at 16 plants showed that at an ESP outlet location, both the mean and
median value for the apparent conversion of SO2 to SO3 was 0.5%. The data review suggests that
on average, such plants with only an ESP for air emissions control would over-report sulfuric
acid emissions by 40% if they used the EPA guidance. Of the 34 measurements, only 7 were at
or above 0.7%.
For wall- or tangentially-fired, eastern bituminous plants with FGD, a data review of 16
measurements at the FGD outlet at 7 plants showed that both the mean and median value for the
conversion of SO2 to SO3 was between 0.2 and 0.3%. All of the individual measurements
showed below 0.7% apparent conversion. At the FGD outlet this apparent conversion value is
based on measured sulfuric acid concentration at that location and the uncontrolled SO2
concentration based on the coal sulfur content. The review suggests that such plants would, on
average, over-report sulfuric acid emissions by over a factor of three if they used the EPA
guidance.
For plants that fire subbituminous western coal or Texas lignite, the discrepancies are even
greater. At two plants that fire Powder River Basin subbituminous coals, ESP outlet
measurements showed 0.01 to 0.1% apparent conversion of SO2 to SO3, and FGD outlet
measurements showed 0.01 to 0.06% conversion based on the uncontrolled SO2 concentrations
calculated from the coal sulfur. Measurements at a plant that fires a Texas medium-sulfur lignite
showed 0.25% apparent conversion of SO2 to SO3 at the ESP outlet, and the equivalent of 0.15%
conversion at the FGD outlet. These data suggest that plants that fire western coals and lignites
could over-report sulfuric acid emissions by as much as an order of magnitude or greater by
relying on the EPA guidance.
At the other extreme, the EPA guidance may under-report sulfuric acid emissions from eastern
bituminous, cyclone-fired plants. One cyclone-fired unit reported CCS measurements at the
stack, downstream of an ESP, corresponding to averages of 0.9 to 1.7% apparent conversion of
SO2 to SO3 at that location. For this plant, the EPA guidance would under-report sulfuric acid
emissions by 20 to 60%.
The EPA guidance is based on an average of data collected for a wide range of coal and lignite
types, boiler types, installed emissions control equipment, and sulfuric acid concentration
measurement techniques. Because all of these factors can cause the observed conversion of SO2
to SO3 to vary over a wide range, a simple average of the data does a poor job of predicting for
most plants. It is clear from this review of the data that only a small number of plants actually
emit sulfuric acid at a rate that is near 0.7% of the uncontrolled SO2 production.
B-3
The Southern Company Services SO3 Estimation Tool
As described above, the Southern Company estimating method includes factors for the
percentage of uncontrolled SO2 that is converted in the boiler to airborne sulfuric acid for a
number of fuel types, including eastern bituminous, western bituminous, Powder River Basin
and other western subbituminous coals, and lignites. It also includes factors for gas and oil firing
and combustions turbines, but these factors are not addressed here. The fuel-impact factors are
labeled “F1” in the estimating method.
The estimating method also includes factors for determining how much of this sulfuric acid is
emitted based on the average sulfuric acid removal across downstream equipment. It includes
removal factors for air heaters, hot- and cold-side ESPs, fabric filters, wet scrubbers, spray
dryer/fabric filter combinations, and furnace sorbent injection for SO3 control. These technology-
impact factors are labeled “F2” in the estimating method. The latest versions also include factors
for flue gas conditioning, NOX controls, and scrubber bypass operation69,70.
The F1 and F2 factors were evaluated individually to see how well the CCS data available in the
literature support the Southern Company estimating method factors. But the overall prediction of
the method is also important to utilities for estimating sulfuric acid impacts on plume opacity.
Therefore the ESP outlet and/or FGD outlet measured values were compared to estimating
method predictions, to see how well the overall predictions compared to field data.
Review of F1 Fuel Impact Factors
Table B-1 summarizes the fuel impact factors used in the most recent version of the Southern
Company estimating method. The factor is multiplied by the uncontrolled SO2 production from
the plant to represent the conversion of SO2 to SO3 in the boiler. The estimating method includes
conversion factors to take into account differences in molecular weight. The F1 factor, if
multiplied by 100, would represent the percent conversion of SO2 to SO3 in the boiler furnace
and back pass, upstream of the air heater. The estimating method includes factors for eastern
bituminous, western bituminous, Powder River Basin, lignite fuels, and petroleum coke fuels.
They also include factors for both wall- and tangential-fired boilers versus cyclone-fired boilers.
The factors for cyclone firing are twice the factors for wall or tangential firing, recognizing that
conversion of SO2 to SO3 is typically higher for cyclone firing. The check marks in the table next
to some of the factors denotes the fuel type and firing type combinations for which comparison
field CCS data were available.
Table B-2 provides a comparison between the Southern Company F1 factors and the factors
determined from a review of available CCS data. Where multiple measurements were available
for comparison, a standard deviation is shown for the calculated factor. Also, the number of sites
and number of data points (where each data point represents an average of several individual
measurements on a single day) are shown for the CCS data.
B-4
Table B-1
Fuel Impact Factors for the Southern Company Estimating Method
Fuel Impact Factor, F1
Coal Type Wall- or Tangential Firing Cyclone Firing
Eastern bituminous 0.008 9 0.016 9
Western bituminous 0.00111 0.00222
Powder River Basin, Western subbituminous 0.000556 9 0.001112
Lignite 0.000556 9 0.001112
Petroleum coke 0.04 0.04
Table B-2
Comparison of Fuel Impact Factors Used in the Southern Company Estimating Method
and Those Determined Experimentally
Average Standard
Factor from Deviation No. of Data
Southern CCS Data (Air of Factor No. of Sites Points
Company Heater Inlet from CCS Represented Represented
Fuel and Firing Type F1 Factor Location) Data in CCS Data in CCS Data
Eastern Bituminous – Wall or 0.008 0.0081 0.0039 7 12

Tangentially Fired
Eastern Bituminous – 0.016 0.023 - 1 1

Cyclone Fired
Powder River Basin, Wall or 0.000556 0.00015 - 1 1

Tangentially Fired
Texas Lignite, Wall or 0.000556 0.0051 0.0030 1 2

Tangentially Fired
North Dakota Lignite, Wall or 0.000556 0.00 0.00 3 3

Tangentially Fired
B-5
The data for the eastern bituminuous, wall- or tangentially fired case show very good agreement
with the Southern Company factor, although it is clear from the standard deviation shown that
there is a wide range of individual values in the data. The individual measurements range from
0.004 (0.4% conversion) to 0.019 (1.9% conversion). For the eastern bituminous cyclone-fired
case, there was only one comparison data point, and that was somewhat higher than the Southern
Company factor. For Powder River Basin coal, one set of measurements was collected as part of
an EPRI study discussed in Appendix A. Those measurements suggest a factor that is about one-
third the factor used in the Southern Company estimate.
For Texas lignite, measurements conducted at one site suggest a factor that is nine times greater
than the factor used by Southern Company. Note that the Southern Company method includes
the same factor for both Powder River Basin subbituminous coal and for lignites, with no
distinction between North Dakota and Texas lignite. Texas lignite typically has higher sulfur
content than North Dakota lignite, and produces an ash that is less alkaline than North Dakota
lignite. One might predict that factors for North Dakota lignite would be similar or equal to those
for Powder River Basin coals, but that the factor for Texas lignite would lie between those for
eastern bituminous and Powder River Basin coals. The data from this project support this
expectation.
For North Dakota lignite, data from the literature for measurements made in one program at three
different sites all showed no measurable sulfuric acid in the flue gas at the air heater inlet,
although the detection limit for their CCS measurements was not reported. Because the detection
limit is not known, Table B-2 shows a measured factor of 0.00, with only two significant digits.
Depending on the detection limits for these data from the literature, the factor of 0.00 could be
within the range of F1 factors shown in the table for other low-sulfur coal conditions.
Review of F2 Technology Impact Factors
Table B-3 summarizes the technology-impact (F2) factors used in the most recent version of the
Southern Company estimating tool. In general, the factor is multiplied by the predicted
uncontrolled SO3 production from the plant to represent the removal of SO3 in the plant air
heater and air emissions control equipment. The F2 factor, if multiplied by 100, would represent
the percent penetration of SO3 across the device or control technology, or 100 minus the percent
removal. The table includes check marks beside the factors for which CCS data were available to
compare to the Southern Company values.
B-6
Table B-3
Summary of F2 Technology Impact Factors Used in the Southern Company Estimating
Method
Technology F2 Technology Impact Factor
Air Heater – Eastern Bituminous Coal 0.50 9
Air Heater – Western Bituminous and Power River Basin Coals, Lignites 0.90 9
Hot-side ESP 1.00
Cold-side ESP 0.50 9
Fabric Filter 0.10
Wet FGD 0.50 9
Spray Dryer/Fabric Filter 0.01 9
MgO Mixed with Fuel Oil 0.50
MgO Injection in Furnace 0.25 9
Table B-4 shows a comparison of the F2 technology impact factors used in the Southern
Company estimating method versus the apparent factors measured by the CCS method in
previous EPRI projects, and in data reported in the literature. Only those factors for which
comparison data are available are shown. In Table B-4, data for medium and high sulfur fuels
(eastern bituminous coal and Texas lignite) are treated separately from data for Powder River
Basin coal. There are no comparison data for western bituminous coal or North Dakota lignite.
B-7
Table B-4
Comparison of Technology Impact Factors Used in the Southern Company Estimating
Method and Those Determined Experimentally
Standard No. of Data

Southern Average Deviation of No. of Sites Points
Technology and Fuel Company Factor from Factor from Represented Represented
Type F2 Factor CCS Data CCS Data in CCS Data in CCS Data
Air Heater – Eastern 0.50 0.81 0.34 4 7

Bituminous and Texas
Lignite
Air Heater – Powder 0.90 1* - 1 1

River Basin
Cold-side ESP – Eastern 0.50 0.77 0.18 6 12

Lignite
Cold-side ESP – Powder 0.50 1* - 1 1

River Basin
Wet FGD – Eastern 0.50 0.50 .20 6 10

Lignite
Wet FGD – Powder River 0.50 0.95 0.07 2 2

Basin
Spray Dryer/Fabric Filter 0.01 0.06 - 1 1

– Eastern Bituminous
Spray Dryer/Fabric Filter 0.01 0.0 - 1 1

– Powder River Basin
MgO Injection in Furnace 0.25 ** ** ** **

– Eastern Bituminous
*All measurements at this site were essentially at the detection limit of the method.
**Field measurements showed that F2 factor is strongly dependent on sorbent injection rate.
The experimental results in Table B-4 show a higher technology impact factor of 0.8 (less
removal) for the air heater, compared to the Southern Company factor of 0.5. However, the
standard deviation on the average for the measured values is high, and the Southern Company
factor lies within one standard deviation of the measured values. It should be noted that the
measurement of SO3 removal across an air heater is very difficult. At many sites, SO3
concentrations at the economizer outlet (air heater inlet) are stratified due to variations in excess
air level and slag buildup in the furnace and back pass. Also, for most eastern bituminous coals,
there can be a substantial variation in the air heater outlet SO3 concentration for Ljungstrom type
air heaters, depending on whether the measurement is made on the hot or cold side of the wheel
as it rotates from combustion air to flue gas exposure. The data from one of the four sites for
which data are included, representing two of the seven measurements used in the average, is
B-8
known to be biased towards the “hot” side of the air heater (i.e., higher air heater outlet SO3
concentrations) as the “cold” side of the wheel (lower concentrations) is difficult to access to
measure. For these reasons, it cannot be stated with confidence that the experimental value of 0.8
shown in Table B-4 represents a better factor for air heater removal than the 0.5 factor used in
the Southern Company estimating method.
For PRB conditions, the one set of experimental data available support the Southern Company
factor that shows little, if any, SO3 removal across the air heater. Actually, as will be discussed
later in this section, the data suggest that for PRB firing, a more accurate approach for estimating
sulfuric acid manufacture and emissions rates may be to use a low F1 fuel impact factor, then
assume no further removal in downstream equipment. The data from the PRB site sampled as
part of the project described in Appendix A showed sulfuric acid concentrations that were
essentially at the detection limit of the CCS method at all four measurement locations, including
the air heater inlet and outlet, ESP outlet, and FGD outlet.
A significant discrepancy is seen between the Southern Company technology impact factor and
the measured values for cold side ESP’s. The Southern Company estimating method uses a
factor of 0.50, while the measured values average nearly 0.8, indicating less removal across a
cold side ESP than the estimating method assumes. The standard deviation for the measured data
is relatively small, at less than 0.2. Of the twelve measurements on eastern bituminous or Texas
lignite sites included in the average, only one corresponds with a factor of 0.50 or lower. As
mentioned above, for a PRB site, the measurements made showed no measurable sulfuric acid
removal across the air heater or any of the downstream control equipment, as all measurements
showed very low sulfuric acid concentrations.
For wet FGD on eastern bituminous coal and medium-sulfur Texas lignite sites, the measured
factor averaged exactly the same as the Southern Company factor. However, the measured data
show that the sulfuric acid removal across an FGD system can vary widely, from less than 30%
to greater than 70%. For wet FGD installed on a PRB site, the data showed essentially no
sulfuric acid removal, while one data point from the literature showed about 10% removal.
However, it should be noted that the measured values were at or near the detection limit for the
CCS method.
For spray dryer/fabric filter FGD systems, the Southern Company estimating method uses a
technology impact factor of 0.01, representing 99% sulfuric acid removal. Data from one high
sulfur, eastern bituminous coal installation showed a factor of 0.06, representing 94% sulfuric
acid removal, while other measurements at that same site while firing a Powder River Basin
blend showed no measurable sulfuric acid downstream of the baghouse.72 The Southern
Company factor is bracketed by these two values.
Another EPRI project has measured the effectiveness of magnesium hydroxide and other alkaline
sorbents injected into the furnace as a means of SO3 control.73 Measured control effectiveness
ranged from less than 50% to greater than 90%, depending on sorbent characteristics, injection
rate and injection location. For this reason, it may be better to use site specific data for the
effectiveness of sorbent injection for SO3 control rather than a generic factor.
B-9
In summary, of the technology impact factors for which comparison data were available, the
apparent sulfuric acid removal across cold-side ESP’s and perhaps across air heaters may be
overstated by the Southern Company factors. It would take more data to develop a convincing
case for changing these factors. For wet FGD on eastern bituminous coal and Texas lignite, the
Southern Company factor is well supported by available data. Similarly, the factor for spray
dryer/fabric filter technology appears to be supported by the data. For PRB coals, an alternate
estimating approach is suggested, where a lower fuel impact factor is used and the effects of
downstream equipment on sulfuric acid removal are considered to be insignificant.
Review of Overall Predictions
Perhaps the most relevant comparison is not to review individual terms, but to compare the
effectiveness of the estimating method for predicting actual sulfuric acid emissions for the units
for which CCS data are available. These emissions estimates are useful for predicting sulfuric
acid impacts on plume opacity. Table B-5 makes comparisons of estimates version measured
sulfuric acid concentrations for a number of combinations of fuel type, boiler type, and air
emissions control equipment.
The data in Table B-5 show that, in general, the Southern Company estimating method under-
predicts the sulfuric acid concentrations measured in the field using the CCS method. The data in
the table represent a total of 59 individual measurement sets, for a variety of coal, boiler and air
emissions control equipment types. Of the 59 individual measurements, the Southern Company
estimating method under-predicted the measured value 47 times, over-predicted 7 times, and
predicted the measured amount (within ±20%) 5 times.
Summary of Review of the Southern Company Estimating Method
Based on a review of the individual factors, the Southern Company estimating method represents
a much more accurate approach for estimating sulfuric acid manufacture and emissions rates
than relying on the EPA guidance. However, it appears that the Southern Company method often
under-predicts sulfuric acid emissions, in most cases because the technology impact factors
included over-predict the amount of sulfuric acid removed across cold side ESPs and across the
air heater on plants that fire eastern bituminous coals.
B-10
Table B-5
Comparison of Estimating Method Predictions versus Measured Values for Sulfuric Acid
Emissions
SO3 Concentrations Compared to

