1

An Assessment of the 

Feasibility of Retrofits for the 

Mercury and Air Toxics Standards Rule 

U.S. Environmental Protection Agency 

Office of Air and Radiation 

December 16, 2011 

 
2

Abbreviations and Glossary 

ACI Activated Carbon Injection – controls mercury 

APC Air Pollution Control(s) – ACI, DSI, FGD, etc 

CAIR Clean Air Interstate Rule 

CSAPR Cross State Air Pollution Rule 

DSI Dry Sorbent Injection – controls acid gasses 

ESP Electrostatic Precipitator – controls particulates 

FF Fabric Filter (baghouse) – controls particulates 

FGD Flue Gas Desulfurization – controls SO2 and acid gasses 

GW Gigawatt(s) – one thousand MW 

GWeq GW(s) of WetFGDeq 

HAPS Hazardous Air Pollutants 

IPM Integrated Planning Model 

MATS Mercury and Air Toxics Standards 

MW Megawatt(s) – one million watts (1000 kilowatts) 

NEEDS National Electric Energy Data System 

SCR Selective Catalytic Reduction – controls nitrogen oxides 

WetFGDeq Wet FGD equivalent - The amount of an APC technology 

expressed as its GW equivalent in wet FGD technology 

 
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An Assessment of the Feasibility of Retrofits 

 for the Mercury and Air Toxics Standards Rule 

PREFACE 

This paper summarizes an EPA assessment of the feasibility of retrofitting various air pollution 

control (APC) technologies to coal-fired power plant units in the U.S. for power sector 

compliance with EPA’s Mercury and Air Toxics Standards Rule (MATS). Following are key 

dates associated with the Rule: 

 December 2011 – Final 

 February 2015 – Statutory Compliance Deadline 

 February 2016 – Compliance Deadline with extension from permitting authorities 

EPA has projected the quantity of each APC technology that may need to be newly retrofitted 

and in service by the compliance date(s). EPA used the latest version of its IPM model to analyze 

which APC technologies would likely be used, and in what quantities, to achieve compliance 

with MATS. 

Result: EPA’s assessment shows that a reasonable, moderately paced effort of the power 

sector and supporting industry, including some early starts, would result in the majority of 

the needed retrofits being installed by February 2015 with the possibility of some 

installations needing up to an additional year for completion. In order for all retrofits to be 

completed by February 2015, more projects would have to start early and the sector would 

have to engage in a more aggressive deployment program. In the event that individual 

projects cannot be completed by the February 2015 statutory deadline for compliance, the 

Clean Air Act offers affected sources the opportunity to apply for a one-year extension. 

ANALYTICAL APPROACH 

Site-specific feasibility studies are typically performed before owners commit to an APC retrofit 

plan for a unit or plant. However, an assessment of the feasibility of retrofitting a sector-wide 

aggregation of APC systems to achieve timely compliance with MATS on a national scale

cannot replicate the same level of detailed analysis of either specific plants or of individual 

components of the APC “supply chain.” Various detailed analyses of the supply chain have been 

conducted for past rules, usually resulting in a significant underestimate of what was ultimately 

achieved in practice1

. Aside from the difficulties of making detailed “bottom-up” analyses of 

either plants or supply chains on a national scale, such analyses miss the mark because no single 

planner can be responsible for the strategies of competitive participants in the supply chain, 
4

much less for owner compliance strategies at all affected units. In reality, the sector will benefit 

from the creative interaction of a multitude of actors in the marketplace developing routes to 

compliance. For the purposes of this Rule, this assessment adopts a broad-scale, order-ofmagnitude estimate of what appears reasonably feasible nationwide based on the pattern of 

power sector deployment activity in the recent past. EPA recognizes that a wide range of sitespecific conditions will result in a range of “better-than-average” and “worse-than-average” 

project outcomes as regards cost and schedule. In developing a broad-scale estimate, the 

influence of differences in local factors and in past, current, and future circumstances has been 

considered at an appropriate level of detail. 

RECENTLY DEMONSTRATED DEPLOYMENT CAPABILITIES OF THE APC 

SUPPLY CHAIN 

Annual GW capacity additions are plotted in Figure 1 for the two most resource intensive APC 

systems: flue gas desulfurization (FGD) and selective catalytic reduction (SCR). Figure 1 data 

reflect the year that systems went into service. These data are from the National Electric Energy 

Data System (NEEDS)2

, as provided by plant owners and updated by EPA. They include both 

retrofitted APC and systems installed as part of new coal plant construction. The FGD 

component is a sum of wet and dry FGD technologies. Dry FGD comprises about 12% of total 

1990-2011 FGD additions. Annual installations of new coal-fired power plant capacity are also 

plotted to indicate the size of its role in contributing to APC additions. Although there have been 

no new coal power projects ordered in the past two years, several are still in construction. The 

supply chain for coal power plants is thus an active and applicable set of resources (including 

engineers, manufacturers, fabrication shops, craft labor, construction managers, etc.) that could 

be tapped to rapidly enlarge the APC supply chain. 

