1 

# An Assessment of the Feasibility of Retrofits for the Toxics Rule

U.S. Environmental Protection Agency Office of Air and Radiation

March 9 , 20112 Abbreviations and Glossary

ACI Activated Carbon Injection

– controls mercury APC Air Pollution Control(s)

– ACI, DSI, etc CAIR Clean Air Interstate Rule DSI Dry Sorbent Injection

– controls acid gasses FF Fabric Filter (baghouse)

– controls particulates FGD Flue Gas Desulfurization

– controls acid gasses GW Gigawatt(s)

– one thou sand MW GWeq GW(s) of WetFGDeq HAPS Hazardous Air Pollutants IPM Integrated Planning Model MW Megawatt(s)

– one million watts (1000 kilowatts) NEEDS National Electric Energy Data System SCR Selective Catalytic Reduction

– controls nitrogen oxides WetF GDeq Wet FGD equivalent

- The amount of an APC technology expressed as its GW equivalent in wet FGD technology3 

## An Assessment of the Feasibility of Retrofits for the Toxics Rule

PREFACE
This paper summarizes an EPA assessment of the feasibility of retrofitting various air pollution control ( APC ) technologies to many coal

- fired power plant units in the U.S. for the Toxics Rule

. The retrofitting program will be needed for power sector compliance with EPA’s proposed Toxics Rule. Following are key dates associated with the Rule:

**•** March 2011

– Proposal

**•** November 2011

– Final

**•** January 2015

– Statutory Compliance Deadline

**•** January 2016

– Compliance Deadline with extension from permitting authorities

EPA has projected the quantity of each APC technology that may need to be newly retrofitted and in service by the compliance date(s). EPA used the latest version of its IPM model to analyze which APC technologies would likely be used, and in w hat quantities, to achieve compliance with the proposed Toxics Rule.

Result: EPA’s assessment shows that a reasonable, moderately paced effort of the power sector and supporting industry , including some early starts, would result in many of the needed re trofits being installed by January 2015 with some needing up to an additional year. In order for all retrofits to be completed by January 2015, most projects would have to start early and the s ector would have to engage in a more aggressive deployment program. In the event that individual projects cannot be completed by the January 2015 statutory deadline for compliance, the Clean Air Act offers affected sources the opportunity to apply for a one

- year extension.

ANALYTICAL APPROACH

S ite

- specific feasibi lity studies are typically performed before owners commit to an APC retrofit plan for a unit or plant . However, an assessment of the feasibility of retrofitting a sector

- wide aggregation of APC systems to achieve timely compliance with the proposed Toxics Rule on a national scale cannot replicate the same level of detailed analysis of either specific plants or of individual components of the APC “supply chain.” Various detailed analyses of the supply chain have been conducted for past rules, usually resulti ng in a significant underestimate of what was ultimately achieved in practice 1

. Aside from the difficulties of making detailed “bottom

- up” analyses of either plants or supply chains on a national scale, such analyses miss the mark4 because no single planne r can be responsible for the strategies of competitive participants in the supply chain, much less for owner compliance strategies at all affected units

. I n reality, the sector will benefit from the creative interaction of a multitude of actors in the mar ketplace developing routes to compliance. For the purposes of this proposed Rule, this assessment adopts a broad

- scale, order

- of

- magnitude estimate of what appears reasonably feasible nationwide based on the pattern of power sector deployment activity in the recent past. EPA recognizes that a wide range of site

- specific conditions will result in a range of “better

- than

- average” and “worse

- than

average” project outcomes as regards cost and schedule. In developing a broad

- scale estimate, the influence of dif ferences in local factors and in past, current, and future circumstances has been considered at an appropriate level of detail.

RECENTLY DEMONSTRATE D DEPLOYMENT CAPABIL ITIES OF THE APC SUPPLY CHAIN
Annual GW capacity additions are plotted in Figure 1 for the two most resource intensive APC systems: flue gas desulfurization ( FGD ) and selective catalytic reduction ( SCR ) . Figure 1 data reflect the year that systems went into service. These data are from the National Electric Energy Data System ( NEEDS ) 2

Figure 1: FGD, SCR, and Coal Plant Annual GW Additions, New and Retrofit , as provided by plant owners and updated by EPA. They include both retrofitted APC and systems installed as part of new coal plant construction. The FGD component is a sum of wet and dry FGD technologies. Dry FGD comprises about 12% of total 1990

- 2011 FGD additions. Annual installations of new coal

- fired power plant capacity are also plotted to indicate the size of its role in contributing to APC additions. Although there have been no new coal power projects ordered in the past two years, several are still in construction. The supply chain for coal power plants is thus an active and applicable set of resources (including engineers, manufacturers, fabrication shops, craft labor, construction managers, etc.) that could be tapped to rapidly enlarge the APC sup ply chain.

