5-1

5. Emission Control Technologies

EPA Base Case v.5.13 includes an update of emission control technology assumptions. EPA contracted 

with engineering firm Sargent and Lundy to update and add to the retrofit emission control models 

previously developed for EPA and used in EPA Base Case v.4.10. EPA Base Case v.5.13 thus includes 

updated assumptions regarding control options for sulfur dioxide (SO2), nitrogen oxides (NOx), mercury 

(Hg), and particulate matter (PM). These emission control options are listed in Table 5-1. They are 

available in EPA Base Case v.5.13 for meeting existing and potential federal, regional, and state emission 

limits. It is important to note that, besides the emission control options shown in Table 5-1 and described 

in this chapter, EPA Base Case v.5.13 offers other compliance options for meeting emission limits. These 

include fuel switching, adjustments in the dispatching of electric generating units, and the option to retire 

a unit.

Table 5-1 Summary of Emission Control Technology Retrofit Options in EPA Base Case v.5.13

SO2 and HCl 

Control 

Technology 

Options

NOx Control 

Technology Options

Mercury Control 

Technology Options

Particulate Matter 

Control Technology 

Options

CO2 Control 

Technology 

Options

Limestone Forced 

Oxidation (LSFO) 

Scrubber

Selective Catalytic 

Reduction (SCR) 

System

Activated Carbon 

Injection (ACI) System

Pulse-Jet Fabric Filter 

(FF)

CO2 Capture and 

Sequestration

Lime Spray Dryer 

(LSD) Scrubber

Selective NonCatalytic Reduction 

(SNCR) System

SO2 and NOx Control 

Technology Removal 

Co-benefits

Electrostatic 

Precipitator (ESP) 

Upgrade Adjustment

Coal-to-Gas 

Conversion

Dry Sorbent 

Injection (DSI) Combustion Controls Heat Rate Improvement

FGD Upgrade 

Adjustment

Detailed reports and example calculation worksheets for Sargent & Lundy retrofit emission control models 

used by EPA are available in Attachments 5-1 through 5-7 at: www.epa.gov/airmarkets/progsregs/epaipm/BaseCasev513.html.

5.1 Sulfur Dioxide Control Technologies - Scrubbers

Two commercially available Flue Gas Desulfurization (FGD) “scrubber” technology options for removing 

the SO2 produced by coal-fired power plants are offered in EPA Base Case v.5.13: Limestone Forced 

Oxidation (LSFO) — a wet FGD technology and Lime Spray Dryer (LSD) — a semi-dry FGD technology 

which employs a spray dryer absorber (SDA). In wet FGD systems, the polluted gas stream is brought 

into contact with a liquid alkaline sorbent (typically limestone) by forcing it through a pool of the liquid 

slurry or by spraying it with the liquid. In dry FGD systems the polluted gas stream is brought into contact 

with the alkaline sorbent in a semi-dry state through use of a spray dryer. The removal efficiency for SDA 

drops steadily for coals whose SO2 content exceeds 3 lbs SO2/MMBtu, so this technology is provided only 

to plants which have the option to burn coals with sulfur content no greater than 3 lbs SO2/MMBtu. In 

EPA Base Casev.5.13 when a unit retrofits with an LSD SO2 scrubber, it loses the option of burning 

certain high sulfur content coals (see Table 5-2).

In EPA Base Case v.5.13 the LSFO and LSD SO2 emission control technologies are available to existing 

"unscrubbed" units. They are also available to existing "scrubbed" units with reported removal 

efficiencies of less than fifty percent. Such units are considered to have an injection technology and 

classified as “unscrubbed” for modeling purposes in the NEEDS database of existing units which is used 

in setting up the EPA base case. The scrubber retrofit costs for these units are the same as regular 

unscrubbed units retrofitting with a scrubber.
5-2

Default SO2 removal rates for wet and dry FGD were based on data reported in EIA 860 (2010). These 

default removal rates were the average of all SO2 removal rates for a dry or wet FGD as reported in EIA 

860 (2010) for the FGD installation year. 

To reduce the incidence of implausibly high, outlier removal rates, units whose reported EIA Form 860 

(2010) SO2 removal rates are higher than the average of the upper quartile of SO2 removal rates across 

all scrubbed units are instead assigned the upper quartile average unless the reported EIA 860 rate was 

recently confirmed by utility comments. One upper quartile removal rate is calculated across all 

installation years and replaces any reported removal rate that exceeds it no matter the installation year. 

Existing units not reporting FGD removal rates in form EIA 860 (2010) will be assigned the default SO2

removal rate for a dry or wet FGD for that installation year. 

As shown in Table 5-2, for FGD retrofits installed by the model, the assumed SO2 removal rates will be 

96% for wet FGD and 92% for dry FGD. These are the average of the SO2 removal efficiencies reported 

in EIA 860 (2008) for dry and wet FGD installed in 2008 or later. These rates have been subjected to 

numerous reviews from utilities and other stakeholders recently, so they remain unchanged and continue 

to be used in EPA Base Case v.5.13.

The procedures used to derive the cost of each scrubber type are discussed in detail in the following 

sections.

Table 5-2 Summary of Retrofit SO2 Emission Control Performance

Assumptions in Base Case v.5.13

Performance 

Assumptions Limestone Forced Oxidation (LSFO) Lime Spray Dryer (LSD)

Percent Removal 96%

with a floor of 0.06 lbs/MMBtu

92%

with a floor of 0.08 lbs/MMBtu

Capacity Penalty

Calculated based on characteristics of the unit:

See Table 5-3

Calculated based on characteristics 

of the unit:

See Table 5-3

Heat Rate Penalty

Cost (2011$)

Applicability Units ≥ 25 MW Units ≥ 25 MW

Sulfur Content 

Applicability Coals ≤ 3 lbs SO2/MMBtu1

Applicable Coal Types BA, BB, BD, BE, BG, BH, SA, SB, SD, SE, LD, LE, 

LG, LH, PK and WC

BA, BB, BD, BE, SA, SB, SD, SE, 

LD, and LE

1

FBC units burning WC and PK fuels are provided with LSD retrofit options

Potential (new) coal-fired units built by the model are also assumed to be constructed with a scrubber

achieving a removal efficiency of 96%. In EPA Base Case v.5.13 the costs of potential new coal units 

include the cost of scrubbers.

5.1.1 Methodology for Obtaining SO2 Controls Costs

Sargent and Lundy’s updated performance and cost models for wet and dry SO2 scrubbers are 

implemented in EPA Base Case v.5.13 to develop the capital, fixed O&M (FOM), and variable O&M 

(VOM) components of cost. See Attachments 5-1 and 5-2 ( www.epa.gov/airmarkets/progsregs/epaipm/BaseCasev513.html ).

Capacity and Heat Rate Penalty: In IPM the amount of electrical power required to operate a retrofit 

emission control device is represented through a reduction in the amount of electricity that is available for 

sale to the grid. For example, if 1.6% of the unit’s electrical generation is needed to operate the scrubber, 

the generating unit’s capacity is reduced by 1.6%. This is the “capacity penalty.” At the same time, to 

capture the total fuel used in generation both for sale to the grid and for internal load (i.e., for operating 
5-3

the control device), the unit’s heat rate is scaled up such that a comparable reduction (1.6% in the 

previous example) in the new higher heat rate yields the original heat rate24. The factor used to scale up 

the original heat rate is called “heat rate penalty.” It is a modeling procedure only and does not represent 

an increase in the unit’s actual heat rate (i.e., a decrease in the unit’s generation efficiency). In EPA Base 

Case v.5.13 specific LSFO and LSD heat rate and capacity penalties are calculated for each installation 

based on equations from the Sargent and Lundy models that take into account the rank of coal burned, its 

uncontrolled SO2 rate, and the heat rate of the model plant.

Table 5-3 presents the capital, VOM, and FOM costs as well as the capacity and heat rate penalty for two 

SO2 emission control technologies (LSFO and LSD) included in EPA Base Case v.5.13 for an illustrative 

set of generating units with a representative range of capacities and heat rates.

 

24 Mathematically, the relationship of the heat rate and capacity penalties (both expressed as positive percentage 

values) can be represented as follows: 

1 100

100

Capacity Penalty 1

1 Heat Rate Penalty
5-4

Table 5-3 Illustrative Scrubber Costs (2011$) for Representative Sizes and Heat Rates under the Assumptions in EPA Base Case v.5.13 

Scrubber 

Type

Heat Rate 

(Btu/kWh)

Capacity 

Penalty 

(%)

Heat Rate 

Penalty 

(%)

Variable O&M 

(mills/kWh)

Capacity (MW)

50 100 300 500 700 1000

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

LSFO

9,000 -1.50 1.53 2.03 819 23.7 819 23.7 600 11.2 519 8.3 471 7.7 426 6.4

10,000 -1.67 1.70 2.26 860 24.2 860 24.2 629 11.5 544 8.6 495 8.0 447 6.6

11,000 -1.84 1.87 2.49 899 24.6 899 24.6 658 11.8 569 8.9 517 8.2 467 6.8

LSD

9,000 -1.18 1.20 2.51 854 29.1 701 17.3 513 8.6 444 6.5 422 5.7 422 5.3

10,000 -1.32 1.33 2.79 894 29.6 734 17.7 538 8.9 465 6.8 442 5.9 442 5.5

11,000 -1.45 1.47 3.07 933 30.0 766 18.0 561 9.1 485 7.0 461 6.1 461 5.7

Note: The above cost estimates assume a boiler burning 3 lb/MMBtu SO2 Content Bituminous Coal for LSFO and 2 lb/MMBtu SO2 Content Bituminous Coal for LSD.
5-5

5.2 Nitrogen Oxides Control Technology

The EPA Base Case v.5.13 includes two categories of NOx reduction technologies: combustion and postcombustion controls. Combustion controls reduce NOx emissions during the combustion process by 

regulating flame characteristics such as temperature and fuel-air mixing. Post-combustion controls 

operate downstream of the combustion process and remove NOx emissions from the flue gas. All the 

specific combustion and post-combustion technologies included in EPA Base Case v.5.13 are 

commercially available and currently in use in numerous power plants.

5.2.1 Combustion Controls

The EPA Base Case v.5.13 representation of combustion controls uses equations that are tailored to the 

boiler type, coal type, and combustion controls already in place and allow appropriate additional 

combustion controls to be exogenously applied to generating units based on the NOx emission limits they 

face. Characterizations of the emission reductions provided by combustion controls are presented in 

Table 3-1.3 in Attachment 3-1. The EPA Base Case v.5.13 cost assumptions for NOx Combustion

Controls are summarized in Table 5-4. Table 3-11 provides a mapping of existing coal unit configurations 

and incremental combustion controls applied in EPA Base Case v.5.13 when units under certain 

conditions are assumed to achieve a state-of-the-art combustion control configuration.

Table 5-4 Cost (2011$) of NOx Combustion Controls for Coal Boilers (300 MW Size)

Boiler Type Technology

Capital

($/kW)

Fixed 

O&M

($/kW-yr)

Variable 

O&M

(mills/kWh)

Dry Bottom WallFired

Low NOx Burner without Overfire Air (LNB without OFA) 48 0.3 0.07

Low NOx Burner with Overfire Air (LNB with OFA) 65 0.5 0.09

Tangentially-Fired

Low NOx Coal-and-Air Nozzles with Close-Coupled 

Overfire Air (LNC1) 26 0.2 0.00

Low NOx Coal-and-Air Nozzles with Separated Overfire 

Air (LNC2) 35 0.2 0.03

Low NOx Coal-and-Air Nozzles with Close-Coupled and 

Separated Overfire Air (LNC3) 41 0.3 0.03

Vertically-Fired NOx Combustion Control 31 0.2 0.06

Scaling Factor

The following scaling factor is used to obtain the capital and fixed operating and maintenance costs applicable to the 

capacity (in MW) of the unit taking on combustion controls. No scaling factor is applied in calculating the variable 

operating and maintenance cost.

