2007  No. 327

Illinois Law Does Require an Average 90 Percent Reduction by 2009

Sid Nelson of Sorbent Technologies wrote us about the following headline in our Alert recently “Illinois Pollution Control Board Approves 90 Percent Mercury Reduction by 2012 with Flexibility.” The headline may have been misleading but the text clarifies that mercury reduction averaging 90 percent is required in 2009 but by 2012 each unit has to achieve the 90 percent reduction. However, the lack of clarity had a positive effect as Sid was energized to provide us with some very useful details. Sid writes:

“I took part in the contested hearings in Illinois and have been following these regulations closely. The Illinois Board rules call for 90 percent average mercury compliance by July 1, 2009, not 2012.”

The Board’s ruling on page 100, says:

Section 225.230 Emission Standards for EGUs at Existing Sources

(A) Emission Standards

(1) Beginning July 1, 2009, the owner or operator of a source with one or more EGUs subject to this Subpart B that commenced commercial operation on or before December 31, 2008, must comply with one of the following standards for each EGU on a rolling 12-month basis:

(a) An emission standard of 0.0080 lb mercury/GWh gross electrical output; or

(b) A minimum 90-percent reduction of input mercury.

Ameren and Dynegy will likely comply under the Multi-Pollutant Standard provisions, which they negotiated to be added, which instead essentially provide them with “safe harbor” if they inject a halogenated (actually brominated) carbon at a rate of 5 lb/MMACF for subbituminous coal (which is nearly all of the Illinois plants). You might also find it newsworthy that the regulations specify that a halogenated carbon from Sorbent Technologies, Norit, or ALSTOM must be used, or their proven equivalent:

Section 225.233 Multi-Pollutant Standards (MPS)

(A) General

(1) As an alternative to compliance with the emissions standards of Section 225.230(a), the owner of eligible EGUs may elect for those EGUs to demonstrate compliance pursuant to this Section, which establishes control requirements and standards for emissions of NOx and SO2, as well as for emissions of mercury.

(c) Control Technology Requirements for Emissions of Mercury

(1) Requirements for EGUs in an MPS Group

(A) For each EGU in an MPS Group other than an EGU that is addressed by (c)(1)(B) of this Section for the period beginning July 1, 2009 (or December 31, 2009 for an EGU for which an SO2 scrubber or fabric filter is being installed to be in operation by December 31, 2009), and ending on December 31, 2014 (or such earlier date that the EGU is subject to the mercury emission standard in Subsection (d)(1) of this Section), the owner or operator of the EGU must install, to the extent not already installed, and properly operate and maintain one of the following emissions control devices:

(i) A Halogenated Activated Carbon Injection System, complying with the sorbent injection requirements of subsection (c)(2) of this Section,

(ii) If the boiler fires bituminous coal, a Selective Catalytic Reduction (SCR) System and an SO2 Scrubber.

(2) For each EGU for which injection of halogenated activated carbon is required by Subsection (c)(1) of this Section, the owner or operator of the EGU must inject halogenated activated carbon in an optimum manner, which, except as provided in Subsection (c)(4) of this Section, is defined as all of the following:

(A) The use of an injection system designed for effective absorption of mercury, considering the configuration of the EGU and its ductwork;

(B) The injection of halogenated activated carbon manufactured by Alstom, Norit, or Sorbent Technologies, or the injection of any other halogenated activated carbon or sorbent that the owner or operator of the EGU has demonstrated to have similar or better effectiveness for control of mercury emissions; and

(C) The injection of sorbent at the following minimum rates, as applicable:

(i) For an EGU firing subbituminous coal, 5.0 lbs per million actual cubic feet …

(ii) For an EGU firing bituminous coal, 10.0 lbs per million actual cubic feet …

(iii) For an EGU firing a blend of subbituminous and bituminous coal, a rate that is the weighted average of the above rates, based on the blend of coal being fired;

For further information see

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