Source: EPA, NEEDSv4.10PTR 0.0 10.0 20.0 30.0 40.0 SCR, GW FGD, GW New Coal, GW5 The large, rather abrupt peaks in annual SCR additions (2000 and 2003) for compliance with the NOx SIP Call are apparent in Figure 1. A more gradual build up to the historic 2009 peak for annual FGD additions in anticipation of the Clean Air Interstate Rule ( CAIR ) is also apparent. These data depict a recent major ramp

- up in the APC deployment capabilities of all industry participant s, includin g plant owners, the APC supply chain, and state and local permitting agencies. These expanded APC capabilities are still active today, even if not fully utilized. EPA believes that in today’s post

- recession economy it is reasonable to expect that these exp erienced capabilities can be quickly re

- engaged, can quickly return to production at historic rates, and can be quickly augmented by additional available resources to increase production rates beyond historic levels.

RETROFIT PROJECTIONS FOR TOXICS RULE

Ta ble 1 shows the types and quantities of APC retrofits that EPA has projected the sector to adopt for Toxics Rule compliance. 3

Table 1: Toxics Rule Retrofit Technologies and GW Capacity required by 2015 for Coal

- fired Units “Retrofit GW” refers to the total generating capacity of coal

- fired units that are projected to receive each APC technology. For example, the table shows that the Rule may require the retrofitting of dry FGD systems to 2 4 GW of coal

- fired generating capaci ty. A sum of the Retrofit GW capacities across the categories in Table 1 would be greater than the amount of generating capacity affected by retrofits because many generating units will receive more than one APC technology.

APC Technology Wet FGD Dry FGD (with FF * ) SCR FF DSI (T rona, etc) ACI

Retrofit GW 0 2 4 3 1 4 3 5 6 9 3 Source: EPA, derived from IPMv4.10 PTR * Note: 2 4 GW of FF included with DryFGD is in addition to the 1 43 GW of stand

- alone FF At any particular coal

- fired power plant it is possible that none or several of these APC technologies might be retrofitted for Toxics Rule compliance. Depending on the plant, they might be retrofitted to each individual unit, or some to one unit but not others, and some might be sized to serve multiple units at a plant. Under the Toxics Rule proposal, plant operators have the flexibility to design for plant

- wide compliance with the rule’s emission rates, rather than requiring each unit to meet the specified standards exactly, which further increases the likely diversity of compliance strategies that may reduce cost and time for implementation. These and many other site

- and owner

- specific factors that cann ot be fully considered in IPM modeling would influence plant owner decisions on how to apply any of these systems on individual units. Therefore, although IPM projections based on “model plants” have proven to be excellent predictors of economic technology deployments on a state

- wide, regional, and national basis, they are not intended and should not be interpreted as authoritative projections for any single plant or unit.6 METRIC FOR TOTAL RET ROFIT DEPLOYMENTS (G W WetFGDeq)

EPA has adopted a single metric to represent all APC technologies in this analysis. Use of a single metric facilitates an extrapolation of historic deployment rate data for wet and dry FGD and SCR to assess feasible future deployment rates needed for the retrofit technologies projected f

or the Toxics Rule. Such a single metric permits assess ment of the overall combined feasibility of all APC retrofits projected

. This metric should be regarded as “average,” not capturing the specifics of any particular site, but representing average diffic ulty across many projects.
As shown in Table 2, EPA converted the projected Retrofit GW capacities of each technology from Table 1 into an “equivalent wet FGD capacity” (WetFGDeq). The total ( 7 0 GW WetFGDeq) is the future APC deployment goal for this retro fit feasibility analysis. One example of this conversion is that retrofitting 2 4 GW of dry FGD systems is considered roughly equivalent in terms of cost and resources to the retrofitting of 19 GW of wet FGD systems.

The e quivalence factor s are computed as the ratio of the capital cost of each technology to that of a wet FGD system . Capital cost includes the installed and commissioned retrofit project elements (engineering, equipment, construction labor, project management, etc.), excluding only financing

c osts and owner’s “home office” costs. The capital costs are derived from IPMv4.10 PTR technology assumptions for single

- unit systems

. Table 2: Toxics Rule Retrofit Technologies and GW WetFGDeq Capacity

Source: EPA Note: Some values may not add exactly due to rounding. WetFGDeq values are intended to approximately represent the relative GWeq capacity, capital cost, and supply chain deployment resources associated with APC technologies individually and in total, on the basis of current market cond itions . They do not directly represent the relative calendar times required to install individual technologies. Wet FGD was selected as the “base” technology for this metric because it has been widely deployed, is f amiliar to the industry , has the highest capital cost, uses the most supply chain resources, and requires the longest schedule for deployment. Use of the single WetFG Deq metric is intended to allow industry to more readily visualize and consider a complex set of relationships among many factors ( including site conditions, APC designs, and supply chains ), and to consider the aggregate level of effort projected for the sector to reach overall Toxics Rule compliance

.

