Technical Support Document (TSD) 

for the Transport Rule 

Docket ID No. EPA-HQ-OAR-2009-0491 

Installation Timing for Low NOX Burners (LNB) 

U.S. Environmental Protection Agency 

Office of Air and Radiation 

July 2010 

1 
Installation Timing for Low NOX Burners (LNB) 

Section IV.D in the preamble to the Transport Rule discusses EPA’s proposed 

approach to quantify upwind state emissions that significantly contribute to 

nonattainment or interfere with maintenance downwind. That section of the preamble 

references EPA’s assumptions regarding the length of time required to install certain air 

pollution controls including low NOX burners (LNB). In this Technical Support 

Document we explain briefly EPA’s assumption that sufficient LNB can be installed by 

2012 for the Transport Rule. 

EPA analysis in support of the Transport Rule indicates that there may be on the 

order of about 30 coal-fired boilers for which it might be economic to install low NOX

burners to achieve compliance. These roughly 30 boilers are located in the four states 

that the proposed Transport Rule would cover but which are not required to reduce 

emissions under the Clean Air Interstate Rule (CAIR).1 EPA analyzed only these four 

states because it is assumed that sources in CAIR states already control NOX emissions. 

EPA anticipates finalizing the Transport Rule by about June 2011. LNB 

installations, burner modifications, or other NOX reduction controls would likely have to 

be installed during fall 2011 or spring 2012 outages in order to achieve significant 

reductions for 2012. While this schedule is aggressive, industry has shown that it can be 

met. Limestone Electric Generating Station Unit 2, a 820 MW tangentially fired lignite 

unit, was retrofitted with Foster Wheeler’s Tangential Low NOX (TLN3) system in less 

than six months, including engineering, fabrication, delivery and installation.2 Harlee 

 

1

 The states of Kansas, Nebraska, and Oklahoma are not covered by CAIR but would be covered by the 

proposed Transport Rule. Minnesota would be covered by the proposed Transport Rule and is included in 

CAIR, however, EPA stayed the effectiveness of CAIR in Minnesota (74 FR 56,721; November 3, 2009). 

2

 R. Pearce, J. Grusha, Reliant Energy Tangential Low NOx System at Limestone Unit 2 Cuts Texas 

Lignite, PRB and Pet Coke NOx, http://www.fwc.com/publications/tech_papers/files/tp_firsys_01_02.pdf 

2 
3 

 

Branch Unit 4, a 535 MW cell-fired unit, was retrofitted with Riley Power’s low-NOX

Dual Air Zone CCV burners on a similar schedule.3 

In addition to LNB retrofits and burner modifications, there are other approaches 

that can be implemented in a short time frame to achieve significant NOX reduction. 

Relatively simple Selective Non-Catalytic Reduction (SNCR) systems can be installed 

quickly. Likewise, the re-tuning or upgrading of existing combustion control systems can 

often provide significant NOX reductions and can be performed quickly.4

There are many LNB technology suppliers currently working in the U.S., 

including Alstom, Babcock Power, Babcock & Wilcox, Combustion Components 

Associates, Foster Wheeler, Fuel Tech, General Electric, RJM, and Siemens. With the 

current tailing-off of new coal plant construction and with recent SO2 scrubber 

installations winding down, these and other firms in the supply chain have the ability to 

respond quickly to a large amount of new orders for emission control systems. They are 

capable of completing LNB retrofits, burner modifications, and other control approaches 

on at least 30 coal-fired boilers in time to obtain significant NOX reductions in 2012.5

3

 B. Courtemanche, et al, Reducing NOX Emissions and Commissioning Time on Southern Company Coal 

Fired Boilers With Low NOX Burners and CFD Analysis, http://www.babcockpower.com/pdf/t-182.pdf 4

 D. Foerter, Institute of Clean Air Companies (personal communication with EPA staff, June 14, 2010) 5

 Ibid