Figure 1: FGD, SCR, and Coal Plant Annual GW Additions, New and Retrofit 

Source: EPA, NEEDSv4.10PTR 

0.0

10.0

20.0

30.0

40.0

SCR, GW FGD, GW New Coal, GW
5

The large, rather abrupt peaks in annual SCR additions (2000 and 2003) for compliance with the 

NOx SIP Call are apparent in Figure 1. A more gradual build up to the historic 2009 peak for 

annual FGD additions in anticipation of the Clean Air Interstate Rule (CAIR) is also apparent. 

These data depict a recent major ramp-up in the APC deployment capabilities of all industry 

participants, including plant owners, the APC supply chain, and state and local permitting 

agencies. These expanded APC capabilities are still active today, even if not fully utilized. EPA 

believes that in today’s post-recession economy it is reasonable to expect that these experienced 

capabilities can be quickly re-engaged, can quickly return to production at historic rates, and can 

be quickly augmented by additional available resources to increase production rates beyond 

historic levels. 

RETROFIT PROJECTIONS FOR MATS 

Table 1 shows the types and quantities of APC retrofits that EPA has projected the sector to 

adopt for MATS compliance. “Retrofit GW” refers to the total generating capacity of coal-fired 

units that are projected to receive each APC technology. For example, the table shows that the 

Rule may require the retrofitting of dry FGD systems to 20 GW of coal-fired generating 

capacity. A sum of the Retrofit GW capacities across the categories in Table 1 would be greater 

than the amount of generating capacity affected by retrofits because many generating units will 

elect to install more than one APC technology. 

Table 1: MATS Retrofit Technologies and GW Capacity required by 2015 for Coal-fired Units 

APC

Technology

Wet

FGD

Dry FGD

w/ FF* SCR FF DSI ACI FGDupgrades**

ESP

upgrades***

Retrofit

GW 0 20 0 85 44 99 63 34

Source: EPA, derived from IPMv4.10_MATS 

*17 GW of FF included with DryFGD is in addition to the 85 GW of FF installed for PM control or in conjunction 

with DSI or ACI. 

**63 GW of existing FGDs are assumed to be upgraded to achieve adequate HCl removal 

***34 GW of existing ESPs are assumed to be upgraded to achieve adequate PM removal 

At any particular coal-fired power plant it is possible that none or several of these APC 

technologies might be retrofitted for MATS compliance. Depending on the plant, they might be 

retrofitted to each individual unit, or some to one unit but not others, and some might be sized to 

serve multiple units at a plant. Under MATS, plant operators have the flexibility to design for 

plant-wide compliance with the rule’s emission rates, rather than requiring each unit to meet the 

specified standards exactly, which further increases the likely diversity of compliance strategies 

that may reduce cost and time for implementation. These and many other site- and ownerspecific factors that cannot be fully considered in IPM modeling would influence plant owner 

decisions on how to apply any of these systems on individual units. Therefore, although IPM 

projections based on “model plants” have proven to be excellent predictors of economic 
6

technology deployments on a state-wide, regional, and national basis, they are not intended and 

should not be interpreted as authoritative projections for any single plant or unit. 

METRIC FOR TOTAL RETROFIT DEPLOYMENTS (GW WetFGDeq) 

EPA has adopted a single metric to represent all APC technologies in this analysis. Use of a 

single metric facilitates an extrapolation of historic deployment rate data for wet and dry FGD 

and SCR to assess feasible future deployment rates needed for the retrofit technologies projected 

for MATS. Such a single metric permits assessment of the overall combined feasibility of all 

APC retrofits projected. This metric should be regarded as “average,” not capturing the specifics 

of any particular site, but representing average difficulty across many projects. 

As shown in Table 2, EPA converted the projected Retrofit GW capacities of each technology 

from Table 1 into an “equivalent wet FGD capacity” (WetFGDeq). The total (64 GW 

WetFGDeq) is the future APC deployment goal for this retrofit feasibility analysis. One example 

of this conversion is that retrofitting 20 GW of dry FGD systems is considered roughly 

equivalent in terms of cost and resources to the retrofitting of 16 GW of wet FGD systems. 

The equivalence factors are computed as the ratio of the capital cost of each technology to that of 

a wet FGD system. Capital cost includes the installed and commissioned retrofit project elements 

(engineering, equipment, construction labor, project management, etc.), excluding only financing 

costs and owner’s “home office” costs. The capital costs are derived from IPMv4.10_MATS 

technology assumptions for single-unit systems. 