APC Technology Retrofit GW Equivalence Factor WetFGDeq GW Wet FGD 0 1 0 Dry FGD 24 0.8 19 SCR 3 0.4 1 FF 143 0.3 43 DSI (trona, etc) 56 0.1 6 ACI 93 0.02 2 Total 707 TRENDS IN TOTAL RETR OFIT DEPLOYMENT EFFO RT (GW WetFGDeq)
Figure 2 shows the total a nnual historical APC additions from Figure 1 and current APC commitments for the future using the WetFGDeq metric. Figure 2 reveals the pattern of retrofit deployment driven solely by CAIR, showing separately the WetFGDeq of APC capacity installed for other reasons. Note that the retrofit capacity depicted as “ other ” in Figure 2 has separately identified drivers, but the portion deployed inside the CAIR region may have been timed in coordination with that rule. Figures 1 and 2 both demonstrate the sector’s early deployment of APC controls in advance of CAIR compliance deadlines of 2009 for NO x and 2010 for SO 2 . Solely CAIR

- driven APC deployments of about 13 GW WetFGDeq occurred within two and a half years after CAIR’s fina lization in mid

- 2005, showing that at least 40 % of total CAIR

- only APC effort through 20 10 was sufficiently planned for installation to start before or immediately upon finalization of the rule

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

Source: EPA (NEEDS) through 2011; Data beyond 2011 d erived with permission from IHS CERA "Announced Environmental Retrofit Project Database: November 2010 Update."
ADDITIONAL SUPPLY CHAIN RESOURCES
EPA estimates that on a GWeq basis, a new coal

- fired plant would have at least 5 times more resources involved than a new retrofit wet FGD system. This is illustrated in Figure 3, which is similar to Figure 2 except that the actual GW values for New Coal h ave been converted to GW WetFGDeq. The comparable GWeq values indicate that there may now be as many underutilized and potentially available New Coal resources as were being used in the APC supply chain at its peak. The currently available APC resource poo l might thus be up to twice as large as would otherwise be expected, and well able to support a major ramp

- up of its deployment capabilities.
Although not quantified here, there is a similar, available, and to some extent transferrable resource pool that has until recently been supporting large annual deployments of the gas turbine 0.0 10.0 20.0 30.0 40.0 APC CAIR only, GW WetFGDeq APC other, GW WetFGDeq New Coal, GW8 combined

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

- cycle capacity additions of 7 GW (actual) in 2009, 3 GW in 2010, and 7 GW for 2011.
Figure 3: Histori cal / Projected APC and New Coal Annual Additions

Source: EPA
SCHEDULE OUTLOOK FOR RETROFIT INSTALLATIO NS
APC Retrofit Planning EPA thinks it likely that the majority of coal

- fired power plant owners performed site

- specific APC retrofit studies sometime prior to or in the seven years since CAIR was proposed in 2004. CAIR is still in effect and the proposed Transport Rule continues to focus the industry on retrofit planning . All owners have long been aware that a Toxics Rule would be forthcoming and that it would have a congressionally mandated January 2015 compliance date. EPA therefore expects that many owners have already determined which of their units would eventually get some combination of APC systems

. Such existing preparatory work should make it possible for many owners to quickly take steps toward making commitments for these systems.
Early Movers CAIR was proposed in early 2 004 and finalized in mid

- 2005. It established compliance dates in 2009 for NO x and 2010 for SO 2 . As discussed above, Figures 1 and 2 show that a significant fraction of “early mover” plant owners must have done their planning and made commitments well in a dvance of the CAIR final rule date . Southern Company’s early 2003 commitment to a large program of APC retrofits, well in advance of CAIR’s finalization, is one example of an “early mover” making major early APC deployment decisions, leading to 8000 MW of installed wet FGD systems on 14 units

. 4 0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 APC, GW WetFGDeq New Coal, GW WetFGDeq

Subsequent commitments from many more owners encouraged a continuing expansion of the supply chain, with further increases in annual deployments. EPA anticipates that this pattern will be repeated for the Toxics Rule. “ E arly movers” making commitments in advance of the Rule are better positioned to avoid any potential increase in APC system costs when the supply chain ramps up to deploy a new peak in retrofit installations in a short pe riod of time

. EPA clearly saw this early mover advantage occur with9 CAIR, and e arly movers may have already triggered the beginning of a major new ramp

- up of the APC supply chain for the Toxics Rule

. Benchmark ing to a New Coal Plant Schedule A ctual sched ule durations for APC retrofits ha ve varied widely from plant to plant , as will be discussed later. There are many reasons for such variability, and for the fact that some retrofit projects apparently had lengthy schedules of 4 years

or more. EPA believes that almost all future APC retrofits can be completed far more quickly than were historical APC projects. EPA’s perspective on this matter derives in part from a comparison of past APC schedules to the project schedule for an entire new coal

