1. A Recent Case Study of Wet FGD Performance Improvements At B.L. England Unit 2 using ALRD® Technology Presenters: Amy Evans, Marsulex Environmental Technologies Dennis Del Vecchio, NAES Corporation

2. Acknowledgments BL England Staff & Management Eric Adolfsen | BL England Plant Engineer Dennis Prichett | BL England Scrubber Supervisor Authors Mike Hammer | Marsulex Environment Technologies Amy Evans | Marsulex Environment Technologies Dennis Del Vecchio | NAES / RC Cape May Holdings Gary Andes | WorleyParsons

3. Agenda Plant Background and Administrative Consent Order (ACO) Upgrade Options Implementation and Constructability Performance Results Conclusions

4. B.L. England Cape May County, NJ on the Great Egg Harbor River 450 MW plant 3 generating units (2 coal, 1 oil) Unit 2 155 MW, balanced draft Equipped with FGD, ESP, LNB, SNCR Eastern bituminous coal (3.2% S) FGD LSFO Wallboard grade gyp, sold locally Retrofitted in 1994 with open spray tower WFGD system Designed for 93% SO2 removal

7. Do not adversely impact particulate emissions

10. Solves flue gas “sneakage” along absorber wallMinimal effect on flue gas pressure drop

11. ALRD Technology Recommended technology for B.L. England Unit 2: Two ALRD levels determined to meet removal requirements Could be incorporated into two scheduled outages Determined most cost and schedule effective method

13. Carbon Steel mounting plate welded to Alloy support brackets.

14. ALRD Plates laser cut in the shop

15. Field Details:

16. Carbon Steel mounting plates eliminated the need for certified alloy welders in the field

17. Better fit-up and quality controlDesign included two ALRD levels with support brackets & rubber lining

19. 2nd and 3rd absorber spray levels

20. 30 brackets and 28sections

21. Level 2

22. 3rd and 4th absorber spray levels

24. ALRD level 1 was installed during Spring 2010 outage, 25 days

26. Project Organization Chart

27. Phased Approach Work Schedule

28. Constructability Developed execution plan during proposal Reviewed contractor and owner safety plan, described construction work plan, resource histogram, reporting and tracking requirements All workers attended a Site safety orientation presentation Fire blankets and fire watch were critical for a rubber-lined vessel Workers required to wear harnesses when in vessel for protection from falling Workers used the “Buddy System” to help insure a safe working environment Project risks reviewed and mitigation strategies implemented

31. Positioning precarious

32. Needed to protect rubber lining on pipe header, spray nozzles, and absorber vessel walls

36. Execution of Work Tower scaffolding was installed on top of the spray headers and the attachment plate locations were laid out The rubber lining was removed

37. Execution of Work The shell was prepped for welding The bracket was made of CS base plate and shop welded to the alloy bracket for easy field welding

38. Execution of Work All of the support brackets were installed and aligned using the actual plates All welding was completed before any of the rubber lining efforts were began

39. Execution of Work The ALRD support bracket shell and rubber lining was beveled to ensure proper lining profile All the lining efforts were completed before the plates were installed

40. Execution of Work The plates were installed, bolting was selected as the preferred method of attachment The plate was lined to seal it to the wall to ensure all the liquid running down the wall could be re-entrained

41. Execution of Work The work area was cramped but all work was performed without incident or any lost time

42. Performance Results System operated to meet the 0.15 lbs SO2/MMBtu after May 1st

43. Performance Results System operated to meet the 0.15 lbs SO2/MMBtu on 30 day rolling average courtesy of EPA's Clean Air Markets Division

45. Outlet Emission of 0.15 lbs SO2/MMBtu is achieved

46. No noticeable increase in pressure drop