LNB without OFA & LNB with OFA = ($/kW for X MW Unit) = ($/kW for 300 MW Unit) x (300/X)

0.359

LNC1, LNC2, and LNC3 = ($/kW for X MW Unit) = ($/kW for 300 MW Unit) x (300/X)

0.359

Vertically-Fired = ($/kW for X MW Unit) = ($/kW for 300 MW Unit) x (300/X)

0.553

where ($/kW for 300 MW Unit) is a value from the above table and X is the capacity (in MW) of the unit taking on 

combustion controls.

5.2.2 Post-combustion NOx Controls

The EPA Base Case v.5.13 includes two post-combustion retrofit NOx control technologies for existing 

coal units: Selective Catalytic Reduction (SCR) and Selective Non-Catalytic Reduction (SNCR). In EPA 

Base Case v.5.13 oil/gas steam units are eligible for SCR only. NOx reduction in a SCR system takes 

place by injecting ammonia (NH3) vapor into the flue gas stream where the NOx is reduced to nitrogen 

(N2) and water (H2O) abetted by passing over a catalyst bed typically containing titanium, vanadium 

oxides, molybdenum, and/or tungsten. As its name implies, SNCR operates without a catalyst. In SNCR 

a nitrogenous reducing agent (reagent), typically urea or ammonia, is injected into, and mixed with, hot 

flue gas where it reacts with the NOx in the gas stream reducing it to nitrogen gas and water vapor. Due 
5-6

to the presence of a catalyst, SCR can achieve greater NOx reductions than SNCR. However, SCR costs 

are higher than SNCR costs.

Table 5-5 summarizes the performance and applicability assumptions in EPA Base Case v.5.13 for each 

post-combustion NOx control technology and provides a cross-reference to information on cost 

assumptions.

Table 5-5 Summary of Retrofit NOx Emission Control Performance Assumptions

Control Performance 

Assumptions

Selective Catalytic Reduction

(SCR)

Selective Non-Catalytic 

Reduction

(SNCR)

Unit Type Coal Oil/Gas Coal

Percent Removal 90% 80%

Pulverized Coal: 25%

Fluidized Bed: 50%

Rate Floor

Bituminous: 0.07 lb/MMBtu

--

Pulverized Coal: 0.1 lb/MMBtu

Subbituminous and Lignite: 0.05 

lb/MMBtu Fluidized Bed: 0.08 lb/MMBtu

Size Applicability Units ≥ 25 MW Units ≥ 25 

MW

Pulverized Coal: Units ≥ 25 MW 

and ≤ 100 MW

Fluidized Bed: Units ≥ 25 MW

Costs (2011$)

See Table 5-6 Illustrative Postcombustion NOx Control 

Costs (2011$) for Coal Plants 

for Representative Sizes and 

Heat Rates under the 

Assumptions in EPA Base 

Case v.5.13

See Table 

5-7

See Table 5-6 Illustrative Postcombustion NOx Control Costs 

(2011$) for Coal Plants for 

Representative Sizes and Heat 

Rates under the Assumptions 

in EPA Base Case v.5.13

5.2.3 Methodology for Obtaining SCR Costs for Coal 

Sargent and Lundy’s updated performance/cost models for SCR and SNCR technologies are 

implemented in EPA Base Case v.5.13 to develop the capital, fixed O&M (FOM), and variable O&M 

(VOM) components of cost. See Attachments 5-3 and 5-4 ( www.epa.gov/airmarkets/progsregs/epaipm/BaseCasev513.html ).

Table 5-6 presents the SCR and SNCR capital, VOM, and FOM costs and capacity and heat rate 

penalties for an illustrative set of coal generating units with a representative range of capacities and heat 

rates. 
5-7

Table 5-6 Illustrative Post-combustion NOx Control Costs (2011$) for Coal Plants for Representative Sizes and Heat Rates under the 

Assumptions in EPA Base Case v.5.13 

Control 

Type

Heat Rate 

(Btu/kWh)

Capacity 

Penalty 

(%)

Heat Rate 

Penalty 

(%)

Variable O&M 

(mills/kWh)

Capacity (MW)

100 300 500 700 1000

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

SCR

9,000 -0.54 0.54 1.23 321 1.76 263 0.76 243 0.64 232 0.58 222 0.53

10,000 -0.56 0.56 1.32 349 1.86 287 0.81 266 0.69 255 0.63 244 0.57

11,000 -0.58 0.59 1.41 377 1.96 311 0.87 289 0.73 277 0.67 265 0.62

SNCR -

Tangential

9,000

-0.05 0.78

1.04 55 0.48 30 0.26 22 0.20 18 0.16 15 0.13

10,000 1.15 56 0.50 30 0.27 23 0.20 19 0.17 15 0.14

11,000 1.27 57 0.51 31 0.27 23 0.21 19 0.17 16 0.14

SNCR -

Fluidized 

Bed

9,000

-0.05 0.78

1.04 41 0.36 22 0.20 17 0.15 14 0.12 11 0.10

10,000 1.15 42 0.37 23 0.20 17 0.15 14 0.12 12 0.10

11,000 1.27 43 0.38 23 0.21 17 0.15 14 0.13 12 0.10

Note: Assumes a boiler burning bituminous coal with an input NOx rate of 0.5 lbs/MMBtu. The technology is applied to boilers larger than 25 MW.
5-8

5.2.4 Methodology for Obtaining SCR Costs for Oil/Gas Steam Units

The cost calculations for SCR described in section 5.2.2 apply to coal units. For SCR on oil/gas steam 

units the cost calculation procedure shown in Table 5-7 is used in EPA Base Case v.5.13. The scaling 

factor for capital and fixed O&M costs, described in footnote a, applies to all size units from 25 MW and 

up.

Table 5-7 Post-Combustion NOx Controls for Oil/Gas Steam Units in EPA Base Case v.5.13

Post-Combustion 

Control Technology

Capital

($/kW)

Fixed O&M

($/kW-yr)

Variable O&M

($/MWh)

Percent

Removal

SCRa80 1.16 0.13 80%

Notes:

The “Coefficients” in the table above are multiplied by the terms below to determine costs.

“MW” in the terms below is the unit’s capacity in megawatts.

Cost data are adjusted to 2011$ by EPA.

a SCR Cost Equations:

SCR Capital Cost and Fixed O&M: (200/MW)0.35

The scaling factors shown above apply up to 500 MW. The cost obtained for a 500 MW unit applies for units larger than 500 MW.

Example for 275 MW unit:

SCR Capital Cost ($/kW) = 80 * (200/275)0.35 ≈ 71.64 $/kW

SCR FOM Cost ($/kW-yr) = 1.16 * (200/275)0.35 ≈ 1.04 $/kW-yr

SCR VOM Cost ($/MWh) = 0.13 $/MWh

5.2.5 Methodology for Obtaining SNCR Costs

In the Sargent and Lundy’s cost update for SNCR a generic NOx removal efficiency of 25% is assumed. 

However, the capital, fixed and variable operating and maintenance costs of SNCR on circulating 

fluidized bed (CFB) units are distinguished from the corresponding costs for other boiler types (e.g. 

cyclone, and wall fired). As with SCR an air heater modification cost applies for plants that burn 

bituminous coal whose SO2 content is 3 lbs/MMBtu or greater. 

5.2.6 SO2 and NOx Controls for Units with Capacities from 25 MW to 100 MW (25 MW ≤ capacity 

< 100 MW)

In EPA Base Case v.5.13 coal units with capacities between 25 MW and 100 MW are offered the same 

SO2 and NOx emission control options as larger units. However, for purposes of modeling, the costs of 

controls for these units are assumed to be equivalent to that of a 100 MW unit for SCR, 50 MW for Dry 

FGD, and 100 MW for Wet FGD. These assumptions are based on several considerations. First, to 

achieve economies of scale, several units in this size range are likely to be ducted to share a single 

common control, so the minimum capacity cost equivalency assumption, though generic, would be 

technically plausible. Second, single units in this size range that are not grouped to achieve economies 

of scale are likely to have the option of hybrid multi-pollutant controls currently under development.25 

These hybrid controls achieve cost economies by combining SO2, NOx and particulate controls into a 

single control unit. Singly, the costs of the individual control would be higher for units below 100 MW than 

for a 100 MW unit, but when combined in the Multi-Pollutant Technologies (MPTs) their costs would be 

roughly equivalent to the cost of individual controls on a 100 MW unit. While MPTs are not explicitly 

represented in EPA Base Case v.5.13, single units in the 25-100 MW range that take on combinations of 

SO2 and NOx controls in a model run can be thought of as being retrofitted with an MPT.

 

25 See, for example, the Greenidge Multi-Pollutant Control Project, which was part of the U.S. Department of Energy, 

National Energy Technology Lab’s Power Plant Improvement Initiative. A joint effort of CONSOL Energy Inc. AES 

Greenidge LLC, and Babcock Power Environmental, Inc., the project is described in greater detail at 

www.netl.doe.gov/technologies/coalpower/cctc/PPII/bibliography/demonstration/environmental/bib_greenidge.html.
5-9

Illustrative SCR costs for 25-100 MW coal units with a range of heat rates can be found by referring to the 

100 MW “Capital Costs ($/kW)” and “Fixed O&M” columns in Table 5-6 and illustrative scrubber costs for 

25-100 MW coal units with a range of heat rates can be found by referring to the LSFO 100 MW and LSD 

50MW “Capital Costs ($/kW)” and “Fixed O&M” columns in Table 5-3. The Variable O&M cost 

component, which applies to units regardless of size, can be found in the fifth column in these tables.

5.3 Biomass Co-firing

Biomass co-firing is provided as a fuel choice for all coal-fired power plants in EPA Base Case v.5.13. 

However, logistics and boiler engineering considerations place limits on the extent of biomass that can be 

fired. The logistic considerations arise because it is only economic to transport biomass a limited 

distance from where it is grown given the low energy density of the fuel. In addition, the extent of storage 

that can be devoted at a power plant to this relatively low density fuel is another limiting factor. Boiler 

efficiency and other engineering considerations, largely due to the relatively higher moisture content and 

lower heat content of biomass compared to fossil fuel, also plays a role in limiting the level of co-firing. 

In EPA Base Case v.5.13 the limit on biomass co-firing is expressed as the percentage of the facility level 

power output that is produced from biomass. Based on analysis by EPA’s power sector engineering staff, 

a maximum of 10% of the facility level power output (not to exceed 50 MW) can be fired by biomass in 

modeling projections. In EPA Base Case v.5.13 “facility level” is defined as the set of generating units 

which share the same ORIS code26 in NEEDS v.5.13. 