Uncontrolled SO2, %
Percent
Predicted Closure, Number
Fuel Sample from Average Standard (measured/ of Data
Type Boiler Type Location Estimate Measured Deviation predicted) Points
Eastern Wall/Tang. ESP 0.20 0.49 0.24 245 34

Outlet
Eastern Cyclone ESP 0.40 1.30 0.57 325 2

Outlet
Eastern Wall/Tang. FGD 0.10 0.23 0.16 230 15

Outlet
Eastern Wall/Tang. Spray 0.01 0.06 - 600 1

Dryer/FF
Outlet
Powder Wall/Tang. ESP 0.03 0.06 0.06 220 2

River Outlet
Basin
Powder Wall/Tang. FGD 0.01 0.04 0.04 280 2

River Outlet
Basin
Powder Wall/Tang. Spray 0.01 0.0 - - 1

River Dryer/FF
Basin Outlet
Texas Wall/Tang. ESP 0.03 0.25 - 1000 1

Lignite Outlet
Texas Wall/Tang. FGD 0.01 0.15 - 1200 1

Lignite Outlet
However, although the 59 data points used in the comparison in Table B-5 represent a significant
compilation of CCS measurement data, they may not adequately represent the entire population
of coal-fired utility boilers in the U.S. In fact, Southern Company has stated their estimation tool
is based largely on in-house data, and that most plants in the Southern Company system fire low-
sulfur, “compliance” coals. In this evaluation of their estimating method, most of the field data
for eastern bituminous coal was for high-sulfur coals, which most likely behave differently with
respect to SO3 formation and collection than low-sulfur bituminous coals.
B-11
For eastern bituminous coal plants that are considering the need for SO3 controls, a more
conservative (higher) flue gas SO3/sulfuric acid concentration estimate would use the F1 and F2
factors developed from the field CCS data, as shown in Tables B-2 and B-4, respectively, rather
than using the Southern Company factors.
For PRB coals, based on the data collected at one site, it was suggested that sulfuric acid
emissions from plants that fire this coal type be estimated in a different manner than the current
form of the Southern Company estimating method. A lower fuel impact factor of approximately
0.00015 was recommended, with 1.0 as the technology impact factors for the air heater, cold side
ESP, and wet FGD systems.
The Southern Company estimating method treats lignites as a single fuel type, and generally
assigns the same fuel and technology impact factors as for PRB coal. This may be appropriate
for North Dakota lignites, but based on the limited measurement data, medium-sulfur Texas
lignites should be treated as a separate fuel type. A fuel impact factor of approximately 0.005 is
recommended based on the limited amount of data available.
There were a number of technologies for which the Southern Company estimating method
includes factors, but for which there was no available data at the time the comparison described
above was made. For example, no comparison data were available for cyclone boilers with fuel
types other than eastern bituminous coal. Also, there were no data for western bituminous coals,
petroleum coke co-firing, hot-side ESP’s and fabric filters as a particulate control technology
(other than spray dryer/fabric filter combinations for the latter), SCR for NOX control, or SO3
injection for fly ash conditioning. Because SCR retrofits can have a significant impact on flue
gas SO3 concentrations, the authors suggest using the catalyst vendor’s guarantee limit for
conversion of SO2 to SO3 across their catalyst as the basis for estimates.
B-12
C
APPENDIX — SO3 CONTROL PROCESS COST
ESTIMATING WORKSHEETS
These worksheets assume the basic plant layout previously shown in Figure 3-1. It is understood
that not all plants will operate all of the devices listed in Figure 3-1. However, to make these
worksheets usable to the widest variety of plant configurations, the nomenclature used in these
worksheets assumes all of the unit operations exist. When you do not have a given unit
operation, you will still input values for the variables associated with it. For example, if you do
not have an ESP, you will still need to input a value for the variable describing SO3 penetration
across the ESP (F2ESP). In this case the penetration will be 1, indicating no SO3 removal across an
ESP. Or as another example, you may be asked for the flow rate exiting the SCR (VolSCR). If
you do not have an SCR, you will enter in the flow rate exiting the economizer for VolSCR and
you will use that value anytime VolSCR is called.
The condition of the flue gas is always referenced by the name of the device that the gas is
exiting. For example, the variable SO3CSESP refers to the SO3 concentration of the flue gas exiting
the cold-side ESP.
The worksheets are presented in numerical order in the remainder of this appendix.
C-1
Appendix — SO3 Control Process Cost Estimating Worksheets
Worksheet 1 — User Inputs
The purpose of this worksheet is to gather data about the plant’s operation. These data will be
used to estimate the amount of flue gas to be treated and the SO3 emissions. These values will
then be used in subsequent worksheets to determine the approximate annual and capital costs for
the various SO3 control technologies.
Provide the following information about the unit of interest at your plant. Be sure to provide data
in the units specified.
• Enter the unit’s gross load, gross plant heat rate, and annual unit capacity factor (net load and
heat rate can be used alternately, as long as a consistent basis is used for both entries). Enter
the number of months per year that you expect the SO3 control system to be used.
Gross Unit Load [MW] = (Load)
Gross Plant Heat Rate [Btu/kwh] = (HeatRate)
Annual Unit Capacity Factor [%] = (Capacity)
Duration of SO3 control operation

[months/year] = (Months)
• If the unit has an FGD scrubber, enter the following parameters regarding the scrubber.
Fractional FGD bypass [fraction] = (FGDBypass)
Fractional SO2 Scrubbing Efficiency = (SO2Eff)
FGD Reagent Fractional Utilization = (FGDUtiliz)
FGD Reagent Fractional Purity = (FGDPurity)

• FGD scrubbers typically use either lime or limestone as the neutralizing agent. For your
plant’s neutralizing reagent, enter in the molecular weight (NeutMW) and the reagent cost
(NeutCost). If you do not know these values, Table C1-1 gives the molecular weight
(NeutMW) and a suggested unit cost (NeutCost) for lime and limestone.
Neutralizing Reagent Molecular Weight

[lb/lbmol] = (NeutMW)
Neutralizing Reagent Cost [$/ton] = (NeutCost)
C-2
Table C1-1
Suggested Costs for Neutralizing Reagents
Molecular Weight Cost

Neutralizing Reagent [lb/lbmol] [$/ton]
Lime 56 75
Limestone 100 8
• What type of coal does the unit burn? Your choices are Eastern Bituminous and Texas lignite
(see the caveat about Texas Lignite in Section 4 of the report).
Coal Type = (Coal Type)

• Provide data related to the type of coal that is burned. For the EPA F-factors, see Table C1-2.
If you are unsure of the percent conversion of SO2 to SO3 in the boiler, consult Table C1-2.
Coal Higher Heating Value, as received

[Btu/lb] = (CoalHV)
Dry EPA Method 19 F-Factor

[dry scf/MMBtu] = (DryFfactor)
Wet EPA Method 19 F-Factor

[wet scf/MMBtu] = (WetFfactor)
Coal Sulfur Content* [lb SO2/MMBtu] = (CoalS)
Conversion of SO2 to SO3 in boiler [%] = (BoilerConv)
Coal Delivered Cost [$/MMBtu] = (CoalCost)
*If the coal sulfur content is not known in lb/MMBtu, then calculate it from the percent sulfur content in the coal
(Coalwt%S) with the following equation. Insert the resulting value into the line for CoalS above.
20,000 • Coalwt% S
CoalS =
CoalHV
20,000 • _______
=
_______
= __________[lb SO 2 /MMBtu] (CoalS)
C-3
Table C1-2
Suggested Default Answers for Coal-Related Parameters
EPA Method 19 F- EPA Method 19F- Conversion of SO2 to

Factor* Factor* SO3 in Boiler**
Coal Type [dry scf/MMBtu] [wet scf/MMBtu] [%]
Texas Lignite 9860 11950 0.5
Eastern Bituminous 9780 10640 1.0
*Note that standard conditions for EPA F-factors are 1 atm and 68°F.
**Note these boiler SO2 conversion values are for wall-fired and tangentially fired furnaces. Values do not apply for
cyclone boilers.
• Enter the requested variables regarding fly ash. If your plant sells its fly ash, enter the price
that you receive for it in AshPrice. If your plant disposes of its fly ash, enter the cost in
AshDisposal.
Ash content of coal [weight %] = (CoalAsh)
Conversion of Coal Ash to Fly Ash [%] = (%AshConv)
Fly ash sales value [$/ton ash] = (AshPrice)
Ash disposal cost [$/ton ash] = (AshDisposal)

