NEWS RELEASE                                   APRIL 2004

Vastly Different Power Plant Air Pollution Approach Needed Now

U.S. power plant air pollution problems are not what they seem and the solutions are not what is being proposed. The McIlvaine Company is submitting a plan to EPA which addresses the true problems and provides cost effective solutions.

“In some areas we are doing better than we thought we were”, says Robert McIlvaine, President of the McIlvaine Company.  The proposed Interstate Air Quality Rule (IAQR) will provide much greater benefit than is being attributed to it.  It will cause the largest investment in air pollution control equipment in the history of the world. (50 percent larger than EPA estimates).

IAQR will result in the greatest reduction in hazardous air pollutants of any rule in the history of the world (EPA has not emphasized this benefit).  This is primarily due to the reduction of hydrogen chloride and toxic metals.

The IAQR will result in elimination of more fine particulate than EPA's total estimated inventory. (However, some techniques to control NO_x and SO₂ will lead to greater particulate reduction than others.)

“The areas where we are doing worse than we think are significant”, says McIlvaine. Power plant particulate emissions are far greater than estimates (2.4 million tons per year plus or minus 1.2 million tons).  The insensitivity to the particulate problem has resulted in the acidification and abandonment of a small town in Ohio.  A loophole in the rules allows a utility to convert SO₂ to SO₃ and discharge sulfur as particulate mist.  The utility gets full credit for the sulfur reduction and is not prohibited from emitting this toxic mist.

A lack of understanding of the particulate problem has resulted in a proposed rule which would allow a utility to discharge all the mercury and still receive credit for the mercury reduction.  The proposed method for monitoring mercury excludes particulate mercury. The rationale is that particulate mercury is only a few percent of the total mercury. However, some of the mercury technologies rely on converting gaseous to particulate mercury.  Under the proposed rule you could use this conversion technology and then discharge all the mercury.

Insensitivity to the particulate problem has resulted in a situation whereby many older power plants are permitted to emit ten times as much discrete particulate as a new plant. This means that these plants on the average also emit ten times as much lead, chromium, arsenic, beryllium, cadmium, nickel, and many other toxic metals.  The disparity is even greater for condensed particulate such as acid mist.

The quantity of toxic metals emitted by U.S. power plants is greater than from all other stationary sources combined.  When the individual metal weights are multiplied by their respective toxicities, their importance is substantial when compared to mercury (even when the bioaccumulation effect is considered).  Yet mercury is being singled out for attention.

Precise automatic measurement techniques for particulate and mercury are not available. This has had a big effect on crafting control schemes.

While these problems are seemingly daunting, there are some surprisingly simple and quickly implemented actions to solve them.  They are as follows:

(1)   Develop a coordinated plan which addresses all power plant pollutants.  This entails developing a “harm rating” for each pollutant and setting long-term goals for each.  (McIlvaine has developed a “harm rating” system using established toxicity factors.)

(2)   Distinguish between the route and the destination.  Despite the apparent huge gulf between utilities and environmentalists on mercury control, the true differences are about routes not the destination.  Both sides seek maximum mercury reduction at reasonable cost.  The utilities are understandably resisting an approach that is fraught with operational and cost uncertainty.

(3)   Create cost based routes to whatever the destination.  McIlvaine is submitting two plans to EPA which will result in substantial and cost effective mercury, fine particulate, and toxic metal emission reduction. These plans are the Mercury Inter-Utility escalating payment plan and the Particulate Inter-Utility escalating payment plan.  These plans require higher emitting utilities to make escalating payments to lower emitting utilities until national goals are reached.

(4)   Unleash the power of private initiative.  These two plans would provide the financial incentive for development of the many control technologies which have been in the arrested mode for the last thirty years.  For example, there are many technologies to solve the mercury removal problem with western coals (e.g. chloride pre-scrubbers).

(5)   Utilize the “audit concept” for monitoring mercury and particulate.  A utility’s profit is not a precise number.  It is the best number the skilled auditor can provide.  Large utilities with more at stake can afford to spend more on auditing than smaller ones.  The same concept can be used for measuring fine particulate and mercury. The auditor will need to integrate the results from multiple inputs and make a judgment.  This can be plus or minus 1 percent with maximum audit effort.  McIlvaine has some very specific monitoring recommendations for both fine particulate and mercury to insure the accuracy of the audits.

McIlvaine concludes, “These actions could be implemented as quickly as the presently proposed IAQR and mercury rules.  Once these actions are implemented, the nation would be swiftly moving on a smooth highway toward the desired destination and will encounter the minimum number of toll booths along the way.”

For details on the plans and background data click on: http://www.mcilvainecompany.com/UtilityFaxAlert668.htm .

You can direct your questions to Bob McIlvaine at 847-784-0012 or e-mail at:  rmcilvaine@mcilvainecompany.com .

Credibility Brief

The McIlvaine Company is paid for continuing advice on these subjects by DOE, EPA, AEP, Southern, Babcock & Wilcox, GE, Sargent & Lundy, and many other utilities, engineers, environmental organizations, and suppliers in countries around the world.  The McIlvaine Company has provided knowledge systems on each of five air pollution control technologies for more than 30 years.  It maintains one of the world’s largest technical libraries on air pollution subjects.

Robert McIlvaine was President of Environeering from 1968 to 1972.  Environeering built the first commercial scrubber for a power plant (sold to Combustion Engineering for installation at Union Electric in 1968).  Environeering also built the first scrubbers to be used for conversion of power plant SO₂ to sulfuric acid (Philadelphia Electric in 1970).   McIlvaine founded the McIlvaine Company in 1974 for the express purpose of providing a better way to convert air pollution information to knowledge.  McIlvaine developed both the Dust Difficulty Determinator and the McIlvaine Mini Scrubber used to assess the ability of scrubbers to remove fine particulate.

The McIlvaine Company employs 35 people including engineers and researchers as well as journalists.  McIlvaine personnel participate in industry activities and have served on the boards of associations and as chairmen of technical committees, e.g. AWMA particulate.  The greatest resource is a network of hundreds of niche experts around the world who contribute unique specialized knowledge.  Since McIlvaine serves all parties on environmental issues, and is paid for accurate assessment, there is no bias toward any position.