The capital and FOM cost assumptions informing EPA Base Case v.5.13 regarding biomass co-firing are 

summarized in Table 5-8, developed by EPA’s power sector engineering staff and updated to 2011$.27

Table 5-8 Biomass Co-firing for Coal Plants

Output From Biomass (MW) 5 10 15 20 25 30 35 40 45 50

Capital Cost (2011$/kW From Biomass) 521 439 396 368 349 333 320 309 301 293

Fixed O&M (2011$/kW-yr) 25.8 17.3 12.5 10.0 8.5 11.8 10.6 9.5 8.6 8.0

In order to economize on model space, instead of designing a biomass co-firing “retrofit” modification for 

units that would include direct representations of the capital and FOM costs shown in Table 5-8. The 

 

26 The ORIS plant locator code is a unique identifying number (originally assigned by the Office of Regulatory 

Information Systems from which the acronym derived). The ORIS code is given to power plants by EIA and remains 

unchanged ownership changes.

27 Among the studies consulted in developing these costs were: 

(a) Briggs, J. and J. M. Adams, Biomass Combustion Options for Steam Generation, Presented at Power-Gen 

97, Dallas, TX, December 9 – 11, 1997.

(b) Grusha, J and S. Woldehanna, K. McCarthy, and G. Heinz, Long Term Results from the First US Low NOx 

Conversion of a Tangential Lignite Fired Unit, presented at 24th International Technical Conference on 

Coal & Fuel Systems, Clearwater, FL., March 8 – 11, 1999.

(c) EPRI, Biomass Co-firing: Field Test Results: Summary of Results of the Bailly and Seward 

Demonstrations, Palo Alto, CA, supported by U.S. Department of Energy Division of Energy Efficiency and 

Renewable Energy, Washington D.C.; U.S. Department of Energy Division Federal Energy Technology 

Center, Pittsburgh PA; Northern Indiana Public Service Company, Merrillville, IN; and GPU Generation, 

Inc., Johnstown, PA: 1999. TR-113903.

(d) Laux S., J. Grusha, and D. Tillman, Co-firing of Biomass and Opportunity Fuels in Low NOx Burners, 

PowerGen 2000 - Orlando, FL, www.fwc.com/publications/tech_papers/powgen/pdfs/clrw_bio.pdf.

(e) Tillman, D. A., Co-firing Biomass for Greenhouse Gas Mitigation, presented at Power-Gen 99, New 

Orleans, LA, November 30 – December 1, 1999.

(f) Tillman, D. A. and P. Hus, Blending Opportunity Fuels with Coal for Efficiency and Environmental Benefit, 

presented at 25th International Technical Conference on Coal Utilization & Fuel Systems, Clearwater, FL., 

March 6 – 9, 2000
5-10

capital and FOM costs were implemented by in EPA Base Case v.5.13 as a $/MMBtu biomass fuel cost 

adder. The discrete costs shown in Table 5-8 are first represented as continuous exponential cost 

functions showing the FOM and capital costs for all biomass outputs between 0 and 50 MW in size. Then, 

for every coal generating unit represented in EPA Base Case 5.13, the annual payment to capital for the 

biomass co-firing capability was derived by multiplying the total capital cost obtained from the capital cost 

exponential function by a 12.1% capital charge rate for utility-owned units and a 16.47% capital charge 

rate for merchant units. The resulting value was added to the annual FOM cost obtained from the FOM 

exponential function to obtain the total annual cost for the biomass co-firing for each generating unit.

Then, the annual amount of fuel (in MMBtus) required for each generating unit was derived by multiplying 

the size of a unit (in MW) by its heat rate (in Btu/kWh) by its capacity factor (in percent) by 8,760 hours 

(i.e., the number of hours in a year). Dividing the resulting value by 1000 yielded the annual fuel required 

by the generating unit in MMBtus. Dividing this number into the previously calculated total annual cost for 

biomass co-firing capability resulted in the cost of biomass co-firing per MMBtu of biomass combusted. 

This was represented in IPM as a fuel cost adder incurred when a coal unit co-fires biomass. In this 

manner, the model’s decision process for determining biomass consumption takes into account not just 

the cost of the biomass fuel, but also the capital and FOM costs associated with biomass co-firing at the 

units in question.

Chapter 11 discusses factors related to the delivered cost of biomass fuel in EPA Base Case v.5.13.

5.4 Mercury Control Technologies

For any power plant, mercury emissions depend on the mercury content of the fuel used, the combustion 

and physical characteristics of the unit, and the emission control technologies deployed. In the absence of

activated carbon injection (ACI), mercury emission reductions below the mercury content of the fuel are 

strictly due to characteristics of the combustion process and incidental removal resulting from other 

pollution control technologies, e.g., the SO2, NOx, and particulate matter controls. The following 

discussion is divided into three parts. Sections 5.4.1 and 5.4.2 explain the two factors that determine 

mercury emissions that result from unit configurations lacking ACI under EPA Base Case v.5.13. Section 

5.4.1 discusses how mercury content of fuel is modeled in EPA Base Case v.5.13. Section 5.4.2 looks at 

the procedure used to capture the mercury reductions resulting from different unit and (non-mercury) 

control configurations. Section 5.4.4 explains the mercury emission control options that are available 

under EPA Base Case v.5.13. Each section indicates the data sources and methodology used. 

5.4.1 Mercury Content of Fuels

Coal: The assumptions in EPA Base Case v.5.13 on the mercury content of coal (and the majority of 

emission modification factors discussed below in Section 5.4.2) are derived from EPA’s “Information 

Collection Request for Electric Utility Steam Generating Unit Mercury Emissions Information Collection 

Effort” (ICR).28 A two-year effort initiated in 1998 and completed in 2000, the ICR had three main 

components: (1) identifying all coal-fired units owned and operated by publicly-owned utility companies, 

Federal power agencies, rural electric cooperatives, and investor-owned utility generating companies, (2) 

obtaining “accurate information on the amount of mercury contained in the as-fired coal used by each 

electric utility steam generating unit ... with a capacity greater than 25 megawatts electric [MWe]), as well 

as accurate information on the total amount of coal burned by each such unit,” and (3) obtaining data by 

coal sampling and stack testing at selected units to characterize mercury reductions from representative 

unit configurations. 

 

28 Data from the ICR can be found at http://www.epa.gov/ttn/atw/combust/utiltox/mercury.html.

In 2009, EPA collected some additional information regarding mecury through the Collection Effort for New and 

Existing Coal- and Oil-Fired Electricty Utility Steam Generating Units (EPA ICR No.2362.01 (OMB Control Number 

2060-0631), however the information collected was not similarly comprehensive and was thus not used to update 

mercury assumptions in this EPA base case. 
5-11

The ICR resulted in more than 40,000 data points indicating the coal type, sulfur content, mercury content 

and other characteristics of coal burned at coal-fired utility units greater than 25 MW. To make this data 

usable, these data points were first grouped by IPM coal types and IPM coal supply regions. IPM coal 

types divide bituminous, subbituminous, and lignite coal into different grades based on sulfur content. 

Oil, natural gas, and waste fuels: The EPA Base Case v.5.13 also includes assumptions on the mercury 

content for oil, gas and waste fuels, which were based on data derived from previous EPA analysis of 

mercury emissions from power plants.29 Table 5-9 provides a summary of the assumptions on the 

mercury content for oil, gas and waste fuels included in EPA Base Case v.5.13.

Table 5-9 Assumptions on Mercury Concentration in Non-Coal Fuel in EPA Base Case v.5.13 

Fuel Type Mercury Concentration (lbs/TBtu)

Oil 0.48

Natural Gas 0.00 a

Petroleum Coke 2.66 b

Biomass 0.57

Municipal Solid Waste 71.85

Geothermal Resource 2.97 - 3.7

Note:

a

The values appearing in this table are rounded to two decimal places. The zero value shown for natural gas is based on an EPA 

study that found a mercury content of 0.000138 lbs/TBtu. Values for geothermal resources represent a range.

b A previous computational error in the mercury emission factor for petroleum coke as presented in Table 6-3 of the EPA report 

titled Control of Mercury Emissions from Coal-fired Electric Utility Boilers: Interim Report Including Errata, 3-21-02 was corrected 

(from 23.18 lbs/TBtu to 2.66 lb/TBtu) based on re-examination of the 1999 ICR data for petroleum coke and implementation of a 

procedure for flagging and excluding outlier values above the 95 percentile value.

5.4.2 Mercury Emission Modification Factors 

Emission Modification Factors (EMFs) represent the mercury reductions attributable to the specific burner 

type and configuration of SO2, NOx, and particulate matter control devices at an electric generating unit. 

An EMF is the ratio of outlet mercury concentration to inlet mercury concentration, and depends on the 

unit's burner type, particulate control device, post-combustion NOx control and SO2 scrubber control. In 

other words, the mercury reduction achieved (relative to the inlet) during combustion and flue-gas 

treatment process is (1-EMF). The EMF varies by the type of coal (bituminous, subbituminous, and 

lignite) used during the combustion process. 

Deriving EMFs involves obtaining mercury inlet data by coal sampling and mercury emission data by 

stack testing at a representative set of coal units. As noted above, EPA's EMFs were initially based on 

1999 mercury ICR emission test data. More recent testing conducted by the EPA, DOE, and industry 

participants30 has provided a better understanding of mercury emissions from electric generating units 

and mercury capture in pollution control devices. Overall the 1999 ICR data revealed higher levels of 

mercury capture for bituminous coal-fired plants than for subbituminous and lignite coal-fired plants, and 

significant capture of ionic Hg in wet-FGD scrubbers. Additional mercury testing indicates that for 

bituminous coals, SCR systems have the ability to convert elemental Hg into ionic Hg and thus allow 

easier capture in a downstream wet-FGD scrubber. This understanding of mercury capture with SCRs is 

incorporated in EPA Base Case v.5.13 mercury EMFs for unit configurations with SCR and wet 

scrubbers.

 

29 Analysis of Emission Reduction Options for the Electric Power Industry,” Office of Air and Radiation, US EPA, 

March 1999.

30 For a detailed summary of emissions test data see Control of Emissions from Coal-Fired Electric Utility Boilers: An 

Update, EPA/Office of Research and Development, February 2005. This report can be found at 

www.epa.gov/ttnatw01/utility/hgwhitepaperfinal.pdf.
5-12

Table 5-10 below provides a summary of EMFs used in EPA Base Case v.5.13. Table 5-11 provides 

definitions of acronyms for existing controls that appear in
5-13

Table 5-16. Table 5-12 provides a key to the burner type designations appearing in
5-14

Table 5-16.