• Calculate intermediate values that will be used in subsequent worksheets. First, calculate the
heat input required for the year. The calculated heat input (HeatInput) accounts for the unit’s
annual capacity and the number of months that SO3 controls will be employed each year.
HeatInput = 7.3 x 10 -3 • Load • HeatRate • Capacity • Months
= 7.3 x 10 -3 • _______ • _______ • ______ • _______
= __________[MMBtu/yr] (HeatInput)
C-4
• Now, calculate the dry lbmol of flue gas (Lbmol0%) to be treated. The following equation
calculates the lbmol of flue gas at 0% O2 because the EPA F-factor (DryFfactor) is based on
stoichiometric combustion. The lbmol of flue gas is calculated on a dry basis, since SO3
measurements with CCS are given on a dry basis.
HeatInput • DryFfactor
Lbmol0% =
385.5
_______• _______
=
385.5
= __________[lbmol/yr at 0% O 2 ] (Lbmol0%)
• The lbmol of flue gas needs to be adjusted for the actual percent oxygen in the flue gas at
each location in the plant. The following calculations assume oxygen contents of 3.5% at
economizer outlet, 3.5% at SCR outlet, 5% at air heater outlet, 5% at ESP outlet, and 6% at
FGD outlet. However, the user can correct the lbmol of flue gas to any O2 concentration
(Lbmolx%) by using the following formula, where x is the percent of oxygen in the flue gas:
Lbmol 0%
Lbmolx % =
(1 − 0.0476 x )
• The dry lbmol of flue gas at the economizer exit (assuming x = 3.5% O2) is:
Lbmol 0%
Lbmol@Econ =
0.833
_______
=
0.833
= __________[lbmol/yr] (Lbmol@Econ)
• The dry moles of flue gas at the SCR exit (assuming x = 3.5% O2) is calculated with the
following equation. If your plant does not have an SCR as part of the baseline scenario, then
enter the value Lbmol@Econ into the line for Lbmol@SCR. Note that in future equations
Lbmol@SCR may be called. If you do not have an SCR, you will still enter the value
Lbmol@SCR.
Lbmol 0%
Lbmol@SCR =
0.833
_______
=
0.833
= __________[lbmol/yr] (Lbmol@SCR)
C-5
• The dry lbmol of flue gas at the air heater exit (assuming x = 5% O2) is:
Lbmol 0%
Lbmol@AH =
0.762
_______
=
0.762
= __________[lbmol/yr] (Lbmol@AH)
• The dry lbmol of flue gas at the ESP exit (assuming x = 5% O2) is:
Lbmol 0%
Lbmol@ESP =
0.762
_______
=
0.762
= __________[lbmol/yr] (Lbmol@ESP)
• The dry lbmol of flue gas at the FGD exit (assuming x = 6% O2) is:
Lbmol 0%
Lbmol@FGD =
0.714
_______
=
0.714
= __________[lbmol/yr] (Lbmol@FGD)
• The actual volumetric flow rate is needed for sizing calculations performed in subsequent
worksheets. For the air heater outlet and ESP outlet flow rates, the actual volumetric gas flow
rate is based on the wet EPA Method 19 F-factors, temperature, and the actual oxygen
concentration at the specified location. The air heater outlet temperature is assumed to be
305°F and the ESP outlet temperature is assumed to be 300°F. The FGD outlet conditions are
assumed to be 125°F and 15% moisture.
C-6
• The actual volumetric flue gas flow rate exiting the air heater (VolAH) assumes an outlet
temperature of 305°F and x = 5% O2.
VolAH = 1.90 • HeatInput • WetFfactor
= 1.90 • _______ • _______
= __________[acf/yr] (VolAH)
• The actual volumetric flue gas flow rate exiting the ESP (VolCSESP) assumes an outlet
temperature of 300°F and x = 5% O2.
VolCSESP = 1.89 • HeatInput • WetFfactor
= 1.89 • _______ • _______
= __________[acf/yr] (VolCSESP)
• The actual volumetric flue gas flow rate exiting the FGD (VolFGD) assumes an outlet
temperature of 125°F, 15% H2O, and x = 6% O2. This calculation assumes that none of the
gas bypasses the FGD.
VolFGD = 1.82 • HeatInput • DryFfactor
= 1.82 • _______ • _______
= __________[acf/yr] (VolFGD)
C-7
Fill in the Table C1-3 with the values you have entered and calculated in this worksheet. This
table will serve as a quick look-up for values used in subsequent worksheets.
Table C1-3
Summary of User Inputs and Calculated Values for Worksheet 1
Variable Name Value Units
Load [MW]
HeatRate [Btu/kwh]
Capacity [%]
Months [months/year]
FGDBypass [fraction]
SO2Eff [fraction]
FGDUtiliz [fraction]
FGDPurity [fraction]
NeutMW [lb/lbmol]
NeutCost [$/ton]
Coal Type
CoalHV [Btu/lb]
DryFfactor [dry scf/MMBtu]
WetFfactor [wet scf/MMBtu]
CoalS [lb SO2/MMBtu]
BoilerConv [%]
CoalCost [$/MMBtu]
CoalAsh [weight %]
%AshConv [%]
AshPrice [$/ton ash]
AshDisposal [$/ton ash]
HeatInput [MMBtu/yr]
C-8
Lbmol0% [lbmol/yr at 0% O2]
Lbmol@Econ [lbmol/yr]
Lbmol@SCR [lbmol/yr]
Lbmol@AH [lbmol/yr]
Lbmol@ESP [lbmol/yr]
Lbmol@FGD [lbmol/yr]
VolAH [acf/yr]
VolCSESP [acf/yr]
VolFGD [acf/yr]
C-9
Worksheet 2 — Calculation of Baseline SO3 Emissions
This worksheet provides a method for estimating the baseline (BL) SO3 profile. However, if you
know the actual SO3 concentrations, use those values instead of the estimation method. The
baseline profile refers to the pre-SO3-controls profile. If an SCR is planned for the unit, include
the SCR as part of the baseline profile.
Step 1: Enter SCR inputs for plant.
If the plant has or will have an SCR, enter the conversion of SO2 to SO3 across the SCR. If this
value is not known, use either the manufacturer’s guarantee or a default value of 1.0% for a
conservative estimate. Conversion values typically range from 0.5 to 1.0%.
Please note that these worksheets assume that a plant will have an SCR. If your plant does not
have an SCR, enter 0% in the line below and use this value anytime the SCRConv variable is
called in these worksheets.
SCR Conversion of SO2 to SO3 [%] (SCRConv)

Step 2: Choose SO3 penetration factors (F2 factors) for unit operations in the plant.
In 1998 Southern Company Services proposed a method for estimating airborne sulfuric acid
manufacture and emissions rates for power plants.69 The model determines the sulfuric acid
manufacture rate based on uncontrolled SOx production rates and the fuel type. The model then
considers the impacts of the air heater and of air emissions control equipment to estimate stack
emissions. These impacts are quantified by the so-called F2 factors, which indicate the fractional
penetration of SO3 across a device. In general, the F2 factor for a device is multiplied by the
predicted uncontrolled SO3 production from the plant to represent the removal of SO3 in the
plant air heater or air emissions control equipment. The F2 factor, if multiplied by 100, would
represent the percent penetration of SO3 across the device or control technology, or 100 minus
the percent removal.
A set of F2 factors was originally developed by Southern Company. However, due to the model’s
observed tendency to under-predict sulfuric acid emissions rate for high-sulfur, eastern
bituminous coals, average values from a survey of CCS measurements are given instead.64 Note
that these measurements were performed on units that did not have SCR installed. The little data
that are available seem to indicate that the F2 factors increase slightly when an SCR is operating.
For example, at one plant operating with an SCR the combined F2 factor for the air heater and
CSESP was 0.83, and the F2 factor for the FGD was 0.89.74 If you have plant data regarding the
SO3 concentrations with an SCR in service, use that data in this worksheet.
74
Sulfuric Acid Removal Process Evaluation: Long-term Results. EPRI, Palo Alto, CA, U.S. Department of Energy,
Columbus, OH, and FirstEnergy, Shippingport, PA: 2002.1004165.
C-10
Consult Table C2-1 for the F2-factors for each unit operation, or use your own F2 factors, if
known. If the plant does not utilize the unit operation, use a value of 1.0 (representing no
removal of SO3). For a worst case analysis of sulfuric acid emissions, use a value of 1.0 for each
F2 factor. No removal across the unit operations is an unlikely situation, but it does provide a
bracketing (or limiting) case. Note that spray dryer/fabric filters are not included in this table. In
general, the outlet SO3 concentrations from a spray dryer/fabric filter are low.
SO3 Penetration through Hot Side ESP = (F2HSESP)
SO3 Penetration through Air Heater = (F2AH)
SO3 Penetration through Cold Side ESP = (F2CSESP)
SO3 Penetration through Wet FGD = (F2FGD)

Table C2-1
F2 Factors for SO3 Penetration across Unit Operations
Standard Number of Number of

Average F2 Deviation of Sites Data Points
Unit Operation Factor from Factor from Represented Represented
Notation and Fuel Type CCS Data CCS Data in CCS Data in CCS Data
F2HSESP Hot-side ESP – 1.0* N/A N/A N/A

Eastern
Bituminous and
Texas Lignite
F2AH Air Heater – 0.81 0.34 4 7

Eastern
Bituminous and
Texas Lignite
F2CSESP Cold-side ESP – 0.77 0.18 6 12

Eastern
Bituminous and
Texas Lignite
F2FGD Wet FGD – 0.50 0.20 6 10

Eastern
Bituminous and
Texas Lignite
*CCS data not available for hot-side ESP. Value of 1.0 taken from Southern Company Model.70
C-11
Step 3: Calculate the SO2 concentration (SO2ppm) at the exit of the boiler.
Alternatively, if the SO2 concentration exiting the boiler is known, enter that value for SO2ppm
and ignore the calculation. For these calculations it is assumed that the boiler exit O2
concentration is 3.5%.
5.01 x 10 6 • CoalS
SO2ppm =
DryFfactor
5.01 x 10 6 • _______
=
_______
= __________[ppm] (SO2ppm)
Step 4: Calculate the SO3 concentration at the exit to each unit operation in the plant.
The calculations are based on the penetration (F2) factors assigned in Step 3. If you know the
actual SO3 concentrations for your plant, use those values instead of these calculations.
Note that using an F2 factor of 1.0 will account for a plant not having a particular unit operation.
For example, if the plant does not have a cold-side ESP (CSESP), the F2CSESP will be 1. The
concentration of SO3 exiting CSESP will be calculated as:
SO3CSESP = SO3AH • F2CSESP

= SO3AH • 1
= SO3AH
Therefore the value you calculate for SO3CSESP would be equal to the SO3 concentration exiting
the air heater. In future equations, the variable SO3CSESP will be called, and you will use the value
SO3CSESP that you calculate by the method below, even though the plant may not actually have a
cold-side ESP. The same reasoning applies to an HSESP, SCR, and FGD.
Step 4a: SO3 concentration at exit to the economizer (SO3Econ,BL).
SO2 ppm • BoilerConv

SO3Econ,BL =
100
_______• _______
=
100
= __________[ppm] (SO3Econ,BL)
C-12
Step 4b: SO3 concentration at exit of hot side ESP (SO3HSESP,BL).
SO3HSESP,BL = F2HSESP • SO3Econ, BL
= _______• _______
= __________[ppm] (SO3HSESP,BL)
Step 4c: SO3 concentration at exit of SCR (SO3SCR,BL).
SCRConv • SO2 ppm

SO3SCR,BL = SO3HSESP , BL +
100
_______ • _______
= _______ +
100
= __________[ppm] (SO3SCR,BL)
Step 4d: SO3 concentration at exit of air heater (SO3AH,BL).
SO3AH,BL = F2AH • SO3SCR , BL
= _______• _______
= __________[ppm] (SO3AH,BL)
Step 4e: SO3 concentration at exit of cold-side ESP (SO3CSESP,BL).
SO3CSESP,BL = F2CSESP • SO3AH , BL
= _______• _______
= __________[ppm] (SO3CSESP,BL)
Step 4f: SO3 concentration at exit of wet FGD scrubber (SO3FGD,BL).
SO3FGD,BL = [
SO3CSESP ,BL F2FGD • (1 − FGDBypass + FGDBypass ) ]
= _______ • [________ • (1 − _______ ) + _______ ]
= __________[ppm] (SO3FGD,BL)
C-13
Step 5: The baseline stack concentration of SO3 (vapor phase or condensed sulfuric acid) is
equal to the SO3 concentration exiting the FGD.
SO3stack,BL = SO3FGD , BL
= __________[ppm] (SO3stack,BL)
Step 6: Identify the target stack SO3 concentration that the control technology should achieve.
Target stack SO3 concentration [ppm] (SO3stack,target)
Fill in Table C2-2 with the values you have entered and calculated in this worksheet. This table
will serve as a quick look-up for values used in subsequent worksheets.
Table C2-2
Summary of User Inputs and Calculated Values for Worksheet 1
SCRConv [%]
F2HSESP [fraction]
F2AH [fraction]
F2CSESP [fraction]
F2FGD [fraction]
SO2ppm [ppm]
SO3Econ,BL [ppm]
SO3HSESP,BL [ppm]
SO3SCR,BL [ppm]
SO3AH,BL [ppm]
SO3CSESP,BL [ppm]
SO3FGD,BL [ppm]
SO3stack,BL [ppm]
SO3stack,target [ppm]
C-14
Worksheet 3 — Fuel Blending Economics
The purpose of this worksheet is to calculate the annual operating costs incurred by switching to
a blend of a low-sulfur coal and the unit’s currently-fired coal. This worksheet gives the user the
option of blending in a Low-Sulfur Eastern Bituminous (LSEB) coal, a Western subbituminous
coal, or a coal of the user’s choice. The first step of this worksheet is to calculate the blend
fractions needed for each of the coals to achieve the targeted SO3 concentration at the stack. The
targeted stack SO3 concentration was identified in Worksheet 2.
The calculations in this worksheet are an iterative process. First, guess the fraction of the low-
sulfur coal that will be placed into the blend. Then, calculate the projected SO3 concentration at
the stack and compare to the targeted SO3 concentration at the stack. Increase or decrease the
fraction of the second coal to be blended and repeat the calculation until the SO3 values match, or
the maximum benefit is achieved (i.e. 100% low-sulfur coal).
This worksheet does not estimate capital costs for fuel blending, as the capital requirements for
this technology are very site specific. Some plants may require little or no capital changes, while
other plants may require extensive revisions such as coal blending conveyors, increased mill
capacity, soot blower upgrades, ESP enhancements, etc. If you have an estimate for the installed
capital cost for fuel blending (BlendCC) for your plant, enter it on the line below.
Capital Cost [$] (BlendCC)
Table C3-1 gives the characteristics of a typical LSEB and a Western subbituminous coal. If you
choose to blend a coal of your own choice, fill in the properties of the coal into the table. The
assigned variable names for these values are given in the second column of the table and will be
used throughout this worksheet.
Table C3-1
Suggested Properties of Typical Coals for Fuel Blending
Parameters for
Western User’s Choice
Variable Name LSEB Subbituminous of Coal
Heating Value [Btu/lb] Coal2HV 12000 8500
EPA Method 19
Coal2Ffactor 9780 9780
F-Factor [dscf/MMBtu]
Coal Sulfur Content [lb

Coal2S 0.83 1.18
SO2/MMBtu]
C-15
Step 1: Guess the fractional BTU input to be supplied by low-sulfur (LS) coal.
The value should be between 0 and 1. As a first guess, you might try a value equal to the
fractional SO3 reduction required at the stack.
Fractional BTU input from LS coal (XLS)
Step 2: Calculate the F-factor for the blend (Ffactorblend).
Ffactorblend = (1 − X LS ) • DryFfactor + X LS • Coal 2 Ffactor
= (1 − _______) • _______ + _______ • _______
= __________[dscf/MMBtu] (Ffactorblend)
Step 3: Calculate the sulfur content for the blend (BlendS).
BlendS = (1 − X LS ) • CoalS + X LS • Coal 2S
= (1 − ______) • _______ + _______ • _______
= __________[lb SO 2 /MMBtu] (BlendS)
Step 4: Calculate the SO2 concentration at the exit of the boiler for the blend (SO2blend). For this
calculation, the assumed oxygen concentration at the boiler outlet is 3.5%.
5.01 x 10 6 • BlendS
SO2blend =
Ffactor blend
5.01 x 10 6 • _______
=
_______
= __________ [ppm] (SO2blend)
C-16
Step 5: Determine the boiler conversion of SO2 to SO3 for the blend of coals (BlendConv). The
boiler conversion for the blend depends upon the type of coal your are blending into the fuel.
• If you are blending in a LSEB coal, the boiler conversion of SO2 to SO3 for the blend is
assumed to be the same as for the original coal (BlendConv = BoilerConv).
• If you are blending in a western subbituminous coal, use the following equation to determine
the boiler conversion of SO2 to SO3 for the blend. This simple equation is based on a limited
amount of experience at a single plant that have been used to estimate the new boiler
conversion of SO2 to SO3.
For Western subbituminous, if XLS < 0.5, then
BlendConv = − 2.0 • X LS + BoilerConv
= − 2.0 • _______ + ________
= __________[%]
For Western subbituminous, if XLS ≥ 0.5, then
BlendConv = 0 [%]
BlendConv = [%] (BlendConv)
Step 6: Calculate the stack SO3 emissions for the blend (SO3stack,blend).
SO3 stack.blend
= SO blend
•
(BlendConv • F 2
HSESP
+ SCRConv )
• F2AH
2
100
[
• F2CSESP • (1 − FGDBypass ) • F2FGD + FGDBypass ]
______ •
(______ • ______ + _____ ) • _______
=
100
• _______ • [(1 − _______ ) • _______ + _______ ]
= _________[ppm] (SO3stack,blend)
C-17
Step 7: Iterate to find the XLS needed to achieve the target stack SO3 concentration.
The targeted stack SO3 concentration was identified in Worksheet 2. Write this value in the line
below.
Target Stack SO3 Concentration [ppm] (SO3stack,target)
If SO3stack,blend > SO3stack,target then increase the fraction of low-sulfur coal (XLS) in the blend in
step 1 and repeat steps 2 through 5.
If SO3stack,blend < SO3stack,target then decrease the fraction of low-sulfur coal (XLS) in the blend in
step 1 and repeat steps 2 through 5.
When SO3stack,blend = SO3stack,target, you have arrived at the minimum required fraction of coal that
must be blended to achieve the target stack SO3.
If XLS = 1 and SO3stack,blend > SO3stack,target, then you have achieved the maximum benefit possible
with coal switching.
Use Table C3-2 to keep track of you iterative guesses.

