FGD Work Book PDF

FGD Optimization Workbook
TR-111118
Final Report, July 1998
EPRI Project Manager

Richard Rhudy
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CITATIONS
This report was prepared by
Radiation International, LLC

8501 North Mopac Blvd.
Austin, TX 78759
Principal Investigators
G.M. Blythe
W.M. Horton
This report describes research sponsored by EPRI.
The report is a corporate document that should be cited in the literature in the
following manner:
FGD Optimization Workbook. EPRI, Palo Alto, CA: 1998. TR-111118.
iii
REPORT SUMMARY
Because flue gas desulfurization (FGD) systems represent a significant operating and
maintenance (O&M) expense for coal-fired power plants, identification and
implementation of cost reduction options are important. This workbook contains
information to assist utilities in assessing FGD O&M cost reduction options through a
series of worksheets that describe and cost most of the options that can be considered.
Background
Over the past 20+ years, EPRI has developed a substantial amount of information that
can be used to optimize and lower costs for new and existing FGD systems. However,
not everyone who has O&M responsibilities for utility FGD systems has adequate time
to research and become familiar with this technology to determine which might be
applicable to his or her system. Similarly, those same individuals may not have a good
feel for how much cost reduction might be possible relative to the "best" practices in the
industry.
Objectives
• To benchmark costs for O&M against costs reported by others with similar FGD
system types
• To determine which O&M cost categories represent the best potential for cost
savings and quantify that potential
• To identify cost saving strategies that would be applicable to specific FGD systems
and calculate an approximate cost effectiveness for that strategy
Approach
Investigators conducted a benchmarking survey of operating and maintenance costs
for all the existing wet and dry FGD systems in the US. The results were summarized
and incorporated into the workbook to allow comparisons by workbook users with
their specific units. In addition, all known FGD optimization strategies were identified
and summarized based on prior EPRI information. Example cost savings were
calculated in a format that can easily be transferred into a simple spreadsheet.
v
Results
This workbook represents a compilation of expertise in optimizing FGD systems
organized by cost saving strategies, along with the results of a benchmarking study of
FGD system O&M costs. The strategies presented include using performance additives;
converting to inhibited or forced oxidation; improving mist elimination, reagent
conversion and preparation, and scrubber internals systems; using a spare module, etc.
Each strategy is described, along with the factors that determine its cost effectiveness for
a particular FGD system. Each example includes details of the calculations that support
these economics. Where possible, average values or "rules of thumb" are provided that
will allow the reader to make a first calculation of the potential cost effectiveness of that
strategy on a specific FGD system.
The completed surveys present costs for 27 wet FGD systems and two spray dryer FGD
systems. The wet FGD systems include eight treating flue gas from high sulfur coal,
seven treating medium sulfur coal, and 12 treating flue gas from low sulfur coal. To
supplement these results, The U.S. Department of Energy's Energy Information Agency
Form 767 cost data on all U.S. power plants was used to expand the information on
FGD costs. While not as detailed as the information requested on the project-specific
survey described above, it does provide meaningful cost information for all of the
operating lime or limestone FGD systems on U.S. coal-fired utility power plants
EPRI Perspective
The information in this workbook will assist utilities in initial evaluations of cost
reduction options for new and existing FGD systems. In addition, where appropriate,
existing systems can be compared to the existing fleet of FGD systems to benchmark
their potential for improvement. In most cases, evaluations using this workbook will
represent preliminary estimates to determine which strategies may be applicable to a
specific situation. For those options that appear attractive, a more detailed study should
be conducted to make a final decision.
TR-111118
Interest Category
Air emissions control
Keywords
Air pollution control
Flue gas desulfurization
Scrubbers
Wet scrubbers
Economic analysis
vi
EPRI Licensed Material
ABSTRACT
Because flue gas desulfurization (FGD) systems represent a significant operating and
maintenance (O&M) expense for coal-fired power plants, identification and
implementation of cost reduction options are important. This workbook contains
information to assist utilities in assessing FGD O&M cost reduction options through a
series of worksheets that describe and cost most of the options that can be considered.
The workbook provides a step-by-step methodology for determining FGD operating
and maintenance costs, including the costs for reagents, additives, operating and
maintenance staff labor, maintenance materials, maintenance subcontract labor, and
byproduct/waste disposal. The costs can be expressed either in dollars per megawatt of
net generation, to focus on FGD impacts on power production costs, or in dollars per
ton of SO2 removed for comparison with SO2 allowance values. Once these costs are
determined, they can be compared to results for similar FGD lime or limestone reagent
systems from two FGD cost surveys included in the workbook. This comparison will
help determine which FGD cost components offer the most promise for cost reduction.
The remainder of the workbook provides information about cost savings strategies for
wet lime and limestone reagent FGD systems. One section describes a number of cost
savings strategies, and provides examples for estimating the potential cost effectiveness
of these strategies on a particular FGD system. The next section provides examples of
how utilities can collect data from their FGD systems to more precisely determine the
cost effectiveness of potential cost savings strategies.
vii
CONTENTS
1 INTRODUCTION ................................................................................................................. 1-1

Report Objectives ............................................................................................................... 1-1
Benchmarking Data Sources .............................................................................................. 1-2
Workbook Organization ...................................................................................................... 1-2
How to Use This Workbook................................................................................................. 1-3
2 IDENTIFYING POTENTIAL SAVINGS ................................................................................ 2-1

Auxiliary Power ................................................................................................................... 2-2
Potential Savings ............................................................................................................ 2-2
Savings Strategies .......................................................................................................... 2-4
Scrubber Booster Fans ............................................................................................... 2-4
Absorber Recycle Pumps............................................................................................ 2-5
Oxidation Air Compressors.......................................................................................... 2-6
Reagent Consumption ........................................................................................................ 2-6
Potential Savings ............................................................................................................ 2-7
Savings Strategies .......................................................................................................... 2-8
Operating Labor................................................................................................................ 2-11
Potential Savings .......................................................................................................... 2-11
Savings Strategies ........................................................................................................ 2-13
Maintenance Labor and Materials..................................................................................... 2-14
Byproduct Sales or Disposal Costs................................................................................... 2-17
Incremental Costs for SO2 Removed ................................................................................ 2-22
ix
3 COST SAVINGS STRATEGIES .......................................................................................... 3-1

Use Performance Enhancing Additives............................................................................... 3-1
Description of the Strategy.............................................................................................. 3-1
Determining the Cost Effectiveness of Performance Additives ....................................... 3-4
Example Economics........................................................................................................ 3-8
Add Sulfur/Inhibit Oxidation ................................................................................................ 3-9
Description of the Strategy.............................................................................................. 3-9
Determining the Cost Effectiveness of Inhibiting Oxidation........................................... 3-13
Example Economics...................................................................................................... 3-14
Modify/Improve Mist Eliminator Wash System .................................................................. 3-16
Description of the Strategy............................................................................................ 3-16
Determine the Cost Effectiveness of Improving/Upgrading the ME Wash System........ 3-17
Increase/Decrease Absorber Recirculating Slurry Percent Solids .................................... 3-21
Determine the Cost Effectiveness of Varying Weight Percent Solids Levels................. 3-22
Modify pH Set Point/Control.............................................................................................. 3-25
Determining the Cost Effectiveness of Improved pH Control ........................................ 3-27
Optimize Makeup Water Use ............................................................................................ 3-29
Determining the Cost Effectiveness of Optimizing Makeup Water Use ......................... 3-31
Modify Reagent Preparation Scheme ............................................................................... 3-36
Determine the Cost Effectiveness of Changes in Reagent Preparation System ........... 3-37
Change Liquid to Gas Ratio.............................................................................................. 3-40
Determining the Cost Effectiveness of Varying L/G ...................................................... 3-41
Convert to Wet Stack Operation ....................................................................................... 3-44
x
Description of Strategy.................................................................................................. 3-44

Determining the Cost Effectiveness of a Wet Stack Conversion ................................... 3-44
Close Bypass Damper ...................................................................................................... 3-46
Determining the Cost Effectiveness of Closed Bypass Operation................................. 3-47
Example Estimate ......................................................................................................... 3-48
Use Spare Module in Normal Operation ........................................................................... 3-50
Determine the Cost Effectiveness of Operating the Spare Module ............................... 3-51
Add Packing or Tray ......................................................................................................... 3-55
Determining the Cost Effectiveness of Adding a Tray or Packing ................................. 3-56
Convert to Forced Oxidation Operation ............................................................................ 3-61
Determining the Cost Effectiveness of a Forced Oxidation Conversion ........................ 3-62
Install Pump Suction Screens ........................................................................................... 3-66
Determining the Cost Effectiveness of Installing Pump Suction Screens...................... 3-67
Change Reagent Type...................................................................................................... 3-68
Determine the Cost Effectiveness of a Reagent Type Change ..................................... 3-69
Optimize Venturi Contactor 'P ......................................................................................... 3-75
Determining the Cost Effectiveness of Optimizing Venturi 'P ...................................... 3-76
Add Polymers/Flocculents to Improve Dewatering Effectiveness ..................................... 3-77
Determine the Cost Effectiveness of Adding Flocculents.............................................. 3-79
xi

Upgrade Materials of Construction/Equipment Design to Increase Service Life ............... 3-81
4 CASE STUDIES .................................................................................................................. 4-1

Case Study Number 1 - Using an Organic Acid Additive to Reduce Auxiliary Power
and Limestone Costs .......................................................................................................... 4-1
General Approach ........................................................................................................... 4-1
Important Considerations ................................................................................................ 4-1
Data Required ................................................................................................................. 4-2
Tests Required................................................................................................................ 4-3
Limestone Utilization versus Slurry pH ........................................................................ 4-3
Number of Recycle Pumps and Slurry pH Versus Organic Acid Concentration .......... 4-5
Organic Acid Consumption Rate ................................................................................. 4-6
Economic Evaluation..................................................................................................... 4-12
Current Operation ..................................................................................................... 4-12
Option 1 - Operate Fewer Recycle Pumps................................................................ 4-12
Option 2 - Operate at a Lower pH Set Point.............................................................. 4-15
Case Study Number 2 - Optimizing Slurry pH Set Point and Number of Recycle
Pumps to Obtain Lowest Combined Auxiliary Power and Limestone Costs ..................... 4-16
General Approach ......................................................................................................... 4-16
Important Considerations .............................................................................................. 4-16
Data Required ............................................................................................................... 4-17
Tests Required.............................................................................................................. 4-17
Case Study Number 3 - Increasing Limestone Fineness to Reduce Auxiliary Power
and Limestone Costs ........................................................................................................ 4-22
General Approach ......................................................................................................... 4-22
Important Considerations .............................................................................................. 4-23
Data Required ............................................................................................................... 4-23
Grinding System Throughput Versus Product Fineness............................................ 4-24
Limestone Utilization Versus Slurry pH ..................................................................... 4-28
Current Operation ..................................................................................................... 4-28
xii
Option 1 - Reduce Ball Mill Throughput..................................................................... 4-31

Option 2 - Purchase Different Limestone .................................................................. 4-33
References ....................................................................................................................... 4-34
5 BIBLIOGRAPHY ................................................................................................................. 5-1

Use Performance Enhancing Additives............................................................................... 5-1
Add Sulfur/Inhibit Oxidation ................................................................................................ 5-3
Modify/Improve Mist Eliminator Wash System .................................................................... 5-3
Modify pH Set Point/Control................................................................................................ 5-3
Optimize Makeup Water Use .............................................................................................. 5-4
Modify Reagent Preparation ............................................................................................... 5-4
Change L/G ........................................................................................................................ 5-5
Convert to Wet Stack Operation ......................................................................................... 5-5
Close Bypass Damper ........................................................................................................ 5-5
Use Spare Module in Normal Operation ............................................................................. 5-6
Change Reagent Type........................................................................................................ 5-6
Optimize Venturi Contactor 'P ........................................................................................... 5-6
Add Tray/Packing ............................................................................................................... 5-7
General Resources for Determining the Effectiveness of Cost Saving Strategies .............. 5-7
A RESULTS OF PROJECT-SPECIFIC FGD COST SURVEY ...............................................A-1

High-Sulfur, Limestone/Forced Oxidation ........................................................................... A-2
High-Sulfur Systems (Mg-Lime and Limestone Reagent, All Oxidation Modes) ................. A-4
Medium-Sulfur Coal Systems (Lime and Limestone Reagent, All Oxidation Modes) .......... A-5
Low-Sulfur Coal Systems (Lime and Limestone Reagent, All Oxidation Modes) ................ A-7
Spray Dryer FGD Systems.................................................................................................. A-8
B RESULTS FROM DEPARTMENT OF ENERGY COST SURVEY ......................................B-1

High-Sulfur Coal.................................................................................................................. B-3
Medium-Sulfur Coal .......................................................................................................... B-10
Low-Sulfur Coal ................................................................................................................B-15
xiii
LIST OF FIGURES
Figure 3-1 Percent SO2 Removal Versus NTU...................................................................... 3-6

Figure 3-2 Pump Suction Screen......................................................................................... 3-67
Figure 4-1 Limestone Utilization Versus Absorber Feed Slurry pH as a Function of L/G....... 4-4
Figure 4-2 Typical Closed-Circuit Horizontal Ball Mill Grinding System ............................... 4-25
Figure 4-3 Typical Limestone Grinding Ball Mill Capacity Versus Bond Work Index............ 4-26
Figure 4-4 Typical Limestone Grinding Ball Mill Product Size Versus Bond Work Index ..... 4-27
Figure 4-5 Limestone Utilization Versus Limestone Grind
(Example Data From Testing Conducted at the EPRI ECTC) ....................................... 4-29
Figure B-1 Effect of FGD System Age on Total O&M Costs, High-Sulfur Coal ...................... B-8
Figure B-2 Effect of Sulfur Content on Total O&M Costs, High-Sulfur Coal........................... B-9
Figure B-3 Effect of Unit Size on Total O&M Costs, High-Sulfur Coal ................................. B-11
xv
LIST OF TABLES
Table 3-1 List of Cost Reduction Strategies and Their Expected Effect on SO2 Control
and Major FGD Cost Categories ..................................................................................... 3-2
Table 3-2 Example Economics: Cost Effectiveness of Organic Acid Addition .................... 3-10
Table 3-3 Example Economics: Cost-Effectiveness of Sulfur Addition ............................... 3-15
Table 3-4 Example Economics: Cost-Effectiveness of Increased Recycle Solids
Concentration................................................................................................................ 3-24
Table 3-5 Example Economics: Cost-Effectiveness of pH Controller Modifications............ 3-30
Table 3-6 Example Economics: Cost-Effectiveness of Improving Water Balance............... 3-35
Table 3-7 Example Economics: Cost-Effectiveness of Finer Limestone Grind ................... 3-39
Table 3-8 Example Economics: Cost-Effectiveness of Finer Limestone Grind ................... 3-43
Table 3-9 Example Economics: Cost-Effectiveness of Closed Bypass Operation .............. 3-49
Table 3-10 Example Economics: Cost-Effectiveness of Using a Spare Module ................. 3-53
Table 3-11 Example Economics: Cost-Effectiveness of Varying Packing Depth ................ 3-58
Table 3-12 Example Economics: Cost-Effectiveness of Forced Oxidation Conversion ...... 3-63
Table 3-13 Example Economics: Cost-Effectiveness of Switching Reagent....................... 3-72
Table 3-14 Example Economics: Cost-Effectiveness of Increased Venturi Pressure
Drop .............................................................................................................................. 3-78
Table 3-15 Example Economics: Cost-Effectiveness of Flocculant Addition ...................... 3-80
Table 4-1 Typical Organic Acid Test Matrix ........................................................................... 4-6
Table 4-2 Example Organic Acid Consumption Calculation................................................... 4-8
Table 4-3 Example Economic Evaluation for Sodium Formate Additive .............................. 4-13
Table 4-4 Typical Test Matrix for Optimizing the Number of Recycle Pumps Operating...... 4-18
Table 4-5 Example Economic Evaluation for Optimizing Number of Recycle Pumps .......... 4-20
Table 4-6 Example Economic Evaluation for Finer Ground Limestone................................ 4-30
Table A-1 Summary of the Wet FGD Systems for Which Cost Information was
Provided.......................................................................................................................... A-2
Table A-2 Costs for High-Sulfur, Limestone/Forced Oxidation FGD Systems ....................... A-3
Table A-3 Costs for High-Sulfur, Limestone/Forced Oxidation FGD Systems ....................... A-3
Table A-4 Costs for All High-Sulfur FGD Systems ................................................................. A-4
Table A-5 Costs for All High-Sulfur FGD Systems ................................................................. A-5
Table A-6 Costs for Medium-Sulfur FGD Systems, All Reagents and Oxidation Modes........ A-6
xvii
Table A-7 Costs for Medium-Sulfur FGD Systems, All Reagents and Oxidation Modes........ A-6
Table A-8 Costs for Low-Sulfur FGD Systems, All Reagents and Oxidation Modes.............. A-7
Table A-9 Costs for Low-Sulfur FGD Systems, All Reagents and Oxidation Modes.............. A-8
Table A-10 Costs for Spray Dryer FGD Systems................................................................... A-9
Table A-11 Costs for Spray Dryer FGD Systems................................................................... A-9
Table B-1 Summary of the Lime/Limestone FGD Systems for Which Cost Information
was Available ..................................................................................................................B-2
Table B-2 Costs for High-Sulfur, Limestone/Forced Oxidation FGD Systems ....................... B-5
Table B-3 Costs for High-Sulfur, Limestone/Inhibited or Natural Oxidation FGD
Systems .......................................................................................................................... B-6
Table B-4 Costs for High-Sulfur, Mg-Lime FGD Systems ...................................................... B-7
Table B-5 Costs for Medium-Sulfur, Limestone/Forced Oxidation FGD Systems ................ B-12
Table B-6 Costs for Medium-Sulfur, Limestone/Inhibited or Natural Oxidation FGD
Systems ........................................................................................................................B-13
Table B-7 Costs for All Medium-Sulfur-Coal FGD Systems ................................................. B-14
Table B-8 Costs for Low-Sulfur, Limestone/Forced Oxidation FGD Systems ...................... B-16
Table B-9 Costs for Low-Sulfur, Limestone/Inhibited or Natural Oxidation FGD Systems ... B-17
Table B-10 Costs for Low-Sulfur, Wet Lime FGD Systems.................................................. B-18
Table B-11 Costs for Low-Sulfur, Wet Lime FGD Systems.................................................. B-19
Table B-12 Costs for Low-Sulfur, Wet, Alkaline-Ash Reagent FGD Systems ...................... B-20
xviii
1
INTRODUCTION
Report Objectives
As electric utilities enter a more competitive environment, every aspect of electric

power generation is being scrutinized to determine where costs can be reduced.
Because flue gas desulfurization (FGD) systems represent a significant capital,
operating, and maintenance expense for coal-fired power plants, FGD systems fall
under this scrutiny.
Over the past 20+ years, EPRI has developed a great deal of information that can be
used to optimize and lower costs for new and existing FGD systems. However, not
everyone that has operating and maintenance (O&M) responsibilities for utility FGD
systems has adequate time to research and become familiar with this technology to
determine which might be applicable to his or her system. Similarly, that person may
not have a good feel for how much cost reduction might be possible, relative to the
“best” practices in the industry.
This workbook is intended to be a helpful tool for that person. The objectives of this
workbook are to allow a utility engineer, FGD supervisor, or others to:
x Benchmark costs for their FGD system against costs reported by others with similar
FGD system types.
x Determine which FGD cost categories represent the best potential for cost savings,
and quantify that potential.
x Identify cost saving strategies that would be applicable to their FGD system, and
calculate an approximate cost effectiveness for that strategy as applied to their
system.
x Develop and implement a plan to develop system-specific data to better determine

the cost effectiveness of several cost reduction strategies.
x Identify EPRI publications and products, and other publications available to

provide more information about the cost reduction strategies that hold the most
promise.
1-1
Introduction
After working through the information in this workbook, the reader should better
understand how cost competitive their FGD system is compared to other similar
systems. The reader should also be able to develop a list of cost reduction strategies that
could measurably improve the cost effectiveness of that system, including a first
estimate of the savings from each.
Note that this workbook is intended to be used by the operators of wet lime or
limestone reagent FGD systems. Although lime spray dryer systems were included in
the cost benchmarking studies discussed below, little of the information provided in this
workbook would be useful for optimizing those systems.
Benchmarking Data Sources
The ability to benchmark FGD costs against other systems is provided by the results of
two FGD cost surveys. One is a survey of utilities with operating FGD systems that was
conducted specifically for this project. This survey, which was begun in the Fall of 1997,
was sent to 80 utility plants with operating lime or limestone reagent FGD systems,
including both wet and spray dryer system types. Of the 80 sent out, 35 surveys were
returned, although not all 35 contained all of the requested cost information. Many
plants that received the survey subsequently declined to participate, citing competitive
reasons for not providing cost data or lack of time to complete the survey. The results
from the 35 partial or completed surveys are summarized in Appendix A.
Because of the disappointing participation in this project-specific survey (less than 40%
of the targeted plants participated in any manner), another source of cost data was
sought. The U.S. Department of Energy’s Energy Information Agency receives cost data
on all U.S. power plants on their Form EIA-767. There is a section on FGD costs that,
while not as detailed as the information requested on the project-specific survey
described above, provides meaningful cost information for all of the operating lime or
limestone FGD systems on U.S. coal-fired utility power plants. The results from this
survey are summarized in Appendix B. In general, because of the limited participation
in the project-specific survey (particularly for high-sulfur-coal systems), the data in
Appendix B provide a more representative source for benchmarking FGD costs.
Workbook Organization
The remainder of this workbook is organized in the recommended order for identifying
cost saving strategies. Section 2 provides an approach for benchmarking FGD system
cost performance in each of five major cost categories, and provides a calculation
approach for determining the approximate annual cost savings potential in each of
these categories. For some cost categories, the reader is referred to Appendices A
and/or B for comparison data.
1-2
Introduction
Section 3 describes approximately 20 strategies that might be applied to reduce FGD

system O&M costs. Each strategy is described, along with the factors that determine its
cost effectiveness for a particular FGD system. An example is provided of the
economics of applying each strategy. Each example includes details of the calculations
that support these economics. Where possible, average values or “rules of thumb” are
provided that will allow the reader to make a first calculation of the potential cost
effectiveness of that strategy on his or her FGD system.
Section 4 provides three specific case studies of how strategies described in Section 3
were applied to optimize an FGD system, and Section 5 contains a bibliography of
reference publications. As mentioned above, Appendices A and B summarize the
results of two FGD cost benchmarking surveys.
How to Use This Workbook
Readers should work through the calculation templates in Section 2 to determine the
cost performance of their FGD system in each of five O&M cost categories. They should
then compare the cost performance for their system to the performance of other similar
FGD systems. These comparison data are presented as cost survey results in
Appendices A and B. The comparisons will help identify any cost categories where the
reader’s FGD system is experiencing costs that are higher than average or even higher
than “best in class” for the particular type of FGD system.
Section 3 then provides information about how various cost saving strategies can be
applied to FGD systems. A table at the beginning of the section provides a cross-
reference for which strategies impact each of the FGD cost categories. Section 3 also
provides typical performance and cost data, and example calculations that can guide
readers through an initial estimate of whether a cost saving strategy might be effective
for their system. However, because of the many situations possible in applying these
strategies to FGD systems, it was not practical to include calculation templates in this
section.
If potentially effective strategies are identified in Section 3, the reader can go to Sections
4 and 5 for more information. Section 4 provides detailed examples of how a utility can
collect system-specific information that will allow a more accurate estimate of the cost
effectiveness of a cost saving strategy. The examples in Section 4 also illustrate how
several strategies interact. In many cases, tradeoffs between a number of strategies
must be evaluated and optimized to produce the lowest overall FGD system O&M cost.
Section 5 provides additional reference material for many of the strategies.
1-3
2
IDENTIFYING POTENTIAL SAVINGS
This section of the workbook shows how to identify potential savings that could be
realized through FGD system optimization and/or the application of improved
technology. The potential savings are considered in terms of the following operating
and maintenance cost categories:
x Auxiliary power consumption.
x Reagent consumption.
x Operating labor.
x Maintenance labor and materials.
x Byproduct sales or disposal costs.
In general, the approach for identifying potential savings is that user inputs are
compared to survey results from Appendices A and B, or to general FGD guidelines to
determine cost categories where significant cost reductions might be achievable. Once
cost categories are identified, the workbook user can determine and evaluate potential
cost saving measures.
This section mentions and briefly discusses several potential cost saving measures for
each category. Many cost saving measures involve tradeoffs, where a savings realized
in one cost category may be partially or completely offset by an increase elsewhere.
Some of these tradeoffs are discussed in this section. However, Section 3 provides a
more detailed discussion of cost saving strategies, including example economics. It will
be up to the workbook user to determine the economics for his or her particular
application, and to consider other site-specific limitations or tradeoffs that may
influence these results. The case studies presented in Section 4 provide further, specific
examples of how to measure or estimate data requirements for optimizing FGD system
cost and performance.
Each of the cost categories listed above is discussed in a separate subsection below. As
mentioned in the Introduction, this workbook is oriented towards the operators of wet
lime or limestone reagent FGD systems. However, the approach used to determine cost
2-1
Identifying Potential Savings
categories where significant cost savings could be realized could also be adapted by the
reader to apply to lime spray dryer FGD systems.
Throughout this section, there are blank templates for calculating FGD cost
performance. The intent is that the workbook readers fill in the templates with data
specific to their FGD systems. Once completed, the template results will serve as the
basis for system-specific identification of FGD cost categories where savings may be
possible. Note that many of the values required for completing these templates can be
found on the most recent submittal of the U.S. Department of Energy Form EIA-767 for
your station.
Also, the template results can be used to estimate the incremental costs of SO2 removed
by your FGD system. This value may be useful for comparing to the current market
value of SO2 allowances, to help determine your utility’s most cost-effective approach
for complying with the 1990 Clean Air Act Amendments. This calculation is discussed
at the end of this section.
Auxiliary Power
Auxiliary power consumption is usually a major FGD operating cost category. FGD
booster fans and absorber recycle pumps typically account for most of a wet FGD
system's power consumption, and thus represent the best opportunities for reducing
auxiliary power costs. Other significant power consumers include air compressors for
forced oxidation systems, and to a lesser extent, reagent preparation mills, centrifuge
dewatering devices, etc.
Fan power is typically a function of flue gas flow rate through the FGD system and the
system pressure drop. Fan power can typically be affected by the number of modules
operated, the velocity of the gas through the modules, the amount of flue gas being
bypassed around the FGD system, and the design and condition of the absorber
internals.
Absorber recycle pump power requirements are proportional to the number of

absorbers in operation and the number of pumps operated per absorber. These may be
varied dependent on the flue gas flow rate, flue gas SO 2 concentration, required SO2
removal efficiency, and other factors. The type of nozzle installed and the size and
condition of the internal slurry distribution headers will also affect pump horsepower
requirements.
Potential Savings
The potential amount of savings achievable by reducing FGD auxiliary power

consumption is a function of the current annual value of the auxiliary power consumed
2-2
and the amount by which it can be reduced. For systems where the current annual cost
is low, it may take a high percent reduction to make improvements worth pursuing,
whereas for systems that currently experience high power costs it may be worth
pursuing small incremental improvements.
The total annual power cost is calculated as:
A. Total annual auxiliary power consumed by the FGD system:__________(MWh).
B. Cost of auxiliary power:__________($/MWh).
C. Total annual cost of auxiliary power (A x B):__________($/year).
The potential for reducing this power consumption can be estimated by comparing the
performance of your station to those reported in the survey. A good unit of measure for
comparison is the auxiliary power consumption as a percentage of the station net
generation. This is calculated as:
D. Station annual net generation:__________(MWh).
E. Specific auxiliary power consumption (A/D x 100):_________(%).
Compare this value to the survey results for systems most like your FGD system (see
Appendices A and B). In particular, compare to the results for the same general sulfur
level and the same oxidation type (forced vs. natural or inhibited oxidation). The latter
is most important for high sulfur systems, where the power consumed by forced
oxidation compressors can be significant. The oxidation type is less important for low
sulfur fuels.
This comparison may also be influenced by other specifics of your system. For example,
FGD systems that employ high-pressure-drop venturi absorbers may show higher
specific power consumption values, or units that bypass a high percentage of the flue
gas around the FGD system may show lower values. Also, the survey results are mostly
based on data from high capacity factor (>70%) units. If your system operates at a much
lower capacity factor (particularly with many hours at low unit load), this comparison
may not be as relevant.
F. Survey results:__________% (median)__________%(low)__________%(high).
If your results in Line C (total annual power cost) are high (e.g., several hundred
thousand dollars or more annually) or if the result in Line E is near or greater than the
survey median value in Line F, you may be able to realize significant savings by
reducing auxiliary power consumption.
2-3
Savings Strategies
Strategies for reducing auxiliary power consumption generally focus on scrubber

booster fans, absorber recycle pumps, and forced oxidation compressors (for units so
equipped).
Scrubber Booster Fans
Booster fan power is typically a function of the amount of flue gas treated and the FGD
system pressure drop. Strategies for reducing fan power consumption include
bypassing more flue gas around the FGD system, modifying the absorber design or
operation to reduce pressure drop, and varying the number of absorbers in service to
treat a given volume of flue gas. The effects of these variables and the tradeoffs
involved in optimizing these variables are briefly discussed below.
Amount of Bypass – On systems equipped with duct or stack bypass provisions, fan
power can be reduced by increasing the amount of flue gas bypass and treating less gas
in the FGD system. This usually requires higher SO 2 removal percentages from the flue
gas treated, by:
x Raising pH set points, at the expense of higher reagent consumption, higher waste
disposal rates, and potentially increased absorber and/or mist eliminator plugging.
x Increasing L/G ratios, which increases pumping power and may increase pump
maintenance costs.
x Adding performance additives or increasing performance additive concentrations,

which results in increased additive costs.
Absorber Pressure Drop – If your absorbers operate at significant pressure drop [e.g.,
more than 2 to 3 inches of water (0.5 to 0.75 kPa)] modifications may be possible to
reduce this value. On venturi absorbers, the throat area may be increased to reduce
pressure drop, to the extent that particulate and SO2 removal performance can be
maintained within target levels. In packed absorbers, the amount of packing may be
decreased, again dependent on maintaining required SO 2 removal levels. For absorbers
that operate at high pressure drop due to O&M problems (plugged packing, plugged
mist eliminators), other process modifications may be implemented to reduce absorber
pressure drop.
However, the ability to realize power consumption gains may be limited by the gas
flow configuration and fan type. For systems where absorber flue gas flow rates are
controlled by dampers, a decrease in absorber pressure drop may be completely offset
by increased pressure drop across the flow control dampers. The dampers typically just
close further to maintain the desired flow rate. Even in systems that control flow rate
2-4
through the absorbers with variable-pitch, axial-flow booster fans, little power savings
may be realized from reduced absorber pressure drop if the fan efficiency decreases
markedly when the blade pitch is decreased to maintain the desired flow rate. In some
cases, fan modifications may be possible to realize power reductions.
Varying Number of Fans and Absorbers in Service – For systems where there is spare
module capacity, the fan power can be minimized by varying the number of modules
in service. In general, having more modules in service will tend to lower flue gas
pressure drop through the modules, which would be expected to lower fan power
requirements. However, because of the fan and damper configuration issues described
above, not all systems will realize significant fan power reductions from operating
more modules at a given flue gas rate. Having more modules in service may increase
pump power consumption, unless fewer pumps per module can be operated at the
lower gas velocities. Also, operating more modules may adversely affect the FGD
system water balance if fresh water is used for mist eliminator washing or pump seals,
and may affect the module sparing/availability philosophy.
For some systems, fan and overall power consumption will be minimized by having
the minimum number of modules in service, as set by mist eliminator velocity or
absorber SO2 removal performance constraints. For others, having more modules on
line at lower gas velocity may lower fan power costs. Other factors influence this
optimization. These can include the booster fan and damper configuration; flue gas
velocity effects on absorber SO2 removal performance, pH set point, reagent utilization,
and sulfur oxidation percentage; mist eliminator performance as a function of flue gas
velocity; and the overall FGD system water balance.
Absorber Recycle Pumps
Absorber recycle pump power consumption is typically a function of the number of

absorbers in service and the number of pumps operating per absorber. For systems that
have spare absorber modules and/or multiple spray header/pump combinations per
absorber, the number of operating modules and pumps per module can be optimized.
That is, at a given unit load and/or flue gas flow rate treated, the number of absorbers
and pumps per absorber can be optimized for minimum overall power consumption.
However, absorber SO2 removal performance, reagent utilization, sulfur oxidation
percentage, and mist eliminator performance, as well as the overall system water
balance may influence this optimization.
Other factors can also be optimized to lower pump power consumption. For example:
pH Set Point – Can be raised to allow operating fewer pumps per module, but at the
expense of greater reagent consumption and possibly increased module or mist
2-5
eliminator plugging. This approach will also increase waste disposal quantities or
could adversely affect the quality of saleable byproducts.
Performance Additives – Can be added to systems not currently using performance

additives, or concentrations can be increased in those that do to allow operating fewer
pumps per module. This approach can require capital costs to install an additive feed
system, and O&M costs to purchase the additive. Other effects on the system can occur
when additives are used, including changes in reagent utilization, sulfite oxidation
percentage, system scaling tendency, slurry dewatering properties, etc.
Module revisions – Modifications such as tray retrofits or nozzle/header revisions in

spray towers, and packing level or type changes in packed absorbers, can allow
operating with fewer pumps to reduce pump power consumption. However, each of
these have capital expense requirements and may affect other cost areas such as reagent
utilization, absorber scaling tendencies, or fan power requirements.
Oxidation Air Compressors
In forced oxidation systems, the power consumed by the oxidation air compressors can
be significant. Compressor power consumption can be minimized by lowering
oxidation air flow rates. However, the air flow rates must be sufficient to ensure
adequate oxidation percentages in the byproduct solids, and to maintain sulfite levels
in the recirculating slurry liquor low enough to avoid limestone blinding episodes.
Other variables may be simultaneously optimized along with oxidation air flow rate.
These may include the number of modules and absorber recirculation pumps in
service, pH set point, and slurry level in the absorber reaction tank (if this can be
varied). The optimum values for these variables may change as the fuel sulfur content
and flue gas flow rate through the FGD system vary.
The ability to realize power savings by reducing oxidizing air rates will depend on the
compressor and air flow control configuration. For example, if the oxidizing air rate is
reduced by merely operating a control valve in a more closed position, little or no
power savings will be realized.
Reagent Consumption
Alkali reagent can be a major cost category, especially for high-sulfur-coal FGD
systems. This expense can often be reduced by improving reagent utilization. In some
cases, reagent costs can be reduced by changing the reagent source or supplier, or even
by changing the reagent type. For systems that use performance additives, these
additives can represent another significant reagent expense that can be optimized.
2-6
Potential Savings
As was discussed for power consumption above, the potential savings achievable
through reducing reagent consumption is dependent on the amount of the current
reagent costs, and the potential percent reduction in the consumption rate and/or the
unit cost of that reagent.
The annual reagent cost may be tracked directly by your utility, or it may be calculated
from the annual tonnage consumed by the FGD system times the average cost per ton.
A. Annual alkali reagent consumption by the FGD system:__________(tons).
B. Average delivered cost per ton:__________($/ton).
C. Annual alkali reagent cost (A x B):__________($/year).
The potential for reducing reagent consumption can be estimated from the FGD system
average reagent ratio, which is defined as the moles of alkali reagent consumed
divided by the moles of SO 2 removed.
The average reagent ratio can be determined two ways. One is based on average
laboratory determinations of reagent utilization.
D. Average laboratory reagent utilization:__________(%).
E. Reagent ratio (100/D):__________(unitless).
Alternately, the reagent ratio can be calculated from the annual tonnage of alkali
reagent consumed, and the tons of SO2 removed by the FGD system.
F. Average reagent purity:__________(%).
G. Molecular weight of reagent (56.1 for lime (calcium oxide) or 100.1 for
limestone):__________ (lb/lb-mole).
H. Moles of reagent consumed (A x 2000 x F/100/G):__________(lb-moles).
I. Tons of SO2 removed by the FGD system:__________(tons).
J. Moles of SO2 removed by the FGD system (I x 2000 / 64):__________(lb-moles).
K. Reagent ratio (H/J):__________(unitless).
2-7
The reagent ratio based on laboratory analyses (E) is usually more accurate than that
based on annual tonnages (K), just because of the difficulties in accurately measuring
quantities such as annual tons of SO2 removed. However, either or both of these reagent
ratio values (E and K) can be compared to “best practice” in FGD systems to determine
how much potential there is to reduce reagent consumption in your system. For most
wet FGD systems, a reagent ratio of approximately 1.02 to 1.05 is about the best that can
be achieved. An exception would be systems that remove fly ash and SO2 together and
that have an alkaline ash. For these systems the contribution of the ash alkalinity to SO 2
removal can make the apparent reagent ratio lower than 1.0.
For most other wet FGD systems, though, the potential cost savings associated with
reducing alkali reagent consumption can be calculated by the difference between the
current reagent ratio and the best possible value, multiplied by the current annual
alkali reagent cost.
L. Potential savings (A x [E {or K} – 1.02] x B):__________($/year).
For wet limestone systems that currently operate at reagent ratio values greater than
approximately 1.2, there may be adverse impacts of operating at such high excess
reagent ratio (such as mist eliminator scaling and plugging) that would further increase
the economic incentive to reduce reagent consumption.
Savings Strategies
There are a number of strategies for reducing alkali reagent consumption. These can
include improving pH control, lowering pH set points, improving limestone reagent
fineness, using performance additives, avoiding limestone blinding incidents, and
using alternate reagents. Each of these is briefly described below. The tradeoffs
associated with implementing each of these measures are also mentioned.
Improved pH Control – Reagent is often wasted because the absorber recirculating

slurry is not controlled at the appropriate level. If the pH is allowed to rise to too high a
level, the reagent ratio and the excess limestone content of the blowdown slurry
increase correspondingly. Excess limestone in the blowdown slurry generally leaves
the FGD system as a waste in the byproduct solids.
There are a number of reasons for poor pH control. These can include operator error,
pH instrument calibration error, pH electrode failure, poor pH control loop tuning,
poor pH control design, limestone blinding episodes, and others.
Improvements in pH control may increase operator or maintenance labor to implement,

and may sometimes require upgrades or revisions to piping, valves, or controllers.
Other than these cost items, there are rarely other tradeoffs involved with this
2-8
technique for reducing reagent consumption. In fact, there may be other benefits such
as decreased ball mill power requirements, reduced waste disposal quantities or
improved byproduct quality, and reduced scaling tendencies in absorbers and mist
eliminators.
Lowering pH Set Points – Lower pH set points generally lead to operation at lower
reagent ratio values, and correspondingly lower excess lime or limestone levels in
absorber blowdown slurries. Lower reagent ratio values generally have the effect of
lowering SO2 removal performance, though. To maintain target SO2 removal values,
lower pH set points typically have to be offset by other changes to restore SO2 removal
performance, such as operating more pumps and slurry headers to increase the L/G, or
adding performance additives. The reduction in reagent consumption that can be
realized has to be weighed against the increased power costs for running more pumps,
or increased additive costs for the latter approach.
These changes to allow operating at lower pH set point may have other adverse affects
on FGD system performance and cost. For example, operating at higher L/G may
increase sulfite oxidation percentages in inhibited or natural oxidation systems, into a
regime where gypsum scaling is encountered. In these systems, lower pH set points
alone can lead to increased sulfite oxidation percentages. Conversely, in forced
oxidation systems lower pH set points can have a beneficial effect of allowing a
decrease in oxidation air rate.
Improved Limestone Fineness – If a finer limestone grind is fed to the absorbers, SO 2

removal performance can typically be maintained at a lower reagent ratio. This lower
reagent ratio may or may not correspond with lower pH set points. Lower reagent
ratios lead to less excess reagent in the absorber blowdown.
Improved limestone fineness is typically achieved by changes in the limestone grinding

circuit. These changes almost always require reduced throughput through the
limestone grinder, which is usually a ball mill. At lower throughput, the mill must
operate for a longer period, and will consume more power. The mill power
consumption rate is typically not very sensitive to the limestone throughput, so greater
hours of operation result in a proportional increase in energy consumed. Equipment
changes to the ball charge and/or to the limestone classifiers may also be required.
Improved limestone fineness can also be achieved by changes in the raw limestone
feed. This effect is discussed below.
Performance Additives – The use of performance additives such as dibasic acid or