Table 5-10 Mercury Emission Modification Factors Used in EPA Base Case v.5.13

Burner 

Type Particulate Control

Post-combustion

Control - NOx

Post-combustion

Control - SO2

Bituminous 

EMF

Subbituminous 

EMF

Lignite 

EMF

Cyclone Cold Side ESP SCR None 0.64 0.97 1

Cyclone Cold Side ESP SCR Wet FGD 0.1 0.84 0.56

Cyclone Cold Side ESP SCR Dry FGD 0.64 0.65 1

Cyclone Cold Side ESP No SCR None 0.64 0.97 1

Cyclone Cold Side ESP No SCR Wet FGD 0.34 0.84 0.56

Cyclone Cold Side ESP No SCR Dry FGD 0.64 0.65 1

Cyclone Cold Side ESP + FF SCR None 0.2 0.75 1

Cyclone Cold Side ESP + FF SCR Wet FGD 0.1 0.3 0.56

Cyclone Cold Side ESP + FF SCR Dry FGD 0.05 0.75 1

Cyclone Cold Side ESP + FF No SCR None 0.2 0.75 1

Cyclone Cold Side ESP + FF No SCR Wet FGD 0.3 0.3 0.56

Cyclone Cold Side ESP + FF No SCR Dry FGD 0.05 0.75 1

Cyclone Cold Side ESP + 

FGC SCR None 0.64 0.97 1

Cyclone Cold Side ESP + 

FGC SCR Wet FGD 0.1 0.84 0.56

Cyclone Cold Side ESP + 

FGC SCR Dry FGD 0.64 0.65 1

Cyclone Cold Side ESP + 

FGC No SCR None 0.64 0.97 1

Cyclone Cold Side ESP + 

FGC No SCR Wet FGD 0.34 0.84 0.56

Cyclone Cold Side ESP + 

FGC No SCR Dry FGD 0.64 0.65 1

Cyclone Cold Side ESP + 

FGC + FF SCR None 0.2 0.75 1

Cyclone Cold Side ESP + 

FGC + FF SCR Wet FGD 0.1 0.3 0.56

Cyclone Cold Side ESP + 

FGC + FF SCR Dry FGD 0.1 0.3 0.56

Cyclone Cold Side ESP + 

FGC + FF No SCR None 0.2 0.75 1

Cyclone Cold Side ESP + 

FGC + FF No SCR Wet FGD 0.1 0.3 0.56

Cyclone Cold Side ESP + 

FGC + FF No SCR Dry FGD 0.1 0.3 0.56

Cyclone Fabric Filter SCR None 0.11 0.27 1

Cyclone Fabric Filter SCR Wet FGD 0.1 0.27 0.56

Cyclone Fabric Filter SCR Dry FGD 0.05 0.75 1

Cyclone Fabric Filter No SCR None 0.11 0.27 1

Cyclone Fabric Filter No SCR Wet FGD 0.1 0.27 0.56

Cyclone Fabric Filter No SCR Dry FGD 0.05 0.75 1

Cyclone Hot Side ESP SCR None 0.9 0.9 1

Cyclone Hot Side ESP SCR Wet FGD 0.1 0.8 1

Cyclone Hot Side ESP SCR Dry FGD 0.6 0.85 1

Cyclone Hot Side ESP No SCR None 0.9 0.94 1

Cyclone Hot Side ESP No SCR Wet FGD 0.58 0.8 1

Cyclone Hot Side ESP No SCR Dry FGD 0.6 0.85 1

Cyclone Hot Side ESP + FF SCR None 0.11 0.27 1

Cyclone Hot Side ESP + FF SCR Wet FGD 0.1 0.15 0.56

Cyclone Hot Side ESP + FF SCR Dry FGD 0.05 0.75 1

Cyclone Hot Side ESP + FF No SCR None 0.11 0.27 1

Cyclone Hot Side ESP + FF No SCR Wet FGD 0.03 0.27 0.56

Cyclone Hot Side ESP + FF No SCR Dry FGD 0.05 0.75 1

Cyclone Hot Side ESP + FGC SCR None 0.9 0.9 1

Cyclone Hot Side ESP + FGC SCR Wet FGD 0.1 0.8 1

Cyclone Hot Side ESP + FGC SCR Dry FGD 0.6 0.85 1

Cyclone Hot Side ESP + FGC No SCR None 0.9 0.94 1

Cyclone Hot Side ESP + FGC No SCR Wet FGD 0.58 0.8 1

Cyclone Hot Side ESP + FGC No SCR Dry FGD 0.6 0.85 1
5-15

Burner 

Type Particulate Control

Post-combustion

Control - NOx

Post-combustion

Control - SO2

Bituminous 

EMF

Subbituminous 

EMF

Lignite 

EMF

Cyclone No Control SCR Wet FGD 0.1 0.7 1

Cyclone No Control No SCR Wet FGD 0.1 0.7 1

FBC Cold Side ESP No SCR None 0.65 0.65 0.62

FBC Cold Side ESP No SCR Dry FGD 0.64 0.65 1

FBC Cold Side ESP + FF No SCR None 0.05 0.43 0.43

FBC Cold Side ESP + FF No SCR Dry FGD 0.05 0.75 1

FBC Fabric Filter SCR None 0.11 0.27 1

FBC Fabric Filter SCR Dry FGD 0.05 0.75 1

FBC Fabric Filter No SCR None 0.05 0.43 0.43

FBC Fabric Filter No SCR Dry FGD 0.05 0.43 0.43

FBC Hot Side ESP + FGC No SCR None 1 1 1

FBC Hot Side ESP + FGC No SCR Dry FGD 0.6 0.85 1

FBC No Control No SCR None 1 1 1

PC Cold Side ESP SCR None 0.64 0.97 1

PC Cold Side ESP SCR Wet FGD 0.1 0.84 0.56

PC Cold Side ESP SCR Dry FGD 0.64 0.65 1

PC Cold Side ESP No SCR None 0.64 0.97 1

PC Cold Side ESP No SCR Wet FGD 0.34 0.84 0.56

PC Cold Side ESP No SCR Dry FGD 0.64 0.65 1

PC Cold Side ESP + FF SCR None 0.2 0.75 1

PC Cold Side ESP + FF SCR Wet FGD 0.1 0.3 0.56

PC Cold Side ESP + FF SCR Dry FGD 0.05 0.75 1

PC Cold Side ESP + FF No SCR None 0.2 0.75 1

PC Cold Side ESP + FF No SCR Wet FGD 0.3 0.3 0.56

PC Cold Side ESP + FF No SCR Dry FGD 0.05 0.75 1

PC Cold Side ESP + 

FGC SCR None 0.64 0.97 1

PC Cold Side ESP + 

FGC SCR Wet FGD 0.1 0.84 0.56

PC Cold Side ESP + 

FGC SCR Dry FGD 0.64 0.65 1

PC Cold Side ESP + 

FGC No SCR None 0.64 0.97 1

PC Cold Side ESP + 

FGC No SCR Wet FGD 0.34 0.84 0.56

PC Cold Side ESP + 

FGC No SCR Dry FGD 0.64 0.65 1

PC Cold Side ESP + 

FGC + FF SCR None 0.2 0.75 1

PC Cold Side ESP + 

FGC + FF SCR Wet FGD 0.1 0.3 0.56

PC Cold Side ESP + 

FGC + FF SCR Dry FGD 0.05 0.75 1

PC Cold Side ESP + 

FGC + FF No SCR None 0.2 0.75 1

PC Cold Side ESP + 

FGC + FF No SCR Wet FGD 0.3 0.3 0.56

PC Cold Side ESP + 

FGC + FF No SCR Dry FGD 0.05 0.75 1

PC Fabric Filter SCR None 0.11 0.27 1

PC Fabric Filter SCR Wet FGD 0.1 0.27 0.56

PC Fabric Filter SCR Dry FGD 0.05 0.75 1

PC Fabric Filter No SCR None 0.11 0.27 1

PC Fabric Filter No SCR Wet FGD 0.1 0.27 0.56

PC Fabric Filter No SCR Dry FGD 0.05 0.75 1

PC Hot Side ESP SCR None 0.9 0.9 1

PC Hot Side ESP SCR Wet FGD 0.1 0.8 1

PC Hot Side ESP SCR Dry FGD 0.6 0.85 1

PC Hot Side ESP No SCR None 0.9 0.94 1

PC Hot Side ESP No SCR Wet FGD 0.58 0.8 1

PC Hot Side ESP No SCR Dry FGD 0.6 0.85 1

PC Hot Side ESP + FF SCR None 0.11 0.27 1

PC Hot Side ESP + FF SCR Wet FGD 0.1 0.15 0.56

PC Hot Side ESP + FF SCR Dry FGD 0.05 0.75 1
5-16

Burner 

Type Particulate Control

Post-combustion

Control - NOx

Post-combustion

Control - SO2

Bituminous 

EMF

Subbituminous 

EMF

Lignite 

EMF

PC Hot Side ESP + FF No SCR None 0.11 0.27 1

PC Hot Side ESP + FF No SCR Wet FGD 0.03 0.27 0.56

PC Hot Side ESP + FF No SCR Dry FGD 0.05 0.75 1

PC Hot Side ESP + FGC SCR None 0.9 0.9 1

PC Hot Side ESP + FGC SCR Wet FGD 0.1 0.8 1

PC Hot Side ESP + FGC SCR Dry FGD 0.6 0.85 1

PC Hot Side ESP + FGC No SCR None 0.9 0.94 1

PC Hot Side ESP + FGC No SCR Wet FGD 0.58 0.8 1

PC Hot Side ESP + FGC No SCR Dry FGD 0.6 0.85 1

PC Hot Side ESP + FGC 

+ FF SCR Dry FGD 0.05 0.75 1

PC Hot Side ESP + FGC 

+ FF No SCR None 0.11 0.27 1

PC Hot Side ESP + FGC 

+ FF No SCR Dry FGD 0.05 0.75 1

PC No Control SCR None 1 1 1

PC No Control SCR Wet FGD 0.1 0.7 1

PC No Control SCR Dry FGD 0.6 0.85 1

PC No Control No SCR None 1 1 1

PC No Control No SCR Wet FGD 0.58 0.7 1

PC No Control No SCR Dry FGD 0.6 0.85 1

PC PM Scrubber SCR None 0.9 1 1

PC PM Scrubber SCR Wet FGD 0.1 0.7 1

PC PM Scrubber SCR Dry FGD 0.6 0.85 1

PC PM Scrubber No SCR None 0.9 0.91 1

PC PM Scrubber No SCR Wet FGD 0.58 0.7 1

PC PM Scrubber No SCR Dry FGD 0.6 0.85 1

Table 5-11 Definition of Acronyms for Existing Controls

Acronym Description

ESP Electro Static Precipitator - Cold Side

HESP Electro Static Precipitator - Hot Side

ESP/O Electro Static Precipitator - Other

FF Fabric Filter

FGD Flue Gas Desulfurization - Wet

DS Flue Gas Desulfurization - Dry

SCR Selective Catalytic Reduction

PMSCRUB Particulate Matter Scrubber

Table 5-12 Key to Burner Type Designations in Table 5-10

“PC” refers to conventional pulverized coal boilers. Typical configurations include wall-fired and tangentially fired 

boilers (also called T-fired boilers). In wall-fired boilers the burner’s coal and air nozzles are mounted on a single wall 

or opposing walls. In tangentially fired boilers the burner’s coal and air nozzles are mounted in each corner of the 

boiler.

“Cyclone” refers to cyclone boilers where air and crushed coal are injected tangentially into the boiler through a 

“cyclone burner” and “cyclone barrel” which create a swirling motion allowing smaller coal particles to be burned in 

suspension and larger coal particles to be captured on the cyclone barrel wall where they are burned in molten slag.

“FBC" refers to “fluidized bed combustion” where solid fuels are suspended on upward-blowing jets of air, resulting in 

a turbulent mixing of gas and solids and a tumbling action which provides especially effective chemical reactions and 

heat transfer during the combustion process.
5-17

5.4.3 Mercury Control Capabilities

EPA Base Case v.5.13 offers two options for mercury pollution control: (1) combinations of SO2, NOx, and

particulate controls which deliver mercury reductions as a co-benefit and (2) Activated Carbon Injection

(ACI), a retrofit option specifically designed for mercury control. These two options are discussed below.

Mercury Control through SO2 and NOx Retrofits

In EPA Base Case v.5.13, units that install SO2, NOx, and particulate controls, reduce mercury emissions

as a byproduct of these retrofits. Section 5.4.2 described how EMFs are used in the base case to capture

mercury emissions depending on the rank of coal burned, the generating unit’s combustion characteristics,

and the specific configuration of SO2, NOx, and particulate controls (i.e., hot and cold-side electrostatic

precipitators (ESPs), fabric filters (also called “baghouses”) and particulate matter (PM) scrubbers).