Table C3-2
Log of Iterative Guesses for Determining Coal Blending Fractions
Trial # XLS Ffactorblend BlendS SO2blend SO3stack,blend
XLS to achieve target SO3 at stack (XLSfinal)
SO2blend for XLSfinal (SO2blend,final)
C-18
Step 8: Calculate the annual increased fuel cost for using low sulfur coal in the fuel blend. The
annual cost is computed only for the portion of the year in which SO3 controls will be
operational. This time period was specified in Worksheet 1 and is incorporated into the variable
HeatInput.
The user must supply the differential cost between the currently burned coal and the low-sulfur
coal. The cost differential is calculated as the cost of the low-sulfur coal minus the cost of the
current coal.
Cost Differential between Low-Sulfur

Coal and Current Coal [$/MMBtu] (CoalCostDifferential)
FuelCost = HeatInput • X LSfinal • CoalCostDifferential
= _______ • _______ • _______
= __________[$/year] (FuelCost)
Step 9: Calculate the annual extra SO2 allowance benefit.
The decrease in tons of SO2 emissions (∆SO2) is calculated with the following equation.
∆SO2 = 5x10 −4 • HeatInput • (CoalS − BlendS )
• (1 − SO2 Eff ) • (1 − FGDBypass)
= 5x10 −4 • _______• (______ − _______ )
• (1 − _______ ) • (1 − _______)
= __________[ton SO 2 /year] (∆SO2)
The decrease in SO2 emissions may translate to monetary value in terms of an SO2 allowance
credit (SO2Credit). The SO2 credit value is subject to market forces, and thus making future
predictions of value difficult. At the time of publication of this report, SO2 credit values were in
the range of $250/ton.
SO2Credit = ∆SO2 • CreditValue
= _______ • _______
= __________[$/year] (SO2Credit)
C-19
Step 10: Calculate the decrease in cost for the decrease in FGD reagent used (NeutSavings).
HeatInput • ( CoalS − BlendS ) • SO2 Eff • NeutMW • NeutCost

NeutSavings =
1.28x10 5 • FGDUtiliz • FGDPurity
_______• (________ − _______ ) • _______ • _______• _______

=
1.28x10 5 • _______• _______
= __________[$/year] (NeutSavings)
Step 11: If your plant produces gypsum for sale, your gypsum revenues (∆GypsumSales) will
approximately decrease by the ratio of the coal blend sulfur content (BlendS) to your original
coal sulfur content (CoalS). Use your current annual revenues [$/year] from the sale of gypsum
for the variable CurrentGypsumRevenues.
 BlendS 
∆GypsumSales = CurrentGypsum Re venues • 1 − 
 CoalS 
 ________ 
= ________ • 1 − 
 ________ 
= __________[$/year] (∆GypsumSales)
Step 12: If your plant disposes of its FGD byproduct (either gypsum or sulfite product), calculate
the savings in disposal costs. This savings (FGDDispose) is calculated as ratio of the blend sulfur
content to the origingal coal sulfur content. Use your current gypsum/suflite disposal costs for
the variable CurrentGypsumDisposalCost.
 BlendS 
FGDDispose = CurrentGypsumDisposalCost • 1 − 
 CoalS 
 ________ 
= ________ • 1 − 
 ________ 
= __________[$/year] (FGDDispose)
Step 13: If your plant disposes of its fly ash, calculate the cost to dispose of the extra fly ash
produced from firing the coal blend. This calculation assumes that the CSESP maintains its
efficiency collection when the fuel feed is switched to the blended coal. It assumes that this
efficiency is near 100%. If the calculated value is negative, it indicates that less fly ash is formed
with the coal blend, and your disposal costs will be less. The variable AshDisposal refers to the
cost per ton to dispose of the ash, tabulated in Worksheet 1.
C-20
AshDispose = 0.05 • HeatInput • AshDisposal • % AshConv • X LSfinal
 Coal 2 Ash CoalAsh 

• − 
 Coal 2 HV CoalHV 
= 0.05 • _______ • _______ • ______ • _______
 _______ _______ 
•  − 
 _______ _______ 
= __________[$/year] (AshDispose)
Step 14: If your plant sells its ash, calculate the gain in fly ash sales. A negative answer indicates
that less ash will be produced and you will lose fly ash sales.
ExtraAsh$ = 0.05 • HeatInput • Ash Pr ice • % AshConv • X LSfinal
 Coal 2 Ash CoalAsh 

• − 
 Coal 2 HV CoalHV 
= 0.05 • _______ • _______ • ______ • _______
 _______ _______ 
•  − 
 _______ _______ 
= __________[$/year] (ExtraAsh$)
Step 15: Calculate the total annual cost for coal blending (BlendOC).
BlendOC = FuelCost − SO2 Credit − NeutSavings + ∆GypsumSales − FGDDispose
+ AshDipose − ExtraAsh$
= __________ − __________ − __________ + ___________ − _________
+ _________− _________
= __________[$/year] (BlendOC)
C-21
Step 16: Fuel switching to a lower sulfur coal can result in boiler efficiency savings, due to the
ability to operate at a lower air heater exit temperature. Consult Worksheet 6 for instructions on
calculating the boiler efficiency savings. Enter the result on the following line.
Boiler Efficiency Savings [$/year] (BlendBE)
Step 17: Fill in the table with the fuel blending capital and operating costs calculated in this
worksheet.
Table C3-3
Summary of Costs Associated with Fuel Blending
Boiler Efficiency
Annual Operating Cost Savings Capital Cost
[$/year] [$/year] [$]
Fuel Blending __________ __________ __________

(BlendOC) (BlendBE) (BlendCC)
C-22
Worksheet 4 — Economics of Injection Technologies
The purpose of this worksheet is to calculate the capital and annual costs for each of the sorbent-
based SO3 control options. The options covered by this worksheet include:
• Addition of OmniClearTM to the fuel;
• Furnace injection of Mg(OH)2 [for plants without SCR];
• Furnace injection of Mg(OH)2 + dry Ca(OH)2 injection upstream of ESP;
• Injection upstream of air heater of
– MgO, and
– SBS;
• Injection upstream of particle collection device of
– SBS,
– ammonia,
– dry hydrated lime,
– humidification with lime injection, and
– hydrated lime and sodium bicarbonate mixture.
Each option is considered within a separate subsection in this worksheet. The capital costs are
estimated based on simplified formulas that are proportional to the projected reagent
consumption at peak load. The annual costs are estimated based on simplified formulas that are
proportional to the amount of reagent projected to be used each year. For each option, the
required SO3 removal needed to achieve the target stack SO3 concentration is calculated to
estimate the required injection molar ratio of reagent to SO3. Injection technologies that are
located upstream of the air heater can provide savings in boiler efficiency. Worksheet 6 provides
a methodology for estimating the potential cost savings.
First, establish the product costs and transportation costs on a $/ton basis for each of the possible
injection reagents. The product and transportation costs will be added to determine a delivered
cost of reagent.
C-23
Reagent Costs
For most of the injection technologies, the primary driver of the annual operating cost is the cost
of the reagent itself. Table C4-1 provides suggested costs for the various injection reagents. If
you have vendor quotes for these materials, please use those values instead. The table provides a
place for you to enter your choice for the cost of each product. The variable names assigned to
the cost for each of the reagents are also listed in the table.
Table C4-1
Reagent Costs Selected for Injection Technologies
Your Choice for Unit

Reagent Suggested Unit Cost Variable Name Cost
OmniClearTM $75/ton f.o.b., $100/ton delivered CostOmni
Magnesium $210/dry ton Mg(OH)2 f.o.b. for

Hydroxide commercial product
[Mg(OH)2]
$100/dry ton Mg(OH)2 f.o.b. for
byproduct Mg(OH)2 produced at CostMag
off-site location
$67/dry ton Mg(OH)2 for on-site

production of byproduct Mg(OH)2
Dry Hydrated Lime $75/ton delivered from Midwest

CostLime
plant
MgO $400/ton f.o.b. CostMgO
SBS $300/dry ton available Na as

Na2SO3, delivered from Green
River, WY; equivalent to $822/dry CostSBS
ton Na as Na, delivered; report
cost in terms of dry ton Na as Na
Ammonia $300/ton delivered from existing

CostNH3
plant system
Sodium $290/ton f.o.b.

CostBicarb
Bicarbonate
C-24
For the magnesium hydroxide injection process, you have three choices for obtaining the reagent
material. The choices are: (1) purchase commercially-made product from a vendor; (2) purchase
magnesium hydroxide as a byproduct from another power plant; or (3) produce your own
byproduct magnesium hydroxide by modifying an existing Thiosorbic® lime FGD process.
Choose the method that you prefer for obtaining the magnesium hydroxide. The suggested cost
listed for byproduct magnesium hydroxide is for on-site production via the Thiosorbic® lime
process, as estimated by Benson.75 The suggested cost includes the cost of Thiosorbic ® lime for
the process, which is assumed to be $50/ton delivered.
Transportation Costs
This section calculates the shipping cost in $/ton for each of the reagents. Please note that Table
C4-2 allows you to calculate shipping costs for all of the reagents. However, some of the
suggested costs are given for the delivered reagent. Be sure to enter a transportation cost of $0,
rather than following the formulas, if you are using a delivered cost estimate for a reagent.
For some reagents, you may know of a manufacturer and have a product and shipping cost.
However, if you do not have this information, Table C4-2 lists the reagents and potential sites
from which they are shipped. This list of locations is not intended to be complete. In the third
column of the table, enter the shipping distance between your plant and the chosen shipping
location.
Table C4-2
Shipping Locations for Injection Reagents
Reagent Possible Shipping Locations Distance to your Plant [miles]

TM
OmniClear Chicago, IL;
Cleveland, OH;
Birmingham, AL
Commercial Mg(OH)2 Manistee, MI
Byproduct Mg(OH)2 Currently available from plants using

magnesium enhanced lime FGD
systems75
Dry Hydrated Lime Contact the National Lime

Association for nearest lime supplier
MgO Manistee, MI
SBS Green River, WY; Tuscaloosca, AL;

Evansville, IN
Ammonia Available nationwide
Sodium Bicarbonate Old Fort, OH

Green River, WY
75
C-25
Multiply the shipping miles by the unit shipping cost to get a $/ton shipment cost. Shipment by
truck costs $0.12/ton/mile. Use this value if you do not have your own freight estimate. Use the
following table to store your data. Remember, if you are using a delivered cost estimate for a
reagent, enter a shipping cost of $0.
Magnesium hydroxide is normally shipped as a slurry. The transportation cost equation for
magnesium hydroxide must be divided by the fractional slurry content to account for the mass of
the entire slurry to be shipped. Commercially available magnesium hydroxide slurry typically
contains a 0.60 fraction of pure Mg(OH)2 solids. Byproduct magnesium hydroxide slurry
typically contains a 0.18 fractional solids, of which a 0.65 fraction is pure Mg(OH)2.
Table C4-3
Unit Shipping Costs in [$/ton] for each Reagent
Shipping Cost = Shipping

Reagent Distance to Plant • Freight Cost Cost [$/ton] Variable Name
OmniClearTM = _______[miles] • _______[$/ton/mile] OmniTrans
Mg(OH)2 _______[miles] • _______[$/ton/mile] MagTrans

=
_____[fractional pure solids content]
if receiving commercial or byproduct
Mg(OH)2
OR
=0
if on-site production of byproduct Mg(OH)2
Dry Hydrated Lime _______[miles] • _______[$/ton/mile] LimeTrans
MgO _______[miles] • _______[$/ton/mile] MgOTrans
SBS _______[miles] • _______[$/ton/mile] SBSTrans
Ammonia _______[miles] • _______[$/ton/mile] NH3Trans
Sodium Bicarbonate _______[miles] • _______[$/ton/mile] BicarbTrans
C-26
Delivered Cost Calculations
Add the product cost and transportation costs determined above to obtain the delivered cost for
each reagent. Record your data in Table C4-4.
Table C4-4
Delivered Costs for Reagents Used in Worksheet 4
Delivered Cost =
Product Cost + Delivered Cost
Reagent Transportation Cost [$/ton delivered] Variable Name
=CostOmni + OmniTrans
OmniClearTM OmniDelivCost
=_______ + _______
Magnesium Hydroxide =CostMag + MagTrans