Table 2: MATS Retrofit Technologies and GW WetFGDeq Capacity 

APC Technology Retrofit

GW

Equivalence

Factor

WetFGDeq  

GW

Wet FGD 0 1 0

Dry FGD 20 0.8 16

SCR 0 0.4 0

FF 85 0.3 26

DSI 44 0.1 4

ACI 99 0.02 2

FGD Upgrade 63 0.2 13

ESP Upgrade 34 0.1 3

Total        64

Source: EPA Note: Some values may not add exactly due to rounding. 

WetFGDeq values are intended to approximately represent the relative GWeq capacity, capital 

cost, and supply chain deployment resources associated with APC technologies individually and 

in total, on the basis of current market conditions. They do not directly represent the relative 

calendar times required to install individual technologies. Wet FGD was selected as the “base” 

technology for this metric because it has been widely deployed, is familiar to the industry, has 

the highest capital cost, uses the most supply chain resources, and requires the longest schedule 
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for deployment. Use of the single WetFGDeq metric is intended to allow the public to more 

readily visualize and consider a complex set of relationships among many factors (including site 

conditions, APC designs, and supply chains), and to consider the aggregate level of effort 

projected for the sector to reach overall MATS compliance. 

TRENDS IN TOTAL RETROFIT DEPLOYMENT EFFORT (GW WetFGDeq) 

Figure 2 shows the total annual historical APC additions from Figure 1 and current APC 

commitments for the future using the WetFGDeq metric. Figure 2 reveals the pattern of retrofit 

deployment driven solely by CAIR, showing separately the WetFGDeq of APC capacity 

installed for other reasons. Note that the retrofit capacity depicted as “other” in Figure 2 has 

separately identified drivers, but the portion of that “other” capacity deployed inside the CAIR 

region may have also been timed in coordination with that rule. Figures 1 and 2 both 

demonstrate the sector’s early deployment of APC controls in advance of CAIR compliance 

deadlines of 2009 for NOx and 2010 for SO2. Solely CAIR-driven APC deployments of about 13 

GW WetFGDeq occurred within two and a half years after CAIR’s finalization in mid-2005, 

showing that at least 40% of total CAIR-only APC effort through 2010 was sufficiently planned 

for installation to start before or immediately upon finalization of the rule. 

Figure 2: Historical / Projected APC and New Coal Annual Additions 

Source: EPA (NEEDS) through 2011; Data beyond 2011 derived with permission from IHS CERA "Announced 

Environmental Retrofit Project Database: November 2010 Update." 

ADDITIONAL SUPPLY CHAIN RESOURCES 

EPA estimates that on a GWeq basis, a new coal-fired plant would have at least 5 times more 

resources involved than a new retrofit wet FGD system. This is illustrated in Figure 3, which is 

similar to Figure 2 except that the actual GW values for New Coal have been converted to GW 

WetFGDeq. The comparable GWeq values indicate that there may now be as many underutilized 

and potentially available New Coal resources as were being used in the APC supply chain at its 

0.0

10.0

20.0

30.0

40.0

APC CAIR only, GW WetFGDeq APC other, GW WetFGDeq New Coal, GW
8

peak. The currently available APC resource pool might thus be up to twice as large as would 

otherwise be expected, and well able to support a major ramp-up of its deployment capabilities. 

Although not quantified here, there is a similar, available, and to some extent transferrable 

resource pool that has until recently been supporting large annual deployments of the gas turbine 

combined-cycle power plant business line. NEEDSv4.10PTR shows gas combined-cycle 

capacity additions of 7 GW (actual) in 2009, 3 GW in 2010, and 7 GW for 2011. 

Figure 3: Historical / Projected APC and New Coal Annual Additions 

Source: EPA 

SCHEDULE OUTLOOK FOR RETROFIT INSTALLATIONS 

APC Retrofit Planning EPA thinks it likely that the majority of coal-fired power plant owners 

performed site-specific APC retrofit studies sometime prior to or in the seven years since CAIR 

was proposed in 2004. CAIR has remained in effect and will transition in 2012 to the recently 

finalized Cross State Air Pollution Rule (CSAPR), which continues to focus the industry on 

retrofit planning. All owners have long been aware that a MATS Rule would be forthcoming and 

that it would have a compliance date three years after the final rule is effective, as mandated by 

statutory language in the Clean Air Act. EPA therefore expects that many owners have already 

determined which of their units would eventually get some combination of APC systems. Such 

existing preparatory work should make it possible for many owners to quickly take steps toward 

making commitments for these systems. There is evidence that many such steps have already 

been taken. 3

Early Movers CAIR was proposed in early 2004 and finalized in mid-2005. It established 

compliance dates in 2009 for NOx and 2010 for SO2. As discussed above, Figures 1 and 2 show 

that a significant fraction of “early mover” plant owners must have done their planning and made 

commitments well in advance of the CAIR final rule date. Southern Company’s early 2003 

commitment to a large program of APC retrofits, well in advance of CAIR’s finalization, is one 

example of an “early mover” making major early APC deployment decisions, leading to 8,000 