Activated Carbon Injection (ACI)

The technology used for mercury control in EPA Base Case v.5.13 is Activated Carbon Injection (ACI) 

downstream of the combustion process in coal fired units. Sargent & Lundy’s updated cost and

performance assumptions for ACI are used. 

Three alternative ACI options are represented as capable of providing 90% mercury removal for all possible

configurations of boiler, emission controls, and coal types used in the U.S. electric power sector. The

three ACI options differ, based on whether they are used in conjunction with an electrostatic precipitator

(ESP) or a fabric filter (also called a “baghouse”). The three ACI options are:

ACI with Existing ESP

ACI with Existing Baghouse

ACI with an Additional Baghouse (also referred to as Toxecon)

In the third option listed above the additional baghouse is installed downstream of the pre-existing

particulate matter device and the activated carbon is injected after the existing controls. This configuration

allows the fly ash to be removed before it is contaminated by the mercury.

For modeling purposes, EPA currently assumes that all three configurations use brominated ACI, where a

small amount of bromine is chemically bonded to the powdered carbon which is injected into the flue gas

stream. EPA recognizes that amended silicates and possibly other non-carbon, non-brominated 

substances are in development and may become available as alternatives to brominated carbon as a 

mercury sorbent. 

The applicable ACI option depends on the coal type burned, its SO2 content, the boiler and particulate

control type and, in some instances, consideration of whether an SO2 scrubber (FGD) system and SCR

NOxpost-combustion control are present.
5-18

Table 5-13 shows the ACI assignment scheme used in EPA Base Case v.5.13 to achieve 90% mercury

removal.
5-19

Table 5-13 Assignment Scheme for Mercury Emissions Control Using Activated Carbon Injection 

(ACI) in EPA Base Case v.5.13

Air pollution controls Bituminous Coal Subbituminous Coal Lignite Coal

Burner 

Type Particulate Control Type

SCR 

System

FGD 

System

ACI 

Required?

Toxecon 

Required?

Sorbent Inj 

Rate

ACI 

Required?

Toxecon 

Required?

Sorbent Inj 

Rate

ACI 

Required?

Toxecon 

Required?

Sorbent Inj 

Rate

(lb/million 

acf)

(lb/million 

acf)

(lb/million 

acf)

FBC Cold Side ESP + Fabric Filter without FGC -- -- Yes No 2 Yes No 2 Yes No 2

FBC Cold Side ESP without FGC -- -- Yes No 5 Yes No 5 Yes No 5

FBC Fabric Filter -- Dry FGD No No 0 Yes No 2 Yes No 2

FBC Fabric Filter -- -- Yes No 2 Yes No 2 Yes No 2

FBC Hot Side ESP with FGC -- -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Cold Side ESP + Fabric Filter with FGC -- Dry FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter with FGC -- -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter with FGC -- Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter with FGC SCR -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter with FGC SCR Dry FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter with FGC SCR Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter without FGC -- Dry FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter without FGC -- -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter without FGC -- Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter without FGC SCR -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter without FGC SCR Dry FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP + Fabric Filter without FGC SCR Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Cold Side ESP with FGC -- Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Cold Side ESP with FGC -- -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Cold Side ESP with FGC -- Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Cold Side ESP with FGC SCR -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Cold Side ESP with FGC SCR Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Cold Side ESP with FGC SCR Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Cold Side ESP without FGC -- Dry FGD Yes No 5 Yes No 5 Yes No 5

Non-FBC Cold Side ESP without FGC -- -- Yes No 5 Yes No 5 Yes No 5

Non-FBC Cold Side ESP without FGC -- Wet FGD Yes No 5 Yes No 5 Yes No 5

Non-FBC Cold Side ESP without FGC SCR -- Yes No 5 Yes No 5 Yes No 5

Non-FBC Cold Side ESP without FGC SCR Dry FGD Yes No 5 Yes No 5 Yes No 5

Non-FBC Cold Side ESP without FGC SCR Wet FGD Yes No 5 Yes No 5 Yes No 5

Non-FBC Fabric Filter -- Dry FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Fabric Filter -- -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Fabric Filter -- Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Fabric Filter SCR Dry FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Fabric Filter SCR -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Fabric Filter SCR Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter with FGC -- -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter with FGC -- Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter with FGC -- Dry FGD No No 0 Yes No 2 Y(b) No 2

Non-FBC Hot Side ESP + Fabric Filter with FGC SCR Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter with FGC SCR Dry FGD No No 0 Yes No 2 Y(b) No 2

Non-FBC Hot Side ESP + Fabric Filter with FGC SCR -- Yes No 2 Yes No 2 Y(b) No 2

Non-FBC Hot Side ESP + Fabric Filter without FGC -- Dry FGD No No 0 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter without FGC -- -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter without FGC -- Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter without FGC SCR Dry FGD No No 0 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter without FGC SCR -- Yes No 2 Yes No 2 Yes No 2

Non-FBC Hot Side ESP + Fabric Filter without FGC SCR Wet FGD Yes No 2 Yes No 2 Yes No 2

Non-FBC Hot Side ESP with FGC -- Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP with FGC -- -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP with FGC -- Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP with FGC SCR Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP with FGC SCR -- Yes Yes 2 Yes Yes 2 Yes Yes 2
5-20

Air pollution controls Bituminous Coal Subbituminous Coal Lignite Coal

Burner 

Type Particulate Control Type

SCR 

System

FGD 

System

ACI 

Required?

Toxecon 

Required?

Sorbent Inj 

Rate

ACI 

Required?

Toxecon 

Required?

Sorbent Inj 

Rate

ACI 

Required?

Toxecon 

Required?

Sorbent Inj 

Rate

(lb/million 

acf)

(lb/million 

acf)

(lb/million 

acf)

Non-FBC Hot Side ESP with FGC SCR Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP without FGC -- Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP without FGC -- -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP without FGC -- Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP without FGC SCR Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP without FGC SCR -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC Hot Side ESP without FGC SCR Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC No Control -- Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC No Control -- -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC No Control -- Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC No Control SCR Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC No Control SCR -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC No Control SCR Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC PM Scrubber -- Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC PM Scrubber -- -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC PM Scrubber -- Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC PM Scrubber SCR Dry FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC PM Scrubber SCR -- Yes Yes 2 Yes Yes 2 Yes Yes 2

Non-FBC PM Scrubber SCR Wet FGD Yes Yes 2 Yes Yes 2 Yes Yes 2

5.4.4 Methodology for Obtaining ACI Control Costs

Sargent & Lundy’s ACI model assumes that the carbon feed rate dictates the size of the equipment and

resulting costs. The feed rate in turn is a function of the required removal (in this case 90%) and the type

of particulate control device. Sargent & Lundy established that a carbon feed rate of 5 pounds of carbon

injected for every 1,000,000 actual cubic feet per minute (acfm) of flue gas would provide the stipulated

90% mercury removal rate for units shown in Table 5-14 as qualifying for ACI systems with existing ESP.

For generating units with fabric filters a lower injection rate of 2 pound per million acfm is required.

Alternative sets of costs were developed for each of the three ACI options: ACI systems for units with

existing ESPs, ACI for units with existing fabric filters (baghouses), and the combined cost of ACI plus an 

additional baghouse for units that either have no existing particulate control or that require ACI plus a

baghouse in addition to their existing particulate control. There are various reasons that a combined ACI

plus additional baghouse would be required. These include situations where the existing ESP cannot

handle the additional particulate load associate with the ACI or where SO3injection is currently in use to

condition the flue gas for the ESP. Another cause for combined ACI and baghouse is use of PRB coal

whose combustion produces mostly elemental mercury, not ionic mercury, due to this coal’s low chlorine

content.

For the combined ACI and fabric filter option a full size baghouse with an air-to-cloth (A/C) ratio of 4.0 is

assumed, as opposed to a polishing baghouse with a 6.0 A/C ratio

31

.

Table 5-14 presents the capital, VOM, and FOM costs as well as the capacity and heat rate penalties for 

the three ACI options represented in EPA Base Case v.5.13. For each ACI option values are shown for 

an illustrative set of generating units with a representative range of capacities and heat rates. See 

Attachment 5-6 ( www.epa.gov/airmarkets/progsregs/epa-ipm/BaseCasev513.html ) for details on the 

Sargent & Lundy model of ACI for Hg control.

 

31 The “air-to-cloth” (A/C) ratio is the volumetric flow, (typically expressed in Actual Cubic Feet per Minute, ACFM) of flue gas 

entering the baghouse divided by the areas (typically in square feet) of fabric filter cloth in the baghouse. The lower the A/C ratio, 

e.g., A/C = 4.0 compared to A/C = 6.0, the greater area of the cloth required and the higher the cost for a given volumetric flow
5-21

5.5 Hydrogen Chloride (HCl) Control Technologies

The following sub-sections describe how HCl emissions from coal are represented in IPM for EPA Base 

Case v.5.13, the emission control technologies available for HCl removal, and the cost and performance

characteristics of these technologies.

5.5.1 Chlorine Content of Fuels

HCl emissions from the power sector result from the chlorine content of the coal that is combusted by 

electric generating units. Data on chlorine content of coals had been collected as part EPA’s 1999 

“Information Collection Request for Electric Utility Steam Generating Unit Mercury Emissions Information 

Collection Effort” (ICR 1999) described above in section 5.4.1 This data is incorporated into the model in 

order to provide the capability for EPA Base Case v.5.13 to project HCl emissions. The procedures used 

for this are presented below. 

Western subbituminous coal (such as that mined in the Powder River Basin) and lignite coal contain 

natural alkalinity in the form of non-glassy calcium oxide (CaO) and other alkaline and alkaline earth 

oxides. This fly ash (classified as ‘Class C’ fly ash) has a natural pH of 9 and higher and the natural 

alkalinity can effectively neutralize much of the HCl in the flue gas stream prior to the primary control 

device. 

Eastern bituminous coals, by contrast, tend to produce fly ash with lower natural alkalinity. Though 

bituminous fly ash (classified as ‘Class F’ fly ash) may contain calcium, it tends to be present in a glassy 

matrix and unavailable for acid-base neutralization reactions.

In order to assess the extent of expected natural neutralization, the 2010 ICR32 data was examined. 

According to that data, units burning some of the subbituminous coals without operating acid gas control 

technology emitted substantially lower HCl emissions than would otherwise be expected from the chlorine 

content of those coals The data also showed that some other units burning subbituminous or lignite coals 

with higher levels of Cl were achieving 50-85 % HCl control with only cold-side ESP (i.e., with no flue gas 

desulfurization or other acid gas control technology). Comparing the Cl content of the subbituminous 

coals modeled in IPM with the ICR results supports an assumption that combustion of those coals can 

expect to experience at least 75% natural HCl neutralization from the alkaline fly ash. Therefore, the HCl 

emissions from combustion of lignite and subbituminous coals are reduced by 75% in EPA Base Case 

v.5.13.

