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# 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

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# 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 Precipitato r – controls particulates FF Fabric Filter (baghouse) – controls particulates
FGD Flue Gas Desulfurization – controls SO 2 

# 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 Reduc tion – controls nitrogen oxides WetFGDeq Wet FGD equivalent - The amount of an APC technology expressed as its GW equiva lent 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 t echnology that may need to be newly retrofitted and in service by the compliance da te(s). EPA used the latest vers ion of its IPM model to analyze which APC technologies would likel y be used, and in what quan tities, 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 ea rly starts, would result in the majority of the needed retrofits being installed by Fe bruary 2015 with the possibility of some installations needing up to an additional year fo r completion. In order for all retrofits to be completed by February 2015, more projects woul d have to start early and the sector would have to engage in a more aggressive deploym ent 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 oppo rtunity to apply for a one-year extension.

ANALYTICAL APPROACH

Site-specific feasibility studies are typically pe rformed 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 achie ve timely compliance with MATS on a national scale cannot replicate the same level of detailed analys is of either specific plants or of individual components of the APC “supply chain.” Various deta iled analyses of the supply chain have been conducted for past rules, usually resulting in a significant underestimate of what was ultimately achieved in practice 1 

# . 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,

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# much less for owner compliance strategies at all a ffected 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 pa st. EPA recognizes that a wide range of sitespecific conditions will result in a range of “b etter-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 approp riate level of detail.

RECENTLY DEMONSTRATED DEPLOY MENT CAPABILITIES OF THE APC
SUPPLY CHAIN

Annual GW capacity additions are plotted in Figu re 1 for the two most resource intensive APC systems: flue gas desulfurization (FGD) and se lective catalytic reducti on (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 pa rt of new coal plan t construction. The FGD component is a sum of wet and dry FGD technol ogies. Dry FGD comprises about 12% of total
1990-2011 FGD additions. Annual installations of ne w coal-fired power plant capacity are also plotted to indicate the size of its role in contributing to APC a dditions. Although there have been no new coal power projects ordere d in the past two years, severa l are still in construction. The supply chain for coal power plants is thus an ac tive and applicable set of resources (including engineers, manufacturers, fabri cation shops, craft labor, construc tion 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

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# The large, rather abrupt peak s 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 (CAI R) is also apparent. These data depict a recent major ramp-up in the APC deployment capab ilities of all industry participants, including plant owners, the APC supply chain, a nd 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-enga ged, can quickly return to producti on at historic rates, and can be quickly augmented by additional availabl e resources to increase production rates beyond
historic levels.

RETROFIT PROJECTIONS FOR MATS

Table 1 shows the types and quantities of APC re trofits that EPA has pr ojected the sector to adopt for MATS compliance. “Retrofit GW” refers to the total generating capacity of coal-fired units that are projected to r eceive each APC technology. For exam ple, 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 cap acity affected by retrofits b ecause many generating units will
elect to install more than one APC technology.

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

APC Technology Wet
FGD Dry FGD w/ FF* SCR FF DSI ACI FGD upgrades** 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 othe rs, 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 rate s, 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 implemen tation. 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 system s on individual units. Th erefore, although IPM projections based on “model plants” have prove n to be excellent predictors of economic

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# technology deployments on a state-wi de, regional, and national basi s, 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 al l APC technologies in th is analysis. Use of a single metric facilitates an extr apolation of historic deployment rate data for wet and dry FGD and SCR to assess feasible future deployment rate s needed for the retrof it technologies projected for MATS. Such a single metric permits assessment of the overall combined feasibility of all APC retrofits projected. This metr ic should be regarded as “avera ge,” not capturing the specifics of any particular site, but representing average difficulty across many projects.

As shown in Table 2, EPA converted the proj ected Retrofit GW capacities of each technology from Table 1 into an “equivalent wet F GD 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 F GD 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 inst alled and commissioned retr ofit project elements (engineering, equipment, construction labor, proj ect 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 Technol ogies 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 asso ciated with APC technol ogies individually and in total, on the basis of current market conditio ns. They do not directly represent the relative calendar times required to insta ll individual technologies. Wet F GD was selected as the “base” technology for this metric because it has been wide ly deployed, is familiar to the industry, has the highest capital cost, uses the most supply ch ain resources, and requi res 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 am ong many factors (including site conditions, APC designs, and supply chains), and to consider th e aggregate level of effort projected for the sector to r each overall MATS compliance.