[Mg(OH)2] MagDelivCost
=_______ + _______
=CostLime + LimeTrans
Dry Hydrated Lime LimeDelivCost
=_______ + _______
=CostMgO + MgOTrans
MgO MgODelivCost
=_______ + _______
=CostSBS + SBSTrans
SBS SBSDelivCost
=_______ + _______
=CostNH3 + NH3Trans
Ammonia NH3DelivCost
=_______ + _______
=CostBicarb + BicarbTrans
Sodium Bicarbonate BicarbDelivCost
=_______ + _______
OmniClearTM Addition to the Fuel
The costs associated with addition of Omni Material’s OmniClearTM to the coal feed are
calculated in this section. Costs are based upon information provided in promotional literature
from Omni Materials, Inc.76 While Omni Material’s literature provides results from full-scale
testing at three facilities, there is not enough information to quantify the effect of feed rate on
SO3 removal. However, two theoretical scenarios are presented in the literature. In the first case,
76
C-27
an addition rate of 0.5% of the coal is assumed to lower the stack SO3 emissions by 55%. In the
second case, an addition rate of 1.0% of the coal lowers the stack SO3 emissions by 86%.
In the absence of additional data, these two theoretical scenarios are used to determine the
required feed rate of OmniClearTM to the coal. The reaction is assumed to be surface area limited.
Therefore, the percent removal of SO3 is assumed to be constant for a given percent addition
rate, no matter the inlet SO3 concentration. A linear relationship between percent removal and
percent feed rate is assumed between the two theoretical points. Obviously, more data are needed
to be able to better estimate additive rates for this control technology.
Step 1: Calculate the percent reduction (Omni%Red) of SO3 needed at the stack to achieve the
target stack SO3 concentration.
 SO3Stack ,t arg et 
Omni%Red = 1 −  • 100
 SO3Stack , BL 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (Omni%Red)
Step 2: Determine the addition rate of OmniClearTM (in terms of % of coal feed) to achieve the
desired percent reduction in SO3. The following correlation is valid only for target percent
removals between 55% and 86%.
Omni%Feed = − 0.387 + 0.0162 • Omni% Re d
= − 0.387 + 0.0162 • _______
= __________[%] (Omni%Feed)
Step 3: Determine the amount of OmniClearTM needed for one year’s operation.
HeatInput • Omni% Feed

TonOmni = 5•
CoalHV
_______ • _______
= 5•
_______
= __________[ton/yr] (TonOmni)
C-28
Step 4: Calculate the annual operating costs for the OmniClear process.
The annual operating cost for OmniClearTM (OmniOC) addition is calculated with the following
equation. The operating cost consists of the reagent and pneumatic air cost.
OmniOC = 1.08 • OmniDelivCost • TonOmni
= 1.08 • _______ • _______
= __________[$/year] (OmniOC)
Step 5: Addition of OmniClearTM to the coal feed can result in boiler efficiency savings, due to
the ability to operate at a lower air heater exit temperature. Consult Worksheet 6 for instructions
on calculating the boiler efficiency savings. Enter the result on the line below.
Boiler Efficiency Savings [$/year] (OmniBE)
Step 6: The capital costs estimate is based upon information provided by Omni Materials.16 A
system designed to feed a maximum 1900 lb/hr of OmniClear has a installed capital cost of
$1.3/kw, while a system designed to a maximum feed 3800 lb/hr has a capital cost of $2.0/kw.
These two points were used to form a linear regression of capital cost versus feed rate.
TonOmni
OmniCC = 1.04x10 6 + 2.44x10 4 •
Capacity • Months
_______
= 1.04x10 6 + 2.44x10 4 •
_______• _______
= __________[$] (OmniCC)
Step 7: Summarize the operating and capital costs for OmniClearTM in the table below.
Table C4-5
Summary of Calculated Costs for OmniClearTM Addition to Coal Feed
Boiler Efficiency Capital Cost

Annual Operating Cost Savings [$]
[$/year] [$/year]
OmniClearTM __________ __________ __________

(OmniOC) (OmniBE) (OmniCC)
C-29
Magnesium Hydroxide (Boiler Injection) – for plants without SCR
The costs associated with furnace injection of magnesium hydroxide slurry are calculated in this
section. You may choose to inject a commercially available magnesium hydroxide or byproduct
from a Thiosorbic® Lime Process. These calculations enable you to calculate the economics for
both reagent types.
Furnace injection of magnesium hydroxide does not reduce SO3 formation across the SCR.
Therefore, these calculations are intended for a plant operating without an SCR. Plants with an
SCR that wish to utilize Mg(OH)2 injection may need to couple it with dry hydrated lime
injection upstream of the ESP. See the following section for calculations for this dual control
method. Alternately, plants with an SCR that require only a moderate overall SO3 control
percentage may be able to use Mg(OH)2 injection alone.
Keep in mind that ESP operational problems are possible with Mg(OH)2 injection, when SO3
concentrations become too low to provide conditioning of fly ash.
Step 1: Calculate the SO3 concentration at the economizer outlet (SO3Econ,target) that corresponds
to the targeted stack SO3 concentration. This calculation assumes that reductions in SO3 by each
unit operation downstream of the economizer are not affected by the presence of the magnesium
hydroxide.
Econ,target SO3stack ,t arg et

SO3 =
F2HSESP • F2AH • F2CSESP [
• F2FGD • (1 − FGDBypass ) + FGDBypass ]
_______
= _______• _______• _______ • [______ • (1 − _______ ) + _______ ]
= __________[ppm] (SO3Econ,target)
Step 2: Calculate the percent reduction (Mg%Red) of SO3 needed at the economizer outlet to
meet the target economizer outlet concentration.
 SO3Econ ,t arg et 
Mg%Red = 1 −  • 100
 SO3Econ ,BL 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (Mg%Red)
C-30
Step 3: The chart below shows the percent SO3 reduction at the economizer outlet versus
Mg:SO3 molar ratio (based on baseline economizer outlet SO3 concentration). Look up the
percent reduction (Mg%Red) on the y-axis of the chart below. Pick off the corresponding
Mg:SO3 molar ratio on the x-axis. This stoichiometry chart applies to both commercial and
byproduct magnesium hydroxide injection.
100
90
Percent SO 3 Reduction at Economizer Outlet
80
70
60
50
40
30
20
10
0
0 1 2 3 4 5 6 7 8
Mg:SO3 Molar Ratio
(based on economizer outlet SO3 concentration)
Figure C4-1
Stoichiometry Curve for Magnesium Hydroxide Injection at Furnace (Adapted from
Benson75)
Required Mg:SO3 (Mg:SO3)
Step 4: Given the stoichiometry assumed in step 3, calculate the mass of dry magnesium
hydroxide used in one year’s operation.
TonMag = 2.91 x 10 -8 • Mg : SO3 • SO3Econ, BL • Lbmol @ Econ
= 2.91 x 10 -8 • _______ • _______ • ______
= __________[dry ton Mg(OH) 2 /year] (TonMag)
C-31
Step 5: Estimate the annual operating costs (MagOC) for Mg(OH)2 injection. Use the delivered
product cost (MagDelivCost) determined at the beginning of this worksheet.
MagOC = 1.03 • MagDelivCost • TonMag
= 1.03 • ______[$/dry ton] • _______
= __________[$/year] (MagOC)
Step 6: Furnace injection of magnesium hydroxide can result in boiler efficiency savings, due to
on calculating the boiler efficiency savings. Enter the result on the line below. The boiler
efficiency savings are the same for both commercial and byproduct magnesium hydroxide
injection.
Boiler Efficiency Savings [$/year] (MagBE)
Step 7: A heat penalty (MagHP) is incurred because the water in the magnesium hydroxide
slurry must be heated and evaporated. The following calculation estimates the heat penalty. It
assumes that the slurry is stored at a temperature of 68°F and that the air heater temperature is
305°F.The variable FractionSolids refers to the fraction of the shipped slurry that is solid, while
the variable FractionPureSolids refers to the fraction of the total solids that is Mg(OH)2 solids.
For commercial magnesium hydroxide, typical values are FractionSolids = 0.60 and
FractionPureSolids = 0.99. For byproduct magnesium hydroxide, typical values are
FractionSolids = 0.18 and FractionPureSolids = 0.65.
2.45 • CoalCost • TonMag • (1 − FractionSolids )

MagHP =
FractionPureSolids • FractionSolids
2.45 • _______ • _______• (1 − ______ )

=
_______• _______
= __________[$/year] (MagHP)
Step 8: Subtracting the heat penalty calculated in Step 7 from the boiler savings from the boiler
savings in Step 6 gives the overall effect on the change in fuel cost associated with furnace
injection of the slurry.
Mag∆Fuel = MagBE − MagHP
= _______− _______
= __________[$/year] (Mag∆Fuel)
C-32
Step 9: Estimate the capital cost for the magnesium hydroxide injection process. Two sets of
calculations are given. The first set of calculation is for a plant that will have the magnesium
hydroxide delivered (either as a commercially made product or as a byproduct from another
plant). The second set of calculations is for a plant that plans to modify its existing Thiosorbic®
FGD process to produce byproduct magnesium hydroxide. Choose the calculations applicable to
your situation.
(a) Estimate the capital cost (DelivMagCC) for a system based on delivery of either commercial
or byproduct magnesium hydroxide slurry.
TonMag
DelivMagCC = 2.65x10 6 + 3.6x10 4 •
Capacity • Months
_______
= 2.65x10 6 + 3.6x10 4 •
_______• _______
= __________[$] (DelivMagCC)
(b) Estimate the capital cost (BPMagCC) for a byproduct Mg(OH)2 system. The capital cost has
two components. The first component is the injection system and accessories, the cost of which
will be the same as the capital costs calculated in part (a). The second component is the
equipment to produce the byproduct magnesium hydroxide. Benson estimates a cost of $4/kW
assuming that the plant already has a Thiosorbic® FGD process75.
BPMagCC = DelivMagCC + 4000 • Load
= _______ + 4000 • _______
= __________[$] (BPMagCC)
Step 10: Summarize the operating and capital costs for magnesium hydroxide injection in the
table below. Note that the value Mag∆Fuel, which acccounts for the heat penalty of injecting a
slurry, should be entered for boiler efficiency savings, rather than the value MagBE.
Table C4-6
Summary of Calculated Costs for Magnesium Hydroxide Furnace Injection
Boiler Efficiency
[$/year] [$/year] [$]
Mg(OH)2 Injection __________ __________ __________

(MagOC) (Mag∆Fuel) (DelivMagCC or
BPMagCC)
C-33
Magnesium Hydroxide Furnace Injection + Lime Injection Upstream of ESP
Injection of Mg(OH)2 into the furnace does not appear to reduce SCR-generated SO3 emissions.
Plants that have an SCR in operation and wish to employ this option to achieve high overall SO3
control percentages (greater than ~70%) may need to couple it with dry hydrated lime injection
at the ESP inlet. This section estimates the cost for such a dual-control system. For the purposes
of estimating reagent use, it is assumed that the quantity of Mg(OH)2 injected is sufficient to
reduce the economizer outlet SO3 concentration by 90%. Then, given the 90% removal of
furnace SO3, the new SO3 profile across the plant is calculated. Based on this new SO3 profile,
the quantity of dry hydrated lime needed to bring the stack SO3 concentration to the target value
is calculated. The user can calculate the annual and capital costs for the magnesium hydroxide
system for both commercial and byproduct magnesium hydroxide. These costs are added to the
costs associated with the lime injection system.
Step 1: Determine the amount of Mg(OH)2 needed to reduce the economizer outlet SO3
concentration by 90%. According to the stoichiometry chart in the previous section, an Mg:SO3
ratio of approximately 7:1 is needed.
TonMag2 = 2.04x 10 -7 • SO3Econ ,BL • Lbmol @ Econ
= 2.04 x 10 -7 • _______ • ______
= __________[dry ton/year] (TonMag2)
C-34
Step 2: Calculate the SO3 profile through the remainder of the plant, assuming 90% removal of
SO3 in the furnace.
The outlet SO3 concentration from the HSESP will be:
SO3HSESP,w/Mg = 0.1 • SO3Econ ,BL • F2HSESP
= 0.1 • _______• _______
= __________[ppm] (SO3HSESP,w/Mg)
The outlet SO3 concentration from the SCR will be:
SCRConv • SO2 ppm