 

32 Collection Effort for New and Existing Coal- and Oil-Fired Electricty Utility Steam Generating Units (EPA ICR 

No.2362.01 (OMB Control Number 2060-0631)
5-22

Table 5-14 Illustrative Activated Carbon Injection (ACI) Costs (2011$) for Representative Sizes and Heat Rates

under the Assumptions in EPA Base Case v.5.13

Control Type

Heat Rate 

(Btu/kWh)

Capacity 

Penalty (%)

Heat Rate 

Penalty (%)

Variable O&M 

cost (mills/kWh)

Capacity (MW)

100 300 500 700 1000

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

ACI System with an 

Existing ESP 9,000 -0.10 0.10 2.19 37.89 0.32 14.90 0.13 9.65 0.08 7.25 0.06 5.35 0.04

10,000 -0.11 0.11 2.43 38.51 0.32 15.14 0.13 9.81 0.08 7.36 0.06 5.44 0.05

Sorbent Injection 

Rate of 5 lbs/million 

acfm

11,000 -0.12 0.12 2.68 39.07 0.33 15.35 0.13 9.95 0.08 7.47 0.06 5.52 0.05

ACI System with an 

Existing Baghouse 9,000 -0.04 0.04 1.57 33.03 0.28 12.98 0.11 8.41 0.07 6.32 0.05 4.66 0.04

10,000 -0.04 0.04 1.75 33.54 0.28 13.18 0.11 8.54 0.07 6.42 0.05 4.74 0.04

Sorbent Injection 

Rate of 2 lbs/million 

acfm

11,000 -0.05 0.05 1.92 34.02 0.29 13.38 0.11 8.66 0.07 6.51 0.06 4.81 0.04

ACI System with an 

Additional 

Baghouse

9,000 -0.64 0.64 0.47 291.26 1.02 219.74 0.77 195.35 0.68 181.36 0.63 167.98 0.59

10,000 -0.64 0.65 0.52 314.32 1.10 238.18 0.83 212.02 0.74 196.97 0.69 182.55 0.64

Sorbent Injection 

Rate of 2 lbs/million 

acfm

11,000 -0.65 0.65 0.57 336.91 1.18 256.26 0.90 228.37 0.80 212.28 0.74 196.83 0.69

Note: The above cost estimates assume bituminous coal consumption.
5-23

5.5.2 HCl Removal Rate Assumptions for Existing and Potential Units

SO2 emission controls on existing and new (potential) units provide the HCl reductions indicated in Table 

5-15. New supercritical pulverized coal units (column 3) that the model builds include FGD (wet or dry)

which is assumed to provide a 99% removal rate for HCl. For existing conventional pulverized coal units

with pre-existing FGD (column 5), the HCl removal rate is assumed to be 5% higher than the reported SO2

removal rate up to a maximum of 99% removal. In addition, for fluidized bed combustion units (column 4)

with no FGD and no fabric filter, the HCl removal rate is assumed to be the same as the SO2 removal rate

up to a maximum of 95%. FBCs with fabric filters are assumed to have an HCl removal rate of 95%.

Table 5-15 HCl Removal Rate Assumptions for Potential (New) and Existing Units

in EPA Base Case v.5.13

Potential (New) Existing Units with FGD

Gas Controls

Supercritical 

Pulverized Coal with 

Wet or Dry FGD

Fluidized Bed 

Combustion (FBC)

Conventional 

Pulverized Coal (CPC) 

with Wet or Dry FGD

Existing Coal Steam Units with 

FGD Upgrade Adjustment

HCl Removal

Rate 99%

Without fabric filter: 

Same as reported SO2

removal rate up to a 

maximum of

95%

−−−

With fabric filter: 95%

Reported SO2

removal rate +

5% up to a

maximum of

99%

If reported SO2 removal < 90%, unit 

incurs cost to upgrade FGD, so that 

SO2 removal is 90%. Then, the 

resulting HCl removal rate is 99%

−−−

If reported SO2

removal is ≥ 90% and

< 94%, then the unit incurs a cost to 

upgrade FGD and the HCl removal 

rate is 99%. (The SO2 removal rate 

remains as reported.)

−−−

If the reported SO2 removal rate is ≥ 

94%, the unit incurs no upgrade cost 

and the HCl removal rate is 99%.

In EPA Base Case v.5.13, coal steam units with existing FGD that do not achieve an SO2 removal rate of 

at least 90% are assumed to upgrade their FGDs in order to obtain at least 90% SO2 removal and 99% 

HCl removal. The cost of this “FGD Upgrade Adjustment” is assumed to be $100/kW and is considered

a sunk cost for modeling purposes.

5.5.3 HCl Retrofit Emission Control Options

The retrofit options for HCl emission control are discussed in detail in the following sub-sections and 

summarized in
5-24

Table 5-16. The scrubber upgrade adjustment was discussed above in 5.5.2.

Wet and Dry FGD

In addition to providing SO2 reductions, wet scrubbers (Limestone Forced Oxidation, LSFO) and dry

scrubbers (Lime Spray Dryer, LSD) reduce HCl as well. For both LSFO and LSD the HCl removal rate is

assumed to be 99% with a floor of 0.0001 lbs/MMBtu. This is summarized in columns 2-5 of
5-25

Table 5-16.
5-26

Table 5-16 Summary of Retrofit HCl (and SO2) Emission Control Performance

Assumptions in v.5.13

Performance

Assumptions

Limestone Forced Oxidation (LSFO) Lime Spray Dryer (LSD) Dry Sorbent Injection (DSI)

SO2 HCl SO2 HCl SO2 HCl

Percent 

Removal

96%

with a floor of 

0.06 lbs/MMBtu

99%

with a floor of 

0.0001 lbs/MMBtu

92%

with a floor of 

0.08 lbs/MMBtu

99%

with a floor of 

0.0001 

lbs/MMBtu

70%

90%

with a floor of 0.0001 

lbs/MMBtu

Capacity 

Penalty Calculated based on characteristics of 

the unit:

See Table 5-3

Calculated based on characteristics 

of the unit:

See Table 5-3

Calculated based on 

characteristics of the unit: 

See 

Excerpt from Table 5-22

Heat Rate 

Penalty

Cost (2011$)

Applicability Units ≥ 25 MW Units ≥ 25 MW Units ≥ 25 MW

Sulfur Content

Applicability Coals ≤ 3.0 lbs of SO2/MMBtu Coals ≤ 2.0 lbs of SO2/MMBtu

Applicable 

Coal

Types

BA, BB, BD, BE, BG, BH, SA, SB, SD, 

SE, LD, LE, LG, LH, PK and WC

BA, BB, BD, BE, SA, SB, SD, SE, LD, 

and LE

BA, BB, BD, SA, SB, SD, 

and LD

Dry Sorbent Injection

EPA Base Case v.5.13 includes dry sorbent injection (DSI) as a retrofit option for achieving (in 

combination with a particulate control device) both SO2 and HCl removal. In DSI for HCl reduction, a dry

sorbent is injected into the flue gas duct where it reacts with the HCl and SO2 in the flue gas to form

compounds that are then captured in a downstream fabric filter or electrostatic precipitator (ESP) and

disposed of as waste. (A sorbent is a material that takes up another substance by either adsorption on its

surface or absorption internally or in solution. A sorbent may also chemically react with another

substance.) The sorbent assumed in the cost and performance characterization discussed in this section

is Trona (sodium sesquicarbonate), a sodium-rich material with major underground deposits found in

Sweetwater County, Wyoming. Trona is typically delivered with an average particle size of 30 μm

diameter, but can be reduced to about 15 μm through onsite in-line milling to increase its surface area and

capture capability.

Removal rate assumptions: The removal rate assumptions for DSI are summarized in
5-27

Table 5-16. The assumptions shown in the last two columns of
5-28

Table 5-16 were derived from assessments by EPA engineering staff in consultation with Sargent &

Lundy. As indicated in this table, the assumed SO2 removal rate for DSI + fabric filter is 70%. The retrofit

DSI option on an existing unit with existing ESP is always provided in combination with a fabric filter 

(Toxecon configuration) in EPA Base Case v.5.13. 

Methodology for Obtaining DSI Control Costs: Sargent & Lundy’s updated performance/cost model for

DSI is used in EPA Base Case v.5.13 to derive the cost of DSI retrofits with two alternative, associated

particulate control devices, i.e., ESP and fabric filter “baghouse”. Their analysis of DSI noted that the cost

drivers of DSI are quite different from those of wet or dry FGD. Whereas plant size and coal sulfur rates

are key underlying determinants of FGD cost, sorbent feed rate and fly ash waste handling are the main

drivers of the capital cost of DSI with plant size and coal sulfur rates playing a secondary role.

In EPA Base Case v.5.13 the DSI sorbent feed rate and variable O&M costs are based on assumptions

that a fabric filter and in-line trona milling are used, and that the SO2 removal rate is 70%. The

corresponding HCl removal effect is assumed to be 90%, based on information from Solvay Chemicals (H.

Davidson, Dry Sorbent Injection for Multi-pollutant Control Case Study, CIBO IECT VIII, August, 2010).

The cost of fly ash waste handling, the other key contributor to DSI cost, is a function of the type of

particulate capture device and the flue gas SO2.

Total waste production involves the production of both reacted and unreacted sorbent and fly ash.

Sorbent waste is a function of the sorbent feed rate with an adjustment for excess sorbent feed. Use of

sodium-based DSI may make the fly ash unsalable, which would mean that any fly ash produced must be 

landfilled along with the reacted and unreacted sorbent waste. Typical ash contents for each fuel are used

to calculate a total fly ash production rate. The fly ash production is added to the sorbent waste to account

for the total waste stream for the VOM analysis. 

For purposes of modeling, the total VOM includes the first two component costs noted in the previous

paragraph, i.e., the costs for sorbent usage and the costs associated with waste production and disposal.

Table 5-17 presents the capital, VOM, and FOM costs as well as the capacity and heat rate penalties of a

DSI retrofit for an illustrative and representative set of generating units with the capacities and heat rates

indicated. See Attachment 5-5 ( www.epa.gov/airmarkets/progsregs/epa-ipm/BaseCasev513.html ) for 

details on the Sargent & Lundy DSI model.

5.6 Fabric Filter (Baghouse) Cost Development 

Fabric filters are not endogenously modeled as a separate retrofit option. In EPA Base Case v.5.13, an 

existing or new fabric filter particulate control device is a pre-condition for installing a DSI retrofit, and the 

cost of these retrofits at plants without an existing fabric filter include the cost of installing a new fabric 

filter. This cost was added to the DSI costs discussed in section 5.5.3.2. The costs associated with a new 

fabric filter retrofit are derived from Sargent & Lundy’s performance/cost model. Similarly, dry scrubber 

retrofit costs also include the cost of a fabric filter.

The engineering cost analysis is based on a pulse-jet fabric filter which collects particulate matter on a 

fabric bag and uses air pulses to dislodge the particulate from the bag surface and collect it in hoppers for 

removal via an ash handling system to a silo. This is a mature technology that has been operating 

commercially for more than 25 years. “Baghouse” and “fabric filters” are used interchangeably to refer to 

such installations.

Capital Cost: The major driver of fabric filter capital cost is the “air-to-cloth” (A/C) ratio. The A/C ratio is 

defined as the volumetric flow, (typically expressed in Actual Cubic Feet per Minute, ACFM) of flue gas 

entering the baghouse divided by the areas (typically in square feet) of fabric filter cloth in the baghouse. 

The lower the A/C ratio, e.g., A/C = 4.0 compared to A/C = 6.0, the greater the area of the cloth required 
5-29

and the higher the cost for a given volumetric flow. An air-to-cloth ratio of 4.0 is used in EPA Base Case 

v.5.13, and it is assumed that the existing ESP remains in place and active.