sodium formate typically allow the pH set point and reagent ratio to be lowered while
maintaining the previous SO2 removal performance. Of course, the resulting decrease in
alkali reagent usage must be weighed against the cost of the additive. Also, the benefits
of reduced reagent consumption by lowering pH set points should be weighed against
2-9
the benefits of other changes possible with additives, such as lowering power
consumption by operating fewer absorber slurry recycle pumps.
Performance additives can affect other portions of the FGD process, including sulfite
oxidation percentages and blowdown slurry dewatering properties. Performance
additives should be tested in one or more modules before being permanently
implemented. Also, performance additives are typically not cost effective in systems
that operate with a relatively open water loop (once-through water usage or low cycles
of concentration).
Avoid Limestone Blinding – Limestone blinding most commonly occurs in “in situ”
forced oxidation wet FGD systems, when liquid phase sulfite concentrations are
allowed to raise too high. During limestone blinding, the reagent ratio can be raised
very high by adding large amounts of limestone to the absorber recirculating slurry,
but the pH remains low. Blinding episodes are typically avoided by improving the
oxidation effectiveness, such as by increasing the oxidation air rate, raising the slurry
level in the oxidation tank, or operating more modules (to lower the SO2 pickup rate
per module).
Limestone blinding has also been observed in systems that use performance additives
such as dibasic acid, for short periods of time after the additive concentration is
increased by “slugging” the system with large quantities of the additive. These
episodes can be avoided by increasing additive concentrations in a more gradual
manner.
Finally, limestone blinding has been encountered in systems with high aluminum
fluoride concentrations in the FGD liquor. This blinding is typically avoided only by
eliminating the source of alumina in the liquor, if possible, generally by improving fly
ash capture in the upstream particulate control device.
Alternate Reagents – In some cases alkali reagent costs can be lowered by considering
alternate reagents. For limestone FGD systems, the choice of stone may influence the
overall limestone consumption rate. For example, a smaller raw limestone feed size or a
limestone with a lower Work Index may grind to a finer product particle size
distribution in the existing grinding system. Also, “unscalped” limestones [e.g., ¾” by
0” (19 mm by 0 cm)] typically grind to a finer product particle size distribution than a
scalped limestone [e.g., ¾” by ¼” (19 mm by 6 mm)] with the same top size.
Many limestones have a measurable magnesium content. In some stones this

magnesium is present as dolomite (MgCO3*CaCO3), which is essentially unreactive in
wet FGD systems. The calcium carbonate present in the dolomite is also unreactive in
wet FGD systems. In other limestones, magnesium is present as a more reactive “solid
solution” with the calcium carbonate. The latter stones are generally more effective as a
wet FGD reagent, because more of the calcium carbonate is available in the FGD
2-10
system. For some FGD system types, the reactive magnesium content also raises the
absorber slurry liquid phase alkalinity.
Alternate sources of limestone or calcium carbonate in other forms may be used to

lower overall alkali reagent costs. For example, calcium carbonate sludges from water
treatment or tailings from limestone quarries may be lower cost sources of alkali than
commercially available, sized limestone products. These alternate reagent sources
should be tested at full scale before implementing permanent changes. Some reagent
handling equipment may require revisions to handle alternate reagent sources.
Some FGD systems can lower their overall costs by considering a change in reagent
type (e.g., lime to limestone or vice versa). However, there are often substantial
conversion costs involved in such reagent switches, usually involving changes to
reagent handling and preparation equipment. Such reagent type switches usually
require detailed engineering studies and cost estimates to determine their cost
effectiveness.
Operating Labor
Operating labor cost ratios provide a measure of how labor intensive is your FGD
system. High operating labor costs may be an indicator that the system is not
adequately automated. These ratios might be lowered by applying cost saving
strategies. On smaller units, high operating cost ratios may be inevitable, though, due
to “economy of scale” issues.
Potential Savings
The potential amount of savings achievable by reducing operating labor is a function of

the current annual FGD operating labor expenditure and the amount by which it can be
reduced. The relative operating labor effort for your FGD system is best put into
perspective by comparison with the FGD cost survey results.
The total annual operating labor cost may be reported in a number of manners, making
it difficult to compare numbers on an equivalent basis. In some cases, the plant
accounting system will be able to track operating labor separately for each area of the
power plant. These labor costs may be reported in terms of direct salary costs, or may
also include indirect costs such as benefits. Where possible, use the “loaded” labor
costs. Supervising labor costs should be included, and the cost of contract labor should
also be included.
In other situations, these labor costs may not be tracked by area of the power plant. In
this situation the best estimate for operating labor may be to count the total number of
persons assigned to the FGD for operations and supervision and multiply the number
2-11
of persons times the hours worked per year, then times the average hourly pay rate.
This hourly rate should include the cost of fringe benefits. If some staff members split
their time between the FGD system and other parts of the power plant, count them as
“fractional” persons, applying the percentage of time they work on the FGD system.
Include laboratory personnel with the operating labor. Operating labor cost data may
also be taken from the EIA-767 form for your station (see Section VII of the form).
For the purposes of benchmarking operating labor against the survey results, the costs
are best compared on the basis of labor dollars per ton of SO2 removed, and/or labor
dollars per MWh for the treated unit(s).
The ratios are calculated as follows:
A. Total operating labor for the FGD system, including laboratory technician support
and supervisors:__________($ annually).
B. Tons of SO2 removed by the FGD system:__________(tons/yr).
C. Total annual operating labor cost per ton of SO2 removed (A / B): _________($/ton).
The operating labor ratio can also be expressed in terms of dollars per megawatt,
calculated as:
D. Annual net electric power generation by the scrubbed unit(s):__________(MWh).
E. Total FGD operating labor cost per unit output (A/D):__________($/MWh).
Compare these values (C and E) to the FGD survey results for systems most like your
FGD system (see Appendix A). The value “E” cost ratio can also be compared to the
EIA-767 form results for “labor and supervision.”
It is best to compare operating labor costs for plants in the same general size range, and
for similar sulfur content in the coal. A small FGD system would tend to have a larger
operating labor ratio than larger units. The average FGD system in the cost
benchmarking surveys typically treat flue gas from about 500 MW of generating
capacity.
Also, consider the implications of reducing operating labor requirements on the station
staffing levels. If the current operating labor levels are being supplied by permanent
utility staff members, it may be difficult to realize any costs savings through improved
FGD operation unless the utility management is willing to consider staff reductions or
reassignments to other areas in the plant.
2-12
This comparison may be influenced by other specifics of your system. For example,
FGD system units that bypass a high percentage of the flue gas around the FGD system
may show higher ratios when expressed in terms of dollars per ton of SO2 removed, but
lower ratios when expressed in terms of dollars per MWh. Also, the survey results are
mostly based on data from high capacity factor (>70%) units. If your system operates at
a much lower capacity factor (particularly with many hours at low unit load), this
comparison may not be as relevant.
The potential for reducing operating labor costs is determined by comparing your
ratios to the median and low values for these similar FGD systems. If your ratios are at
or above the median, there is probably a good potential for lowering these costs.
To determine the annual savings that may be possible, multiply the median and low
values for the similar FGD system by your annual tons of SO2 removed (B) or net
generation (D), depending on which ratio you are comparing. The product of these
numbers can be subtracted from your values, and will represent a range of savings in
operating labor costs that may be possible.
Savings Strategies
Strategies for lowering operating labor requirements include:
x Co-locating the FGD control room with the boiler control room so the boiler
operator can also serve as the FGD control room operator.
x Providing remote start/stop capability and status indicators wherever possible to

minimize the need for manual starts and stops when taking absorbers, pumps, and
mills on and off line.
x Installing control room indicators for key pressure, flow rate, temperature, and
valve position indicators to minimize the need for local recording of these
measurements.
x Providing other automation such as automatic flush and drain lines on recycle
pumps to minimize manual efforts when pumps are taken off line.
However, these capabilities are generally expensive to retrofit on existing units, and it
may be difficult to adjust operator staffing levels after the FGD system has been
operating for some time. Consequently, more emphasis in this report will be placed on
reducing maintenance requirements, which are discussed below.
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Maintenance Labor and Materials
This cost category includes maintenance staff labor and contract maintenance as well as
maintenance materials costs. Significant maintenance materials costs include packing
and mist eliminator element replacement; ball mill ball charge and liners; recycle pump
seals, liners, and impellers; absorber and duct linings; thickener rakes and drives;
centrifuge shafts, bowls, bearings, and drives; filter belts and vacuum pumps; pH
electrodes; CEM parts; etc.
Potential Savings
As in the previous section, maintenance costs are best compared with the survey results
on the basis of dollars per ton of SO2 removed, and dollars per MWh of generation by
the unit(s) treated. Maintenance staff labor costs can be estimated on a head count basis
in the same manner as was described above for operating labor. Maintenance staff
labor, contract maintenance materials costs as an aggregate can be taken from the most
recent Form EIA-767 for your station (see Section VII of the form).
The maintenance cost comparison values are calculated as:
A. Total annual maintenance materials cost for the FGD system:____________________

($ annually).
C. Total annual maintenance materials cost per ton of SO2 removed (A / B):
_________($/ton).
The maintenance materials ratio can also be expressed in terms of dollars per
megawatt-hour, calculated as:
D. Annual net electric power generation by the scrubbed unit(s):__________(MWh).
E. Total FGD maintenance materials cost per unit output (A/D):__________($/MWh).
The values for maintenance staff labor and contract maintenance are calculated
similarly:
F. Total maintenance staff labor for the FGD system, including supervisors:
__________($ annually).
G. Total FGD maintenance staff labor cost per ton of SO2 removed (F / B):
_________($/ton).
2-14
H. Total FGD maintenance staff labor cost per unit output (F / D):
__________($/MWh).
I. Total contract maintenance costs for the FGD system: __________($ annually).
J. Total FGD contract maintenance cost per ton of SO2 removed (I / B):
_________($/ton).
K. Total FGD contract maintenance staff labor cost per unit output (I / D):
__________($/MWh).
It is best to compare maintenance costs for plants in the same general size range, and
for similar sulfur content in the coal. The age of the FGD system also tends to influence
maintenance costs, as newer units have taken advantage of lessons learned from earlier
systems to produce more reliable designs and of course have newer equipment. The
maintenance costs for the newest FGD systems probably represent the lower limit of
what can be achieved by older systems. The oxidation mode and reagent may also
influence maintenance costs.
This comparison can be influenced by other specifics of your system. For example, FGD
systems units that bypass a high percentage of the flue gas around the FGD system may
show higher ratio values when expressed in terms of dollars per ton of SO2 removed,
but lower ratios when expressed in terms of dollars per MWh. Also, the survey results
are mostly based on data from high capacity factor (>70%) units. If your system
operates at a much lower capacity factor (particularly with many hours at low unit
load), this comparison may not be as relevant.
The potential for reducing maintenance costs is determined by comparing your ratios
to the median and low values for these similar FGD systems. If your ratios are at or
above the median, there is probably a good potential for lowering these costs.
To determine the annual savings that may be possible, multiply the median and low
values for the similar FGD system by your annual tons of SO2 removed (B) or net
generation (D), depending on which ratio you are comparing. The product of these
numbers can be subtracted from your values, and will represent a range of savings in
maintenance materials costs that may be possible. These comparison data are available
in both Appendices A and B.
Note that if you are using the EIA data in Appendix B for comparison, the maintenance
materials ratio “E” will have to be combined with the corresponding ratios “H” for
maintenance staff labor and “K” for contract maintenance. The sum of these three
values can be compared to the EIA survey results for “maintenance, materials, and all
other costs.”
2-15
Savings Strategies
A number of the strategies discussed in Section 3 can have an impact on maintenance

labor and materials requirements. A prevalent maintenance requirement in wet
limestone FGD systems is the need to take absorbers off line to manually clean scaled
or plugged mist eliminators, scaled packing or other absorber internals, plugged slurry
nozzles, etc. In-line reheaters in FGD systems so equipped have also been problematic,
experiencing tube failures and plugging of gas flow passages.
Example strategies for lowering maintenance requirements include:
x Add sulfur to inhibit oxidation in natural oxidation systems, and reduce absorber
and mist eliminator gypsum scaling tendencies.
x Modify/upgrade the mist eliminator design and wash system to reduce scaling and
plugging.
x Convert an FGD system with in-line or fired reheaters to wet stack operation to
avoid reheater corrosion, pluggage, or other maintenance.
x Convert a bypass reheat system to wet stack operation to avoid corrosion and
scaling at the interface between cool, wet gas and hot, high-sulfur-content gas.
x Upgrade materials of construction in stack liner, outlet ductwork, absorber, reaction

tank, etc. to avoid corrosion, liner failures or other materials problems.
x Improve pH control to avoid high reagent ratio operation and reduce the potential
for absorber and mist eliminator scaling.
x Improve limestone grind fineness, use performance additives, and/or increase L/G
to allow operation at lower excess limestone levels, to reduce the potential for
absorber and mist eliminator scaling.
x Modify dual-loop FGD systems to split limestone feed and directly control the pH
in both loops, to avoid high reagent ratio operation in the upper loop and reduce the
potential for absorber and mist eliminator scaling.
x Convert natural or inhibited oxidation systems that cannot control sulfite oxidation
percentages below 15% to forced oxidation, to reduce the gypsum scaling potential.
x Modify dual-loop, forced-oxidation FGD systems to force-oxidize in both loops

rather than just the lower loop, to reduce the likelihood of gypsum scaling in the
upper loop.
x Add pump suction screens to avoid spray nozzle pluggage.
2-16
x Convert packing gland seals on recycle pumps to mechanical seals.
Many of these strategies impact other cost categories as well, such as auxiliary power
consumption and reagent consumption. These impacts and cost category tradeoffs are
further discussed in Section 3.
Byproduct Sales or Disposal Costs
This cost (or revenue) is directly related to the FGD type and reagent, and the volume,
SO2 content, and control efficiency of the flue gas treated. Typically, only FGD systems
that forced oxidize the byproduct to gypsum can sell their byproduct. Systems that
produce a sulfite byproduct are typically faced with some sort of byproduct disposal
cost. Similarly, systems that remove fly ash along with the FGD byproduct face a
limited market for this mixed material.
The location of the FGD system also has a big impact on revenues or disposal costs.
Gypsum-producing systems must be located near a wallboard plant to be able to
realize such revenues. For sulfite-producing plants, or plants that remove fly ash along
with the FGD byproduct, plants in the Western U.S. that are located in areas of high net
evaporation can often blow down from their absorbers to evaporation ponds, with very
low treatment and disposal costs. Mine-mouth plants are often able to dewater and
stabilize the FGD byproduct, and return this material to closed sections of the mine at
relatively low cost.
EPRI supported research has determined that there may be other markets for FGD
byproduct use. Gypsum and stabilized sulfite sludge from wet FGD systems can be
used as structural fill or road base material. Spray dryer FGD wastes may also be used
in these applications. Gypsum that cannot be used in wallboard manufacturing can be
used in other applications, such as agricultural uses, cement production, and fillers in
plastic.
Otherwise, plants have to place their dewatered and stabilized byproducts in lined
landfills. Some newer landfills are requiring double liners and continuous leak
detection. For plants located in or near populated areas, where land values are high,
disposal costs can correspondingly be quite high.
While the FGD system operators have little control over some of these factors, they can
minimize the amount of waste generated by maximizing reagent utilization and
byproduct dewatering. The FGD system operator can also consider a system change
from producing a sulfite waste to forced oxidizing and producing a gypsum byproduct.
2-17
Potential Savings
Byproduct revenues or disposal costs are best compared on the basis of dollars per ton
of SO2 removed. This ratio is calculated as:
A. Total annual byproduct disposal cost (byproduct revenue) for the FGD
system:__________($ annually).
C. Total annual byproduct disposal cost (credit) per ton of SO2 removed (A / B):
_________($/ton).
The disposal cost (A) should consider all costs associated with handling the byproduct.
These costs typically include stabilization additives (lime and other additives such as
Calcilox), the cost of lost fly ash sales revenues if saleable ash must be mixed with the
FGD sludge, sludge transportation, and amortized landfill purchase, construction, and
operating costs. For systems that produce a saleable gypsum byproduct, the credit
applied here should be equal to the annual gypsum tonnage produced times the
gypsum contract sales price F.O.B. the power plant site.
The ratio C above can be compared to other similar FGD systems from the FGD cost
survey and/or EIA Form 767. For the purposes of benchmarking, the comparison is
best made to FGD systems that treat approximately the same sulfur level, use the same
reagent, and operate in the same oxidation mode.
For determining the potential cost savings in this cost category, two options can be
considered. The first is to consider the potential revenues from converting a sulfite-
producing system to produce a saleable gypsum byproduct. The revenues that could be
generated can be estimated as:
D. Annual tons of SO2 removed by the FGD system (B) x (172 tons gypsum/64 tons
SO2) x Gypsum sales price ($/ton): _________($ annually).
The gypsum sales price would typically be in the range of $0 to $3.00, assuming there is
a wallboard manufacturer in close proximity to the FGD system. This price quickly
becomes negative if the gypsum has to be shipped an appreciable distance [e.g., more
than 50 to 100 miles (80 to 160 km) by truck; this distance could be greater if barge
shipment is an option].
The annual savings from this conversion would be calculated as A + D. This amount
would be available to cover the amortized capital cost for the gypsum conversion and
the increased operating cost in this mode (typically includes maintenance and power
2-18
for air compressors, and performance additives). Section 3 provides example economics
for such a conversion.
Another approach for determining the possible savings would be to look at the
potential for reducing the amount of FGD byproduct sent to disposal under the current
FGD operating mode. Obviously, one way to reduce the amount of byproduct sent to
disposal is to remove fewer tons of SO2 annually. However, this might only be
considered if the market value of SO2 allowances is less than the incremental cost of
removing SO2 in the FGD system and disposing of the byproduct, and if allowed by
state and local regulations.
Typically the excess reagent content and the moisture content of the byproduct are the
only parameters that can be controlled to reduce the amount of byproduct sent to
disposal. The effects of reducing each of these tends to have a multiplicative effect on
the waste disposal quantity, so the two should be considered in concert to estimate the
potential savings in byproduct disposal costs that might be realized.
If the quantity currently being sent to byproduct disposal is not already known, it can
be estimated as follows:
E. Tons of SO2 removed by the FGD system annually:__________(tons/yr).
F. Molecular weight of byproduct:__________(130 for calcium sulfite, 172 for gypsum).
G. Dry tons of byproduct annually (E x F / 64):__________(tons/yr).
H. Average reagent utilization in FGD system:________(%).
I. Average reagent purity:________(%, assume 95% if not known).
J. Molecular weight of reagent:________(74.1 for slaked lime, 100 for limestone).
K. Excess reagent codisposed with byproduct ([E x J x (100 – H)] / [64 x H]):
_________(tons/yr).
L. Reagent inerts codisposed with byproduct ([E x J x 100 x (100 – I)] / [64 x H x I]):
_________(tons/yr).
M. Total dry solids sent to disposal (G + K + L):_________(tons/yr).
N. Average wt% solids in byproduct sludge sent to disposal:_________(wt%).
O. Total wet sludge sent to disposal (M x 100 / N):_________(tons/yr).
2-19
To estimate the potential for reducing this quantity, these calculations can be repeated
with “best” values substituted for the average reagent utilization and byproduct weight
percent solids levels experienced by your plant. These calculations would be:
P. Maximum reagent utilization in FGD system:________(%, use 98% as an upper limit

in most cases).
Q. Minimum excess reagent co-disposed with byproduct ([E x J x (100 – P)] / [64 x P]):
_________(tons/yr).
R. Minimum reagent inerts codisposed with byproduct ([E x J x 100 x (100 – I)] / [64 x
P x I]): _________(tons/yr).
S. Minimum dry solids sent to disposal (G + Q + R):_________(tons/yr).
T. Maximum wt% solids in byproduct sludge sent to disposal:_________(wt%, typical

high values are 75 wt% for calcium sulfite from limestone reagent FGD systems,
65% for calcium sulfite from lime systems, and 95% for gypsum from fully oxidized
systems).
U. Minimum amount of wet sludge that could be sent to disposal (S x 100 / T):
_________(tons/yr).
The amount that could be saved by minimizing sludge production can then be
estimated as a ratio compared to the current value, by calculating:
V. Potential amount saved (A x [O – U] / U):__________(potential $ saved annually).
This amount is only a first estimate. The amount that could actually be saved could be
substantially higher or lower. If the current disposal costs are not closely related to
sludge quantity, the actual savings potential would be lower. Examples of this situation
would be plants that have ample waste disposal area available, do not have a market
for fly ash that is currently co-disposed with the FGD sludge, do not use lime or other
additives to help stabilize the sludge/fly ash mixture.
Examples where the savings could be greater might be plants that have to increase the
ratio of FGD byproduct to saleable fly ash, lime, and/or other stabilization additives as
the moisture content of the byproduct increases. Such plants might realize a greater
savings than would be predicted by ratios of the wet sludge amounts according to
Equation V.
2-20
Savings Strategies
For systems that currently produce a calcium sulfite sludge, conversion to forced
oxidation to produce a saleable byproduct could have a significant impact on
byproduct disposal costs. This conversion is discussed in some detail in Section 3. Of
course, this conversion typically requires capital investment in the millions of dollars,
and the economics are generally only attractive if there is a suitable market for the
gypsum byproduct.
If a gypsum conversion is not being considered, the best strategies for reducing
byproduct disposal costs are those that maximize reagent utilization and byproduct
sludge solids content. Several strategies that address these values are discussed in
Section 3. Example strategies include:
x Add performance additives to allow operation at lower pH set points and higher
limestone utilization. This strategy may also affect the byproduct sludge moisture
content; the effect could be either beneficial or negative.
x Adjust recycle slurry weight percent levels to maximize limestone utilization

and/or dewatered sludge solids content.
x Modify reagent preparation/reagent source to maximize reagent utilization.
x Vary number of absorbers in service and pumps/spray header levels per absorber
to maximize reagent utilization.
x Lower pH set point/improve pH control to improve reagent utilization.
x Add a tray or packing to the absorbers to allow operation at lower pH set points
and improved reagent utilization.
x Add polymers/flocculents to improve primary and secondary dewatering

equipment performance.
x Optimize primary and secondary dewatering equipment operating variables to

produce the highest weight percent solids levels in dewatered sludge.
x Raise venturi contactor throat pressure drop to allow operating at lower pH set
points and higher reagent utilization.
Of course, most of these strategies impact other cost areas, such as auxiliary power
consumption and reagent consumption. Note that strategies that reduce byproduct
disposal costs by improving reagent utilization will also result in savings in the reagent
consumption cost category.
2-21
Incremental Costs for SO2 Removed
The results from completing the calculation templates in this section can be used to
estimate the incremental costs for removing SO2 in your FGD system. This value is
useful for comparing your costs to the market value of SO2 allowances under the
program established by the Clean Air Act Amendments of 1990, to help determine your
utility’s most cost-effective approach for compliance.
The incremental cost is that associated with removing more (or fewer) tons of SO2 in an
existing FGD system, considering that relatively fixed costs such as FGD system capital
recovery expenses and operating staff labor will be spent regardless. If a decision were
made to shut down an existing FGD system and purchase allowances for compliance
with the provisions of the 1990 Clean Air Act Amendments, operating staff labor costs
could be reduced, though.
In general, the costs for reagent, additives, and waste disposal are directly proportional
to the tons of SO2 removed by the FGD system. The simplest estimate of the incremental
cost of SO2 removed by an existing FGD system would be to sum the dollar per ton
rates for these three categories, as calculated earlier in this section.
Other cost categories such as maintenance staff labor, contract maintenance,

maintenance materials, and auxiliary power may vary with the amount of SO2
removed, but generally, not in direct proportion. A more accurate estimate of the
incremental cost of SO2 removed may result if these cost categories are analyzed and a
portion of these costs are added to the estimate.
Section 3 provides information about how cost saving strategies can be applied to lower
the incremental cost of SO2 removed, and/or to cost effectively remove more SO2 with
an existing FGD system.
2-22
3
COST SAVINGS STRATEGIES
This section discusses a number of strategies that may be employed to optimize

performance and/or reduce O&M costs for existing wet lime or limestone FGD
systems. Each strategy is described, and factors that affect the cost effectiveness of that
strategy are discussed. For each strategy, an example is provided for how that strategy
might be applied and the economics for that application. Not all of the examples are
cost effective, as would be expected in the “real world.” For the more complex
examples, details of the cost effectiveness calculations are provided as a guideline for
completing similar calculations for the reader’s system. Also, where possible average
values or “rules of thumb” have been provided for the strategies, to allow the reader to
make a first estimate of whether that strategy would be cost effective for his or her FGD
system.
The strategies are not presented in a particular order, although in general the most
widely applicable strategies are presented first. Table 3-1 lists the strategies discussed
and which of the five cost categories discussed in Section 2 are most impacted by each
strategy.
Use Performance Enhancing Additives
Description of the Strategy
Performance additives are used as a cost-saving measure in a number of FGD systems.

Most use organic acids, or salts of organic acids, that serve to buffer the pH of the
recirculating slurry droplets as they fall through the absorber. This effectively increases
the liquid phase alkalinity available in the droplets for SO 2 absorption. Typical
performance additives of this type include adipic acid, dibasic acid (a mixture of
adipic, glutaric and succinic acid that is a byproduct of adipic acid production), sodium
formate, and formic acid.
Organic acid buffers are typically purchased as high weight percent (e.g., 40 to 50%)
solutions in truckload quantities, stored on site in tanks, and metered into the FGD
system in a controlled manner. Adipic acid and DBA are relatively corrosive, so
stainless steel tanks, pumps, and piping are typically used in most additive feed
systems, to allow flexibility in the type of additive that can be used.
3-1
Table 3-1
List of Cost Reduction Strategies and Their Expected Effect on SO2 Control and Major FGD Cost Categories
Auxiliary Power Reagent Operating/ Maintenance Byproduct

FGD Cost Control Strategies SO2 Control Consumption Consumption Maintenance Labor Materials Disposal
Use performance enhancing additives X X X X X X
Add sulfur/inhibit oxidation X X
Modify/Improve mist eliminator wash system X X
Increase/decrease absorber recirculating slurry percent solids X X
Modify pH set point/control X X X X X
Optimize makeup water use X
Modify reagent preparation X X X X X X
Change liquid-to-gas ratio (L/G) X X X X
Convert to wet stack operation X X X
Close bypass damper X X X X X X
Use spare module in normal operation X X X X
Add tray/packing X X X X
Convert to forced oxidation X X X X X
Install pump suction screens X
Change reagent type X X X X X
Optimize venturi contactor delta P X X X X
Add polymers/flocculents to improve dewatering effectiveness X
Upgrade materials of construction/equipment design X X
3-2
Cost Savings Strategies
Some low oxidation FGD systems use another type of performance additive; they add
magnesium oxide with their reagent. Higher magnesium levels can directly increase
liquid-phase alkalinity by increasing sulfite concentrations in the droplets (sulfite is an
alkaline species with respect to absorbing SO2 into the droplets). The effectiveness of
magnesium as a performance additive is diminished when chloride or sulfate levels are
high. Magnesium is typically added to FGD systems by purchasing a reagent with high
available magnesium content, although some systems slake dolomitic lime and add that
to their normal reagent.
Performance additives can be used in several manners to reduce FGD costs. One is to
allow the pH set point and reagent ratio to be lowered while maintaining the current
SO2 removal performance. This results in a decrease in alkaline reagent usage and a
corresponding decrease in byproduct solids production rate, but at the expense of
purchasing the additive and feed system.
Another possible savings measure is to use the additives to lower power consumption
by operating fewer absorber slurry recirculation pumps per absorber, or even fewer
absorbers. Performance additives may allow the current SO2 removal performance to be
maintained at the resulting lower L/G.
Performance additives can be used to enhance SO2 removal performance. These uses
can include improving the performance of underdesigned absorbers, or
“overscrubbing” a well-performing system to generate additional SO2 allowance
credits.
In some cases, systems that use performance additives can realize savings in
maintenance costs. For example, systems that currently operate at high reagent ratio
(low limestone utilization) may also be experiencing related gypsum scaling on
absorber and/or mist eliminator internals. This effect is described later in this section.
Adding performance additives to allow operating at lower reagent ratio can have an
added effect of reducing scaling tendencies, and may lower absorber and/or mist
eliminator scale cleanup labor and materials costs.
At least one system has seen an additional benefit that also reduced absorber scaling
tendencies. At this location, a performance additive was found to lower sulfite
oxidation percentages in an inhibited oxidation system that had difficulty maintaining
oxidation percentages below 15%. Gypsum scaling can usually be avoided by
maintaining oxidation percentages below 15% in inhibited or natural oxidation
systems, as below this percentage the calcium sulfate formed is precipitated as a solid
solution with calcium sulfite hemihydrate and does not form as a separate gypsum
phase. The decrease in oxidation percentage with the additive was attributed to an
apparent decrease in droplet pH drop across the absorber. Lower pH values in the
droplets can increase oxidation by increasing the solubility of some reactants in the
3-3
sulfite oxidation mechanism. This is not an expected benefit in most performance

additive applications, though.
Performance additives can affect other portions of the FGD process, such as blowdown
slurry dewatering properties. In some cases slurry dewatering properties have been
observed to improve with additives, but in others they have deteriorated. The latter is
particularly true for systems that use magnesium as a performance additive.
Performance additives should be tested in one or more modules before being
permanently implemented.
Determining the Cost Effectiveness of Performance Additives
Performance additives may not be effective in absorbers that already operate at the gas
film mass transfer limit. In these systems SO2 removal is limited by the rate at which
SO2 diffuses from the bulk gas to the droplet surface, such that increasing liquid-phase
alkalinity in the droplet has little effect on overall SO 2 removal. These are typically FGD
systems that already achieve high (e.g., >95%) SO2 removal across the absorbers,
and/or systems that treat flue gas with a very low initial SO2 concentration.
Also, performance additives are typically not cost effective in systems that operate with
a relatively open water loop (once-through water usage or low cycles of concentration),
as the additives are lost with the blowdown liquor. These so-called “solution” losses
occur in all FGD systems with the water that remains adhered to dewatered FGD
solids. Solution loss rates can be calculated by material balance.
“Non-solution” losses also occur in all FGD systems to a varying extent. These include
oxidative degradation (to species that no longer provide buffering capacity),
coprecipitation with solids forming in the absorber recirculating slurry, and
vaporization into flue gas and/or oxidation air. DBA does not vaporize to any
significant extent in FGD systems. The relative importance of DBA degradation and
coprecipitation losses depends on the FGD system oxidation mode. In forced oxidized
systems, DBA coprecipitation losses have been found to be insignificant; degradation is
the primary non-solution loss mechanism. In inhibited or low percent natural oxidation
systems, coprecipitation is typically the primary non-solution DBA loss mechanism, but
degradation can also be significant. Performance additive consumption due to non-
solution losses can vary widely from site to site; it is best to conduct full-scale tests to
determine site-specific consumption rates.
The overall cost effectiveness of performance additives is very site specific, depending
on the amount of benefit realized, the additive consumption rate, and delivered
additive costs. This cost effectiveness can vary markedly by the type of additive
considered, as each will produce different levels of benefit, be consumed at different
3-4
rates, ship from different production locations (different freight costs), and have
different f.o.b. prices.
To make a first estimate of the cost effectiveness of performance additives at your site,
the results of Department of Energy (DOE) and EPRI funded testing at five utility sites
can be used as a guideline. However, remember that this is only a gross estimate and
that the cost effectiveness of additives can vary widely from system to system.
References for this DOE/EPRI are study included in the bibliography presented in
Section 5.
In the DOE/EPRI study, four of these sites were tested for performance improvement
and additive consumption rate at additive concentrations of 1050 ppm to 1200 ppm as
DBA or as formate ion in the absorber recirculating slurry liquor. The observed
improvement in SO2 removal performance was in the range of 1.0 to 1.5 NTU (which is
defined below), and the average additive consumption rate was 11 lb of additive per
ton of SO2 removed by the system (5.5 kg/metric ton). Additive consumption is
expressed as weight of DBA or formate ion consumed on a dry basis.
The actual additive consumption rates ranged from 9 lb/ton to 17 lb/ton of SO 2

removed (4.5 to 8.5 kg/metric ton), and included both solution and non-solution losses.
These were all systems that operate with closed water balances (no liquor blowdown)
and that dewater byproduct solids to approximately 70 wt%. For systems that blow
down liquor or that dewater less effectively, those additional solution losses should be
factored into this estimate.
The SO2 removal performance improvement is expressed in NTU because mass transfer
theory predicts and test data confirm that at lower additive concentrations
(approximately 1000 ppm or less), the effects of additive concentration on SO2 removal
performance is linear when the latter is expressed as NTU. The term NTU (number of
transfer units) can be calculated as:
NTU = ln([SO2 concentration in]/[SO2 concentration out]).
Figure 3-1 illustrates the relationship between percent SO2 removal and NTU.
The performance benefit from using performance additives can be estimated by

calculating your current NTU (consider the SO2 removal across the absorber only, not
including the effects of flue gas bypass on stack SO2 concentrations), then calculating a
new outlet SO2 concentration at an NTU value one unit higher. Again, this is only a first
estimate; the results for your FGD system may vary significantly.
For systems that wish to use performance additives to lower pH set points and improve
limestone reagent utilization, the DOE/EPRI project provides example data. In one
dual-loop system, approximately 1000 ppm of DBA in the upper loop allowed the pH
3-5
100.0%
95.0%
90.0%
Percent Removal
85.0%
80.0%
75.0%
70.0%
0 1 2 3 4 5 6 7
NTU
Figure 3-1
Percent SO2 Removal Versus NTU
3-6
set points in both loops to be lowered by 0.3 units while baseline SO 2 removal
performance was maintained. This increased the observed limestone utilization from 87
to 95%.
The data from this study also illustrate the effectiveness of using performance additives
to allow operation at a lower L/G. In a system with a vertical spray absorber, the
absorber SO2 removal performance achieved with five pumps operating could also be
maintained with four pumps and approximately 200 ppm of formate ion, and with
three pumps and approximately 400 to 500 ppm of formate ion. This system has one
pump per spray header level, so the L/G is essentially proportional to the number of
pumps operating.
The cost of using performance additives mostly depends on the consumption rate of the
additive, which was discussed above, the delivered cost of the additive, and the capital
cost of the additive feed system. There will also be a modest amount of O&M labor
associated with operating and maintaining the system, and laboratory analysis
required to monitor additive concentrations. In most cases existing staff should be able
to provide both the O&M and laboratory support, so this is not typically considered an
“out of pocket” cost when an additive feed system is implemented.
The delivered cost of the additive should be determined by requesting a price quote
from a vendor. DBA is supplied by DuPont and Solutia, and sodium formate is
supplied by Perstorp Polyols, Celanese, and others.
An additive feed system cost can be based on the estimated cost of a generic additive
feed system developed in the DOE/EPRI study mentioned above. That system cost was
estimated at $550,000 for a feed system to deliver 100 lb per hour (45 kg/hr) as dry
DBA or dry sodium formate. The cost of this system was estimated to vary with design
feed rate by the ratio of the actual feed rate divided by 100, with that ratio raised to the
0.15 power. In the DOE/EPRI study, this capital cost was annualized with a capital recovery
factor of 0.17; this value corresponds with a ten-year recovery period and an 11% interest rate.
Your utility may use other capital recovery formulas.
In systems where the performance additive is used to increase system SO 2 removal

performance, limestone consumption and byproduct solids production rates will
increase in direct proportion to the amount of SO2 removed and will represent an
additional cost. If the performance additives are used to lower pH set points and
improve limestone utilization, the corresponding decrease in limestone consumption
and dewatered byproduct solids should represent a direct savings from the use of the
additive. In some installations a reduction in mist eliminator plugging and scaling may
also be realized, with a corresponding reduction in mist eliminator maintenance labor
and materials.
3-7
Similarly, if the additive is used to lower L/G by operating fewer absorbers and/or
absorber slurry recirculation pumps, the corresponding reduction in fan power and/or
pump power will represent a savings attributable to the additive.
Also, in some systems the amount of dewatered byproduct solids sent to disposal may
vary with the use of additives beyond the increase attributable to increased SO2
removal or the decrease attributable to improved limestone utilization. This can be due
to additive effects on solids dewatering properties. The amount of dewatered
byproduct sludge sent to disposal can increase or decrease depending on the how the
weight percent solids in this sludge is impacted. In the absence of any site-specific data,
it is reasonable to assume no impact for this initial evaluation, though.
The cost of acquiring or modifying environmental permits also needs to be considered

for plants that discharge liquid from the FGD process. The presence of these organic
acids or salts results in increased biological oxygen demand in the blowdown liquor.
Example Economics
A based-loaded, 500 MW plant fires a 2.5% sulfur coal, and removes about 70,000 tons
(64,000 metric tons) per year of SO2 in the FGD system. The FGD system operates in an
inhibited oxidation mode, operates with a closed water balance, and dewaters the FGD
byproduct to an average of 70 wt% solids. The current limestone utilization is about
85%, corresponding to an annual limestone consumption of 136,000 tons (123,000 metric
tons).
In this example, DBA is being considered to allow operating at a lower pH set point,
and improving limestone utilization. Using the example data from the DOE/EPRI
study, we assume that the system can be operated with about 1000 ppm of DBA in the
absorber recirculating slurry liquor, and that a drop in pH set point of 0.3 units will
allow operating at a 93% limestone utilization value. We also assume that the DBA
consumption will amount to approximately 11 lb per ton (5.5 kg/metric ton) of SO2
removed.
In this example, the DBA consumption would be estimated at 770,000 lb (349,000 kg)
per year. Assuming a delivered DBA price of $0.30/lb, this corresponds to an additive
cost of $231,000 per year. This additive consumption rate corresponds to about 100
lb/hr (45 kg/hr), so we will use the value of $550,000 from the DOE/EPRI study as the
required capital investment to install a feed system. With a 0.17 annual capital recovery
factor, this amounts to an annual cost of $93,500 for the feed system. In this example,
the total estimated cost of using DBA is $324,500 annually.
The savings associated with using DBA will be realized from decreased limestone
consumption and a corresponding decrease in byproduct sludge disposal. The increase
3-8
in limestone utilization to 93% is estimated to lower the limestone consumption to

124,000 tons (112,000 metric tons) per year, a savings of 12,000 tons (11,000 metric tons).
This is also 12,000 tons of material that will not go to sludge disposal at 70 wt% solids,
so there is a corresponding reduction in sludge disposal of 17,000 tons (wet basis)
(15,000 metric tons).
At this plant, the prepared limestone reagent costs about $12 per ton after considering
the delivered cost of limestone, power consumed by the ball mills, and ball mill
maintenance materials. The cost for waste sludge disposal is about $5 per ton (wet
basis). The savings from using DBA would amount to $144,000 in prepared reagent,
and $85,000 in avoided sludge disposal, for a total of $229,000 annually.
In this case, then, the savings resulting from improved limestone utilization alone do
not appear to justify the expenses of using a performance additive ($229,000 annual
savings vs. $324,500 annual costs). Although these numbers are based on a number of
assumptions, and the actual values for this plant may vary significantly from these
estimates, it would take substantially better performance (higher limestone utilization
realized and/or lower actual DBA consumption) to make this application of
performance additives financially attractive. Thus, for this example further
consideration of performance additives as a means of improving limestone utilization
does not appear to be warranted.
The estimating approach described above is further illustrated in Table 3-2. This
approach can only be used to make an initial estimate of whether performance
additives should be further considered for your site. If the initial estimate looks
promising, full-scale testing should be conducted to provide site-specific data. Case
Study No.1, in the following section, provides a good example of how to conduct a full-
scale test and how to subsequently use those data to more accurately estimate the cost
effectiveness of using performance additives under several scenarios at a particular site.
Add Sulfur/Inhibit Oxidation
Some FGD systems add sodium thiosulfate to inhibit the oxidation of sulfite formed by
the removal of gas phase SO2. Most systems that inhibit oxidation, though, add an
emulsion of elemental sulfur to generate the thiosulfate ion in situ, by the following
reaction:
SO3= + S0 £ S2O3=
A generally accepted mechanism for sulfite oxidation in wet limestone FGD systems
involves transition metals such as iron or manganese that react with sulfite ions in
3-9
Table 3-2
Example Economics: Cost Effectiveness of Organic Acid Addition
Plant Specifics Assumptions
Based-loaded 500 MW System will use 1000 ppm DBA
2.5% sulfur coal DBA consumption estimated at 11

lb/ton SO2 removed
70,000 tons SO2 removed per DBA delivered price of $0.30/lb

year
Inhibited oxidation Decrease of operational pH of 0.3
85% limestone utilization Increase in limestone utilization to 93%
Prepared limestone cost of Limestone purity of 94.5%

$12/ton
Disposal price of $5/ton wet
A. SO2 Removal Rate (ton/yr) = (Avg. Unit Load)*(Oper. Hours)*(Heat Rate)*(Sulfur Content)*(SO2 Removal)
(32 lb Sulfur/64 lb SO2)*(1 MW/1000 kW)*(Btu/lb Coal)*(2000 lb/ton)
= (470 MW)*(8400 hr/yr)*(9500 Btu/kWh)*(2.5%S/100)*(90% SO2 Rem./100)