SO3SCR,w/Mg = SO3HSESP ,w / Mg +
100
_______• _______
= _______ +
100
= __________[ppm] (SO3SCR,w/Mg)
The outlet SO3 concentration from the air heater will be:
SO3AH,w/Mg = F2AH • SO3SCR , w / Mg
= _______• _______
= __________[ppm] (SO3AH,w/Mg)
The outlet SO3 concentration from the CSESP will be:
SO3CSESP,w/Mg = F2CSESP • SO3AH , w / Mg
= _______• _______
= __________[ppm] (SO3CSESP,w/Mg)
C-35
Step 3: Calculate the SO3 concentration at the CSESP outlet (SO3CSESP,target,w/Mg) that corresponds
to the targeted stack SO3 concentration.
SO3stack ,t arg et
SO3CSESP,target,w/Mg =
[F 2
FGD
• (1 − FGDBypass ) + FGDBypass ]
_______
=
[_______• (1 − _______ ) + _______ ]
= __________[ppm] (SO3CSESP,target,w/Mg)
Step 4: Calculate the percent reduction of SO3 needed at the CSESP outlet.
 SO3CSESP ,t arg et , w / Mg 
Lime%Red = 1 −  • 100
 SO3CSESP , w / Mg 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (Lime%Red)
Step 5: Determine the rate of lime injection needed to produce the desired percent reduction in
SO3 (Lime%Red). Look up the calculated percent reduction on the y-axis of the sorbent injection
rate performance curve given below. Pick off the corresponding sorbent injection rate on the x-
axis.
Hydrated Lime Injection Rate [lb/hr/kacfm] (LimeRate)
C-36
100%
90%
80%
SO3 Reduction at ESP Outlet [%]
70%
60%
50%
40%
30%
20%
10%
0%
0 1 2 3 4 5
Sorbent Injection Rate [lb/hr/kacfm]
Figure C4-2
Sorbent Injection Rate Performance Curve for Lime Injection at ESP Inlet77
Step 6: Given the injection rate determined above, calculate the mass of lime used in one year of
operation.
LimeRate • VolAH
TonLime =
1.2 x10 8
______ • ______
=
1.2 x10 8
= __________[ton/year] (TonLime)
77
SO3 Mitigation Guide. EPRI, TR-104424s. October 1994.
C-37
Step 7: Calculate the annual operating costs for the magnesium hydroxide injection and for the
lime injection.
(a) Calculate the annual operating cost for the magnesium hydroxide system (MagOC2).
MagOC2 = 1.03 • MagDelivCost • TonMag 2
= 1.03 • ______[$/dry ton] • _______
= __________[$/year] (MagOC2)
(b) Calculate the annual operating cost for the lime injection system (LimeOC).
LimeOC = 1.23 • LimeDelivCost • TonLime
= 1.23 • _______ • _______
= __________[$/year] (LimeOC)
(c) Add the operating costs for the magnesium hydroxide and lime injection systems to obtain
the total operating cost for the dual control system (MgLimeOC).
MagLimeOC = MagOC 2 + LimeOC
= ______ + _______
= __________[$/year] (MagLimeOC)
Step 8: Furnace injection of magnesium hydroxide can result in boiler efficiency savings, due to
the ability to operate at a lower air heater exit temperature. The lime injection will not contribute
to the savings, as it is injected downstream of the air heater. Consult Worksheet 6 for instructions
on calculating the boiler efficiency savings. Enter the result on the line below. The boiler
efficiency savings are the same whether you use commercial or byproduct magnesium hydroxide
injection.
Boiler Efficiency Savings [$/year] (MagLimeBE)
C-38
Step 9: A heat penalty (MagLimeHP) is incurred because the water in the magnesium hydroxide
slurry must be heated and evaporated. The following calculation estimates the heat penalty. It
assumes that the slurry is stored at a temperature of 68°F and that the air heater temperature is
305°F. For the values to enter for FractionSolids and FractionPureSolids, see the explanation of
Step 7 in the section above on furnace injection of Mg(OH)2 for plants without SCR.
2.45 • CoalCost • TonMag 2 • (1 − FractionSolids )

MagLimeHP =
FractionPureSolids • FractionSolids
2.45 • _______ • _______• (1 − ______ )

=
_______• _______
= __________[$/year] (MagLimeHP)
Step 10: Subtracting the heat penalty calculated in Step 7 from the boiler savings from the boiler
savings in Step 6 gives the overall effect on the change in fuel cost associated with furnace
injection of the slurry.
MagLime∆Fuel = MagLimeBE − MagLimeHP
= _______− _______
= __________[$/year] (MagLime∆Fuel)
Step 11: Estimate the capital cost for the magnesium hydroxide injection process. Two sets of
calculations are provided. The first set of calculation is for a plant that will have the magnesium
hydroxide delivered (either as a commercially made product or as a byproduct form another
plant). The second set of calculations is for a plant that plans to modify its existing Thiosorbic
Lime FGD process to produce byproduct magnesium hydroxide. Choose the calculations
appropriate to your situation.
(a) Estimate the capital cost (DelivMagCC2) for system based on delivery of either commercial
or byproduct magnesium hydroxide slurry..
TonMag 2
DelivMagCC2 = 2.65x10 6 + 3.6x10 4 •
Capacity • Months
_______
= 2.65x10 6 + 3.6x10 4 •
_______• _______
= __________[$] (DelivMagCC2)
C-39
(b) Estimated the capital cost (BPMagCC2) for a byproduct Mg(OH)2 system. The capital cost
has two components. The first component is the injection system and accessories, the cost of
which will be the same as the commercial magnesium capital costs calculated above. The second
component is the installation of equipment to produce the byproduct magnesium hydroxide.
Benson estimates a capital cost of $4/kW assuming that the plant already has a Thiosorbic Lime
FGD process.75
BPMagCC2 = DelivMagCC 2 + 4000 • Load
= _______ + 4000 • _______
= __________[$] (BPMagCC2)
Step 10: Calculate the installed capital costs associated with the hydrated lime system (LimeCC).
TonLime
LimeCC = 4.22x10 6 + 3.6x10 4 •
Capacity • Months
_______
= 4.22x10 6 + 3.6x10 4 •
_______• _______
= __________[$] (LimeCC)
Step 11: Calculate the total installed capital costs (MagLimeCC) for the dual control system by
adding the capital costs for the magnesium hydroxide system and the lime system.
MagLimeCC = ( DelivMagCC 2 or BPMagCC 2) + LimeCC
= ______ + _______
= __________[$] (MagLimeCC)
Step 12: Summarize the annual and capital costs for magnesium hydroxide injection in the table
below. Note that the value MagLime∆Fuel, which acccounts for the heat penalty of injecting a
slurry, should be entered for boiler efficiency savings, rather than the value MagLimeBE.
Table C4-7
Summary of Costs associated with Magnesium Hydroxide + Lime Injection
Boiler Efficiency
[$/year] [$/year] [$]
Mg(OH)2 + Lime __________ __________ __________

Injection (MagLimeOC) (MagLime∆Fuel) (MagLimeCC)
C-40
MgO Powder (Injection Upstream of Air Heater)
The costs associated with injecting MgO powder upstream of the air heater are calculated in this
section. Martin Marietta indicates that an average stack SO3 reduction of 65% has been achieved
over the course of 12 field tests.78 This worksheet enables the user to choose a removal
efficiency greater than 65%. However, the vendor cautions that while removal efficiencies over
70% have been achieved, these high efficiencies are not typical. Also note that ESP operational
problems are possible with MgO injection, when SO3 concentrations become too low to provide
conditioning of the fly ash.
Step 1: Calculate the percent reduction needed at the stack.
 SO3stack ,t arg et 
MgO%Red = 1 −  • 100
 SO3stack ,BL 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (MgO%Red)
Step 2: Calculate the feed ratio of MgO:SO3 needed to achieve the targeted reduction, assuming
a 50% utilization of the reagent.
MgO% Re d
Mg:SO3 =
50
________
=
50
= __________ (MgO:SO3)
Step 3: Given the required molar feed ratio, calculate the mass of MgO powder needed for one
year’s operation (TonMgO).
TonMgO = 2.07 x 10 -8 • MgO : SO3 • SO3SCR ,BL • Lbmol @ SCR
= 2.07 x 10 -8 • _______ • _______ • ______
= __________[dry ton/year] (TonMgO)
78
Schmidtchen, Paul, Martin Marietta Specialty Chemicals, Email to Katherine Dombrowski. 31 October 2003.
C-41
Step 4: Estimate the annual operating costs (MgOOC) for MgO injection.
MgOOC = 1.05 • MgODelivCost • TonMgO
= 1.05 • ______[$/ton] • _______
= __________[$/year] (MgOOC)
Step 5: Injection of MgO powder upstream of the air heater can result in boiler efficiency
savings, due to the ability to operate at a lower air heater exit temperature. Consult Worksheet 6
for instructions on calculating the boiler efficiency savings. Enter the result on the line below.
The boiler efficiency savings are the same for both commercial and byproduct magnesium
hydroxide injection.
Boiler Efficiency Savings [$/year] (MgOBE)
Step 6: Calculate the installed capital costs (MgOCC).
TonMgO
MgOCC = 2.95x10 6 + 9.7x10 4 •
Capacity • Months
_______
= 2.95x10 6 + 9.7x10 4 •
_______• _______
= __________[$] (MgOCC)
Step 7: Summarize the calculated costs for the MgO injection process in the following table.
Table C4-8
Summary of Calculated Costs for MgO Injection
Boiler Efficiency
[$/year] [$/year] [$]
MgO Injection __________ __________ __________

(MgOOC) (MgOBE) (MgOCC)
C-42
SBS (Injection at Air Heater Inlet)
The costs associated with injecting SBS upstream of the air heater, but downstream of the SCR,
are calculated in this section.
Step 1: Calculate the SO3 concentration at the air heater outlet that corresponds to the target
stack SO3 concentration.
SO3stack ,t arg et
SO3AH,target =
[
F2CSESP • F2FGD • (1 − FGDBypass ) + FGDBypass ]
_______
=
_______• [______ • (1 − _______ ) + _______ ]
= __________[ppm] (SO3AH,target)
Step 2: Calculate the SO3 reduction (SBS%Red) required at the air heater outlet to meet the
target stack concentration.
 SO3AH ,t arg et 
SBS%Red = 1 −  • 100
 SO3AH ,BL 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (SBS%Red)
Step 2: Look up the % reduction (SBS%Red) on the molar ratio chart and pick off the Na:SO3
ratio required.
Required Na:SO3 to achieve target stack

SO3 concentration (Na:SO3)
C-43
100
90
80
70
SO3 Removal [%]
60
50
40
30
20
10
0
0 0.25 0.5 0.75 1 1.25 1.5 1.75 2
Na:SO3 Molar Ratio Injected
Figure C4-3
Stoichiometry Curve for SBS Injection79
Step 3: Calculate the amount of SBS as dry ton Na (TonNa) needed for one year’s operation.
TonNa = 1.15 x 10 -8 • Na : SO3 • SO3SCR , BL • Lbmol @ SCR
= 1.15 x 10 -8 • _______ • _______ • ______
= __________[dry ton Na/year] (TonNa)
79
Rhudy, R. and R. Moser. “SBS Technology for SO3 Removal.” Article submitted to Modern Power Systems for
publication in July 2003.
C-44
Step 4: Calculate the estimated annual operating cost (SBSOC) for SBS injection. The annual
operating cost includes a technology licensing fee of $200/MW/year. Use a delivered cost for
SBS (SBSDelivCost) that is in units of $/dry ton Na.
SBSOC = 1.09 • SBSDelivCost • TonNa + $200 • Load
= 1.09 • _______ • _______ + $200 • ________
= __________[$/year] (SBSOC)
Step 5: Injection of SBS upstream of the air heater can result in boiler efficiency savings, due to
on calculating the boiler efficiency savings. Enter the result on the line below.
Boiler Efficiency Savings [$/year] (SBSBE)
Step 6: Calculate the capital cost (SBSCC) for the SBS injection system.
TonNa
SBSCC = 2.74x10 6 + 6.11x10 5 •
Capacity • Months
_______
= 2.74x10 6 + 6.11x10 5 •
_______• _______
= __________[$] (SBSCC)
Step 7: Summarize the costs associated with injecting SBS upstream of the air heater in the
following table.
Table C4-9
Summary of Calculated Costs for SBS Injection upstream of Air Heater
Boiler Efficiency
[$/year] [$/year] [$]
SBS Injection upstream __________ __________ __________

of Air Heater (SBSOC) (SBSBE) (SBSCC)
C-45
SBS (Injection at CSESP Inlet)
The costs associated with injecting SBS upstream of the CSESP are calculated in this section.
Step 1: Calculate the SO3 concentration needed at the outlet of the CSESP that corresponds to
the target stack SO3 concentration.
CSESP,target SO3stack ,t arg et

