EPA

- 6 0 0 / R

- 0 2 / 073

O c t o ber 2 0 0 2 

# Final Report

ENGINEERING AND
ECONOMIC FACTORS

AFFECTING THE
INSTALLATION OF CONTROL

TECHNOLOGIES FOR
MULTIPOLLUTANT

STRATEGIES

The information presented here reflects EPA's modeling of the Clear Skies Act of 2002. The Agency is in the process of updating this information to reflect modifications included in the Clear Skies Act of 2003. The revised information will be posted on the Agency's Clear Skies Web site (www.epa.gov/clearskies) as soon as possible.

## clobtloa

The U. S. Environm ental Protection Agency is charged by Congress with protecting the Nation' s land, air, and water resources. Under a m a ndate of national environm ental laws, the Agency

strives to form ulate and im plem ent actions l eading to a com p atible balance between hum an activities and the ability of natural sy stem s to s upport and nurture life. To m eet this m a ndate,

EPA' s research program is providing data and technical support for solving environm ental problem s today and building a science knowledge base necessary to m a nage our ecological resources wisely

, understand how pollutants a ffect our health, and prevent or reduce

environm ental risks in the future.

The National Risk Managem e nt Research Laborator y is the Agency 's center for investigation of technological and m a nagem e nt approaches for reducing risks from threats to hum an health and

the environm ent. The focus of the Laboratory ' s research program is on m e thods for the prevention and control of pollution to air, land, water, and subsurface resources, protection of water quality in public water sy stem s; rem e dia tion of contam inated sites and groundwater; and prevention and control of indoor air pollution. The goal of this research effort is to cataly z e developm ent and im plem entation of innovative, cost-effective environm ental technologies; develop scientific and engineering inform ation needed by EPA to support regulatory and policy decisions; and provide technical support and in form ation transfer to ensure effective

im plem entation of environm enta l regulations and strategies.

This publication has been produced as part of th e Laboratory ' s strategic long-term research plan. It is published and m a de available by EPA's O ffice of Research and Developm ent to assist the

user com m unity and to link researchers with their clients.

E. Tim o thy Oppelt, Director National Risk Managem e nt Research Laboratory



### EPA REVIEW NOTICE

This report has been peer and administrativel y reviewed by the U.S. Environmental Protection Agency, and approved for public ation. Mention of trade names or commercial products does not constitute endorsement or recommendation for use.

This document is available to the public through the National Technical Information Service, Springfield, Virginia 22161.

ii

### EPA-600/R-02/073

October 2002



# Engineering and Economic Factors Affecting the Installation of Control Technologies for Multipollutant Strategies

Prepared by: ARCADIS Geraghty & Miller 4915 Prospectus Drive, Suite F

Durham , NC 27713

EPA Contract No. 68-C-99-201

W o rk Assignm ent 3-034

U.S. EPA Project Officer: Ravi K. Srivastava National Risk Managem e nt Laboratory Research Triangle Park, NC 27711

Prepared for:

U.S. Environm ental Protection Agency

Office of Research and Developm ent

W a shington, DC 20460

iii

## ^ÅâåçïäÉÇÖÉãÉåíë

ARCADIS would like to acknowledge the m a ny c ontributors to this docum ent, without whose efforts this report would not be com p lete. In particular, we wish to acknowledge the advice of

Chad Whitem a n of Clean Air Markets Division, Office of Air and Radiation, U.S. Environm ental Protection Agency

. Helpful suggestions we re received from Kevin Culligan and Mary Jo Krolewski, both of Clean Air Markets Division. Technical guidance was received from Dr. Ravi Srivastava of the National Risk Managem e nt Research Laboratory

, Office of Research and Developm ent, U.S. Environm ental Protection Agency

.

ARCADIS would also like to acknowledge other or ganizations, which provided research that was incorporated into the report. These organi zations include ESI In ternational and Andover Technology Partners.

iv

## bñÉÅìíáîÉ=pìãã~êó

This report evaluates the engineering and econom ic factors of installing air pollution control technologies to m eet the requirem e nts of m u ltipollutant control strategies. The im plem entation

tim ing and reduction stringency of such strategi es affect the quantity of resources required to

com p lete the control technology installations and the ability of m a rkets to adjust and to provide

m o re resources where needed. Using the Integrated Planning Model (IPM), the U.S.

Environm ental Protection Agency (EPA) estim ated the num ber and size of facilities that need to

install new em issions control equipm ent to m eet the im plem entation dates and em ission

reductions set forth in the Clear Skies Act.

This study provides an estim ate of the resources required for the installation of control technologies to obtain em ission reductions of sulfur dioxide (SO 2 ), nitrogen oxides (NO

x ), and

m e rcury under the Clear Skies Act. More innovative control technologies and com p liance alternatives requiring fewer resources than those considered for this study are likely to be developed with the im plem entation of the Clear Skies Act. Market based approaches reward

firm s for finding cost-effective m easures that ex ceed em ission reduction targets. For exam ple,

im proved scrubber perform ance and the ability of som e firm s to switch to lower sulfur fuels under the Acid Rain Program were reasons the co st of that program were less than projected. The developm ent of control technology alterna tives to selective cataly tic reduction (SCR) under

the NO X State Im plem entation Plan (SIP) Call is another exam ple of how alternative solutions

m a y require fewer resources than the projected approach. In addition to innovative technologies,

the tim e allowed for installation of significant num bers of control technologies is an im portant factor to consider, especially for the near futu re. While it is expected that m a rkets for the

m a terials and labor used in the constructi on and operation of the control technologies will respond to increased dem a nd, this response will not be instantaneous. It is likely that the strength of this m a rket response will increase as tim e progresses. It is expected that the m a rket

would have sufficient tim e to respond to phase II of the program as the m o re stringent em ission targets for phase II are set for 2018. Even though th is analy s is looks at the resource availability bey ond 2010, these projections are of lim ited value as they do not take into account this m a rket

response. However, it is projected that there are sufficient resources available to com p lete the projected control technology installations for phase I by 2010. It should also be noted that decreasing the am ount of tim e provided to install control technologies to m eet a given strategy has the potential to affect the cost of com p liance as this will accelerate their installation.

The control technologies considered by this re port as candidates to be used for m u ltipollutant control strategies include: lim estone forced oxida tion (LSFO) flue gas desulfurization (FGD) for

the control of SO 2 , SCR for the control of NO X , and activated carbon injection (ACI) for the

control of m e rcury

.

Installation of LSFO presents a conservatively high estim ate of anticipated resources and tim e to provide additional control of SO 2 em ission, since LSFO sy stem s com m only are m o re resource intensive than m a ny other FGD technologies. Conservatively high assum p tions were m a de for

the tim e, labor, reagents, and steel needed to install FGD sy stem s. For LSFO installation tim ing, it is expected that one sy stem requires about 27 m onths of total effort for planning, engineering, installation, and startup, with connecti ons occurring during norm a lly scheduled outages. Multiple retrofits at one plant would take longer to install (e.g., approxim a tely 36 m onths for the

vretrofit of three absorbers for six boilers). Lim estone is the reagent used in LSFO to rem ove SO 2 from the flue gas stream

. Steel is the m a jor hardware com ponent for FGD sy stem s and is used prim arily for the absorber, ductwork, and supports.

Other elem ents of FGD installations, such as c onstruction equipm ent requirem e nts, are ty pically

m odest, particularly given that sy stem s are installed at the back end of the facility and close to the ground. More recently , im provem e nts in technology have been im plem ented where space requirem e nts were an issue for construction and accom m odating the FGD sy stem , including

fewer and sm aller absorbers and m o re efficient on-site use and treatm e nt of wastes and by products.

SCR is currently the predom inant technology to be used for NO X control and is also the m o st
dem a nding in term s of resources and tim e to install when com p ared to other NOx control technologies. It is expected that one SCR sy stem requires about 21 m onths of total effort for planning, engineering, installation, and startup. Multiple SCR sy stem s at one facility would take longer to install (e.g., approxim a tely 35 m onths for seven SCRs). Am m onia and urea are the reagents used along with a cataly s t to rem ove NO X from the flue gas stream

. Experience in installing SCRs for the NO X SIP Call has shown that the SCR equipm ent can be installed on the facilities in the space provided. In som e cases, som e m oving of equipm ent has been necessary

. One of the prim ary pieces of specialized construction equipm ent that can be useful for SCR installations are tall, heavy

- lift cranes, a nd these appear to be in adequate supply

.

ACI was presum e d to be the technology that would be used to reduce m e rcury where dedicated

m e rcury controls were needed. Planning, engi neering, installation, and start up of one ACI

sy stem is only about 15 m onths. Multiple ACI sy stem s at any one facility are assum e d to take longer to install (e.g., approxim a tely 16 m onths for two ACI). ACI hardware is com p rised of relatively com m on m echanical com ponents and is largely m a de of steel. An ACI sy stem requires

m

u ch less in term s of steel, labor, or other resources to install than either FGD or SCR technology

. Therefore, the im pact of ACI hardware on resource dem a nd is m u ch less than that of FGD or SCR technologies for SO 2 or NO X control, respectively

.

The resources required for the installation of control technologies to achieve the em ission

reductions under the Clear Skies Act were estim ated and com p ared to their current m a rket availability

. For the Clear Skies Act, control tec hnology installations have been looked at for the periods between now and 2005, 2005 and 2010, 2010 and 2015, and 2015 and 2020. For the first period, it is assum e d that all controls need to be installed in a 31-m onth period. This will provide a conservatively high estim ate of the required resources because m a ny of the necessary control installations have already begun. For the other five y ear-periods, it is conservatively estim ated

that all installations will be com p leted within three y ears. However, the estim ates indicate that

there is am ple steel and general constructi on labor to support the installation of these technologies over these tim e periods. As noted above, projections bey ond 2010 are of lim ited

value as m a rket conditions could change signi ficantly between now and 2010 in response both to

dem a nd for resources for a m u ltipollutant program and because of other m a rket factors. Skilled labor requirem e nts, specifically for boilerm akers, were estim ated and have the potential to be the

m o re lim iting resource requirem e nt in phase I of the program

. The dem a nd for boilerm aker labor

due to the NO X SIP Call over the next few y ears is likely to be lim iting, but through the

im plem entation of the Clear Skies Act, additional recruiting and training of new boilerm akers would create a stronger m a rket for skilled labor, ultim ately increasing the supply

.

viWith regards to reagents and other consum ables, it is projected that there is sufficient supply of

lim estone for additional FGD sy stem s. It is estim ated that there is also enough SCR cataly s t capacity to supply this m a rket. Am m onia and urea supply is also plentiful, although it is expected that NO X reduction will cause a m oderate increase in U.S. dem a nd. Bolstered by the fact that there is currently a worldwide ex cess capacity problem for suppliers of these globally

traded com m odity chem icals, it is projected that there will be an am ple supply of am m onia and

urea. U.S. dem a nd for activated carbon is expect ed to slightly increase as a result of the Clear

Skies Act. Activated carbon is traded on a globa l basis and there is currently substantial excess capacity that can readily provide for this increase in dem a nd.

viiviii

## `çåíÉåíë

Acknowledgem e nts

............................................................................................................... .......... iv

Executive Sum m a ry

.............................................................................................................. ............ v

List of Figures

................................................................................................................ ................. xi

List of Tables

................................................................................................................. ................ xii

List of Acrony m s

............................................................................................................... ........... xiii

Chapter 1 B ackground

............................................................................................................ 1

Chapter 2 SO 2 Control Technology Retrofits

......................................................................... 3

2.1 S y s tem Hardware

................................................................................ 3

2.2 R eagents

.............................................................................................. 6

2.3 Construction Equipm ent

..................................................................... 7

2.4 Installation Tim e

................................................................................. 7

2.5 Labor

................................................................................................. 11

2.6 Space Requirem e nts

.......................................................................... 12

Chapter 3 N O X Control Technology Retrofits

...................................................................... 15

3.1 Sy stem Hardware

.............................................................................. 15

3.2 Cataly st and Reagents

....................................................................... 18

3.3 Construction Equipm ent

................................................................... 19

3.4 Installation Tim e

............................................................................... 20

3.5 Labor

................................................................................................. 22

3.6 Space Requirem e nts

.......................................................................... 24

Chapter 4 M ercury Control Technology Retrofits

................................................................ 26

4.1 Sy stem Hardware

.............................................................................. 26

4.2 Reagent

............................................................................................. 29

4.3 Construction Equipm ent

................................................................... 30

4.4 Installation Tim e

............................................................................... 30

4.5 Labor

................................................................................................. 32

4.6 Space Requirem e nts

.......................................................................... 34

Chapter 5 S y n ergies of Com b inations of Control Retrofits on a Single Unit

....................... 35

5.1 SCR and FGD (Scrubber) Installations

............................................ 35

5.2 Mercury Control Technology and Scrubber Installations

................. 35

5.3 Mercury Control Technology and SCR Installation

......................... 36

ixChapter 6 S y s tem Res ource Availability

.............................................................................. 37

6.1 S y s tem Hardware

.............................................................................. 40

6.2 L abor

................................................................................................. 41

6.3 C onstruction Equipm ent

................................................................... 46

6.4 R eagents

............................................................................................ 47

6.5 C reation of Jobs under Clear Skies Act due to Control Technology

Installations

....................................................................................... 53

Chapter 7 C onclusions

.......................................................................................................... 5 4

Chapter 8 R ef erences

.......................................................................................................... 58

Appendix A I m p lem e ntation Schedules for Control Technology Installations

..................... A-1

x

## iáëí=çÑ=cáÖìêÉë

2-1. Gas path for coal-fired boiler with FGD

.................................................................................. 4

2-2. Major com ponents of Wet FGD

............................................................................................. .5

3-1. Gas path for coal-fired boiler with SCR, ESP, and FGD

....................................................... 15

3-2. SCR installation at 675 MW

e AES Som e rset Station

............................................................ 16

3-3. Plate and honey c om b cataly s t

............................................................................................. ... 17

4-1. Gas path for coal-fired boiler with SCR, ACI, and ESP

........................................................ 27

4-2. Gas path for coal-fired boiler with SCR, ACI, ESP, and FF

.................................................. 27

4-3. Sim p lified schem a tic of ACI sy stem

...................................................................................... 2 8

6-1. U.S. construction em ploy m e nt and unem p loy m ent

............................................................... 42

6-2. Boilerm aker Dem a nd Under Clear Skies Act (32 GW

e of FGD Installations)

...................... 44

6.3. Boilerm aker Dem a nd Under Clear Skies Act (10 GW

e of FGD Installations)

...................... 45

6.4. Cum u lative SCR Cataly st Dem a nd Com p ared To Cum u lative Production Capacity

............ 50

6-5. SCR installations on coal-fired plants in Germ any

................................................................ 51

xi

## iáëí=çÑ=q~ÄäÉë

2-1. Estim ated Resources Needed for Single and Multiple FGD Retrofits

................................... 13

3-1. Estim ated Resources Needed for Single and Multiple SCR Retrofits

................................... 24

4-1. Estim ated Steel Requirem e nt for 500 MW

e ACI Sy stem....................................................... 29

4-2. Estim ated AC Injection Rates for a 500 MW

e Boiler

............................................................ 30

4-3. Estim ated Man-hours for Supply of an ACI Sy stem for a 500 MW

e 0.6 % Bitum i nous

Coal Boiler Coal with ESP (Exam p le 1 from Table 4-4) 33

................................................... 32

4-4. Estim ated Perform ance and Resources Needed for Single ACI Retrofit

............................... 33

4-5. Estim ated Perform ance and Resources Needed for Single and Multiple ACI Retrofits

........ 34

6-1. a) FGD Retrofits, b) S CR Retrofits, c) ACI Retrofits

............................................................ 38

6-2. Estim ated Steel Required for Multipollutant Initiative

.......................................................... 40

6-3. Estim ated Annual Construction and Boilerm aker Labor Required for Clear Skies Act

........ 41

6-4. Estim ated Annual Boilerm aker Dem a nd Created by the Clear Skies Act

............................. 46

6-5. Crushed Lim estone Sold or Used By U.S. Producers

............................................................ 47

6-6. Estim ated FGD Lim estone Consum ption and U.S. Production

............................................. 48

6-7. SCR Cataly st Capac ity for Coal-fired Boilers

....................................................................... 48

6-8. Estim ated Annual SCR Cataly st Dem a nd Resulting from Clear Skies Act

and NO X SIP Call

................................................................................................................. 49

6-9. Projected AC Dem a nd Due to Multipollutant Initiative

....................................................... 52

7-1. Estim ated Resources Needed for Inst allation and Operation of Technologies

...................... 57

xii

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AC Activated carbon

ACI A ctivated carbon injection

CAAA Clean Air Act Am endm ents

DCS D istributed control sy stem

ESP Electrostatic precipitator

FF Fabric filter

FGD F lue gas desulfurization

GW

e Gigawatt (electric)

IPM I ntegrated Planning Model

LSD Lim e spray dry e r

LSFO Lim estone forced oxidation

MEL M agnesium enhanced lim e

MW

e Megawatt (electric)

NAAQS National Am bient Air Quality Standards

PJFF Pulsejet fabric filter

PLC Program m a ble logic controller

SCR S elective cataly tic reduction

SIP S tate Im plem entation Plan

TVA T ennessee Valley Authority

xiiixiv

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In response to continuing concerns about em issions from electric generating units, further reductions of

em issions of m u ltiple pollutants from electric power sector are being considered. Because the largest portion of em ission reductions are expected to com e from the coal-fired electricity -generating segm e nt of the electric power sector, this report considers environm ental im provem e nt for coal-fired electricity generating power plants. Strategies enabling the cont rol of m u ltiple pollutants (m ultipollutant control strategies) from these plants have recen tly been receiving increased attention.

Currently , power plants are required to reduce em issions of nitrogen oxides (NO X ) and sulfur dioxide (SO 2 ). The revisions of the National Am bient Air Quality Standards (NAAQS) aim e d at reducing haze

m a y require electric utility sources to adopt additional control m easures. In addition, the U.S.

Environm ental Protection Agency (EPA) has determ in ed that the regulation of m e rcury em issions from coal-fired power plants is appropriate and necessary

. Concurrently , legislation has been proposed in previous and current Congresses that would require sim u ltaneous reductions of m u ltiple em issions, and

the Adm i nistration’s National Energy Policy reco m m e nds the establishm ent of “m andatory reduction targets for em issions of three m a in pollutants: sulfur dioxide, nitrogen oxides, and m e rcury

. ”

The adm i nistration’ s m u ltipollutant proposal, a far reaching effort to decrease power plant em issions,

was introduced as the Clear Skies Act in the U.S. House of Representatives on July 26, 2002 and in the U.S. Senate on July 28, 2002. This legislation is intended to reduce air pollution from electricity generators and im prove air quality throughout the country

. The Clear Skies Act is designed to decrease air pollution by 70 percent through an em ission cap-and-trade program , using a proven, m a rket-based approach that could save consum ers m illions of dollars. The Clear Skies Act calls for:

■ Decreasing SO 2 em issions by 73 percent, from current em issions of 11 m illion tons to a cap of 4.5

m illion tons in 2010, and 3 m illion tons in 2018,

■ Decreasing NOx em issions by 67 percent, from current em issions of 5 m illion tons to a cap of 2.1

m illion tons in 2008, and to 1.7 m illion tons in 2018, and

■ Decreasing m e rcury em issions by 69 percent by im plem enting the first-ever national cap on m e rcury

em issions. Em issions will be cut from current em issions of 48 tons to a cap of 26 tons in 2010, and

15 tons in 2018.

Therefore, it is tim ely to review the engineeri ng and resource requirem e nts of installing control technologies for m u ltipollutant control strategies.

This report analy zes the resources required for inst alling and operating retrofit control technologies for achieving reductions in m u ltiple pollutants from coal-fire d power plants in the United States. It exam ines the control technology ’s hardware, reagents, availa bility of the needed construction equipm ent, tim e required to im plem ent at plants with single and m u ltip le installation requirem e nts, and the availability of

labor needed for installation. The control technologi es considered in this report include lim estone forced oxidation (LSFO) wet flue gas desulfurization (FGD) , selective cataly tic reduction (SCR), and activated carbon injection (ACI) for the control of SO 2 , NO X , and m e rcury , respectively

.

The report is organized into eight chapters and one appendix. Chapter 1 provides general background

inform ation on em ission control technologies. Chapter 2 analy zes the SO 2 control technology resource

1requirem e nts by providing inform ation on control t echnology ’s hardware and r eagents, the construction equipm ent necessary to install a control technology

, tim e required to im plem ent this control technology at plants with single and m u ltiple installation requirem e nts, and the am ount of labor needed to install the control technology

. Chapters 3 and 4 review, in the sam e fashion, the resource requirem e nts of installing NO X and m e rcury control technology , respectively

. Chapter 5 focuses on sy nergistic

com b inations of control retrofits on a single unit. Chapter 6 exam ines the availability of resources

necessary for the installation of SO 2 , NO X , and m e rcury control retrofit technologies for the tim ing and

em ission reductions proposed under the Clear Skies Ac t. Conclusions are presented in Chapter 7 and references in Chapter 8. Appendix A is located at the end of this report. It provides im plem entation schedules for single and m u ltiple control technology installations.

2

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In this chapter, the resource requirem e nts to retrofit FGD sy stem s to rem ove SO 2 are exam ined for existing coal-fired electric utility boilers. The FGD t echnology m o st com m only installed in the U.S. and

worldwide is LSFO. Material, labor, and construc tion equipm ent resource estim ates presented in this chapter are for LSFO sy stem s and are a conservativ e estim ate com p ared to less resource intensive

m a gnesium enhanced lim e (MEL) or lim e spray dry e r (LSD) technologies. Ty pically , MEL and LSD technologies rely upon increased reactivity of reagents with flue gas and require fewer resources for

installation. Advances in FGD technology , design, m a terials, and expertise available for retrofit

installations m a de over the last decade form a sharp contrast to earlier retrofit sy stem s. Technology to

rem ove SO 2 is anticipated to continue along current tr ends and rely heavily on wet FGD and other advanced technologies. This chapter exam ines the experience and issues for the retrofit installation of LSFO technology

.