(32 lb S/64 lb SO2)*(1 MW/1000 kW)*(12000 Btu/lb Coal)*(2000 lb/ton)
= 70,000 tons SO2 removed per year
B. Actual Feed Rate (lb/hr) = (Tons SO2 removed per year) * (Additive consumption rate)
(320 operating days/year) * (24 hr/day)
= (70,000 tons/yr) * (11 lb/ton SO2 removed) = 100 lb additive/hr

(320*24)
C. Additive Cost ($/yr) = (Tons SO2 removed/yr) * (Additive consumption rate) * (Delivered price)
= (70,000 tons/yr) * (11 lb/ton) * ($0.30/lb) = $231,000/yr

0.15
D. Capital Cost ($) = ($550,000) * (Additive Feed Rate/100)
0.15
= ($550,000) * [(100 lb/hr)/(100)] = $550,000
E. Annualized Capital Cost ($) = (Total Capital Cost) * (Capital Recovery Factor)
= ($550,000) * (0.17) = $93,500
F. Total Annual Cost of = (Annual Capital Cost) + (Annual Additive Cost)

DBA ($)
= ($93,500) + ($231,000) = $324,500
G. Current Limestone = (Tons SO2 removed per year) * (100 tons L.S./64 tons SO2)
Usage (ton/yr) (L.S. Utilization/100) * (L.S. Purity/100)
3-10
= (70,000 tons/yr) * (100/64) = 136,000 ton/yr

(0.85) * (0.945)
H. Limestone Usage = (70,000 tons/yr) * (100/64) = 124,000 ton/yr

w/DBA (ton/yr) (0.93) * (0.945)
I. Limestone Savings ($/yr) = [(Current Limestone Usage) - (Future L.S. Usage)] * (Prepared price)
= [(136,000 ton) - (124,000 ton)] * ($12/ton) = $144,000/yr
J. Disposal Savings ($/yr) = [(Current Limestone Usage) - (Future L.S. Usage)] * (Disposal price)
(Byproduct Concentration/100)
= [(136,000 ton) - (124,000 ton)] * ($5/ton wet) = $85,000/yr

(0.70)
K. Total Annual Savings ($) = (Limestone Savings) + (Disposal Savings)
= ($144,000) + ($85,000) = $229,000
3-11
solution to produce sulfite free radicals. These sulfite free radicals react with oxygen
and other sulfite ions in a series of chain reactions to produce sulfate, other free
radicals, and to regenerate the transition metal catalyst. Thiosulfate ion limits sulfite
oxidation by reacting with these free radicals to break the chain reactions.
The benefit of inhibiting oxidation is to control sulfite oxidation percentages below
15%. As mentioned above, by reducing the sulfite oxidation percentages below
approximately 15%, all of the sulfate formed is coprecipitated with calcium sulfite, and
no gypsum solids are formed. Said another way, lowering the oxidation fraction below
15% typically lowers gypsum relative saturation levels in the absorber reaction tanks
below 1.0 (subsaturated). Operating in a subsaturated regime with respect to gypsum
greatly reduces tendencies for scale formation throughout the absorbers.
FGD systems that operate with oxidation percentages in the range of approximately
15% to less than 85 to 90% oxidation can experience severe gypsum scaling on absorber,
reaction tank, and mist eliminator internals. At these oxidation percentages gypsum can
be formed, but there is not a sufficient surface area of gypsum solids in the
recirculating slurry solids to promote rapid crystal growth. Instead, sulfate formed by
the oxidation of sulfite ion tends to scale out on scrubber internals.
Several factors lead to natural oxidation percentages that exceed 15%. These include:
x Reduced load operation. Many power plants operate at reduced megawatt output
rates, particularly during off-peak time periods in the day. Low load operation
generally requires higher boiler excess air levels, which can promote sulfite
oxidation in the FGD system. Also, during days where the load cycles to lower
levels for only portions of the day, some plants retain all absorber modules in
service. In some FGD system designs, the spray headers for multiple spray levels
are manifolded together, so it is not possible to turn off individual spray header
levels to reduce L/G ratios either. The net effect is that at reduced loads, the SO2
pickup rate is reduced while the oxygen pickup rate, which is presumably directly
related to L/G ratio, remains high. This also promotes higher oxidation percentages.
x High slurry temperatures. Some fuels, particularly lignites, have relatively high
moisture content, such that their flue gas moisture content is also relatively high.
The flue gas adiabatic saturation temperature is correspondingly higher than for
lower moisture-content fuels. A wet scrubber recirculating slurry temperature
typically remains near the flue gas adiabatic saturation temperature, so slurry
temperatures at lignite-fired plants are typically 5oF to 10oF (3oC to 6oC) greater than
in FGD systems on bituminous coal-fired plants. Oxidation rates have in general
been observed to increase at elevated slurry temperatures, presumably due to
increases in the intrinsic reaction rate for one or more of the oxidation reactions.
Thus, higher oxidation percentages are typically observed in lignite-fired plant FGD
systems than in similar systems on a bituminous coal-fired unit.
3-12
x Low coal sulfur levels. In general, for a given absorber design and with most other
operating variables being fixed, the oxidation rate remains relatively constant when
expressed in terms of moles of sulfite oxidized per unit time. As the absorber inlet
SO2 concentration is reduced due to lower fuel sulfur content, the SO2 pickup rate
(in moles per unit time) will be reduced while the sulfite oxidation rate will remain
relatively constant. Hence, the percent of sulfite that is oxidized tends to increase as
the fuel sulfur content decreases, making FGD systems on lower sulfur coals harder
to control below 15% oxidation.
x High transition metals content in the scrubber liquor. Transition metals such as iron
and manganese are thought to catalyze sulfite oxidation by reacting with sulfite ion
to produce sulfite free radicals. Additional chain reactions occur to produce sulfate,
more free radicals, and regenerate the transition metal catalyst. At some plants with
less effective particulate control devices upstream of the FGD system, higher ash
loadings are encountered at the inlet to the FGD system. Fly ash is a common source
of soluble transition metals in FGD liquors, so in such incidences of poor upstream
particulate control performance there is typically an ample supply of oxidation
reaction catalysts in the FGD liquor.
In the systems that add sulfur to inhibit oxidation, the sulfur is delivered in truckload
quantities as a high weight percent solids (e.g., 70%) emulsion, and stored in a tank on
site. This emulsion is metered into the FGD system, typically by adding it to the
prepared reagent slurry. Thiosulfate ion is produced by reaction of this sulfur with
sulfite ions in the recirculating slurry liquor, and the sulfur addition rate is adjusted as
necessary to maintain target thiosulfate ion levels. The target thiosulfate level may be
adjusted also, depending on the observed sulfite oxidation percentages.
Determining the Cost Effectiveness of Inhibiting Oxidation
The amount of sulfur required to inhibit oxidation is typically site specific. However,
typical thiosulfate levels are in the range of 500 ppm to 1500 ppm in the recirculating
slurry liquor.
For the purposes of estimating sulfur consumption rates, a thiosulfate concentration

within this range can be assumed, and the sulfur makeup rate can be estimated from
this concentration and the rate at which liquor leaves the FGD system via blowdown
and associated with dewatered FGD byproduct solids. The amount of sulfur required is
typically two to three times the theoretical amount calculated on this basis. Sulfur
emulsion is typically delivered to utility sites at a cost of approximately $200/ton on a
wet basis (approximately $300/ton dry basis).
The authors have estimated the installed capital cost of a generic sulfur emulsion
addition system at $54,000 for a system sized for 40 tons/yr (36 metric tons/yr) as
3-13
sulfur emulsion at 70 wt% solids. This cost estimate can be adjusted for other feed rates
by multiplying $54,000 by the new feed rate (in tons per year as sulfur emulsion)
divided by 40, with this ratio raised to the 0.12 power.
The benefits from sulfur addition will vary from site to site, but it is not uncommon for
the need to manually clean absorber, reaction tank, and mist eliminator internals to be
virtually eliminated. In plants that rely on high magnesium levels in the absorber
recirculating slurry liquor as a performance additive, another benefit of sulfur addition
may be improved SO2 removal performance, due to higher liquid phase sulfite
concentrations.
Example Economics
As an example, a based-loaded 500 MW plant that fires a 2.5% sulfur coal and achieves
90% overall SO2 removal removes about 70,000 tons (64,000 metric tons) of SO2 per year.
The FGD system operates in a natural oxidation mode, but sulfite oxidation
percentages frequently exceed 15%. As a result, the plant spends about $90,000 per year
for contract labor to clean gypsum scale from absorber modules. Sulfur addition is
being considered to inhibit oxidation, as a means of controlling gypsum scale
formation. The calculations to determine the cost effectiveness of sulfur addition are
summarized in Table 3-3, and described below.
This FGD system produces about 155,000 tons (141,000 metric tons) of byproduct solids
in a year, assuming 15% sulfite oxidation and 90% limestone utilization. These
byproduct solids are typically dewatered to 70 wt% solids, so about 66,400 tons/yr
(60.2 metric tons/yr) of water leave the system with these solids. The FGD system
operates with a closed water balance, so this is the only liquor leaving the FGD system.
Assuming a 1000 ppm thiosulfate concentration would be required to inhibit sulfite

oxidation to below 15%, this means 66.4 tons/yr (60.2 metric tons/yr) of thiosulfate
would be lost with this liquor loss. The stoichiometry of the thiosulfate formation
reaction shown above calls for 32 lb of sulfur to react with sulfite to produce 112 lb of
thiosulfate ion. Assuming a 3:1 actual-to-theoretical ratio, it would take 57 tons (52
metric tons) of dry sulfur to produce the 66.4 tons (60.2 metric tons) of thiosulfate ion
lost. At 70 wt% solids, this equates to an annual consumption of just over 81 tons of
sulfur emulsion. At a typical delivered price of $200 per ton, this amounts to less than
$17,000 per year in sulfur costs to inhibit oxidation. The sulfur used will increase the
amount of byproduct solids produced from the FGD system, but the quantity involved
is negligible (57 tons out of 155,000 tons).
There will also be costs associated with installing, operating, and maintaining the
sulfur feed system, and laboratory analyses to verify and allow control of thiosulfate
3-14
Table 3-3
Example Economics: Cost-Effectiveness of Sulfur Addition
Plant Specifics Assumptions
Base-loaded 500 MW 15% Sulfite oxidation
2.5% sulfur coal 90% Limestone utilization
70,000 tons SO2 removed per year Solids byproduct dewatered to 70 wt%
Natural oxidation with 90% removal Decrease of operational pH of 0.3
90% SO2 removal efficiency Increase in limestone utilization to 93%
$90,000/yr to clean gypsum scale Limestone purity of 94.5%
Closed water balance
A. Byproduct Molecular Wt (g/mole) = (145*Oxidation/100 + 129*(1-Oxidation/100))
= (145*15/100 + 129*(1-15/100)) = 131.4 g/mole
B. Byproduct Solids Rate (tons/yr) = (Tons SO2 removed/yr)/(SO2 M.W.) * [Prod. M.W. + Limestone M.W.*(1-Util.)]
= (70,000 tons/yr)/64 * (131.4 + 100*(1-0.9)) = 155,000 tons/yr
C. Total Solution Loss Rate (tons/yr) = (1-Byproduct Solids Conc./100)/(Byproduct Sol Conc./100)*(Byproduct Sol Rate)
= (1-70%/100)/(70%/100) * (155,000 ton/yr) = 66,400 tons/yr

6
D. Sulfur Feed Rate (tons/yr) = (Solution Loss Rate)*(Thio. Conc./10 )*(3 lb S Actual/1 lb S Theoretical)
(112 lb Thio/32 lb Sulfur)*(Emulsion Concentration/100)
6
= (66,400 tons/yr)*(1000 ppm/10 )*(3/1) = 81 tons/yr
(112/32)*(70%/100)
E. Annual Sulfur Cost ($/yr) = (Sulfur Feed Rate) * (Delivered Price)
= (81 ton/yr) * ($200/ton) = $16,200

0.12
F. Total Capital Cost ($) = ($54,000) * (Sulfur Feed Rate/40)
0.12
= ($54,000) * [(81 ton/yr)/(40)] = $59,000
G. Annualized Capital Cost ($/yr) = (Total Capital Cost) * (Capital Recovery Factor)
($59,000) * (0.17) = $10,000
H. Total Annual Cost of Sulfur ($/yr) = (Annual Capital Cost) + (Annual Sulfur Cost)
= ($10,000) + ($17,000) = $27,000
3-15
concentrations. In most instances the operation and maintenance of the system, and the
laboratory analyses are small efforts, and can be handled by existing staff.
The costs for installing a sulfur emulsion and feed system can be estimated from the
equation provided above. For this case the estimate is $59,000. Using a capital recovery
factor of 0.17, the annual cost for the sulfur addition system is $10,000.
Thus, the total annual cost for sulfur addition on this unit is estimated at $27,000. Since
this plant currently spends several times this amount annually on cleanup efforts
related to gypsum scale formation in absorbers, reaction tanks, and mist eliminators, it
would probably be cost effective for this plant to add a sulfur addition system and
operate in an inhibited oxidation mode. The apparent payback period would be
approximately four months. The plant should probably conduct a full-scale test of
sulfur addition, with sulfur added from a tanker trailer parked at the site, before
making a capital investment to install a permanent sulfur feed system.
Modify/Improve Mist Eliminator Wash System
Many FGD systems have to bring absorbers off line at regular intervals to manually
clean mist eliminator (ME) internals, due to scale buildup and plugging over time.
Sometimes this need for manual cleaning is due to operating at low limestone
utilization (high reagent ratio).
When operating absorbers at low limestone utilization, the droplets carried up to the
ME surfaces contain a significant fraction of unreacted reagent. This reagent continues
to react with flue gas SO2 while in the ME, at conditions of relatively low pH and low
SO2 to O2 molar ratios. These conditions lead to the formation of gypsum on the ME
surface, and can cause scaling and plugging. This mechanism for ME plugging can be
addressed by changing absorber conditions to improve reagent utilization (discussed
elsewhere in this section).
However, many times ME scaling and plugging are caused (or exacerbated) by
inadequate washing of the ME surfaces. Inadequate washing is often a result of
incomplete coverage of the ME face with wash nozzles, and/or washing rates that
result in too low a wash intensity.
EPRI has previously studied the requirements for effective ME washing, and has
recommended guidelines. The EPRI guidelines call for:
3-16
x Washing the front face of a single-stage ME or the first stage of a two-stage ME at an

intensity equivalent to 1.5 gpm of wash water flow per ft2 (3.66 m3/hr per m2) of ME
cross sectional area.
x Washing the back side of the first stage of a two-stage ME at an intensity of 0.5
gpm/ft2 (1.22 m3/hr per m2).
x Washing the front face of the second stage of a two-stage ME at 0.5 gpm/ft2 (1.22
m3/hr per m2).
x Not washing the back side of a single stage ME or of the second stage of a two-stage
ME.
x Washing the ME for a duration of at least 45 to 60 seconds each wash cycle.
x Washing each face at a frequency of once every 30 to 60 minutes.
x Using 90o, full-cone, round spray pattern nozzles with a large minimum solids
passage diameter, in sufficient number to provide at least 150% coverage of the ME
face (180 to 200% is typically recommended). The nozzle pressure should be 20 to 40
psig (138 to 276 kPa), and the nozzle tip should be no more than 4 feet (1.2 m) from
the ME face.
In many cases, the need to manually, off-line clean ME surfaces at a regular interval can
be eliminated by upgrades to the ME wash system to conform with the EPRI
guidelines. Many absorbers were designed without the amount of wash nozzle overlap
called for in the EPRI guidelines, and many wash at too low a wash intensity but at a
more frequent rate than needed. There is often an opportunity to revise these wash
systems to wash at a higher rate but less frequently, without adversely affecting the
FGD system water balance.
Also, the ME wash water should be subsaturated with respect to gypsum, to ensure
that the wash water can effectively remove any gypsum deposits that collect on ME
surfaces. Supersaturated wash water can actually have an adverse effect in contributing
to scale growth. If the ME is washed with FGD process water (usually dewatering
system overflow) and this water source is not subsaturated with respect to gypsum,
some fresh water or other subsaturated makeup water source should be blended with
this stream to make it subsaturated. A gypsum relative saturation level of 0.5 or less is
recommended.
Determine the Cost Effectiveness of Improving/Upgrading the ME Wash System
The first step is to determine how closely the existing ME wash system conforms to the
EPRI guidelines. The wash duration and frequency can be determined directly by
3-17
observing the wash system in operation. Sometimes the programming of the ME wash
cycle can be modified at no cost to bring the wash duration and frequency within the
range of the EPRI recommendations.
The wash intensity may not be as obvious to determine, but there are several ways to
get this number. One is to determine the number of nozzles in the headers washing
each ME face, the water pressure at those nozzles (or as close as can be measured), then
consult the nozzle vendor for water flow rate data at that pressure. If the pressure is
measured at a lower elevation than the nozzle tips, remember that each additional foot
of elevation lowers the static pressure by about 0.43 psi (9.7 kPa per m). The wash
intensity is then the number of nozzles times that flow rate divided by the cross
sectional area of the vessel at the ME face. A better way is to measure actual flow rates
in the headers feeding the nozzles.
Many times an ME face is washed by sets of nozzles fed from more than one header,
and each header may operate independently of the others. In this case, the flow rate of
all headers that wash a single face must be summed, then divided by the ME face cross
sectional area. Even if there are no flow meters on the wash water lines, if there is a
wash water tank, it may be possible to determine rates by temporarily shutting off the
makeup water to this tank and measuring the tank level drop with time while the ME is
being washed.
The wash intensity can be varied in several manners, such as by replacing existing
nozzles with larger or smaller nozzles, or varying the pressure at the nozzle tip. In
many circumstances, it may require a pump change to effect a significant change in
nozzle pressure, and if the nozzles already operate at the upper end of the
recommended range (40 psig or 276 kPa) there may be little opportunity to increase the
rate by pressure increase. In some instances the need for pump change can be avoided
if two or more headers are fed by the wash pump at the same time. In this situation a
fairly simple piping change to separate the feed piping and valves for those headers
can allow an existing pump to wash at a higher rate just by feeding fewer headers at a
time.
The wash pattern and overlap are also important for effective ME washing. The overall
percent overlap can be determined from the nozzle spray angle, the distance from the
nozzle tip to the ME face, the number of nozzles, and the ME face cross sectional area.
Each nozzle will cover an area equal to:
A = S x [(Distance from nozzle tip to ME face) x TAN(spray angle y 2)]2
3-18
The percent overlap is then calculated as:
Overlap = A x (no. of nozzles) y (ME cross sectional area) x 100
These equations assume that the distance is expressed in feet, and the areas are
expressed in square feet. Also, note that the distance from the nozzle tip to the ME face
should not be greater than approximately four feet, and that for nozzles with spray
angles greater than 90 degrees, it is probably most conservative to use 90 degrees in the
first equation above. Droplets beyond the 90 degree spray angle impact the ME almost
perpendicular to the ME elements, and hence tend to be relatively ineffective at
washing the element surfaces.
The EPRI recommendation of 150 to 200% overlap of the ME face recognizes that the
area at the center of the nozzle layout pattern may not be touched by the nozzle sprays,
which originate from the corners of that pattern. The area along the lines directly
between each pair of nozzles in the pattern may be washed by both. The best way to
determine complete coverage is to make a scaled drawing of the ME face and spray
header arrangement, and ensure that when the washed area “A” as calculated above is
drawn for each nozzle, the entire ME face is covered. Any area not covered is not being
washed effectively, and may be the starting point for ME scaling and plugging.
Inadequate spray pattern coverage is typically expensive to correct, as it usually

requires replacing the spray headers and/or nozzles to improve the coverage. If the
existing headers are closer than 4 feet (1.2 m) to the ME face, the coverage may be
improved by moving the headers farther away, if possible. However, in lined vessels it
is usually expensive to make new vessel penetrations to support moving the headers.
As an example of the costs associated with complete replacement of the wash headers,
for one FGD system with 32-ft (9.8 m) diameter absorbers, the cost for replacing the
wash headers, nozzles, and wash pump for a two-stage mist eliminator was estimated
at $300,000 per module. This estimate was based on using Alloy G for the header
piping. The estimate would have been lower if FRP could be used.
The ME wash water composition should be analyzed periodically, and a computer

program such as FGDPRISM should be used to verify that the water is subsaturated
with respect to gypsum. If the wash water is supersaturated or nearly saturated with
respect to gypsum, another subsaturated water source should be blended to achieve a
low relative saturation level in the blend (e.g., 0.5 or less).
Example Economics
A 400 MW power plant in the Midwest has a “first generation” FGD system that was
installed in the mid-1970’s. Since startup, the FGD system experienced severe ME
3-19
scaling. For the first five to six years of operation, to avoid unit load restrictions each
ME had to be manually cleaned at least once per week. A crew of five to six men
working five nights per week was required to manually clean the ME surfaces. This
cost the utility greater than $150,000 annually in contract labor costs. Furthermore, the
FGD system availability averaged only 65% during the first several years of operation.
The original ME wash system operated in a closed loop, where wash water was
returned to a tank and reused. A small amount of blowdown from this closed loop
controlled solids levels in the wash water. This system was replaced with a once-
through wash with recycled disposal pond water, but only marginal improvements in
mist eliminator cleanliness were realized.
It was noted that the ME scaling was exacerbated by scaling and plugging of the ME
wash nozzles and headers, which reduced or eliminated wash water flow to some
portions of the ME. The pond water was analyzed for pH and concentrations of major
cations and anions, and it was determined that this water source was supersaturated
with respect to gypsum. Thus, the pond water was not a good ME wash water source.
Furthermore, the limestone reagent utilization in the absorber was regularly measured
at 80% or lower, which indicated that reagent utilization would have to be increased to
improve ME reliability.
In the early 1980’s, the utility began a program to improve ME reliability. First, the ball
mill circuit was derated to improve the limestone fineness from 80% <200 mesh (-0.074
mm) to 85% <325 mesh (-0.044 mm), and the pH set point was lowered to 5.6 (this
strategy is discussed later in this section). These changes allowed the limestone
utilization to improve to 85% or better while maintaining SO2 removal performance.
The ME wash water source was changed from pond return to fresh water. The initial
design washed the front and back faces of the first-stage ME, and the front face of the
second-stage ME all at the same time and at the same rate. This rate corresponded to
0.75 gpm/ft2 (1.83 m3/hr per m2, which is only half of the EPRI recommendation for the
front face of the first stage but 50% greater than the recommendation for the other faces.
The piping to the wash header for the front face of the first stage was separated from
that for the other faces, which allowed this face to be washed at the desired rate of 1.5
gpm/ft2 (3.66 m3/hr per m2).
Because fresh water was being used to wash the ME, the wash frequency and duration
were reduced from nearly continuous washing to only four minutes of washing of each
ME face per hour. This wash rate, which is well within the EPRI guidelines, allowed
the FGD system to operate with a closed water balance at the average unit load of 300
MW.
With these changes, the need to manually clean the ME weekly was eliminated; a fire
hose washing during annual outages was the only required supplement to the on-line
3-20
washing routine. The FGD system reliability was observed to improve from 65 to
greater than 95%.
The cost effectiveness of reducing the throughput of a limestone grinding circuit to

improve limestone fineness and utilization are discussed elsewhere in this section.
Other than that change, the only expense the utility realized was a $25,000 piping and
control change on the ME wash piping system. The cost of this piping change was
recovered in less than two months of avoided manual cleaning.
Increase/Decrease Absorber Recirculating Slurry Percent Solids
In general, the weight percent solids level in the absorber recirculating slurry directly
affects the solids residence time in the FGD system. In most FGD systems the volume of
slurry in the absorber and reaction tank are fixed, so at a given weight percent solids
level the inventory of solids in the absorber and reaction tank are also fixed. At a
constant SO2 removal rate, the average residence time for solids in the absorber and
reaction tank can be calculated as the molar sulfur content of this solids inventory
divided by the SO2 removal rate (e.g., moles removed per hour). If the weight percent
solids in the recirculating slurry is adjusted up or down, the inventory of solids in the
system similarly goes up or down. For a given SO2 removal rate, then, the solids
residence time increases or decreases in proportion with the weight percent solids level
in this slurry.
Note that the reaction tank and absorber approximate a “continuous stirred tank
reactor” with respect to solids residence time. Although an average solids residence
time can be calculated as described above, there is generally a wide distribution of
residence times for individual crystals ranging from a fraction of the average to several
times the average residence time.
Increasing the weight percent solids level, and hence increasing the solids residence
time, can have several beneficial effects in limestone reagent FGD systems. One is that
the limestone reagent spends more time in the FGD system, and correspondingly can
be more completely utilized. Another beneficial effect is that the calcium sulfite or
gypsum byproduct formed in the FGD system has more time to grow large crystal
sizes. These larger crystals are generally easier to dewater, producing a drier byproduct
sludge. The latter can decrease waste disposal costs for facilities that pay by the wet ton
to dispose of their byproduct, and can help systems that produce a saleable gypsum
byproduct stay within specifications. A third beneficial effect is that by having a larger
amount of byproduct solids in the recirculating slurry, there is greater solids surface
area for precipitation of calcium sulfite and/or gypsum from supersaturated liquor.
With a greater surface area available for precipitation, a lower level of supersaturation
3-21
is required to achieve a given solids precipitation rate. Thus, higher solids content and
longer solids residence time can reduce scaling tendencies in the absorber and reaction
tank.
However, the effects of higher weight percent solids level and longer solids residence
time are not always positive. Both the higher weight percent solids level and the longer
solids residence time increase the likelihood of mechanical damage to the byproduct
calcium sulfite or gypsum crystals. The mechanical damage is caused by particle-to-
particle attrition or particle collisions with other surfaces as the slurry circulates
through pumps, nozzles, piping, agitators, etc. This mechanical damage has the effect
of breaking fine particles off of the larger crystals formed, limiting overall particle size
and producing a large number of fines in the system. Both of these adversely affect
byproduct dewatering performance. This is particularly true in magnesium-enhanced
lime reagent systems, where higher weight percent solids levels in the recirculating
slurry are known to produce deleterious effects on solids dewatering properties. These
systems typically operate at lower weight percent solids levels than do limestone
reagent systems.
Also, operating at higher weight percent solids levels has the effect of increasing the
horsepower requirements of the slurry recirculation pumps. Besides increasing pump
power consumption, in some circumstances the pump motors can be “redlined” with
respect to current drawn as the weight percent solids is increased.
In current wet limestone FGD practice, the upper limit for recycle slurry solids levels is
in the range of 20 to 30 wt%. For lime systems, current practice is to control solids levels
well below 10%.
Determine the Cost Effectiveness of Varying Weight Percent Solids Levels
Each FGD system will have an optimum weight percent solids level that takes best
advantage of the benefits of higher solids residence time, without resulting in excessive
mechanical damage to the byproduct crystals. This optimum is best found through
experimentation. The absorber recirculating slurry weight percent solids levels can be
raised or lowered in small increments, and the effects on system operation can be
observed. A beneficial increase in recirculating slurry weight percent solids content
should improve limestone utilization, lower calcium sulfite and/or gypsum relative
saturation levels (if measured), and/or increase dewatered byproduct weight percent
solids levels. A detrimental increase in recirculating slurry solids content will actually
lower dewatered byproduct weight percent solids levels. Higher recirculating slurry
solids levels may also lead to slurry handling difficulties.
A high-powered optical or scanning electron microscope is very effective in supporting

such experimentation. The dewatered recirculating slurry solids can be examined
3-22
under microscope to determine the onset of fines formation and rounding of crystal
edges as the slurry weight percent solids level is increased. Bench-scale settling rate
tests conducted on absorber slurry samples can also be effective in supporting this type
of experimentation.
As the weight percent solids level is varied, the cost effectiveness of the change should
be compared to baseline conditions. The benefits of varying the weight percent solids
level (e.g., improved limestone utilization) should be weighed against any adverse
effects (e.g., lower weight percent solids in the dewatered sludge). For example, any
savings in limestone consumption must be weighed against the increase in byproduct
disposal cost.
Example Economics
In this example, a 500 MW power plant fires a 2.5% sulfur coal, and has a wet limestone
FGD system that achieves 90% overall SO2 removal. The limestone utilization averages
85%, corresponding to about 136,000 tons/yr (124,000 metric tons/yr) of limestone
used. The byproduct solids are dewatered to about 70 wt% solids, and about 230,000
tons/yr (209,000 metric tons/yr) of waste sludge are sent to disposal.
The plant experiments with changes to the control point for the solids content of the
recirculating slurry. As the control point is raised from 10 to 14 wt%, the limestone
utilization is observed to increase from 85 to 87%. At the same time, though, the weight
percent solids in the dewatered byproduct sludge decreases from 70 to 65%. The
calculations to determine the cost effectiveness of these changes are summarized in
Table 3-4, and described below.
The increase in limestone utilization will decrease the amount of limestone consumed
by about 3000 tons/yr (2700 metric tons/yr). This plant figures their prepared
limestone costs about $12/ton (dry basis). The savings associated with decreased
limestone consumption would amount to about $36,000 per year.
However, the corresponding decrease in solids content in the waste byproduct sludge
will increase waste disposal costs. Even taking into account the lesser amount of dry
byproduct that results from the decreased limestone, the wet tonnage sent to disposal
increases to about 244,000 tons/yr (222,000 metric tons/yr). At a disposal cost of $5.00
per ton (wet basis), this increase of almost 15,000 tons/yr (13,000 metric tons/yr) of wet
tonnage increases annual waste disposal costs by $70,000.
Also, at 10 wt% solids, each slurry recirculation pump motor consumes power at a rate
of 283 kW. At 14 wt%, this increases by about 3%, to 291 kW. The FGD system operates
about 8000 hours per year, and normally nine pumps are in service, so this increase
3-23
Table 3-4
Example Economics: Cost-Effectiveness of Increased Recycle Solids Concentration
Plant Specifics At 10 wt% Recycle Solids
500 MW 85% Limestone utilization
2.5% Sulfur coal 70 wt% Waste sludge solids
90% SO2 removal efficiency Pump power consumption of 283 kW
70,000 Tons SO2 removed per year At 14 wt% Recycle Solids
Limestone cost of $12/ton 87% Limestone utilization
Disposal cost of $5/ton wet basis 65 wt% Waste sludge solids
Internal Power Cost of $0.02/kWh 65 wt% Waste sludge solids
Pump Operating 8000 hours/year Pump power consumption of 291 kW
A. Current Limestone Usage (ton/yr) = (Tons SO2 removed per year) * (100 tons L.S./64 tons SO2
(L.S. Utilization/100) * (L.S. Purity/100)
= (70,000 tons/yr) * (100/64) = 136,000 ton/yr

(0.85) * (0.945)
B. Limestone Usage w/14wt%(ton/yr) = (70,000 tons/yr) * (100/64) = 133,000 ton/yr

(0.87) * (0.945)
C. Limestone Savings ($/yr) = [(Current Limestone Usage) - (14 wt% L.S. Usage)] * (Prepared price)
= [(136,000 ton) - (133,000 ton)] * ($12/ton) = $36,000 /yr
D. Pres. Waste Sludge Rate (tons/yr) = (Tons SO2 removed/yr)/(SO2 M.W.) * [Product M.W. + Limestone M.W.*(1-Utilization)]
(Sludge Concentration/100)
= (70,000 tons/yr)/64 * (132 + 100*(1-0.85))/(70/100) = 230,000 tons/yr
E. New Waste Sludge Rate (tons/yr) = (70,000 tons/yr)/64 * (132 + 100*(1-0.87))/(65/100) = 244,000 tons/yr
F. Increase in Disposal Cost ($) = (New Waste Sludge Rate - Present Rate) * ( Disposal Cost)
= (244,000 - 230,000 ton/yr) * ($5/ton) = $70,000
G. Pump Power Cost ($) = (New Power Rate - Present Power Rate) * (Oper. Hrs) * (Power Cost) * (# Pumps)
= (291 - 283 kW)*(8000 hr)*($0.02/kWhr)*(9) = $11,500
H. Annual Operating Costs ($/yr) = (Pump Power Cost) + (Disposal Cost) - (Limestone Savings)
= ($11,500) + ($70,000) - ($36,000) = $45,500
3-24
corresponds to an increase of 576,000 kWh annually. This increased power consumed

has an annual value of $11,500 at the internal power cost of $0.02 per kWh.
Because the increase in waste disposal and power costs exceeds the amount saved
through improved limestone utilization ($81,500 vs. $36,000), this change does not
appear to be cost effective.
Modify pH Set Point/Control
The pH of the absorber recirculating slurry is one of the most important FGD system
control variables. With other variables fixed, the pH affects both the SO2 removal
performance and the reagent utilization. These two parameters in turn directly impact
two major FGD cost factors: reagent consumption and byproduct production rates.
Thus, selection of pH set points and control of the recirculating slurry pH directly
influence the cost of operating the FGD system.
Control of the pH of the recirculating slurry impacts other portions of the FGD system
as well. For example, if the pH is regularly allowed to rise too high, resulting in poor
limestone utilization (e.g., less than 80% utilization), the absorber mist eliminators may
tend to scale and plug. This is because excess limestone is deposited on the ME surfaces
along with entrained slurry droplets. This limestone continues to react with flue gas
SO2, which results in the formation of gypsum scale on the ME surface.
There are a number of strategies for controlling pH to reduce FGD operating costs.
These can include improving the design and operation of the pH control system itself,
lowering pH set points, and avoiding limestone blinding incidents. Each of these is
briefly described below.
Improved pH Control – Reagent can be wasted because the absorber recirculating

slurry pH is not controlled at the appropriate level. If the pH is allowed to increase, the
reagent ratio and the excess limestone content of the blowdown slurry increase
correspondingly. Excess limestone in the blowdown slurry usually leaves the FGD
system as a waste in the byproduct solids.
There are a number of reasons for poor pH control. These can include operator error,
pH instrument calibration error, pH electrode failure, poor pH control loop tuning,
poor pH control design, limestone blinding episodes, and others. Operator errors are
typically due to a lack of attention to pH values or setting pH control levels too high to
provide a “cushion” for SO2 removal performance. Instrument calibration errors can be
due to infrequent calibration, poor technique by laboratory and/or instrument
technicians, or systematic errors such as measuring the pH of slurry that is not
3-25
representative of the well-mixed reaction tank. Failure of pH electrodes can be due to

scale formation, erosion damage, or physical breakage. Control loops that are poorly
tuned can lead to large “overshoots” of pH above the set point, and poorly designed
pH control systems can lead to an inability to precisely control pH. Limestone blinding
is discussed later in this section.
Dual loop wet FGD systems sometimes have unique pH control issues. For example, in
some systems the pH in the lower loop, from which slurry blowdown is fed to the
dewatering system, is not directly controlled. In these systems, this pH is indirectly
controlled by slurry overflow from the upper loop. At some operating conditions, the
pH in this lower loop becomes much higher than the desired value, and leads to high
excess limestone in the blowdown slurry. At other conditions, the pH in the lower loop
drops very low while an excess of limestone is added to the upper loop. This transient
condition can lead to scaling and plugging in the upper loop, particularly for packed
absorbers. Slurry piping revisions and/or split limestone feed (feed directly to both
loops) are generally required to correct these pH control difficulties.
Lowering pH Set Points – Lower pH set points generally lead to operation at lower
reagent ratio values, and correspondingly lower excess limestone levels in absorber
blowdown slurries. Lower reagent ratio values generally have the effect of lowering
SO2 removal performance, though. To maintain target SO2 removal values, lower pH set
points typically have to be offset by other changes to restore SO2 removal performance,
such as operating more pumps and slurry headers to increase the L/G, producing a
finer limestone reagent grind, or adding performance additives. The reduction in
reagent consumption that results has to be weighed against the increased power costs
for running more pumps or producing a finer limestone grind, or increased additive
costs for the latter approach.
In some natural or inhibited oxidation systems, lower pH set points can lead to
increased sulfite oxidation percentages, which could lead to greater tendencies for
gypsum scaling in the absorber. Conversely, in forced oxidation systems, lower pH set
points may allow decreased oxidation air requirements.
Avoid Limestone Blinding – Limestone blinding sometimes occurs in “in situ” forced
oxidation wet FGD systems, when liquid phase sulfite concentrations are allowed to
raise too high. During limestone blinding, the pH control system can add a large
amount of limestone to the absorber recirculating slurry, but the pH remains below the
set point. This excess of limestone results in poor limestone utilization until the
blinding episode is over. Blinding episodes are typically avoided by improving the
oxidation effectiveness to lower liquid-phase sulfite concentrations.
Limestone blinding has also been observed in systems that use performance additives
such as dibasic acid, for short periods of time after the additive concentration is
increased by “slugging” the system with large quantities of the additive. These
3-26
episodes can be avoided by increasing additive concentrations in a more gradual

manner.
Limestone blinding can also occur due to the presence of aluminum fluoride in the
FGD recirculating slurry. Alumina can enter the FGD system as an impurity with the
limestone reagent or with fly ash carried into the FGD system from a poor-performing
upstream particulate control device. Fluoride typically is present in small quantities in
most coals. It enters the FGD system as HF in the flue gas and is removed in the
absorber. Aluminum fluoride blinding is typically avoided by eliminating or
minimizing the source of alumina. This is generally accomplished by improving the
upstream particulate control performance.
Determining the Cost Effectiveness of Improved pH Control
For most wet FGD systems, a reagent ratio of approximately 1.02 to 1.05 is about the
best that can be achieved (approximately 95 to 98% reagent utilization). An exception
would be systems that remove fly ash and SO2 together and that have an alkaline ash.
For these systems the contribution of the ash alkalinity to SO2 removal can make the
apparent reagent ratio lower than 1.0 (greater than 100% utilization).
For most other wet FGD systems, though, the potential cost savings associated with
reducing alkali reagent consumption can be estimated as the difference between the
current reagent ratio and the best possible value, multiplied by the current annual
alkali reagent cost. For plants that produce a waste byproduct sludge, there will also be
a corresponding savings in sludge disposal costs.
For wet limestone systems that currently operate at reagent ratio values greater than
approximately 1.2 (less than 85% utilization), there may be adverse impacts of operating
at such high excess reagent ratio that would further increase the economic incentive to
reduce reagent consumption. For example, the costs associated with cleaning plugged
packing and/or mist eliminators might be eliminated or reduced if the limestone
utilization were improved.
The cost associated with achieving these savings will depend on the strategy employed.
Improved pH control could require any of a number of equipment upgrades, including
new reagent slurry control valves, new pH controllers, revised pH meter sample
piping, new pH electrodes, new pH meters, etc. Improvements in pH control may also
increase operator or maintenance labor to keep the instrumentation calibrated. Other
than these cost items, there are rarely other tradeoffs involved with this technique for
reducing reagent consumption. In fact, there may be other benefits such as decreased
ball mill power requirements and reduced scaling tendencies in absorbers and mist
eliminators.
3-27
Lowered pH set points will usually require other changes to the FGD system to restore
SO2 removal levels. These changes, such as increasing L/G or using performance
additives are discussed elsewhere in this section.
Limestone blinding in forced oxidized systems is typically avoided by increasing the

oxidizing air rate, if additional compressor capacity is available, primarily incurring
increased expense for air compressor power. In some cases, modifications to the air
sparger to improve the distribution of oxidizing air may help avoid blinding. Other
means of avoiding limestone blinding in forced oxidation systems include raising the
slurry level in the oxidation tank, if possible, operating more modules (to lower the SO 2
pickup rate per module), or operating at lower pH set points.
In forced oxidation systems that produce a saleable gypsum byproduct, there is often
additional financial incentive for avoiding limestone blinding. Contracts for the
purchase of byproduct gypsum by wallboard manufacturers typically specify a
minimum gypsum purity. Episodes of limestone blinding typically raise the excess
limestone content of the byproduct to the point where gypsum purity specifications are
not met. In this circumstance, the off-spec gypsum must be disposed of by the utility
rather than being taken by the wallboard manufacturer.
In the case of aluminum fluoride blinding, the costs associated with reducing the
alumina content in the FGD recirculating slurry will depend largely on the source of
that alumina. If the source is a poorly performing ESP upstream of the FGD system, the
costs associated with upgrading the ESP may outweigh the value of the excess reagent
caused by the blinding.
Example Economics
In this case a utility has determined that the FGD system on one of its units can achieve
90% limestone utilization or better when the pH of the recirculating slurry is controlled
at the desired set point value of 5.3. However, the plant engineer notes that when
compared to the coal consumption, coal sulfur content, and FGD system SO2 removal
percentage, the annual limestone consumption by the FGD system corresponds to a
utilization of only 85%.
The FGD system consumed about 124,000 tons (112,000 metric tons) of limestone last
year. If the average limestone utilization could be improved to 90%, the corresponding
limestone consumption should be reduced to approximately 117,000 tons (106,000
metric tons) annually. The plant pays $8.00 per ton of delivered limestone, and figures
the cost of their prepared limestone slurry at $12.00 per ton. This improvement in
limestone utilization would save $56,000 annually in limestone purchases and would
reduce the overall cost of prepared limestone slurry by $84,000 annually.
3-28
Also, the FGD byproduct is sent to disposal as a 70 wt% solids content sludge at a
disposal cost of $5.00 per wet ton. Reducing the limestone consumption by 7000 tons
(6400 metric tons) annually will correspondingly reduce the byproduct sludge disposal
rate by 10,000 tons (9000 metric tons). This will produce another $50,000 in annual
savings.
After investigating the cause of the poorer than expected limestone utilization, the
engineer determined that the cause was poor placement of the electrodes for the
module pH meters. The electrodes were located high on the side of the reaction tank,
near the area where slurry leaving the absorber drains back into the tank. Because this
returning slurry is at a lower pH, this was apparently biasing the pH measurements
low. Slurry samples collected from drain valves on the slurry recirculation pump
suction line typically measure several tenths of a pH unit higher than the on-line meters
read.
To correct this bias, the plant moved the pH meter electrodes. New 1-1/2-inch (38 mm)
piping was added from the discharge of the slurry recirculation pumps back to the
absorber reaction tanks, and the pH electrodes for each absorber were installed on these
pipe runs. The piping was connected to two different pumps on each absorber, with
block valves at each pump, to ensure that the pH electrode would always have a source
of slurry.
The cost effectiveness calculations for this change are illustrated in Table 3-5. The cost
of these modifications was $25,000. The expected savings through improved limestone
utilization should total $134,000 annually, including reduced delivered limestone costs,
limestone grinding costs, and byproduct disposal costs. The payback period for this
modification is, therefore, expected to be only two months.
Optimize Makeup Water Use
Some FGD systems regularly operate with a positive water balance. That is, the fresh
water makeup to the FGD system regularly exceeds the rate at which water leaves the
system through evaporation into the hot flue gas and adhered to dewatered byproduct
leaving the system. Depending on the design of the FGD system, fresh water makeup
can be used for reagent slurry preparation, mist eliminator washing, packing gland
seals, and other uses. Some plants that dewater intermittently sometimes have to make
up fresh water just to maintain slurry levels in reaction tanks.
x A negative water balance results in the need to blow down liquor from the FGD
system. Depending on how the plant is permitted, the blowdown can be to a pond,
3-29
Table 3-5
Example Economics: Cost-Effectiveness of pH Controller Modifications
Plant Specifics With Current pH Electrode
450 MW average 85% Limestone utilization
2.5% Sulfur coal With New pH Controller
90% SO2 Removal efficiency 90% Limestone utilization
63,700 Tons SO2 removed per year $25,000 Capital investment
Prepared limestone cost of $12/ton
Disposal cost of $5/ton wet basis
A. Current Limestone Usage = (Tons SO2 removed per year) * (100 tons L.S./64 tons SO2)
(ton/yr) (L.S. Utilization/100) * (L.S. Purity/100)
= (63,700 tons/yr) * (100/64) = 124,000 ton/yr