Table 5-18 presents the capital, VOM, and FOM costs for fabric filters as represented in EPA Base Case

v.5.13 for an illustrative set of generating units with a representative range of capacities and heat rates. 

See Attachment 5-7 (www.epa.gov/airmarkets/progsregs/epa-ipm/BaseCasev513.html) for details of the 

Sargent & Lundy fabric filter PM control model.
5-30

Table 5-17 Illustrative Dry Sorbent Injection (DSI) Costs for Representative Sizes and Heat Rates

under Assumptions in EPA Base Case v.5.13

Control Type

Heat Rate 

(Btu/kWh)

SO2

Rate

(lb/

MMBtu)

Capacity 

Penalty (%)

Heat Rate 

Penalty 

(%)

Variable O&M 

(mills/kWh)

Capacity (MW)

100 300 500 700 1000

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kW-yr)

DSI 9,000 2.0 -0.64 0.65 8.49 138.5 3.71 63.1 1.38 43.7 0.88 34.4 0.65 31.6 0.52

Assuming 

Bituminous 

Coal

10,000 2.0 -0.71 0.72 9.44 142.8 3.75 65.0 1.40 45.1 0.89 35.1 0.66 35.1 0.55

11,000 2.0 -0.79 0.79 10.39 146.8 3.78 66.9 1.41 46.4 0.90 38.6 0.69 38.6 0.58

Table 5-18 Illustrative Particulate Controls for Costs (2011$) for Representative Sizes and Heat Rates

under the Assumptions in EPA Base Case v.5.13

Coal Type

Heat Rate 

(Btu/kWh)

Capacity 

Penalty (%)

Heat Rate 

Penalty (%)

Variable 

O&M 

(mills/kWh)

Capacity (MW)

100 300 500 700 1000

Capital 

Cost 

($/kW)

Fixed O&M 

($/kW-yr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Capital 

Cost 

($/kW)

Fixed 

O&M 

($/kWyr)

Bituminous

9,000 -0.60 0.60 0.05 251 0.9 204 0.7 185 0.6 174 0.6 162 0.6

10,000 0.06 274 1.0 222 0.8 202 0.7 189 0.7 177 0.6

11,000 0.07 296 1.0 240 0.8 218 0.8 204 0.7 191 0.7
5-31

5.6.1 MATS Filterable Particulate Matter (PM) Compliance

EPA Base Case v.5.13 assumes that all coal-fired generating units with a capacity greater than 25 MW 

will comply with the MATS filterable PM requirements through the operation of either electrostatic 

precipitator (ESP) or fabric filter (FF) particulate controls. The control mechanism is not modeled 

endogenously but supplied as an input when setting up the run as specified below.

Units with existing fabric filters are assumed to be able to meet the filterable PM compliance requirement. 

For units with existing ESPs the following procedure is used to determine if they already meet the 

filterable PM requirement, can meet it by one of three possible ESP upgrades, or can only meet it by 

installing a FF.

First, PM emission rate data derived either from 2005 EIA Form 767 or (where available) from EPA’s 

2010 Information Collection Request33 are compared to the applicable filterable PM compliance 

requirement. If the unit’s emission rate is equal to or less than the compliance requirement, adequate 

controls are assumed already to be in place and no additional upgrade costs are imposed. For units that 

do not meet the filterable PM compliance requirement, the incremental reduction needed (in lbs/mmBtu) 

is calculated by subtracting the filterable PM compliance standard from the reported emission rate. 

Depending on the magnitude of the incremental reduction needed, the unit is assigned one of three ESP 

upgrade costs (designated ESP1, ESP2, and ESP3) or the cost of a FF installation (designated ESP4), if 

the required incremental reduction cannot be achieved by an ESP upgrade. Table 5-19 shows the four 

levels of ESP upgrades (column 1), the key technologies included in each upgrade (column 2), trigger 

points for the upgrades (column 3), the capital cost of each upgrade (column 4), and the percent increase 

in collection efficiency provided by the upgrade, differentiated according to the rank (subbituminous, 

bituminous, or lignite) of coal burned. 

The percentage improvements in collection efficiency shown in column 5 in Table 5-19 are additive in the 

sense that the values shown in this column are added to the pre-upgrade collection efficiency to obtain 

the after-upgrade collection efficiency. 

Table 5-19 Electrostatic Precipitator (ESP) Upgrades as Implemented in EPA Base Case v.5.13 ---

Characteristics, Trigger Points, Associated Costs, and Performance Improvements

Upgrade

Level

Key Technologies 

Employed in

Upgrade

Trigger Points for ESP 

Upgrade

(Expressed in terms of 

incremental reduction 

needed (lbs/mmBtu) to

meet the filterable PM

Compliance Standard) Capital Cost

Additive Percent Improvementein 

Collection Efficiency as a Result of 

the Upgrade (differentiated by the 

rank of coal combusted)

1

High Frequency transformerrectifier

(TR) sets

> 0.0 to ≤ 0.005 $55/kWa

0.12 for subbituminous

0.05 for bituminous

0.01 for lignite

2

High frequency transformerrectifier

(TR) sets + New internals 

(rigid electrodes, increased 

plate spacing, increased 

plate height)

> 0.005 to ≤ 0.01 $80/kWb

0.25 for subbituminous

0.10 for bituminous

0.02 for lignite

 

33 2005 EIA Form 767 is the last year where the data was reported in the format of lb/MMBtu, which is compatible 

with this analysis. Since any changes to facilities since 2005 would likely have improved (reduced) emissions, the 

use of this data is conservative. More recent 2010 ICR test data is used where available. (Collection Effort for New 

and Existing Coal- and Oil-Fired Electricty Utility Steam Generating Units (EPA ICR No.2362.01 (OMB Control 

Number 2060-0631).
5-32

Upgrade

Level

Key Technologies 

Employed in

Upgrade

Trigger Points for ESP 

Upgrade

(Expressed in terms of 

incremental reduction 

needed (lbs/mmBtu) to

meet the filterable PM

Compliance Standard) Capital Cost

Additive Percent Improvementein 

Collection Efficiency as a Result of 

the Upgrade (differentiated by the 

rank of coal combusted)

3

High frequency transformerrectifier

(TR) sets + New internals 

(rigid electrodes, increased 

plate spacing, increased

plate height) + Additional field

> 0.01 to ≤ 0.02 $100/kWc

0.50 for subbituminous

0.20 for bituminous

0.05 for lignite

4

Replacement with fabric filter

(baghouse) > 0.02

Use capital cost 

equations for a 

fabric filterd

(Not Applicable)

a Assumes upgrading the specific collection area (SCA) to 250 square-feet/1000 afm (actual feet per minute).

b Assumes upgrading the specific collection area (SCA) to 300 square-feet/1000 afm (actual feet per minute).

c Assumes upgrading the existing specific collection area (SCA) by 100 square-feet/1000 afm (actual feet per minute), a 20% height increase, and 

additional field.

d

The cost equations for fabric filters are described in Section 5.5.4 

e

The percentage improvement due to the ESP upgrade as shown in this column is added to the pre-upgrade collection efficiency to obtain the afterupgrade collection removal efficiency.

Excerpt from Table 5-20 contains a complete listing of coal generating units with either cold- or hot-side 

ESPs but no fabric filters. For each generating unit in Excerpt from Table 5-20 shows the incremental 

reductions needed to meet the PM filterable compliance requirement and the corresponding ESP upgrade 

(if any) assigned to the unit to enable it to meet that requirement. A filterable PM limit of 0.279 lb/mmBtu 

was used in this analysis. This value is roughly 10% below the limit in the final MATS rule, therefore 

resulting in a conservative estimate of the need to upgrade existing ESPs.

5.7 Coal-to-Gas Conversions34

In EPA Base Case v.5.13 existing coal plants are given the option to burn natural gas in addition to coal by

investing in a coal-to-gas retrofit. There are two components of cost in this option: Boiler modification

costs and the cost of extending natural gas lateral pipeline spurs from the boiler to a natural gas main

pipeline. These two components of cost and their associated performance implications are discussed in

the following sections.

5.7.1 Boiler Modifications For Coal-To-Gas Conversions

Enabling natural gas firing in a coal boiler typically involves installation of new gas burners and

modifications to the ducting, windbox (i.e., the chamber surrounding a burner through which pressurized

air is supplied for fuel combustion), and possibly to the heating surfaces used to transfer energy from the

exiting hot flue gas to steam (referred to as the “convection pass”). It may also involve modification of

environmental equipment. Engineering studies are performed to assess operating characteristics like

furnace heat absorption and exit gas temperature; material changes affecting piping and components like

superheaters, reheaters, economizers, and recirculating fans; and operational changes to sootblowers,

spray flows, air heaters, and emission controls.

 

34 As discussed here coal-to-gas conversion refers to the modification of an existing boiler to allow it to fire natural gas.

It does not refer to the addition of a gas turbine to an existing boiler cycle, the replacement of a coal boiler with a new

natural gas combined cycle plant, or to the gasification of coal for use in a natural gas combustion turbine
5-33

Excerpt from Table 5-20 ESP Upgrade Provided to Existing Units without Fabric Filters so that 

They Meet Their Filterable PM Compliance Requirement

This is a small excerpt of the data in Excerpt from Table 5-20. The complete data set in spreadsheet 

format can be downloaded via the link found at www.epa.gov/airmarkets/progsregs/epaipm/BaseCasev513.html)

Plant Name Unit ID

State 

Name Unique ID

Capacity

(MW)

Level of

ESP

Upgrade

Required

to Meet

Filterable

PM

Requirement

A B Brown 2 Indiana 6137_B_2 245 ---

AES Beaver Valley Partners Beaver Valley 2 Pennsylvania 10676_B_2 43 ESP-4

AES Beaver Valley Partners Beaver Valley 3 Pennsylvania 10676_B_3 43 ESP-4

AES Beaver Valley Partners Beaver Valley 4 Pennsylvania 10676_B_4 43 ESP-1

AES Cayuga 1 New York 2535_B_1 150 ---

AES Cayuga 2 New York 2535_B_2 151 ---

AES Deepwater AAB001 Texas 10670_B_AAB001 139 ---

AES Somerset LLC 1 New York 6082_B_1 681 ---

Allen Steam Plant 1 Tennessee 3393_B_1 245 ---

Allen Steam Plant 2 Tennessee 3393_B_2 245 ---

Allen Steam Plant 3 Tennessee 3393_B_3 245 ---

Alma B4 Wisconsin 4140_B_B4 51 ---

Alma B5 Wisconsin 4140_B_B5 77 ESP-4

Ames Electric Services Power Plant 7 Iowa 1122_B_7 33 ---

Ames Electric Services Power Plant 8 Iowa 1122_B_8 70 ---

Apache Station 2 Arizona 160_B_2 175 ---

Apache Station 3 Arizona 160_B_3 175 ---

Asbury 1 Missouri 2076_B_1 213 ESP-4

Asheville 1 North Carolina 2706_B_1 191 ---

Asheville 2 North Carolina 2706_B_2 185 ---

The following table summarizes the cost and performance assumptions for coal-to-gas boiler modifications

as incorporated in EPA Base Case v.5.13. The values in the table were developed by EPA’s engineering

staff based on technical papers35 and discussions with industry engineers familiar with such projects. They

were designed to be applicable across the existing coal fleet.