SO3 =
[F2
FGD
________
=
[______ • (1 − _______ ) + _______ ]
= __________[ppm] (SO3CSESP,target)
Step 2: Calculate the percent reduction (SBS%Red2) needed at the ESP outlet to meet the target
 SO3CSESP ,t arg et 
SBS%Red2 = 1 −  • 100
 SO3CSESP ,BL 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (SBS%Red2)
Step 3: Look up the percent reduction (SBS%Red2) on the molar ratio chart in Figure C4-3 and
pick off the Na:SO3 ratio required.
Required Na:SO3 (Na:SO3)
Step 4: Calculate the amount of SBS as dry ton Na (TonNa2) needed for one year’s operation
TonNa2 = 1.15 x 10 -8 • Na : SO3 • SO3AH ,BL • Lbmol @ AH
= 1.15 x 10 -8 • _______ • _______ • ______
= __________[dry ton/year] (TonNa2)
C-46
Step 5: Calculate the estimated annual costs (SBSOC2) for SBS injection upstream of the
CSESP. The annual operating cost includes a technology licensing fee of $200/MW/year. Use a
delivered cost for SBS (SBSDelivCost) that is in units of $/dry ton Na.
SBSOC = 1.09 • SBSDelivCost • TonNa + $200 • Load
= 1.09 • _______ • _______ + $200 • ________
= __________[$/year] (SBSOC)
Step 6: Since injection of SBS is downstream of the air heater, there are no boiler efficiency
savings.
Boiler Efficiency Savings [$/year] $0 (SBSBE2)
Step 7: Calculate the capital cost (SBSCC2) for the SBS injection system.
TonSBS 2
SBSCC2 = 2.74x10 6 + 6.11x10 5 •
Capacity • Months
_______
= 2.74x10 6 + 6.11x10 5 •
_______• _______
= __________[$] (SBSCC2)
Step 8: Summarize the calculated costs for SBS injection upstream of the CSESP in the
following table.
Table C4-10
Summary of Calculated Costs for SBS Injection upstream of CSESP
Boiler Efficiency
[$/year] [$/year] [$]
SBS Injection upstream __________ 0 __________

of CSESP (SBSOC2) (SBSBE2) (SBSCC2)
C-47
Ammonia (Injection upstream of ESP)
This economic analysis of ammonia injection assumes that the plant already operates an SCR.
Ammonia injection is an option for users who desire high removals of SO3 from the flue gas.
Almost complete removal (>95%) can be achieved at NH3:SO3 molar ratios between 1:1 and 2:1.
Injecting a molar ratio less than 1:1 produces ammonium bisulfate, which is sticky, corrosive,
and causes fly ash handling problems. Injecting greater than 2:1 does not provide much
additional removal for the increase in reagent cost, and can result in ammonia slip from the ESP.
The following calculations for ammonia injection are based on a fixed 95% removal
Step 1: Assuming 95% reduction of SO3, calculate the corresponding stack SO3 concentration.
SO3stack,w/NH3 = 0.05 • SO3stack ,BL
= 0.05 • _______
= __________[ppm] (SO3stack,w/NH3)
Step 2: Determine the injection molar ratio of NH3:SO3.
• If your plant would like to increase cohesivity of its fly ash, use an NH3:SO3 ratio of 1.25:1.
• If your plant is concerned with ash-handling problems, use an NH3:SO3 ratio of 1.75:1.
Required NH3:SO3 molar ratio (NH3:SO3)
Step 3: Calculate the amount of ammonia needed per year.
TonNH3 = 8.5 x 10 -9 • NH 3 : SO3 • SO3AH , BL • Lbmol @ AH
= 8.5 x 10 -9 • _______ • _______ • ______
= __________[dry ton/year] (TonNH3)
C-48
Step 4: If your plant sells its fly ash, it may not be able to sell the fly ash once an ammonia
conditioning system is in place. If loss of fly ash sales is a concern for your plant, use the
formula below to estimate the amount of lost fly sales per year and the cost to dispose of the ash.
HeatInput • CoalAsh • % AshConv • ( Ash Pr ice + AshDisposal )

0.05 •
LostAsh$ = CoalHV
_______ • _______ • ______ • (_______ + _______ )

= 0.05 •
_______
= __________[$/year] (LostAsh$)
Step 5: Calculate the annual cost for ammonia injection (NH3OC). The annual operating cost
consists of reagent and utility costs, ash disposal costs and lost fly ash sales (if applicable to your
plant).
NH3OC = 1.15 • TonNH 3 • NH 3 DelivCost + LostAsh$
= 1.15 • _______• _______ + _______
= __________[$/year] (NH3OC)
Step 6: Since injection of ammonia is downstream of the air heater, there are no boiler efficiency
savings.
Boiler Efficiency Savings [$/year] $0 (NH3BE)
Step 7: Calculate the capital cost (NH3CC) of the ammonia injection system.
TonNH 3
NH3CC = 1.5x10 6 + 6.7x10 4 •
Capacity • Months
_______
= 1.5x10 6 + 6.7x10 4 •
_______• _______
= __________[$] (NH3CC)
Step 8: Summarize the calculated costs for the ammonia injection process in the following table.
Table C4-11
Summary of Calculated Costs for Ammonia Injection
Boiler Efficiency
[$/year] [$/year] [$]
Ammonia Injection __________ 0 __________

(NH3OC) (NH3BE) (NH3CC)
C-49
Dry Hydrated Lime Injection (upstream of ESP)
The costs associated with injecting dry hydrated lime upstream of the ESP are calculated in this
section. ESP operational problems are possible with dry lime injection, when SO3 concentrations
are too low to provide conditioning of fly ash. If ESP operational problems are expected, the user
might consider humidification plus dry lime injection. See the next section for an economic
evaluation of this option.
Step 1: Calculate the SO3 concentration at the CSESP outlet corresponding to the target stack
SO3 concentration.
SO3stack ,t arg et
SO3CSESP,target =
[F2
FGD
________
=
[______ • (1 − _______ ) + _______ ]
Step 2: Calculate the required percent SO3 reduction (Lime%Red2) needed at the ESP outlet.
Lime%Red2 = 1 −  • 100
 SO3CSESP , BL 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (Lime%Red2)
Step 3: Determine the rate of sorbent injection. Look up your calculated percent removal on the
sorbent injection rate performance curve in Figure C4-2.
Hydrated Lime Injection Rate [lb/hr/kacfm] (LimeRate2)
C-50
Step 4: Calculate the amount of lime needed per year.
LimeRate2 • VolAH
TonLime2 =
1.2x10 8
______ • ______
=
1.2x10 8
= __________[ton/year] (TonLime2)
Step 5: Calculate the annual operating cost for the lime injection system (LimeOC2).
LimeOC2 = 1.23 • LimeDelivCost • TonLime 2
= 1.23 • _______ • _______
= __________[$/year] (LimeOC2)
Step 6: Since injection of lime is downstream of the air heater, there are no boiler efficiency
savings.
Boiler Efficiency Savings [$/year] $0 (LimeBE)
Step 7: Calculate the capital costs for hydrated lime injection (LimeCC2).
TonLime 2
LimeCC2 = 4.22x10 6 + 3.6x10 4 •
Capacity • Months
_______
= 4.22x10 6 + 3.6x10 4 •
_______• _______
= __________[$] (LimeCC2)
Step 8: In the following table, summarize the calculated costs for lime injection upstream of the
CSESP.
Table C4-12
Summary of Calculated Costs for Dry Hydrated Lime Injection
Boiler Efficiency
[$/year] [$/year] [$]
Dry Hydrated Lime __________ 0 __________

Injection (LimeOC2) (LimeBE) (LimeCC2)
C-51
Humidification + Hydrated Lime Injection
For the cost estimation of humidification coupled with hydrated lime injection, it is assumed that
the gas will be humidified to 260°F. Hydrated lime will be injected downstream of the
humidification nozzles, but upstream of the ESP.
Step 1: Calculate the SO3 concentration at the outlet of the CSESP that corresponds to the target
SO3stack ,t arg et
SO3CSESP,target =
[F2
FGD
________
=
[______ • (1 − _______ ) + _______ ]
Step 2: Calculate the percent SO3 reduction (LH%Red) needed across the ESP.
LH%Red = 1 −  • 100
 SO3AH , BL 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (LH%Red)
Step 2: Determine the rate of sorbent injection. Look up your calculated percent reduction
(LH%Red) on the curve provided below or calculate the rate of hydrated lime injection from the
equation given. The plot shows the total SO3 removal achieved for a humidification and hydrated
lime coupled system.
Hydrated Lime Injection Rate [lb/hr/kacfm] (LimeRate3)
C-52
100
90
80
SO3 Removal across ESP [%]
70
60
50
40
30
20
10
0
0 0.5 1 1.5 2 2.5 3 3.5 4 4.5 5
Sorbent Injection Rate [lb/hr/kacfm]
Figure C4-4
Sorbent Injection Rate Performance Curve for Lime Injection Coupled with
Humidification37
Step 3: Calculate the mass of lime needed for one year’s operation.
LimeRate3 • VolAH
TonLime3 =
1.2 x10 8
______ • ______
=
1.2 x10 8
Step 4: Calculate annual operating cost (LHOC) for lime injection coupled with humidification.
LHOC = 1.50 • LimeDelivCost • TonLime 3
= 1.50 • _______ • _______
= __________[$/year] (LHOC)
C-53
Step 5: Since injection of lime is downstream of the air heater, there are no boiler efficiency
savings.
Boiler Efficiency Savings [$/year] $0 (LHBE)
Step 6: Calculate capital cost (LHCC) for lime injection coupled with humidification.
TonLime3
LHCC = 3.93x10 6 + 1.2x10 5 •
Capacity • Months
_______
= 3.93x10 6 + 1.2x10 5 •
_______• _______
= __________[$] (LHCC)
Step 7: In the following table, summarize the calculated costs for lime injection system coupled
with humidificaiton.
Table C4-13
Summary of Calculated Costs for Humidification + Lime Injection
Boiler Efficiency
[$/year] [$/year] [$]
Humidification + Lime __________ 0 __________

Injection (LHOC) (LHBE) (LHCC)
C-54
Lime and Sodium Bicarbonate Mixture
ESP operational problems encountered with dry lime injection can be mitigated by injecting a
combination of lime and sodium bicarbonate. Testing at the ECTC showed that a mixture of 20%
sodium bicarbonate and 80% lime was optimum from a cost and performance standpoint.77
However, a correlation between injection rate and SO3 removal is not available for this mixture.
For the purposes of these economic estimates, it will be assumed that the mixture of 20% sodium
bicarbonate and 80% lime has a required injection rate equal to that of 100% hydrated lime.
Based on the discussions in the reference document, this should be a reasonable assumption.
Step 1: Calculate the SO3 concentration at the outlet of the CSESP that corresponds to the target
CSESP,target SO3stack ,t arg et

SO3 =
[F 2
FGD
________
[______ • (1 − _______ ) + _______ ]
Step 2: Calculate the percent SO3 reduction needed at the ESP outlet.
LSB%Red = 1 −  • 100
 SO3CSESP , BL 
 
 _______ 
= 1 −  • 100
 _______ 
= __________[%] (LSB%Red)
Step 3: Determine the rate of sorbent injection. Look up your calculated percent reduction
(LSB%Red) on the performance curve in Figure C4-2. The figure is for lime injection. It is
assumed that a mixture of 20% bicarbonate and 80% lime will behave similarly to a 100% lime
mixture for SO3 removal purposes.
Sorbent Injection Rate [lb/hr/kacfm] (SorbentRate)
C-55
Step 4: Calculate the amount of lime needed for one year.
SorbentRate • VolAH
TonLime4 =
1.5x10 8
______ • ______
=
1.5x10 8
Step 5: Calculate the amount of sodium bicarbonate needed for one year.
SorbentRate • VolAH
TonBicarb =
6.0x10 8
______• ______
=
6.0x10 8
= __________[ton/year] (TonBicarb)
Step 6: Calculate the annual operating cost (LSBOC) for the dual sorbent injection system.
LSBOC = 1.23 • [LimeDelivCost • TonLime 4 + BicarbDelivCost • TonBicarb ]
= 1.23 • [_______ • _______ + _______• _______ ]
= __________[$/year] (LSBOC)
Step 7: Since the sorbent injection is downstream of the air heater, there are no boiler efficiency
savings.
Boiler Efficiency Savings [$/year] $0 (LSBBE)
Step 8: Calculate capital cost (LSBCC) for the combined lime and sodium bicarbonate injection
system.
TonLime4 + TonBicarb
LSBCC = 4.41x10 6 + 4.3x10 4 •
Capacity • Months
_______ + _______
= 4.41x10 6 + 4.3x10 4 •
_______• _______
= __________[$] (LSBCC)
C-56
Step 9: Summarize the costs calculated for lime and sodium bicarbonate injection in the
following table.
Table C4-14
Summary of Calculated Costs for Lime+Sodium Bicarbonate Injection
Boiler Efficiency
[$/year] [$/year] [$]
Lime + Sodium __________ 0 __________

Bicarbonate Injection (LSBOC) (LSBBE) (LSBCC)
C-57
Worksheet 5 — Wet ESP Economics - Capital and Annual Costs
The purpose of this worksheet is to calculate the capital cost and annual operating cost for a wet
ESP.
Step 1: Determine the Type of Wet ESP Installation
A wet ESP can be installed as a stand-alone unit, as a retrofit to a dry ESP, or as a retrofit to an
existing wet FGD scrubber. The type of installation depends upon the existing pollution control
equipment at the plant and the desired SO3 removal efficiency. Use the following rough
guidelines to decide which type of installation may be best-suited for your plant.
First, calculate the SO3 removal efficiency required by the wet ESP (WESP-Eff).
 SO3stack ,t arg et 
WESP-Eff = 1 −  • 100
 SO stack, BL 
 3 
 ________ 
= 1 −  • 100
 _______ 
= ____________[%] (WESP-Eff)
• If the wet ESP will be installed downstream of a dry ESP, and there is no existing wet
scrubber, then use the following guidelines to determine whether a last field retrofit or stand-
alone installation can be used.
– If the removal efficiency required (WESP-Eff) is between 60 and 75%, a last field
retrofit of the dry ESP may be possible.
– If the removal efficiency required (WESP-Eff) is greater than 75%, then a stand-alone
wet ESP installation may be required.
• If the wet ESP will be installed downstream of a wet FGD scrubber, then a close-coupled wet
FGD/wet ESP system may be possible.
Chosen Type of Wet ESP Installation
C-58
Step 2: Estimate the Capital Cost
Based on the type of wet ESP installation you have chosen, determine the appropriate capital
cost factor in $/kW.
Table C5-1 provides estimated cost factors for an installation downstream of an existing dry
ESP.
Table C5-1
Approximate Installed Costs for Wet ESP Installed Downstream of a Dry ESP
Type of Installation Capital Cost Factor [$/kw]
Last field retrofit of dry ESP80 $25 - $35
Stand-alone installation81 $90
Table C5-2 gives cost factors for installation of a close coupled wet FGD/Wet FGD system for a
new 500 MW facility.82 If the wet ESP will be retrofitted onto an existing FGD scrubber, the
capital cost can range from $40-90/kW or greater, per vendor discussions.
Table C5-2
Approximate Installed Costs for Close-Coupled Wet FGD/Wet ESP System81
(New 500 MW Facility)
Number of Fields SO3 Collection Efficiency [%] Capital Cost [$/kW]
1 50 20
2 80 30
3 95 40
Enter your chosen cost factor (WESPCapFactor) in the space below.
Capital Cost Factor for wet ESP Installation (WESPCapFactor)