(0.85) * (0.945)
B. Future Limestone Usage = (63,700 tons/yr) * (100/64) = 117,000 ton/yr

(ton/yr) (0.90) * (0.945)
C. Limestone Savings ($/yr) = [(Current Limestone Usage) - (Future L.S. Usage)] * (Prepared Price)
= [(124,000 ton) - (117,000 ton)]*($12/ton) = $84,000 /yr
D. Limestone Disposal Savings = (Tons Limestone Decrease) * (Disposal Cost)

($/yr) (Sludge Concentration/100)
= (124,000 - 117,000 ton/yr) * ($5/ton)/(70 wt%/100) = $50,000/yr
E. Annual Operating Savings = (Limestone Savings) + (Disposal Savings)

($/yr)
= ($84,000) + ($50,000) = $134,000
F. Payback Period (months) = (Capital Cost)/(Operating Savings)*(12 months/yr)
= ($25,000)/($134,000/yr)*(12 months/yr) = 2 months
3-30
to a wastewater treatment plant, or directly to a river or other body of water. As long as

the latter is permitted, there is not much financial incentive to close the FGD water
balance.
However, there is generally an incentive to operate in a closed water balance for plants
that cannot discharge directly to a body of water, and/or for plants that use
performance additives. For plants in areas where annual rainfall totals commonly
exceed evaporation rates, FGD blowdown to a pond can result in ever increasing pond
area requirements. If the plant has to treat a blowdown stream before discharge, this
represents an ongoing O&M cost. Also, plants that use performance additives such as
DBA have a financial incentive to close the water balance to reduce additive loss.
There are a number of strategies for closing the water balance on an FGD system. These
include:
x Wash the mist eliminator less frequently and/or for lesser duration, while
remaining within the EPRI guidelines for these parameters.
x Use a blend of fresh water and process water instead of 100% fresh water, where
possible.
x Replace packing glands on slurry pumps with mechanical seals.
x Restrict fresh water flow rates to packing gland seals on pumps and agitators to
near minimum recommended values.
x Add surge capacity so that process water from periods of high production rate (e.g.,
during intermittent dewatering) or low consumption rate can be used later.
There are also means of discarding more water, such as dewatering byproduct sludge
less effectively or treating more flue gas in systems with bypass just to evaporate more
water. However, these strategies tend to increase costs in other areas and are not
typically effective in lowering overall FGD costs.
Determining the Cost Effectiveness of Optimizing Makeup Water Use
The cost savings associated with closing the water balance on an FGD system will tend
to be site specific, largely dependent on the cost of makeup water and the costs
associated with blowdown. Plants with a relatively inexpensive source of makeup
water that are permitted to blow down to a river or other body of water will have little
if any incentive for optimizing makeup water use. For plants that must treat their
blowdown before discharge, these treatment costs could be avoided. For plants that
blow down to a pond, there may be little incentive to optimize makeup water use if the
plant is situated in a net positive evaporation rate area (annual evaporation exceeds the
3-31
annual precipitation). For plants in a net negative evaporation area, the avoided cost
may be the projected cost of building a new pond when the existing pond is filled. For
plants that are not allowed to discharge water, the need to operate with a closed water
loop may be a basic compliance issue.
A relatively closed water balance is also necessary to make the use of performance
additives such as DBA or sodium formate cost effective. Additive losses with the
blowdown can greatly increase the additive costs in plants with a positive water
balance.
A switch from packing gland type seals to mechanical seals is often part of a system-
wide effort to close the FGD water balance. Packing gland seals on large-diameter
pump shafts can consume 15 to 20 gpm (3.4 to 4.5 m3/h) of fresh water, while
mechanical seals typically require only 0 to 2 gpm (0 to 0.5 m3/h) to cool and flush the
seal surfaces.
Mechanical seals are relatively expensive, at approximately $10,000 each. However, it

may be possible to justify a switch to mechanical seals just to eliminate the cost of
maintaining packing gland seals on absorber recycle pumps.
In the mid-1980’s, one utility estimated that it cost $7200 per year in parts and labor to
maintain the packing gland seal on an absorber recycle pump. Another utility
estimated this cost at $3800. Mechanical seals typically last several years, and require
little or no ongoing maintenance, so there could be a payback period of one to three
years for this conversion irrespective of water balance considerations.
A closed water balance can sometimes be detrimental, though, particularly for plants
that operate in a forced oxidation mode. Forced oxidized systems dewater the
byproduct solids to low moisture content (typically less than 10 wt% moisture), so they
have a reduced capability to purge ionic species such as chloride. Systems that operate
in an inhibited or natural oxidation mode tend to dispose of byproduct solids at a much
higher free water content (typically 30 to 35 wt% moisture). Thus, chloride
concentrations in forced oxidation systems are often 3 to 4 times those in low oxidation
systems.
High chloride concentrations in FGD systems can have several adverse effects. One is
on materials of construction, particularly in the absorber where the vessel walls are
continually exposed to chlorides in the recirculating slurry liquor, and to relatively low
pH conditions. In some FGD systems it may not be practical to operate with a closed
water balance, because the absorber materials would be subject to severe chloride
pitting corrosion at the chloride concentrations that would result.
Another adverse effect of high chloride concentrations is on gypsum quality from

forced oxidation FGD systems. Wallboard quality gypsum typically has a specification
3-32
for maximum chloride content in the gypsum. Gypsum-producing FGD systems that
operate with a closed water balance typically have to wash their gypsum byproduct to
remove chlorides, and have to blow down some liquor anyway as a means of
controlling chloride concentrations at a manageable level.
Example Economics
A utility operates three 750-MW power plants, each with an FGD system. The FGD
systems typically operated with a positive water balance. The typical water balance
was as follows:
3
Water In gpm m /h
Pump / Agitator Seal Water 1600 363
Mist Eliminator Wash 1200 273
Limestone Grinding 300 68
Rainfall Runoff 600 136
TOTAL 3700 840

3
Water Out gpm m /h
Evaporated into Flue Gas 1700 386
Discharged with Byproduct Sludge 100 23
TOTAL 1800 409
Net Balance +1900 +431
The plant is located in an area of net negative evaporation in some years, and the FGD
pond was filling up with blowdown water. The plant installed and was operating a 600
gpm (136 m3/h) brine concentrator and a reverse osmosis unit to recover blowdown
water from the pond. The brine concentrator consumed 2 MW of power under normal
operation, and deep-well disposal of the concentrated brine was costing the utility
$50,000 per month.
The plant began an effort to close the water balance. Packing gland seals on the
absorber recycle pumps were replaced with mechanical seals, and the gland seals on
agitators had their seal water flow rates lowered from 15 to 2 gpm (3.4 to 0.5 m 3/h).
3-33
These changes lowered the seal water requirements from 1600 gpm (363 m3/h) to 600
gpm (136 m3/h).
The mist eliminator wash system was revised to wash at a higher intensity but less
frequently. This change lowered the wash water requirements from an average of 1200
gpm (272 m3/h) to 600 gpm (136 m3/h), and resulted in better ME reliability (reduced
tendency for plugging).
At the same time, the limestone grinding system was changed to use thickener
overflow rather than fresh water to slurry the incoming limestone. This eliminated the
need for an additional 300 gpm (68 m3/h) of fresh water.
The revised water balance looked like this:

3
Water In gpm m /h
Pump / Agitator Seal Water 600 136
Mist Eliminator Wash 600 136
Limestone Grinding - -
Rainfall Runoff 600 136
TOTAL 1800 409

3
Water Out gpm m /h
Evaporated into Flue Gas 1700 386
Discharged with Byproduct Sludge 100 23
TOTAL 1800 409
Net Balance 0 0
These modifications were very cost effective to make. The cost effectiveness calculations
are summarized in Table 3-6. The change in limestone grinding water source was just
an operating change, and had no associated cost. The change in the mist eliminator
wash frequency and duration was accomplished by reprogramming the controller for
the wash system, and similarly had no significant associated cost. The wash intensity
was increased by replacing the nozzles on the wash headers for the first stage mist
eliminator front face. Each of 24 absorbers has 60 front-face wash nozzles. The new
nozzles cost $25 each and were replaced during routing absorber maintenance. The
total cost of this modification was $36,000.
3-34
Table 3-6
Example Economics: Cost-Effectiveness of Improving Water Balance
Plant Specifics
Three 750 MW units
FGD systems have positive water balance
1900 gpm Positive balance
Mechanical seals added
ME wash less frequently
Thickner overflow used for L.S. grinding
Disposal cost of $5/ton wet basis
Internal power cost of $0.02/kWh
2 MW power for brine concentrator
$50,000/month brine disposal cost
A. ME Improvement Cost ($) = (Number of Absorbers) * (# Nozzles/Absorber) * (Cost per Nozzle)
= (24 Abs.) * (60 Nozzles/Abs.) * ($25/Nozzle) = $36,000
B. Mechanical Seal Cost ($) = (Number of Pumps) * (Cost per Seal)
= (84 Recycle Pumps) * ($10,000/seal) = $840,000
C. Concentrator Power = (Power Consumption) * (Operating Hours) * (Energy Cost)

Savings ($/yr):
= (2000 kW) * (8400 hr/yr) * ($0.02/kWhr) = $336,000/yr
D. Brine Disposal Savings ($/yr) = (Brine Disposal Cost per Month) * (12 months/year)
= ($50,000)*(12) = $600,000/yr
E. Seal Packing Savings ($/yr) = (Maintenance Cost/year/seal) * (# Recycle Pumps)
= ($7,2000)*(84) = $605,000/yr
F. Total Capital Costs ($) = (Pump Seal Cost) + (ME Nozzle Cost) + (Agitator Seal Cost)
= ($840,000) + ($36,000) + ($10,000) = $886,000
G. Payback Period (months) = (Capital Cost)/(Operating Savings)*(12 months/yr)
= ($886,000)/($336,000+ $600,000+ $605,000)*(12 months/yr) = 7 months
3-35
The agitator seal water flow was reduced by installing orifices and/or rotameters with
valves in the tubing to each seal. The parts for this modification cost $10,000 and were
installed by plant maintenance personnel.
The biggest expense item for this water balance improvement effort was for replacing
mechanical seals on the absorber recycle pumps. The plant has a total of 84 recycle
pumps. At $10,000 per seal, this represented an expense of $840,000. However, the
plant figured that they spent an average of $7200 per year per pump on maintaining
packing gland seals. Once installed, the mechanical seals were relatively maintenance-
free, and they had an expected life of two years or better. Therefore, the mechanical seal
installation could be justified independent of water balance considerations.
The costs of implementing these water balance modifications totaled $886,000. The
avoided costs were substantial. At the plant’s internal power cost of $0.02/kWh, the 2
MW consumed by the brine concentrator was worth $336,000 annually in savings if it
could be shut down. Eliminating the need for deep-well concentrated brine injection
would save $600,000 annually. Finally, eliminating the need for recycle packing gland
maintenance would reduce maintenance costs by $604,000 annually. Thus, the total
annual savings were on the order of $1.54 million. The payback period for these
expenditures was about 7 months.
Modify Reagent Preparation Scheme
Lime or limestone reagent represents a major FGD operating expense, particularly for
higher sulfur coals. For some FGD systems, it may be cost effective to consider alternate
reagent types or alternate sources for the same type of reagent. The former strategy is
discussed later in this section. For systems that use limestone reagent, modifications to
the limestone grinding equipment may also produce cost savings through improved
limestone reagent fineness. These approaches are described below.
For wet FGD systems that use lime reagent, reagent preparation conditions generally
have a lesser effect on utilization. Only if the reagent is “dead burned,” has excessive
“core” (remaining calcium carbonate), or if the lime slaking conditions are poor (high
sulfate content slaking water or excessive water dilution of the slurry in the slaking
chamber) might changes in the reagent or preparation system significantly improve
reagent utilization.
If a finer limestone grind is fed to the absorbers of a wet limestone FGD system, SO 2
removal performance can typically be maintained at a lower reagent ratio. This lower
reagent ratio may or may not correspond with lower pH set points. Lower reagent
3-36
ratios decrease the excess reagent in the absorber blowdown and reduce overall
limestone reagent consumption.
Determine the Cost Effectiveness of Changes in Reagent Preparation System
Improved limestone fineness is typically achieved by changes in the limestone grinding

circuit. These changes almost always require reducing the throughput of the limestone
grinder, which is usually a ball mill. At lower throughput, the mill must operate for a
longer period, and will consume more power. The mill power consumption rate is
typically not very sensitive to the limestone throughput, so greater hours of operation
typically result in a proportional increase in power consumed. Often, corresponding
equipment changes to the ball charge, limestone classifiers, and/or classifier feed
pumps are required.
The ball mill and/or classifier vendor can recommend changes to equipment and
operating conditions to most cost effectively produce a finer limestone grind. The
effectiveness of a finer limestone grind for improving limestone utilization can often be
tested by operating the existing grinding equipment at reduced throughput, though.
Improved limestone fineness can also be achieved by changes in the raw limestone
feed. For example, a smaller raw limestone feed size or a limestone with a lower Work
Index may grind to a finer product particle size distribution in the existing grinding
system. Also, “unscalped” limestones [e.g., ¾” by 0” (19 mm by 0 mm)] typically grind
to a finer product particle size distribution than a scalped limestone [e.g., ¾” by ¼” (19
mm by 6 mm)] with the same top size. However, the fines included in unscalped
limestone sometimes make the raw limestone harder to handle.
Changes in reagent source could have other cost saving effects. Many limestones have a
measurable magnesium content. In some stones this magnesium is present as dolomite
(MgCO3*CaCO3), which is essentially unreactive in wet FGD systems. The calcium
carbonate portion of the dolomite is also unreactive in wet FGD systems. In other
limestones, magnesium is present as a more reactive “solid solution” with the calcium
carbonate. The latter stones are generally more effective as a wet FGD reagent, because
more of the calcium carbonate is available in the FGD system. Also, in some FGD
system types the reactive magnesium content enhances SO2 removal performance by
raising the absorber slurry liquid phase alkalinity.
For wet FGD systems that use lime reagent, the magnesium content of the lime can
directly impact system performance and costs. In wet lime systems, the form of the
magnesium content is less important than in limestone reagent. Once the original
limestone is calcined to produce lime, even dolomite present in the limestone is
generally a reactive component of the slaked lime.
3-37
For wet lime systems designed to take advantage of the magnesium content to increase
liquid phase alkalinity, system SO2 removal performance typically improves with
greater lime magnesium content. However, many magnesium-enhanced lime FGD
systems see poorer byproduct solids dewatering performance as the magnesium
content of the FGD liquor increases. For these systems, the benefits of higher lime
magnesium content on SO2 removal performance may be offset by increased waste
disposal costs (having to dispose of a greater quantity of sludge because of a higher
water content).
In magnesium-enhanced lime wet FGD systems, the magnesium level is typically

varied by switching to a lime source with a different magnesium content. There are
usually only a couple of options available at a given plant, so it may be worthwhile to
test each lime source in full-scale trials to see which produces the most cost effective
overall performance.
Alternate sources of limestone or calcium carbonate in other forms may be used to

lower overall alkali reagent costs in limestone wet FGD systems. For example, calcium
carbonate sludges from water treatment plants or tailings from limestone quarries may
be lower cost sources of alkali than commercially available, sized limestone products.
These alternate reagent sources should be tested at full scale before implementing
permanent changes. Some reagent handling equipment may require revisions to handle
alternate reagent sources.
Example Economics
In this example, a 500 MW power plant fires a 2.5 % sulfur coal, and has a wet
limestone FGD system that achieves 90% overall SO2 removal. The reagent preparation
system only operates for one shift per day on average, and produces a relatively coarse
limestone grind (70% <200 mesh). The average limestone utilization is about 85%. The
limestone ball mills require a little over 600-hp power input while operating, or about
460 kW.
To investigate the effectiveness of producing a finer limestone grind, the plant runs a
week-long trial where the limestone grinding rate is cut in half. At this much lower
grinding rate, the limestone fineness improves to 95% <200 mesh, and the limestone
utilization correspondingly improves to 93%.
The calculations to determine the cost effectiveness of this change are summarized in
Table 3-7. To calculate the cost effectiveness of operating with a finer limestone grind,
first the value of the reduction in limestone consumption needs to be evaluated. This
improvement in limestone utilization will decrease the annual limestone consumption
from about 136,000 tons (123,000 metric tons) to 124,000 tons (112,000 metric tons), a
savings of 12,000 tons/yr (11,000 metric tons). The plant pays $7.00 per ton for the
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Table 3-7
Example Economics: Cost-Effectiveness of Finer Limestone Grind
Plant Specifics At 70% < 200 Mesh Grind
2.5% Sulfur coal 600 hp input for ball mill (460 kW)
90% SO2 Removal efficiency Ball mill operated 2700 hours per year
70,000 Tons SO2 removed per year At 95% < 200 Mesh Grind
Limestone cost of $7/ton 93% limestone utilization
Disposal cost of $7/ton wet basis Ball mill operated 4900 hours per year
Internal power cost of $0.02/kWh
A. Current Limestone Usage = (Tons SO2 removed per year) * (100 tons L.S./64 tons SO2)
= (70,000 tons/yr) * (100/64) = 136,000 ton/yr

(0.85) * (0.945)
B. Fine Limestone Usage (ton/yr) = (70,000 tons/yr) * (100/64) = 124,000 ton/yr

(0.93) * (0.945)
C. Limestone Savings ($/yr) = [(Current Limestone Usage) - (Fine L.S. Usage)] * (Del.’d Price + Disposal Cost)
= [(136,000 ton) - (124,000 ton)]*($7/ton + $7/ton) = $168,000 /yr
D. Grinding Power Cost ($) = (Power Consumption Rate) * (Fine Op. Hrs - Current Oper. Hours) * (Power Cost)
= (460 kW)*(4900 - 2700 hr)*($0.02/kWhr) = $20,200
E. Annual Operating Savings = (Limestone Savings) - (Pump Power Cost)

($/yr)
= ($168,000) - ($20,200) = $147,800
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limestone, and their waste byproduct disposal cost runs about $7.00 per ton (wet basis).
Considering the reduction in raw limestone purchases and the corresponding decrease
in waste byproduct disposal, the gross savings associated with the finer grind amounts
to $168,000 annually.
There is a corresponding cost to operate the mills for almost double the time they
currently operate. The primary cost will be the increased mill power consumption. The
mills will go from the current 2700 hours per year of operation to approximately 4900
hrs (grinding at half the rate but a lesser amount of limestone). The mill power
consumption will not vary much with grinding rate, so assuming the same 460 kW,
the mill power consumption will go from approximately 1.24 million kWh to 2.25
million kWh. At an internal power cost of $0.02/kWh, the annual increase in mill
power consumption would be $20,200.
As a first approximation, it appears that it could save over $140,000 per year in O&M
costs to use the existing equipment to produce a finer limestone grind. This analysis
assumes there would be no increase in operating labor, since limestone grinding
equipment is generally not labor intensive to operate, and that the existing operating
crew would be able to operate this equipment for an average of two shifts rather than
one shift per day. There will be other costs, such as increased grinding ball
consumption and increased mill liner wear. Also, it may prove that minor capital
expenses such as classifier modifications may be necessary to optimize circuit
performance at the finer grind conditions. A more detailed analysis would be needed
to quantify these additional costs. However, these calculations indicate that improving
limestone grind fineness should be cost effective at this plant, with potential savings in
excess of $100,000 per year even considering these other possible expenses.
Change Liquid to Gas Ratio
In some FGD system designs, operating costs can be minimized by varying the
absorber liquid-to-gas (L/G) ratio. For a given flow rate of flue gas being treated,
absorber recycle pump power requirements are directly related to the L/G ratio. This
in turn is a function of the number of absorbers in operation and the number of pumps
operated per absorber. These may be varied dependent on the flue gas flow rate, flue
gas SO2 concentration, required SO2 removal efficiency, and other factors.
For systems that have spare absorber modules and/or multiple spray header/pump
combinations per absorber, the number of operating modules and pumps per module
can be optimized to produce the lowest overall FGD operating cost. That is, at a given
unit load and/or flue gas flow rate treated, the number of absorbers and pumps per
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absorber in service can be optimized for minimum overall operating cost. However, the
optimal operating conditions may not be those where the lowest pump power
consumption is experienced. Absorber SO2 removal performance, reagent utilization,
sulfur oxidation percentage, mist eliminator performance, booster fan power, as well as
the overall system water balance must be considered in developing this optimum.
Determining the Cost Effectiveness of Varying L/G
A number of factors can be varied to allow operating at lower L/G. However, each
results in O&M and/or cost impacts elsewhere in the system. For example:
pH Set Point – Can be raised to allow operating fewer pumps per module but at the
expense of greater reagent consumption and possibly increased module or mist
eliminator plugging.
Performance Additives – Can be added to systems not currently using performance

additives, or concentrations can be increased in those that already do, to allow
operating fewer pumps per module. This approach can require capital costs to install
an additive feed system, and O&M costs to purchase the additive. Other effects on the
system can occur when additives are used, including changes in reagent utilization,
sulfite oxidation percentage, system scaling tendency, slurry dewatering properties, etc.
Environmental permits also need to be considered for plants that discharge liquid from
the FGD process.
Module revisions – Modifications such as tray retrofits in spray towers, and packing
level or type changes in packed absorbers can allow operating with fewer pumps to
reduce pump power consumption. However, each of these has capital expense
requirements, and may affect other cost areas such as reagent utilization, absorber
scaling tendencies, or fan power requirements.
In some systems multiple spray header levels are fed slurry from a common
recirculation pump, making it more difficult to vary L/G. In these systems it still may
be possible to realize cost savings from operating at reduced L/G through piping
changes, pump impeller changes, sheave changes on pump belt drives, etc. Again,
though, the savings available through operating at reduced L/G have to justify these
expenses.
Example Economics
In this example, a 500 MW plant fires a low sulfur coal, and has a limestone FGD
system operating four spray tower absorbers. Each absorber has four spray header
levels and two slurry recirculation pumps. The upper pair of headers is fed by one
pump and the lower pair is fed by the other. Testing on one module has determined
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that with a tray retrofit, SO2 removal performance can be maintained at half the L/G,
allowing one pump on each absorber to be shut down. The cost effectiveness of this
change is calculated in Table 3-8, and summarized below.
Measurements indicate that each pump feeding the upper pair of spray headers
consumes 380 kW of electric power. For a plant that operates 8000 hours per year,
shutting down one pump would save a little over 3 million kWh per year, or about
$60,800 in power costs at $0.02/kWh. There would also be associated savings in pump
maintenance materials if this pump does not operate, but these savings have not been
estimated here.
There would be two costs associated with adding a tray to allow this pump to be shut
down. One is the cost of the tray conversion itself, which was estimated at $60,000 per
absorber. Using a capital recovery factor of 0.17, this capital cost corresponds with an
annual expense of $10,200. The other cost is increased scrubber booster fan power,
because of the increased absorber pressure drop with the trays installed and operating.
Data from the test absorber indicate that the pressure drop will increase by an average
of 1.5 in. H2O (0.37 kPa), which corresponds to a 20% increase in system pressure drop.
This plant has axial flow booster fans, with variable pitch rotor blades, so this increase
in pressure drop will result in an increase in fan motor power consumption. In plants
that have centrifugal fans and control flue gas flow rate with dampers, there may not
be a net increase in fan power consumption with such a retrofit.
In this case, though, annual fan power consumption is assumed to increase by a

corresponding 20%. This is a conservative estimate, as most variable-pitch axial flow
fans improve in efficiency as the fan approaches maximum output. This effect could
reduce the actual fan power increase to well below 20%.
For this estimate, though, we will assume that the 2000 hp (1500 KW) booster fan
motors, which currently operate at about 1300 hp (970 KW) at average unit load, will
increase to 1560 hp (1164 KW) average power output. This amounts to a 260 hp
increase, or an increase in power consumption by 194 kWh. For 8000 hours of plant
operation annually and an internal power cost of $0.02/kWh, this increased fan power
amounts to $31,200 annually.
Therefore, in this example the annual pump power savings amount to $60,800 per
absorber, while the costs include $10,200 in capital recovery and $31,200 in increased
fan power, for a net annual savings of $19,400 per absorber. For the entire unit, this
amounts to $77,600 in annual savings. Also, the net generating capacity of the plant
would be increased by about 0.7 MW.
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Table 3-8
Example Economics: Cost-Effectiveness of Finer Limestone Grind
Plant Specifics With Open Spray Tower
500 MW 380 kW for upper sprays pump
Low sulfur coal 1300 hp for axial booster fan (1000 kW)
Four open tower absorbers With Tray Installed
Four spray headers with 2 recirculation pumps 260 hp increase for axial booster fan (194 kW)
Internal power cost of $0.02/kWh $60,000 for tray installation per absorber
8000 operating hours per year
A. Energy Savings per Pump = (Pump Power Consumption) * (Operating Hours) * (Energy Cost)
($/yr)
= (380 kW) * (8000 hr/yr) * ($0.02/kWhr) = $60,800/yr
B. Annualized Tray Capital Cost = (Tray Capital Cost) * (Capital Recovery Factor)
($/yr)
= ($60,000) * (0.17) = $10,200/yr
C. Booster Fan Energy Cost ($/yr) = (Increased Power Consumption Rate) * (Operating Hours) * (Power Cost)
= (194 kW) * (8000 hr/yr) * ($0.02/kWhr) = $31,200 /yr
D. Annual Operating Savings = (Pump Power Savings) - (Annual Capital Cost) - (Fan Power Cost)
($/yr)
= ($60,800) - ($10,200) - (31,200) = $19,400/yr/absorber
E. Total Annual Savings ($/yr) = (Number of Absorbers) * (Savings per Absorber)
= 4 * ($19,400) = $77,600/yr
F. Increase in Generating Cap. = [(Pump Power Savings) - (Fan Power Cost)] * (No. of Absorbers)/1000 kW/MW
(MW)
= [(380 kW) - (194 kW)]*4/1000 = 0.7 MW
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Convert to Wet Stack Operation
Description of Strategy
Many FGD systems are designed such that the moisture-saturated flue gas exiting the
FGD system is reheated to above its dew point. Reheat is typically included in the
system design to improve plume buoyancy and dispersion, to avoid the rainout of
acidic droplets in the vicinity of the stack, and/or to allow less expensive materials of
construction for ductwork and the stack liner.
There are several methods for doing this, but most reheat systems either involve
bypassing a portion of the hot flue gas around the FGD system and mixing that gas
with the saturated stream leaving the FGD system, or using steam or a supplemental
fuel to directly or indirectly heat the flue gas stream. The latter (indirect reheat) uses
steam or a supplemental fuel to heat ambient air, and the heated air is mixed with the
flue gas to raise it well above saturation conditions.
Gas bypass is typically the least inexpensive means of providing reheat for FGD
systems with moderate to low SO2 removal efficiency requirements (e.g., 85% removal
or less). Plants with higher SO2 removal efficiency requirements generally cannot
bypass enough gas to effectively reheat the FGD outlet gas while still maintaining a
high overall SO2 removal efficiency. Gas bypass is further discussed in the next
subsection. The remainder of this discussion will focus on steam or fired reheat
systems.
Steam or gas/oil fired reheat is generally expensive to operate and maintain. Steam
requirements can represent up to several percent of the station’s steam recirculation
rate. Gas or oil fuel requirements can represent several percent of the unit’s heat input.
In-line reheaters are subject to corrosion, scaling and plugging, and indirect reheaters
require additional fans, ductwork, and dampers that have to be maintained. Plants
with steam or fired reheaters can typically realize immediate benefits from improved
net plant heat rate and reduced maintenance costs if they can convert to wet stack
operation.
Determining the Cost Effectiveness of a Wet Stack Conversion
As mentioned above, there are two scenarios for wet stack conversions. One is where
there is an incentive to close a bypass duct and treat all of the flue gas in an FGD
system, and the other is where there are existing steam or fired reheaters and a desire
to shut them down. This subsection discusses the latter.
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A major issue for any wet stack conversion is the design of the existing stack. The gas
velocity through the stack must be suitable for wet stack operation [wet stack operation
generally requires gas velocities of 45 to 50 ft/sec (13.7 to 15.2 m/s) or less], and the
stack liner materials must be compatible with moisture-saturated, acidic conditions.
Wet stack conversion typically involves the addition of liquid collection devices and
drains inside the stack liner. Laboratory-scale flow modeling is typically required to
design these devices. Wet stack conversion for one 500 MW plant that had a suitable
existing ductwork layout, stack velocity and liner material was estimated to cost
between $300,000 and $600,000, exclusive of any cost penalty for a unit outage to allow
the conversion to take place.
If stack replacement is necessary, the associated costs will be much higher. New stacks
typically cost somewhere in the range of $5 to $15 million, depending on unit size,
stack height, materials of construction, and site access specifics.
Another issue common to any wet stack conversion is that of air emissions permitting.
Although closing a bypass may actually improve overall system SO 2 performance, the
power plant may be under local or regional controls that limit ground level SO2 or NOx
concentrations (e.g., Prevention of Significant Deterioration or PSD). Since the
temperature and velocity of the flue gas impacts the plume buoyancy and dispersion,
ground-level SO2 and NOx concentrations in the vicinity of the plant may be impacted
by a wet stack conversion. In situations where the gas bypass is closed, the lower stack
SO2 concentration that results from treating all of the flue gas will help offset ground
level SO2 impacts. For situations where a steam or fired reheater is eliminated, the SO2
concentration in the flue gas will not be reduced by the wet stack conversion. In these
cases, and for NOx emissions from either type of wet stack conversion, ground level
concentrations of SO2 or NOx may increase in some areas. It may be necessary to
conduct dispersion modeling of the wet stack operation and modify the permit for the
unit. In some instances, such as a plant in a non-attainment area for criteria pollutants,
it may not be possible to permit a wet stack conversion.
If an existing steam or direct-fired reheat system is shut down, and the existing stack is
suitable for conversion, there is typically no significant cost beyond the stack
conversion, permitting, and decommissioning/demolition costs. There should be an
immediate benefit in fuel costs, though. For direct-fired reheaters, this entire fuel
requirement can be eliminated. For steam reheaters, the amount of fuel savings is less
straightforward to estimate, as the amount saved will depend on details of the
medium- or low-pressure turbine and the reheat zones of the boiler.
3-45
Example Economics
In this example, a 55-MW power plant was originally designed with an in-line steam
reheater to raise the saturated flue gas exiting the absorber above its moisture dew
point. The stainless steel reheater was found to be subject to scaling and plugging, and
corrosion which caused steam leaks. After several years of operation, the plant
determined that to be able to continue operating with reheat, the existing reheater
would have to be replaced with a new unit constructed of a high grade nickel alloy.
The plant also considered shutting down the reheater. The existing stack was lined
with gunite, which was not in good condition, and the existing FGD outlet duct and
bypass dampers were constructed of 316L stainless steel. It was determined that these
materials would not hold up well under wet flue gas conditions. The stack and duct
were relined with borosilicate block on the walls, and C-22 alloy on the floor. The stack
floor was also raised to accommodate drains. The bypass dampers were replaced with
C-276 materials of construction.
The wet stack conversion was completed during a planned turbine outage. The costs
for the wet stack conversion and materials upgrades were actually $200,000 less than
the estimated cost to replace the reheater. The O&M costs for the wet stack conversion
were estimated on a 10-year, present value basis. The present value of O&M costs for
the wet stack case was estimated to be $1.1 million lower than the costs to continue with
a new reheater. In total, the present value for the wet stack conversion was $1.3 million
lower than the cost estimate for continuing to operate the reheater.
After the conversion the plant efficiency was reportedly 4% higher, mostly due to the
elimination of the reheater steam consumption. The plant was also able to eliminate
weekly unit outages due to steam leaks in the old reheater. This previous expense is not
reflected in the comparison economics above.
Close Bypass Damper
Many FGD systems are designed such that not all of the flue gas is treated in the FGD
system. In these systems a portion of the hot flue gas is bypassed around the FGD
system and mixed with the saturated gas stream leaving the FGD system. Bypass is
typically employed for two reasons. One is that the plant may not be required to
achieve high overall SO2 removal efficiencies. For these units it is generally more cost
effective to treat a portion of the flue gas in the wet FGD system at relatively high SO2
removal efficiency, then bypass as much gas as possible while remaining within
permitted emissions rates. This is because some costs associated with FGD systems are
more a function of the volume of gas treated rather than the removal efficiency (e.g.,
3-46
fan power). Another reason for designing systems with gas bypass is to reheat the
treated gas to well above its saturation temperature, as discussed in the previous
subsection.
The biggest expense in implementing bypass reheat tends to be in materials of

construction at the point of mixing. The mixing of cool, saturated gas with hot gas
laden with SO2 (and SO3) tends to make a very corrosive environment. Bypass reheat
mixing zones are often “wallpapered” with high alloy plate.
With the 1990 Clean Air Act Amendments, utilities have an incentive to operate FGD
systems at higher overall SO2 removal efficiencies. Increased efficiencies
correspondingly increase the tons per year of SO2 removed by the FGD system, which
can be used to offset the emissions from other units or sold to other utilities. In this
regulatory environment, it may be economically desirable to eliminate bypass reheat
where possible and scrub 100% of the flue gas in the FGD system. Closing the bypass
also generally requires that the stack be modified to operate in a “wet” mode, as
described in the previous subsection.
Determining the Cost Effectiveness of Closed Bypass Operation
There are several issues that impact whether closed bypass operation is feasible. One is
whether or not the existing FGD system is adequate for treating all of the flue gas.
Limiting factors can include fan power availability, resulting gas velocities through
absorber vessels and mist eliminators, resulting L/G values, reagent preparation
system capacity, dewatering system capacity, etc.
If flue gas bypass is eliminated (or reduced) as a means of increasing the tons per year
of SO2 removed by the FGD system, there are a number of O&M costs associated with
this additional removal. At a minimum, there is usually increased fan power for
achieving the additional gas flow through the FGD system, increased limestone
consumption, and increased byproduct disposal costs (if a saleable byproduct is not
produced). Other costs can include additional pump power if an additional module
and/or if more pumps per module must be operated, increased oxidation air rates for
forced oxidation systems, increased performance additive and/or sulfur additive
consumption, and any associated increases in maintenance costs for FGD equipment.
However, closing the bypass will generate additional SO2 allowances, by allowing the
existing FGD system to remove more tons of SO2. These additional allowances can be
sold under the allowance trading system or used by the utility elsewhere in its system
for compliance with Title IV of the 1990 Clean Air Act Amendments.
Another issue for closing the bypass is the design of the existing stack. The gas velocity
through the stack must be suitable for wet stack operation [wet stack operation
3-47
generally requires gas velocities of 45 to 50 ft/sec (13.7 to 15.2 m/s) or less], and the
stack liner materials must be compatible with moisture-saturated, acidic conditions.
Wet stack conversion was discussed previously.
Finally, some utility flue gas systems are designed and/or operated with an “open
bypass” configuration, where the FGD booster fans pull flue gas from an open duct to
the stack, and the treated flue gas is returned to that duct further downstream. This
makes the boiler draft relatively independent of the FGD system operation. If a bypass
damper is closed between the FGD suction and return ducts, the boiler draft becomes
dependent on the gas flow through the FGD system. A booster fan trip could trip the
boiler as well. Power plants with this flue gas flow configuration should conduct a
boiler draft study to ensure that the control strategy will minimize the possibility of
boiler trips caused by potential FGD system upsets.
Example Estimate
In this example, a 700-MW lignite-fired power plant operates 8000 hours per year at an
average load of 500 MW. The lignite sulfur content averages 3.6 lb/million Btu (1.7
g/J), and the outlet emissions are controlled at 1.05 lb/million Btu (0.5 g/J). The FGD
absorbers are quite efficient, achieving about 98% removal on the flue gas treated at full
load conditions. On average, about 28% of the flue gas is bypassed around the FGD
system.
This plant removes about 54,000 tons/yr (49,000 metric tons/yr) of SO2. However, at
the currently permitted level the plant still emits about 22,000 tons/yr (20,000 metric
tons/yr). As part of its overall compliance plan for Phase II of the 1990 Clean Air Act
Amendments, the utility is considering operating this FGD system with a closed
bypass, and removing much of this additional 22,000 tons/yr (20,000 metric tons/yr) of
SO2.
Short-term, full-scale testing with the bypass closed indicates that the FGD system will
be able to maintain 98% overall SO2 removal at average unit load and lignite sulfur
conditions. The increase in system pressure drop with all of the flue gas going through
the four modules was measured at 1.6 in. H2O (0.40 kPa).
If the FGD system is able to achieve 98% overall removal when treating all of the flue
gas, the total tons of SO2 removed would amount to 73,500 (66,700 metric tons)
annually, an increase of 19,500 tons (17,700 metric tons) from the present value.
Additional costs to achieve this level of removal on a continued basis will be the cost of
a wet stack conversion, plus costs for additional fan power, limestone reagent, and
waste byproduct disposal. The cost effectiveness of closing the bypass is calculated in
Table 3-9, and discussed below.
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Table 3-9
Example Economics: Cost-Effectiveness of Closed Bypass Operation
Plant Specifics With Bypass Open
700 MW, 500 MW average 53,000 Tons SO2 removed per year
Lignite coal 70 wt% waste sludge solids
98% SO2 removal efficiency With Bypass Closed
85% Limestone utilization 73,500 tons SO2 removed per year
Limestone cost of $12/ton 70 wt% waste sludge solids
Disposal cost of $5/ton wet basis $90,000 annual fan power cost Increase
Internal power cost of $0.02/kWh $600,000 capital cost for wet-stack conversion
Pump operating 8000 hours per year
A. Increased Limestone Cost = (Increased Tons SO2 removed/year) * (100 tons L.S./64 tons SO2) * (Price)
($/yr) (L.S. Utilization/100) * (L.S. Purity/100)
= (19,500 tons/yr) * (100/64) * ($12/ton) = $454,000/yr