The chapter focuses on the resources needed for ty pical or norm a lly constrained wet FGD, specifically LSFO, retrofit installations. Wet FGD retrofit t echnology generally provides a conservatively high

estim ate of m o st resources. However, it is likely that other SO 2 rem oval technologies, as well as upgrades or enhancem ents to existing FGD sy stem s, will com p ete in the m a rket under a m u ltipollutant
strategy

. Upgrades to existing FGD sy stem s woul d include a case-by -case exam ination of the absorber tower, flue gas inlet, absorber gas velocity , reag ent preparation, upgrade pum ps, and potential changes to

som e internals, the ty pe of reagent, and to the chem ical processes to increase perform ance. Scrubber upgrades were not considered in this analy s is in or der to provide a conservative estim ate of the resource

dem a nd for a m u ltipollutant strategy

. This is because upgrades to existing retrofits will generally

consum e fewer resources than full retrofits regardless of the technology

.



### OKN **póëíÉã=e~êÇï~êÉ**

The wet FGD process operates by reacting SO 2 in the flue gas with a r eagent in an absorber. FGD

sy stem s are ty pically positioned after the particulate control device. FGD retrofits are positioned

downstream , ty pically at the back end of the facility , and are not intrusive to the boiler. Ty pical configuration is shown in Figure 2-1. At the ty pical unit, hot corrosive flue gases leaving the particulate control device (149– 182 oC) are cooled, or quenche d, before entering the m a in absorber device. Quenching cools and saturates the flue gas with abso rber slurry

. Quenching can occur in a prescrub area

or m o re com m only an area integral to the absorb er. After quenching, the less corrosive flue gases entering the absorber decrease to tem p eratures of 49 – 66 o C with pH values between 5 and 6.5. Som e higher efficiency boilers m a y have increased flue gas velocities and can result in corrosive flue gas “blow through” to the absorber. The chem ical reactions th at occur with the lim estone reagent form a corrosive

environm ent requiring m a ny of the sy stem com ponents to be corrosion and abrasion resistant. The quenching area is ty pically a highly corrosive environm ent and the reagent slurries are highly abrasive. The handling and processing of the reagent, com m onl y lim estone, is often done onsite, as is the treatm e nt of the effluent as waste or processing into a saleable product (e.g., gy psum handling facility ).

3exhaust

F GD



### B o iler SCR

ESP

Co m bustion Air Coal By product/Waste Stack

Disposal



### Figure 2-1. Gas path for coal-fired boiler with FGD.

The m a jor sy stem s and com ponents of a wet FGD lim estone reagent sy stem include:
Reagent Feed

■ Lim estone convey i ng and crushi ng (e.g., ball m ills) equipm ent

■ Slurry preparation tank and reagent feed equipm ent

SO 2 Rem oval

■ Absorber tower or reactor (tray optional)

■ Absorber slurry recirculation/reaction tank a nd optional air sparger (forced oxidation operation)

■ Mist elim inator wash sy stem

■ Slurry bleed

■ Pipes, pum ps, and valves

■ Gas reheaters
Flue Gas Handling

■ Ductwork

■ Support steel

■ Fans, blowers, and dam p ers Waste/By -Product

■ Dewatering sy stem (settling tanks/vessels, hy drocy c lones, and/or vacuum filters)

■ Stacking equipm ent

Major wet FGD sy stem com ponents are shown in Figur e 2-2. The hardware and equipm ent to support wet FGD technology involves five m a jor sy stem s. Two sy stem s are prim arily responsible for the direct scrubbing and handling of flue gases, and three sy stem s are involved with delivery of reagents, processing of wastes (air, solids, and water), and the processing of wastes into saleable by -products. Ty pically , the greatest hardware requirem e nts involve the sy stem s for SO 2 rem oval, prim arily the absorber vessel, and flue gas handling, particularly ductwork and support steel. Much of the equipm ent for these sy stem s will be unique to the site a nd project requirem e nts, although the equipm ent

4specifications m a y be repeated if m u ltiple absorbers are involved. Ty pically an FGD retrofit can use an existing chim ney or stack.



### Figure 2-2. Major com ponents of wet FGD.

The m a terial used in the largest qua ntity for an FGD retrofit, aside from reagent, is steel. In general, the

am ount of structural steel for a ty pical FGD retrofit sy stem is equal to or less than the steel requirem e nts
for a SCR retrofit of the sam e size. 1 The reduced requirem e nt for structural steel is due to the FGD absorber usually being self-supporting, weighing less, and being installed closer to the ground. In
contrast, a ty pical SCR installation is heavier, elev ated, and adjacent to the boiler. The m a jority of

structural steel in m odern FGD installations is de dicated to ductwork and supports. Other steel m a y be needed to reinforce existing steel at a facility . In a ddition to structural steel, additional light, or gallery

, steel m a y be used in the lim estone preparation area and for the processing of waste or by products (e.g., buildings). Modern FGD sy stem s are m o re attuned to the corrosive SO 2 scrubbing environm ent and therefore increasingly utilize fiberglass, rubber lined steel, and alloy s in construction. In addition, because of existence of corrosive zones, preference is often given to the use of large-sized sheets that

m i nim i ze welding. 2 Large-sized sheets are used to fabri cate the absorber vessel, the ductwork, and
supports. Particularly over the past decade, there h as been greater availability of plate steel for FGD projects due to the global sourcing of carbon steel.

5Total steel requirem e nts for retrofitting a ty pical 500 m e ga Watt, electric (MW

e ) FGD sy stem are in the range of 1000 to 1125 tons of steel, or be tween 2.0 and 2.25 tons of steel per MW

e . This range assum e s approxim a tely 80 percent of the structural steel is for ductwork and supports and 20 percent is required

for m i scellaneous steel such as reagent convey i ng equi pm ent, buildings, and solids handling sy stem s. An

assum p tion of 1125 tons of steel is a conservatively high estim ate since 500 MW

e FGD retrofit

installations have been com p leted with as little as 250 to 375 tons of steel, or 0.5 tons of steel per

MW

e .. 1, 3 Often a single absorber will serve m u ltiple boilers and reduce m u ch of the steel that would be required if absorbers had been fed by individual boilers. Currently , the installed m a xim u m single absorber capacity in the U.S. is 890 MW

e being fed by 2 boilers at Tam p a Electric’s Big Bend Station. It is likely that two 450 MW

e boiler units will use a com m on single absorber with com m e nsurate reduction in required steel from efficiencies gained by com m on areas. For exam ple, a 900 MW

e sy stem is

estim ated to use approxim a tely 2000 tons of steel, or about 2.2 tons of steel per MW

e , rather than a

com b ined m a xim u m of 2025 tons for a situation in which the boilers required separate absorbers.

In general, a better understanding of the chem ical processes in an FGD sy stem allows designers to

m a xim i ze m ass transfer in a m i nim u m am ount of space. 4 More efficient designs can also reduce the

am ount of steel needed for the absorber and ductw ork. Other advanced design factors reduce steel requirem e nts, including the virtual elim ination of re dundant absorbers, the ability to down-size absorbers without sacrificing perform ance (e.g., by increasing fl ue gas velocity , advanced placem ent of spray nozzles, enhancing lim estone characteristics), and m a terial changes including wallpapering with alloy s and utilizing fiberglass. 5 A new generation of wet FGD sy stem s, pioneered in the m i d to late 1990’s,

im proved m ass transfer, which resulted in the usage of m o re com p act absorbers that are estim ated to require 50 percent less m a terial, com p ared to an older generation of wet FGD sy stem s. 5 In addition,
ty pical MEL absorber units need less steel due to the use of sm aller absorbers enabled by shorter

residence tim e requirem e nts than for LFSO sy stem s.

**==** In this report, the estim ate of ty pical LFSO FGD

sy stem hardware requirem e nts provides a conservatively high estim ate of installation resources com p ared

to other SO 2 control technologies.

The m a jority of hardware required for FGD sy stem s is com m only available. Storage tanks, nozzles, and piping for the reagent storage and delivery sy stem are also com m on and therefore widely available. The

m a jor hardware for an FGD sy stem includes the flue gas duct sy stem , lim estone storage (including loading and convey e r equipm ent), gy psum dewatering and wastewater treatm e nt, gy psum storage, piping, valves, pum ps and tanks, electricity supply

, controls, instrum e ntation, pipe bridges and cable channels, and foundations and buildings as needed. FGD sy st em s also include hardware such as inlet fans,

dam p ers, absorber internals, recirculation pum ps, a nd oxidation blowers that are com m only used in other large industries. Because this hardware is used extensively throughout industry

, availability should not be an issue, except that supply of this ty pe of e quipm ent needs to be integrated into the overall project

schedule so it does not cause bottlenecks. Early FGD sy stem s were designed with separate quenching, or prescrubber, sy stem s to cool the flue gas com i ng off th e particulate control device. Modern sy stem s take the hot flue gas directly into the absorber, where quenching occurs. Lim estone and gy psum handling also

includes m illing, convey i ng, and wastewater treatm e nt sy stem s.



### OKO **o É~ÖÉåíë** 

Wet FGD sy stem s require a continuous feed of reagent to rem ove SO 2

. Generally , if pH of scrubbing liquor falls below a range of 5.0 to 6.0, additional r eagent is required to m a intain the reactivity of the

absorbent. Lim estone is the m o st com m only used reagent, with the quantity of its consum ption depending prim arily on coal sulfur levels. For exam ple, even in the range of 3 percent to 4 percent coal

6sulfur levels, a 4 percent sulfur coal can increase consum ption by about one-third. 6 It is not uncom m o n for m odern FGD sy stem s to achieve 97 percent utilization of lim estone. 7 Generally , higher percent utilization equates to higher reactivity of the reagent, and, therefore, less reagent is needed to achieve a given level of SO 2 rem oval. The production of gy psum requires a m i nim u m of 92 percent lim estone
utilization.

A 500 MW

e plant uses roughly 25-32 tons per hour of lim estone. A coal with 4 percent sulfur, conservatively

, will require 32 tons * of lim estone per hour, or 0.064 tons per MW

e per hour. This

estim ate is based on an 85 percent load factor, 10,500 Btu/kWh, stoichiom e try of 1.1 for lim estone, SO 2

rem oval rate of 95 percent, and a m i nim u m purity of 95 percent for CaCO 3

. Any enhancem ent of the reagent (i.e., m a gnesium or buffering agents) will re duce the am ount of lim estone needed. MEL sorbent

consum ption for a 4 percent sulfur coal is approxim a tely 17-18 tons per hour. 6 These estim ates are conservatively high given that recent FGD sy stem s are operating at near stoichiom e tric levels 8 and

additives are com m only used to achieve higher SO 2 rem oval, particularly to enhance the perform ance of existing retrofits. Lim estone stoichiom e try is th e num ber of m o les of Ca added per m o le of SO 2

rem oved. Ty pically the required stoichiom e try of a wet FGD lim estone sy stem is in the range of 1.01 to 1.1, with 1.01 to 1.05 ty pical for m odern wet FGD sy stem s. 8 A stoichiom e try of 1.03 is ty pical when the FGD process is producing gy psum by -product, while a stoichiom e try of 1.05 is needed to produce waste

suitable for a landfill. Grinding lim estone to an ultrafine particle size im proves dissolution rate of

lim estone in the slurry and can decrease the size requirem e nt of the reaction tank. 8



### OKP **`çåëíêìÅíáçå=bèìáéãÉåí**

The construction equipm ent required for ty pical FGD in stallations is standard construction equipm ent – welders, excavation equipm ent, c oncrete pouring equipm ent, cranes, etc. Crane requirem e nts for FGD technology retrofits are generally site specific, although these requirem e nts are generally less dem a nding than requirem e nts for SCR retrofits. Generally , FGD sy stem s tend to be constructed closer to the ground

com p ared to SCR technology retrofits. Lift at a site rarely exceeds 30 m e ters (100 feet) and 100 tons.

The use of m odular and fabricated absorbers shifts m u ch of the construction off-site, reducing the need for specialized cranes and equipm ent. The useful ness and appropriateness of using cranes in an FGD installation is dependent on several factors, including the ability to phy sically place a crane on site or adjacent to the site (e.g., on a barge) and the u se of m odular construction of m a jor FGD technology

com ponents. Prefabrication has been used since th e early 1990’s, notably on two large retrofit projects:

the 1300 MW

e Zim m e r Station and the 2600 MW

e Gavin station. Both facilities had lim ited lay

- down area to perform the retrofit installation. In these tw o retrofits, the absorber m odules were fabricated in two pieces, shipped by barge, and assem bled on site. Often m odular units can be transported via barges

or trucks to the site for assem bly

. Com ponent m odularization and prefabrication off-site can reduce the

am ount of tim e cranes are needed on a site, as well as provide opportunities to reduce project schedules and construction costs and to concentrate j obs locally at the prefabrication facility

.



### OKQ **f åëí~ää~íáçå=qáãÉ** 

Im plem entation of an SO 2 control technology at a plant involves several activities contingent upon each

other. These activities m a y be grouped under the following phases of an im plem entation project: (1)

* EPA cost m odel i ng for wet scrubber i n st al l a t i ons est i m at e 29 t ons of l i m est one requi red t o achi e ve 95 percent SO 2

rem oval whi l e burni ng a 4 percent sul f ur coal

.

7conducting an engineering review of the facility a nd awarding a procurem ent contract; (2) obtaining a construction perm it; (3) installing the control technology ; and (4) obtaining an operating perm it.

Modular construction can m i nim i ze field labor and cons truction tim e on a site by prefabricating at a shop and then transporting large sections, such as ductwork or absorber m odules, by barge or truck. For

exam ple, the 550 MW

e boiler at Kansas City Power & Light Com p any ’ s Hawthorne Generating Station required rebuild and NO X , SO 2 , and PM sim u ltaneous control retrofits. To expedite placing the facility back into use, large sections were fabricated off site and transported by barge to the site. Shop

fabrication has also been used outside of the U. S. For exam ple, ten absorber m odules handling a

com b ined capacities of 2000 MW

e and 3000 MW

e at two facilities were installed during Decem ber 1995 (order placed) through March 2000. The ten absorbers we re m o stly installed sequentially with startup of the units staggered over 22 m onths. The 2000 MW

e FGD sy stem s at the Taean facility in South Korea

were fabricated off-site in three m odules, sh ipped by barge, and then assem bled on-site.

FGD installation plans and experience have been extens ive in the U.S. and abroad. To date, there have been approxim a tely 94 GW

e of scrubber capacity built on coal-fired power plants in the US. Over 200

GW

e of capacity has been built worldwide.

Exhibits A-1 and A-2 in Appendix A depict the tim elines ty pical to com p lete a single absorber m odule

and a three absorber-m odule installation of FGD, r espectively

. The three ab sorber-m odule installation

assum es each absorber m odule can treat up to 900 MW

e of boiler capacity . Currently , approxim a tely 900

MW

e of single absorber capacity has been successfully installed in the U.S. However, greater absorber capacities are being offered outside of the U.S. 9 While the sum of the tim e estim ated to com p lete individual tasks generally exceeds the overall estim ated installation tim e, the overall installation schedule accounts for overlap in these tasks. These tim elines also indicate that com p letion of som e of the activities is contingent upon com p letion of som e othe r activities. In general, the FGD im plem entation schedule appears to be driven prim arily by th e pre-hookup construction activities. Multiple absorber installations will ty pically add a few m onths to th e im plem entation schedule, particularly to connect additional absorbers during scheduled outages. Prefab rication of absorber m odules can reduce the overall

construction schedule. The m a jor phases of th e im plem entation schedule are discussed below.



### båÖáåÉÉêáåÖ=oÉîáÉï
As shown in Exhibits A-1 and A-2 in Appendix A, in the first phase of technology im plem entation, an engineering review and assessm ent of the com busti on unit is conducted to determ ine the preferred

com p liance alternative. During this phase, the specifications of the control technology are determ ined, and bids are requested from the vendors. After negotiating the bids, a contract for im plem enting the SO 2 control technology is awarded. The tim e necessary to com p lete this phase is approxim a tely four m onths.



### `çåëíêìÅíáçå=mÉêãáí

Before the actual construction to install the tec hnology can com m e nce, the facility m u st receive a construction perm it from the applicable State or lo cal regulatory authority

. The construction perm it process requires that the facility prepare and subm it the perm it application to the applicable State or local regulatory agency

. The State or local regulatory agen cy then reviews the application and issues a draft approval. This review and approval process is es tim ated to take about six m onths. The draft construction perm it is then m a de available for pub lic com m e nt. After any necessary revisions, a final construction perm it is issued. The estim ated tim e to obtain the construction perm it is approxim a tely

**=** nine

m onths 10 but can vary with State and local perm itting procedures as well as other interests in the project.

8

### `çåíêçä=qÉÅÜåçäçÖó=fåëí~ää~íáçå
In the second phase, the control technology is installed. This installation includes designing, fabricating, and installing the control technology

. In addition, com p liance testing of the control technology is

com p leted in this phase. Since FGD technology is not invasive to the boiler, m o st of the construction activities, such as earthwork, foundations, process elect rical, and control tie-ins to existing item s , can occur while the boiler is in operation. The tim e n eeded to com p lete this phase of an im plem entation project is about 23 m onths.

An im portant elem ent of the overall control technology im plem entation is the tim e needed to connect, or hook up, the control technology equipm ent, particularly in relationship to the planned outage tim e for the

unit. On average, it takes about f our to seven weeks to connect FGD. 1, 3 For exam ple, the Hom e r City and Centralia facility FGD retrofit connections were perform ed during the scheduled outages in approxim a tely five weeks. Based on experience in Germ any in response to a com p liance directive, a significant quantity of SO 2 and NO X control installations were perform ed within outage periods consisting of less than four weeks. 11 Electricity generating facilities often plan the connection to occur during planned outages to avoid additional downtim e. Additional downtim e leading to loss of a unit’s availability to supply electricity is aty p ical for FGD technology installations. 3, 12 Because peak electricity

dem a nd generally occurs during the sum m e r m onths (May through Septem ber), ty pically control connections occur during m onths of ot her seasons, notably the spring or fall. 10 For exam ple, FGD

connections to the two Centralia units were perform ed outside of the peak electricity dem a nd period. Sources located where peak dem a nd does not occu r during the sum m e r m onths m a y be less tim econstrained to connect the FGD controls. Howeve r, FGD connections for single and m u ltiple sy stem s can ty pically be perform ed during planned outage tim es. Multiple sy stem s norm a lly are installed in sequence and overlapping to m a intain a high level of ac tivity at the site. Installation of the control device hookup on a sequential basis usually involves an overlap of com p liance testing of FGD sy stem on one unit with hookup of an FGD sy stem with the next un it. The total im plem entation tim e for sequential hookup for m u ltiple sy stem s is estim ated at between 32 m onths for two absorber m odules and 36 m onths

for three absorber m odules. Although not as com m on, m u ltiple sy stem s installed at a single facility can be perform ed sim u ltaneously

. Generally , scheduled outages will govern which m e thod can be used for

m

u ltiple FGD sy stem installations.



### léÉê~íáåÖ=mÉêãáí

Facilities will also need to m odify their Title V ope rating perm it to incorporate the added control devices

and the associated reduced em ission lim its. In som e States, an interim air-operating perm it m a y need to be obtained until the Title V perm it is m odified. The operating perm it m odification process consists of preparation and subm ission of the application to the applicable State or local regulatory agency

. This process can occur sim u ltaneously with the pro cessing of the construction perm it application. 10 The process of transitioning from the construction perm it to the operating perm it varies am ong States, but the application review process is estim ated to take between 9 – 11 m onths. The Title V operating perm it

m

u st also be m a de available for public com m e nt. The Title V operating perm it is then not m a de final

until com p liance testing on the control device is com p leted. Therefore, the total estim ated tim e to

m odify the Title V operating perm it is about 17 m onths , plus the additional tim e to com p lete com p liance testing.

Based on the estim ated tim e periods needed to com p lete each of the four phases described above, the

estim ated tim e period to com p lete the im plem entation of a single FGD installation is conservatively 27

m onths. For the Clear Skies Act, EPA’s projections reflect that the m a jority of FGD installations will involve a single absorber unit installation per plant; however, the m a xim u m projected num ber of scrubbers retrofitted at any facility is three absorb er m odules serving six boilers with a m a xim u m of 2400

9MW

e of boiler capacity

. Changes in FGD technology and reliability have resulted in planning for sm aller and fewer absorbers per retrofit installation. For exam ple, the Zim m e r and Gavin station FGD retrofits perform ed in the early 1990’ s both involve three absorbers on each 1300 MW

e unit. If these retrofits were being planned today

, these stations’ two 1300 MW

e units would likely require only two absorbers per unit rather than three. 6

Average FGD installation tim es have com m only been within 24-27 m onths. For exam ple, recent FGD retrofit sy stem s installed at Hom e r City (Septem b er 2001) and Centralia (July 2001) were both com p leted within approxim a tely 24 m onths. 13 Although these FGD sy stem installations are considered ty pical, the

Hom e r City FGD retrofit installation was perform ed during the sam e tim e fram e as the installation of

three SCR units. Both of these units provide m o re r ecent insight into the ability and scheduling to install FGD sy stem s during a period of high dem a nd for SCR installations.