Table 5-21 Cost and Performance Assumptions for Coal-to-Gas Retrofits

Factor Description Notes

Applicability: Existing pulverized coal (PC) fired and

cyclone boiler units of a size greater

than 25 MW:

Not applicable for fluidized bed

combustion (FBC) and stoker boilers.

CapacityPenalty: None The furnace of a boiler designed to burn coal is

oversized for natural gas, and coal boilers

include equipment, such as coal mills, that are

not needed for gas. As a result, burning gas

should have no impact on net power output.

 

35 For an example see Babcock and Wilcox’s White Paper MS-14 “Natural Gas Conversions of Exiting Coal-Fired

Boilers” 2010 (www.babcock.com/library/tech-utility.html#14).
5-34

Factor Description Notes

Heat Rate

Penalty:

+ 5% When gas is combusted instead of coal, the

stack temperature is lower and the moisture

loss to stack is higher. This reduces

efficiency, which is reflected in an increase in

the heat rate.

Incremental Capital

Cost:

PC units: $/kW = 267*(75/MW)^0.35

Cyclone units: $/kW =

374*(75/MW)^0.35

The cost function covers new gas burners and

piping, windbox modifications, air heater

upgrades, gas recirculating fans, and control

system modifications.

Example for 50 MW PC unit:

$/kW = 267*(75/50)^0.35 = 308

Incremental

Fixed O&M:

-33% of the FOM cost of the existing 

coal unit

Due to reduced needs for operators,

maintenance materials, and maintenance staff

when natural gas combusted, FOM costs

decrease by 33%.

Incremental

Variable O&M:

-25% of the VOM cost of the existing 

coal unit

Due to reduced waste disposal and

miscellaneous other costs, VOM costs

decrease by 25%.

Fuel Cost: Natural gas To obtain natural gas the unit incurs the cost of

extending lateral pipeline spurs from the boiler

location to the natural gas transmission 

pipeline. See section 5.7.2.

NOx emission rate: 50% of existing coal unit NOx

emission rate, with a floor of

0.05 lbs/MMBtu

The 0.05 lbs/MMBtu floor is the same as the

NOx rate floor for new retrofit SCR on units

burning subbituminous coal

SO2 emissions: Zero

5.7.2 Natural Gas Pipeline Requirements For Coal-To-Gas Conversions

For every individual coal boiler in the U.S., EPA tasked ICF to determine the miles and associated cost of

extending pipeline laterals from each boiler to the interstate natural gas pipeline system.

To develop these costs the following principles were applied:

For each boiler, gas volume was estimated based on size and heat rate.

Direct distance to the closest pipeline was calculated. (The analysis only considered mainlines with

diameters that were 16 inches or greater. The lateral distance represented the shortest distance – “as

the crow flies” – between the boiler and the mainline.)

Gas volume (per day) of the initial lateral was not allowed to exceed more than 10 percent of the

estimated capacity of the mainline.

The mainline capacities were estimated from the pipe’s diameter using the Weymouth equation

36

.

If the gas requirement exceeded 10 percent of the estimated capacity of the mainline, the cost of a

second lateral to connect to the next closest mainline was calculated.

This procedure was repeated until the entire capacity required for the boiler was reached.

Diameters of each lateral were then calculated using the Weymouth equation based on their required

capacities.

 

36 The Weymouth equation in classical fluid dynamics is used in calculating compressible gas flow as a function of 

pipeline diameter and friction factors. It is used for pipe sizing.
5-35

The cost of all the laterals was calculated based on the pipeline diameter and mileage required. Thus,

the final pipeline cost for each boiler was based on the total miles of laterals required.

Figure 5-1 shows the calculations performed.

Figure 5-1 Calculations Performed in Costing Lateral Pipeline Requirement

There are several points to note about the above approach. First, for relatively large boilers or in cases

where the closest mainline has a relatively small diameter, multiple laterals are required to connect the

boiler to the interstate gas transmission grid. This assures that each individual boiler will not become a

relatively large portion of a pipelines’ transmission capacity. It also reflects real-world practices where

larger gas-fired power plants typically have multiple laterals connecting them to different mainlines. This

increases the reliability of their gas supply and provides multiple options for gas purchase allowing them to

capture favorable prices from multiple sources of gas supply at different points in time.

Second, expansion of mainlines was not included in the boiler specific pipeline cost, because the

integrated gas model within IPM already includes corridor expansion capabilities. However, if in future IPM

runs, multiple converted boilers are concentrated on a single pipeline along a corridor that includes

multiple pipelines, a further assessment may be required to make sure that the mainline expansion is not

being understated due to modeled efficiencies that may not actually be available in the field.

Figures 5-2 through 5-7 summarize the results of the pipeline costing procedure described above. They

provide histograms of the number of laterals required per boiler (
5-36

Figure 5-2), miles of pipeline required per boiler (Figure 5-3), diameters of the laterals in inches (
5-37

Figure 5-4), total inch-miles of laterals required per boiler (Figure 5-5), total cost to each boiler in million$

(Figure 5-6), and cost (in $) per kW of boiler capacity (Figure 5-7). Excerpt from Table 5-22 shows the

pipeline costing results for each qualifying existing coal fired unit represented in EPA Base Case v.5.13.
5-38

Figure 5-2 Number of Laterals Required per Boiler

Figure 5-3 Miles of Pipeline Required per Boiler
5-39

Figure 5-4 Diameter of Laterals

Figure 5-5 Total Inch-Miles of Laterals Required per Boiler
5-40

Figure 5-6 Total Cost to Each Boiler

Figure 5-7 Cost per kW of Boiler Capacity
5-41

Excerpt from Table 5-22 Cost of Building Pipelines to Coal Plants

This is a small excerpt of the data in Table-22. The complete data set in spreadsheet format can be 

downloaded via the link found at http://www.epa.gov/airmarkets/progsregs/epa-ipm/BaseCasev513.html.

Unique ID Plant Name State Name

Coal Boiler

Capacity

(MW)

Number

of

Laterals

Required

Miles of

New Pipeline

Required to

Hook Up Unit

(miles)

Cost of New

Pipeline

(2011$)

Cost of New

Pipeline

per KW

of Coal

Capacity

(2011$/kW)

3_B_1 Barry Alabama 138 2 8.5 2324786 16.85

3_B_2 Barry Alabama 137 2 8.5 2136794 15.60

3_B_3 Barry Alabama 249 2 8.5 7209727 28.95

3_B_4 Barry Alabama 362 2 8.5 8979092 24.80

3_B_5 Barry Alabama 726 2 8.5 12412831 17.10

7_G_1 Gadsden Alabama 64 1 28.7 22383509 349.74

7_G_2 Gadsden Alabama 66 1 28.7 22617875 342.70

8_B_10 Gorgas Alabama 703 2 68.4 87979597 125.15

8_B_6 Gorgas Alabama 103 1 7.6 6250679 60.69

8_B_7 Gorgas Alabama 104 1 7.6 6269532 60.28

8_B_8 Gorgas Alabama 161 1 7.6 7407093 46.01

8_B_9 Gorgas Alabama 170 1 7.6 7533473 44.31

10_B_1 Greene County Alabama 254 1 6.9 7898586 31.10

10_B_2 Greene County Alabama 243 1 6.9 7776757 32.00

26_B_1 E C Gaston Alabama 254 1 23.0 26126943 102.86

26_B_2 E C Gaston Alabama 256 1 23.0 26294370 102.71

26_B_3 E C Gaston Alabama 254 1 23.0 26143766 102.93

26_B_4 E C Gaston Alabama 256 1 23.0 26143766 102.12

26_B_5 E C Gaston Alabama 842 3 162.4 201898208 239.78

47_B_1 Colbert Alabama 178 1 0.7 725276 4.07

47_B_2 Colbert Alabama 178 1 0.7 722785 4.06

47_B_3 Colbert Alabama 178 1 0.7 722785 4.06

47_B_4 Colbert Alabama 178 1 0.7 723409 4.06

47_B_5 Colbert Alabama 472 2 4.6 5183155 10.98

50_B_7 Widows Creek Alabama 473 3 253.0 231385577 489.19

50_B_8 Widows Creek Alabama 465 3 253.0 227553333 489.36

51_B_1 Dolet Hills Louisiana 638 4 28.3 28812871 45.16

56_B_1 Charles R Lowman Alabama 80 1 17.3 13132673 164.16

56_B_2 Charles R Lowman Alabama 235 2 43.8 38349442 163.19

56_B_3 Charles R Lowman Alabama 235 2 43.8 38128365 162.25

59_B_1 Platte Nebraska 100 1 25.8 21561000 215.61

60_B_1 Whelan Energy Center Nebraska 77 1 8.1 6169545 80.12

60_B_2 Whelan Energy Center Nebraska 220 1 8.1 9036600 41.08

87_B_1 Escalante New Mexico 247 2 11.4 7831404 31.71

108_B_SGU1 Holcomb Kansas 362 5 77.1 43429164 119.97

113_B_1 Cholla Arizona 116 1 27.5 23648324 203.86

113_B_2 Cholla Arizona 260 1 27.5 32391059 124.58

113_B_3 Cholla Arizona 271 1 27.5 32691880 120.63
5-42

5.8 Natural Gas Co-firing

Existing coal plants with existing natural gas pipelines have an option of co-firing with natural gas. Gas 

co-firing at these units is limited to 10% of the unit’s power output.

The option of co-firing with gas at an existing coal boiler is only offered if one of the following two criteria 

based on 2012 EIA 860, 2012 EIAForm 923 and NEEDS v.5.13 is met: (1) the unit reported the use of 

gas as a startup fuel, or (2) an existing gas-fired unit (e.g., NGCC) is located at the same facility (with the 

same ORIS) as the coal-fired unit. EPA assumes that in either of these cases, sufficient pipeline capacity 

exists to supply up to 10% of total power output of the coal steam boiler located at these sites. These 

units are detailed below in Excerpt from Table 5-23.

Similar to the coal-to-gas retrofit option, there is a 5% increase in heat rate for the share of generation 

fueled by natural gas (accounting for the increased flue gas moisture and stack heat loss). On a $/kWh 

basis, any change in capital or operating costs of co-firing with natural gas at low levels is very small. 

Hence, EPA do not include additional capital or operating costs for this option.

Excerpt from Table 5-23 List of Coal Steam Units with Natural Gas Co-firing option

This is a small excerpt of the data in Excerpt from Table 5-23. The complete data set in spreadsheet 

format can be downloaded via the link found at http://www.epa.gov/airmarkets/progsregs/epaipm/BaseCasev513.html

UniqueID Plant Name ORIS Code State Name Capacity (MW)

10684_G_TG5 Argus Cogen Plant 10684 California 7

1077_G_3 Sutherland 1077 Iowa 78

1554_G_2 Herbert A Wagner 1554 Maryland 135

2943_G_3 Shelby Municipal Light Plant 2943 Ohio 5

511_G_1 Trinidad 511 Colorado 3.8

54407_G_1 Waupun Correctional Central Heating Plt 54407 Wisconsin 0.2

54407_G_2 Waupun Correctional Central Heating Plt 54407 Wisconsin 0.5

56564_G_1 John W Turk Jr Power Plant 56564 Arkansas 609

56785_G_WG01 Virginia Tech Power Plant 56785 Virginia 2.5

7_G_1 Gadsden 7 Alabama 64

7_G_2 Gadsden 7 Alabama 66

728_G_4 Yates 728 Georgia 133

728_G_5 Yates 728 Georgia 135

10_B_1 Greene County 10 Alabama 254

10_B_2 Greene County 10 Alabama 243