(0.85) * (0.947)
B. Byproduct Rate Increase = (Tons SO2 Increased/yr)/(SO2 M.W.) * [Prod. M.W. + Limestone M.W.*(1-Utilization)]
(tons/yr) (Sludge Concentration/100)
= (19,500 tons/yr)/64 * (131.4 + 100*(1-0.85)) = 63,700 tons/yr

(70 wt%/100)
C. Increase in Disposal Cost ($/yr) = (New Waste Sludge Rate) * ( Disposal Cost)
= (63,700 ton/yr) * ($5/ton) = $319,000/yr
D. Annual Stack Capital Cost ($/yr) = (Wet Stack Capital Cost) * (Capital Recovery Factor)
= ($600,000) * (0.17) = $102,000/yr
E. Annual Inc. Operating Costs = (Fan Power Cost) + (Disposal Cost) + (Limestone Cost) + (Stack Cost)
($/yr)
= ($90,000) + ($319,000) + ($454,000) + ($102,000)
= $965,000/yr
F. Cost per Ton SO2 ($/ton) = (Annual Operating Cost)/(Tons Additional SO2 Removed)
= ($965,000) / (19,500 tons) = $50/ton
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At the internal power cost of $0.02/kWh, the additional fan power was estimated at
$90,000 annually. At the average limestone utilization of 85%, an additional 37,800 tons
(34,300 metric tons) of limestone will be required to remove the additional 19,500 tons
(17,700 metric tons) of SO2. The average cost of prepared limestone slurry at this plant is
$12/ton (dry basis), so this limestone represents an additional annual cost of $454,000.
The additional 19,500 tons (17,700 metric tons) of SO2 removed will produce 40,000
tons/yr (36,300 metric tons) of calcium sulfite byproduct (assumes 15% oxidation), and
the excess limestone will amount to 4600 tons/yr (4200 metric tons) of waste. The waste
byproduct sludge typically runs 70 wt% solids, so this 44,600 tons/yr (40,500 metric
tons) of dry waste will amount to 63,700 tons (57,800 metric tons) of wet sludge. At the
plant’s sludge disposal cost of $5.00 per wet ton, this amounts to an annual expense of
$319,000.
The variable expense associated with removing these additional 19,500 tons (17,700
metric tons) of SO2 annually amount to $863,000 ($90,000 for fan power, $454,000 for
limestone, and $319,000 for waste sludge disposal), which is equivalent to $45 per
additional ton of SO2 removed.
For a first estimate of the capital cost for a wet stack conversion, the plant assumed
$600,000. Using a capital recovery factor of 0.17, this amounts to an annual cost of
$102,000. Factoring in this capital expense, the annual cost for removing an additional
19,500 tons of SO2 totals $965,000, which is equivalent to $50 per additional ton of SO2
removed. If this cost is attractive compared to other Phase II compliance options for this
utility, they should further investigate closed bypass operation with a wet stack
conversion. For comparison, in May 1998, the average market value of SO2 allowances
under the allowance trading program established by the 1990 Clean Air Act
Amendments was around $140/ton of SO2.
Use Spare Module in Normal Operation
Many FGD systems have been built with spare module capability. That is, there is often
one or sometimes two more absorber modules than are required to treat the design flue
gas flow. In most instances the “spare” module varies in a rotation, with one module
being taken off line for maintenance while the others operate. That module remains off
line until another module needs to come down for cleaning or other maintenance.
Some utilities would benefit from operating that spare module as much as possible. In
this scenario all of the FGD absorbers would be in operation unless a module needed to
come off line for cleaning or other maintenance. After that work was completed, the
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module would be put back on line and all would operate until another needed
maintenance.
Determine the Cost Effectiveness of Operating the Spare Module
There are several circumstances where this might be beneficial. One is where there is a
favorable trade-off between fan power and pumping power. For example, in a system
where there are four absorbers, and four pump/spray headers per absorber, normal
operation may consist of three modules in service with all four pump/spray header
levels running. However, it may reduce overall power consumption to operate all four
absorbers with only three pump/spray header levels in service. Fan power may be
reduced by operating four absorbers, resulting in lower gas velocities and lower system
flue gas pressure drop. A minor reduction in pump power may also be realized if the
three lowest spray headers are preferentially operated, due to a small overall pumping
head reduction.
The ability to save fan power operating in this mode will depend on the fan type and
damper configuration. For example, systems with centrifugal fans that control gas flow
rate with dampers would not benefit from operating in this mode unless permanent fan
modifications were made.
Another circumstance where a savings might be realized by operating all modules is

where mist eliminator plugging appears to be exacerbated by high flue gas velocities
through the ME. In this case operating all modules should result in a proportional
decrease in flue gas velocity through the ME, and could markedly reduce droplet carry
up to the ME and improve the performance and cleanliness of the ME.
A third reason for operating all modules when possible might be where additional SO2
removal performance is desired, because of SO2 emissions compliance issues or to
generate additional SO2 allowances. Using the example of a four-module system,
additional SO2 removal could be achieved by operating all four modules with four
pump/spray header levels per module, compared to normal operation with three
modules and four pump/spray header levels. The cost effectiveness of this
overscrubbing approach will depend on the number of additional tons that can be
removed by operating in this mode, versus the increased variable costs (increased
reagent consumption; byproduct production; fan, pump and agitator power
consumption; associated equipment maintenance).
Water balance impacts must be considered for any approach where more absorbers are
used to treat the same amount of flue gas. If the mist eliminators are washed with
fresh/makeup water, or a mix that includes fresh/makeup water, having to continually
clean one more ME may have an adverse affect on the system water balance. Similarly,
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if more side-mount agitators and/or more pumps are operated, more seal water will be
required unless mechanical seals are used.
There could be other impacts of operating the spare module. Reagent utilization may
improve because the solids residence time in the FGD system increases. Assuming the
weight percent solids levels in the absorber recirculating slurry is not changed, the
inventory of solids in each absorber reaction tank remains fixed but the amount of SO2
removed in each absorber is reduced in proportion to the flue gas flow rate. Similarly,
other factors such as sulfite oxidation or byproduct solids dewatering properties may
be affected.
Also, the system SO2 removal performance may be affected by operating the spare
module. Besides the effects of any changes in L/G, the change in flue gas velocity
through the absorbers can impact gas/droplet mixing. This impact could be positive or
negative.
Example Economics
A 500-MW power plant that fires a 2.5% sulfur coal has an FGD system with four
modules, each with a booster fan and four pump/spray header combinations. Normal
operation calls for operating three modules with all four pump/spray headers in
service. At typical high load conditions (450 MW) the FGD system achieves 90% SO2
removal. The normal pH set point results in 85% limestone reagent utilization. The
FGD system pressure drop at 450 MW and with three modules in operation averages
6.2 in. H2O (1.5 kPa). The superficial gas velocity through the absorbers is 10.4 ft/sec
(3.2 m/s). The booster fan motor current runs about 83 amps at these conditions.
The plant decides to investigate four-module operation, and conducts a test while
operating in that mode. With four modules in service the flue gas velocity through the
absorbers drops to 7.7 ft/sec (2.3 m/s). To maintain the same L/G, only three
pump/spray header levels are operated on each of the four modules. The three pumps
and spray header levels operated vary from module to module based on the cleanliness
of the nozzles, so no pump head decrease can be claimed.
The FGD system SO2 removal performance and byproduct solids dewatering
performance is relatively unaffected by this change, but the limestone utilization is
observed to increase by three percentage points. The FGD system pressure drop is
lowered to 3.4 in. H2O (0.85 kPa), and the fan motor current drops to 59 amps for the
four rather than three fans that are operating.
Table 3-10 summarizes the calculations for estimating the cost effectiveness of operating
the spare module. The fan motors operate at 6600 volts, with a power factor of 0.9. In
three-module operation the fan motors consume a total of 2560 kW of power. In
3-52
Table 3-10
Example Economics: Cost-Effectiveness of Using a Spare Module
Plant Specifics With Three Modules
500 MW (450 MW average) Four pumps with headers in service
2.5% Sulfur coal 6.2 inch pressure drop with 10.4 ft/s velocity
90% SO2 removal efficiency Fan motor amperage of 83 amps with 2560 kW
power
70 wt% byproduct sludge conc. 85% Limestone utilization
63,700 tons SO2 removed per year With Four Modules
Limestone cost of $12/ton Three pumps and headers in service
Disposal cost of $5/ton wet basis 3.4 inch pressure drop with 7.7 ft/s gas velocity
Internal power cost of $0.02/kWh Fan motor amperage of 59 amps with 2430 kW
power
Pump operating 8400 hours per year Agitator in spare module consumes 50 kW
power
88% Limestone utilization
A. Booster Fan Energy Savings = (Decreased Power Consumption Rate) * (Operating Hours) * (Power Cost)
($/yr)
= (2560 - 2430 - 50 kW)*(8400 hr/yr)*($0.02/kWhr) = $13,000/yr
B. SO2 Removal Rate (ton/yr) = (Avg. Unit Load)*(Operating Hrs)*(Heat Rate)*(Sulfur Content)*(SO2 Removal)
= (450 MW)*(8400 hr/yr)*(9000 Btu/kWh)*(2.5%S/100)*(90% SO2 Rem./100)

C. Current Limestone Usage = (Tons SO2 removed per year) * (100 tons L.S./64 tons SO2)
= (63,700 tons/yr) * (100/64) = 124,000 ton/yr

(0.85) * (0.945)
D. Spare Mod. Limestone Usage = (63,700 tons/yr) * (100/64) = 120,000 ton/yr

(ton/yr) (0.88) * (0.945)
E. Limestone Savings ($/yr) = [(Current Limestone Usage) - (Spare Mod. L.S. Usage)] * (Prepared price)
= [(124,000 ton) - (120,000 ton)] * ($12/ton) = $48,000 /yr
3-53
F. Limestone Disposal Savings = (Tons Limestone Decrease) * (Disposal Cost)

= (124,000 - 120,000 ton/yr) * ($5/ton)/(70 wt%/100) = $29,000/yr
G. Annual Operating Savings = (Pump Power Savings) + (Disposal Savings) + (Limestone Savings)
($/yr)
= ($13,000) + ($29,000) + ($48,000) = $90,000/yr
3-54
four-module operation, the total fan motor power consumption dropped to 2430 kW.
However, the agitators on the reaction tank for the spare module consume about 50
kW. Thus the net fan power savings would be 80 kW. For 8400 hours per year of
operation and an internal power cost of $0.02/kWh, operating with four rather than
three modules in service would save about $13,000 in power costs.
The observed improvement in limestone utilization would lower the annual limestone
consumption from 124,000 tons(112,000 metric tons) to 120,000 tons (109,000 metric
tons). At a cost of $12 per prepared ton, this improvement in limestone utilization
would amount to about $48,000 in savings on limestone purchase and preparation
annually. Furthermore, this amount of limestone would not end up in the waste
byproduct sludge, which at 70 wt% solids corresponds to an annual reduction in sludge
quantity of 5700 tons (5200 metric tons). At the waste sludge disposal cost of $5 per wet
ton, this savings amounts to almost $29,000 per year.
Thus, the total saving in operating and maintenance costs would be about $90,000
annually. The decision whether to operate with four rather than three modules should
also consider other factors such as mist eliminator performance and water balance
considerations, but this initial evaluation shows that four-module operation is more
cost effective than the present mode.
Add Packing or Tray
In FGD systems where the current gas contactor is an open spray absorber, it may be
cost effective to retrofit packing or a tray. If the gas contactor is packed, it may similarly
be cost effective to vary the depth of packing.
Adding a tray or packing increases the area available for mass transfer within the
absorber. To convert an existing spray tower, several potential benefits should be
considered. One is that system SO2 removal performance may be improved, making
this a strategy for “overscrubbing” to generate additional SO2 allowances. A packing or
tray retrofit may also be considered as a means of reducing FGD power consumption.
In some instances a tray retrofit may allow fewer slurry recycle pumps to operate while
achieving the current SO2 removal level. The savings in pump power will be offset to
some degree by the expected increase in fan power due to the gas pressure drop across
the packing or trays.
Many utilities are hesitant to consider a packing retrofit to existing spray absorbers.
Many “first generation” FGD systems were packed, and were notorious for scaling and
plugging in the packing. Operators of these systems frequently had to shut down and
3-55
manually clean their absorbers to restore full load gas flow capabilities. While most
modern packed absorbers have been designed to minimize scaling in the packing, the
legacy of the earlier systems remains.
Utilities are in general more open to tray retrofits. The trays are simpler mechanically
than packing, often consisting of no more than a perforated alloy plate installed at a
certain level within the absorber. While scale formation on tray surfaces is definitely
possible, it is generally easier to clean than scaled packing. Also, metal trays are
considerably more durable than plastic packing
In existing packed systems, packing depth may be varied to lower overall system costs,
particularly in combination with performance additives such as DBA or sodium
formate. Adding packing will tend to improve system SO2 removal performance, but
will tend to increase absorber pressure drop and increase the potential for scaling in the
packed section. Lesser packing depths will tend to lower absorber pressure drop and
scaling potential, but at the expense of SO2 removal performance. The latter can often be
offset by the use of performance additives, though.
Determining the Cost Effectiveness of Adding a Tray or Packing
The effectiveness of a tray or packing retrofit will tend to be site specific. The
improvements in SO2 removal performance or the ability to lower L/G with a tray or
packing retrofit will be greatest in FGD systems that currently operate near their gas-
film limitation to mass transfer. Examples of this type of system include those that treat
flue gas with a low inlet SO2 concentration and/or that are currently achieving high SO2
removal percentages.
As an example of the effectiveness of a tray retrofit, a Western utility operates a 450

MW power plant with an FGD system that uses spray tower absorbers. At the design
L/G of 60 gpm/Kacfm (8.0 m3/h slurry per km3/h flue gas) and typical pH set point
values, the absorbers can achieve almost 95% SO2 removal on the flue gas treated. A
tray was retrofitted to one absorber; however, details of the tray design were not
available (e.g., hole diameter and percent open area on the tray). At the design flue gas
velocity and L/G, the SO2 removal across that absorber increased to over 98% while the
absorber pressure drop increased by 2 in. H 2O (0.5 kPa).
This performance increase is more dramatic when expressed in terms of NTU (see the
subsection on performance additives for a discussion of NTU). The tray improved the
baseline performance by 1.5 NTU at the design flue gas flow rate and L/G. The NTU
increase averaged about 1.0 over the normal range of absorber operation, with gas
velocities of 8.5 to 10.0 ft/sec (2.6 to 3.0 m/s), and L/G values of 60 (8.0) down to 50
(6.7 m3/h slurry per km3/h flue gas).
3-56
At the design flue gas velocity, the SO2 removal was lowered to 96% when reducing the
L/G by half, to 30 gpm/Kacfm (4.0 m3/h slurry per km3/h flue gas) (turning off one
pump and two of four spray header levels). Thus, the plant could maintain baseline SO2
removal performance with half the pumping power, although with a small increase in
fan power because of the tray pressure drop. For this case the tray retrofit costs were
estimated at $60,000 per absorber, for each of four absorbers.
In testing under high sulfur conditions (2000 ppm inlet SO2) at the EPRI Environmental
Control Technology Center (ECTC), a tray with a 38% open area was observed to
improve SO2 removal performance over that of an open spray tower by about 0.9 NTU
(96% vs. 90% removal). This was measured at an absorber gas velocity of 10 ft/sec (3.0
m/s) and an L/G of 110 (14.7). The pressure drop across the tray added about 1.6 in.
H2O (0.4 kPa) to the total absorber pressure drop at these conditions.
Similar testing of a relatively “open” packing at the ECTC showed an improvement of

about 0.3 NTU when adding a 2-ft (0.6 m) depth of packing. This result was measured
at the same inlet SO2 concentration of 2000 ppm and a gas velocity of 10 ft/sec (3.0
m/s), but at a lower L/G of 55 (7.3). The pressure drop for the packing at these
conditions was 0.9 in. H2O per foot of packing depth (0.74 kPa/m). The specific surface
area of this packing was reportedly 42 ft2/ft3 (138 m2/m3).
Example Economics
Previously in this section, example economics were provided for the cost effectiveness
of retrofitting a tray to allow operating an absorber at a lower L/G (Change Liquid to
Gas Ratio). That example is also relevant to this strategy. Another example is provided
here, for varying packing depth vs. using DBA as a performance additive. The cost
effectiveness calculations for this example are summarized in Table 3-11.
In this example, a utility is operating a 450-MW unit that fires a 3% sulfur bituminous
coal. The unit has a dual-loop, forced oxidized FGD system that currently achieves 93%
SO2 removal. The FGD system produces a gypsum byproduct that is sold to a local
wallboard company.
As part of their overall strategy for complying with Phase II of the 1990 Clean Air Act
Amendments, the utility is considering “overscrubbing” this unit. Two options are
being considered: performance additives (DBA) or adding an additional foot (0.3 m) of
packing depth to the absorbers.
Performance additives are evaluated in a series of short-term SO2 removal tests

followed by an additive consumption test. These results show that with a DBA
concentration of 250 ppm in the absorber upper loop slurry liquor, the overall SO2
removal performance can be increased by 5 percentage points. This results in the
3-57
Table 3-11
Example Economics: Cost-Effectiveness of Varying Packing Depth
Plant Specifics With DBA Addition
450 MW (415 MW average) 250 ppm DBA in upper loop will result in 98% SO2
removal
3% Sulfur coal An extra 3750 tons SO2 removed each year
93% SO2 removal $233,000 per year for extra SO 2 removal
Wallboard grade gypsum, $1.20/ton With Tray Installed
4 Dual loop scrubbers A third foot of packing will result in 98.5% SO 2

removed
8000 Operating hours per year An extra 4100 tons SO2 removed each year
69,500 Tons SO2 removed per year $17,000/ft/absorber annual cost of packing
$0.05/kWh Internal energy cost $66,000 in extra fan power cost per year
99% Limestone utilization
$8.00/ton prepared limestone
A. SO2 Removal Rate (ton/yr) = (Avg. Unit Load)*(Oper. Hrs)*(Heat Rate)*(Sulfur Content)*(SO2 Removal)
= (415 MW)*(8000 hr/yr)*(9000 Btu/kWhr)*(3.0%S/100)*(93% SO2 Rem./100)

B. Extra Limestone Cost ($/yr) = (Tons SO2 removed per year)*(100 tons L.S./64 tons SO2)*(Price)
= (4,100 tons/yr) * (100/64) * ($8.00/ton) = $53,000/yr

(0.99) * (0.975)
C. Packing Annual Cost ($/yr) = (Number of Absorbers) * (Cost per Absorber)
= 4 * ($17,000) = $68,000/yr
D. Increased Gypsum Revenues = (Extra SO2 Removed per Year)*(172 tons Gypsum/64 tons SO2)*(Price)
($/yr)
= (4100 tons/yr)*(172/64)*($1.20/ton) = $13,000/yr
E. Annual Inc. Operating Costs = (Fan Power Cost) + (Packing Cost) + (Limestone Cost) - (Gypsum Revenues)
($/yr)
3-58
= ($66,000/yr) + ($68,000/yr) + ($53,000/yr) - ($13,000/yr)
= $174,000/yr
F. Cost per Extra Ton SO2 ($/ton) = (Annual Operating Cost)/(Tons Additional SO2 Removed)
= ($174,000) / (4,100 tons) = $42/ton
3-59
removal of an additional 3750 tons (3400 metric tons) of SO2 annually. The costs for the
DBA addition (DBA purchase plus capital costs for the feed system) are estimated at
$233,000 annually. The costs for the additional limestone consumed amount to almost
$49,000 per year, and revenues from additional gypsum sales are estimated at $12,000.
The total cost for removing these additional 3750 tons (3400 metric tons) of SO2 with
DBA is estimated at $270,000, which is equivalent to $62 per additional ton of SO2
removed. As an alternate strategy, the plant tests one module with a third foot (0.3 m)
of packing in the upper loop of the absorber. With no DBA in the system, the SO2
removal for this module is observed to improve to 98.5% from the baseline of 93%. If all
of the modules were converted, an additional 4100 tons/yr (3700 metric tons) of SO2
would be removed.
The costs for achieving this additional SO2 removal include the cost of the packing, the
increased fan power to overcome the additional pressure drop, the increased reagent
cost, and the net byproduct cost. The plant replaces the packing every year, and they
estimate the purchase and installation cost to add an additional foot of packing at
$17,000 for each of four absorbers. The absorber pressure drop was observed to increase
by 1 in. H2O with the additional foot (0.8 kPa/m) of packing. The utility uses
$0.05/kWh as an internal power cost, so the additional fan power cost totals $66,000
annually.
The plant calculates the cost of their prepared limestone slurry at $8.00 per ton (dry
basis). Because of the dual loop design, the overall limestone utilization is very high
(99%). To remove an additional 4100 tons (3700 metric tons) of SO2 per year, the
limestone usage will increase by approximately 6700 tons (6100 metric tons), at a
prepared cost of $53,000.
The gypsum byproduct is sold to a local gypsum plant. After considering O&M costs to
dewater, wash, and load the gypsum, the plant realizes a net revenue of $1.20 per ton
of gypsum. The additional 4100 tons (3700 metric tons) of SO2 removed will produce an
additional 11,000 tons (10,000 metric tons) of gypsum, producing a net revenue of
$13,000 annually.
The net cost for removing this additional 4100 tons/yr (3700 metric tons) of SO 2 by
adding packing is, therefore, $174,000 per year, which is equivalent to $42 per ton of
SO2 removed. Therefore, adding another foot (0.3 m) of packing appears to be more cost
effective as an overscrubbing option than using DBA as a performance additive.
However, the additional foot (0.3 m) of packing raises some concern by the plant O&M
personnel about an increased potential for scaling in the absorber. It would be
advisable for the plant to operate the test absorber with additional packing for an
extended period of time (e.g., three months to a year) to observe scaling tendencies
before proceeding with this conversion on all four absorbers.
3-60
Convert to Forced Oxidation Operation
In this strategy, an FGD system that is currently operating in an inhibited or natural

oxidation mode is converted to operate in a forced oxidation mode and produce a
gypsum byproduct. The gypsum byproduct can either be stacked on or near the plant
site, or sold to a wallboard manufacturer as a synthetic feed stock.
The conversion will require the retrofit of air compressors, piping, and sparge rings in
the FGD absorber reaction tanks. The byproduct dewatering system may need to be
revised also, as the gypsum byproduct typically settles at a faster rate than do sulfite
solids. In some cases the existing thickener will be grossly oversized for the gypsum
application. Many forced oxidation systems use hydroclones instead of thickeners for
primary dewatering. Also, the dewatered filter cake will likely need to be washed to
remove chlorides. If the existing secondary dewatering device (e.g., centrifuge or filter)
cannot be modified to allow washing the cake, a new device may be required.
There are several potential benefits from this conversion, including:
x The potential for gypsum scaling is generally reduced in forced oxidation systems.
At high oxidation percentages, there is a large surface area of gypsum crystals
present in the recirculating slurry solids, promoting continued crystal growth rather
than scaling on absorber internals.
x The byproduct can either be sold as a feedstock to a wallboard manufacturer, or can

be dewatered and stored very cost effectively in a gypsum stack.
x The large gypsum crystals dewater very effectively, so dewatering equipment that
performs marginally in a natural or inhibited oxidation mode will probably perform
well in forced oxidation service, if it is retained in the forced oxidation conversion.
However, because of the oxidation that occurs in the reaction tank, liquid-phase sulfite
concentrations are low. Sulfite is an alkaline species with respect to SO2 removal. Also,
because of gypsum purity specifications, the FGD system typically has to operate at low
reagent ratios (low excess limestone levels) in the recycle slurry, so there is a reduced
opportunity for limestone dissolution across the absorber. These two effects result in
reduced alkalinity in the recycle slurry droplets, and can limit SO2 removal
performance when converting to forced oxidation. Consequently, unless the original
system design provided the capability for operating at a high L/G, forced oxidation
conversions typically have to use performance additives such as DBA or formate.
3-61
Determining the Cost Effectiveness of a Forced Oxidation Conversion
The conversion of an existing inhibited or natural oxidation FGD system to forced

oxidation is almost always driven by byproduct economics. Typically, the conversion
will allow the utility to avoid building a new landfill when their existing landfill is
nearing its design capacity, and/or will allow them to sell the gypsum byproduct if
there is a nearby market. Even if there is not a wallboard plant near the FGD system,
the utility may be able to develop a strategic relationship with a wallboard
manufacturer that will build a grass roots plant nearby. This will be very dependent on
the location of the power plant relative to the demand for wallboard. A gypsum
production rate of about 500,000 tons/yr (450,000 metric tons) is usually required to
justify a grass roots wallboard facility. That amount is approximately produced by
1,000 MW of base-loaded capacity firing a 3 wt% sulfur coal.
Without a market for the gypsum, the economics of a forced oxidation conversion are
rarely attractive. An exception might be a plant that is running out of landfill space,
where the estimated cost of a replacement facility is very high. In such a case the more
compact land area requirements for a gypsum stack could drive the economics for a
conversion.
Example Economics
Example economics for a forced oxidation conversion project are summarized in Table
3-12. In this example, a utility operates a 500-MW power plant that fires a 3.5 wt%
sulfur coal. The plant has a limestone FGD system that operates in an inhibited
oxidation mode. The overall SO2 removal averages 90%, and the limestone utilization
typically averages 85%. The cost of prepared limestone reagent is about $12 per ton
(dry basis).
The FGD system removes about 100,000 tons (91,000 metric tons) of SO2 per year, and
generates about 232,000 tons (210,000 metric tons) of calcium sulfite byproduct solids.
The byproduct dewaters to about 65 wt% solids, so approximately 357,000 tons (324,000
metric tons) of byproduct sludge are produced.
The on-site sludge disposal landfill is nearing its capacity. The plant has completed an
initial design for a replacement landfill. The projected average cost for treating and
disposing of the FGD byproduct sludge in the new landfill is $10 per ton (wet basis).
Therefore, the projected cost for byproduct disposal is $3.57 million annually.
The plant is considering a gypsum conversion as an alternative to building this new

landfill. An engineering study determined that the capital cost for the conversion
would be $15 million. Using a capital recovery factor of 0.17, the annual cost for this
capital investment would be $2.55 million.
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Table 3-12
Example Economics: Cost-Effectiveness of Forced Oxidation Conversion
Plant Specifics With Inhibited Oxidation
3.5% Sulfur coal 65 wt% byproduct sludge
90% SO2 removal efficiency $10/ton disposal cost, $30,000/yr sulfur

emulsion cost
100,000 tons SO2 removed per year With Forced Oxidation
Prepared limestone cost of $12/ton 95% limestone utilization
Internal power cost of $0.02/kWh $15 Million for capital costs of conversion
$2.00/ton revenues for gypsum byproduct
11 lb/ton SO2 DBA consumption rate
$0.30/lb DBA delivered

B. Current Byproduct Rate = (Tons SO2 Increased/yr)/(SO2 M.W.) * [Prod. M.W. + Limestone M.W.*(1-Utilization)]
= (100,000 tons/yr)/64 * (133.5 + 100*(1-0.85)) = 357,000 tons/yr

(65 wt%/100)
C. Current Disposal Cost ($/yr) = (Byproduct Rate) * (Disposal Cost)
= (357,000 tons/yr) * ($10/ton) = $3.57 Million/yr
D. Annualized F.O. Capital Cost = (Forced Ox. Conversion Capital Cost) * (Capital Recovery Factor)
($/yr)
= ($15,000,000) * (0.17) = $2.55 Million/yr
E. Gypsum Revenues ($/yr) = (Tons SO2 Removed per Year)*(172 tons Gypsum/64 tons SO2)*(Price)
(Gypsum Purity/100)
= (100,000 tons/yr)*(172/64)*($2.00/ton) = $566,000/yr

(95%/100)
3-63
F. DBA Additive Cost ($/yr) = (Tons SO2 removed/yr) * (Additive consumption rate) * (Delivered price)
= (100,000 tons/yr) * (11 lb/ton) * ($0.30/lb) = $330,000 /yr
G. Compressor Power Cost ($) = (Power Consumption Rate) * (Operating Hours) * (Power Cost)
= (2400 kW)*(8400 hr/yr)*($0.02/kWhr) = $400,000/yr
H. Current Limestone Usage = (Tons SO2 removed per year) * (100 tons L.S./64 tons SO2)
= (100,000 tons/yr) * (100/64) = 189,500 ton/yr

(0.85) * (0.97)
I. F.O. Limestone Usage (ton/yr) = (100,000 tons/yr) * (100/64) = 169,500 ton/yr

(0.95) * (0.97)
J. Limestone Savings ($/yr) = [(Current Limestone Usage) - (Spare Mod. L.S. Usage)] * (Prepared price)
= [(189,500 ton) - (169,500 ton)] * ($12/ton) = $240,000 /yr
K. Annual Operating Costs ($/yr) = (Capital) - (Gypsum Sales) + (DBA Cost) + (Power incr.) - (Sulfur Savings) - (L.S. Savings)
= ($2,550,000/yr) -($566,000/yr) + ($330,000/yr) + ($400,000/yr) - ($30,000/yr) - ($240,000/yr)
= $2,444,000/yr
L. Simple Payback Period (yr) = (Capital Cost)/(Current Cost - F.O. Cost without Capital Recovery)
= ($15 Million)/($3.57 Million/yr + $0.106 Million/yr) = 4.1 yr
3-64
The forced oxidation conversion would allow the plant to produce approximately
283,000 tons (257,000 metric tons) of gypsum. There is a market for this gypsum at $2.00
per ton F.O.B. the power plant, so that the annual value of this byproduct is $566,000.
The limestone/forced oxidation system will have two additional expenses: DBA
additive and forced oxidation compressor power. The DBA additive consumption rate
is estimated at 11 lb/ton of SO2 removed (5.5 kg/metric ton removed). At a delivered
cost of $0.30/lb, this represents an annual expense of $330,000.
The design for the conversion calls for 2400 kilowatts for forced oxidation compressor
power at average load conditions. For 8400 hours of operation each year and an
internal power cost of $0.02/kWh, this corresponds to an annual cost of $400,000 for
compressor power.
There will also be a small savings in limestone costs, due to improved limestone
utilization expected under the operating conditions for the forced oxidation design.
This design calls for a lower pH set point to allow the limestone utilization to improve
to 95%, from the current 85% utilization, to meet gypsum purity specifications. The
DBA performance additive will be used to restore SO 2 removal performance at the low
reagent ratio operation. This improvement in utilization will decrease limestone
consumption by about 20,000 tons/yr (18,000 metric tons). At a cost of $12 per ton of
prepared reagent (dry basis), the equivalent annual savings is estimated at $240,000.
Finally, the current annual expense of $30,000 for the sulfur emulsion additive will be
eliminated.
If the plant completes the forced oxidation conversion, the expected waste disposal
expense of $3.57 million will be avoided. The costs projected for the forced oxidation
conversion are as follows:
Forced oxidation conversion capital recovery $2,550K
Gypsum sales ($566K)
DBA additive $330K
Compressor power $400K
Eliminate sulfur additive ($30K)
Reduced limestone consumption ($240K)
NET ANNUAL COST $2,444K
3-65
This option shows annual expenses that are about $1.1 million less than if the plant
continues in the current inhibited oxidation mode of operation and builds a new
landfill ($2.44 million vs. $3.57 million). An alternate way to look at these economics is
that the actual payback for the conversion capital expense would be less than the 10
years on which the capital recovery factor was based. The simple payback period is 4.1
years.
Install Pump Suction Screens
Some FGD systems are adversely affected by having slurry nozzles plugged by small
pieces of tramp material. This tramp material is usually small pieces of plastic packing
or mist eliminator plates, or pieces of scale that fall into the absorber reaction tank. This
tramp material is then recirculated to the absorber by the recycle pump. If the material
is larger than the minimum free passage diameter of the spray nozzles, it will lodge in
a nozzle and plug it.
In these systems, absorber performance gradually degrades as more nozzles become

plugged and ultimately the absorber must be taken off line for cleaning. In packed
absorbers, having a number of plugged nozzles in one area can lead to low slurry flow
rates through that portion of the packing, and cause plugging and scaling of the
packing.
The cleaning effort is often tedious, as the absorber usually must be scaffolded to allow
personnel access to every nozzle, and the nozzles must be removed and replaced one
by one to ensure that the slurry passages are clear.
Many utilities have installed strainers to prevent large solids particles from plugging
nozzles or even damaging pump liners. In-line strainers are not feasible because they
would get plugged too quickly. Instead, the most common solution is to install a screen
in the tank over the area around the suction nozzle. Figure 3-2 is a simple drawing of
this type of suction screen. The screen can either be flat as shown in the illustration, or
built like a “cage” around the pump suction opening. It can be made of heavy-duty
wire mesh, expanded metal, or perforated plate. The screen opening should be smaller
than the spray nozzle free passage. The total open area on the screen should be
relatively large (e.g., equivalent to several times the pump suction line cross-sectional
area) to avoid blinding the screen and starving the pump suction. The screen design
typically includes structural reinforcements welded to the tank floor and side walls.
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Screen
Inside
of Tank To Pump
Figure 3-2
Pump Suction Screen
Determining the Cost Effectiveness of Installing Pump Suction Screens
The need for installing pump suction screens will be dependent on the plant’s
experience with plugged nozzles. One Western utility with FGD installed on about 400
MW of generating capacity reports that they currently have to bring each FGD absorber
off line several times a year to clean plugged and/or scaled packing, mist eliminators,
and nozzles. At each cleaning, they report that 15 to 20 nozzles out of 90 in each
absorber are typically plugged with tramp material. This FGD system is a good
candidate for installing pump suction screens.
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Example Economics
In the example provided above, the cost of installing pump suction screens for a total of
fourteen absorber slurry recycle pumps was estimated at $40,000. In this case the plant
operates with a relatively open water loop, so chloride levels are not high and the
screens could be made from type 316L stainless steel. In a system with higher chloride
levels, the screens may have to be constructed of a higher alloy with a correspondingly
higher cost.
In this example case, the utility reports that they spend an average of $180,000 per year
cleaning absorber packing, mist eliminators, and nozzles. Pump suction screens are
being considered as part of a comprehensive strategy for eliminating packing and mist
eliminator scaling and plugging, so it is difficult to assign a cost effectiveness value to
this retrofit alone. However, it is likely that adding the pump suction screens alone
could effect a 20% savings in the annual cleanup costs. This expected reduction would
be through greatly reducing the number of plugged nozzles that have to be cleaned and
by helping avoid scaling and plugging in the packing that is now caused by areas of
low slurry recirculation rates. If this assumption is valid, the payback period for
installing pump suction screens would be just over a year.
Change Reagent Type
Some FGD systems may lower their overall costs by considering a change in reagent
type (i.e., lime to limestone or vice versa). Other changes in reagent type might also be
considered, such as from dual alkali or from regenerable processes like Mg-Ox or
Wellman-Lord. However, there are few remaining installations of these systems in the
U.S., so these conversions will not be discussed here.
There are often substantial conversion costs involved in reagent type changes, usually
involving major changes to reagent handling and preparation equipment. Changes to
the absorber and/or the byproduct dewatering systems may also be required. Reagent
type switches usually require detailed engineering studies and cost estimates to
determine their cost effectiveness. However, the factors to consider and example
economics are presented here.
An overview of the lime vs. limestone FGD technologies must be presented before
discussing the rationale for considering a reagent switch. This discussion focuses on
medium- to high-sulfur-coal applications, where magnesium-enhanced lime is the
predominant lime technology.
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Magnesium-enhanced lime (Mg-lime) systems typically have high liquid-phase

alkalinity in the recirculating slurry. This allows high SO 2 removals to be achieved with
relatively low L/G values (usually less than 50) even in high-sulfur-coal applications.
This also results in a low pH drop as the slurry circulates through the absorber. The
lower L/G and lower pH drop typically lowers sulfite oxidation percentages relative to
a similar limestone reagent system.
The Mg-lime reagent is generally more expensive on a delivered, molar basis than
limestone. However, lime slurry preparation equipment (lime slaker) is typically less
expensive to build, maintain and operate than limestone grinding mills, and lime
utilization values are generally very high (e.g., 98%).
The byproduct from Mg-lime systems is a calcium sulfite sludge. This sludge typically
dewaters less effectively than the byproduct from a limestone reagent system.
Technologies exist to oxidize the byproduct from Mg-lime systems to produce saleable
gypsum or other byproducts, but these technologies have not yet been widely applied
commercially. A benefit of the higher water content of the sulfite sludge produced is
that chloride levels are typically lower than in limestone systems.
In general, Mg-lime reagent systems can enjoy lower capital costs (shorter absorber,
fewer recycle pumps, less expensive reagent preparation system, less expensive
materials of construction due to lower chloride levels) and perhaps lower maintenance
costs (reduced tendencies for gypsum scaling, lower chloride levels) relative to
limestone reagent systems. However, the FGD survey results presented in Appendix A
do not show lower maintenance costs for Mg-lime systems than the most recently built
limestone systems. Mg-lime systems typically experience higher reagent and byproduct
disposal costs than limestone systems.
By comparison, limestone systems generally require higher L/G values to achieve a

similar SO2 removal percentage, which requires taller absorbers and more recycle
pumps with associated piping and nozzles, and a more expensive reagent grinding
system. Limestone systems typically have to either use a sulfur additive to inhibit
sulfite oxidation, or force oxidize to produce gypsum. However, the sulfite sludge
produced from an inhibited oxidation system typically dewaters more effectively than
that from a Mg-lime system. The gypsum produced from forced oxidized systems can
often be sold to a wallboard manufacturer rather than incurring a disposal cost.
Determine the Cost Effectiveness of a Reagent Type Change
Some low-sulfur-coal FGD systems in the Western U.S. have considered changing from
limestone to lime reagent just on the basis of the delivered cost of the two reagents.
Lime has a lower molecular weight than limestone (56.1 vs. 100.1) and thus can incur
lower shipping costs per mole of reagent. However, this discussion focuses on
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medium- to high-sulfur coal applications that are considering Mg-lime versus

limestone reagent.
Utilities with existing limestone FGD systems that are considering conversion to Mg-
lime reagent typically have earlier systems that operate in a natural or inhibited
oxidation mode, and that currently incur relatively high O&M costs. A conversion to
Mg-lime reagent offers the possibility of increased SO2 removal performance (which
can be desirable as a compliance strategy for the 1990 Clean Air Act Amendments),
lower recycle pump power consumption, reduced gypsum scaling tendencies, lower
chloride levels, and a corresponding decrease in maintenance labor and materials costs.
O&M costs for reagent purchase and for byproduct disposal will likely increase.
The capital expenditures for the conversion will at a minimum include revisions to the
reagent preparation system. The reagent handling system may need revisions, as the
lime reagent must be kept dry during shipping and handling. The existing ball mill
grinding circuits must be replaced with lime slaking equipment. This may involve
converting the ball mills to slaking service, or replacement with simpler detention-type
slakers. Revisions to absorber piping and upgrades to byproduct dewatering
equipment may also be required.
Plants that are looking for strategies for reducing maintenance costs might consider a
conversion from limestone to Mg-lime. However, they should also consider other cost
savings strategies described elsewhere in this section. The results of the FGD survey
discussed in Appendix B show that the current generation of limestone FGD systems,
particularly those installed to comply with Phase I of the 1990 Clean Air Act
Amendments, realize low maintenance costs. While some of this may be due to the fact
that their equipment is all new, much can be attributed to system designs that take
advantage of lessons learned in 25+ years of design and operation of limestone FGD
systems. Much of the know-how developed from these lessons learned is discussed in
this section.
Mg-lime systems considering a change to limestone reagent would most likely be

considering this in concert with a change to forced oxidation to produce a saleable
gypsum byproduct. The economic drivers for this change would be reduced reagent
cost, and turning a byproduct sludge disposal expense into a gypsum byproduct
revenue stream. Also, most Mg-lime systems mix their FGD byproduct with their fly
ash, which is not done in gypsum-producing systems. With a limestone conversion it
may be possible to generate a new revenue stream from fly ash sales as well.
Systems designed for Mg-lime operation typically were designed with a low L/G and a
relatively short absorber vessel. It is usually necessary to use performance additives
such as DBA or formate to maintain SO2 removal performance when converting to
limestone. Thus an additive feed system must be installed, and the FGD system will
incur an ongoing expense for additive purchase. Also, the absorber materials of
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construction must be suitable for chloride concentrations that could be several times
higher than those in the current, Mg-lime operation.
It is not always necessary to retrofit limestone grinding equipment when making this
conversion. In some cases a source of ground limestone is available, and the required
conversion costs for existing lime handling equipment are not extensive. In other cases,
though, limestone grinding equipment must be installed, and will represent a
significant capital expense. Alternatively, some FGD systems purchase pre-ground
limestone, thus avoiding ball mills. However, powdered stone is much more expensive
than rock.
The existing byproduct dewatering system may not be well suited to gypsum
production. Thickeners for Mg-lime systems are sized for solids that settle at
approximately 1/10th or less of the rate of gypsum solids, and thus are grossly
oversized for gypsum service. Such thickeners can tend to plug or experience rake
failures. In some cases existing thickeners would be replaced with hydrocyclones for
primary dewatering. Secondary dewatering equipment (filters or centrifuges) in forced
oxidation systems typically have to include provisions for washing the dried filter cake
to remove chlorides and/or performance additives. Not all existing secondary
dewatering equipment will be adaptable for washing.
As mentioned above, the primary incentive for making a conversion from Mg-lime to
limestone/forced oxidation would be the ability to sell gypsum to a wallboard
manufacturer. This will require close proximity to an existing wallboard plant, or an
FGD system that is large enough and in a suitable market that a gypsum manufacturer
would commit to installing a grassroots plant. In either case, the wallboard
manufacturer may require pilot quantities of gypsum produced from the FGD system
before committing to purchase the material.
Plants considering either reagent change should first look at reagent purchase and
byproduct disposal costs, as these costs will drive the overall economics. For a Mg-lime
conversion of an existing natural- or inhibited-oxidation limestone system, the existing
delivered limestone cost will be known. The Mg-lime reagent is typically delivered for
a cost ranging from $40 to $60 per ton, so the increase in reagent cost can be estimated.
Waste disposal costs may also increase slightly; although reagent utilization will likely
be higher with the Mg-lime reagent, the moisture content of the byproduct sludge will
likely be greater. These reagent and potential byproduct disposal costs must be
weighed against the potential reduction in FGD system maintenance expense, if such
would be realized from this conversion, and reduced recycle pump and ball mill
power. Also, the capital costs for the conversion must be considered.
For conversion of existing Mg-lime systems to limestone/forced oxidation, the current

reagent and byproduct disposal costs should be known. Limestone typically costs $5.00
to $15.00 per ton on a delivered basis, depending on plant location, limestone purity
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and size. Gypsum byproduct selling prices range from break-even to a few dollars per
ton. Fly ash selling prices are typically in the same range. Costs for performance
additives can be estimated from the information presented in that portion of this
section. The capital costs for a limestone/forced oxidation conversion are typically in
the range of $20 to $50 per kilowatt of plant capacity.
Example Economics
Example economics for a reagent conversion project are illustrated in Table 3-13. In this
example, a 500-MW Midwest power plant fires a bituminous coal with a 3.5 wt% sulfur
content. The installed FGD system uses Mg-lime reagent, and achieves 95% SO2
removal. The plant removes about 100,000 tons (91,000 metric tons) of SO2 annually.
The Mg-lime reagent costs $45 per ton, delivered, and the calcium sulfite sludge costs
about $10 per wet ton for stabilization and disposal. The corresponding annual costs
are $4.0 million for lime reagent, and $3.4 million for waste stabilization and disposal.
The conversion to limestone/forced oxidation would be an extensive capital project,

because a limestone grinding circuit will have to be added as well as new horizontal
belt filter (the existing horizontal-shaft centrifuges cannot be adapted to wash the cake).
The plant has a budgetary estimate of $23.9 million for this conversion. The operating
costs for the limestone/forced oxidation system need to be compared to those of the
current system to determine whether this capital investment makes sense.
The limestone reagent consumption is estimated at 170,000 tons (154,000 metric tons)
annually. At a cost of $12 per ton of prepared reagent (dry basis), the equivalent annual
expense is $2.0 million. The FGD system will produce 283,000 tons (257,000 metric tons)
of gypsum each year. The gypsum can be sold to a nearby wallboard manufacturer.
Assuming a sales price of $2.00 per ton F.O.B. the power plant, the gypsum sales will
represent an annual credit of $566,000.
The limestone/forced oxidation system will have two additional expenses: DBA
additive and forced oxidation compressor power. The DBA additive consumption rate
is estimated at 11 lb/ton of SO2 removed (5.5 kg/metric ton removed). At a delivered
cost of $0.30/lb, this represents an annual expense of $330,000.
The design for the conversion calls for 2400 kilowatts for forced oxidation compressor
power at average load conditions. For 8400 hours of operation each year and an
internal power cost of $0.02/kWh, this corresponds to an annual cost of $400,000 for
compressor power.
The cost for reagent and byproduct disposal for the current Mg-lime system totals $7.4
million annually. With a limestone/forced oxidation conversion, the total estimated
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Table 3-13
Example Economics: Cost-Effectiveness of Switching Reagent
Plant Specifics With Current Lime Reagent
500 MW (480 MW average) Delivered lime cost of $45/ton
3.5% Sulfur coal Disposal cost of $10/ton
95% SO2 removal efficiency With Limestone Reagent
100,000 Tons SO2 removed per year Prepared limestone cost of $12/ton
$23.9 million for capital costs of conversion
$2.00/ton revenues for gypsum byproduct
11 lb/ton SO2 DBA consumption rate
$0.30/lb DBA delivered
A. SO2 Removal Rate (ton/yr) = (Avg. Unit Load)*(Operating Hours)*(Heat Rate)*(Sulfur Content)*(SO2 Removal)