One factor that can increase the tim e to install a scrubber is com p etition for resources with other

em ission control projects. During the first tim e period analy zed (through the end of 2005), EPA projects that a large num ber of SCR’s will be installed to m eet the requirem e nts of the NO X SIP Call. However, SCR installations designed to com p ly with the NO X SIP Call are generally already into the installation
process or, at a m i nim u m , into the engineering phase of the project. 13 Furtherm ore, construction has already begun or been com p leted for 4 GW

e of the scrubbers that EPA projects will be built by 2005 under current regulatory requirem e nts. Ty pically the overall engineering, fabrication, and construction

resources would rem a in the sam e as the scenario anal y zed above, with the exception that these resources

are reallocated over an extended schedule. One es tim ate is that, as dem a nd for installation resources increase for FGD and other air pollution control insta llations, planned FGD retrof it installations could be

between 30 and 42 m onths 1 while another source estim ates FGD installations at 36 m onths. 14 It should be noted, however, that som e recent contracts have been signed to install scrubbers between now and

2005 that would be installed in less than 36 m onths. For instance, a contract to install a scrubber on a

500 MW

e unit at the Colem a n Station in Kentucky is scheduled to be com p leted in early 2004 (approxim a tely 24 m onths after the contract was a nnounced, which is several m onths shorter than the installation schedule set forth in Exhibit A-1). This suggests that labor dem a nds to install SCR’ s for the

NO X SIP Call m a y not lead to increased installation tim e for scrubbers.

Single-unit FGD installations have occurred in as little as 20-21 m onths 9 , and m u ltiple FGD sy stem s have

been installed within 36 m onths. In addition, owners of new, or “greenfield,” power generation facilities often request 24 m onths for com p letion of these pr ojects, including installation of the boiler, FGD

sy stem , and SCR. Prim arily as a cost cutting option, m o re relaxed installation schedules of up to 36

m onths for a single FGD retrofit installation m a y be planned, but are not com m on. Despite changes in overall installation schedules, efficient utilization of labor and sequencing the in stallation during planned outages will continue to be planning issues. In sum m a ry , the total tim e needed to com p lete the design, installation, and testing at a ty pical 500 MW

e facility with one FGD unit is 27 m onths, 32 m onths at a facility with two boilers being served by a single ab sorber m odule, and approxim a tely 36 m onths at a facility with three absorber m odules (six boiler units ). For the m u ltiple installation of three absorber

m odules at one plant (six boiler units), an additional four m onths m a y be needed to schedule the outage for the FGD hookup outside of the high electricity dem a nd m onths. Ty pically , m u ltiple absorbers will be installed sequentially with som e overlap to con serve and schedule continuous use of labor, as well as keep associated installation costs down.

10

### OKR **i ~Äçê** 

The installation of an FGD sy stem requires a significant am ount of labor. Approxim a tely 80 percent of the labor is for construction of the sy stem , and 20 - 25 percent of the labor is for engineering and project

m a nagem e nt. The installation of the FGD control technologies m a y require the following ty pes of labor:

■ general construction workers for site prep aration and storage facility installation;

■ skilled m e tal workers for specialized hardware and/or other m a terial assem bly and construction;

■ other skilled workers such as electricians, pipe fitte rs, m illwrights, painters, and truck drivers; and

■ unskilled labor to assist with hauling of m a terials and cleanup.

A ty pical turnkey 500 MW

e unit FGD sy stem retrofit requires 380,000

**=** m a n-hours, or approxim a tely 200

person-y ears, of which 20 percent, or 72,000 m a n- hours, are dedicated to engineering and project

m a nagem e nt, 3 and roughly 40 percent of m a n-hours are for boilerm akers. 14 The labor required to install

an absorber vessel and ductwork is a m a jor portion of the sy stem installation m a n-hours. Generally

, construction labor is proportional to the am ount of steel used in the sy stem

. The greatest labor requirem e nt occurs for FGD on a single unit (i.e., 500 MW

e ), and additional efficiencies in increm ental labor occur when scheduling m u ltiple units at one f acility , particularly when com b ining m u ltiple boilers into a single absorber. In general, large num bers of boilerm akers have been used in this industry ; however, it is not expected that this dem a nd will im pact other industries. A m o re thorough discussion of

boilerm aker labor dem a nd is given in Chapter 6.

There are som e efficiencies that r esult when m u ltiple sy stem s are installed at one site. In engineering alone, there is a 10-15 percent savings in engineer ing and project m a nagem e nt labor com m only realized when installing m u ltiple units of sim ilar design. In addition, other increases in project m a nagem e nt and labor productivity and efficiencies in using resour ces and equipm ent can occur with m u ltiple sy stem
installations on one site. While m u ltiple sy stem s on one site are com m on, the num ber of required sy stem s to serve large MW

e of capacity has been decreasing. For ex am ple, in the past FGD sy stem s for 2,600

MW

e stations included six absorbers; however, today these sy stem s would likely be designed for four absorber sy stem s, or approxim a tely 650 MW

e of boiler capacity per absorber. 6 Using the m e thodology

described for 900 MW

e of capacity , today a six-absorber sy stem could serve as m u ch as 5,400 MW

e of capacity , or m o re than double the capacity ser ved in installations in the early 1990’s.

A reasonable estim ate of m u ltiple FGD installations at one site includes 380,000 m a n-hours for the initial

500 MW

e of capacity (or 760 m a n-hours/MW

e ) and an additional 500 m a n-hours per MW

e , up to a total

of 900 MW

e , for any com b ination into a single com m on absorber. Therefore, a 900 MW

e sy stem requires the initial 500 MW

e at 380,000 m a n-hours, and the second 400 MW

e at about 273,200, for a

com b ined labor requirem e nt of 653,200 m a n-hours, or approxim a tely 300 person-y ears, or the equivalent

of about 725 m a n-hours per MW

e . As another exam ple, a 1400 MW

e sy stem retrofit using 2 (700 MW

e ) turnkey sy stem s requires 700,000 m a n-hours, or only 500 m a n-hours per MW

e . 6 Generally , extending

FGD installation schedules m a y reduce the num ber of pe rsons on a job at one tim e but will not reduce the overall labor requirem e nt.

While, it is likely that installation of m u ltiple sy stem s will benefit from econom ies of scale to reduce labor requirem e nts, the range for m a n-hours per MW

e for m u ltiple sy stem s is bounded by 500 and 725

m a n-hours per MW

e . It is also clear that boiler capacities of at least 900 MW

e can be served by a

com m on absorber, and a m i nim u m 10 percent reducti on in engineering and project m a nagem e nt labor

will result from m u ltiple absorbers being installed at a single site. For exam ple, procurem ent contracts only need to be negotiated once, and com m on site issues need only be addressed once. Therefore,

11653,200 m a n-hours is a conservative estim ate of labor required to install FGD at a 900 MW

e facility

. Because no additional efficiencies in engineering and project m a nagem e nt are assum e d for larger installations, m u ltiple 900 MW

e absorber sy stem s each add another 653,200 m a n-hours. A 2,700 MW

e facility requires approxim a tely 1,960,000 m a n-hours fo r the retrofit installation. This produces a conservatively high estim ate bounding the uncertainties of labor and how m a ny boilers or units will be

com b ined into a single absorber.

The above estim ates of labor are conservative particul arly given efficiencies realized in recent retrofit

installations. In m a ny cases, portions of retrofit cons truction can be perform ed off-site, particularly with

m odular designs. For exam ple, at the Gavin scr ubber retrofit installation the absorber m odules were fabricated at the vendor’s shop and then shipped by barge to the site for hookup. To take advantage of off-site fabrication requires that a shop and facility are available and collocated with an adequate shipping and transport facilities (i.e. water accessible f acility and a barge). When the requirem e nts are

m e t the fabrication has the potential to em ploy a nd retain a skilled work force as well as opportunity to
save tim e and reduce field labor requirem e nts.

Based upon the discussion from sections 2.1 through 2. 5, the total resources needed for a single 500

MW

e FGD retrofit and m u ltiple FGD retrofits are shown in Table 2-1.



### OKS **p é~ÅÉ=oÉèìáêÉãÉåíë** 

Generally 1-acre on-site will allow the installation of an FGD retrofit. 1 The need for additional space for
support sy stem s ranges from no additional space need ed to 2.5 acres ty pical for up-front reagent processing and 1 acre for dewatering when reagent processing and dewatering operations are selected as part of the FGD sy stem design. Space issues also in clude the positioning of the FGD after the particulate

control device and before the stack. This area of th e power unit is generally referred to as the “back end” – an area where there is ty pically am ple space for retrofit installations.

The FGD retrofit on the Cinergy ’ s Gibson Unit 4 is an exam ple of an extrem ely space lim ited retrofit. 1

Gibson Unit 4 is a 668 MW

e inhibited oxidation lim estone FGD retrofit designed for 92 percent SO 2

rem oval and com p leted in late 1994. In the case of th is scrubber retrofit, the congestion at the site did not allow for a clean pick by a standard sized crane. With up-front planning, one m odule was raised by

less conventional m eans (jacking construction), allo wing for the second m odule to be constructed using

m o re conventional m e thods. Because of the difficulty due to congestion of the site, this retrofit required

additional tim e and labor, but worked within space cons traints. This m e thod of jacking construction has

been used in other retrofits. The wet FGD retrofit at the Bailly Generating Station, Units 7 & 8, is an

exam ple where a full service sy stem (singl e lim estone absorber for com b ined 528 MW

e capacity , 2-4.5 percent sulfur coal, >95 percent SO 2 rem oval) was able to significantly reduce space requirem e nts while also decreasing cost by about one-half and creating no new waste stream s. Much of the success of this public/private project (DOE/operator and vendors) w as due to a m o re com p act and m u lti-functional (prequenching, absorption, and oxidation) absorber vessel that used a co-current flow design. As a result, the FGD sy stem required only m odest space requirem e nts. 15 In m o st locations connection space is not a problem since there is usually adequate space behind th e flue gas stack to perform the scrubber retrofit. If connection space is lim ited, additional ductwork m a y be necessary

.

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Often absorbers can be designed to accom m odate site-s pecific requirem e nts. Sm aller absorbers, use of

com m on absorbers for m u ltiple boilers, and technol ogy advances that supplant the need for redundant absorbers, have decreased the footpr int needed for a m odern FGD retr ofit installation. Where space for the FGD installation is an issue, reducing the overall absorber size can be accom p lished by using

m

u ltiple absorber tray s (within one absorber) a nd im proving m ass transfer with the use of a fan. 16

Im proved absorption at higher velocities has contribut ed to sm aller, m o re com p act absorbers. For

exam ple, designers are continually im proving absorber efficiencies by increasing absorber gas velocities in the range of 5 m / s (15 feet/s) and greater. Veloc ities of 6.1 m / s (20 feet/s) have been dem onstrated. 8
By contrast, earlier sy stem s’ design capacities were b ased on absorber flue gas velocities of 3 m / s (10

13feet/s). In addition to sm aller absorbers, single absorbers com m only serve m u ltiple boilers, reducing the overall footprint of the FGD retrofit. To date, a si ngle absorber has been su ccessfully installed to serve up to 900 MW

e of capacity in the U.S. while even larger absorber m odules (i.e. 1000 MW

e and greater) are now being offered for purchase overseas.

Space for an FGD installation m a y also include areas for reagent processing and treatm e nt of the waste or by product. Com p lete lim estone processing (delivery

, crushing, slurry preparation, reagent feed equipm ent, etc.) requires as m u ch as 2 to 3 acres; however, this space is a one-tim e requirem e nt and does not increase with increasing FGD capacity being serve d. Conservatively

, when on-site reagent processing is selected, an additional 2.5 acres for an entire facility will be sufficient. While lim estone processing can be perform ed at the facility , purchased powdered lim estone is an option that also reduces

or elim inates the requirem e nt for on-site reagent preparation and other equipm ent, as well as the space these processes would occupy

. Ultra-fine lim estone h as been dem onstrated as an optional enhancem ent
over ty pical lim estone reagent feed. 17 In areas where the ability to deliver lim estone on a continuous basis during winter m onths m a y be lim ited, storage of lim estone m a y be needed. For exam ple, a 30-day supply of lim estone to feed a 500 MW

e FGD sy stem (95 percent control efficiency , 85 percent capacity

, 4 percent sulfur coal) will require approxim a tely 40 by 40 m (120 by 120 foot) storage area to handle approxim a tely 23,000 tons of lim estone.

Traditionally , FGD sy stem s have produced a solid w aste product that can be sent to a landfill, or an increasingly attractive alternative is to treat the by product for the m a nufacture and sale of gy psum

. If dewatering is required, ty pically 1-acre will be need ed for an entire facility regardless of the am ount of FGD capacity being served. One approach to im provi ng sorbent utilization is recy cling the spent sorbent

for m u ltiple exposure to the SO 2 in the flue gas. The result is less unreacted sorbent and sm aller quantities of end product. 18 Im proved perform ance and alternative reagents are becom i ng com m on. By

the m i d-1990’ s, at least one FGD vendor was supply i ng a sy stem that took advantage of a water

treatm e nt sy stem ’s precipitated calcium and m a gnesium carbonates that produced a high quality , fine

calcium and m a gnesium carbonate FGD reagent. In addition to reducing the facility ’s dependence on

lim estone, this process also reduced equipm en t required for lim estone handling and m illing. 4

More efficient use of water in m odern sy stem s has alm o st com p letely rem oved the need for dewatering

and containm ent ponds. Ty pically , purge stream s are used if the wastewater contains high levels of

chlorides. However, usually water is either evapor ated from the sy stem or rem a ins in the by -product or

waste. Techniques for wastewater m i nim i zation or elim ination are com m only available. For exam ple,

m a ny FGD sy stem s repeatedly cy cle the cooling towe r blow-down before being treated in the wastewater

sy stem

. As a result, the wastewater has a high solids content as well as high alkalinity for im proved perform ance. Since large am ounts of water are evaporat ed during this cy cling, this m e thod also benefits

from reduced effluent that requires treatm e nt by a wastewater sy stem

. 16

While water treatm e nt of FGD effluent was once a concern, contem porary FGD sy stem s are m u ch m o re effective in lim iting production of waste water and can achieve zero, or near-zero, wastewater discharge. 9
Many of the wastewater advances being used outside of the U.S., including conserving blowdown in the absorber vessel prim arily for chloride control, are now being used or considered in the U.S. For

exam ple, the 446 MW

e Hunter Unit 3 (operated by PacifiCorp) installed a wet FGD lim estone reagent

sy stem in 1983; and, by use of m echanical draft c ooling towers, the plant is zero-discharge for waste

water. The FGD sy stem operates at 0.12 lb SO 2 /MMBtu and is designed for 90 percent SO 2 rem oval. An

additional exam ple of zero wastewater discharge is the 446 MW

e Craig Units 1 & 2 (installed 1980) that are designed for 85 percent SO 2 rem oval and also em ploy lim estone reagent and m echanical draft cooling

towers.

14

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## =`çåíêçä=qÉÅÜåçäçÖó=oÉíêçÑáíë

In this chapter, retrofit of SCR will be assessed fo r coal-fired electric utility boilers that would be affected by a m u ltipollutant regulation. SCR is the NO X control technology that is expected to have the greatest im pact on future utility boiler NO X em issions and is the m o st difficult NO X control technology to
install. It is, therefore, the m o st im portant NO X control technology to understand from both a NO X reduction and resource requirem e nt perspective.



### PKN **póëíÉã=e~êÇï~êÉ**

The SCR process operates by reacting am m onia with NO X in the exhaust gas in the presence of a cataly s t

at tem p eratures of around 315 to 370 oC. For m o st applications, this tem p erature range m a kes it

necessary to locate the SCR reactor ad jacent to the boiler – im m e diately after the boiler and before the air preheater as shown in Figure 3-1. An infrequen tly used alternative approach is to locate the SCR

after the FGD. This approach, however, increases opera ting costs, as it requires additional heating of the

gas. By locating the SCR reactor as in Figure 3-1, it is often necessary to install the cataly s t reactor in an elevated location, which m a y result in a structure hundreds of feet tall. Figure 3-2 shows the configuration of the SCR that was retrofit onto AES Som e rset Station, a 675 MW

e boiler already equipped with an electrostatic precipitator (ESP) and wet FGD sy stem

. In this com m on installation, the SCR reactor is installed on structural steel that elevates it above existing ductwork and the ESP (designated “precipitator” in the Figure 3-2). In the lo wer right corner of Figure 3-2, an im age of a person provides a perspective of the size of the SCR installation.

B o ile r 

### SCR A i r P r e h eater

ES P FG D

S t ack exhaust

Combustion Air Coa l

Figure 3-1. Gas path for coal-fired boiler with SCR, ESP, and FGD.

15Figure 3-2. SCR installation at 675 MW

e AES Som e rset Station. 19

The SCR sy stem reduces NO X through a reaction of am m onia and NO X in the presence of oxy gen and a cataly s t at tem p eratures around 315 to 370 °C (600 to 700 o F ). The products of this reaction are water vapor and nitrogen. The cataly s t is m ounted inside an expanded section of duc twork and is configured for the gas to pass through it as in Figure 3-2.

The m a jor com ponents of an SCR sy stem include:

■ Am m onia or urea storage

■ Am m onia vaporization sy stem (if aqueous am m onia is used)

■ Urea to am m onia converter (if urea is used)

■ Am m onia or urea m e tering and controls

■ Dilution air blowers

■ Am m onia injection grid

■ Cataly st

■ Cataly st reactor, ductwork and support steel

■ Cataly st cleaning devices (soot blowers, sonic horns, etc)

■ Instrum e ntation

16Except for the cataly s t, m o st of the m a terial/equi pm ent used to assem ble an SCR sy stem is either

standard m echanical and electrical com ponents (pum ps, blowers, valves, piping, heaters, pressure vessels, tem p erature and pressure sensors, etc.) or is largely m a nufactured for other power plant applications and has been adopted for use in S CR sy stem s (cleaning devices such as soot blowers or sonic horns, gas analy zers, etc.). The cataly s t, how ever, is a specialized product designed specifically for this purpose.

The cataly s t is ty pically a ceram ic m a terial that , in m o st cases, is either extruded into a ceram ic honey c om b structure or is coated onto plates, as shown in Figure 3-3. The cataly s t is assem bled into

m odules at the factory

. The m odules are shipped to the site and installed into the SCR reactor in lay e rs. Each lay e r of cataly s t is com p rised of several individual m odules that are installed side-by

- side.

Figure 3-3. Plate and honey c om b cataly s t. 20

The m a terial used in the largest quantity , aside from a cataly s t or reagent, is steel. The am ount of steel required for an SCR in the range of 300-500 MW

e is about 800 to 1200 tons, 20 or about 2.4 to 2.6 tons per

MW

e . About 4,000 tons of steel is necessary for retrofit of two 900 MW

e units (1,800 MW

e total), 20 or about 2.2 tons per MW

e . The steel used for an SCR includes larg e structural m e m b ers, plates, and sheets. These steel pieces are used to fabricate the cataly s t r eactor, the ductwork, and the support steel. There is
ty pically less of a requirem e nt for corrosive resistant alloy s for an SCR installation when com p ared to a

scrubber installation. Steel is also needed for bo iler m odifications. In this case, large pieces of steam piping or other large steel boiler com ponents m a y need to be replaced. The cataly s t reactor is often

fabricated on-site. Sections of the cataly s t reactor and ductwork m a y be fabri cated off-site and shipped in pieces to the site for final assem bly

, or they m a y be fabricated on-site into subassem blies and lifted into place during erection.

If m o re than one boiler at a facility is to be retrof it with SCR, then som e , but not all, equipm ent can be

m a de com m on. For exam ple, it m a y be possible, a nd is probably preferable, to have a com m on am m onia

17or urea storage facility

. Reagent storage is probably the only m a jor equipm ent item that lends itself to sharing between adjacent boilers. Therefore, there is so m e gained efficiency in the use of equipm ent at a
site with m u ltiple units. However, this gain in effici ency is generally sm all com p ared to the total project.

The m a jor sy nergy will be in construction equipm ent and in labor, as will be discussed in Sections 3.3 and 3.5, respectively

.



### PKO **` ~í~äóëí=~åÇ=oÉ~ÖÉåíë** 

An SCR sy stem requires an initial and ongoing supply of cat aly s t. It also requires reagent. The reagent

can be am m onia or urea. Most facilities to date have used am m onia; however, urea is becom i ng an increasingly popular reagent due to its inherent safety and the recent availability of sy stem s to convert

urea to am m onia on-site.



### `~í~äóëí

The am ount of cataly s t required for an SCR sy stem is directly proportional to the capacity (or gas flowrate) of the facility , if all other variables are equal. The actual am ount of cataly s t for any specific plant depends upon several param e ters ; in particular, the am ount per MW

e (m easured in m 3 per MW

e ) for a given level of reduction and lifetim e will fall within a general range. Therefore, it is possible to m a ke

an estim ate of how m u ch cataly s t would be necessary to retrofit a particular facility or a large num ber of facilities if the total capacity is known. It is assum e d that m o st SCR sy stem s to be retrofit onto electric utility boilers will be designed for about 90 percent re duction. For m o st boilers, this level of reduction

m a y initially require about 0.90 to 1.3 m 3 of cataly s t for each MW

e of coal-fired boiler capacity

. 18, 21, 22

For exam ple, a 500 MW

e plant would be expected to have about 450 to 650 m 3 of cataly s t. The am ount of cataly s t for a particular situation will vary som e what depending on the cataly s t supplier and the difficulty of the application. At the 675 MW

e AES Som e rset Boiler, 90 percent NO X reduction was achieved with SCR using 897 m 3 of plate cataly s t, 19 or about 1.33 m 3 per MW

e . This unit fires 2.5 percent sulfur coal. At each of the 745 and 755 MW

e Montour Units 1&2, 671 m 3 of ceram ic cataly s t were used, 22 or about 0.89 m 3 per MW

e . This unit fires 1.5 percent sulfur coal that can have arsenic levels as high as 100 ppm (lim estone injection is used to reduce gaseous arsenic concentration in the furnace). The am ount of cataly s t will tend to be lower in situations that are less challenging, such as with lower sulfur coals or situations expected to have lo wer gaseous arsenic concentration (gaseous arsenic is a cataly s t poison that originates in the coal; it will re duce the lifetim e of the SCR cataly s t). Hence, less

than 0.90 m 3 per MW

e m a y be sufficient in som e cases.