[$/kW]
Calculate the approximate capital cost (WESPCC).
80
Reynolds, J., W. Buckley, and I. Ray. “Advances in wet electrostatic precipitation technology at fossil fuel power
plants for multi-pollutant control,” paper presented at the Institute of Clean Air Companies (ICAC) Forum 2003:
Multi-Pollutant Emission Controls & Strategies. Nashville, TN, 12-15 October 2003.
81
Pontbriand, M.W., R.J. Keeth, R.S. Blagg. “Performance of a Full-scale Wet Electrostatic Precipitator,” paper
presented at PowerGen 2002, Orlando, FL, 10-12 December 2002.
82
Kumar, K.S., A. Mansour. “Wet ESP for controlling sulfuric acid plume following an SCR system,”paper
presented at the Institute of Clean Air Companies (ICAC) Forum 2002: Cutting NOX. Houston, TX, 12-13 February
2003.
C-59
WESPCC = 1000 • WESPCapFactor • Load
= 1000 • _______• _______
= _________________[$] (WESPCC)
Step 3: Estimate the Operating Cost
The primary components of the annual operating cost are water, power, and neutralizing reagent.
For the purpose of comparison to other technologies, the operating costs estimations assume that
the wet ESP will run just during the SO3 control season. In practice, however, it is more likely
that wet ESP equipment would be operated year-round. The operating cost is estimated as 0.24%
of the capital cost.
WESPOC = 0.0024 • WESPCC
= 0.0024 • _______
= __________[$/yr] (WESPOC)
Step 4: Boiler Efficiency Savings
Since the WESP is downstream of the air heater, no boiler efficiency savings will be accrued.
Boiler Efficiency Savings [$/year] $0 (WESPBE)
Step 5: Summarize the Costs Associated with a Wet ESP

Table C5-3
Summary of Costs Associated with a Wet ESP
Boiler Efficiency
[$/year] [$/year] [$]
Wet ESP __________ 0 __________

(WESPOC) (WESPBE) (WESPCC)
C-60
Worksheet 6 — Boiler Efficiency Savings Calculations
The purpose of this worksheet is to calculate savings associated with improved boiler efficiency
when SO3 concentrations are reduced upstream of the air heater. The boiler efficiency savings
might save anywhere between 2 to 10% of the annual operating cost, depending on the
technology. Technologies covered in this Process Economics Workbook that may realize boiler
efficiency savings include:
• Fuel Switching
• Addition of OmniClearTM with the coal
• Mg(OH)2 injection in furnace
• MgO injection upstream of air heater
• SBS injection upstream of air heater
Step 1: Define the baseline air heater exit temperature and the minimum temperature at which
air heater can run (exclusive of sulfuric acid dew point considerations).
Baseline Air Heater Exit Temperature

[°F] (TAHBL)
Minimum Operational Temperature for

Air Heater Exit [°F] (TAHmin)
Step 2: Determine the sulfuric acid dew point at the exit to the air heater. The acid dew point
(Tdp) is a function of the SO3 concentration in the gas and the water concentration of the gas. The
SO3 concentration of the flue gas typically decreases across the air heater. As a conservative
approach, these calculations use the SO3 concentration at the entrance of the air heater. The
convention of these worksheets is to refer to the flue gas as it exits a unit operation. Therefore,
the air heater entrance is referred to as the SCR exit in these worksheets. If your plant does not
have an SCR, go ahead with the calculations using the variables that are called.
The SO3 concentration at the exit of the SCR will depend on the type of SO3 control technology
employed. The following bullets show how to calculate the SO3 concentration at the SCR exit for
each of the injection technologies. The value SO3econ,target, which is called in the table, is
calculated in Worksheet 4 in the section entitled “Magnesium Hydroxide (Boiler Injection) – for
plants without SCR”.
C-61
Table C6-1
Determination of SO3 Exit Concentration from SCR
SO3SCR
Technology SO3SCR [ppm]
(
= SO2blend , final • BoilerConv • F2HSESP + SCRConv )
Fuel Switching
= _______ • (_______ • _______ + _______ )
= SO3econ ,t arg et
TM
OmniClear
= _______
= SO3econ ,t arg et
Mg(OH)2 only
= _______
= SO3SCR ,w / Mg
Mg(OH)2 + Lime = _______
= _______
SO3SCR ,w / MgO
= FGD
[ ]
F2 ( 1 − FGDBypass ) + FGDBypass • F2CSESP • F2AH
MgO upstream of AH
_______
=
[_______ (1 − _______ ) + _______ ] • _____• _____
SO3AH ,t arg et
=
F2AH
SBS upstream of AH
_______
=
_______
Using Figure 6-1, look up the value for SO3SCR calculated in the above bullets, along with the
water concentration at the inlet to the air heater. You will need to enter the flue gas percent
moisture at the SCR exit. This value is not calculated for you. A typical flue gas moisture
concentration for bituminous coal ranges from 8-10%.
C-62
Table C6-2
Determination of Sulfuric Acid Dewpoint
SO3SCR
(From Table
Injection Technology Above) % H2O at SCR exit Tdp [°F]
Fuel Switching
OmniClearTM
Mg(OH)2 only
Mg(OH)2 + Lime
MgO upstream of AH
SBS upstream of AH
320
310
300
Sulfuric Acid Dew Point (°F)
290
280
270 14% H20

260 12% H20
250
10% H20
240
8% H20
6% H20
230
220
0 10 20 30 40 50 60
SO3 Concentration (ppm)
Figure 6-1
Acid Dew Point as a Function of SO3 and H2O Concentration
C-63
Step 3: Determine the minimum air heater exit temperature that is possible when utilizing one of
the upstream air heater control technologies. Compare the acid dew point (Tdp) to the minimum
possible operating temperature of the air heater (TAHminimum).
If Tdp < TAHmin, then TAH w/ injection = TAHmin.
If Tdp > TAH min, then TAHw/ injection = Tdp.

Table C6-3
Minimum Temperature at which Air Heater Can Operate with SO3 Controls
TAHw/injection
Technology [°F]
Fuel Switching
OmniClearTM
Mg(OH)2 only
Mg(OH)2 + Lime
MgO upstream of AH
SBS upstream of AH
Step 4: Calculate the change in the air heater exit operating temperature from baseline operation
to operation with SO3 mitigation technology.
Table C6-4
∆T Between Air Heater Operation at Baseline and Injection Conditions
BL w / injection T
∆T = T AH − T AH
Technology [°F]
Fuel Switcing = _______ − _______ = _______
OmniClearTM = _______ − _______ = _______
Mg(OH)2 only = _______ − _______ = _______
Mg(OH)2 + Lime = _______ − _______ = _______
MgO upstream of AH = _______ − _______ = _______
SBS upstream of AH = _______ − _______ = _______
Step 5: Calculate the cost savings associated with this reduction in air heater outlet temperature.
For these calculations it is assumed that a 0.025% improvement in boiler efficiency is obtained
with each °F that the air heater outlet temperature is lowered. The values for the variables
HeatInput and FuelCost were entered in Worksheet 1.
C-64
Table C6-5
Boiler Efficiency Savings
Boiler Efficiency Savings

Boiler Efficiency
Technology = 2.5x10 −4 • HeatInput • FuelCost • ∆T Savings [$/year]
Fuel Switching = 2.5x10 −4 • ______• _______• _____ = _______

BlendBE
OmniClearTM = 2.5x10 −4 • ______• _______• _____ = _______

OmniBE
Mg(OH)2 only = 2.5x10 −4 • ______• _______• _____ = _______

MgBE
Mg(OH)2 + Lime = 2.5x10 −4 • ______• _______• _____ = _______

MgBE2
MgO upstream of AH = 2.5x10 −4 • ______• _______• _____ = _______

MgOBE
SBS upstream of AH = 2.5x10 −4 • ______• _______• _____ = _______

SBSBE
C-65
Worksheet 7 — Summary of Economic Evaluation
Enter the capital costs calculated for each SO3 mitigation technology into Table C7-1.
Table C7-1
Summary of Capital Costs for SO3 Mitigation Options
SO3 Mitigation Option Capital Cost [$]
Fuel Blending __________

(BlendCC)
OmniClearTM __________
(OmniCC)
Mg(OH)2 Injection __________

(DelivMagCC or BPMagCC)
Mg(OH)2 + Lime Injection __________

(MagLimeCC)
MgO Injection __________

(MgOCC)
SBS Injection Upstream of Air Heater __________

(SBSCC)
SBS Injection Upstream of CSESP __________

(SBSCC2)
Ammonia Injection __________

(NH3CC)
Dry Hydrated Lime Injection __________

(LimeCC2)
Humidification + Lime Injection __________

(LHCC)
Lime + Sodium Bicarbonate Injection __________

(LSBCC)
Summarize the annual operating costs and boiler efficiency savings in Table C7-2.
Enter your chosen capital recovery factor.
Capital Recovery Factor
Calculate the capital recovery for each technology, using the following formula. Enter the results
in Table C7-2.
C-66
Capital Recovery = Capital Recovery Factor ● Capital Cost
Calculate the total annual cost with the following formula. Enter the results in Table C7-2.
Total Annual Cost = Annual Operating Cost – Boiler Efficiency Savings + Capital Recovery
Table C7-2
Summary of Annual Costs for SO3 Mitigation Options
Annual Operating Boiler Efficiency Capital Recovery Total Annual

SO3 Mitigation Cost Savings Cost
Option [$/year] [$/year] [$/year] [$/year]
Fuel Blending __________ __________ __________

(BlendOC) (BlendBE) (BlendCR)
OmniClearTM __________ __________ __________

(OmniOC) (OmniBE) (OmniCR)
Mg(OH)2 Injection __________ __________ __________

(MagOC) (Mag∆Fuel) (ComMagCR or
BPMagCR)
Mg(OH)2 + Lime __________ __________ __________

Injection (MagLimeOC) (MagLime∆Fuel) (MagLimeCR)
MgO Injection __________ __________ __________

(MgOOC) (MgOBE) (MgOCR)
SBS Injection __________ __________ __________

upstream of Air (SBSOC) (SBSBE) (SBSCR)
Heater
SBS Injection __________ 0 __________

upstream of CSESP (SBSOC2) (SBSBE2) (SBSCR2)
Ammonia Injection __________ 0 __________

(NH3OC) (NH3BE) (NH3CR)
Dry Hydrated Lime __________ 0 __________

Injection (LimeOC2) (LimeBE) (LimeCR2)
Humidification + Lime __________ 0 __________

Injection (LHOC) (LHBE) (LHCR)
Lime + Sodium __________ 0 __________

Bicarbonate Injection (LSBOC) (LSBBE) (LSBCR)
C-67
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This report describes research sponsored by EPRI.

2 OVERVIEW OF SO3 CONTROL TECHNOLOGIES...............................................................2-1

Solid Waste Impacts of Dry Sorbent Injection............................................................2-14

3 EXAMPLE ECONOMICS FOR SO3 CONTROL TECHNOLOGIES .......................................3-1

4 SO3 CONTROL PROCESS ECONOMICS WORKBOOK OVERVIEW .................................4-1

5 SO3 CONTROL TECHNOLOGY VENDORS..........................................................................5-1

Vendors of Sorbent Injection Technologies...........................................................................5-1

A APPENDIX — MEASURING SO3 CONCENTRATIONS IN FLUE GAS X ........................... A-1

B APPENDIX — ESTIMATING FLUE GAS SO3 CONCENTRATIONS................................... B-1

C APPENDIX — SO3 CONTROL PROCESS COST ESTIMATING WORKSHEETS.............. C-1

Delivered Cost Calculations .......................................................................................... C-27

Table 2-1 Full-scale Ammonia Injection Experience for SO3 Control.......................................2-11

Mechanism for SO3 Formation

Factors Influencing SO3 Formation

Fuel Type and Sulfur Content

Boiler Oxygen Concentration

Boiler Design and Operating Temperatures

Chemical Composition of Fuel Ash

Effect of SCR on SO3 Formation

Impacts of Flue Gas SO3

SO3 Concentration (ppm)

Overview of Mitigation Options

Overview of SO3 Control Technologies

Furnace Mg(OH)2 Injection

Overview of SO3 Control Technologies

Magnesium hydroxide slurry is available as a commercial product, or it can be produced on-site

Overview of SO3 Control Technologies

A project co-funded by DOE/NETL, EPRI, FirstEnergy Corporation, Tennessee Valley

Overview of SO3 Control Technologies

Post-Combustion Injection of MgO

Overview of SO3 Control Technologies

SO3 + 2NaHSO3 → Na2SO4 + 2SO2 + H2O

H2SO4 + 2NaHSO3 → Na2SO4 + 2SO2 + 2H2O

Overview of SO3 Control Technologies

SO2 + Na2SO3 + H2O → 2NaHSO3

Overview of SO3 Control Technologies

Overview of SO3 Control Technologies

Ammonia reacts with sulfuric acid vapor by the following reactions:

NH3 (gas) + H2SO4 (gas) → NH4HSO4 (solid or liquid)

2 NH3 (gas) + H2SO4 (gas) → (NH4)2SO4 (solid)

Configuration of Ammonia Injection System

Overview of SO3 Control Technologies

Performance Data for Ammonia Injection

Overview of SO3 Control Technologies

Tampa Big Bend 450 2.2-3.4 20 30 95+ Not

NYSEG Kintigh 643 2.8 4 8 95 85

Not Not 400 - 22 30 95+ Not

Detroit Monroe 750 2 2-5 8 95+ 40

Impacts on ESP Performance

Impacts on Waste Disposal Options

Overview of SO3 Control Technologies

Impacts of Ammonia Injection on FGD Systems

Ammonia Injection Safety Concerns

Overview of SO3 Control Technologies

Dry Sorbent Injection Upstream of ESP

Overview of SO3 Control Technologies