B. Current Byproduct Rate = (Tons SO2 Increased/yr)/(SO2 M.W.) * (Product M.W.)

= (100,000 tons/yr)/64 * (131.4 lb/lb mole) = 340,000 tons/yr

(60 wt%/100)
C. Current Disposal Cost ($/yr) = (Byproduct Rate) * (Disposal Cost)
= (357,000 tons/yr) * ($10/ton) = $3.4 Million/yr
D. Current Lime Usage (ton/yr) = (Tons SO2 removed per year) * (56 tons Quick lime/64 tons SO2) * (Reagent Ratio)
(Lime Purity/100)
= (100,000 tons/yr) * (56/64) * (1.07) = 95,600 ton/yr

(97%/100)
E. Current Lime Costs ($/yr) = (Current Lime Usage) * (Delivered price)
= (95,600 ton/yr) * ($42/ton) = $4 Million/yr
F. Annualized Capital Costs = (Reagent Conversion Capital Cost) * (Capital Recovery Factor)
($/yr)
= ($23,900,000) * (0.17) = $4.1 Million/yr
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G. New Limestone Cost ($/yr) = (Tons SO 2 removed per year) * (100 tons L.S./64 tons SO2)*(Price)
= (100,000 tons/yr) * (100/64)*($12/ton) = $2.0 Million/yr

(0.95) * (0.97)
H. Gypsum Revenues ($/yr) = (Tons SO2 Removed per Year)*(172 tons Gypsum/64 tons SO2)*(Price)
(Gypsum Purity/100)
= (100,000 tons/yr)*(172/64)*($2.00/ton) = $566,000/yr

(95%/100)
I. DBA Additive Cost ($/yr) = (Tons SO2 removed/yr) * (Additive consumption rate) * (Delivered price)
= (100,000 tons/yr) * (11 lb/ton) * ($0.30/lb) = $330,000 /yr
J. Compressor Power Cost ($) = (Power Consumption Rate) * (Operating Hours) * (Power Cost)
= (2400 kW)*(8400 hr/yr)*($0.02/kWhr) = $400,000/yr
K. Annual Operating Savings = Disp. Cost + Lime Cost - Capital + Gypsum Sales - DBA Cost - Power Inc. - L.S. Cost
($/yr)
= $3.4M/yr + $4M/yr - $4.1 M/yr + $0.566M/yr - $0.33M/yr - $0.4M/yr - $2M/yr
= $1.1 Million/yr
L. Simple Payback Period (yr) = (Capital Cost)/(Annual Savings + without Capital Recovery)
= ($23.9 Million)/($1.1 Million/yr + $4.1 Million/yr) = 4.6 yr
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cost for limestone, gypsum sales credit, DBA additive, and compressor power is about
$2.2 million. However, the capital costs for this conversion are considerable. Using a
0.17 capital cost recovery factor, which corresponds to a ten-year payback, the capital
recovery expense is $4.1 million annually. Thus, the total expense for the
limestone/forced oxidation case is estimated at $6.3 million.
In this first look at the economics of the proposed conversion, it appears that the plant
could save a net of $1.1 million annually by making the conversion, or that the actual
payback period for this capital investment would be less than ten years. For this
relatively simple analysis, other O&M costs were not considered. Before proceeding
with this conversion, the plant should conduct an in-depth analysis of expected
changes in operating labor and maintenance labor and material requirements if the
conversion is completed. Also, this analysis assumed that all of the current byproduct
disposal cost of $10 per wet ton would be avoided with the gypsum conversion. If this
estimate includes fixed costs, such as land purchase or liner installation, these “sunk”
costs would not be avoided unless the current landfill is near the end of it life and the
plant would have to make new investments if the conversion were not completed.
Optimize Venturi Contactor 'P
Some FGD systems use venturi-style absorbers to effect both particulate and SO2
removal. Venturi absorbers are typically very compact, and have a relatively small
volume for gas/slurry contact. Often, SO2 removal performance is limited by the
amount of droplet surface area available for mass transfer within the absorber.
Sometimes it may be possible to improve SO2 removal performance by adjusting the

venturi throat to increase the pressure drop. This, in turn, generally forms smaller
slurry droplets and can improve SO2 removal performance.
Such an increase in venturi throat pressure drop will also increase the FGD system
pressure drop. However, many FGD systems with venturi absorbers are earlier systems
with centrifugal fans and dampers to control flue gas flow rate through the absorber. In
these systems, an increase in venturi pressure drop will generally cause the flue gas
flow rate control dampers to open wider, and no net increase in fan power requirement
results.
Thus, additional SO2 removal may be available for only the cost of the additional
reagent required and the additional byproduct produced. Alternately, it may be
possible to improve reagent utilization while maintaining the current level of SO2
removal by lowering the pH set point in the recirculating slurry.
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Conversely, in other FGD systems with venturi absorbers, SO2 removal performance
may be limited by other parameters, such as the amount of alkali available in the slurry
liquor and from reagent dissolution across the absorber. These systems may be able to
lower venturi pressure drop with little or no effect on SO2 removal performance. It will
depend on the fan type and flue gas flow controls as to whether any fan power savings
can be realized, though. Also, particulate control requirements may not allow any
reduction in venturi throat pressure drop, as lower pressure drop usually lowers
particulate control effectiveness.
Determining the Cost Effectiveness of Optimizing Venturi 'P
The ability to realize any improvement in system cost effectiveness will depend on
system specifics. If it is possible to monitor the SO2 removal performance of individual
absorber modules, it is relatively straightforward to conduct a parametric test of
absorber performance as the venturi pressure drop and recirculating slurry pH are
varied. Usually, both of these parameters are automatically controlled. A parametric
test can be conducted just by varying the set points of these two parameters according
to the test design, and measuring SO2 removal performance and reagent utilization
when the absorber reaches steady state performance after the changes (typically a few
hours).
The cost factors that are being optimized usually are fan power (depending on the fan
type and flow control configuration), reagent consumption, byproduct production rate,
and SO2 removal rate. The latter can have economic value when considering the
provisions of the Clean Air Act Amendments of 1990.
Example Economics
An Eastern utility operates a “first generation” FGD system at a 500-MW power plant
that fires a 2% sulfur bituminous coal. The FGD system uses venturi absorbers for SO2
removal and to “polish” the particulate control by a small ESP upstream. The reagent is
magnesium-enhanced lime.
The venturi pressure drop is set at 10 in. H 2O. The flue gas flow through each of five
absorbers (four operating) is controlled by a centrifugal booster fan with an upstream
control damper. To achieve the required SO2 removal performance (89% removal), the
pH set point for the FGD system is set relatively high, at 7.2. The corresponding lime
reagent utilization is 89%.
The plant conducts a parametric study of the effects of pH and venturi pressure drop
on SO2 removal and lime utilization on one of the four operating absorbers. The pH is
varied from 7.2 down to 6.5, and the venturi pressure drop is varied from 8 to 12 in.
H2O (2.0 to 3.0 kPa) in a 3 by 3 matrix. The study results indicate that SO2 removal
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compliance can be maintained at a lower pH set point of 6.8 if the venturi pressure
drop is raised to 12 in. H2O (3.0 kPa). This change improved the observed lime
utilization in that absorber to 93%. The flue gas flow rate through this absorber could
be maintained at the previous level at the higher pressure drop just by further opening
the control damper upstream of the booster fan.
Table 3-14 summarizes the calculations required to estimate the cost effectiveness of
this change in operating conditions. This is clearly a more cost-effective operating
mode, as there is no significant expense since the fan power requirement essentially
stays the same. There is, however, an obvious savings in lime consumption and waste
disposal cost. The FGD system currently removes about 49,000 tons/yr (44,500 metric
tons) of SO2. At 89% lime utilization, about 48,200 tons (43,700 metric tons) of lime
(CaO) are used annually. With an improvement in lime utilization to 93%, this lime
consumption would drop to about 46,200 tons/yr (41,900 metric tons/yr). The plant
pays $60/ton for lime, so this improvement in reagent utilization will save $120,000 per
year in lime costs. The quantity of sludge sent for disposal will be reduced as well. The
reduction in lime consumed (2000 tons or 1800 metric tons) will amount to 2640 tons
(2400 metric tons) of slaked lime (Ca(OH)2 vs. CaO). The byproduct sludge from this
FGD system dewaters to 50 wt% solids, so the byproduct sludge quantity should be
reduced by 5280 tons/yr (4790 metric tons) because of the improved reagent utilization.
The plant’s sludge disposal cost is $8.00 per ton (wet basis), so this reduction should be
worth $42,000 annually.
Thus, this optimization of the venturi absorber should save the utility $162,000
annually, with no capital expenditure required.
Add Polymers/Flocculents to Improve Dewatering Effectiveness
In some FGD systems that operate in an inhibited or natural oxidation mode, the
byproduct solids may not settle effectively in thickeners used as a primary dewatering
device. In these circumstances, the thickener overflow may contain a significant solids
content, and/or the underflow may have a low solids content. These symptoms could
have further adverse effects on the FGD system. For example, the thickener overflow
could not be blended with fresh water for use as ME wash water, and the low weight
percent solids in the thickener underflow could lead to higher moisture content in the
sludge sent to disposal.
Some FGD systems use flocculents to improve thickener performance. These flocculents
are added to the thickener feed, and typically cause the individual crystals to clump
together and settle as a loosely held mass. In some cases they improve the “flowability”
of the underflow solids, lessening the likelihood of stalled rakes or plugged underflow
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Table 3-14
Example Economics: Cost-Effectiveness of Increased Venturi Pressure Drop
Plant Specifics With Current Conditions
500 MW (440 MW average) 89% Lime utilization
2% sulfur coal pH set point 7.2
89% SO2 removal efficiency Venturi pressure drop of 10 in. H2O
49,000 Tons SO2 removed per year With Increased Pressure Drop
Delivered lime cost of $60/ton 93% Lime utilization
50 wt% byproduct solids pH set point of 6.8
Venturi pressure drop of 12 in. H2O

B. Current Lime Usage (ton/yr) = (Tons SO2 removed per year) * (56 tons Lime/64 tons SO2)
(Lime Utilization/100) * (Lime Purity/100)
= (49,000 tons/yr) * (56/64) = 48,200 ton/yr

(0.89) * (0.998)
C. Future Lime Usage (ton/yr) = (49,000 tons/yr) * (56/64) = 46,200 ton/yr

(0.93) * (0.998)
D. Lime Savings ($/yr) = [(Current Lime Usage) - (Future Lime Usage)] * (Delivered Price)
= [(48,200 ton) - (46,200 ton)]*($60/ton) = $120,000 /yr
E. Lime Disposal Savings = (Tons Lime Decrease) * (74 tons Slaked Lime/56 tons Quicklime) * (Disposal Cost)
= (48,200 - 46,200 ton/yr) * (74/56) * ($8/ton)/(50 wt%/100) = $42,000/yr
F. Annual Operating Savings = (Lime Savings) + (Disposal Savings)

($/yr)
= ($120,000) + ($42,000) = $162,000
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pump suction lines. They can also help keep the solids bed cohesive, improving the
solids content of the underflow.
Determine the Cost Effectiveness of Adding Flocculents
Flocculents are typically polymers that are purchased from water treatment companies
as a dry powder or in solution, at a cost ranging from less than $1.00 to $4.00 per
pound. They are typically added in ppm levels to the thickener feed slurry. The type of
flocculent and the dosage that is most effective is usually determined through
experimentation, although the vendor can usually make recommendations. The annual
costs for polymeric flocculents range for a 500-MW plant typically range from $3,000 to
$30,000, depending on type, dosage, and byproduct rates.
If these flocculents are effective at keeping the thickener overflow clear, reducing the
frequency of rake failures or thickener underflow line pluggage, and/or increasing the
sludge solids content from the secondary dewatering device, they can be very cost
effective. If they cannot be clearly linked to such benefits, they may represent an
unneeded operating expense.
Example Economics
A 500-MW plant fires a bituminous coal with a 2.5 wt% sulfur content. The plant
operates in an inhibited oxidation mode, and the sulfite oxidation percentage ranges
from 10% to nearly 15%. The blowdown slurry from the absorbers goes to a thickener
followed by a horizontal shaft centrifuge. The solids do not settle well, and the
thickener underflow solids content ranges from 40 wt% down to less than 20%. With
the thickener underflow solids content varying so widely, the centrifuge product solids
content varies from 60 to 65 wt%.
The plant tries polymer flocculent addition as a means of improving thickener

performance. After experimenting with several polymers, one appears to be most
effective. The calculations required to estimate the cost effectiveness of this polymer are
summarized in Table 3-15. At the dosage used, the annual polymer cost is estimated at
$12,000. With the addition of this flocculent, the thickener underflow solids content
becomes much more consistent, averaging 35 to 40 wt%. Correspondingly, the solids
content from the horizontal shaft centrifuges improves to 65 to 70%, an improvement of
about 5 percentage points.
The plant figures the cost of disposal of byproduct sludge at $5.00 per wet ton. The
annual byproduct solids production rate is approximately 160,000 tons/yr (145,000
metric tons). Increasing the average solids content of the byproduct sludge from 62.5 to
67.5% will decrease the wet sludge tonnage from 256,000 tons (232,000 metric tons) to
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Table 3-15
Example Economics: Cost-Effectiveness of Flocculant Addition
Plant Specifics With Current Conditions
500 MW (440 MW average) 32.5 wt% thickner underflow
2.5% Sulfur coal 62.5 wt% byproduct solids
Inhibited oxidation (10-15% Ox.) With Flocculant
160,000 Tons dry byproduct per year $12,000/yr flocculant cost
Delivered lime cost of $60/ton 37.5 wt% thickner underflow
50 wt% byproduct solids 67.5 wt% byproduct solids
A. Current Byproduct Rate = (Dry Byproduct Production Rate tons/yr)

= (160,000 tons/yr)/(62.5 wt%/100) = 256,000 tons/yr
B. New Byproduct Rate (tons/yr) = (160,000 tons/yr)/(67.5 wt%/100) = 237,000 tons/yr
C. Decrease in Disposal Cost ($) = (New Waste Sludge Rate - Present Rate) * ( Disposal Cost)
= (256,000 - 237,000 ton/yr) * ($5/ton) = $95,000/yr
D. Savings with Flocculant ($) = (Disposal Savings) - (Flocculant Cost)
= ($95,000/yr) - ($12,000/yr) = $73,000/yr
3-80
237,000 tons (215,000 metric tons), a reduction of 19,000 tons/yr (17,000 metric tons).
The savings associated with this improvement in solids content would thus be about
$95,000 per year. Thus, the polymer appears to be a very cost effective additive.
Upgrade Materials of Construction/Equipment Design to Increase Service

Life
Many FGD systems have equipment that continually requires repair or maintenance. In
some cases maintenance and repair costs could be greatly reduced by upgrading
materials of construction or other equipment design features. There are usually two
issues when considering making an upgrade as a means of reducing maintenance costs:
x How much will operating and maintenance costs really be reduced after the
upgrade is made?
x Do the savings meet my utility’s rate-of-return requirements when compared to the

capital investment to make the upgrade?
Probably any ongoing operating or maintenance headache in the FGD system should
occasionally be considered for a permanent fix. Often, the costs of continual
maintenance and repairs can justify investment in a long-term solution. Even if the
avoided annual maintenance costs do not provide what appears to be an attractive
payback for the capital investment in a long-term solution, other benefits may convince
utility management to proceed. These can include:
x Avoid the potential for future catastrophic failures.
x Avoid the potential for future unit derates.
x Reduce annual outage efforts.
x Free up existing staff to conduct other needed maintenance.
A number of utility FGD systems currently deal with ongoing problems that could cost
effectively be solved. Experience from other FGD systems provides a number of
examples of such solutions:
x Duct liners or coatings that require continual maintenance and repairs can be
replaced with a “wallpaper” of alloy lining.
3-81
x Undersized agitators can be replaced to avoid solids buildup in reaction tanks and
continual agitator repairs.
x Undersized or problematic thickeners can be replaced or supplemented with

hydroclones as a primary dewatering device.
x Eroding slurry piping can be replaced with abrasion-resistant piping.
x Plugging slurry nozzles can be replaced with more open nozzle styles.
x Problematic centrifuge dewatering devices can be replaced with drum or belt filters.
x Louver dampers can be replaced with guillotine isolation dampers to allow man-
safe entry into absorbers while the FGD system is on line.
x Problematic belt-drive recycle pumps can be replaced with direct-drive or gear-

drive pumps.
Example Economics
In this example, a 450-MW power plant has an FGD system that operates with bypass
reheat. The hot, SO2-laden flue gas mixes with treated flue gas before entering the stack.
The bypass mixing zone is a section of ductwork approximately 15 ft wide by 30 ft high
by 50 ft long (4.6 m wide by 9.1 m high by 15.2 m long). The duct is constructed of
carbon steel with a vinyl ester coating reinforced with glass flake. Over time, the lining
has begun to deteriorate and the plant typically replaces about 15% of the lining at each
of the unit’s annual scheduled outages. The plant wants to reduce the annual
maintenance costs and avoid a potential major failure of the duct.
Although flake glass resin is relatively inexpensive to install on clean metal, removing
and replacing the old coating is difficult and expensive. The utility’s experience has
shown that the total cost of replacing the flake glass coating is $100 per square ft. About
$60/ft2 of this cost is removal of the existing lining to a white metal blast, which is
required for installing the new lining.
Installing other types of corrosion-resistant materials would provide a more permanent

solution to the lining failures. For instance, many utilities have installed C-class alloy
(e.g., C-276) wallpaper in the outlet mixing zone. Wallpapering is the process of
installing thin (typically 1/16-inch or 1.6 mm) sheets of alloy on the carbon steel
ductwork. The sheets are overlapped and seal-welded to provide a continuous alloy
lining. The plant determined that a lining of C-276 can be installed for about $60/ft 2
($10/ft2 for materials and $50/ft2 for labor), including the cost of removing the old flake
glass coating (a white metal blast is not required for wallpapering).
3-82
In this case, the economics are favorable for a complete replacement of organic flake
glass coating with C-276 alloy wallpaper. The 30,000 ft 2 (2800 m2) of ductwork can be
wallpapered for $1.8 million, which provides a material that will need minimal routine
maintenance in the future. The plant would then avoid replacing the coating on 4500 ft2
(420 m2) of ductwork per year, at a cost of $450,000 annually. The simple payback is,
therefore, 4 years ($1.8 million/$450,000).
Alternately, consider the “present value” of the next 10 years of vinyl ester coating
repairs compared to the cost of relining the entire duct with C-276 now. Assuming a
10% cost of capital and a $450,000 annual cost (i.e., no escalation), the present value of
these future repairs is $2.8 million (a series present worth factor of 6.14 times $450,000).
Thus, the wallpaper lining repair has a present cost that is $1 million less than the
present value of continuing to repair the vinyl ester lining over the next ten years.
However, a more important benefit is that the ductwork lining has a ‘permanent’ fix
that will prevent a major failure that could result from corrosion of the carbon steel
substrate under the current scenario.
3-83
4
CASE STUDIES
This section includes three case studies that illustrate in greater detail the use of strategies
discussed in Section 3 to reduce FGD O&M costs. These case studies provide more
information about how to gather the data required to evaluate cost saving strategies for
specific FGD systems, and illustrate some of the tradeoffs involved in applying these
strategies.
The case studies involve the use of an organic acid performance additive, varying L/G
versus pH set point, and improving limestone fineness. Each of these is discussed in a
separate subsection below.
Case Study Number 1 - Using an Organic Acid Additive to Reduce Auxiliary

Power and Limestone Costs
General Approach
Organic acid additives (adipic acid, DBA, formic acid, or sodium formate) increase the
alkalinity of the slurry liquor that is recycled to the scrubber. This increased alkalinity
permits operation with less excess limestone (higher utilization) and/or fewer recycle
pumps. Operation at higher limestone utilization also produces less waste for disposal.
Depending on site-specific technical and economic factors, the cost of the organic additive
can be significantly less than the savings in limestone costs, waste disposal costs, and/or
power consumption. The example in Section 3 showed how to conduct a cursory evaluation
of the cost effectiveness of performance additives. However, additive performance and
costs are typically very system dependent. A short-term performance test using the additive
can be conducted to obtain the necessary data for estimating system-specific cost
effectiveness.
Important Considerations
Organic acid additives are not completely consumed in the FGD system. If the FGD system
has a permitted discharge ("open-loop operation"), the additive could potentially add
BOD/COD to the water being discharged. Under some conditions, the discharge might
have to be treated to remove the remaining organic acid.
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Organic acid additives may alter the size, shape, and dewatering properties of inhibited-
oxidation FGD byproduct solids. Significant increases in settling rate may be encountered
in tests with DBA or formate. Thickener operators should be alert for higher-than-normal
rake torque and should maintain lower-than-normal solids inventory in the thickener if
necessary to avoid potential operating problems.
Data Required
Technical Inputs:
x Flue Gas Mass Flow (lb/hr) - Calculated from CEM volumetric flow or from
combustion calculation.
x Average SO2 Removed (ton/year) - Calculated from fuel and emissions data.
x Recycle Pump Power (kW) - Measured directly or calculated as the product of

amps, volts, and power factor.
x Decrease in FGD System Pressure Drop with the Reduction in Number of Recycle
Pumps (inches W.C.) - Measured directly.
x Relationship Between Limestone Utilization and Slurry pH set point - Measured by

slurry analyses.
x Relationship Between Organic Acid Additive Concentration and Slurry pH (at

constant SO2 removal efficiency) - Estimated from published data, predicted using
EPRI’s FGD Process Integration and Simulation Model (FGDPRISM), or determined
by test (see below).
x Relationship Between Organic Acid Additive Concentration and Number of Recycle

Pumps (at constant SO2 removal efficiency) - Estimated from published data,
predicted using FGDPRISM, or determined by test (see below).
x Organic Acid Additive Consumption Rate (lb/ton SO2 removed) - Estimated from
published data, predicted using FGDPRISM, or determined by test (see below).
Economic Inputs:
x Auxiliary Power Cost ($/kWh).
x Limestone Cost ($/ton) - Calculated as the total marginal cost of limestone delivered
to the site and prepared as a finely ground slurry.
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x Waste Disposal Cost ($/ton) - Calculated as the total marginal cost of FGD waste
material placed in the landfill (or otherwise disposed), including all fixation costs.
x Organic Acid Additive Cost ($/dry lb) - Delivered price obtained by vendor
quotation.
x Capital Cost of Additive Storage/Delivery System - Estimated from published data.
x Annual Capital Recovery Factor - Calculated from assumed project life and cost of
capital.
Tests Required
Limestone Utilization versus Slurry pH
Figure 4-1 illustrates a typical performance curve showing the relationship between slurry
pH set point and limestone utilization in a wet limestone FGD system. At the lower end of
the pH operating range, utilization is not a strong function of pH. As the slurry pH
increases, the liquid becomes saturated with calcium carbonate and limestone utilization
begins to decrease rapidly with increasing pH. Limestone utilization at a given pH is also a
function of the amount of SO2 removed. Therefore, tests to quantify utilization versus pH
should be conducted at maximum load and with a relatively constant inlet SO2
concentration.
The tests can be run on a single module of the FGD system. For systems with several
operating modules, this allows testing at lower-than-normal pH and SO2 removal efficiency
while still maintaining emissions compliance for the overall system. For single-module
units, emissions compliance at lower-than-normal slurry pH can be maintained by
operating more recycle pumps. If the flue gas flow to an individual module can be
independently controlled, then the tests can be done regardless of fluctuations in boiler
load. Otherwise, the tests should be done during a period of sustained high-load operation.
A typical test sequence would include five successive days of operation at four decreasing
levels of pH set point (e.g., 5.8, 5.6, 5.4, 5.2). The pH set point would be selected each
morning and maintained overnight. The slurry in the test module reaction tank would be
sampled the following morning, and the pH set point changed to the next condition.
Solids from each slurry sample are analyzed to determine limestone utilization. There are
several options for analyses. Ideally, the slurry solids would be analyzed for calcium,
carbonate, and total sulfur (sulfite plus sulfate). Limestone utilization is calculated as:
Utilization (%) = (mmole/g CO3) / (mmole/g CO3 + mmole/g SOx) x 100
4-3
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100
95
90
Limestone Utilization (%)
85
80
75
70
Test Conditions
8250 scfm Gas Flow
65 2500 ppm Inlet SO2
140 mM Calcium
60 12% Slurry Solids
6000 gal Volume 132 gal/macf L/G
55 90% <325 Grind 66 gal/macf L/G
50
5.2 5.3 5.4 5.5 5.6 5.7 5.8
Absorber Feed Slurry pH
Source: Data collected at the EPRI ECTC.
Figure 4-1
Limestone Utilization Versus Absorber Feed Slurry pH as a Function of L/G
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or
Utilization (%) = (mmole/g CO3) / (mmole/g Ca) x 100
If the extent of sulfite oxidation and the amount of inert (non-carbonate, non-sulfite/sulfate)
material in the slurry are known, utilization can be estimated from the carbonate analyses
alone by estimating the mmole/g of SOx in the slurry as follows:
mmole/g SOx = [(1000 - mmole/g CO3) x (100 - mg/g inert)] / MW
where MW is the molecular weight of the sulfite/sulfate solid solution (MW typically = 130
mg/mmole) or gypsum (MW = 172 mg/mmole).
Number of Recycle Pumps and Slurry pH Versus Organic Acid Concentration
After the relationship between limestone utilization and slurry pH is defined, tests must be
conducted to determine what pH set point can be used with the organic acid additive.
These tests can be done with a single module if a means of measuring individual-module
SO2 removal efficiency is available. Alternately, the tests can be done on the entire FGD
system and the stack CEM can be used to determine efficiency if there is no gas bypass.
Single-module tests have the advantage of using less additive, and operating conditions can
more easily be monitored and controlled. However, accurate SO2 removal efficiency
measurements for a single module will probably require traversing the module outlet duct
using a sample probe and portable CEM.
Additive solution is delivered in 40,000 to 45,000 lb (18,000 to 20,000 kg) quantities in

heated [125 –135oF (52 - 57oC)], insulated tank trailers. DBA is typically supplied as a 50%
solution. Sodium formate is supplied as a 40% solution. The trailers are equipped with
o
internal heating coils with external connections. During cold-weather conditions [<40 F
o
(4 C)], the tanker may need to be supplied with a small quantity of hot water or steam to
keep the organic acid in solution. In warmer weather, the tanker will typically be emptied
before significant cooling occurs.
If more than one tanker will be needed during the test, the first tank trailer can remain on
site throughout the test, and additional additive can be off-loaded into the first tanker.
Additive can be pumped from the tanker, or the additive can be off-loaded by controlled
pressurization of the tanker using plant service air. Additive can be introduced to the entire
FGD system through the limestone slurry supply tank, process water return tank, or
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Case Studies
directly to individual reaction tanks. Test conditions can be reached more quickly by
adding directly to the reaction tanks.
Table 4-1 illustrates a typical test sequence, which would include operation at three
increasing levels (e.g., 200, 500, 1000 mg/L) of organic acid additive in the reaction tank(s)
slurry. The organic acid concentration is set by initially "spiking" the tank with sufficient
acid. The desired concentration is then maintained by adding acid continuously. At each
level of additive concentration, the slurry pH and number of recycle pumps are varied to
determine the required operating conditions for maintaining emissions compliance. After
overnight operation at each condition, the slurry is sampled to verify the limestone
utilization and extent of sulfite oxidation (for inhibited-oxidation systems).
Table 4-1
Typical Organic Acid Test Matrix
Day Organic Acid (mg/L) Number of Pumps Slurry pH
1 200 4 Adjust*
2 200 3 Adjust
3 500 4 Adjust
4 500 3 Adjust
5 1000 4 Adjust
6 1000 3 Adjust
7 1000 2 Adjust
*
Slurry pH adjusted to maintain compliance
Organic Acid Consumption Rate
The cost of using organic acid additive depends directly on the consumption rate. A portion
of the acid is lost with process liquid leaving the FGD system. This portion of the total
consumption rate is termed "solution loss", and can be calculated directly from the FGD
system material balance. The solution loss is typically less than half of the total
consumption rate. Additional acid is consumed by two mechanisms. In a forced-oxidation
process, the acid is oxidized to lower-molecular-weight components, CO2 and water. In an
inhibited-oxidation process, some acid is lost by oxidation, and some is incorporated into
the calcium sulfite byproduct solids. These other loss mechanisms are called "non-solution
losses." Both the solution and non-solution losses are proportional to the concentration of
additive in the slurry.
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For purposes of an economic evaluation, the consumption rate must be estimated or

measured by testing. A consumption test would typically be done immediately following
the performance tests described above, because a considerable amount of organic acid
additive is already present in the process liquid. The consumption test is conducted by
maintaining a constant concentration of additive in the FGD system for a period of seven to
ten days. During this period, the total amount of additive fed to the system is measured by
gauging the tank trailer level. The total amount of SO2 removal is also measured for the
consumption test period, so that the additive consumption rate can be expressed in terms of
pounds of additive/ton of SO2 removed (kg/metric ton removed).
In practice, the additive concentration in the FGD system might vary somewhat during the
consumption test. Therefore, in order to make an accurate calculation of the additive
consumption rate, it is also necessary to estimate the change in the total amount or
"inventory" of additive held within the FGD process liquid. That is, some portion of the
total additive fed to the system is not consumed, but remains in the system, so that the
consumption rate is calculated as follows for the consumption test period:
Additive Consumption = Additive Fed - Additive Inventory Change
The inventory change term is calculated by measuring and subtracting the amount of
additive in the system at the beginning of the test from the amount in the system at the end
of the test.
Table 4-2 shows example data from a sodium formate additive consumption test. Part A of
this table shows how the formate inventory in the FGD system was calculated at the
beginning and end of the consumption test by summing the products of the additive
concentration and liquid volume for each vessel in the FGD system. The organic acid
concentrations were measured using EPRI method S1 (Buffer Capacity Titration).(1) In this
example, the amount of formate (COOH, molecular weight 45) in the FGD system liquid at
the beginning of the test was 40,975 lb (18,586 kg) and at the end of the test was 37,870 lb
(17,178 kg). The difference in formate inventory for the test period was a decrease of 3105
lbs (1408 kg).
Part B of Table 4-2 shows how the formate consumption rate for the test was calculated.
Formate was added to the system from a tank trailer as 40% sodium formate solution
(NaCOOH, molecular weight 68, specific gravity 1.28). The initial tank level was 4103
gallons (15,532 liters). During the test, an additional 45,580 lb (20,675 kg) of 40% sodium
formate solution was off-loaded into the tank trailer. The final tank level was 5534 gallons
(20,948 liters). The total sodium formate solution added during the test was 45,580 lb (20,675
4-7
Table 4-2
Example Organic Acid Consumption Calculation
Part A - Calculating the Formate Inventory Change - Beginning of Test Data:
Tank Multiplier Tank Height Tank Tank Volume Formate in Slurry Specific Liquor Specific Solids in Formate in
Sample Location (gal/ft) (%) Height (ft) (gal) Liquid (mg/L) Gravity Gravity Slurry wt% Liquid (lb)
A Module 14420 100 24 346080 1050 1.109 1.012 15.1 2820
B Module 14420 100 24 346080 1140 1.094 1.012 12.9 3097
C Module 14420 100 24 346080 1080 1.082 1.012 11.2 2961
D Module 14420 100 24 346080 1200 1.132 1.012 18.3 3165
A Thickener 133000 10.5 1396500 710 1.012 1.012 0.0 8267
B Thickener 133000 11.2 1489600 1300 1.03 1.012 3.0 15945
LS Slurry Storage A 7200 90 28.8 207360 970 1.27 1.012 35.0 1367
LS Slurry Storage B 7200 64 20.5 147456 990 1.27 1.012 35.0 992
Underflow Storage A 6400 55 17.1 109120 1100 1.32 1.012 40.0 781
Underflow Storage B 6400 62 19.2 123008 1100 1.32 1.012 40.0 881
Supernate Tank 6790 9.5 64505 980 1.012 1.012 0.0 527
Filtrate Tank 1700 11.0 18700 1100 1.012 1.012 0.0 172
Total Formate in FGD Sysem Liquid (lbs) 40,975
4-8
Part A - Calculating the Formate Inventory Change - End of Test Data:

Tank Multiplier Tank Height Tank Tank Volume Formate in Slurry Specific Liquor Specific Solids in Formate in
Sample Location (gal/ft) (%) Height (ft) (gal) Liquid (mg/L) Gravity Gravity Slurry wt% Liquid (lb)
A Module 14420 100 24 346080 1045 1.094 1.012 12.9 2839
B Module 14420 100 24 346080 1100 1.11 1.012 15.2 2952
C Module 14420 100 24 346080 1070 1.073 1.012 9.8 2953
D Module 14420 100 24 346080 1250 1.104 1.012 14.4 3370
A Thickener 133000 10.5 1396500 850 1.012 1.012 0.0 9897
B Thickener 133000 11.2 1489600 900 1.03 1.012 3.0 11039
LS Slurry Storage A 7200 70 22.4 161280 990 1.27 1.012 35.0 1085
LS Slurry Storage B 7200 91 29.1 209664 990 1.27 1.012 35.0 1411
Underflow Storage A 6400 51 15.8 101184 1100 1.32 1.012 40.0 725
Underflow Storage B 6400 63 19.5 124992 1100 1.32 1.012 40.0 895
Supernate Tank 6790 9.5 64505 990 1.012 1.012 0.0 532
Filtrate Tank 1700 11.0 18700 1100 1.012 1.012 0.0 172
Total Formate in FGD Sysem Liquid (lbs) 37,870
Change in Formate Inventory (3,105)
4-9
Example Organic Acid Consumption Calculation
Part B - Calculating the Consumption Rate
Tanker Level at Beginning of Test (gal) 4,103
40% Sodium Formate in Tanker (lbs) 43,748
Tanker Level at End of Test (gal) 5,534
40% Sodium Formate in Tanker (lbs) 59,006
Additional 40% Sodium Formate Added to Tanker (lbs) 45,580
Formate Added to FGD System from Tanker (lbs) 8,027
Total Formate Consumed during Test, with inventory change (lbs) 11,132
Limestone used During Test (tons) 1,535
Average Limestone Utilization (%) 90
Tons SO2 Removed During Test (based on LS) 799
Tons SO2 Removed During Test (based on CEM) 824
Filter Cake Produced during Test (tons) 2,007
Average Cake Solids Content (%) 77
Formate Lost with Cake Liquid during Test (lbs) 1,007
Formate Solution Loss (lb/ton SO2) 1.2
Formate Non-Solution Loss (lb/ton SO2) 12.3
Total Formate Consumption (lb/ton SO2) 13.5
Total Sodium Formate Consumption (lb/ton SO2) 20.4
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kg) less the increase in the tank level of 1431 gallons (15,258 lbs or 6921 kg), or 30,322 lbs
(13,754 kg). The total formate consumption for this test period was equal to the amount
added from the tanker, which was 8026 lbs (3641 kg) (30,322 lbs 40% solution x 0.4 x 45 lb
formate/68 lb sodium formate), plus the decrease in inventory, 3105 lbs (1408 kg), for a
total of 11,132 lbs (5,049 kg).
The amount of SO2 removed during the test was calculated in two ways. The first method
was based on limestone use. Limestone consumption was measured as the difference in ball
mill feed belt-scale totalizer reading at the beginning and end of the test period plus any
difference in the limestone slurry tank inventory. A total of 1525 tons (1383 metric tons) of
limestone was used. The limestone contained 91% CaCO3, and the average limestone
utilization during the test was 90%. One mole of SO2 (MW = 64) reacts with one mole of
CaCO3 (MW = 100). Therefore the amount of SO2 removed based on limestone consumption
was calculated as:
SO2 removed = 1,525 tons x .91 ton CaCO3/ton x .9 x 64/100 = 799 tons (762 metric
tons)
The second method was to calculate SO2 removed directly from the amount of fuel fired,
the fuel sulfur analyses, and the stack CEM data for the test period. This method yielded a
value of 824 tons (748 metric tons) for SO2 removed. In this case, the two results
independently calculated results were close, as would be anticipated.
The total calculated formate and sodium formate consumption rates, expressed as lb/ton of
SO2 removed are shown on the last two lines of Table 2, Part B. The total consumption rate
expressed in pounds of formate ion was 11,132 lb (5049 kg) of formate per 824 tons (748
metric tons) SO2 removed or 13.5 lb/ton (6.8 kg/metric ton) of SO2 removed. This is equal to
20.4 lb of sodium formate per ton (10.2 kg/metric ton) of SO2 removed.
The solution loss component of the total formate consumption rate was also calculated.
The amount of filter cake produced during the test was measured by belt scale totalizer,
and the amount of formate lost with process liquid was calculated as the product of the
total filter cake production (2007 tons or 1821 metric tons), the average filter cake
moisture content (77%), and the average filtrate additive concentration (1100 mg/L) for
the test period. For this example, during which the FGD system was operated close-
loop with a relatively high (77%) solids content in the filter cake, the solution loss was
1015 lb (460 kg), or 1.2 lb formate/ton (0.6 kg/metric ton) of SO 2 removed. This
represents only 9% of the total formate additive consumption rate.
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Economic Evaluation
After the FGD system performance with organic acid additive has been defined, an
economic evaluation can be done to estimate potential operating cost savings. An example
evaluation is shown in Table 4-3. Technical and economic inputs are summarized at the top
of the table, and the cost calculations are shown below.
Current Operation
Potential savings are evaluated relative to the current operating conditions without the use
of organic acid additive. The example FGD system is operated with a relatively high
capacity factor of 85%, at an annual average load of 660 MW. The average SO2 removal rate
is 11.2 tons/hr (10.2 metric tons/hr). Annual cost calculations are based on 8000 hours per
year of operating time. The system currently is operated with four absorber modules, each
with four operating recycle pumps. The normal slurry pH set point is 5.6, which results in
an average limestone utilization of 85%. The required SO2 removal efficiency is 85%.
Option 1 - Operate Fewer Recycle Pumps
The first option evaluated is to maintain the same pH set point while adding sodium
formate to the FGD system. Based on the performance test results, the number of operating
recycle pumps/module can be reduced to two with 700 mg/L formate in the recycle slurry
or three with only 125 mg/L formate. The required organic acid feed rate for each of these
conditions was calculated based on the measured sodium formate consumption rate, which
for this system was 16.6 lb sodium formate/ton (8.3 kg/metric ton) of SO2 removed when
operating at full load with 1000 mg/L formate in the recycle liquid.
The sodium formate feed rate (e.g., 111 lb/hr (50.4 kg/hr) for 700 mg/L formate) is the
product of the measured consumption rate (at 1000 mg/L formate) and the SO2 removal
rate, adjusted in each case for the required formate concentration:
Sodium Formate Feed (lb/hr) = 11.2 tons/hr inlet SO2 x 85/100% removal
x 16.6 lb/ton removed x 700 mg/L/1000 mg/L
= 111 lb sodium formate/hr (50.4 kg/hr)
The cost for using sodium formate additive includes the annualized capital cost for the
additive storage and delivery system, plus the purchase cost of the additive. The capital
cost is based on capacity and is factored from a base installed cost of $300,000 for a 100
4-12
Table 4-3
Example Economic Evaluation for Sodium Formate Additive
Pumps/ Slurry Organic Acid Lbs SO2 Removal SO2 Removal Organic Acid Organic Acid Organic Acid Fan Power Pump Power Reagent Waste Disposal Total Savings
Options Module pH (mg/L) Utility (%) (ton/hr) Feed (lb/hr) Capital ($/yr) ($/yr) Savings ($/yr) Savings ($/yr) Savings ($/yr) Savings ($/yr) ($/yr)
Current operation 4 5.6 0 85 85.0 9.52 0 0 0 0 0 - 0 0
OPTION 1:
Operate with fewer 2 5.6 700 85 85.0 9.52 111 52,000 206,000 (19,000) (305,000) 0 0 (66,000
pumps at current
pH set point
3 5.6 125 85 85.0 9.52 20 40,000 37,000 (9,000) (152,000) 0 0 (84,000))
OPTION 2:
Operate with lower 3 5 600 92 85.0 9.52 95 51,000 176,000 (9,000) (152,000) (136,000) (82,000) (152,000)
pH set point
4 5 300 92 85.0 9.52 47 46,000 88,000 0 0 (136,000) (82,000) (84,000)
Notes: Additive rate and tons of SO2 are based on 11.2 tons SO2/hour entering the FGD system.
Pump power is based on 8000 hours/year operation. Fan power is based on 8000 hours/year at average load of 660 MW
All annual costs are evaluated relative to the base conditions.
Assumptions:
Capacity factor 0.85
Flue gas flow (average total @660 MW) 2,340,000 acfm
Cost of station service power $0.017 /kWh
Additive feed system capital costs @ 100 lb/hr $300,000
Organic acid cost $0.25 /dry lb delivered
Total organic acid loss rate at 1000 mg/L 16.6 lb/ton SO2 removed
Cost of prepared limestone $12.5 /ton delivered and ground
Calcium carbonate content in limestone 91 wt%
Cost of additional sludge produced $7.5 /ton
Change in flue gas delta P per spray pump 0.2 inches H 2O
Pump power 280 kW
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Case Studies
lb/hr (45 kg/hr) additive system, using an exponent of 0.15 (the capital cost is relatively
insensitive to the feed rate). The cost for a system to feed F lb/hr is equal to (F/100)0.15 x
$300,000. In this example, the capital cost is expressed as an annual cost [$52,000/yr for 111
lb/hr (50.4 kg/hr)] using a factor of 0.17, which is based on a capital recovery period of 10
years and annual interest rate of 11%.
The annual sodium formate purchase cost ($206,000) is calculated from the hourly feed rate,
the unit capacity factor, and the delivered price of the sodium formate:
Annual Additive Cost = 111 lb/hr x 24 hrs x 365 days x .85 x $0.25/lb = $206,000
Annual savings for this option include fan power and pump power. The fan power savings
is due to lower pressure drop across the FGD system when fewer recycle pumps are
operated. In this example, the total FGD system pressure drop is reduced by 0.2 inches of
water (0.05 kPa) for each recycle pump (per module) that is not operated. Note that this
power savings is small and would only be realized with variable-pitch or variable-speed
fans. There would be no power savings with a fixed-speed centrifugal fan controlled by
inlet vanes.
The annual pump power savings is calculated directly from pump power consumption
(280 kW for each pump in this example), the reduction in the number of pumps operating,
the number of operating hours in a year (8000 hrs), and the cost of auxiliary power
($0.017/kWhr):
Pump Power Savings = 2 Pumps x 4 Modules x 280 kW x 8000 hr/yr x
$0.017/kWhr
= $305,000
The net annual savings ($66,000/yr) for this option (700 mg/L formate, 2 recycle
pumps/module) is calculated by subtracting the total additive costs ($258,000/yr) from the
power savings ($324,000/yr). The table shows that operation with 125 mg/L formate and
three pumps/module yields a slightly greater savings of $84,000/yr.
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Option 2 - Operate at a Lower pH Set Point
In this option, the pH set point is decreased to 5.0 so that limestone utilization increases.
Increased limestone utilization also results in less waste for disposal. As shown in Table 4-3,
300 mg/L formate is required to maintain 85% SO2 removal at the lower pH set point with
four recycle pumps/module. With three pumps/module, 600 mg/L formate is needed.
For this option, the fan power and pump power savings (if applicable) are calculated as in
Option 1 above. The limestone savings is calculated according to the difference in the base
case limestone utilization (85%) and the utilization achieved at the lower pH set point
(92%):
Limestone Savings = SO2 Removed (ton/yr) x 100 lb CaCO3/64 lb SO2

x 1 lb Limestone/.91 lb CaCO3 x (1/.85 - 1/.92)
x $12.5/ton limestone
= $136,000/yr
Waste disposal savings are directly proportional to the limestone savings, because each ton
of limestone saved results in one less ton of sludge for disposal:
Waste Disposal Savings = $136,000/yr x $7.5/ton sludge/$12.5/ton limestone

= $82,000/yr
The resulting net savings (limestone savings + waste savings + power savings - formate
capital - sodium formate purchase cost) is $152,000/yr for operation with three recycle
pumps/module and $84,000/yr for operation with four recycle pumps/module.
Thus for this system it appears to be cost effective to use sodium formate as a
performance additive. Of the options considered, the most cost effective use of sodium
formate additive is to allow operation at lower pH to allow higher utilization while
simultaneously allowing operation with three rather than four recycle pumps per
absorber. These annual savings estimated for combining these two strategies ($152,000)
is greater than the estimated savings from either individually (both were estimated at
$84,000 annually).
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Case Studies
Case Study Number 2 - Optimizing Slurry pH Set Point and Number of

Recycle Pumps to Obtain Lowest Combined Auxiliary Power and Limestone
Costs
General Approach
Many FGD systems are required by region, state, or local regulations to achieve a fixed SO2
emissions limit (e.g., 1.2 lb SO2/million Btu or 0.575 g/J) and/or a fixed removal efficiency
(e.g., 90%). The FGD system must also respond to changes in inputs such as boiler load and
fuel sulfur content, which will affect removal efficiency. As the input conditions change,
FGD system operating conditions are controlled, either manually or automatically, to
maintain the required emissions rate.
The most common absorber design for wet limestone systems is the open spray tower with
multiple spray levels, each served by a dedicated recycle pump. With this type of FGD
system, operators can typically vary the number of operating recycle pumps and spray
header levels per module as required to achieve emissions compliance.
Sometimes, though, operating more pumps can permit operation with a lower pH set point
and increase limestone utilization. Operation at higher limestone utilization also produces
less waste for disposal. The most cost effective operating conditions are those that will meet
the emissions limit with the lowest combined cost for auxiliary power, limestone, and
waste disposal.
To determine the best operating conditions, a series of performance tests can be conducted
at different boiler loads to establish allowable combinations of number of recycle pumps
and slurry pH. Limestone utilization, fan power, and pump power are measured at each
condition, and the best operating conditions are selected by evaluating the total operating
costs for the different options. The results are expressed as guidelines for the FGD system
operators for selecting the pH set point and number of operating recycle pumps versus unit
load.
In addition to affecting limestone utilization and power consumption, changes in the

number of operating pumps and the slurry pH set point may change two other important
FGD system operating parameters: sulfite oxidation fraction, and mist eliminator scaling
tendency. Sulfite oxidation tendency increases with higher L/G (more recycle pumps
operating) and lower slurry pH. For inhibited-oxidation FGD systems where maintaining
subsaturated operation (< 15% sulfite oxidation) has been difficult, increasing the number
of operating recycle pumps may not be desirable. For systems where mist eliminator
scaling problems occur due to high reagent ratios/low limestone utilization, decreasing the
4-16
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number of operating recycle pumps (and, therefore, further decreasing limestone

utilization) also may not be desirable.
Data Required
Technical Inputs:
x Recycle Pump Power (kW) - Measured directly or calculated as the product of

amps, volts, and power factor.
x Relationship Between Number of Operating Pumps and Required Slurry pH (at

constant SO2 emissions rate or removal efficiency) - Determined by test (see below).
x Relationship Between Limestone Utilization and Slurry pH Set point - Measured by

slurry analyses.
x Fan power versus unit load and number of operating pumps (kW) - Measured
directly or calculated from flue gas volumetric flow rate and FGD system pressure
drop.
Economic Inputs:
x Auxiliary Power Cost ($/kWh)
x Limestone Cost ($/ton) - Calculated as the total marginal cost of limestone delivered
to the site and prepared by grinding.
x Waste Disposal Cost ($/ton dry sludge) - Calculated as the total marginal cost of
FGD waste sludge placed in the landfill (or otherwise disposed), including all
fixation costs.
Tests Required
Table 4-4 summarizes a typical test matrix for optimizing the number of recycle pumps.
Each test at a single operating condition can typically be conducted during a single shift.
The tests are conducted at three different boiler loads. The range of loads should be selected
to best represent the load profile for the unit being tested. For example, if a base-loaded unit
is rarely operated at 40% load, then tests at that condition may be deleted. The number of
operating recycle pumps must be selected based on experience so that compliance can be
maintained at a practical operating pH set point. Extended operation of the system at a
slurry pH that will result in very low limestone utilization (e.g., <75%) is not
recommended.
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Table 4-4
Typical Test Matrix for Optimizing the Number of Recycle Pumps Operating
Day Boiler Load Number of Pumps Slurry pH

*
1 100% 5 Adjust
2 100% 4 Adjust
3 100% 3 Adjust
4 70% 5 Adjust
5 70% 4 Adjust
6 70% 3 Adjust
7 40% 4 Adjust
8 40% 3 Adjust
9 40% 2 Adjust
*
Slurry pH is adjusted to maintain compliance.
When the boiler is operating at the desired test load, and the selected number of recycle
pumps are operating in each module, the slurry pH in each reaction tank is adjusted (all at
the same pH) until the SO2 emissions rate is just below the specified or desired level. The
FGD system is operated at these conditions for about 6 to 8 hours. The slurry in each
reaction tank is then sampled for chemical analyses to determine the limestone utilization.
Note that the slurry pH and limestone utilization required to maintain compliance are also
a function of the inlet SO2 concentration in the flue gas. Therefore, tests should be
conducted to the extent possible with a uniform, representative fuel quality. If fuel quality
is typically highly variable, a fuel supply from a single mine and seam should be procured
for use during the test period, if possible. This will simplify interpretation of test results.
Solids from each slurry sample are analyzed to determine limestone utilization. There are
several options for analyses. Ideally, the slurry solids would be analyzed for calcium,
carbonate, and total sulfur (sulfite plus sulfate). Limestone utilization is calculated as:
Utilization (%) = (mmole/g CO3) / (mmole/g CO3 + mmole/g SOx) x 100
or
Utilization (%) = (mmole/g CO3) / (mmole/g Ca) x 100
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Case Studies
If the extent of sulfite oxidation and the amount of inert (non-carbonate, non-sulfite/sulfate)
material in the slurry are known, limestone utilization can be estimated from the carbonate
analyses alone by estimating the mmole/g of SOx in the slurry as follows:
mmole/g SOx = (1000 - mmole/g CO3 x 100 - mg/g inert) / MW
where MW is the molecular weight of the sulfite/sulfate solid solution (MW typically = 130
mg/mmole) or gypsum (MW = 172 mg/mmole).
Economic Evaluation
Table 4-5 is a spreadsheet showing the example economic evaluation based on test results
from a 335 MW FGD system. This example FGD system has two scrubber modules, each
with four separate spray header levels served by individual recycle pumps, for a total of
eight recycle pumps. In this example, operating costs are calculated as hourly rates, since
different load conditions are being considered.
Input data used in the cost calculations are shown at the top of the table. The average fuel
sulfur content during the tests was 5.2 lb SO2/million Btu (2.5 g/J). The allowable SO2
emissions rate for the unit is 1.2 lb SO2/million Btu (0.575 g/J). The cost of auxiliary power
supplied to the FGD system for this example is $0.017/kWhr. Limestone is delivered to the
FGD system at a total cost of $18/ton. The limestone contains 91 wt% calcium carbonate
available for reaction with absorbed SO2. For this inhibited-oxidation system, with 10%
sulfite oxidation, the byproduct solids disposal cost is $7.50/ton of dry filter cake, and the
average molecular weight of sulfur species in the byproduct solids is 131 lb/mole (131 g/g-
mole).
The test data shown in the table were collected while the boiler/FGD system operated at
three different loads (335, 235, and 105 MW). In the first row of calculations, the boiler load
is 335 MW and the gross heat rate is 8570 Btu/kWh (9040 kJ/kWh). The FGD system was
operated with at an SO2 emissions rate of 1.15 lb SO2/million Btu (0.55 g/J), measured by
the stack CEM. To obtain this emissions rate with four recycle pumps operating per
module, a slurry pH set point of 5.4 was required. Under these conditions, the measured
limestone utilization was 95%. The measured fan power consumption was 2950 kW, and
the total measured pump power consumption was 3050 kW.
4-19
Table 4-5
Example Economic Evaluation for Optimizing Number of Recycle Pumps
Boiler Load Gross Heat SO2 Emissions Operating Slurry Limestone Util. Fan Power Pump Power SO2 Removed Fan Power Pump Power Limestone Limestone Byproduct Byproduct Total Cost
(Mw) Rate (Btu/kW) (lb/MM Btu) Pumps/Module pH (%) (kW) (kW) (ton/hr) ($/hr) ($/hr) (ton/hr) ($/hr) Disposal (ton/hr) Disposal ($/hr) ($/hr)
335 8,570 1.15 4 5.4 95 2,950 3,050 5.81 50 52 10.5 189 13.3 100 391
335 8,570 1.15 3 5.7 90 2,700 2,250 5.81 46 38 11.1 200 13.9 104 388
335 8,570 1.15 2 6.1 50 2,500 1,500 5.81 43 26 20.0 359 22.8 171 598
235 8,800 1.15 4 5.2 97 2,000 3,050 4.19 34 52 7.4 133 9.4 71 290
235 8,800 1.15 3 5.4 96 1,950 2,250 4.19 33 38 7.5 135 9.5 71 278
235 8,800 1.15 2 5.8 89 1,900 1,500 4.19 32 26 8.1 145 10.1 76 279
105 10,490 1.15 3 4.9 99 1,350 2,250 2.23 23 38 3.9 70 4.9 37 168
105 10,490 1.15 2 5.1 98 1,350 1,500 2.23 23 26 3.9 70 5.0 37 156
Input Data:
Fuel sulfur content 5.2 lb SO2/MM Btu
Allowable SO2 emissions rate 1.2 lb SO2/MM Btu
Cost of station service power $0.017 /kWh
Cost of prepared limestone $18.00 /ton delivered and ground
Calcium carbonate content in limestone 91 wt%
Cost of additional byproduct produced $7.5 /ton
Byproduct molecular weight 131 lb/mole
Number of FGD modules 2
4-20
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The amount of SO2 removed by the FGD system was calculated as follows:
SO2 Removed = (5.2-1.15)lb/106 Btu x 335,000 kW x 8,570 Btu/kWh x 1

ton/2000 lb
= 5.81 tons/hr SO2 (5.28 metric tons/hr)
At the measured value of 95% limestone utilization, the amount of limestone (LS in the
equation below) used to remove the above SO2 was:
LS Used = 5.81 ton SO2/hr x 100 ton CaCO3/64 ton SO2
x 1 ton LS/0.91 ton CaCO3 x 1 ton actual/0.95 ton theoretical
= 10.5 tons/hr LS (9.5 metric tons/hr)
Under these conditions, the amount of byproduct solids produced for disposal was:
Byproduct = 5.81 ton SO2 x 131 ton (CaSO3)0.9(CaSO4)0.1· ½ H2O/64 ton SO2
+ (10.5 tons total LS - 5.81 x 100/64 theoretical tons CaCO3)
= 13.3 tons/hr byproduct solids (12.1 metric tons/hr)
The total variable operating cost for the FGD system can be calculated from the above
quantities using the unit costs for auxiliary power, limestone, and byproduct solids
disposal. For the conditions shown in the first row of calculations, the total variable
operating cost was $391/hr.
The second and third rows of calculations show the results for tests at 335 MW with three
pumps/module and two pumps/module operating. The cost calculation shows that
operation with three pumps/module is slightly less expensive ($3/hr) compared to four
pumps/module. However, operating costs with only two pumps/module are much
4-21
Case Studies
higher, about $210/hr more than the three pumps/module case. This is a result of the rapid
decrease in limestone utilization at operating pH levels above about 5.8 in this FGD system.
The next three rows of calculations are results for operation at 235 MW (about 70% load). At
this reduced load, there is almost no difference in operating costs for the two
pumps/module and three pumps/module cases.
The next two rows of calculations are results for operation at 105 MW, the lowest load
tested, with three and two pumps/module. At this low load, limestone utilization is very
high, and the two-pumps/module operation is clearly less expensive than operating three
pumps/module.
Therefore, for this system, it appears that for unit loads ranging from full load down to
approximately 200 MW, the most cost effective manner to operate would be with three
pumps operating and adjusting the pH to maintain the desired SO2 removal performance.
Below approximately 200 MW, it appears that the most cost effective operating mode is
with just two pumps and spray header levels in service. A future evaluation for this FGD
system should consider whether at low load it is more economical to operate one absorber
with more pumps in service or two absorbers with two pumps operating in each.
Case Study Number 3 - Increasing Limestone Fineness to Reduce Auxiliary

Power and Limestone Costs
General Approach
Most utility FGD systems use limestone as the reagent to neutralize SO2. The two most
important limestone parameters are chemical reactivity and particle size (i.e., particle
size distribution, or PSD). Since limestone is relatively slow to dissolve in the FGD
reaction tanks, decreasing the average particle size and thus increasing the specific
surface area of the ground limestone increases the rate at which it dissolves. This effect
in turn increases reaction tank pH and/or limestone utilization.
Most recent FGD limestone grinding systems were designed to produce a limestone
size distribution that has over 90% passing 44 Pm (325 mesh). Many grinding systems
installed before 1990 were designed to produce a product with less than 90% passing 74
Pm (200 mesh). However, options are available to operators of these older systems that
allow the production of a finer limestone grind. In a situation where limestone is
ground in a wet closed-circuit ball mill, which is in good condition and contains the
correct ball charge, the following changes typically produce a finer grind:
x Purchase a softer limestone;
4-22
Case Studies
x Purchase raw limestone that has a smaller size distribution; or
x Decrease the grinding system feed rate and increase the ratio of recirculation rate to
feed rate.
Although all options would likely result in a higher cost of ground limestone,
increasing ground limestone fineness has benefits that can offset the increased costs.
Operating the scrubber at a higher pH increases SO2 removal, which could allow
operation with fewer absorber recycle pumps. Reducing the number of recycle pumps
reduces flue gas pressure drop through the absorbers and reduces induced draft fan
power requirements. The increase in limestone utilization reduces both the quantity of
limestone purchased and the quantity of FGD byproduct to be disposed.
Feeding smaller limestone material to the ball mill system typically produces a smaller
product. However, a feed material that consists of a high fraction of fines may be
difficult to handle in the on-site storage and conveying systems. That is the reason some
utilities prefer to purchase a scalped or washed feed [e.g., ¾ in. by ¼ in. (19 mm by 6
mm)] rather than an unwashed stone [e.g., ¾ in. by 0 (19 mm by 0 mm)].
Data Required
Technical Inputs:
x Recycle pump power (kW) - Measured directly and calculated as the product of
amps, volts, and power factor, or calculated from slurry flow rate and pump
developed head.
x Relationship between limestone utilization and slurry pH set point (for finer
limestone grind) - Measured by slurry analyses.
x Fan power versus unit load and number of operating pumps (kW) - Measured
directly or calculated from flue gas volumetric flow rate and FGD system pressure
drop.
Economic Inputs:
x Auxiliary power cost ($/kWh).
x Current limestone cost ($/ton) - Calculated as the total marginal cost of limestone
delivered to the site and prepared by grinding.
4-23
Case Studies
x Alternate limestone cost ($/ton) - Cost of softer or smaller material obtained from
limestone vendors, and including cost of preparing limestone by grinding, which is
determined by test (see below).
x Additional grinding cost ($/ton) - Cost to grind current limestone to a finer product,
determined by test (see below).
x Byproduct disposal cost ($/ton dry byproduct) - Calculated as the total marginal
cost of FGD byproduct placed in the landfill (or otherwise disposed), including all
fixation costs.
Tests Required:
Grinding System Throughput Versus Product Fineness
Full-scale testing of an alternate limestone supply is difficult to accomplish at an

operating FGD system. The new material must be segregated from the old and
sufficient limestone must be processed to allow for complete purging of the old
limestone. In order to predict the optimum limestone feed for a given FGD system, the
engineer must understand some basic principles of limestone grinding. A typical wet
closed-circuit horizontal ball mill system is shown in Figure 4-2. Having the correct ball
charge in the mill is a key factor in achieving the finest grind. Another important
consideration is proper operation of the hydrocyclones, which are used to separate
larger particles from the smaller ones. The larger particles are returned to the ball mill
for regrinding.
Each limestone grinding system was designed for a specific limestone supply,
including specifications for limestone hardness and feed size distribution. Because
changes in supply over time could have altered the feed, the original design should be
compared with the current operation. Limestone hardness is usually specified in terms
of Bond Work Index (BWI), which is determined using a laboratory-scale ball mill to
measure the amount of energy to grind stone from 3.36 mm to 80% less than 100 Pm.
The effects of BWI on mill capacity and product size are shown in Figures 4-3 and 4-4.
Note that data in these two figures are based on operating the mill system at constant
grinding power (e.g., kWh/ton). These figures can be used to estimate the effects of
changing to a softer limestone supply.
In many cases, it is preferable to optimize the current limestone grinding system rather
than change the limestone supply contract. The main operating variable for ball mill
systems is the limestone feed rate. The water rate is constrained by having to maintain
solids density in the product slurry. Limestone product fineness is maximized by
providing less than about 54% solids in the cyclone feed.(2) If the cyclone feed contains
4-24
Case Studies
L im es to n e
D ay S ilo
O v erflo w L au n de r H y d ro cy clo n e
C la ss ifiers
D a sh e d lin es sh o w U n de rflo w L a u nd er
rec yc le position.
W e ig h
F eed e r
D is trib u to r
G rin d in g W a te r
Tro m m el
D ilu tio n
R ejec ts W a ter
S lu rry R ea g en t
H o riz o n tal S lu rry
B all M ill M
S to rag e
M ill S lu rry Tan k
C lu tch
M o to r Sum p
R ed u c er M ill S lu rry
S um p Pu m p
Figure 4-2
Typical Closed-Circuit Horizontal Ball Mill Grinding System
4-25
Case Studies
28
Mill Capacity (dry metric tons/hr) 26
24
22
20
18
16
14
12
8 9 10 11 12 13
Bond Work Index
Source: “Flue Gas Desulfurization” a brochure by Allis Mineral Systems Grinding

Division, York, PA, November 1991.
Figure 4-3
Typical Limestone Grinding Ball Mill Capacity Versus Bond Work Index
4-26
Case Studies
100
99
Percent Less Than 44 mm (325 Mesh)
98
97
96
95
94
93
92
91
90
9 10 11 12 13
Bond Work Index
Source: “Flue Gas Desulfurization” a brochure by Allis Mineral Systems Grinding

Division, York, PA, November 1991.
Figure 4-4
Typical Limestone Grinding Ball Mill Product Size Versus Bond Work Index
4-27
Case Studies
over 54% solids and the product slurry is the correct consistency, the ball mill feed rate
should be reduced.
Limestone Utilization Versus Slurry pH
After the grinding system operation is modified to produce a finer limestone product,
the FGD system can be tested to determine the effects of a finer grind on SO2 removal
and process operation. Using the finer limestone, the FGD system should be optimized
to determine the best combination of operating pH and number of recycle pumps. Refer
to Case Study 2, Optimizing Slurry pH Set point and Number of Recycle Pumps to
Obtain Lowest Combined Auxiliary Power and Limestone Costs. That case study has a
discussion of testing to optimize pH and number of operating recycle pumps.
Figure 4-5 depicts typical data that show the relationship between limestone grind and
limestone utilization. A finer grind yields higher utilization at constant pH. Conversely,
a finer grind allows operation at a higher pH, at constant utilization. Since operation at
a higher pH increases SO2 removal, the finer grind may allow use of fewer recycle
pumps. The goal of this testing is to determine what combination of limestone grind,
number of operating recycle pumps, and operating pH results in the lowest FGD
operating costs.
Economic Evaluation
Table 4-6 summarizes the economic evaluations of two options for increasing limestone
fineness in an existing limestone grinding system. The example data used in this
spreadsheet are based on test results from several utility FGD facilities. In this example,
a 600-MW unit has an FGD system with two operating absorber modules, each with
four recycle pump/spray header combinations. Input data for the cost calculations are
listed at the top of the table. The basic premise for choosing options is to maintain
constant SO2 removal while reducing operating costs.
Current Operation
In the Current Operation case in Table 4-6, limestone is ground to 50% passing 74 Pm
and costs $16 per ton for delivery and grinding. The goal for both options is to increase
fineness to 93% passing 74 Pm. The current system achieves 85% SO2 removal at a
recycle slurry pH set point of 5.6. With four pumps per absorber operating, the full-
load L/G is 90 gal/1000 acfm. The FGD system flue gas pressure drop is 6 inches water
gauge (1.5 kPa).
4-28
Case Studies
92
Baseline Limestone Tests
Reagent Preparation Tests
90
Limestone Utilization (%)
88
86
Test Conditions
8250 scfm Gas Flow
84 2500 ppm Inlet SO2
132 gal/macf L/G
5.5 Slurry pH
140 mM Calcium
82 12% Slurry Solids
6000 gal Volume
80
65 70 75 80 85 90 95
Limestone Grind [% <44µm (325 mesh)]
Figure 4-5
Limestone Utilization Versus Limestone Grind
(Example Data From Testing Conducted at the EPRI ECTC)
4-29
Table 4-6
Example Economic Evaluation for Finer Ground Limestone
Options Pump/ Slurry Limestone Grinding Fan Power Pump Limestone Byproduct Grinding Fan Power Pump Power Limestone Byproduct Total
Module pH Utilization Power (kW) Power Usage Solids Power Diff. Difference Difference Difference Difference Difference
(%) (kWh//ton (kW) (ton/hr) (ton/hr) ($/yr) ($/yr) ($/yr) ($/y) ($/yr) ($/yr)
Current Operation 4 5.6 85 10 2,460 3,800 19.8 24.6 $0 $0 $0 $0 $0 $0

(50% < 74 um)
Option 1: (93% < 4 5.5 98 15 2,460 3,800 17.2 22.0 $12,000 $0 $0 (235,000) ($129,000 ($352,000)
74um) Reduce
throughput and
3 5.7 89 15 2,290 2,850 18.9 23.7 $13,000 ($24,000) (152,000) (34,000) $44,000) ($241,000)
optimize grinding
circuit recycle.
Assume extra
cost of $0.50 per
ton LS for ball
attrition.
Option 2: (93% < 4 5.5 98 10 2,460 3,800 17.2 22.0 $0 $0 $0 $6,000 ($129,000) ($123,000)
74um) Purchase
smaller, softer LS.
3 5.7 89 10 2,290 2,850 18.9 23.7 $0 ($24,000) ($152,000) $232,000 (44,000) $12,000
Optimize grinding
circuit recycle.
Assume extra
cost of $2.50 per
ton LS
Notes: The FGD system has two operating absorber modules and is operated in the inhibited oxidation mode, producing
a byproduct with an average molecular weight of 131 lb/lb-mole.
Assumptions:
Unit Gross Capacity 600 MW Byproduct Disposal Cost $7.00 /ton
Gross Heat Rate 9100 Btu/kWh Recycle pump power, Each 475 kW
Unit Capacity Factor 0.80 Pump and Fan Operating Time 8000 hours/year
Fuel Sulfur Content 4.5 lb SO2/MM Btu
SO2 Removal 85 %
SO2 Removal Rate 9.9 tons/hr
Flue Gas delta P per Spray Pump 0.4 inches H2O
Cost of Auxiliary Power $0.02 /kWh
Cost of Standard Limestone $16.00 /ton delivered and ground
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Case Studies
Option 1 - Reduce Ball Mill Throughput
The utility may be able to increase fineness by reducing the limestone throughput to
the ball mill. This operating change can increase some FGD operating costs, primarily
by increasing ball attrition and by increasing auxiliary power usage (e.g., kWh/ton LS).
The latter can be measured during grinding tests, but the former will take an extended
period of operation to determine.
In this example the mill throughput is decreased to optimize the feed of slurry to the
hydrocyclone classifiers. A ball mill draws almost constant power as the limestone feed
rate varies, if the ball charge is kept near optimum. This is because the mass of balls is
greater than the mass of limestone in the mill. (A decrease in mill motor current
indicates to the operator that additional balls are required.) A decrease in limestone
and grinding water feed rates reduces the solids density of slurry pumped by the mill
slurry sump pump. This allows the classifiers to produce a finer cut of slurry, sending a
stream of smaller particles to the reagent slurry storage tank. In this example, the mill's
specific energy consumption increased from 10 to 15 kWh/ton (11 to 16.5 kWh/metric
ton). This change could result from a decrease in mill throughput from 30 to 20 tons per
hour (27 to 18 metric tons). In many cases, such a decrease could be accomplished by
operating the grinding system more hours per day. In other cases where the mill is
operating near capacity, the spare mill may be put into service in order to meet demand
at reduced throughput.
This change in limestone feed rate affects six different FGD operating costs:
1. Increased ball attrition - Assumed to be $0.50 per ton of limestone ground.

Actual costs would be determined by long-term testing of the grinding system
and comparing the new ball addition rate at lower limestone throughput with
historical costs.
2. Increased grinding power - a straightforward calculation based on new versus

old limestone throughput and mill power draw.
3. Reduced recycle pump power - Can change if the finer limestone allows
operation of fewer recycle pumps and a higher slurry pH. In this example,
operation with three pumps per absorber is more economical than four pumps.
Even though the higher pH results in lower limestone utilization, running fewer
recycle pumps is more economical. In some FGD installations, (e.g., where
auxiliary power costs are lower) operating fewer pumps may not be the best
alternative. Recycle pump power cost is calculated as follows:
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Case Studies
Pump power = 2 modules x 4 pumps x 475 kW/pump

= 3800 kW
4. Induced draft fan or FGD booster fan power - Is affected by the number of
recycle pumps in operation. An operating spray header typically affects flue gas
pressure drop through the absorbers by 0.2 to 0.5 inches of water (0.05 to 0.12
kPa). ID fan power can be estimated by the following equation:
Fan power = 0.000117 x 2,100,000 acfm x 6 in.H2O

/ 0.6 efficiency
= 2460 kW
* Differential pressure across the fan.
5. Limestone usage - Typically decreases with a finer grind. The effect of a finer
grind on limestone utilization is difficult to predict but can be determined
through testing. Based on the improved limestone utilization of 98% determined
through the tests and the SO2 removal rate, the new limestone (LS) consumption
rate can be estimated as follows:
Limestone = 10.4 ton SO2/hr x 100 ton CaCO3/64 ton SO2

x 1 ton LS/0.92 ton CaCO3 x 1 ton fed/0.98 ton reacted
= 18.0 tons/hr (16.4 metric tons/hr)
6. Byproduct solids quantity - Decreases as limestone utilization increases.

Byproduct solids include the sulfur product, which in this case is the calcium
sulfite/sulfate solid solution, excess limestone, and limestone inerts. Fly ash may
also be collected by some FGD systems, but its presence would not affect the
differential byproduct volume. The byproduct solids rate is estimated from:
4-32
Case Studies
Byproduct = 10.4 tons SO2/hr x 131 ton (CaSO3)0.9(CaSO4)0.1x1/2H2O / 64 ton

SO2
+ 18.0 tons LS/hr - 10.4 x 100/64 reacted tons CaCO3/hr
= 23.0 tons/hr (20.9 metric tons/hr)
Annual costs are determined separately for each of the six rates and then are summed
for a total annual cost or savings. Consumables such as limestone vary with the unit
capacity factor, but auxiliary power depends on how many hours per year the
equipment actually operates. Pumps continue to draw full power even when the unit is
operating at reduced load.
The results of this analysis, indicate the best option is to operate four recycle pumps per
absorber with a slurry pH of 5.5. As shown in Table 4-6, the very high limestone
utilization that is achievable from the fine grind and 5.5 pH saves almost $250,000 per
year in limestone costs. The savings in auxiliary power by operating three rather than
four pumps per absorber is offset by increased limestone consumption at the lower
utilization that results at a pH of 5.7.
Option 2 - Purchase Different Limestone
For plants that are constrained in their grinding operation, changing the limestone
supply may be the only available option to produce a finer grind. In some cases, the
effects of Options 1 and 2 can be combined. See Option 1 above for cost estimating
details.
A national survey of available limestones found a range of work indexes from 4.2 to
13.3 kWh/ton (4.6 to 14.7 kWh/metric ton).(2) Soft stone is not available in all areas, but
may be an option for many utilities. Another option is to reduce the raw limestone feed
size. Some utilities may find that employing a combination of the two changes is
required to produce the finer grind using existing equipment. The cost of changing the
limestone contract is site-specific, but was assumed to be an additional $3.50/ton in this
example. By operating the ball mill system at the same throughput as was used for
harder (or larger) stone, the specific grinding power does not change. However, there
are other changes in operating costs attributable to the finer grind.
Despite a reduction in the limestone consumption rate, the net cost of limestone
increases for both cases in Option 2. However, the higher limestone utilization causes a
reduction in byproduct volume and net byproduct disposal savings are greater than net
limestone costs.
4-33
Case Studies
References
(1) EPRI CS-3612, Volume 2, Revision 1 FGD Chemistry and Analytical Methods
Handbook, Volume 2: Chemical and Physical Test Methods, Revision 1. November
1988.
(2) R.K. Seward and K.A. Brame, "A Review of Methods for Increasing Limestone
Reagent Fineness for Flue Gas Desulfurization," Presented at the
EPRI/EPA/DOE SO2 Control Symposium, Atlanta, GA, November 17-21, 1986.
4-34
5
BIBLIOGRAPHY
This section provides a list of additional resources for information on cost saving
strategies discussed in Sections 3 and 4. Information from many of these documents
were used to develop the discussions and examples presented in those sections. These
resources are organized according to the cost saving strategy they primarily discuss.
However, many of the resources discuss several FGD cost savings strategies.
A number of papers from EPRI-sponsored symposia are included in this section.