The cataly s t is ty pically loaded in three or m o re lay e rs. This perm its replacem ent of sections of the cataly s t as activity is reduced. The advantage of this approach is that it perm its lower overall cataly s t usage over the econom ic lifetim e of the plant. Norm ally , room for an extra lay e r is provided, so a fourth lay e r can be added, if necessary

. At the first cat aly s t addition (ty p ically , after about 24,000 operating hours), the fourth lay e r will be filled or half filled. Once the SCR reactor is full, lay e rs of cataly s t are replaced after cataly s t activity drops to a m i nim u m level. At the first cataly s t replacem ent, new cataly s t will replace the original first lay e r; at the next cat aly s t replacem ent, new cataly s t will replace the original second lay e r, and so on. EPA m odeling projections conservatively assum e d that one lay e r of cataly s t is replaced for every 15,000 – 20,000 hours of operation for coal-fired units. Therefore, after the initial installation, there is a need to replace roughly one fourth of the total cataly s t reactor volum e every 24- 32

m onths or so – or conservatively about 1 / 8 of the installed volum e should be replaced each y ear for the

coal-fired installations.

18The cataly s t m a y also be regenerated rather than replaced. 23 This will reduce the am ount of new cataly s t
that m u st be purchased. However, due to the lim ite d experience with this m e thod, it will be assum e d that the cataly s t is replaced according to the cataly s t m a nagem e nt plan.



### oÉ~ÖÉåíë

The am ount of reagent consum ed in the SCR process is directly proportional to the am ount of NO X reduced. Although am m onia is the chem ical that act ually participates in the chem ical reaction, som e suppliers have developed equipm en t to convert urea to am m onia on-s ite. According to one supplier of

urea-to-am m onia converters, each m o le of urea within the conversion sy stem is converted to two m o les

of am m onia. 24 For exam ple, reducing one pound of NO X will require roughly 0.176 kg of am m onia or about 0.312 kg of urea. This includes a 1⁄2 percent increase in reagent dem a nd due to am m onia slip and a five percent increase to account for a sm all am ount of nitrogen dioxide (NO 2 ) in the flue gas.

Therefore, for any given plant size, the am ount of cataly s t and reagent consum ption can be estim ated.

For a 500 MW

e plant reducing NO X from 0.50 lb/MMBtu to 0.05 lb/MMBtu and 85 percent capacity factor (this is conservatively high for m o st coal boilers), approxim a tely 3,400 tons/y r of am m onia (anhy drous equivalent) or about 6, 100 tons/y r of urea (as 100 percent urea) would be needed. The sam e 500 MW

e plant would have around 450-650 m 3 of cataly s t with roughly 120-160 m 3 replaced about every three y ears. This is, if a third of the initial catal y s t loading m u st be replaced, on average, every 15,000 to 20,000 operating hours, then 0.015 to 0.0289 cubic m e ters per MW

e per 1000 hours m u st be replaced.



### PKP **`çåëíêìÅíáçå=bèìáéãÉåí**

Construction equipm ent needed for installation of an SCR includes standard construction equipm ent – welders, excavation equipm ent, conc rete pouring equipm ent, cranes, etc. In som e cases, installers m a y use tall-span heavy

- lift cranes. These cranes are capable of lifting h eavy loads, as m u ch as 100 tons or

m o re, several hundred feet. The advantage of this crane ty pe is realized when lifting assem bled sections of cataly s t reactor or other large pieces high off th e ground. If lower capacity cranes are used, sm aller pieces m u st be lifted, which m eans that less pre-fabrication is possible and m o re assem bly m u st be done in place. Less pre-fabrication could lengthen the necessary boiler outage som e what. Although the availability of the largest cranes is reported to a bout 60 or m o re, about 12 new cranes can be supplied

every six m onths. 25 It has been reported that, in som e cases, it has been necessary to go further away

from the plant to source cranes with adequate lift a nd reach capacity

. In other cases, engineers found that by changing the design/fabrication m e thod to m eet th e available crane, the project could be m a naged with lower capacity cranes (lifting sm aller pieces). 26, 27 If m o re than one boiler is retrofit at one facility

, then the crane can be used for both boilers, saving cost and tim e when com p ared to boilers retrofit separately

. It is im portant to note that in m a ny cases the erection m e thod is not lim ited by the available crane, but is lim ited by the access to the plant (For exam ple, can large sections be delivered by barge, rail, or roadway ? ) and by the available lay

- down area for m a terial and construction equipm ent on site. At

m a ny facilities, there is inadequate area to prefabri cate large sections. In som e instances, transportation routes to the facility do not perm it transporting large, pre-assem bled equipm ent to the site. In such cases, it will not be possible to do m u ch pre-assem bly

, and a sm aller, less expensive crane m a y be adequate. As a result, the ty pe of crane that is best for a particular SCR installation frequently is not the largest

crane available. The crane selected for a project w ill be determ ined as part of an overall construction plan developed to optim ize all of the available resources – labor, m a terial, and equipm ent - for a particular project.

19The need to lift m a terial to high elevations is a r esult of the location of the SCR – often above existing ductwork and adjacent to existing equipm ent. Figur e 3-2 provided one good exam ple of this. It m a y be

necessary to m ove existing equipm ent, such as the ai r preheater, in order to accom m odate the addition of

the SCR reactor. As a result, every retrofit is a custom fit. However, engineers have been very innovative when installing these sy stem s, even on fac ilities that apparently had little room available for

the SCR. Hence, the phy sical size of the technology has not been lim iting.



### PKQ **f åëí~ää~íáçå=qáãÉ** 

Im plem entation of a NO X control technology at a plant involves several activities contingent upon each

other. These activities m a y be grouped under the following phases of an im plem entation project: (1) conducting an engineering review of the facility a nd awarding a procurem ent contract; (2) obtaining a construction perm it; (3) installing the control technology ; and (4) obtaining an operating perm it.

Exhibit A-3 in Appendix A depicts the tim eline expected for com p leting a single unit installation of SCR.

Com p letion of som e of the activities is continge nt upon com p letion of som e other activities. For

exam ple, construction activities cannot com m e nce until a c onstruction perm it is obtained. In general, the

SCR im plem entation tim eline appears to be driven prim arily by the engineering activities (i.e., design, fabrication, and construction).

**båÖáåÉÉêáåÖ=oÉîáÉï** As shown in Exhibit A-3 in Appendix A, an engi neering review and assessm ent of the com bustion unit is conducted in the first phase of technology im plem entation to determ ine the preferred com p liance

alternative. During this phase, the specifications of the control technology are determ ined, and bids are requested from the vendors. After negotiating the bids, a contract for im plem enting the NO X control technology is awarded. The tim e necessary to com p le te this phase is approxim a tely four m onths for

SCR.

**`çåëíêìÅíáçå=mÉêãáí**

Before the actual construction to install the tec hnology can com m e nce, the facility m u st receive a construction perm it from the applicable state or lo cal regulatory authority

. The construction perm it process requires that the facility prepare and subm it the perm it application to the applicable state or local regulatory agency

. The state or local regulatory agen cy then reviews the application and issues a draft approval. This review and approval process is es tim ated to take about six m onths. The draft construction perm it is then m a de available for pub lic com m e nt. After any necessary revisions, a final construction perm it is issued. The actual tim e need ed will depend on the size and com p lexity of the project and the local procedures for issuing a perm it. Exhibit A-3 in Appendix A shows that nine m onths are allowed for the construction perm it. This is exp ected to be am ple tim e. In one case, only about 4-5

m onths were needed for obtaining the construction perm it, 26 and only six m onths were needed to obtain the construction perm it for retrofit of two 900 MW

e boilers in another case. 21 Shorter periods for construction perm it authorization would allow earlie r com m e ncem ent of construction activities and could potentially shorten the overall schedule.

**`çåíêçä=qÉÅÜåçäçÖó=fåëí~ää~íáçå** In the second phase, the control technology is installed. This installation includes designing, fabricating, and installing the control technology

. In addition, com p liance testing of the control technology is also

com p leted in this phase. Most of the construc tion activities, such as earthwork, foundations, process

20electrical and control tie-ins to existing item s , can occur while the boiler is in operation. The tim e needed to com p lete this phase of an im plem entation project is about 17 m onths for SCR.

An im portant elem ent of the overall control technology im plem entation is the tim e needed to connect, or hook up, the control technology equipm ent to the com bustion unit because the boiler ty pically m u st be shut down for this period. SCR connection can occur in a three to five week outage period. 28 In som e cases longer outages are needed. When Babcock & Wilcox retrofitted the 675 MW

e AES Som e rset boiler, the outage began on May 14, and the boiler w as returned to service on June 26 – about a six-week
outage. 19 One m a jor SCR sy stem supplier in the U.S. stat ed that they would want in the range of one to

two m onths of boiler down tim e and have never required m o re than two m onths. 27 Difficulty is increased

as the extent of boiler m odifications necessary to f it the SCR into the facility is increased. A Germ an SCR sy stem supplier installed SCR on a significant portion of the Germ an capacity within outage periods consisting of less than four weeks. 11 Based upon outages in this tim e range for SCR connection, electricity -generating facilities would norm a lly be ab le to plan the SCR connection to occur during planned outages to avoid additional downtim e. Som e facility owners have been innovative in their construction plans to m i nim i ze down tim e. At the Tennessee Valley Authority ’ s (TVA’ s) 700 MW

e Paradise Unit 2, it was necessary to dem o lish the exis ting ESP with the unit on line. TVA installed a construction by pass to send gas from the air preheater outlet directly to the FGD, while the ESP was being dem o lished and the SCR reactor erected in its place. 11 However, in m o re difficult retrofits, down

tim e m i ght be im pacted in a significant way

. In so m e cases it m a y be desirable to plan a brief outage in advance of the hook-up to install structural steel through sleeves placed in existing equipm ent, such as the ESP, or to relocate existing equipm ent that would otherwise interfere with erection of the SCR. This

perm its erection of the cataly s t reactor above existing equipm ent while the unit is on line. 26 However, because an SCR project is expected to extend close to two y ears (see Exhibits A-3 and A-4 in Appendix A), it should be possible to incorporate this work into planned outages, which would have occurred regardless of whether an SCR was to be installed.

**léÉê~íáåÖ=mÉêãáí**

Facilities will also need to m odify their Title V ope rating perm it to incorporate the added control devices

and the associated reduced em ission lim its. In som e states, an interim air-operating perm it m a y need to be obtained until the Title V perm it is m odified. The operating perm it m odification process consists of preparation and subm ission of the application to th e applicable state or local regulatory agency

. As shown in Exhibit A-3 in Appendix A, this process can occur sim u ltaneously with the processing of the construction perm it application. The process of transitioning from the construction perm it to the operating perm it varies am ong states and appears to be som e what unclear due to the infancy of the Title V operating perm it process. Nonetheless, based on di scussions with several states, the application review process is estim ated to take approxim a tely 9-11 m onths. The Title V operating perm it m u st also

be m a de available for public com m e nt. Following public com m e nt, the Title V operating perm it is not

m a de final until com p liance testing on the control devi ce is com p leted. Therefore, the total estim ated

tim e to m odify the Title V operating perm it is about 17 m onths, plus the additional tim e to com p lete

com p liance testing. 10

Based on the estim ated tim e periods needed to com p lete each of the four phases described above, the

estim ated tim e period to com p lete the im plem en tation of SCR on one com bustion unit is about 21

m onths. This tim e period is shown in Exhibit A-3 in Appendix A. However, depending upon the specifics of the project, the tim e needed could vary by a couple of m onths. For exam ple, at AES

Som e rset station, the tim e to com p lete the retrofit from the point of contract award was nine m onths. 19

Assum i ng four m onths of work prior to contract award, a total elapsed tim e of 13 m onths would have been necessary to retrofit this 675 MW

e boiler. Another facility , Reliant Energy ’s Key s tone plant, has

21two 900 MW

e , 8-corner, T-fired com bustion engineering units that burn approx 1.5 percent sulfur

bitum i nous coal. Reliant intends to reduce the NO X from a baseline of 0.40 lb/MMBtu to 0.04

lb/MMBtu. The perm it to construct was received in approxim a tely six m onths. The tim e from placing

the order to com p letion of com m i ssioning activities is 46 weeks for both units. However, prelim inary engineering was accom p lished earlier. Even if pre lim inary engineering and contract negotiation took as long as six to eight m onths, the total tim e for com p leting two 900 MW

e units would be about 17 to 19

m onths. 21 For the New Madrid plant, units 1 & 2 (600 MW

e each), the specifications were released to turnkey contractors in February 1998, the project specification was released in March 1998, the contract was awarded on June 26, 1998, and the first unit was in operation by February 2000. In this project, an option for a second unit was available (and was ex ercised), and air preheaters were replaced. 29
Therefore, 21 m onths should be a reasonable, and in som e cases a conservative estim ate of the total tim e

necessary to retrofit a single utility boiler.

Under the Clear Skies Act, EPA does not expect that SCR will be im plem ented at every facility

. For those plants where EPA projects SCR retrofits will o ccur, EPA’ s projections reflect that these facilities will ty pically have 1 to 4 boilers retrofit per site. However, for one facility , seven SCR retrofits are projected to be installed by 2020. Exhibit A-4 in Appendix A exam ines a schedule for retrofitting a facility with m u ltiple (seven) SCR retrofits. This exam ines the installation of the control device hook-up on a sequential basis. Installation is staggered by tw o to three m onths between sequential units to enable

m o re efficient utilization of m a npower and project m a nagem e nt than if m u ltiple units were connected at

one tim e. This approach also assures that at least about 83 percent of the plant capacity is available at

any given tim e (only one boiler is s hut down), and during m o st of the tim e there is no im pact to the plant availability at all. This approach requires a to tal tim e of 35 m onths for seven SCR retrofits. An alternative approach m i ght be to schedule outages to avoid any outage during high electricity dem a nd periods. This m i ght extend the total elapsed tim e by about four m onths. However, because there is a

substantial am ount of work that can be accom p lished with the boiler on line, the additional tim e would be

m

u ch less than the num ber of high electricity dem a nd m onths that are accom m odated by this approach. Another alternative approach woul d involve retrofit of m o re than one unit at a tim e during low-dem a nd periods and avoiding any outage duri ng high dem a nd periods. This alternative could result in a faster project com p letion, but would have less even labor utilization, which is an im portant cost-benefit

tradeoff. 30

In sum m a ry , the total tim e needed to com p lete the d esign, installation, and testing at a facility with one

SCR unit is about 21 m onths; at a facility with m u ltip le SCR (seven) units, total tim e is approxim a tely 35

m onths. Based on these tim elines, it is estim ated, in principal, that the NO X controls needed to com p ly

with a m u ltipollutant strategy can be m e t provided th at: (1) an adequate supply of m a terials and labor is available, and (2) the control technology im plem enta tion process begins at least about 35 m onths prior to

the date controls m u st be in place. However, ideally , longer than 35 m onths would allow for all of the retrofits to occur over a period of several y ears so that facility owners can properly plan outages and suppliers can properly plan for resource availability

.



### PKR **i ~Äçê** 

The installation of an SCR sy stem requires a significant am ount of labor. Most of the labor is necessary for the construction of the facility

. However, engin eering and project m a nagem e nt labor are also needed for the project. The total construction labor for an SCR sy stem of 500 MW

e is in the range of 333,000 to 350,000 m a n-hours. 22, 27 Ty pically , approxim a tely 40-50 percent of the labor is for boilerm akers. 31
However, the percent of labor for boilerm akers will va ry from one project to another, with 40-50 percent

22being an average for several projects. 32 Som e projects require a higher degree of boiler integration and less erected steel and, therefore, have a higher per centage of boilerm aker labor. Other projects require extensive steel erection with less boiler integration and will, therefore, have a lower percentage of

boilerm akers versus other trades. For a 500 MW

e plant, the construction labor would be about 340,000

m a n-hours, of this roughly 136,000-170,000 m a n-hours woul d be boilerm aker activity

. Engineering and project m a nagem e nt are about 5 percent of the total cost, while construction is about 50 percent of the

total cost. 19 If labor rates for engineering and project m a nagem e nt is 50 - 100 percent greater than construction labor, then about 17, 000 to about 28,000 m a n-hours of engi neering and project m a nagem e nt are needed for the project. Total labor m a n-hours of construction and engineer ing labor are then about 365,000 m a n-hours for a single 500 MW

e unit.

Construction m a n-hours are approxim a tely proportional to the tons of steel fabricated. As noted earlier,

the m a terial needed for m u ltiple boiler installati ons is generally not reduced significantly over the projects if they were installed separately

. However, if m o re than one sy stem is installed at a site, som e significant efficiencies result.

When there are m u ltiple units retrofit at one site only

, one m obilization is needed for all of the boilers, only one construction supervis or is required, and equipm ent is m o re efficiently used. As a result, 15-20 percent efficiencies can be realized from these activities and can be planned into the project. 22 Longterm projects, such as retrofits of m o re than one unit at one site, also lend them selves to additional

efficiencies from learning curves. Learning cu rves result from productivity im provem e nts over the duration of the project. Productivity m easures the actual m a n-hours used versus those planned. A productivity value over 100 indicates that fewer m a n-hours are needed to accom p lish the goal than expected. A labor productivity value of 110 m eans th at 10 percent m o re work was accom p lished for the level of labor expended than if a productivity value of 100 was achieved. There are exam ples of productivity im provem e nts of 9 to 19 percent during the project due to additional efficiencies gained

from learning curves. 30 If only 10 percent or less im proved efficiency results from planned reduced labor

and from productivity im provem e nts that occur after th e project com m e nces, the labor for each additional

500 MW

e plant m i ght be reduced from 340,000 m a n- hours to about 310,000 m a n-hours, or about 2,170,000 construction m a n-hours for seven 500 MW

e units at one plant.

For a site with m u ltiple units, the total engineeri ng and project m a nagem e nt m a n-hours are likely to be significantly less than the total if each unit were addr essed separately

. This is because there will be m a ny

com m on site issues that need to be addressed and e ngineered only once. Procurem ent contracts need to be negotiated only once, and only one project m a nagem e nt team is needed over the duration of the

contract. However, it is difficult to say how m u ch engineering will be reduced, because adjacent units

m a y be very sim ilar or very different. One a pproxim a tion is to m a ke total engineering, project

m a nagem e nt, and testing proportional to the project duration. Thus, a seven-unit facility would require about 42,000 m a n-hours of engineer ing and project m a nagem e nt.

Based upon the discussion from sections 3.1 through 3. 5, the total resources needed for a single 500

MW

e plant and a site with seven 500 MW

e plants is shown on Table 3-1.

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### PKS **pé~ÅÉ=oÉèìáêÉãÉåíë**

An SCR sy stem for a coal-fired boiler m a y have a neglig ible im pact on the footprint of the boiler. This is because the SCR is frequently installed in an el evated position near the boiler and well off of the ground. The choice of installing the SCR reactor near the ground level or elevated well above ground level depends upon which conf iguration is viewed as m o st cost effective while considering installation cost and operating cost. Locating the SCR in an el evated location near the boiler econom izer and air preheater is frequently done to m i nim i ze the length of ductwork (with the associated pressure loss) and because no additional real estate is necessary for the S CR reactor. When this ty pe of installation is perform ed, the SCR reactor is installed atop a steel structure that m u st be erected above existing equipm ent, such as the electrostatic precipitator. Th is is an approach that is frequently used because engineers have developed cost effective m e thods to install the SCR reactor while addressing potential

interferences from existing equipm ent. Section 3. 4 of this docum ent discussed how brief outages, in advance of the outage to connect the SCR, were taken to address interferences and perm it SCR reactor

24construction with the unit on line. In som e cases, howev er, the preferred approach has been to locate the SCR reactor on the ground near the boiler and to route the ductwork to and from the SCR reactor. This is the approach that was taken on the retrofit of PSNH Merrim ack Unit 2, the first retrofit of a coal-fired

boiler in the United States. In this case there was a large am ount of space near the boiler to perm it this approach. Regardless of where the SCR reactor is located, ductwork from the econom izer outlet to the SCR reactor and back to the air preheater inlet m u st be accom m odated. In cases where space for this

ductwork was extrem ely lim ited, the air preheater was relocated. However, relocation of the air preheater(s) usually is not necessary

. Only a few in stallations have required the relocation of the air preheater.

The other item that m u st be located is the reagent storage sy stem

. This usually does not take up as m u ch

room as the SCR reactor itself. However, the storage and unloading sy stem m u st be located near rail or truck access to perm it delivery of reagent. In so m e cases, long piping is run from the storage and unloading area to the SCR reactor. In these cases, the pi ping m a y be insulated and heat traced to prevent

condensation of the am m onia vapor.

25

## `Ü~éíÉê=Q **jÉêÅìêó=`çåíêçä=qÉÅÜåçäçÖó=oÉíêçÑáíë**

Under a m u ltipollutant control scenario, m e rcury em issions would be controlled from coal-fired power plants by equipm ent that reduces em issions of othe r pollutants (e.g., scrubbers and SCR) and the use of sorbent injection. Other m e thods are being i nvestigated (such as oxidation and scrubbing technologies), which utilize ozone, barrier discharge, and cataly s t and/or chem ical additives in com b ination with existing technologies. To the extent that other technologies are developed, these would provide m o re options for com p liance, so their introduction w ould serve to reduce issues related to resource requirem e nts of installing controls. Sim ilarly

, with regard to sorbent injection, sorbents other than activated carbon (AC) m a y ultim ately prove to be supe rior for this application in term s of cost or collection efficiency perform ance and m a y reduce the likely dem a nd for ACI from what is projected

here. Nevertheless, all of the sorbent-based appro aches use sim ilar hardware to inject sorbent as ACI. Therefore, the assum p tion of ACI as a control m e thod will provide a fairly representative indication of

the dem a nd for hardware and construc tion resources regardless of which so rbents are used in the m a rket.

The assum p tion of ACI as a m e rcury control m e thod will be m o re conservative with regard to sorbent

consum ption since it will assum e that all of the fac ilities installing sorbent injection for m e rcury control require AC.