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10.0

20.0

30.0

40.0

50.0

60.0

70.0

GW WetFGDeq

APC, GW WetFGDeq New Coal, GW WetFGDeq
9

MW of installed wet FGD systems on 14 units. 4 Subsequent commitments from many more 

owners encouraged a continuing expansion of the supply chain, with further increases in annual 

deployments. EPA anticipates that this pattern will be repeated for the MATS Rule. “Early 

movers” making commitments in advance of the Rule are better positioned to avoid any potential 

increase in APC system costs when the supply chain ramps up to deploy a new peak in retrofit 

installations in a short period of time. EPA clearly saw this early mover advantage occur with 

CAIR, and early movers may have already triggered the beginning of a major new ramp-up of 

the APC supply chain for the MATS Rule. 

Benchmarking to a New Coal Plant Schedule Actual schedule durations for APC retrofits have 

varied widely from plant to plant, as will be discussed later. There are many reasons for such 

variability, and for the fact that some retrofit projects apparently had lengthy schedules of 4 years 

or more. EPA believes that almost all future APC retrofits can be completed far more quickly 

than were historical APC projects. EPA’s perspective on this matter derives in part from a 

comparison of past APC schedules to the project schedule for an entire new coal-fired unit, 

including its APC systems. Springerville Unit 3, for example, is a 400 MW coal-fired unit that 

became operational in July 2006, some 33 months after the turnkey engineering-construction 

contractor was given a notice to proceed with engineering.5

 Springerville was clearly on an 

accelerated schedule, as its original planned schedule was about 38 months. The main point here 

is that typical schedules for large complex power projects can be significantly accelerated. 

Because the scope of the work involved for an entire new coal unit is at least five times that of a 

retrofit wet FGD system, EPA believes that even the most complex retrofit APC project can be 

significantly accelerated as well. EPA therefore also believes that its schedule assumptions used 

in CSAPR, 27 months for retrofitted wet FGD and 21 months for dry FGD, remain reasonable 

expectations for both CSAPR and MATS. 

Retrofit Project Schedules The recently surveyed wet FGD project schedules shown in Table 3 

are not all representative of the shorter project schedules that EPA expects to be prevalent under 

the MATS Rule. Some of these projects were conducted in a period of regulatory uncertainty 

without a strong driver for accelerated retrofit completion, tie-in, and subsequent operation – 

particularly where initiating such operation increases marginal operating costs without a certain 

regulatory benefit. Factors that will likely accelerate project schedules under MATS include the 

use of overtime and/or two-shift work schedules during construction, and 5- or 6-day work 

weeks, instead of the 4-day x10-hr schedules often used to minimize cost when time is not of the 

essence. Increased use of offsite modularization and pre-fabrication of APC components can also 

shorten schedules and reduce job hours. Also, many of the wet FGD projects performed in 

response to CAIR or to other legal actions in the same time frame took longer to perform than 

under normal market conditions due to the initial high demand for a large number of complex 

wet FGD systems in a short period of time. Extended lead times in the 2007/2008 time period, as 

high as 18 months for key wet FGD engineered equipment (such as large recycle pumps, large 

motors, and chimneys) contributed to extended wet FGD project durations. Increased lead times 
10

quickly subsided as the supply chain processed the initial influx of orders for this equipment. 

Neither CSAPR nor MATS, however, as shown in Table 1, is projected to require a significant 

number of large, complex wet FGD systems. The relatively much simpler dry FGD, fabric filter, 

and other even simpler dry sorbent injection (DSI) and ACI systems that may be required under 

the MATS rule will take significantly less time to plan, design, install, and commission than wet 

FGDs. 