However, it was impractical to list every paper that addressed cost saving strategies for
FGD systems, as that is a central theme of most EPRI-sponsored symposia related to
FGD technology. The proceedings from the SO2 Control Symposia in 1990, 1991, 1993,
and 1995, as well as the proceedings from the Mega-Symposium in 1997 provide an
extensive source of reference material.
Use Performance Enhancing Additives
Bailey, M.D., et al. “Results of an Investigation to Improve the Performance and

Reliability of HL&P’s Limestone Station FGD System.” Paper presented at the 1991 SO2
Control Symposium. Washington, DC, December 1991.
Burke, J.M., et al. “Results of Sodium Formate Addition Tests at EPRI’s HSTC and
AECI’s Thomas Hill Unit 3 FGD System.” Paper presented at the 1990 SO2 Control
Symposium. New Orleans, LA, May 1990.
EPRI High Sulfur Test Center: Selection of FGD Upgrade Options for Achieving High SO2
Removal Efficiency. Draft Report. Palo Alto, CA: Electric Power Research Institute, July
1994.
Evaluation of High Efficiency Test Results at Hoosier Energy’s Merom Station. Topical
Report, Contract No. DE-AC22-92PC91338. Pittsburgh, PA: U.S. Department of Energy
Federal Energy Technology Center, April 1996.
Hendry, D., J. Weis, and D. Baumgardner. “FGD Performance Improvements at Plains-

Escalante Generating Station.” Paper presented at the 1990 SO2 Control Symposium.
New Orleans, LA, May 1990.
5-1
Bibliography
High Efficiency Flue Gas Desulfurization Guidelines. TR-104597. Palo Alto, CA: Electric
Power Research Institute, December 1994.
High SO2 Removal Efficiency Testing, Final Report. Contract No. DE-AC22-92PC91338.
Pittsburgh, PA: U.S. Department of Energy Federal Energy Technology Center, October
1997.
Jankura, B.J., et al. “Organic Acid Buffer Testing at Michigan South Central Power
Agency’s Endicott Station.” Paper presented at the 1991 SO2 Control Symposium.
Washington, DC, December 1991.
Noblett, J.G., et al. “FGDPRISM, EPRI’s FGD Process Model – Recent Applications.”
Paper presented at the 1991 SO2 Control Symposium. Washington, DC, December 1991.
PSI Energy’s Gibson Station High SO2 Removal Efficiency Test Program. Topical Report,
Contract No. DE-AC22-92PC91338. Pittsburgh, PA: U.S. Department of Energy Federal
Energy Technology Center, May 1996.
Results of DBA Additive Tests at Tampa Electric Company’s Big Bend 4 FGD System. Topical
Federal Energy Technology Center, March 1995.
Results of DBA and Sodium Formate Additive Tests at Southwestern Electric Power Company’s
Pirkey Station. Topical Report, Contract No. DE-AC22-92PC91338. Pittsburgh, PA: U.S.
Department of Energy Federal Energy Technology Center, May 1996.
Results of High Velocity Tests at Tampa Electric Company’s Big Bend 4 FGD System. Topical
Federal Energy Technology Center, October 1997.
Results of Sodium Formate Additive Tests at New York State Electric and Gas Corporation’s
Kintigh Station. Topical Report, Contract No. DE-AC22-92PC91338. Pittsburgh, PA: U.S.
Department of Energy Federal Energy Technology Center, February 1997.
Reynolds, Paul, et al. “Options for Increasing SO2 Removal at Hoosier Energy’s Merom
Station.” Paper presented at the 1993 SO2 Control Symposium. Boston, MA, August
1993.
Smolenski, John, et al. “High Efficiency SO 2 Removal Tests at Tampa Electric

Company’s Big Bend Unit 4.” Paper presented at the 1993 SO2 Control Symposium.
Boston, MA, August 1993.
5-2
Bibliography
Stohs, M., et al. “Development of a Predictive Model for Organic Acid Consumption in
Wet Limestone FGD Systems.” Paper presented at the 1993 SO2 Control Symposium.
Boston, MA, August 1993.
Add Sulfur/Inhibit Oxidation
Investigation of Flue Gas Desulfurization Chemical Process Problems. GS-6930. Palo Alto,
CA: Electric Power Research Institute, August 1990.
Modify/Improve Mist Eliminator Wash System
FGD Mist Eliminator Replacement Guide. TR-109108. Palo Alto, CA: Electric Power
Research Institute, October 1997.
FGD Mist Eliminator System Design and Specification Guide. TR-102864. Palo Alto, CA:
Electric Power Research Institute, December 1993.
Modify pH Set Point/Control
Department of Energy Federal Energy Technology Center, May 1996.
Results of High Velocity Tests at Tampa Electric Company’s Big Bend 4 FGD System. Topical
Federal Energy Technology Center, October 1997.
5-3
Bibliography
Topical Report for Duquesne Light’s Elrama Station. Topical Report, Contract No. DE-
AC22-92PC91338. Pittsburgh, PA: U.S. Department of Energy Federal Energy
Technology Center, June 1997.
Optimize Makeup Water Use
Colley, D., D. Stewart, and L. Haynes. “FGD System and Water Balance Improvements
at CILCo’s Duck Creek Station.” Paper presented at the Symposium on Advances in
Fossil Power Plant Water Management. Orlando, FL, February 1986.
Hargrove, O.W. Jr., et al. “Mist Eliminator and Water Balance Improvements at IPL
Petersburg Station.” Paper presented at the Symposium on Advances in Fossil Power
Plant Water Management. Orlando, FL, February 1986.
Hargrove, O.W., et al. “FGD System and Water Balance Improvements at Texas
Utilities Generating Company’s Martin Lake Station.” Paper presented at the
Symposium on Advances in Fossil Power Plant Water Management. Orlando, FL,
February 1986.
Modify Reagent Preparation

Limestone Selection Methodology for Wet Flue Gas Desulfurization Systems. TR-102660. Palo
Alto, CA: Electric Power Research Institute, August 1993.
5-4
Bibliography
Change L/G
EPRI High Sulfur Test Center: Selection of FGD Upgrade Options for Achieving High SO2
Removal Efficiency. Draft Report. Palo Alto, CA: Electric Power Research Institute, July
1994.
EPRI High Sulfur Test Center: Wet FGD Baseline Limestone Tests. GS-7043. Palo Alto, CA:
Electric Power Research Institute, October 1990.

Convert to Wet Stack Operation
Campbell, F., D. Patterson, and J. Novak. “Elimination of the FGD System Reheat for
the Endicott Station.” Paper presented at the 1990 SO2 Control Symposium. New
Orleans, LA, May 1990.
Entrainment in Wet Stacks. CS-2520. Palo Alto, CA: Electric Power Research Institute,
August 1982.
Close Bypass Damper
Campbell, F., D. Patterson, and J. Novak. “Elimination of the FGD System Reheat for
the Endicott Station.” Paper presented at the 1990 SO2 Control Symposium. New
Orleans, LA, May 1990.
Entrainment in Wet Stacks. CS-2520. Palo Alto, CA: Electric Power Research Institute,
August 1982.
5-5
Bibliography
Department of Energy Federal Energy Technology Center, May 1996
Use Spare Module in Normal Operation
Change Reagent Type
Benson, L., et al. “Advanced Mg-Enhanced Lime SO2 and NOX Control Pilot Plant.”
Paper presented at the 1990 SO2 Control Symposium. New Orleans, LA, May 1990.
Brockman, W.D., et al. “Operation and Maintenance Update of the Zimmer Generating
Station FGD System.” Paper presented at the 1993 SO2 Control Symposium. Boston,
MA, August 1993.
Lime FGD Systems Data Book. CS-2781. Palo Alto, CA: Electric Power Research Institute.
Limestone FGD Systems Data Book. CS-2949. Palo Alto, CA: Electric Power Research
Institute.
Optimize Venturi Contactor 'P
Topical Report for Duquesne Light’s Elrama Station. Topical Report, Contract No. DE-
AC22-92PC91338. Pittsburgh, PA: U.S. Department of Energy Federal Energy
Technology Center, June 1997.
5-6
Bibliography
Add Tray/Packing
EPRI Environmental Control Technology Center: FGD Wet Scrubbing Performance at

High Flue Gas Velocities, Final Report. Palo Alto, CA: Electric Power Research Institute,
September 1996.
Evaluation of High Efficiency Test Results at Hoosier Energy’s Merom Station. Topical
Federal Energy Technology Center, April 1996.

General Resources for Determining the Effectiveness of Cost Saving

Strategies
Electric Utility Engineer’s FGD Manual. Prepared under Grant No. DE-FG22-94PC94256,
2 vols. Pittsburgh, PA: U.S. Department of Energy Pittsburgh Energy Technology
Center, May 1996.
FGD Chemistry and Analytical Methods Handbook, Volume 1: Process Chemistry, Sampling,
Measurement, Laboratory, and Process Performance Guidelines. CS-3612, Vol.1, Revision 1.
Palo Alto, CA: Electric Power Research Institute, August 1990.
FGD Chemistry and Analytical Methods Handbook, Volume 2: Chemical and Physical Test
Methods. CS-3612, Vol.2, Revision 1. Palo Alto, CA: Electric Power Research Institute,
November 1988.
FGDCOST: Cost Estimating Model, Computer User’s Manual, Version 1.0. GS-7525-CCML.
Palo Alto, CA:
5-7
A
RESULTS OF PROJECT-SPECIFIC FGD COST
SURVEY
This appendix summarizes the results of an FGD cost comparison survey that was
conducted as part of the FGD Optimization Workbook project. The survey consisted of
a nine-page form that was sent to participating electric utility stations that operate lime
or limestone reagent FGD systems. The survey requested information about details of
the FGD system and about operating and maintenance (O&M) costs.
A total of 90 utility stations were identified as having lime or limestone reagent FGD
systems in operation. Several other stations with installed FGD were not included
because it was known that they were firing a compliance coal and not operating the
FGD system, or because the FGD system used a unique reagent (e.g., mag-ox or dual
alkali).
An attempt was made to contact all 90 stations to request their participation in the
survey. Of the 90, 80 were contacted and agreed to have the survey sent to them. For
the other ten, either contact was never made or the utility declined to participate.
Of the 80 surveys sent, 35 were returned. The other 45 declined to participate after
reviewing the survey contents. Some cited competitive pressures that led their
management to decline to provide cost information, and others simply did not have
time to complete the detailed survey.
Of the 35 surveys returned, 29 contained at least part of the requested cost information
and 6 contained none. In most cases, for stations that have multiple FGD systems at
least part of the cost information was co-mingled. For these systems the station FGD
costs were treated as an aggregate. One station firing high sulfur coal reported costs for
two FGD systems that were completely separate. This station’s FGD systems were
treated as two separate entries in the survey, making 30 stations or FGD systems for
which some cost information was available.
The completed surveys present costs for 28 wet FGD systems and 2 spray dryer FGD
systems. The wet FGD systems include 7 treating flue gas from high sulfur coal, 8
treating medium sulfur coal, and 13 treating flue gas from low sulfur coal. Table A-1
A-1
Results of Project-Specific FGD Cost Survey
summarizes the makeup of the wet FGD systems for which cost information was
provided.
Table A-1
Summary of the Wet FGD Systems for Which Cost Information was Provided
Reagent/Oxidation Mode High Sulfur Medium Sulfur Low Sulfur
Limestone/Forced 3 2 2
Limestone/Inhibited 3 1 1
Limestone/Natural - 3 4
Lime 1 2 2
Ash/Limestone - - 2
Alkaline Ash - - 2
The original intent of the survey was to be able to present average, high and low cost information
in a number of cost categories for each sulfur level, reagent and oxidation mode. Because of the
limited number of survey responses, the high sulfur, limestone/forced oxidation category is the
only such combination that is addressed separately in this appendix. Therefore, the FGD
categories for which cost information are presented include high sulfur, limestone/forced
oxidation; high sulfur (all reagents and oxidation mode); medium sulfur; and low sulfur. For the
low sulfur systems in particular, the effects of reagent type and oxidation mode on FGD costs
were thought to be minimal, though.
It was also intended to report FGD costs on the basis of other FGD system attributes such as year
installed. However, the limited number of responses at each sulfur level makes it difficult to make
such comparisons. Where relevant, some comments about the impacts of system age on FGD
costs are made, though.
The FGD cost categories reported included operating and laboratory staff labor, maintenance staff
labor, contract maintenance labor, maintenance materials, reagent costs, additive costs (sulfur,
DBA, etc.), auxiliary power costs and percent of station output, waste disposal, and total variable
costs. The rest of this appendix reports the FGD cost information for the 30 FGD systems that
participated in the cost survey.
High-Sulfur, Limestone/Forced Oxidation

High sulfur was defined as coals or lignites with a sulfur content of 4.5 lb per million Btu of heat
content or greater. The high-sulfur, limestone/forced oxidation systems that reported costs
included two “Phase I” retrofit FGD systems placed in service around 1995, and one early
1980’s-vintage system. The three systems reported that the units from which they treat flue gas
had capacity factors of 70% or greater.
A-2
Table A-2 summarizes the cost information from these four FGD systems, in terms of dollars per
ton of SO2 removed. Table A-3 shows the same information expressed in terms of dollars per
MWh of net generation by the scrubbed unit(s).
Table A-2
Costs for High-Sulfur, Limestone/Forced Oxidation FGD Systems
Cost Category Average High Low
Operating Labor $16.31 $28.86 $9.41
Maintenance Labor $25.07 $46.88 $3.27
Contract Maintenance $13.03 $24.04 $2.01
Maintenance Materials $5.92 $8.91 $2.93
Reagent $14.12 $18.54 $9.05
Additives $0.75 $1.51 $0.00
Auxiliary Power $12.59 $14.31 $11.02
- % of station output 1.6% 2.8% 1.0%
Waste Disposal $1.01* - -
Total O&M Costs $88.81 $138.24 $42.90
Note: All values in dollars/ton of SO2 removed except as noted.

*Only one value reported.
Table A-3
Operating Labor $0.522 $0.940 $0.295
Reagent $0.459 $0.603 $0.249
Additives $0.021 $0.042 $0.000
Auxiliary Power $0.403 $0.507 $0.344
A-3
Waste Disposal $0.028 - -
Total O&M Costs $2.846 $4.500 $1.183
Note: All values in dollars/MWh of annual net generation by scrubbed units.
In general, the lower costs are associated with a larger (>500 MW) Phase I system, while the
higher costs are associated with an older (early 1980’s), smaller (~200 MW) system. There is a
wide range of reported waste disposal costs. The low costs are associated with a gypsum stack,
while the high costs are for gypsum that is apparently hauled a large distance for reuse or
disposal. None of the systems that reported costs sell their gypsum to a nearby wallboard plant. In
that case negative (credit) values would be expected.
High-Sulfur Systems (Mg-Lime and Limestone Reagent, All Oxidation

Modes)
The cost data from all seven high sulfur systems that reported cost data are presented in Tables
A-4 (dollars per ton of SO2 removed) and A-5 (dollars per net MW of generation). The high
sulfur systems included one lignite-fired station that reported a lignite sulfur content of greater
than 5 lb per million Btu. The three limestone forced oxidation systems reported above are also
included.
Table A-4
Costs for All High-Sulfur FGD Systems
Reagent $20.24 $44.93 $9.05
Additives $0.85 $2.26 $0.00
Auxiliary Power $15.19 $25.84 $9.55
Waste Disposal $15.86 $23.99 $1.01
Total O&M Costs $95.43 $138.24 $42.9
A-4
Table A-5
Costs for All High-Sulfur FGD Systems
Operating Labor $0.389 $0.940 $0.140
Reagent $0.629 $1.440 $0.249
Additives $0.028 $0.077 $0.000
Auxiliary Power $0.452 $0.827 $0.281
Waste Disposal $0.403 $0.660 $0.028
Total O&M Costs $2.841 $4.500 $1.183
Note: All values in dollars/MWh of annual net generation by scrubbed unit(s).
Three systems reported total O&M costs lower than $100 per ton of SO2 removed. These
included two Phase I systems, one that was forced oxidized and one inhibited oxidation. Two
systems reported O&M costs of greater than $130 per ton of SO2 removed. Both were built in the
late 1970’s/early 1980’s. One uses limestone reagent and the other Mg-lime reagent. The highest
reagent cost was for the Mg-lime reagent system, and the highest auxiliary power cost and
percentage were for a system with a venturi absorber for both SO 2 and particulate control. The
higher waste disposal costs were reported for inhibited oxidation limestone and Mg-lime systems.
Medium-Sulfur Coal Systems (Lime and Limestone Reagent, All Oxidation

Modes)
The cost data for all medium-sulfur-coal systems are presented in Tables A-6 and A-7. Medium-
sulfur coal systems were defined as those that treat flue gas from coal or lignite with a sulfur
content ranging from greater than 2.25 lb per million Btu to less than 4.5 lb per million Btu.
As might be expected, the costs for the medium-sulfur systems are higher than for the high-sulfur
systems when expressed in terms of dollars per ton of SO2 removed, but lower when expressed in
terms of dollars per net MW of generation. In general, the lowest O&M costs expressed in dollars
per ton were for a Phase I system, and the highest costs were for a smaller (~200 MW) system
with a sulfur content at the lower end of this range and that was built in the 1970’s. This reversed
somewhat when the costs were expressed in terms of dollars per MW of net generation. In the
latter case, the costs are roughly proportional to fuel sulfur content.
A-5
Capacity factors for the medium-sulfur system stations ranged from the mid-50’s into the 90’s
when expressed as a percentage. There was not a clear link between capacity factor and FGD cost
in the reported data, though.
The high reagent costs were for the two lime reagent systems (one Mg-lime and one high calcium
lime). These two systems did not report enough cost information to determine how their total
O&M costs compared to the limestone reagent systems, though.
Table A-6
Costs for Medium-Sulfur FGD Systems, All Reagents and Oxidation Modes
Reagent $33.73 $60.00 $8.13
Additives $1.45 $5.61 $0.00
Auxiliary Power $24.54 $41.60 $9.22
Waste Disposal $12.63 $26.99 $0.00
Total O&M Costs $132.23 $207.66 $84.93
Table A-7
Costs for Medium-Sulfur FGD Systems, All Reagents and Oxidation Modes
Operating Labor $0.216 $0.558 $0.029
Reagent $0.384 $1.173 $0.072
A-6
Additives $0.019 $0.084 $0.000
Auxiliary Power $0.166 $0.322 $0.052
Waste Disposal $0.133 $0.357 $0.000
Total O&M Costs $1.224 $1.845 $0.573
Note: All values in dollars/MWh of annual net generation by scrubbed unit(s).
Low-Sulfur Coal Systems (Lime and Limestone Reagent, All Oxidation

Modes)
Low-sulfur systems were defined as those that treated flue gas from a coal or lignite with a sulfur
content less than 2.25 lb per million Btu. The greatest number of survey respondents have low-
sulfur FGD systems (13 that reported costs). Capacity factors for the low-sulfur FGD system
stations ranged from the low 40’s to the low 80’s when expressed as a percentage. The low sulfur
results are reported in Tables A-8 (dollars per ton) and A-9 (dollars per MW of net generation).
When comparing the low sulfur results to those for medium- and high-sulfur systems, the
expected trend continues: higher costs in terms of dollars per ton of SO2 removed and lower costs
in terms of dollars per MW of net generation. Note that Table A-8 excludes the values from one
very low sulfur system that only treats a small percentage of the flue gas (the rest is bypassed).
For that system, the O&M costs totaled over $950 per ton of SO2 removed! The costs for that
system were low when expressed in terms of dollars per MW, though, as should be expected.
The high reagent costs represent lime systems, and the low (zero) reagent costs represent systems
that scrub with alkaline ash or water treatment waste calcium carbonate sludge. An average is not
shown for waste disposal costs for the low-sulfur systems. Very few of the systems reported
waste disposal costs. Many blow down directly from the absorber recycle tanks to evaporation
ponds, and the waste disposal costs are almost inconsequential. The ranges of reported costs for
the few that did report costs are shown though. Two of the 13 systems are able to sell their
byproduct, and thus show a negative value for this cost.
Table A-8
Costs for Low-Sulfur FGD Systems, All Reagents and Oxidation Modes
Operating Labor $42.07 $62.40 $20.22
A-7
Reagent $21.53 $50.66 $0.00
Additives $2.24 $9.78 $0.00
Auxiliary Power $47.43 $137.95 $15.36
Waste Disposal - $11.66 -$15.2
Total Variable Costs $197.01 $226.07 $127.46
Table A-9
Costs for Low-Sulfur FGD Systems, All Reagents and Oxidation Modes
Operating Labor $0.212 $0.585 $0.042
Reagent $0.114 $0.254 $0.000
Additives $0.016 $0.062 $0.000
Auxiliary Power $0.253 $1.103 $0.059
Waste Disposal - $0.037 -$0.140
Total Variable Costs $0.906 $1.807 $0.436
Note: All values in dollars/ MWh of annual net generation by scrubbed unit(s).
Spray Dryer FGD Systems

Costs for the spray dryer FGD systems that reported are included in Table A-10 and A-11. Only
two systems reported cost data, and those two systems treat flue gas from coals with a medium
sulfur content (greater than 2.25 lb per million Btu). Both did not report costs for all cost
categories; only those categories where both reported are included. No averages are shown
because it was not appropriate to do so with only two responses.
A-8
Table A-10
Costs for Spray Dryer FGD Systems
Cost Category High Low
Operating Labor $16.92 $9.49
Maintenance Labor $8.72 Incl. w/op.
Contract Maintenance $3.28 $0.00
Maintenance Materials $12.80 $3.23
Reagent $101.59 $37.00
Additives $0.00 $0.00
Auxiliary Power - -
- % of station output 0.4% 0.3%
Waste Disposal - -
Total O&M Costs - -
Table A-11
Costs for Spray Dryer FGD Systems
Cost Category High Low
Operating Labor $0.221 $0.091
Maintenance Labor $0.114 Incl. w/op.
Contract Maintenance $0.043 $0.000
Maintenance Materials $0.167 $0.031
Reagent $0.979 $0.483
Additives $0.000 $0.000
Auxiliary Power - -
Waste Disposal - -
Total O&M Costs - -
Note: All values in dollars/ MWh of annual net generation by scrubbed unit(s).
A-9
B
RESULTS FROM DEPARTMENT OF ENERGY COST
SURVEY
Each year, all power plants of greater than 10 MW in generator nameplate capacity are
required to submit a detailed design and cost form to the U.S. Department of Energy’s
Energy Information Administration (EIA). This form, “Steam-Electric Plant Operation
and Design Report” (Form EIA-767), covers many areas of the power plant, but
includes data about FGD system design features and annual operating and
maintenance costs. The data from all of the forms submitted each year are keyed in to
an electronic file, and are available from the EIA on floppy disk in a self-extracting,
column-delimited ASCII file. These data become available near the end of the calendar
year following the subject year.
At the time this report was prepared, the most recent Form EIA-767 data were for
calendar year 1996. This is the same year for which most of the FGD cost surveys
discussed in Appendix A reported costs. As part of the preparations for this workbook,
the 1996 Form EIA-767 data were requested and received from the EIA, and the FGD
cost data were analyzed to supplement the data discussed in Appendix A.
The 1996 Form EIA-767 data provided information from over 90 electric utility stations
with installed FGD systems. Table B-1 provides an overview of the FGD systems for
which cost data were reported. Costs were provided for almost 130 FGD systems. Note
that in a few cases a “system” includes multiple FGD systems on several units at a
single station. That is, in some cases the costs for all of the FGD systems at a station
were reported in a combined manner. However, in most cases costs were reported by
individual FGD system.
As shown in the table, cost data were available for 68 low-sulfur-coal systems, 18
medium-sulfur-coal systems, and 40 high-sulfur-coal systems. For the purposes of this
cost survey, low sulfur was defined as any coal or lignite with a sulfur content of less
than 2.25 lb of SO2 per million Btu of heat content. High sulfur was defined as a coal or
lignite with a sulfur content of 4.5 lb of SO2 per million Btu or greater, so medium-
sulfur-coal was, therefore, any coal or lignite with a sulfur content between 2.25 and 4.5
lb of SO2 per million Btu.
B-1
Results from Department of Energy Cost Survey
Table B-1
Summary of the Lime/Limestone FGD Systems for Which Cost Information was Available
Reagent - Oxidation Mode High Sulfur Medium Sulfur Low Sulfur
Wet FGD Systems:
Limestone – Forced Oxidation 12 5 5
Limestone – Inhibited or Natural 15 7 25

Oxidation
Lime, high calcium 2 7
Mg-Lime 13 1 5
Alkaline ash plus lime or limestone - 1 13
Spray Dryer FGD Systems:
Lime plus alkaline ash - 2 13
Total 40 18 68
Expressed in terms of percent sulfur, the low-sulfur coals included bituminous coals
with up to 1.25 wt% sulfur, and subbituminous coals with up to 0.9% sulfur. The high-
sulfur coals included bituminous coals with approximately 2.7 to 4.1% sulfur, and one
lignite with about 1.8 % sulfur. The medium-sulfur coals included bituminous coals
with sulfur contents ranging from approximately 1.5 to 2.6%, and lignites with 0.7 to
1.4% sulfur.
The FGD O&M cost categories reported on the EIA-767 form are slightly different than
those in the project-specific survey discussed in Appendix A. The cost categories
include:
A. Feed materials and chemicals
B. Labor and supervision
C. Waste disposal
D. Maintenance, materials, and all other costs
E. Total
B-2
Comparing these cost categories to those used in the project-specific cost survey
discussed in Appendix A, only Item C (waste disposal) exactly matches. Item A
includes both the reagent and additive cost categories in the project-specific survey.
Operating labor should clearly be included in Item B, but it is ambiguous as to whether
maintenance staff labor is included in Item B (Labor and supervision) or Item D
(Maintenance, materials, and all other costs). It is possible that utilities could have
reported maintenance staff labor in either cost category. Contract maintenance and
maintenance materials should be included in Item D.
The EIA form does not report tons of SO2 removed, so it is not possible to accurately
report FGD costs in terms of dollars per ton removed. However, the total unit net
generation is reported on the form, so the FGD costs can be expressed in terms of
dollars per megawatt of net generation.
The cost of auxiliary power is not reported on the EIA form, but the power
consumption is reported in kWh. Therefore FGD auxiliary power consumption can be
reported from the EIA data in terms of percent of net generation.
The results from the project-specific cost survey discussed in Appendix A and the Form
EIA-767 results presented in this appendix were compared for consistency. For the
medium- and low-sulfur coal results, the total O&M costs in the two sets of data
compared well, particularly taking into account that the EIA totals do not include
auxiliary power costs. For the high-sulfur-coal results, however, the project-specific cost
survey results in Appendix A generally report higher values. In reviewing the
individual FGD system responses in the two surveys, this bias appears to be related to
the limited number of responses to the project-specific survey. It appears that more of
the higher cost high-sulfur-coal FGD systems responded to the project-specific survey,
such that the project-specific survey results do not accurately represent the entire
population of high-sulfur-coal FGD systems. For this reason, the authors feel that the
EIA data presented in this appendix provide the better basis for comparison for high-
sulfur-coal FGD systems.
The cost data from the EIA survey are presented and discussed in the remainder of this
appendix. The discussions are first divided by coal sulfur level, then each combination
of reagent and oxidation mode is discussed. Most of the cost data are for wet FGD
systems, but lime spray dryer systems are also included. Lime spray drying is included
in the appropriate sulfur level discussions as though it was another reagent/oxidation
mode combination.
High-Sulfur Coal
The high-sulfur-coal FGD systems included limestone/forced oxidation,

limestone/inhibited or natural oxidation (the difference between inhibited and natural
B-3
oxidation could not be distinguished from the survey data), and Mg-lime. The costs
reported for each system type are presented in Tables B-2 through B-4, respectively.
There were 12 high-sulfur, limestone reagent, forced oxidation FGD systems for which
cost data were reported. Half of these systems were installed to comply with Phase I of
the 1990 Clean Air Act Amendments, and thus started up around January 1995. The
remainder were built previously, with in-service dates ranging from the early 80’s to
the early 90’s. There are actually more systems of this type that were designed for high-
sulfur coal, but their respective units currently fire a coal with a lower sulfur content,
placing them in the medium-sulfur-coal category.
The data in Tables B-2 through B-4 show that on average the limestone/forced
oxidation systems had the lowest annual O&M costs, but a higher auxiliary power
consumption percentage than the other two. Assuming a typical utility internal power
consumption cost of about $20/MWh, the higher power consumption for the
limestone/forced oxidation systems would add $0.10 to $0.20/MWh to the costs for this
system type relative to the costs for the other two.
Even considering the difference in power costs, the O&M costs for the limestone/forced
oxidation systems are reported to be about 50 to 60% of the costs for the
limestone/inhibited or natural oxidation systems, and about 40% of those for the Mg-
lime systems. As might be expected, the limestone/forced oxidation systems showed
the lowest waste disposal costs (several sell their byproduct), and the lowest reagent
cost (forced oxidation systems typically operate at high reagent utilization).
The limestone/forced oxidation systems are also on average the newest, and fire the
lowest sulfur content coal. It is possible that these effects lowered some O&M cost
components. For example, the lower sulfur content would tend to lower reagent costs,
and the systems being newer might result in lower maintenance costs. In an effort to
determine whether these effects skewed the survey results, the individual plant total
O&M cost data for each system type are plotted in Figures B-1 (effect of in-service date)
and B-2 (effect of coal sulfur content).
The data plotted in Figure B-1 do show a clear trend for lower total O&M costs as the
FGD system age decreases. When just looking at the newest FGD systems, those put in
service since 1990, the wet limestone system O&M costs fall in the range of about
$0.5 to $1.5/MWh and the Mg-lime system costs fall in the range of $1.5 to $2.5/MWh.
B-4
Table B-2
Feed Materials and Chemicals $0.246 $0.651 $0.091
Labor and Supervision $0.341 $1.302 $0.047
Waste Disposal ($0.002)* $0.118 ($0.207)*
Maintenance, Materials, and Other $0.239 $1.488 $0.037
Total O&M Expenditures $0.828 $3.437 $0.196
Unit Size, MW 612 1300 207
Capacity Factor 63.3% 76.9% 49.2%
Average Sulfur, lb SO2/million Btu 5.4 7.0 4.9
Average In-Service Date Dec-89 Jan-78 May-96
Aux. Power, % of Net Generation 2.5% 3.6% 1.0%
Note: All costs are reported in dollars/MWh of annual net generation by scrubbed
units.
* Reflects credit for gypsum byproduct sales.
B-5
Table B-3
Costs for High-Sulfur, Limestone/Inhibited or Natural Oxidation FGD Systems
Waste Disposal $0.275 $0.417 $0.127
Unit Size, MW 500 715 173
Average In-Service Date Mar-83 Jul-76 Jan-95
units.
B-6
Table B-4
Costs for High-Sulfur, Mg-Lime FGD Systems
Waste Disposal $0.461 $0.708 $0.120
Unit Size, MW 747 1426 299
Average In-Service Date May-85 Apr-76 Mar-95
units.
B-7
4.5
3.5
Total O&M Costs, $/MWh
2.5
1.5
0.5
0
Jan-74 Jan-79 Jan-84 Jan-89 Jan-94 Jan-99
FGD In-Service Date
LSFO LSIO Mg-Lime
Figure B-1
Effect of FGD System Age on Total O&M Costs, High-Sulfur Coal
B-8
4.5
3.5
2.5
1.5
0.5
0
4 4.5 5 5.5 6 6.5 7 7.5
Coal Sulfur Content, lb/MM Btu
LSFO LSIO Mg-Lime
Figure B-2
Effect of Sulfur Content on Total O&M Costs, High-Sulfur Coal
B-9
The data plotted in Figure B-2 show only a weak trend for increasing total O&M cost as
the coal sulfur increases. Judging by the strong influence of system age on total O&M
costs seen in Figure B-1, it is probably system age and other influences such as site-
specific reagent and waste disposal costs that produce the wide scatter in these data. It
does not appear that the range of coal sulfur in these high-sulfur-coal systems
measurably skews the comparison of system-type costs.
The data in Table B-4 show that the Mg-lime systems are on average installed on
significantly larger capacity units than the limestone systems (747 MW versus 612 MW
and 500 MW for the limestone/forced oxidation and inhibited/natural oxidation
systems, respectively). It is possible that economies of scale could produce lower unit
O&M costs for the larger units, which may benefit the Mg-lime systems in this
comparison. Figure B-3 shows the individual unit data by system type versus generator
nameplate capacity on the scrubbed units. These data show a clear trend for lower total
O&M costs, as expressed in terms of $/MWh, for larger units over the range of 200 MW
to 800 MW. The limestone/forced oxidation data show a trend for continued lower
costs for two units larger than 800 MW. However, the Mg-lime systems do not show
this trend. There are two apparent reasons that no further economy of scale is seen in
the largest Mg-lime systems. One is that the unit size data are confounded with FGD
system age (several of the larger Mg-lime systems are relatively old). Another is that
the unit O&M costs for the Mg-lime are dominated by reagent and waste disposal costs,
which would be expected to remain proportional to plant size and not tend to scale
down when expressed in terms of dollars/MWh.
Medium-Sulfur Coal
A total of 18 systems were classified in the medium-sulfur-coal category. These systems

include a mixture of systems that were designed for high-sulfur coal but currently treat
flue gas from a coal with a lower sulfur content (11 total), and lignite units that fire a
lignite with a relatively high sulfur content (7 total). The system types represented
include limestone/forced oxidation (5), limestone/inhibited or natural oxidation (7),
high-calcium lime (2), Mg-lime (1), wet alkaline ash reagent scrubbing (1) and lime
spray drying (2).
It is difficult to make meaningful comparisons for the medium-sulfur coal systems

because of the relatively small number of systems, the relatively wide range of sulfur
levels (a factor of two spread), and the diversity of reagents and oxidation modes
represented. Consequently, cost data are presented only for the limestone/forced
oxidation systems, limestone/inhibited or natural oxidation systems, and then for all of
the medium-sulfur-coal systems combined. These cost data are presented in Tables B-5
through B-7, respectively.
B-10
4.5
3.5
2.5
1.5
0.5
0
0 200 400 600 800 1000 1200 1400 1600
Generator Nameplate (MW)
LSFO LSIO Mg-Lime
Figure B-3
Effect of Unit Size on Total O&M Costs, High-Sulfur Coal
B-11
Table B-5
Costs for Medium-Sulfur, Limestone/Forced Oxidation FGD Systems
Cost Category Average High Low*
Waste Disposal $0.186 $0.623 $0.024
Average In-Service Date Mar-95 Dec-94 Jun-95
units.
* Some plants reported only total O&M expenditures, so in some cases, the low value
for individual cost categories can be greater than the lowest total O&M cost reported.
B-12
Table B-6
Costs for Medium-Sulfur, Limestone/Inhibited or Natural Oxidation FGD Systems
Waste Disposal $0.213 $0.358 $0.025
Average In-Service Date Oct-83 Mar-79 Oct-86
units.
B-13
Table B-7
Costs for All Medium-Sulfur-Coal FGD Systems
Cost Category Average High Low*
Waste Disposal $0.261 $1.389 $0.000
Average Sulfur, lb/million Btu 3.2 4.3 2.3
Average In-Service Date Oct-86 Sep-76 Jun-95
units.
* Some plants reported only total O&M expenditures, so in some cases, the low value
for individual cost categories can be greater than the lowest total O&M cost reported.
B-14
There are a few anomalies in these data. One is that the costs for the limestone/forced
oxidation systems are reportedly higher than for the limestone/inhibited oxidation
systems, in spite of the forced oxidation systems all being relatively new. This cost
comparison appears to be skewed by the effects of one small forced oxidation system in
the Northeast, which reports very high labor costs and relatively high waste disposal
costs. The former is most likely an artifact of the small plant size (operating labor
expressed in dollars/MWh should realize a significant economy of scale as FGD system
size increases). The latter is most likely an effect of the FGD system being located in a
heavily populated area but not near a wallboard plant.
Looking at the overall population of medium-sulfur-coal systems in Table B-7, there are
a few outliers in the “high” and “low” value data that warrant mention. The high
reagent cost system is the one Mg-lime system, as might have been expected. This
system is also located in a heavily populated area in the Northeast, and thus
experiences the highest waste disposal cost. Finally, this system uses a venturi contactor
to effect both particulate and SO2 control, and thus represents the high end of the range
in auxiliary power consumption percentage as well. The two spray dryer FGD systems
represent the low end of the auxiliary power consumption percentages.
Low-Sulfur Coal
Surprisingly, the largest numbers of FGD systems that reported cost data on the Form
EIA-767 are installed on units that fire low-sulfur coals. A total of 68 low-sulfur-coal
systems reported cost data, representing 5 forced oxidation limestone systems, 25
inhibited or natural oxidation limestone systems, 12 wet lime reagent systems, 13 wet
systems that use alkaline ash as a reagent (some are supplemented with lime or
limestone), and 13 lime/alkaline ash spray dryer FGD systems. The cost data for these
systems are presented in Tables B-8 through B-12.
Comparing the costs reported in Tables B-8 through B-12, the average O&M costs for
the low-sulfur-coal systems do not vary widely when expressed in terms of
dollars/MWh. The highest average cost of $0.92/MWh was reported for the wet lime
reagent systems, and the lowest average cost of $0.58/MWh was reported for the
alkaline ash reagent systems. About half of the difference between these two values is
due to the effects of reagent cost. Note that several of the alkaline ash systems are
supplemented with lime or limestone reagent, but reagent consumption is presumably
reduced below the stoichiometric requirement by the contributions of the alkalinity in
the ash. This explains why the reagent costs for these systems are not essentially zero.
Also in comparing the information in the tables, it is apparent that the limestone/forced
oxidation FGD systems are on average the newest, and treat the highest average coal
sulfur content. The wet alkaline ash reagent systems are on average the oldest, smallest,
and also consume the highest percentage of the power plant net generation. The latter
B-15
is because most of these systems use venturi contactors to effect simultaneous ash and
SO2 control.
Another interesting point about the low-sulfur-coal data is that there is a very narrow
range in the reported average costs for labor and supervision, and for maintenance,
materials, and other costs. The former varies only from $0.20/MWh to $0.36/MWh, and
the latter varies only from $0.21/MWh to $0.33/MWh.
Table B-8
Costs for Low-Sulfur, Limestone/Forced Oxidation FGD Systems
Waste Disposal* $0.061 $0.071 ($0.010)
Unit Size, MW 475 1147** 176
Average In-Service Date Mar-88 Dec-82 Jun-96
units.
*For plants that reported waste disposal costs separately.
**Multiple units at one station that reported FGD costs as an aggregate.
B-16
Table B-9
Costs for Low-Sulfur, Limestone/Inhibited or Natural Oxidation FGD Systems
Waste Disposal* $0.049 $0.162 $0.003
Unit Size, MW 505 2380** 195
Average In-Service Date May-82 Jun-73 Jun-96
units.
B-17
Table B-10
Costs for Low-Sulfur, Wet Lime FGD Systems
Waste Disposal* $0.023 $0.058 $0.000
Average In-Service Date May-78 Jan-72 Jan-85
units.
B-18
Table B-11
Costs for Low-Sulfur, Wet, Alkaline Ash Reagent FGD Systems
Waste Disposal* $0.050 $0.101 $0.020
Average In-Service Date Jul-75 Jun-69 Apr-86
units.
B-19
Table B-12
Costs for Low-Sulfur, Spray Dryer FGD Systems
Waste Disposal* $0.056 $0.226 $0.000
Unit Size, MW 423 1046** 172
Average In-Service Date May-85 Jun-82 Jun-90
Aux. Power, % of net Generation 0.8% 1.7% 0.3%
units.
B-20

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FGD Optimization Workbook

Final Report, July 1998

EPRI Project Manager

ORGANIZATION(S) THAT PREPARED THIS REPORT

Radian International LLC

This report was prepared by

Radiation International, LLC

This report describes research sponsored by EPRI.

FGD Optimization Workbook. EPRI, Palo Alto, CA: 1998. TR-111118.

1 INTRODUCTION ................................................................................................................. 1-1

2 IDENTIFYING POTENTIAL SAVINGS ................................................................................ 2-1

3 COST SAVINGS STRATEGIES .......................................................................................... 3-1

Description of Strategy.................................................................................................. 3-44

Example Economics...................................................................................................... 3-79

4 CASE STUDIES .................................................................................................................. 4-1

Option 1 - Reduce Ball Mill Throughput..................................................................... 4-31

5 BIBLIOGRAPHY ................................................................................................................. 5-1

A RESULTS OF PROJECT-SPECIFIC FGD COST SURVEY ...............................................A-1

B RESULTS FROM DEPARTMENT OF ENERGY COST SURVEY ......................................B-1

Figure 3-1 Percent SO2 Removal Versus NTU...................................................................... 3-6

As electric utilities enter a more competitive environment, every aspect of electric

x Develop and implement a plan to develop system-specific data to better determine

x Identify EPRI publications and products, and other publications available to

Benchmarking Data Sources

Section 3 describes approximately 20 strategies that might be applied to reduce FGD

How to Use This Workbook

x Auxiliary power consumption.

x Maintenance labor and materials.

x Byproduct sales or disposal costs.

Absorber recycle pump power requirements are proportional to the number of

The potential amount of savings achievable by reducing FGD auxiliary power

The total annual power cost is calculated as:

A. Total annual auxiliary power consumed by the FGD system:__________(MWh).

B. Cost of auxiliary power:__________($/MWh).

C. Total annual cost of auxiliary power (A x B):__________($/year).

D. Station annual net generation:__________(MWh).

E. Specific auxiliary power consumption (A/D x 100):_________(%).

F. Survey results:__________% (median)__________%(low)__________%(high).

Strategies for reducing auxiliary power consumption generally focus on scrubber

Scrubber Booster Fans

x Adding performance additives or increasing performance additive concentrations,

Absorber Recycle Pumps

Absorber recycle pump power consumption is typically a function of the number of

Performance Additives – Can be added to systems not currently using performance

Module revisions – Modifications such as tray retrofits or nozzle/header revisions in

Oxidation Air Compressors

A. Annual alkali reagent consumption by the FGD system:__________(tons).

B. Average delivered cost per ton:__________($/ton).

C. Annual alkali reagent cost (A x B):__________($/year).

D. Average laboratory reagent utilization:__________(%).

E. Reagent ratio (100/D):__________(unitless).

F. Average reagent purity:__________(%).

H. Moles of reagent consumed (A x 2000 x F/100/G):__________(lb-moles).

I. Tons of SO2 removed by the FGD system:__________(tons).

J. Moles of SO2 removed by the FGD system (I x 2000 / 64):__________(lb-moles).

K. Reagent ratio (H/J):__________(unitless).

L. Potential savings (A x [E {or K} – 1.02] x B):__________($/year).

Improved pH Control – Reagent is often wasted because the absorber recirculating

Improvements in pH control may increase operator or maintenance labor to implement,

Improved Limestone Fineness – If a finer limestone grind is fed to the absorbers, SO 2

Improved limestone fineness is typically achieved by changes in the limestone grinding

Performance Additives – The use of performance additives such as dibasic acid or

Many limestones have a measurable magnesium content. In some stones this

F. Survey results:% (median)%(low)__%(high).