### QKN **póëíÉã=e~êÇï~êÉ**

The AC is ty pically injected at the lowest tem p eratur e available that is upstream of a particle-collecting device because experience has found that m e rcury collecti on is m o st efficient at lower tem p eratures. On a boiler equipped with an ESP or a fabric filter (FF) for particle collection, the configuration would look as in Figure 4-1. Collection of m e rcury is som e wh at m o re efficient when a FF is used for particle collection because of the higher gas-sorbent contact in the filter cake. Another approach is to have injection downstream of an ESP, which would collect m o st of the coal fly ash, and upstream of a fabric filter (FF), which would m o stly capture sorbent. This approach is shown in Figure 4-2. The advantages of this approach are that greater m e rcury capture occurs because of the additional m e rcury capture that can occur on the FF filter cake; and, because the ash is largely separated from the sorbent, m o re efficient sorbent utilization is possible through sorbent recy cli ng. This approach could be im plem ented through addition of a Pulse Jet Fabric Filter (PJFF) when ACI is installed.

The ACI Sy stem consists of the following com ponent s, as shown in the sim p lified schem atic of Figure

4-3:

■ A silo for storing the sorbent

■ A m e tering sy stem for m e tering the am ount of sorben t injected into the ductwork – ty pically a rotary

m e tering valve

■ A pneum atic or m echanical convey i ng sy stem fo r m oving the sorbent to the injection location

■ An injection sy stem for dispersing and distributi ng the sorbent in the boiler ductwork. For m a ny facilities, injection of sorbent will occur after the air preheater and upstream of the ESP or FF. This injection sy stem is principally m a de from piping that m a y split off to m a nifolds for injecting in

m

u ltiple locations. Special nozzles or ot her hardware are generally not required.

26■ A blower to provide a carry ing m e dium

■ Associated piping for the blower and the distribution sy stem

■ A hum idification sy stem m a y be used in som e cases to reduce tem p erature and im prove m e rcury capture. The hum idification sy stem will ty pically consist of water spray injectors (possibly air

atom ized) located upstream of the ACI injectors, a grid for the spray injectors, and a water supply

sy stem that will include pum ping and m e tering sy stem s.

■ A control sy stem that m a y utilize a program m a ble logic controller (PLC) or m a y be accom m odated by the plant distributed control sy stem (DCS)



### B o ile r SC R (if installed) 

### Air Pre h ea te r

ESP or
FF



### Combusti on Air Coa l

S o r b en t an d f l y

as h

ar e co l l ect e d h e re Act i v a te d Car bon I n j ect io n e xha us t

Stack

Figure 4-1. Gas path for coal-fired boiler with SCR, ACI, and ESP.



### exhaust

Ai r B o iler SCR (if in stalled ) A i r P r eheate r



### ES P S t ack exhaust

Combu s tion

Ai r Coal Fa b r i c
F i lter

F l y as h is co llected he re S o r b ent is co llected h e re A c t i v at ed Carbon I n j ect i o n

Figure 4-2. Gas path for coal-fired boiler with SCR, ACI, ESP, and FF.

27Activ ated Ca rbon

So rbe n t St or age Si lo

Blow e r Rotar y Me t e r i n g

Va l v e O p tio n a l

wa t e r s p ra y Fr o m a i r

p r eh ea ter

Exha ust

Gas Duct

To ES P

Or FF

Figure 4-3. Sim p lified schem atic of ACI sy stem

.

Regardless of boiler size, an ACI sy stem will require the sam e equipm ent. The principal differences will be the size of the sorbent storage silo, the size of the m e tering and convey i ng sy stem , and the size and

num ber of injectors for the sorbent injection sy stem

.

There are also several other com b inations that m a y be used, including com b inations of ACI with spray dry e r and FF and com b inations of ACI with FGD. 32 The various com b inations will be discussed further

in Section 4.2. In each of these com b inations, th e actual equipm ent associated with the ACI sy stem is

sim ilar. The particular com b ination of equipm ent c hosen for m e rcury reduction at a particular facility is largely determ ined by the existing equipm ent and cond itions at the facility

. However, m o st facilities are currently equipped with ESPs, and som e are equippe d with FFs. Thus, the m o st likely scenario for application of ACI is in a configuration with ESP or FF.

Most existing facilities have ESPs for partic le em ission control and do not have any SO 2 rem oval technology

. Therefore, injection of sorbent, and possibly water for hum idification, will m o st often be perform ed downstream of the air preheater and upstream of the electrostatic precipitator, where the gas

tem p erature is ty pically in the range of 280-300 oF. In this part of the boiler ductwork, there are no water

wall tubes. Therefore, the m echanical interface be tween the ACI sy stem and the boiler is through the duct walls, and high-pressure boiler tubing will not be affected by the retrofit of ACI.

Som e com p anies offer other sorbent-based m e thods for reduction of m e rcury em issions; however, the equipm ent used is very sim ilar in scope to the equipm ent used for ACI. 32

28The m a jority of the equipm ent used for an ACI sy stem is produced from standard m echanical or electrical hardware that is sold for a wide range of purposes. The total am ount of steel is relatively sm all

in com p arison to an SCR or an FGD for a 500 MW

e plant. 27 The estim ated steel requirem e nt for a 500

MW

e ACI sy stem is indicated in Table 4-1. 33 Since the largest item contributing to the steel requirem e nt is the storage silo, it will be assum e d that the total st eel requirem e nt is proportional to the capacity of the unit, as the storage requirem e nt would be proportional to the capacity

. For m u ltiple units at one site, all but the silo would certainly need to be duplicated. It is possible that there m i ght be one large silo serving

several units with m o re than one feed off of it, or, th at individual silos m a y be needed. In any event, the

sy nergies in reducing total steel requirem e nt over what would be needed for individual units is expected

to be sm all.

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### QKO **o É~ÖÉåí** 

AC is assum e d to be the principal reagent used to ab sorb the m e rcury in the exhaust gases. Most of the

inform ation on the AC injection requirem e nts for a coal-fired power plant is from pilot studies and

dem onstrations of ACI technology

. Table 4-2 shows AC injection rates estim ated from the data provided

a com p rehensive assessm ent of ACI under a range of scenarios. 34 For exam ple, to achieve 80 percent

m e rcury reduction from a low sulfur bitum i nous coal using an ACI sy stem with hum idification will require a treatm e nt rate of about 8 lb/m illion acf (MMacf). 34 If a pulsejet FF (PJFF) is used downstream

, the sorbent injection rate can be reduced to about 4. 6 lb/MMacf. If the facility fires high sulfur coal and is equipped with FGD, then the estim ated sorbent ra te is between 6.1 lb/MMacf to 2.0 lb/MMacf, without and with a PJFF, respectively

. For a high sulfur co al application, hum idification would not be perform ed

due to risk of acid condensation. Table 4-2 sum m a rizes estim ated injection rates for a 500 MW

e boiler

under various scenarios. 34 As shown, the injection rates vary substantially based upon the circum stances.

Because com b ination of SCR and FGD are expected to have high m e rcury rem oval due to the SCR and FGD sy stem s, those facilities that are so e quipped are not expected to add ACI sy stem s.

There are really no sy nergies in consum ption if m u ltip le ACI units are installed at one site. Therefore,

the total AC consum ption at a plant will be roughly proportional to the total plant capacity equipped with

ACI.

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### QKP **`çåëíêìÅíáçå=bèìáéãÉåí**

Construction equipm ent needed for installation of an ACI sy stem includes standard construction equipm ent – welders, excavation equipm ent, concrete pouring equipm ent, cranes, etc. Since an ACI

sy stem is m u ch sm aller and uses substantially less steel than an SCR or FGD sy stem , cranes and other lifting equipm ent can be of low to m oderate lifting cap acity

. Blowers, the sorbent storage silo, and other equipm ent will be m ounted on concrete pads or foundations. In m o st cases, the sorbent storage silo will be field erected; however, for som e facilities that requi re less sorbent, a sm aller, prefabricated silo m a y be installed. Steel erection and m i nor excavation a nd concrete work is necessary for an ACI sy stem , and this work should not require any m o re than very com m on construction equipm ent. Piping for sorbent transport will ty pically be welded steel and can be erected in the field in m a ny cases. It should not be

necessary to relocate any existing boiler equipm ent to in stall an ACI sy stem

. Therefore, the construction effort and need for equipm ent is relatively m od est com p ared to the m o re involved SCR and FGD projects.



### QKQ **f åëí~ää~íáçå=qáãÉ** 

Im plem entation of a control technology at a plant involves several activities contingent upon each other.

These activities m a y be grouped under the following phases of an im plem entation project: (1) conducting an engineering review of the facility and awarding a procurem ent contract; (2) obtaining a construction

perm it; (3) installing the control technol ogy ; and (4) obtaining an operating perm it.

Exhibit A-5 in Appendix A depicts the tim eline expected for com p leting a single unit installation of ACI.

Com p letion of som e of the activities is contingent upon com p letion of other activities. For exam ple,

construction activities cannot com m e nce until a construc tion perm it is obtained. In general, the ACI

im plem entation tim eline appears to be driven prim arily by the engineering activities (i.e., design, fabrication, and construction).

30**båÖáåÉÉêáåÖ=oÉîáÉï** As shown in Exhibit A-5 in Appendix A, in the firs t phase of technology im plem entation, an engineering

review and assessm ent of the com bustion unit, is conducted to determ ine the preferred com p liance

alternative. During this phase, the specifications of the control technology are determ ined and bids are requested from the vendors. After negotiating the bids, a contract for im plem enting the control technology is awarded. The tim e necessary to com p lete this phase is approxim a tely four m onths.

**`çåíêçä=qÉÅÜåçäçÖó=fåëí~ää~íáçå** In the second phase, the control technology is installed. This installation includes designing, fabricating, and installing the control technology

. In addition, com p liance testing of the control technology is also

com p leted in this phase. Most of the construc tion activities, such as earthwork, foundations, process electrical and control tie-ins to existing item s , can occur while the boiler is in operation. The tim e needed to com p lete this phase of an im plem entation project is expected to be less than three m onths. 33

An im portant elem ent of the overall control technology im plem entation is the tim e needed to connect, or hook up, the control technology equipm ent to the com bustion unit. As a result of the m i nim a l

m echanical interface between the sorb ent injection sy stem and the boiler, retrofit of an ACI sy stem will
ty pically require a fairly short outage - one week or less. 33, 34 This brief outage is necessary to install injection hardware and to m a ke any control sy stem connections that m a y be necessary between the ACI

control and the boiler control. Other equipm ent associat ed with the ACI sy stem can be installed with the boiler on line, as it does not require any interfacing with the boiler and should not require m oving any essential boiler equipm ent.

It should be possible to com p lete a project in less than 4 m onths from receipt of order. 34 If construction and operating perm its are included in the analy s is, th e project is likely to take longer than would be

necessary only for engineering, supply

, installation, a nd startup of the ACI sy stem

. This is because the

perm itting activities m i ght becom e the tim e-lim iting steps. In som e localities, it is possible that the

perm itting activities will not be the lim iting steps. In this case, a faster execution is possible than shown on Exhibit A-5 in Appendix A.

**léÉê~íáåÖ=mÉêãáí**

Facilities will also need to m odify their Title V ope rating perm it to incorporate the added control devices

and the associated reduced em ission lim its. In som e states, an interim air-operating perm it m a y need to be obtained until the Title V perm it is m odified. The operating perm it m odification process consists of preparation and subm ission of the application to th e appropriate state or local regulatory agency

. As shown in Exhibit A-5 in Appendix A, this process can occur sim u ltaneously with the processing of the construction perm it application. The process of transitioning from the construction perm it to the operating perm it varies am ong states and appears to be som e what unclear due to the infancy of the Title V operating perm it process. Nonetheless, based on discussions with several states, the application review process is estim ated to take approxim a tely 38 weeks (9-10 m onths). The Title V operating perm it

m

u st also be m a de available for public com m e nt a nd is not m a de final until com p liance testing on the

control device is com p leted. Therefore, the total estim ated tim e to m odify the Title V operating perm it is

about 12 m onths, plus the additional tim e to com p lete com p liance testing. 10

Based on the estim ated tim e periods needed to com p lete each of the four phases described above, the

estim ated tim e period to com p lete the im plem en tation of ACI on one com bustion unit is about 15

m onths, as shown in Exhibit A-5 in Appendix A. Since the perm itting process lim its the tim eline, a faster perm itting process will shorten the tim e necessary to install ACI on a single unit.

31Under the Clear Skies Act, EPA does not expect that ACI will be im plem ented at m a ny facilities due to

the co-benefit of m e rcury rem oval from other control technologies. For those plants where EPA projects ACI retrofits will occur, EPA’ s projections reflect that these facilities will either have 1 to 2 boilers retrofit per site. Exhibit A-6 in Appendix A exam ines a schedule for retrofitting a facility with m u ltiple (two) ACI retrofits. This exam ines the installati on of the control device hook-up on a sequential basis. Installation is staggered by one m onth between sequential units to en able m o re efficient utilization of

m a npower and project m a nagem e nt than if m u ltiple un its were connected at one tim e. This approach requires a total tim e of 16 m onths.

In sum m a ry , the total tim e needed to com p lete the d esign, installation, and testing at a facility with one

ACI unit is about 15 m onths, at a facility with tw o ACI units is approxim a tely 16 m onths. Based on

these tim elines, it is estim ated that, in principle, the m e rcury controls needed to com p ly with a

m

u ltipollutant strategy can be m e t provided that (1) an adequate supply of m a terials and labor is available and (2) the control technology im plem entati on process begins at least 16 m onths prior to the

date controls m u st be in place. However, ideally

, longer than 16 m onths would allow retrofits to occur over a period of several y ears so that facility owners can properly plan outages and suppliers can properly plan for resource availability

. Erection of a PJFF would ty pically take 16 to 20 m onths from award of
contract to start up. 35 If 4 m onths is added for pre-contract e ffort and 1-2 m onths is provided for start up

and com m i ssioning, the total project duration would be any w here from about 21 m onths to 26 m onths. However, EPA’s m odeling under the Clear Skies Act projects that the units installing ACI will not be installing PJFFs. 36



### QKR **i~Äçê**

The m a n-hours of labor estim ated to be required for supply of an ACI sy stem are listed in Table 4-3,

which includes a breakdown of m a n-hours by task. 33 Craft labor for installation is also indicated.

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In sum m a ry , a 500 MW

e boiler firing eastern bitum i nous coal with 0.6 percent sulfur, an ESP, and no SCR or FGD, is estim ated to provide the perform an ce and require the resources listed in the first colum n of Table 4-4, and estim ates of perform ance and resources needed for other ty pes of fuels and boiler configurations are shown in the other colum n s. A boiler firing subbitum i nous coal and with only an ESP for particle collection and pollution control will re quire the m o st activated carbon consum ption and the

m o st steel for the ACI sy stem

. Table 4-5 shows the estim ated perform ance and resources needed for a single and m u ltiple (two) ACI retrofit on a 500 MW

e boiler firing subbitum i nous coal and equipped with

an ESP. As shown, as long as at least 16 m onths ar e provided for installation of ACI control technology

,

32then there should be sufficient tim e for the technology to be installed. If a facility owner chose to install a Pulse-Jet Fabric Filter (PJFF) in addition to the ACI sy stem for the purpose of im proving sorbent utilization, the project tim e would necessarily be le ngthened bey ond this 16-m onth period to allow for

the installation of the PJFF. As stated in section 4. 4, the total duration for a PJFF retrofit is estim ated to be any w here from about 21 m onths to 26 m onths, including pre-contract effort and start up and

com m i ssioning. Since the Clear Skies Act provides m u ch m o re than 26 m onths of notice for any

m e rcury control regulation, there should be adequate tim e for com p liance even if som e facilities install

PJFFs.

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### QKS **pé~ÅÉ=oÉèìáêÉãÉåíë**

Most of the equipm ent and piping associated with a so rbent injection sy stem is fairly sm all and can be easily accom m odated on any facility

. The only piece of equipm ent that could potentially be a challenge to locate on site is the sorbent storage silo, the ot her equipm ent largely being piping and a blower. The storage silo is, by far, the largest part of the ACI sy st em

. It is estim ated that a storage silo that is sized for 15 day s of AC storage at full load for a 500 MW

e plant firing bitum i nous coal and with only an ESP

would be about 10.7 m in diam eter and about 26.7 m high. 33 This sized piece of equipm ent, while large, should be readily accom m odated on m o st sites large enough for a 500 MW

e boiler. For boilers with fabric filters, the size of the silo would be less becau se of the lower sorbent injection rate. Som e facility
operators m a y choose to install a PJFF in order to reduce sorbent consum ption and to segregate carbon

from the ash. In this case, m o re space would be need ed for the PJFF. The dim e nsions for a PJFF on a

500 MW

e plant would be roughly 62 feet wide x 92 feet long x 90 feet high. 35

34

## `Ü~éíÉê=R **póåÉêÖáÉë=çÑ=`çãÄáå~íáçåë=çÑ=`çåíêçä=oÉíêçÑáíë=çå=~=páåÖäÉ=råáí**

This chapter will explore the com b ination of these technologies and how deploy m e nt of m o re than one technology at a unit could potentially result in im proved resource utilization. It is assum e d that the ACI, FGD, and SCR would not be necessary at a single unit because of the high m e rcury rem oval efficiencies expected through com b ination of FGD and SCR. Hence, the sy nergies of com b ining all three technologies were not explored.



### RKN **p `o=~åÇ=cda=EpÅêìÄÄÉêF=fåëí~ää~íáçåë** 

In som e cases, facility owners m a y choose to retrof it their plants with both SCR and FGD technology to
achieve both NO X and SO 2 reduction. Com b ination of SCR and FGD will also result in significant

reduction of m e rcury em issions, thereby m itigating th e need for the addition of ACI. However, both SCR and FGD are very capital-intensive projects, wh ich require a substantial level of m a terial and

construction. Therefore, it is worthwhile to consid er if both SCR and FGD installations can be com b ined efficiently

.

An SCR project involves retrofitting in the boiler and its im m e diate area. Therefore, an SCR retrofit project m a y require relocation of equipm ent in the boiler area. An FGD sy stem is installed farther

downstream in the plant, after the ESP. Occasionally , it is necessary to install a new sm oke stack, and it

m a y be necessary to add m o re fan capacity

. Ho wever, an additional sm oke stack is norm a lly

unnecessary

. The FGD connection with the facility is generally less difficult than with SCR because it does not require m odification of the boiler, just connec tion to ductwork in the vicinity of the stack. As a result, the construction activities would norm a lly be in different locations at the plant, reducing the interference between the two projects. The SCR m i ght be the lim iting item on the boiler outage because

of its m o re com p lex connection. In any event, the tie-in of the SCR and the FGD sy stem s could be done

in the sam e outage, and it has been confirm e d that the installation of SCR and scrubber could be perform ed sim u ltaneously without interference. 37 Therefore, installing these at the sam e tim e on a boiler is preferable to doing them separately as they m a y be able to use the sam e outage, and project

efficiencies result from a single m obilization, a single construction m a nager, and sharing of large construction equipm ent for the two projects. At Kansas City Power and Light’ s Hawthorn Power Station, Unit 5 was replaced (excluding turbine) in under 22 m onths. This included the boiler, an SCR,

and an LSD/FF. 38 Although, in this case the equipm ent did not have to be erected adjacent to an operating boiler, the erection included dem o lishi ng and erecting a com p lete boiler island and

dem o lishing the existing electrostatic precipitator. Hence, this was a very com p lex project that was

com p leted approxim a tely within the tim e fram e es tim ated and shown in Exhibit A-7 in Appendix A.



### RKO **j ÉêÅìêó=`çåíêçä=qÉÅÜåçäçÖó**  **=~åÇ=pÅêìÄÄÉê=fåëí~ää~íáçåë**

As noted in Chapter 4, ACI entails a m u ch sm aller construction project than either an FGD or an SCR. Moreover, the ACI is located in a different part of the plant than FGD or SCR and activated carbon injection occurrs in the ductwork between the air preh eater and the ESP or FF. One benefit of com b ining

35these two projects is that the ACI hookup can be com p leted during the outage for the scrubber hookup,

since the installation effort necessar y for the FGD will far outweigh that of the ACI sy stem

. A second benefit is better planning of m a terial storage and handling equipm ent. Both FGD and ACI require a

substantial am ount of m a terial (lim estone and AC, respectively ) and associated storage and handling

facilities. Installing both technologies at the sam e tim e will perm it better planning of m a terial storage and equipm ent locations, thereby avoiding interference. Other benefits, such as a single m obilization, a single construction m a nager, and sharing of large c onstruction equipm ent for the two projects exist, but they are not expected to m a ke a significant differe nce due to the difference in size between the portions

of the com b ined FGD and ACI project. Therefore, as shown in Exhibit A-8 in Appendix A, the schedule

for a com b ined FGD and ACI project is expected to be the sam e as the schedule of an FGD project.



### RKP **j ÉêÅìêó=`çåíêçä=qÉÅÜåçäçÖó=~åÇ=p`o=fåëí~ää~íáçå** 

As noted in Chapter 4, ACI entails a m u ch sm aller construction project than either an FGD or an SCR. The prim ary benefit of com b ining these two projects is that the ACI hookup can be com p leted during the outage for the SCR hookup, since the installation effo rt necessary for the SCR will far outweigh the ACI

sy stem

. Other benefits, such as a single m obilization, a single construction m a nager, and sharing of large construction equipm ent for the two projects exist, but they are not expected to m a ke a significant

difference due to the difference in size between th e SCR and ACI portions of the com b ined project. Therefore, as shown in Exhibit A-9 in Appendix A, the schedule for a com b ined SCR and ACI project is expected to be the sam e as the schedule of an SCR project.