Table 3: Recent Wet FGD Project Deployment Schedules 

Wet FGD Projects Schedules (without planning) 

13 26 – 35 months 

8 37 – 52 months 

Source: EPA (see Appendix A) 

Motivation for MATS Rule Compliance There is a notable difference between CAIR and the 

MATS Rule as regards incentives for plant owners to be early movers - making retrofit 

commitments in advance of the final rule date. CAIR included provisions for the banking and 

trading of emission allowances, and thus offered unit owners the flexibility to deliberate over 

time varying compliance strategies that could be offset by allowance purchases if eventual 

emissions exceeded allowance allocations to that unit. The MATS Rule, on the other hand, does 

not offer trading flexibility and requires plant-level compliance as soon as the regulatory period 

begins. Compliance planning under MATS will involve assessment of the long-term differences 

between the costs of keeping in service an existing unit with newly retrofitted controls and the 

costs of building and operating a new generating unit that complies. In some cases, it may be 

possible for owners to delay a retrofit decision until after the MATS Rule is final and still be able 

to make the necessary deployments in good time. In some other cases, however, any delay in 

making a retrofit commitment may compromise a unit’s ability to meet the statutory MATS Rule 

compliance deadline. Therefore, the rational expectation should be that affected unit owners 

would have been more motivated to move early on retrofit planning decisions in advance of the 

MATS Rule than they were to anticipate actions under previous trading-based regulations. 

Ultimately, affected plant owners should already have factored in the risk of noncompliance with 

the MATS Rule as they planned the futures of their coal units. 

DEVELOPMENT OF APC DEPLOYMENT SCENARIOS

Current Supply Chain Activity Current activity levels for various participants in the supply 

chain depend on when their particular activity (engineering, manufacturing, fabrication, 

construction, etc) occurs in an APC project schedule. As shown in Figure 3, the deployment rate 

is currently in a second year of decline. Therefore, the activity level of front-end engineering and 

shop fabrication resources has by now decreased more than that of construction resources 

(relatively), and both have decreased very significantly. Overall, the current activity level of 

front-end resources is supporting committed projects that will likely come on-line in the 2013-

2015 time frame, corresponding to an annual baseline deployment rate of 10 GW WetFGDeq or 

less. Not shown in Figure 3 are any additional deployments that may be made by 2014 in 
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response to CSAPR. EPA’s IPM analysis for CSAPR projected a need for at most 6 GW of FGD 

retrofits by 2014. This is an amount that has likely already accelerated a ramp-up in supply chain 

activity, but, as discussed below, is well within the previously demonstrated capabilities of the 

supply chain, even when added to retrofits that may be needed for MATS. 

Moderate Future Deployment Historical peak annual APC deployments were nearly 30 GW 

WetFGDeq in 2009. Average year-on-year growth in annual deployments over the 3-year period 

from 2006 to the peak in 2009 was 45%. A renewed ramp-up in deployment capability, likely 

already started in early 2011, would have started from roughly the same reduced level of activity 

that preceded the sustained ramp-up for CAIR. With these observations EPA developed a 

“moderate” APC deployment scenario, as follows (see Table 4): 

 Within three years (by early 2014) a moderate effort by the supply chain could put in 

service APC retrofits of at least 20 GW WetFGDeq for MATS. This is significantly less 

than the nearly 30 GWeq deployed in a similar time frame under CAIR, and leaves 

demonstrated capability for limited additional deployments under CSAPR as well. This 

initializing assumption is supported by EPA engineering staff interaction with the supply 

chain community and informal appraisals of the current activity and preparedness of the 

sector. The starting point assumption directly influences the computation of what 

proportion of retrofit effort is "on time" in 2015 and what proportion is "late" and would 

require the one-year extension to February 2016. This Moderate scenario expresses 

EPA’s current expectation of what is reasonably achievable while recognizing that there 

is no definitive way to project how many controls will be on time and how many will 

require the extension. Completion of this scenario by 2016 seems a reasonable 

expectation since the MATS is not projected to require use of wet FGD, the most timeand resource-consuming APC technology. Note that although this WetFGDeq analytical 

concept appears to suggest that nothing is deployed until 2014; in reality there would 

likely be deployed increasing amounts of DSI, activated carbon injection (ACI), fabric 

filter (FF) technology, and upgrades of existing FGD and ESP starting in the earliest 

years, 2012 and 2013, and continuing throughout the program. Dry FGD retrofits could 

begin coming online sometime in 2013. 

 With a small further growth in the supply chain deployment rate, an additional 24 GWeq 

can be deployed by early 2015, making a cumulative deployment of 44 GWeq. A further 

20 GWeq is completed by February 2016, thus meeting the MATS Rule cumulative 

projection of 64 GW WetFGDeq. 

EPA views this moderate 5-year ramp-up as a reasonable and achievable deployment scenario, 

without anticipating that the sector may find more productive routes to effective and efficient 

compliance not yet reflected in the historic record. 

 
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Table 4: APC Deployment Scenarios, Cumulative GW WetFGDeq 

Cumulative GW 

WetFGDeq Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 

5-year ramp-up Moderate-paced increase in 

resources 

20 44 64 

4-year ramp-up Aggressive increase in 

resources

28 64 

Source: EPA 

The relative magnitudes of past and projected annual APC and New Coal deployments are 

depicted in Figure 4, where the incremental GWeq of APC for the MATS Rule under a moderate 

5-year ramp-up are added to projected APC deployments without the Rule. This visual 

representation of the relative magnitudes of the resources involved supports the reasonableness 

of EPA’s expectation that timely compliance is achievable in this moderately paced scenario. 

