Mercury Levels Dropping - June 19, 2006

Mercury Levels Dropping - June 19, 2006

Response from Readers of EnergyBiz

Unfortunately, the approach that the EPA has taken towards mercury pollution from coal-fired power plants misses the mark on two fronts. First is the "socio-technical" aspect; the trading of pollution credits will act just as you described in your article, and heavily coal-dependent areas with older plants will not see reductions in mercury pollution. It's possible that pollution will in fact increase in some areas. It may be more palatable if the EPA were to modify the rules to require proportionally accelerated reductions through technology where the use of credits meets or exceeds a designat ed level. That could help reduce the amount of mercenary operation of coal-fired power plants. Most companies will react rationally (economically) as the carrots get smaller and the stick gets bigger.

The second aspect is the basic philosophy behind this concept. The concept of trading pollution credits may make perfect sense on a purely economic basis, but even then the idea as applied does not include all the variables in the equation. At the very least, the cost of the pollution and its long term affects should be paid by those who benefit from the exploitation of the resource - the government (mineral rights), the business (energy sales), investors (capital gains) and the consumers. This cost is an expense, a form of investment in that very business of exploitation of resources. Trading pollution credits exports some of the value of the resource exploitation but does nothing to balance the harm it causes.

The EPA and thereby the government is explicitly sanctionin g participation by these coal-fired generating plants in a form of the "tragedy of the commons." The rational approach to profit for individuals (the companies) will lead to greater harm for all in terms of long-term health effects and degradation of the environment. This occurs in addition to the depletion of the natural resource that (in many cases) under the mining laws of this country belongs to all the citizens, not just the purchaser of mineral rights. My recollection of the mining laws and their purpose is based on application in the Western States, where most mining occurs on government "owned" land and only mineral rights are "sold" to private parties for development. In effect the mining laws and environmental laws as applied ensure that resources of the many will become profit for the few -- and the many will pay for the negative consequences.

It seems to me that since we've learned so much more about the long-term effects of mineral extraction and coal-burning pol lution in just the last 20 years we should be doing better than this.

Jim Van Sickle
Safety Administrator
IBEW Local 18/LA DWP
Joint Safety Institute

With the increased pressure on the reduction of mercury emissions from coal-fired power plants, it was surprising that your June 19 article "Mercury Levels Dropping" failed to make any mention of the benefits and advantages of coal-based Integrated Gasification Combined Cycle (IGCC) technology in that regard.

From accepted published field data from operating plants it appears that IGCC is far superior in mercury capture potential compared to available exhaust gas treatment for new PC plants.

Also surprising were the kudos given in your article to We Energies for their mercury reduction program. Granted, plans for their existing plants appear to be admirable and are commended. But the record shows that their decision to go forward with two new 615 MW coal-burning plants rather tha n seriously consider IGCC technology for those plants precluded the opportunity to realize a two thirds reduction in total plant emissions (from nearly 10,000 tpy to 3,400 tpy per plant). This includes a similar 2/3 reduction of mercury emissions from 0.03 tpy per plant to 0.01 tpy.

One would expect that this impressive difference in mercury reduction potential by use of IGCC technology is worthy of mention in an article dedicated to that very subject?

True, there appears to be a cost premium to be paid for IGCC technology - at last estimate perhaps about 10% in the cost of electricity - but that may be a small price to pay for its superior environmental performance. In fact, the so-called "cost gap" would likely disappear or even reverse in direction if/when PC plants are required to meet the same environmental performance as IGCC plants - if it were technically feasible to do so.

True, too, there are not as many large-scale IGCC plants as one would like to s ee in making critical decisions on billion dollar commitments for future power generating plants. But the technology is well beyond the experimental and demonstration phases, as is often claimed. One only needs to look across the Atlantic to see how well several large plants are performing.

And the fact is that there are major US utilities that are making such commitments for large IGCC plants to be in service in the same timeframe as the new WE Energies plants. Based on past performance, these are sure to set the standard for mercury reduction.