36

## `Ü~éíÉê=S **póëíÉã=oÉëçìêÅÉ=^î~áä~Äáäáíó**

Having assessed the resource requirem e nts for individua l or m u ltiple retrofits of control technologies, this chapter will assess the resource availability in th e United States for retrofit of control technologies

for the Clear Skies Act. This analy s is considers th e current availability of resources for the construction of control technologies and does not consider any pot ential increase in production of resources due to the

dem a nd created by the Clear Skies Act. Because th is effect will be m o re pronounced in the period following 2010 and because other m a rket factors m a y also change over tim e, the longer term projections

are of less value than those out to 2010. EPA has m a de prelim inary estim ates of the retrofits of each technology that would result from the Clear Skies Act. Tables 6-1a, b, and c list the expected total MW

e of facilities that would be equipped with SCR, FGD, or ACI after response to a m u ltipollutant rule. It is

im portant to note that the “Current Air Quality Rule Retrofit MW

e ” row of the table includes only the projected retrofits under the current air quality rules. The control technology retrofits estim ated to result

from the Clear Skies Act, including the retrofits from current air quality rules, is listed in the “Multipollutant & Current Retrofits MW

e ” row of the tables. The “Cum ulative Total” MW

e shown in Table 6-1 includes facilities that currently are equipped with the technology or are expected to be equipped with the technology as a result of current air quality rules, such as SCRs resulting from the NO X SIP Call as well as the projected retrofits under the Clear Skies Act. EPA estim ated that up to 72 GW

e of

SCR would result from the NO X SIP Call and an additional 13 GW

e from individual state m u ltipollutant rules with approxim a tely 14 GW

e currently installed. However, facilities are responding to the NO X SIP

Call at this tim e and it is uncertain exactly how m a ny facilities will ultim ately be equipped with SCR in

2004 when the NO X SIP Call deadline arrives.

EPA projections estim ate that it would be cost effective for 32,000 MW

e of FGD retrofits to be installed under the Clear Skies Act by 2005 even though the first phase of the SO 2 cap is not in effect until 2010. These retrofits would be early installations that s ources initiate due to the ec onom ic benefits of banking

SO 2 allowances. It is estim ated that there are about 4,000 MW

e of FGD capacity being constructed or just recently com p leted. Based on availability of r esources, particularly labor, it is projected that an additional 6,000 MW

e of FGD capacity could be built for a total of 10,000 MW

e by 2005. Because the

FGD estim ate based on availability of resources is m u ch less than the am ount of FGD capacity that would be cost effective to build, EPA ran m odel sensitivities constraining the am ount of scrubber capacity that could be installed by 2005 at 10,000 MW

e . This estim ate for the potential num ber of FGD retrofits considers the resource and labor requirem e nt s of the sim u ltaneous installation of SCRs, which is further discussed under the labor section (6.2) of this chapter. The 22,000 MW

e difference, between the

num ber of FGDs which would be cost effective to build and the estim ated num ber based on resources, would be pushed back a few y ears to be com p leted by 2010. Therefore, the 53,000 MW

e of FGD retrofits projected to be built by 2010 for Clear Skies and current requirem e nts rem a ins the sam e under

both scenarios. It is likely that additional FGD retr ofits could be com p leted by 2005, but there would be the potential for an increase in the cost of c onstruction due to decreased im plem entation tim e.

A ty pical unit size of 500 MW

e was selected for each technology

. In previous sections, capacity factors of 85 percent were assum e d. In reality , coal-fired fac ilities, on average, have lower capacity factors. For

exam ple, in 1999, 39.8 percent of 786 GW

e of generating capacity in the U.S., or 313 MW

e , was coal

fueled. In that sam e y ear, coal-fired U.S. plants produced about 51 percent of 3,691 billion kWh, or

37ä ä

ä

í í 1,882 billion kWh. 39 This corresponds to a capacity factor of 68.7 percent (Data is from Energy

Inform ation Adm i nistration Web Site; Capacity Factor is total MW

e -h produced divided by the total

MW

e -h that would be produced if the plant were run at full capacity for 8,760 h in the y ear). As a result,

assum i ng a capacity factor of 85 percent will result in a m u ch m o re conservative (high) estim ate of resources needed than is likely to be the case.

In estim ating the resources necessary to put new control technology capacity in place (labor, steel, etc.), the “Multipollutant & Current Rule Retrofits MW

e ” values of Tables 6-1a, b and c are of greatest

interest. For estim ating the consum ables necessar y for the technologies, such as lim estone, am m onia, cataly s t, or activated carbon, the “Cum ulative Total MW

e ” value is m o st im portant. The m u ltipollutant

and total MW

e of control technology retrofits are give n for 2005, 2010, 2015, and 2020. To provide a

conservative estim ate of required resources, the followi ng analy s is looks at im plem enting the retrofits for

2005 in 31 m onths prior to 2005 and retrofits for 2010, 2015, and 2020 three y ears prior to each five-y ear period. For exam ple, it estim ates the resource requirem e nts from the period between 2005 and 2010 over three y ears prior to 2010 instead of five y ears. Thirty -one m onths was used for 2005, because the analy s is for 2005 was based on the projected num ber of retrofits needed by 2005, less the am ount of capacity installed by May 2002. It should also be not ed that m o st of the retrofits needed by 2005 are being installed to m eet existing requirem e nts under the NO X SIP Call or other regulatory requirem e nts as opposed to the requirem e nts of a m u ltipolluta nt program such as the Clear Skies Act.

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í 

### SKN **póëíÉã=e~êÇï~êÉ**

The hardware item s such as steel, piping, nozzles, pum ps , soot blowers, fans, tower packing, and related equipm ent required for a ty pical SCR, FGD, or ACI sy stem s installation are used in large industries such as construction, chem ical production, auto production, and power production. C onsequently , installation of these technologies on m a ny coal-fired utility boilers is not expected to result in severe changes in

dem a nd for the hardware item s listed.

From Chapter 2, roughly 1,125 tons of steel is needed for a 500 MW

e FGD sy stem , which is about 2.25 tons per MW

e . This is conservatively high since there are som e significant sy nergies possible when there

are m u ltiple units on site. In pa rticular, two boilers with 900 MW

e of capacity require approxim a tely 2.1 tons per MW

e . From Chapter 3, an SCR for a coal-fired utility boiler requires roughly 2.5 tons of steel per MW

e for the ty pical size. From Chapter 4, a 500 MW

e facility will need about 175 tons of steel to install an ACI sy stem , or about 0.35 tons per MW

e . Estim ated steel requirem e nts for the projected

retrofit MW

e are shown in Table 6-2 assum i ng that the re trofits occur over 31 m onths prior to 2005 and over three y ears prior to 2010, 2015, and 2020. For re trofits starting in 2005 facility owners are likely to
have m o re than three y ears to com p lete this work as m a ny of these retrofits have already begun. These

tim e periods were chosen to show that even under short periods of tim e, no significant im pact to U.S. steel supply is expected.

Census Bureau data on

**=** U.S. steel shipm e nts in 2000 was approxim a tely 108,703,000 tons, and im ported steel was 30,993,000 tons for a total dem a nd of about 140 m illion tons. An assum e d growth rate of US

steel dem a nd was chosen at 3 percent, a ty pical num ber for growth in GDP. For each increm ent of tim e, the im pact to US steel dem a nd was less than one tenth of one percent. Even if there were no growth in the US steel production and im ports from 2000 out to 2020, the am ount of steel needed to com p lete the

retrofits for the Clear Skies Act would still be l ess than one tenth of one percent of US production including im ports.

Sim ilarly

, available supplies of piping, nozzles, pum ps, soot blowers, fans, and other related standard

com ponent necessary for SCR, FGD or ACI installations are not expected to present constraints on the ability of facilities to install the technology

. SCR cat aly s t is the only specialized piece of equipm ent that

is needed. Cataly st is discussed in Section 6.4.

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40

### SKO **i ~Äçê** 

The installation of the SCR, FGD, and ACI control technologies will require the following ty pes of labor:

• general construction workers for site prep aration and storage facility installation;

• skilled m e tal workers for specialized m e tal a nd/or other m a terial assem bly and construction;

• other skilled workers such as boilerm akers, electrician s, pipe fitters, painters, and truck drivers; and

• unskilled labor to assist with hauling of m a terials, placing of cataly s t elem ents, and clean up.

From Chapter 2, it takes roughly 760 m a n-hours of labor per MW

e of FGD built. Chapter 3 showed that

about 700 m a n-hours of labor per MW

e are required for an SCR sy stem on a coal-fired boiler, and Chapter 4 showed that roughly 10 m a n-hours of labor are needed per MW

e for an ACI sy stem

. Using these factors and the expected retrofits, the labor re quirem e nt for SCR, FGD, and ACI retrofits can be

determ ined and are shown in Table 6-3. These estim ates do not take into account any sy nergies or

efficiencies realized from retrofitting m u ltiple units on a site, as are described in Section 2.5 and 3.5, or

from a com b ination of technologies, as described in Chapter 5. Roughly 50 percent of an SCR project

m a n-hours and 40 percent of an FGD project m a n-hours are for boilerm akers. 40 There is little data on ACI breakdown of labor; however, a conservative level of 50 percent is assum e d. Using these rates and

assum i ng the above m e ntioned cons truction periods, it is possible to estim ate the num ber of fully

em ploy ed laborers and boilerm akers. The results ar e shown in Table 6-3. The actual annual requirem e nt
for labor would be less if the estim ated num ber of re trofit installations were evenly distributed over the full five-y ear increm ent of tim e instead of the conservative three-y ear increm ent.

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Figure 6-1 shows a sum m a ry of construction worker labor available in the United States. The data shows steady growth in construction industry em ploy m e nt at the national level during the 1992 to 2000 period.

Em ploy m e nt in the construction sector grew by 49. 1 percent (4.1 percent annualized) over the period

com p ared to 21.7 percent (2.0 percent annualized) for the econom y as a whole. The unem p loy m ent rate of 6.4 percent in 2000 com p ares to 4.0 percent for the whole econom y

. 41

41Figure 6-1. U.S. construction em ploy m e nt and une m p loy m ent (Source: Bureau of Labor Statistics).

The available construction labor in the United Stat es, about 6.7 m illion, will provide a large labor pool for the trades that are not unique to the power industr y , such as iron and steel workers, pipe fitters, and

electricians. In other words, that the estim ated dem a nd of under 20,000 full-tim e workers represents only about 0.3 percent of the current total labor pool.

Boilerm akers are a skilled labor source that is fairly unique to utility work. Sixty percent of the dem a nd

for boilerm akers in the construction division is from the utility industry

. 31 Other industries requiring

boilerm aker labor include refinery (13 percent), chem ical (6 percent), paper (7 percent), and m e tals (6 percent). These are the industries where boilers a nd high-energy vessels are m o st likely to be found. Retrofit of equipm ent on utility boilers often requir es a significant num ber of boilerm akers due to the integration that is needed with the boiler that ofte n requires m odification of steam piping or other boiler equipm ent. Also, in response to the increase in de m a nd for boilerm akers over the last few y ears, their

ranks have increased from 15,444 active m e m b ers in 1998 to 17,587 * m e m b ers in 2000 - an annualized growth rate of 6.7 percent. 31 Em ploy m e nt level also increased during this tim e from 69.8 percent to 81.8 percent (em p loy m ent level is equal to the total m a n-hours worked in the y ear divided by total active

m e m b ers tim e 2080 h/y r). During m u ch of the 1990’s the num ber of active boilerm akers had been declining due to very low em ploy m e nt levels resu lting from very low activity in the utility power plant

construction business. 30 Therefore, the increased activity of the last few y ears has been a welcom e change to boilerm akers.

Several sources have m e ntioned that the availability of boilerm akers has been tight for the SCR projects underway for the NO X SIP Call. 42, 43 However, where shortages have been experienced in m a nning SCR construction projects with adequa te num bers of boilerm akers, m a npower planning had been done with

short notice. 44 Many boilerm akers travel to work sites that are out of their local area. A large project

m a y require m obilization of several hundred boilerm ak ers to a site, which will frequently require pulling

* It i s assum e d t h at t h i s num ber i s for journey m an bo i l e rm akers and does not i n cl ude persons i n apprent i ceshi p

program s.

42m e m b ers from other parts of the country

. In th e current, com p etitive environm ent for utilities, power plant owners are reluctant to provide m u ch advan ce notice of when outages will occur. Therefore, in

som e cases contractors m u st find m a npower on very short notice. The boilerm aker' s union (The

International Brotherhood of Boilerm akers, Iron Sh ip Builders, Blacksm iths, Forgers and Helpers)

attem p ts to provide the necessary m a npower to the cont ractors. However, with very short notice, it is

som e tim es difficult to m ove the m a npower to the site in the short tim e desired. Nevertheless, the union has been successful in providing sufficient m a npower to the project sites where they have had adequate

advance notice. 44 Therefore, although there is little slack in the availability of boilerm akers, better

coordination m a y have avoided the labor shortage problem s.

It is worthwhile to consider the expected future st ate of the supply of boilerm akers. The total num ber of

m e m b ers in the boilerm aker' s construction divi sion is currently about 24,000 journey m en and apprentices. 44 The union has about 4000 m e m b ers in Canada. These num bers are up from the 1990' s when a severe drought of work for boilerm akers caused m a ny boilerm akers to seek other lines of work. Due to the current workload, the bo ilerm aker ranks are growing. However, the average age of the work

force is about 48. Because of the aging workfor ce and because of the anticipated dem a nd for work at power plants, the union has m a de it an objective to have at least 28,000 m e m b ers in the construction division by 2005, or at least a 5.3 percent annual growth rate. The boilerm aker' s union is working to

recruit new m e m b ers into their apprenticeship program s, which takes four y ears to com p lete. Also,

skilled workers from other trades m a y choose to work as a boilerm aker, so a shorter apprenticeship m a y be possible, depending upon the experience and skill le vel of the individual. For exam ple, iron and

steelworkers who had been boilerm akers in the past could m ove back into boilerm aker work very quickly

. Since, boilerm akers earn som e what m o re than ironworkers, 42 it is reasonable to expect that with increased job stability in the boilerm aker trade, som e ironworkers m i ght choose to m ove to the

boilerm aker trade for the higher pay

, especially if th ey had worked as boilerm akers in the past. The iron and steelworkers union has 150,000 m e m b ers. 45 Even without prior boilerm aker experience, som e of

these iron and steelworkers could choose to m ove to boilerm akers with m u ch less than a full four-y ear training requirem e nt because of their knowledge a nd skill level. In addition, the boilerm aker' s shipbuilding division has about 30,000 m e m b ers 45 who, depending upon industr y conditions, could m ove over to the construction division quickly

.

As noted earlier, the num ber of boilerm akers dr opped quickly during the 1990s when little work was

available. Conversely

, increasing dem a nd for boilerm akers that would result from a m u ltipollutant rule

should stim ulate m o re workers to enter the trade. The overall em ploy m e nt outlook for boilerm akers should be quite good, considering the work created by a m u ltipollutant initiative and the work on new power plants that is projected over the next 20 y ears. As stated in the National Energy Policy (May 2001):

Over the next 20 years, the United States will need 1300 to 1900 new power plants. Electricity demand is expected to increase at a rate of 1.8 percent per year over the next 20 years, creating the need for 393,000 MW

e of generating capacity. At a 1.5 percent growth rate that number is reduced by between 60,000 to 66,000 M W

e to about 330,000 M W

e of new generating capacity.

A large quantity of new generating capacity , consisti ng m o stly of gas com b ined cy cle units, has been built within the last several y ears. Since 1998, close to 200 GW

e of new capacity have been built or is currently under construction with an even larger quantity being proposed. This excess in capacity is projected to create an overall reserve m a rgin greater than 25 percent in the US over the next few y ears. By com p arison, this is a significant increase in the r eserve m a rgin since it dipped below 10 percent in the

late 1990' s. As the dem a nd in electricity grows, the need for new generating capacity will not be felt

43until the excess capacity is worked off. Assum i ng ne w capacity will be needed when the reserve m a rgin approaches 15 percent, it is expected to push back the need for additional capacity bey ond 2005 and in

som e regions as late as 2010.

Due to the installation of SCR units for the NO X SIP Call, a significant percentage of the boilerm akers who are currently working in the utility industry woul d be needed to com p lete those retrofits by 2004. Integrated Planning Model (IPM) projections indicate that it would be cost effective to install 32 GW

e of scrubbers by 2005 in addition to the projected SCR installations; however, boilerm aker labor is not expected to be sufficient to m eet this dem a nd even if their num bers grow at the projected 5.3 percent annual growth rate. Figure 6.2 shows the boile rm aker labor requirem e nts out to 2010 assum i ng 32 GW

e of scrubbers and 85 GW

e of SCR installations are installed by 2005 and com p ares the dem a nd to the supply of labor.



### B o i l er m aker S u p p l y vs. C l ear S k i e s D e m a n d
( 3 2 G W e S c r ubbe r I n s t a l l a t i ons by 2 0 0 5 )

0 5

, 000 10

, 000 15

, 000 20

, 000 25

, 000 30

, 000 35

, 000

20 00 2 001 20 02 20 03 2 004 2005 20 06 2 007 2 008 20 09 2 010BoilermakerLabor(1000 man-hrs)

O t her U t i l i t y D e m a nd C l ear S k i e s D e m a n d U t i l i t y B o i l e r m a k

e r S uppl y

Figure 6-2. Boilerm aker dem a nd under Clear Skies Act (32 GW

e of FGD installations).

Assum i ng that the boilerm aker m e m b ership grows at a 5.3 percent growth rate out to 2005, it is estim ated

that there will be sufficient new boilerm aker labor to com p lete approxim a tely 10 GW

e of scrubber retrofits by 2005. Considering that 4 GW

e of scrubber capacity is either being built or recently constructed, it is conservativel y assum e d than an additional 6 GW

e could be com p leted by 2005. This

estim ate of 10 GW

e of scrubber retrofits by 2005 was determ ined from the difference between the

boilerm aker labor hours available from the boilerm aker m e m b ership working in the electric utility industry and the labor hours needed to com p lete c ontrol technology retrofits and other electric utility projects. This estim ate is supported by the num be r of orders of FGDs for 2001 and projected orders through 2002 by the electric utility industry

, which totals over 11 GW

e 46 , and over 13 GW

e of announced scrubbers which are scheduled to start up by 2005. Or ders for scrubbers, such as the recent order for the

Colem a n Station in Kentucky , are continuing to be r eceived in spite of the concerns raised about the availability of boilerm aker labor during the sim u ltaneous installation of SCRs for the NO X SIP Call. The other electric utility projects that boilerm akers work on include such projects as routine m a intenance at operating plants and new plant construction, wh ich account for approxim a tely 13,500,000 m a n-hours of

44boilerm aker labor per y ear. 30 Figure 6-3 com p ares the available boilerm aker labor to the dem a nd from the electric utility industry which includes the retrofits from the Clear Skies Act.



### B o i l e r m a k e r Suppl y v s

. C l e a r Ski e s D e m a nd

( 10 G W e S c r u b b e r I n s t all a t i o n s b y 200 5)

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010BoilermakerLabor(1000man-hrs)

O t h e r U t ilit y D e m a n d C l ear S k i e s D e m and U t ilit y B o ile r m a k

e r S uppl y

Figure 6-3. Boilerm aker dem a nd under Clear Skies Act (10 GW

e of FGD installations).

Since boilerm akers earn m o re m oney than m o st other craft trades 42 and the dem a nd for boilerm akers should be steady and increasing, it is reasonable to expect that the growth in boilerm aker num bers experienced these last few y ears should continue for m a ny m o re y ears. To assess the im pact of this, it

was assum e d that the boilerm akers in the U.S. con tinued to grow at the 5.3 percent pace that the

International Brotherhood of Boilerm akers, Iron Ship Builders, Blacksm iths, Forg ers, and Helpers has set

as a m i nim u m growth target. Based upon the estim ates of Table 6-3 and the assum e d growth rates, the

annual boilerm aker dem a nd created by the Clean Skies Act can be estim ated and is shown in Table 6-4. Table 6-4 was derived considering that 14 GW

e of SCRs have already been installed for the NO X SIP Call, so the rem a ining 71 GW

e of SCR and 10 GW

e of scrubber installations were considered for 2005. According to Table 6-4, if the retrofit of the FGD, SCR, and ACI sy stem s for 2005 occur over thirty -one

m onths prior to 2005 and over a three-y ear period for each five-y ear increm ent after 2005 to 2020, the

m a xim u m dem a nd would be about 23 percent of the journey m an boilerm akers or about 19 percent for journey m en and apprentices com b ined.

Considering only the boilerm akers who are currently in dem a nd by the utility industry

, the dem a nd would be about 38 percent of the journey m an boilerm akers or about 31 percent for journey m en and apprentices

com b ined. These percentages of dem a nd are expected to be experienced prior to 2010, but with growth

in the boilerm aker num bers out to 2010, the percent of boilerm akers affected drops off. The num ber of

boilerm akers in dem a nd for retrofit installations under th e Clear Skies Act is spread fairly evenly out to
2010 when the dem a nd begins to decrease. However, there m a y still be significant dem a nd for

boilerm akers after 2010 from other power plant construction program s.

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The actual im pact on the dem a nd for boilerm akers could be lower for several reasons. Due to the longer

increm ents of tim e that the Clear Skies Act provides facility owners to com p ly than was assum e d in this analy s is, installation of these technologies will extend over m o re than three y ears, spreading out the

dem a nd. As stated earlier, this analy s is does not c onsider any of the sy nergies or efficiencies that have

been dem onstrated to occur on m u ltiple unit retrof its or m u ltiple-technology retrofits. The boilerm aker population has been growing at a faster rate– 6.7 percent annually – in recent y ears than the union’ s

m i nim u m target of 5.3 percent that was assum e d. Therefore, the num ber of boilerm akers m a y actually

grow m o re quickly than what was assum e d. This analy s is also neglects overtim e, which would reduce

the dem a nd for workers som e what.