TRENDS IN TOTAL RETROFIT DEPL OYMENT EFFORT (GW WetFGDeq)

Figure 2 shows the total annual historical AP C additions from Figure 1 and current APC
commitments for the future usi ng the WetFGDeq metric. Figure 2 re veals the pattern of retrofit deployment driven solely by CAIR, showing separately the WetFGDeq of APC capacity
installed for other reasons. Note that the retrof it 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 coordina tion with that rule. Figures 1 and 2 both demonstrate the sector’s early deployment of APC c ontrols in advance of CAIR compliance
deadlines of 2009 for NO x 

# and 2010 for SO 2 

# . 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 i mmediately 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 syst em. 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

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# peak. The currently available APC resource pool might thus be up to twice as large as would otherwise be expected, and well ab le 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 suppor ting 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 R ETROFIT INSTALLATIONS

APC Retrofit Planning EPA thinks it likely that the major ity of coal-fired power plant owners performed site-specific APC retrof it 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 comb ination 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 NO x 

# and 2010 for SO 2 

# . 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 fina l 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 0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0GW WetFGDeq 

# APC, GW WetFGDeq New Coal, GW WetFGDeq

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# MW of installed wet FGD systems on 14 units. 4 

# Subsequent commitments from many more owners encouraged a continuing e xpansion of the supply chain, w ith 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 wh en 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 tri ggered 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 AP C retrofits can be completed far more quickly than were historical APC proj ects. 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, fo r 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 sc hedule was about 38 months. The main point here is that typical schedules for large complex pow er projects can be si gnificantly 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 al so 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 th e 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 incr eases marginal operating costs without a certain regulatory benefit. Factors that will likely acce lerate project schedules under MATS include the
use of overtime and/or two-shift work schedul es during construction, an d 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 AP C components can also shorten schedules and reduce job hours. Als o, 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. Ex tended lead times in the 2007/2008 time period, as high as 18 months for key wet FGD engineered e quipment (such as large recycle pumps, large motors, and chimneys) contributed to extended we t FGD project durations. Increased lead times

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# quickly subsided as the supply ch ain processed the ini tial influx of orders for this equipment. Neither CSAPR nor MATS, however, as shown in Ta ble 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 sorb ent injection (DSI) a nd 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 ow ners 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 offere d 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 exis ting unit with newly retrof itted 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 exp ectation 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 ac tions under previous trad ing-based regulations. Ultimately, affected plant owners should already ha ve 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 va rious participants in the supply chain depend on when their particular activ ity (engineering, manufa cturing, fabrication, construction, etc) occurs in an APC project sche dule. As shown in Figure 3, the deployment rate is currently in a second year of decline. Therefor e, 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 decrea sed very significantly. Overall, the current activity level of front-end resources is supporting committed project s that will likely come on-line in the 2013- 2015 time frame, corresponding to an annual baselin e deployment rate of 10 GW WetFGDeq or less. Not shown in Figure 3 are any additiona l deployments that may be made by 2014 in

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# response to CSAPR. EPA’s IPM an alysis for CSAPR projected a need for at most 6 GW of FGD retrofits by 2014. This is an amount that has likel y already accelerated a ramp-up in supply chain activity, but, as discussed below, is well within the previously demonstrat ed 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 rene wed 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 si milar time frame under CAIR, and leaves demonstrated capability for limited additional deployments under CSAPR as well. This initializing assumption is supported by EPA e ngineering staff interaction with the supply chain community and informal appraisals of the current activity a nd preparedness of the sector. The starting point assumption directly influe nces 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 reasona bly 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 th is 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 th at although this We tFGDeq analytical concept appears to suggest th at nothing is deployed until 2014; in reality there would likely be deployed increasing amounts of DSI, activated carbon injec tion (ACI), fabric filter (FF) technology, and upgrad es of existing FGD and ESP starting in the earliest years, 2012 and 2013, and continuing throughou t 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 cumula tive deployment of 44 GWeq. A further 20 GWeq is completed by February 2016, t hus 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 se ctor may find more productive rout es to effective and efficient compliance not yet reflected in the historic record.

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# Table 4: APC Deployment Scen arios, 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

resource s 28 64

Source: EPA



# The relative magnitudes of past and projecte d 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 wit hout the Rule. This visual representation of the relative ma gnitudes of the resources involv ed 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 An nual 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 th ree 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 “throttl e back” its resource growth; it would tap all
available sources until all resources that are need ed are in place to pr oduce 64 GW WetFGDeq of deployments by early 2015. Under this more a ggressive 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 70.0GW 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 di fference 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 re trofitted 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 limit ed 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 accurate ly 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 mi nimize resource needs and capital cost, could significantly limit the number of APC systems a nd projects involved. Shared APC systems will allow the overall effort to be more manageable than otherwise, and s hould 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 th an 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 inst alled for CAIR. They will entail far fewer component suppliers, less proce ss engineering effort, fewer tec hnical specifications, etc. A typical upgrade or fabric filter project is therefor e far less difficult to manage or supervise than a typical wet scrubber project. Likewise they are easi er 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 pe rsonnel than CAIR experience and the WetFGDeq metric might suggest.

Referring again to Figure 4, EPA expects that the combined unde rutilized resources for the APC and New Coal supply chains, pos sibly supplemented with underut ilized 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 SO 2 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+Scr ubber+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/scr ubber_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/0 5072007_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/scr ubber_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/pch 570.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+%24 375+M illion+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 ) WGI selected 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/pch 570.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+%24 375+M illion+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 ) WGI selected 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/RL 24592/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/RL 24592/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.c om/images/white%20paper%20

‐ %20availability%20of%20resources%20for%2 0clean%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/d isplay/articledisplay/ 277709/articles/power

‐ engineering/

‐ /2006/11/best

‐ coal

‐ fired

‐ projects.html