Figure 4: Online Year for MATS Rule APC Annual Additions in 5-Year Ramp-up Scenario 

Source: EPA 

More Aggressive Future Deployment It is conceivable that the supply chain could begin 

immediately to ramp up its capabilities over three years to the same peak deployment rate 

achieved for CAIR, and to continue ramping up at an aggressive pace through a final year of 

APC deployments. Conceivably, it would not “throttle back” its resource growth; it would tap all 

available sources until all resources that are needed are in place to produce 64 GW WetFGDeq of 

deployments by early 2015. Under this more aggressive 4-year ramp-up scenario, 28 GWeq 

could be in service by early 2014 (40% more than in the moderate scenario, but about equal to 

the CAIR peak), with an additional 36 GWeq needing to be placed into service by early 2015. 

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

GW WetFGDeq

New Coal, GW WetFGDeq MATS Rule APC, GW WetFGDeq APC, GW WetFGDeq
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EFFECT OF RETROFIT UNIT SIZES 

It is useful to consider whether a difference in the past and future average size of the units 

involved, and thereby a difference in the number of unique units or projects involved, might 

significantly affect the feasibility results. NEEDS data indicate that the peak APC deployment of 

38 actual GW in 2009 (Figure 1) involved a peak of 66 unique units. The average size unit built 

anew or retrofitted in 2009 with APC systems was therefore about 575 MW. Not all of those 

units were managed as unique projects, as some were part of continuing multi-unit projects at 

some plants, and a few shared an APC system with one or two other units at the same plant. 

EPA projects that the future average unit size retrofitted for the MATS Rule will be about 300 

MW. However, that does not necessarily mean that there will be proportionately more APC 

projects to be managed simultaneously. The limited time for compliance will likely necessitate 

parallel retrofitting activities at many multi-unit plants, with such plant-wide efforts managed 

most efficiently as single projects. Furthermore, with smaller average unit sizes being retrofitted 

in the future, there will likely be many plants (projects) where multiple smaller units share an 

APC system. Although it is not possible to accurately predict the future numbers of APC systems 

that will be uniquely deployed to single units, or to multiple units, it is clear that the sharing of 

APC systems by multiple smaller units, done to minimize resource needs and capital cost, could 

significantly limit the number of APC systems and projects involved. Shared APC systems will 

allow the overall effort to be more manageable than otherwise, and should require relatively 

fewer supply chain resources. 

A higher number of projects might be expected to impact project management and supervisory 

labor to some greater degree than craft labor. However, many of the projects will be upgrading 

existing systems and/or installing fabric filters and less complex technologies, any of which are 

far less complex than the wet FGD systems installed for CAIR. They will entail far fewer 

component suppliers, less process engineering effort, fewer technical specifications, etc. A 

typical upgrade or fabric filter project is therefore far less difficult to manage or supervise than a 

typical wet scrubber project. Likewise they are easier to construct and will require relatively less 

craft labor. Thus, although there may be more APC projects, they will be far easier to manage, 

and should require relatively fewer skilled personnel than CAIR experience and the WetFGDeq 

metric might suggest. 

Referring again to Figure 4, EPA expects that the combined underutilized resources for the APC 

and New Coal supply chains, possibly supplemented with underutilized resources from the gas 

combined-cycle business line, will be adequate to support a moderately paced APC deployment 

scenario. 
14

Appendix ‐ Wet FGD Retrofit Timelines

Plant Name Unit ID Capacity

(MW)

PROJ START

(CAMD

findings)

PROJ FINISH

(CAMD

Findings)

PROJ

Duration

(months)

Reference

CAMD SO2

Control Start

Date

Asheville 1 191 Sep‐03 Nov‐05 26 (web site:  http://www.powergenworldwide.com/index/display/articledisplay/277709/articles/power‐

engineering/‐/2006/11/best‐coal‐fired‐projects.html )  Construction start Sept 2003.  Unit #1 complete Nov 2005;

unit #2 complete 2006. Detail design to Start‐up: 26 months. (web site: http://progress‐

energy.com/aboutus/news/article.asp?id=14282) unit 2 on‐line May 25, 2006; unit #1 on‐line Nov 2005.