### SKP **`çåëíêìÅíáçå=bèìáéãÉåí**

Most of the construction equipm ent necessary for the installation of SCR, FGD, and ACI technology is standard construction equipm ent that is used for m o st construction activities. The piece of equipm ent
that is not standard that m a y be needed for SCRs and possibly for FGD sy stem s is a tall-span heavy

- lift

crane. These cranes are necessary to lift heavy pieces (som etim es over 100 tons) several hundred feet and are not needed for all projects. When the largest piece to be lifted is determ ined from the construction plan, the necessary crane can be determ ined

. In som e cases, the available crane or the crane pricing m a y lim it the largest piece to be lifted, and the construction plan m a y be m odified to

accom m odate a sm aller crane by lifting sm aller pieces. In m a ny instances, the best crane for the job is

46not the largest because the large cranes are very expens ive to rent (one size up could double or triple the

m onthly charges for renting the crane 30 ). As a result, it m a y be m o re cost effective overall to use a

sm aller crane and lift sm aller pieces. This m a y lengt hen the installation tim e slightly , but it will reduce

crane rental fees. Therefore, an econom ic trade off m u st be assessed for each project.

As discussed in Section 3.3, utility engineers reported that while installing SCRs for the NO X SIP Call, crane availability has been an i ssue that can be accom m odated with proper planning. The construction plan could be m odified to em ploy the available or m o st cost-effective crane. Therefore, sufficient supply of construction equipm ent is expected to be ava ilable for installing air pollution control equipm ent.



### SKQ **o É~ÖÉåíë** 

The m a jor groups of reagents considered in this Section include lim estone for FGD sy stem s, SCR cataly s t, Am m onia/Urea, and AC for ACI sy stem s.



### iáãÉëíçåÉ=Ñçê=cda=póëíÉãë

Lim estone is used for a wide range of purposes in the United States. Overall lim estone usage increased 22 percent over the four y ears from 1995 to 1999 (annuali zed growth of 5.1 percent). Table 6-5 shows the production of crushed lim estone sold or used by U.S. producers.

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**qçí~ä=rëÉ vÉ~ê**  **EíÜçìë~ åÇ=íçåëF** 

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**NVVU** NIMRMIMMM

**NVVT** NIMNMIMMM

**NVVS** VRSIMMM

**NVVR** UUQIMMM

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As noted in Chapter Two, 500 MW

e plant firing 4.0 percent sulfur coal and equipped with LSFO FGD technology will use about 32 tons per hour of lim estone, or about 240,000 tons/y r (about 0.064 tons/MWh), and lim estone consum pti on for MEL technology would be less. 6 Using an LSFO

consum ption rate is conservatively high, and Table 6-6 shows expected consum ption rates if all projected FGD retrofits were LSFO technology and opera ted at 85 percent capacity factor. The row “Multipollutant & Current Rule FGD Lim estone Consum ption (tons)” provides an estim ate of the

lim estone consum ption for the projected retrofits due to the m u ltipollutant strategy and current air quality

rules. The row “Cum ulative FGD Lim estone Consum ption (tons)” provides an estim ate of the lim estone

consum ption for the cum u lative total num ber of FGD installations, which includes 94 GW

e of current

installations. As shown, the im pact to total U.S. production for the m u ltipollutant strategy rem a ins less than 2 percent out to 2020 while the overall dem a nd fro m all installed FGD rem a ins less than 4 percent

out to 2020.

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### p`o=`~í~äóëí
SCR cataly s t is a critical part of the SCR sy stem th at is m a nufactured on a worldwide basis by som e of the largest com p anies in the world. Manufacturing is largely in the United States, Europe, and Japan, and the worldwide capacity is used to support worldwid e sales. The current and planned capacity of SCR cataly s t supply available to the U.S. m a rket for coal-fired boilers is nearly 90,000 m 3 /y r. Table 6-7 shows the results of a survey of m a jor suppliers of SCR cataly s t to coal-fired boilers. The suppliers provided EPA their current capacity and the capacity th at will be on line in the y ear 2002. The estim ated capacity of other suppliers of cataly s t to coal-fired bo ilers that could not be reached in tim e for this study

is listed also. Suppliers that have offered cataly s t fo r coal applications in the past but currently focus strictly on gas and oil -fired applications were not included. However, it is recognized that these

com p anies could shift their product m i x if the m a rket conditions justified it, so the capacity value shown could be quickly increased if m a nufacturers sim p ly changed product focus.

The current capacity was originally built overseas to m eet overseas dem a nd or was subsequently built to

m eet U.S. dem a nd for cataly s t spurred by the NO X SIP Call and the build up of gas turbine power plants

in the U.S. Except for a m oderate dem a nd for re placem ent cataly s t, m u ch of this capacity will be available after 2004 because these large dem a nd peaks will have m o stly passed. Because m o st of the

com p anies that supply cataly s t are divisions of very large com p anies with the resources to rapidly expand

their m a nufacturing capacity to m eet increases in m a rk et dem a nd, it is reasonable to assum e that this

m a nufacturing capacity could be expanded if the m a rk et dem a nd justified it. In fact, recent capacity expansions provide strong evidence of this.

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48ä ó

ë ä í Currently , the equivalent of approxim a tely 100 GW

e of coal, oil, and gas-fired capacity worldwide utilizes SCR technology

. At these worldwide insta llations, the volum e of SCR cataly s t in use is

estim ated to be approxim a tely 55,000 to 95,000 m 3

. 10 Assum i ng that one-twelfth of the current cataly s t is replaced each y ear on average, the annual dem a nd for replacem ent SCR cataly s t is approxim a tely 5,000 to 8,000 m 3 /y r. Note that the estim ate for the current annual dem a nd is quite conservative since the cataly s t replacem ent rate on oil- and gas-fired com bus tion units is likely to be less frequent than onetwelfth of the cataly s t per y ear. By 2005, an additional 85 GW

e of coal-fired SCR capacity is expected to be on line in response to the NO X SIP Call and recently prom ulgated State rules (this includes anticipated SCR retrofits under the state rules for Missouri, C onnecticut, and Texas). Assum i ng conservatively that one-eighth of the cataly s t is replaced each y ear on average for coal-fired units, the annual dem a nd for replacem ent SCR cataly s t would increase by 12,600 m 3 /y r by 2005. Adding the current annual replacem ent dem a nd from worldwide installations to the projected annual replacem ent dem a nd under the Clear Skies Act would y i eld a total of 17,600 - 20,600 m 3 /y r dem a nd for replacem ent cataly s t by 2005. 10

The estim ated annual dem a nd for cataly s t from the Clear Skies Act, which consists of the dem a nd due to new installations and annual replacem ent is shown in Table 6-8. The highest cataly s t dem a nd will occur by 2010. From Table 6-7, the estim ated capacity of cataly s t supply is 87,300 m 3 /y r. Considering the

initial fill dem a nd of 26,000 m 3 /y r from 65 GW

e of SCR installations and replacem ent dem a nd of 22,300

m 3 /y r from 150 GW

e of cum u lative SCR installations plus the worldwide cataly s t replacem ent dem a nd of between 5,000 and 8,000 m 3 /y r, the annual excess capacity is estim ated to be 31,000 to 34,000 m 3 /y r. A m o re conservative approach to determ ining if th ere is sufficient cataly s t supply to m eet the dem a nd

from the Clear Skies Act is dem onstrated in Figure 6-4. It com p ares the current cum u lative production capacity for SCR cataly s t to the cum u lative a nnual dem a nd for SCR cataly s t from the total SCR

installations in 2005 and 2010. This approach assum es that the annual production of cataly s t continues at the current level of 87,300 m 3 /y r and starts accum u lating in May 2002. If all SCR sy stem s were loaded with cataly s t in just a one y ear period prior to 2005 and 2010 instead of spreading out the loading over several y ears, there would be sufficient accu m u lated supply to m eet the increased dem a nd.

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49

### C u m u la t i v e S C R C a t a l y s t Pr oduc tion C a pa c i t y

v s Cu mu l a t i ve Cl ear S k i es Deman d

0 100 200 300 400 500 600 700 800

2002 2003 2004 200 5 2006 2007 2008 2009 201 0Catalyst(1000 m3/yr)

C l e a r S k ie s C u mu la t i v e I n it i a l F i l l De m a n d Cl e a r Sk i e s Cu mu l a t i v e Re p l a c e me nt De m a n d

Cumu lat i v e P r odu ct i o n Capac i t y

Figure 6-4. Cum u lative SCR cataly s t dem a nd com p ared to cum u lative production capacity

.

Utility power plants are already installing SCR cataly s t for the purpose of NO X SIP Call com p liance in

2004. As shown in Figure 6-4, the cum u lative dem a nd from the Clear Skies Act plus the worldwide

dem a nd can be m e t with the total cum u lative confir m e d capacity

. Consequently , adequate capacity of SCR cataly s t supply is available to satisfy the dem a nd that m a y result from the projected installations. Of course, as dem onstrated by the cataly s t suppliers, if m o re capacity was desirable to satisfy the m a rket, it could be added given sufficient lead tim e for the construction of the cataly s t production facility

.

The ability to retrofit a large num ber of SCR sy stem s over a short period of tim e was exem plified in

Germ any during the late 1980s. Figure 6-5 shows th e num ber of sy stem s installed over an eight-y ear period, with m o st of these sy stem s (97 of 137) installed during two consecutive y ears (1989-1990). This pattern of installations exhibits that the cataly s t m a rket dem onstrated the ability to respond to the surge in

dem a nd resulting from a dram atic increase in SCR installations.



### ^ããçåá~=~åÇ=rêÉ~
The installation and operation of SCR sy stem s is not e xpected to be constrained by the future availability

of am m onia or urea. The production of anhy drous am m onia in the U.S. in 2000 was approxim a tely 17,400,000 tons (equivalent anhy dr ous) with apparent consum p tion of 22,000,000 tons and about 4,600,000 m e t through net im ports, as shown in a 2001 edition of U.S. Geological Survey Minerals

Com m odity Sum m a ries. Am m onia dem a nd is directly proportional to the tons of NO X reduced. The

increased am m onia dem a nd from a m u ltipollutant rule is estim ated to increase to about 1,040,000 tons

per y ear by 2020. This 4 percent increase in dem a nd over a nearly 20-y ear period can easily be m e t. Moreover, the U.S. and worldwide am m onia business is struggling because of slum ping dom estic

dem a nd and increased global capacity for the product a nd other nitrogen fertilizers derived from it, such

as urea. Nevertheless, m o re capacity is scheduled to com e on in the U.S. during the near future. In addition, 1.2 m illion tons of capacity is being built in Trinidad and Venezuela. Algeria and the form er Soviet Union have also added significant capacity

. Another problem is the withdrawal of China as an

im porter of am m onia. China traditionally bought 3 to 6 m illion tons of urea annually (which is produced

50from am m onia), but in 1996, the country launched a driv e to becom e self-sufficient in urea, a m ove that has displaced 1.9 to 3.7 m illion tons of am m onia. 47 Based on these estim ates, the ability to supply of

am m onia will continue to exceed its dem a nd, even with the additional dem a nd from newly installed SCR

sy stem s.

SCR sy stem s can also use urea as a reagent, and it is becom i ng preferred to am m onia in m a ny cases because of its safety

. Urea is a com m only available chem ical with approxim a tely 11,760,000 tons of

dom estic annual production capacity

. 48 For SCR purposes, this adds effectively another 6.7 m illion tons

of am m onia annually available as SCR reagent. * Additionally , U.S. urea m a nufacturers and distributors routinely trade within a 130,000,000 tons worldwide annual production capacity

. 10 Based on total world urea trade, increased dem a nd due to a m u ltipollutant regulation would be well under 2 percent of world

trade if all SCRs used urea rather than am m onia. And, like am m onia, the urea m a rket is currently experiencing an oversupply situation. Urea prices ha ve fallen precipitously since China, form erly a

m a jor buy er, decided to strive for self-sufficiency

. From 1994 to 1997, China opened nine new urea plants and raised its dom estic pr oduction by 50 percent. U.S. producers knew China would bring on the

new, m o re-efficient plants, but they did not expect that country to continue running its sm aller, lessefficient ones. 48 Thus, it is expected that this worldw ide supply will provide additional flexibility in

m eeting any significant increases in dem a nd. Since urea production is perform ed on a worldwide basis, plants producing urea would be able to expand their capacity if needed. Based on these considerations, adequate urea supply is expected to be available for the SCR sy stem s.

60

50

40

30

20

10

2 5 7 17 51

46

6

3

0

198 5 1 9 8 6 1 987 198 8 1 9 8 9 1 990 199 1 1 9 9 2

Y ear

Figure 6-5. SCR Installations on coal-fired plants in Germ any

. 11# ofInstallations Per Year

* It t a kes about 1.76 l b s of urea t o m a ke one l b of am m oni a reagent i n a urea t o am m oni a conversi on.

51í í á 

### ^`=Ñçê=^`f=póëíÉãë

AC is produced in the United States and abroad fo r filtration and other m a nufacturing purposes. Total AC usage in the United States was 182,887 tons/y r in 2000, as given in the U.S. Census Bureau Sum m a ry Current Industrial Reports for the Inorganic Chem ical Industry

. Capacity in the U.S. is equal to 465

m illion pounds/y r, or 233,000 tons. 49 Both of these num bers include both granular and powdered carbon, powdered being preferable to granular for ACI appli cations. U.S. dem a nd is projected to grow to 454

m illion pounds, or about 227,000 tons, in 2004. 49 However, large underutilized capacity overseas will provide a ready supply of potential im ports, which will tend to lim it price increases for m o st grades. 49

The com p etition from Chinese and South-East Asian producers rem a ins strong. 50 Chinese exports quadrupled from 53,230 tons in 1995 to 224,331 tons in 1997, with the average product cost dropping by 16 percent to 660/ton. Therefore, growth in dem a nd experienced in the 1990’s has not been reflected in

the value of the m a rket due to over-capacity and th e continued rise in Asian exports. AC producers are concentrating increasingly on the Asia-Pacific region to exploit growing m a rkets and take advantage of lower production costs; reported capacity expansions of over 15,000 tons/y r are all planned for AsiaPacific and Russia. 50

According to Norit, the largest supplier of AC for air pollution control purposes, there is currently adequate excess capacity to accom m odate significant growth in the dem a nd (tens of m illions of pounds/y r, or roughly tens of thousands of tons/y r). 51 However, depending upon how m u ch growth occurs as a result of regulation, additional capacity m a y be necessary

. It would take 2-3 y ears to add a plant; and this would only be done after a regulation was put in place, the technical advantages of ACI

for m e rcury rem oval were proven relative to other approaches, and a clear tim e-line for com p liance was

m a ndated. 51 Therefore, even if a m u ltipollutant st rategy im plem entation causes a large increase in

dem a nd for AC, provided that the tim ing of com p lian ce was clear and far enough in the future, adequate supply of AC should be assured.

EPA estim ated that, of the total 1,300 MW

e to be retrofit by 2020 with ACI, all of that capacity would have existing fabric filters. 36 As m e ntioned before, EPA’s m odeli ng indicates that none of the total MW

e of ACI retrofits will include a PJFF. 36 AC usage nationally for m e rcury control from power plants should be roughly proportional to the total MW

e of coal-fired facilities that are equipped with the technology (this assum es an average capacity factor of 85 percent and other assum p tions of Tables 4-4 and 4-5). Table 6-9 shows the results of this an aly s is. Based upon this analy s is, it is possible that existing excess capacity in AC production could ade quately address the increased dem a nd for AC. And,

even if ACI is m o re broadly used than anticipated by EPA (m ore than 1,300 MW

e ), it is clear that with at least 2-3 y ears of preparation tim e to build m o re production capacity the AC industry can accom m odate

any additional dem a nd.

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52

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The Clear Skies Act is expected to create jobs for those directly involved in the retrofit of facilities.

These have been estim ated in Section 6.2 of this doc um ent. In addition to the jobs that are directly created by this activity , jobs will be created indirectly as a result of the econom ic activity that is

stim ulated by additional discretionary incom e worker s will have. Workers that are directly em ploy ed on these clean air projects will purchase consum er goods and services, which will stim ulate additional

econom ic activity

. To account for these indirect e ffects of econom ic activity , econom ists use econom ic

m

u ltipliers that are related to worker’s m a rginal pr opensity to consum e. Econom ic m u ltipliers of 2 to 3

are often used. 52 Using the lower m u ltiplier of 2 and the total labor estim ates of Table 6-3, 25,000 additional jobs m a y be created through indirect econom ic activity (2 tim es the peak direct labor level of 12,500 workers indicated in Table 6-3). This effect does not consider the additional job-gain potential

from U.S.-based equipm ent suppliers that export to other countries the clean-air technology know-how they will gain from these clean-air program s.

53

## `Ü~éíÉê=T
**`çåÅäìëáçåë**

This report evaluated the resources necessary to co m p ly with the Clear Skies Act for which EPA

estim ated, by using the IPM, the num ber, and size of facilities that will have to install new hardware. The control technologies considered by this report as ca ndidates to be used for this m u ltipollutant control
strategy include:

■ LSFO for the control of SO 2 ;

■ SCR for the control of NO X ; and

■ ACI for the control of m e rcury

.

Based upon the IPM-generated inform ation from EPA and the characteristics of the technologies listed above, the total resources needed to com p ly with the m u ltipollutant control strategy were estim ated and

com p ared to the available resources. The availa bility of resources was based on their current m a rket

dem a nd and does not reflect the increased production capacity that a m u ltipollutant strategy m a y create. It is likely that the m a rket for m a terials, labor, c onstruction equipm ent, and other resources used in the construction and operation of ai r pollution control technologies would respond by increasing production

to m eet dem a nd where needed.

Installation of wet FGD, specifically LSFO, presen ts a conservatively high estim ate of anticipated

resources and tim e to provide additional control of SO 2 em issions. LSFO sy stem s com m only are m o re resource intensive than m a ny other FGD technologies. Conservatively high assum p tions were m a de for

the tim e, labor, reagents, and steel needed to inst all FGD sy stem s. Although FGD installations are tim e and labor intensive, they are ty pically planned and installed within norm a lly scheduled outages. It is expected that one FGD sy stem requires about 27 m onths of total effort for planning, engineering, installation and startup. Modern FGD sy stem s ty pically use fewer and sm aller absorbers and increasingly control greater am ounts of generating capacity using com m on absorbers fed by m u ltiple

boilers. Under the Clear Skies Act, three absorber sy stem s for six boilers are anticipated to handle 2,400

MW

e of capacity . The estim ate of labor includes pla nning and engineering, ge neral labor, and skilled

boilerm akers. Construction of absorbers off-site is one way that projects can control project resources, schedules, and labor.

Steel is the m a jor hardware com ponent for FGD sy stem s. Structural steel is used prim arily for the absorber, ductwork, and supports, and secondarily in m i scellaneous co m ponents including reinforcem ent of existing structures at a facility

. FGD sy stem s are installed on the back end of a facility , are usually built close to the ground, and do not require the am ounts of structural steel generally associated with

elevated installations such as SCR. By com p aris on, the conservative estim ate of the am ount of steel required for a full FGD sy stem is less than or equal to that required for an SCR retrofit. Corrosion and

abrasion resistant m a terials are increasingly bei ng applied with success in m odern FGD sy stem s to
im prove reliability and long-term perform ance. The total dem a nd for additional FGD installations will

be m odest and is expected to be well within the an ticipated steel capacity , even with dem a nds from other applications.

54Construction equipm ent requirem e nts for FGD installati ons are ty pically m odest, particularly given that

sy stem s are installed at the back end of the facility and close to the ground. However, experience has indicated that project planning can surm ount even di fficult situations (e.g., prefabrication and jacking up

com ponents). Experience has also shown that specifi c site issues, while often a planning challenge, have not prevented installations of FGD sy stem s. Mo re recently , space requirem e nts for construction and

accom m odating the FGD sy stem have been addressed with the im plem entation of im provem e nts in technology , including fewer and sm aller absorbers and m o re efficient on-site use and treatm e nt of wastes and by products.

Lim estone was used as an estim ate of reagent for F GD sy stem s. Experience indicates that the quantity of

lim estone is conservatively high com p ared to other enhanced reagents such as fine-ground lim estone and

MEL. Even with the assum p tion that all new FGD capacity will require lim estone, the am ount of

lim estone needed as a reagent is projected to be within availability of supply

.

SCR is the technology that will prim arily be used for NO X control. Since it is also the m o st dem a nding

in term s of resources needed for installation, it was assum e d to be the only technology used for NO X control. SCR sy stem s are prim arily m a de from st eel, standard m echanical hardware, and cataly s t. Conservatively high assum p tions were m a de for steel, cataly s t, reagents, and the labor and equipm ent

necessary to install the sy stem s projected by the IPM that result from a m u ltipollutant control strategy

. The am ount of am m onia or urea reagent needed can be estim ated with good confidence as constituting a

sm all portion of available supply

.

Experience in installing SCRs for the NO X SIP Call has shown that the SCR equipm ent can be installed on the facilities in the space provided. In som e cases, m oving of equipm ent has been necessary

, but this has not proved to be lim iting. The only specialized construction equipm ent that can be useful for SCR installations are tall, heavy

- lift cranes. These appear to be in adequate supply and are not essential, since the erection plan can be m odified to accom m odate th e use of sm aller cranes, which are frequently m o re

econom ical. The only specialized labor necessary for S CR installations are m e m b ers of the boilerm akers trade, and estim ates of boilerm aker dem a nd were m a de

. It is expected that one SCR sy stem requires

about 21 m onths of total effort for planning, engin eering, installation, and start-up. Experience has

shown that m a ny installations have been com p leted in m u ch shorter tim es. Therefore, 21 m onths appears

to be som e what conservative.

ACI was presum e d to be the technology that would be used to reduce m e rcury where dedicated m e rcury controls were needed because the hardware is re presentative of m o st sorbent injection technologies. Also, other sorbent-based approaches in developm ent m a y prove in tim e to be preferable to ACI, m a king the use of ACI only a conservative assum p tion. AC I hardware is com p rised of relatively com m o n

m echanical com ponents and is largely m a de of steel. An ACI sy stem requires m u ch less in term s of steel, labor, or other resources to install than either FGD or SCR technology

. Therefore, the im pact of

ACI hardware on resource dem a nd is m u ch less than that of FGD or SCR technologies for SO 2 or NO X control, respectively

. The only piece of equipm ent of any consequence in term s of size is the storage silo, and this piece of equipm ent is not so large as to pose a problem with regard to location for m o st
facilities. Planning, engineering, installation, and st art-up of an ACI sy stem is only about 15 m onths and

could be done in m u ch less tim e if adm i nistrative m a tters, such as perm itting, occur m o re quickly than

assum e d. Figures for consum ption of AC were based on prior, peer-reviewed EPA work, and conservative operating conditions were assum e d.