Harry Jaeger
Gasification Editor
Gas Turbine World Magazine

There is a better regulatory approach that lets markets discover prices and best ways to limit mercury, and it involves giving every heat and power generator an allowance of mercury per megawatt-hour of delivered heat and/or power, regardless of the facility's technology, fuel, age of plant, location, or past mercury emissions.

Di vide total mercury emissions by total MWh delivered to users in the US to learn the emissions per delivered MWh of electricity today. Do the same for every MWh of useful thermal energy to determine a starting allowance per MWh thermal. Then pass a law that sets a declining schedule of allowances per MWh electrical and per MWh thermal for the next ten to twenty years. Instruct DOE to revise the table every year to correct for actual consumption of heat and electricity. Simply multiply each year's allowances per MWh in the original law by a fraction of the base year's total MWh delivered to users divided by the prior year's MWh delivered to users. This makes sure that rising heat and power use does not increase the cap on mercury emissions. This approach will let the market determine the optimal way to limit mercury.

Note the beauty of this approach in promoting the deployment of clean and efficient power plants, without interfering in market decisions. A new wind farm would re ceive the same mercury allowance that a new or existing coal plant receives. The market determines the price of the allowances, and that signal goes to the wind developer, making his/her project slightly more cost effective. Any improvements in efficiency increase the MWh from a given amount of fuel, and thus increase the allowances for mercury. Thus efficiency improvements gain an added boost by selling extra allowances. At the same time, owners of old coal plants are faced with the true costs of mercury control, as determined by the market. They can then decide to burn cleaner coal, add mercury controls, increase efficiency, substitute opportunity fuels, or move the facility from base load to intermediate or peaking use, or even close the facility.

The Sulfur system works beautifully in discovering the price of removing sulfur, but transferred wealth to the worst polluting facilities by giving them the allowances based on historical emissions. Mercury is a chance to get it right.

Thomas R. Casten
Chair & CEO
Primary Energy LLC

The U.S. EPA estimates that FOUR percent (4%) of mercury deposition in the U.S. is from U.S. coal fired power plants. The most optimistic estimates are that it would take 15-20 years to see any change in mercury concentration levels in the environment as a result of controlling mercury emissions for coal-fired power plants, ASSUMING NOTHING ELSE CHANGES. However, this assumption is almost assuredly not going to be valid since 75% of worldwide mercury emissions and re-emissions into the atmosphere come from natural sources over which we have little or no control. For example, we have no control over the largest variable affecting atmospheric mercury emissions -- volcanic activity.

Moreover, concerns that coal-fired power plants cause local "hot spots" of mercury deposition are not backed by actual deposition data. This should not be surprising since mercury emission levels for U.S. coa l-fired power plants typically range from 4-13 parts per BILLION emitted from very tall stacks with high exit gas velocities. Currently no continuous emission monitor (CEM) has demonstrated the accuracy and dependability necessary to assure compliance with even a 70% reduction in mercury emissions, much less the kind of accuracy and dependability that would be needed to assure compliance with a 90% mercury reduction requirement.

Finally, EPA's basis for setting the acceptable level of mercury in humans is based on questionable science. The Seles Islanders have blood mercury concentration levels approximately 10 times higher than the EPA safe concentration limit and this population shows no indications of adverse health effects or increased birth defect rates. The EPA's mercury limit is based on a study of an Iranian population that grew food using mercury and PCB tainted fertilizer. The EPA attributed ALL of the higher birth defect rate to the mercury and none to the PCBs in the fertilizer; even though EPA had previously justified its PCB regulations on the basis the small concentrations of PCBs caused birth defects. This incident occurred in the 1980's during the Iran-Iraq War and it was known that Iraq had used chemical and biological weapons on Iranian civilian populations in the area; EPA assumed since there were no reports of mass deaths due to chemical/biological weapons in the immediate area, that none of the birth defects could be attributed to residual effects of chemical/biological weapons.

In conclusion, other than spending $billions to control an unimportant source of a pollutant whose impact on human health is probably vastly overstated, and being unable to either measure whether the pollution control measures are really working or weather the regulation has an actual impact on pollutant concentrations in the environment, mercury emissions controls on coal-fired power plants are a really good idea.

Ben Ziesmer

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