11/6/2005

Killen Station 2 615 Mar‐05 Jun‐07 28 (web site:  http://www.bv.com/News_3_Publications/News_Releases/2005/0503.aspx)  B&V announcement ‐ 

alliance w DP&L for Killen & Stuart stations to utilize scrubber tecnology ‐ May 3, 2005.   (web site:

http://www.thefreelibrary.com/Black+%26+Veatch%27s+Largest+CT‐121+Scrubber+Project+in+North+America+...‐

a0166786209)  B&V start‐up of a CT‐121 WFGD for Killen unit#2 ‐ July 25, 2007.  

5/24/2007

Brandon Shores 1 643 Jun‐07 Dec‐09 29 (web site: http://www.highbeam.com/doc/1G1‐165318616.html ) Construction start June 20, 2007.  (web site:

http://www.constellation.com/vcmfiles/Constellation/Files/scrubber_factsheet.pdf)  Unit#1 connected Dec 2009;

unit #2 connected Mar 2010.   

11/21/2009

Crist 7 472 May‐07 Jan‐10 32 (web site: http://www.bv.com/wcm/press_release/05072007_1374.aspx)  B&V selected by Gul f Pwr Comp to

provide EPC for CT‐121 WFGD at Plant Crist station; all units will be scrubbed; unit 4,5,6,7 ‐ announ May 7, 2007.  

NOTE: use CAMD SO2 control start date

1/1/2010

Brandon Shores 2 643 Jun‐07 Mar‐10 32 (web site: http://www.highbeam.com/doc/1G1‐165318616.html ) Construction start June 20, 2007.   (web site:

http://www.constellation.com/vcmfiles/Constellation/Files/scrubber_factsheet.pdf)  Unit#1 connected Dec 2009;

unit #2 connected Mar 2010.

1/1/2010

Asheville 2 185 Sep‐03 May‐06 33 (web site:  http://www.powergenworldwide.com/index/display/articledisplay/277709/articles/power‐

engineering/‐/2006/11/best‐coal‐fired‐projects.html )  construction start Sept 2003; unit#1 complete Nov 2005;

unit #2 complete 2006.  Detail design to Start‐up: 26 months.  (web site: http://progress‐

energy.com/aboutus/news/article.asp?id=14282) unit 2 on‐line May 25, 2006; unit #1 on‐line Nov 2005.

Wansley 1 891 Jan‐06 Oct‐08 33 (web site: http://www.times‐herald.com/Local/Scrubber‐project‐planned‐at‐Yates‐596100) Wansley constrction

begin ‐ Jan 2006. (Meag Power Current vol.2: issue 1, 2009) Wansley unit 1 scrubber completed Oct 2008; unit #2

by next mid april).

10/1/2008

Mitchell 2 800 Mar‐04 Jan‐07 34 (web site: http://www.babcock.com/library/pdf/pch570.pdf)  per B&W: Project award mar 2004; unit 2

operational Jan 07, unit 1 operational Apr 07. 2x800 Mw units

1/15/2007

Warrick 2 136 Jul‐05 May‐08 34 (web site: http://www.thefreelibrary.com/Alcoa+Investing+%24375+Million+for+Warrick%2c+IN+Facilities‐

a0134312217) Alcoa announces investment in WFGDs for Warrick July 22, 2005.   (web site:

https://www.alcoa.com/locations/usa_warrick/en/info_page/power_plant.asp)  Dec 2008, all 4 units completed ‐

WFGD'd installed ‐ final scrubber installed in Dec 2008; project start 2005. (web site:

https://www.insideindianabusiness.com/newsitem.asp?ID=29541) the first scrubber went on‐line 5/27/2008.  

(web site: http://www.alcoa.com/locations/usa_warrick/en/news/newsletters/june08.asp#0) Unit #2 identi fied.

4/12/2008

Fort Martin Power

Station

1 552 Mar‐07 Feb‐10 35 (web site: http://findarticles.com/p/articles/mi_m0EIN/is_2007_March_15/ai_n27304049/) Allegheny Pwr

announces EPC contract w WGI for scrubber at Fort‐Martin station ‐ March 15, 2007.  (web site:

http://newsblaze.com/story/2010020408561700001.bw/topstory.html ) Allegheny Pwr announce completion of

scrubber project for Fort Martin station ‐ Feb 04, 2010.  

10/31/2009

Fort Martin Power

Station

2 555 Mar‐07 Feb‐10 35 (web site: http://findarticles.com/p/articles/mi_m0EIN/is_2007_March_15/ai_n27304049/) Allegheny Pwr

announces EPC contract w WGI for scrubber at Fort‐Martin station ‐ March 15, 2007.  (web site:

http://newsblaze.com/story/2010020408561700001.bw/topstory.html ) Allegheny Pwr announce completion of

scrubber project for Fort Martin station ‐ Feb 04, 2010.  