In sum m a ry , this study found that the expected dem a nd for resources resulting from a m u ltipollutant control strategy could be m e t. However, the m a rket is expected to adjust to changes in both the dem a nd

for resources under a m u ltipollutant program and other m a rket factors. For this reason, the longer term

55projections are of less value than those for the 2005 and 2010 tim e period. Table 7-1 shows a sum m a ry of resource dem a nd and its effect on current supply

. In Table 7-1 the Supply Basis m a y be current U.S.

dem a nd, capacity available to U.S. users, or other basis as appropriate and described in the table notes. For all resources needed for installation, it is assu m e d that these resources are required over a 31-m onth period prior to 2005 and a three-y ear period prior to 2010, 2015, and 2020. This is a very conservative

assum p tion because the m o st com p lex FGD installati ons will require three y ears while the actual

available tim e to com p lete the projected retrofits for each period, except prior to 2005, is five y ears.

As shown in Table 7-1, there is am ple steel and ge neral construction labor to support the installation of these technologies, assum i ng a 31-m onth period of insta llation prior to 2005 and a three-y ear installation prior to 2010, 2015, and 2020. Moreover, the dem a nd assum p tions do not consider any efficiencies that

can be achieved at m u ltiple unit installations or in stallations of m u ltiple technologies at a site. As

discussed in this docum ent, these e fficiencies can reduce steel requirem e nt som e what and labor needs substantially

. Dem a nd for boilerm aker labor is si gnificant when com p ared to the boilerm aker labor supply basis. However, m o st boilerm akers (60 percen t) work in the electric power industry

, so it should not be surprising that the percentage is high. It s hould also be considered that the value in this table

assum es conservatively high proportion of boilerm aker labor and that the boilerm aker trade grows at its

m i nim u m target rate of 5.3 percent. In fact, the bo ilerm aker trade has been growing at about 6.7 percent annually in recent y ears due to the im proving em ploy m e nt prospects for boilerm akers.

There is also am ple SCR cataly s t capacity to supply this m a rket. SCR cataly s t m a nufacturing is alm o st entirely dedicated to power generating applications. Thus, it should not be surprising that dem a nd for initial fill and periodic replacem ent cataly s t should account for a significant portion of the supply basis. Moreover, the U.S. m a rket for cataly s t is currently la rger than all of the other national m a rkets com b ined. With regard to reagents and other consum ables, cl early there is am ple supply of lim estone for additional FGD sy stem s, especially in light of conservativel y high assum p tions that were used to m a ke these

estim ates. Am m onia and urea supply is also plentiful, although it is expected that NO X reduction will

cause a m odest increase in U.S. dem a nd. In fact, there is currently a worldwide excess capacity problem for suppliers of these com m odity chem icals that ar e traded globally

. Although U.S. dem a nd for activated carbon is expected to increase by a sm all am ount as a result of a m u ltipollutant strategy , activated carbon is traded on a global basis, and there is currently substantial excess capacity that can readily provide for

this increase in dem a nd. Suppliers have also indicat ed that new plants could be brought on line within 3

y ears, if needed, to satisfy increased dem a nd. Additionally , there are other technologies under developm ent that potentially could reduce activat ed carbon dem a nd from what is estim ated here.

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57

## `Ü~éíÉê=U
**oÉÑÉêÉåÅÉë**

1. Personal Com m unication with R. Te lez, Babcock & Wilcox, August 2001.

2. DOE/EPRI: Materials & Com ponents Newsletter, No. 141, August 1, 1999.

3. Personal Com m unication with P. Croteau , Babcock Borsig Power, August 2001.

4. Feeney , S., Gohara, W.F., Telez, R.W., “Bey ond 2000: Wet FGD in the Next Century

, ” ASME

International Joint Power Gene ration Conference, October 1995.

5. Fukasawa, K., “Low Cost, Retrofit FGD Sy stem s,” IEA Coal Research, London England, Septem ber 1997.

6. Personal Com m unication with D. Foerter, Institu te of Clean Air Com p anies, August 28-29, 2001.

7. Wu, Z., “Materials for FGD Sy stem s,” IEA Coal Research, London England, January 2000.

8. Srivastava, R. K., Jozewicz, W., "Controlling SO 2 Em issions: A Review of Technologies,” EPA600/R-00-093 (NTIS PB2002-101224), Research Triangle Park, NC, Decem ber 2000.

9. Personal Com m unication with S.Kum a r, FLS m iljo, Septem ber 2001.

10. U.S. Environm ental Protection Agency , “Feasibility of Installing NO X Control Technologies by May 2003,” Septem ber 1998.

11. Bultm ann, A., Watzold, F., “The Im plem enta tion of National and European Legislation Concerning Air Em issions from Large Com bustion Plants in Germ any , ” UFZ-Centre for

Environm ental Research Leipzig-Halle, August 2000.

12. North Am erican Electric Reliability Council (NERC), “Im p act of FGD Sy stem s: Availability Losses Experienced by Flue Gas Desulfurizati on Sy stem s,” NERC Generating Availability Trend Evaluations Working Group, July 1991.

13. Personal Com m unication with J. Bushm a n, Alstom Power, February 19, 2002.

14. Klingspor, J.S., Brown, G.N., “Techniques for Im proving FGD Sy stem Perform ance to Achieve Ultra-High SO 2 Rem oval Efficiencies,” In the Proceedings of the U.S. EPA-DOE-EPRI

Com b ined Power Plant Air Pollutant Control Sy m posium : The Mega Sy m posium and The A&WMA Specialty Conference on Mercury Em issions: Fate, Effects, and Control, Chicago, IL, August 20-23, 2001.

15. Advanced Flue Gas Desulfurization Dem onstration Project, DOE/NETL project fact sheet, http://www.lanl.gov/projects/cctc/factsheets/puair/adflugasdem o.htm l

16. Feeney , S., Gohara, W.F., Telez, R.W., “Bey ond 2000: Wet FGD in the Next Century

, ” Presented

at the ASME International Joint Po wer Generation Conference, October 1995.

5817. CT-121 Chiy oda Thoroughbred 121 Flue Gas Desulfurization Process, http://www.chiy odacorp.com /select business, environm ental pr eservation, Chiy oda Thoroughbred 121 (CT-121) FGD process

18. Claussen, R. L., Martin, C. E., Sm ith, P. V., Oberjohn, W. J., Weber, G. F., “Engineering and Design Guidelines for Duct Injection Retrofits,” In the Proceedings of the 1993 SO 2 Control Sy m posium

, Boston, MA, 1993.

19. Nischt, W., Woolridge, B., Hines, J., Robison, K., “Selective Cataly tic Reduction Retrofit of a

675 MW

e Boiler at AES Som e rset,” Presented at the ICAC Forum 2000, Washington, DC, March 23-24, 2000.

20. Siem ens, Kat Treff ’97, Washington, D.C. June 3-5, 1997.

21. Personal Com m unication with J. Urb as, Reliant Energy , August 13, 2001.

22. Glaser, R., Licata, A., Robinson, T., “The SCR Retrofit at the Montour Steam Electric Station,”

Electric Power Generation Association M eeting, Hershey

, PA, October 24-25, 2000.

23. Hartenstein, H., Servatius, P., Schluttig, A., "L ifetim e Extension of SCR De-NOx Cataly sts Using SCR-Tech's High Efficiency Ultrasonic Rege neration Process," Presented at the Coal-Gen Conference, Chicago, IL, July 25-27, 2001.

24. Personal Com m unication with M. Gialanella , Ham on Research Cottrell, August 7, 2001.

25. Air Daily , “For Now, Labor Capable of Meeting SCR Dem a nd,” Clear Air Regulations and Markets, Vol. 8, No. 138, July 18, 2001.

26. Personal Com m unication with a utility engineer that asked to rem a in anony m ous, August 6,

2001.

27. Personal Com m unication with J. Bushm a n of Alstom , August 8, 2001.

28. Babb, B., Angelini, E., Pritchard, S., “Im p lem e nt ation of SCR Sy stem at TVA Paradise Unit 2,”

Presented at the ICAC Forum 2000, Washington DC, March 23-24, 2000.

29. Cochran, J., Hellard, D., Rum m e nhohl, V., “Desi gn and Initial Startup Results from the New Madrid SCR Retrofit Project,” Presented at the ICAC Forum 2000, Washington DC, March 23- 24, 2000.

30. Hines, J., Kokkinos, A., Fedock, D., “Design fo r Constructability – A Method for Reducing SCR Project Costs,” In the Proceedings of the U.S. EPA-DOE-EPRI Com b ined Power Plant Air Pollutant Control Sy m posium : The Mega Sy m posium and The A&WMA Specialty Conference on Mercury Em issions: Fate, Effects, and Control, Chicago, IL, August 20-23, 2001.

31. Personal Com m unication with T. Licata, Ba bcock Borsig Power, February 20, 2002.

32. Personal Com m unication with T. Licata, Babcock Borsig Power, August 3, 2001.

33. Personal Com m unication with C. Martin of ADA Environm ental Solutions, August 14, 2001.

34. Personal Com m unication with M. Durham

, ADA Environm ental Solutions, August 3, 2001.

35. E-m a il from Rich Miller, Ham on Research-Cottrell, March 19, 2002.

5936. Personal Com m unication with Chad Whitem a n, U. S. Environm ental Protection Agency , February 22, 2002.

37. Personal Com m unication with John Bushm a n, Alstom , July 10, 2001.

38. Burnett, G., Tonn, D., Redinger, K., Sny d er, R ., Varner, M., “Integrated Environm ental Control

On the 21 st Century ’ s First New Coal-Fired Boiler,” In the Proceedings of the U.S. EPA-DOEEPRI Com b ined Power Plant Air Pollutant Control Sy m posium : The Mega Sy m posium and The A&WMA Specialty Conference on Mercury Em issions: Fate, Effects, and Control, Chicago, IL, August 20-23, 2001.

39. Electricity production, Energy Inform ation Adm i nistration web site http://www.eia.doe.gov/cneaf/electricity /epav1/elecprod.htm l

.

40. Personal Com m unication with Tony Licata, Babcock Borsig Power, February 20, 2002.

41. Bureau of Labor Statistics Website, Industry at a Glance, Construction, http://www.bls.gov/iag/ iag.construction.htm

.

42. “Market Gy rations Make Hitting Targets for Sk illed Crafts an Art”, Power Magazine , vol. 146, no. 1, January /February 2002, pp. 28-32.

43. Hines, J., Jones, W., Wasilewski, K., “Reliant Energy SCR Construction Im plem entation Plan”, presented at ICAC Forum 2002, Houston, February 12-13, 2002.

44. Personal Com m unication with Ande Abbot, Intern ational Brotherhood of Boilerm akers, Iron Ship Builders, Blacksm iths, Forgers and Helpers, February 5, 2002.

45. Personal Com m unication (2) with Ande Abbot, In ternational Brotherhood of Boilerm akers, Iron Ship Builders, Blacksm iths, Forgers and Helpers, February 22, 2002.

46. Institute of Clear Air Com p anies, “Equipm ent Market Forecasts,” Issue Num b er 20, Septem ber

2001.

47. Chem expo.com web site, Novem b er 29, 1999, http://www.chem expo.com / news/newsfram e .cfm ?

fram e body =/news/profile.cfm

.

48. Chem expo.com web site, Decem ber 13, 1999, http://www.chem expo.com / news/newsfram e .cfm ?

fram e body =/news/profile.cfm

.

49. Chem expo.com web site, April 23, 2001, http://www.chem expo.com / news/PROFILE010423.cfm

.

50. Roskill Inform ation Services Website, http://www.roskill.co.uk/acarbon.htm l

51. Personal Com m unication with Bob Thom as, Norit Am ericas, Septem ber 6, 2001.

52. Institute of Clean Air Com p anies, White Paper, Novem b er 2001.

60

## ^ééÉåÇáñ=^

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Exhibit A-1: Single FGD

Exhibit A-2: Three FGD Modules on Six Units Exhibit A-3: Single SCR

Exhibit A-4: Seven SCRs Exhibit A-5: Single ACI

Exhibit A-6: Two ACIs Exhibit A-7: Single FGD and SCR Exhibit A-8: Single FGD and ACI Exhibit A-9: Single SCR and ACI

**iÉÖÉåÇW** Major Task – Dark Gray Subtask – Light Gray Key Completion Point – Black

A- 1A-2Exhibit A-1:SingleFGDMonths12345678910 1112 1314 1516 1718 1920 21 2223 2425 2627FacilityEngineeringReviewandAwardofContractEngineering AssessmentofTechnologiesDevelop and Send Requestfor BidsReceive,Reviewand Negotiate BidsAward ContracttoTechnologyProviderControlTechnologyInstallationEngineering FabricationDeliveryConstruction:Pre HookupConstruction:Control DeviceHookup (Eqmtoutage)ControlTechnology TestingConstruction PermitPermitApplication - Preparation and SubmissionConstructionPermit- State Reviewand DraftProposalConstructionPermit- PublicCommentConstructionPermit- Approval(final)Title VOperating PermitModificationTitleVPermitApplication Preparation and SubmissionTitleVPermitApplication - State ReviewTitleVPermitApplication - PublicCommentInitial ComplianceStackTestingReceiptofTitle VOperating PermitA-3Exhibit A-2:ThreeFGD Modules onSixUnitsMonths123456789101112131415161718192021222324252627282930313233343536FacilityEngineering Reviewand Award ofContractEngineering AssessmentofTechnologiesDevelopand SendRequestfor BidsReceive,ReviewandNegotiateBidsAward Contractto Technology ProviderControl TechnologyInstallationEngineering Fabrication DeliveryModule #1: Construction: Pre HookupModule #1: Construction: Control DeviceHookup (Eqmtoutage)Module #1: Control TechnologyTestingModule #2: Construction: Pre HookupModule #2: Construction: Control DeviceHookup (Eqmtoutage)Module #2: Control TechnologyTestingModule #3: Construction: Pre HookupModule #3: Construction: Control DeviceHookup (Eqmtoutage)Module #3: Control TechnologyTestingConstructionPermitPermitApplication -Preparationand SubmissionStateReviewandDraftProposalPublicCommentApproval(final)TitleVOperating Permit ModificationPreparation andSubmissionState ReviewPublicCommentModule #1: Initial Compliance StackTestingModule #1: Receipt of Title V OperatingPermitModule #2: Initial Compliance StackTestingModule #2: Receipt of Title V OperatingPermitModule #3: Initial Compliance StackTestingModule #3: Receipt of Title V OperatingPermitA-4Exhibit A-3:SingleSCRMonths12345678910 11 1213 1415 16 1718 192021FacilityEngineering Reviewand Award ofContractEngineeringAssessmentofTechnologiesDevelop and SendRequestfor BidsReceive,Reviewand NegotiateBidsAwardContracttoTechnology ProviderControlTechnologyInstallationEngineeringFabrication DeliveryConstruction:PreHookupConstruction:ControlDeviceHookup (Eqmtoutage)ControlTechnologyTestingConstruction PermitPermitApplication - Preparation and SubmissionStateReviewandDraftProposalPublicCommentApproval(final)Title VOperatingPermitModificationPreparation and SubmissionStateReviewPublicCommentInitialComplianceStack TestingReceiptofTitle VOperating PermitA-5Exhibit A-4:Seven SCRs(pg 1 of 2)Months12345678910 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35FacilityEngineering Reviewand Award ofContractEngineering Assessment of TechnologiesDevelopandSendRequest forBidsReceive,ReviewandNegotiate BidsAwardContracttoTechnologyProviderControlTechnologyInstallationEngineering Fabrication DeliveryUnit#1:Construction: Pre HookupUnit#1:Construction:ControlDeviceHookup(Eqmtoutage)Unit#1:Control TechnologyTestingUnit#2:Construction: Pre HookupUnit#2:Construction:ControlDeviceHookup(Eqmtoutage)Unit#2:Control TechnologyTestingUnit#3:Construction: Pre HookupUnit#3:Construction:ControlDeviceHookup(Eqmtoutage)Unit#3:Control TechnologyTestingUnit#4:Construction: Pre HookupUnit#4:Construction:ControlDeviceHookup(Eqmtoutage)Unit#4:Control TechnologyTestingUnit#5:Construction: Pre HookupUnit#5:Construction:ControlDeviceHookup(Eqmtoutage)Unit#5:Control TechnologyTestingUnit#6:Construction: Pre HookupUnit#6:Construction:ControlDeviceHookup(Eqmtoutage)Unit#6:Control TechnologyTestingUnit#7:Construction: Pre HookupUnit#7:Construction:ControlDeviceHookup(Eqmtoutage)Unit#7:Control TechnologyTestingA-6Exhibit A-4: Seven SCRs(pg 2 of 2)1234567891011121314151617181920212223242526272829303132333435Construction PermitPermitApplication - Preparation and SubmissionStateReviewand DraftProposalPublicCommentApproval (final)Title V Operating PermitModificationPreparation and SubmissionStateReviewPublicCommentUnit#1Initial Compliance Stack TestingUnit#1ReceiptofTitleVOperatingPermitUnit#2Initial Compliance Stack TestingUnit#2ReceiptofTitleVOperatingPermitUnit#3Initial Compliance Stack TestingUnit#3ReceiptofTitleVOperatingPermitUnit#4Initial Compliance Stack TestingUnit#4ReceiptofTitleVOperatingPermitUnit#5Initial Compliance Stack TestingUnit#5ReceiptofTitleVOperatingPermitUnit#6Initial Compliance Stack TestingUnit#6ReceiptofTitleVOperatingPermitUnit#7Initial Compliance Stack TestingUnit#7ReceiptofTitleVOperatingPermitMonthsA-7ExhibitA-5:SingleACIMonths123456789101112131415FacilityEngineering Reviewand Award ofContractEngineering AssessmentofTechnologiesDevelop and Send Requestfor BidsReceive,Reviewand NegotiateBidsAward ContracttoTechnology ProviderControlTechnologyInstallationEngineering Fabrication DeliveryConstruction:Pre HookupConstruction:ControlDeviceHookup (Eqmtoutage)ControlTechnology TestingConstruction PermitPermitApplication - Preparation and SubmissionState Reviewand DraftProposalPublicCommentApproval(final)Title VOperatingPermitModificationPreparation and SubmissionState ReviewPublicCommentInitial ComplianceStackTestingReceiptofTitle VOperating PermitA-8Exhibit A-6:TwoACIsMonths12345678910111213141516FacilityEngineeringReviewandAward of ContractEngineeringAssessmentofTechnologiesDevelopand Send Requestfor BidsReceive,ReviewandNegotiate BidsAward ContracttoTechnology ProviderControlTechnologyInstallationEngineering FabricationDeliveryUnit#1:Construction:PreHookupUnit#1:Construction:ControlDeviceHookup(Eqmtoutage)Unit#1:ControlTechnologyTestingUnit#2:Construction:PreHookupUnit#2:Construction:ControlDeviceHookup(Eqmtoutage)Unit#2:ControlTechnologyTestingConstructionPermitPermitApplication - Preparation andSubmissionStateReviewand DraftProposalPublicCommentApproval(final)TitleVOperatingPermitModificationPreparation andSubmissionStateReviewPublicCommentUnit #1Initial ComplianceStack TestingUnit#1 ReceiptofTitleVOperating PermitUnit #2Initial ComplianceStack TestingUnit#2ReceiptofTitleVOperatingPermitA-9Exhibit A-7:SingleFGDandSCRMonths123456789101112131415161718192021222324252627FacilityEngineering Reviewand Award ofContractEngineeringAssessmentofTechnologiesDevelop andSendRequestforBidsReceive,ReviewandNegotiateBidsAward Contractto TechnologyProviderControl TechnologyInstallationEngineering FabricationDeliveryConstruction:PreHookupConstruction:ControlDeviceHookup(Eqmtoutage)ControlTechnology TestingConstructionPermitPermitApplication- Preparationand SubmissionState ReviewandDraftProposalPublic CommentApproval(final)Title VOperating PermitModificationPreparation andSubmissionStateReviewPublic CommentInitialComplianceStack TestingReceiptofTitleVOperating PermitA-10ExhibitA-8:SingleFGDand ACIMonths123456789101112131415161718192021222324252627FacilityEngineeringReviewandAwardofContractEngineering AssessmentofTechnologiesDevelopand Send RequestforBidsReceive,ReviewandNegotiateBidsAward ContracttoTechnologyProviderControlTechnologyInstallationEngineeringFabrication DeliveryConstruction:Pre HookupConstruction:ControlDeviceHookup (Eqmtoutage)ControlTechnologyTestingConstruction PermitPermitApplication- Preparationand SubmissionState ReviewandDraftProposalPublicCommentApproval(final)Title VOperatingPermitModificationPreparation andSubmissionState ReviewPublicCommentInitial ComplianceStackTestingReceiptofTitleVOperatingPermitA-11ExhibitA-9:SingleSCR and ACIMonths123456789101112131415161718192021FacilityEngineering ReviewandAward ofContractEngineeringAssessmentofTechnologiesDevelop and SendRequestfor BidsReceive,ReviewandNegotiateBidsAward ContracttoTechnologyProviderControl TechnologyInstallationEngineering FabricationDeliveryConstruction:PreHookupConstruction:Control DeviceHookup (Eqmtoutage)Control TechnologyTestingConstructionPermitPermitApplication- Preparationand SubmissionState ReviewandDraftProposalPublic CommentApproval(final)TitleVOperating PermitModificationPreparation and SubmissionState ReviewPublic CommentInitial ComplianceStackTestingReceiptofTitleVOperating Permit