8/26/2009

Miami Fort 7 500 Jun‐04 Apr‐07 35 (web site: http://www.mcilvainecompany.com/utility/subscriber/DefaultOLD.htm) McIlvaine #821 (4/27/2007)  

Miami‐Fort unit #7 WFGD operating; (personal note: worked on proj, proj start June 2004)

4/1/2007

Monroe 4 775 Jul‐06 Jun‐09 35 (web site:  

http://www.redorbit.com/news/business/560181/washington_group_international_to_retrofit_scrubbers_at_det

roit_edison_power/index.html )  WGIselected to provide EPC  for WFGD's on Monroe units 3&4 ‐ 5 july 2006.  

(web site:  http://www.tradingmarkets.com/.site/news/Stock%20News/2657108/)  Monroe unit #4 WFGD

operational June 2009.   note:scrubber is a ceramic vessel (tile w concrete).

5/4/2009

Clay Boswell 3 351 Feb‐07 Mar‐10 37 (web site:

http://www.redorbit.com/news/business/840682/minnesota_power_awards_boswell_energy_center_retrofit_co

ntract/index.html );  Award 14 Feb 2007.   (http://hamon‐researchcottrell.com/news_20100601) Completed Mar

2010

10/30/2009

Mitchell 1 800 Mar‐04 Apr‐07 37 (web site: http://www.babcock.com/library/pdf/pch570.pdf)  per B&W: Project award mar 2004; unit 2

operational Jan 07, unit 1 operational Apr 07.  Two 800 MW units.

1/1/2007

Warrick 1 136 Jul‐05 Oct‐08 39 (web site: http://www.thefreelibrary.com/Alcoa+Investing+%24375+Million+for+Warrick%2c+IN+Facilities‐

a0134312217) Alcoa announces investment in WFGDs for Warrick July 22, 2005.    (use CAMD SO2 control start

date)

10/15/2008

Wansley 2 892 Jan‐06 Apr‐09 39 (web site: http://www.times‐herald.com/Local/Scrubber‐project‐planned‐at‐Yates‐596100) Wansley constrction

begin ‐ Jan 2006.   (use CAMD SO2 control start date)

4/1/2009

Bowen 3BLR 902 Jan‐05 May‐08 40 (web site: http://findarticles.com/p/articles/mi_m0EIN/is_2005_May_2/ai_n13664268/) scrubber contract

signed Jan 2005 ‐ Chiyoda JBR.  (http://www.georgiapower.com/environment/air_quality.asp) Bowen scrubber

commercial operating May 2008.  

1/1/2008

Monroe 3 795 Jul‐06 Nov‐09 41 (web site:

http://www.redorbit.com/news/business/560181/washington_group_international_to_retrofit_scrubbers_at_det

roit_edison_power/index.html )  WGIselected to provide EPC  for WFGD's on Monroe units 3&4 ‐ 5 july 2006;  

(web site: http://www.tradingmarkets.com/.site/news/Stock%20News/2657108/)  unit #3 WFGD operational 16

Nov 2009. note ‐  ceramic wfgd  vessel (tile w concrete).

11/1/2009

E W Brown 1 94 Dec‐05 Apr‐10 52 (web site: http://www.corporatenews.net/_client/RL24592/Ghent‐Brown%20FGD%20Final.pdf)  contract award

EPC (WFGD) Gent units 1,3,4 & EW Brown units 1,2,3 98% SO2 Removal. Award Dec 2005. [note: will use CAMD

SO2 control date  ‐ 4/1/2010)

4/1/2010

E W Brown 2 160 Dec‐05 Apr‐10 52 (web site: http://www.corporatenews.net/_client/RL24592/Ghent‐Brown%20FGD%20Final.pdf)  contract award

EPC (WFGD) Gent units 1,3,4 & EW Brown units 1,2,3 98% SO2 Removal. Award Dec 2005. [note: will use CAMD

SO2 control date  ‐ 4/1/2010)

4/1/2010
15

                                                           

1 Staudt, Availability of Resources for Clean Air Projects, October  2010,

http://www.andovertechnology.com/images/white%20paper%20‐

%20availability%20of%20resources%20for%20clean%20air%20projects_public.pdf

2 National Electric Energy Data System

3 Staudt, U.S. Power Companies Actively Planning for Compliance with Clean Air Rules; Significant Work is Already

Underway, December 2011, http://www.andovertechnology.com/images/compliance_progress.pdf

4 Huggins, et al, Implementation Strategies for Southern Company FGD Projects, 2010 Mega Symposium , Paper#68

5

Best Coal‐fired Projects , Springerville Unit 3 Expansion Project, Power Engineering, December 2006,

http://www.powergenworldwide.com/index/display/articledisplay/277709/articles/power‐engineering/‐

/2006/11/best‐coal‐fired‐projects.html