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

- fired unit that became operational in July 2006, some 33 months after the turnkey engineering

- construction contractor was given a notice to proceed with engineering. 5

Retrofit Project Schedules The recently surveyed wet FGD project schedules shown in Table 3
are not all representative of the shorter project schedules that EPA expects to be prevalent under the Toxics Rule. Some of these projects were conducted in a period of regulatory uncertainty without a strong driver for accelerated retrofit com pletion, tie

- in, and subsequent operation

– particularly where initiating such operation increases marginal operating costs without a certain regulatory benefit. Factors that will likely accelerate project schedules under the Toxics Rule include the use o f overtime and/or two

- shift work schedules during construction, and 5

- or 6

- day work weeks, instead of the 4

- day x10

- hr schedules often used to minimize cost when time is not of the essence . Increased use of offsite modularization and pre

- fabrication of AP C components can also shorten schedules and reduce job hours. Also, m any of the wet FGD projects performed in response to CAIR or to other legal actions in the same time frame took longer to perform than under normal market conditions due to the initial high demand for a large number of complex wet FGD systems in a short period of time. Extended lead times in the 2007/2008 time period, as high as 18 months for key wet FGD engineered equipment ( such as large recycle pumps, large motors, and chimneys ) cont ributed to extended wet FGD project duration s. I ncreased lead times quickly subsided as the supply chain processed the initial influx of orders f or this equipment. Neither the proposed Transport Rule nor the Toxics Rule, however, as shown in Table 1, is pr ojected to require a significant number of large, complex wet FGD systems. The relatively much simpler dry FGD, fabric filter, and other even simpler dry sorbent injection ( DSI ) and ACI systems that may be required under the Toxics rule will take significa ntly less time to plan, design, install, and commission than wet FGDs. Springerville was clearly on an accelerated schedule, as its original planned schedule was about 38 months . The main point here is that typical schedules for large complex power projects can be significantly accelerated. Because t he scope of the work invol ved for an entire new coal unit is at least five times that of a retrofit wet FGD system, EPA believes that even the most complex retrofit APC project can be significantly accelerated as well. EPA therefore also believes that its schedule assumptions used in the Transport Rule proposal, 27 months for retrofitted wet FGD and 21 months for dry FGD, remain reasonable expectations for both the Transport Rule and the Toxics Rule.10 Table 3: Recent Wet FGD Project Deployment Schedules Wet FGD Projects Schedules (without planning) 1 3 26

– 35 months 8 37

– 5 2 months Source: EPA (see Appendix A) Motivation for Toxics Rule Compliance There is a notable difference between CAIR and the Toxics Rule as regards incentives for plant owners to be early movers

- making retrofit commitments in advance of the final rule date. CAIR included provisions for th e banking and trading of emission allowances, and thus offered unit owners the flexibility to deliberate over time varying compliance strategies that could be offset by allowance purchases if eventual emissions exceeded allowance allocations to that unit. The Toxics Rule , on the other hand, does not offer trading flexibility and requires plant

- level compliance as soon as the regulatory period begins

. Compliance planning under the Toxics Rule will involve assessment of the long

- term differences between the costs of keeping in service an existing unit with newly retrofitted controls and the costs of building and operating a new generating unit that complies. In some

cases , it may be possible for owners to delay a retrofit decision until after the Toxics Rule is final and still be able to make the necessary deployments in good time. In some other cases, however, any delay in making a retrofit commitment may compromise a unit’s ability to meet the statutory Toxics Rule compliance deadline. Therefore, the ration al expectation should be that affected unit owners would be more motivated to move early on retrofit planning decisions in advance of the Toxics Rule than they were to anticipate actions under previous trading

- based regulations. Ultimately, affected plant owners should already be factoring in the risk of noncompliance with the Toxics Rule as they plan the futures of their coal units.

DEVELOPMENT OF APC D EPLOYMENT SCENARIOS
Current Supply Chain Activity Current activity levels for various participants in t he supply chain depend on when their particular activity (engineering, manufacturing, fabrication, construction, etc) occurs in an APC project schedule. As shown in Figure 3, the deployment rate is currently in a second year of decline . Therefore, the acti vity level of front

- end engineering and shop fabrication resources has by now decreased more than that of construction resources (relatively), and both have decreased very significantly. Overall, the current activity level of front

- end resources is support ing committed projects that will likely come on

- line in the 2013

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

. Not shown in Figure 3 are any additional deployments that may be made by 2014 in response to EPA’s proposed Transport Rule. As of early March 2011, EPA’s ongoing analysis as part of finalizing the Transport Rule indicates that the projected amount of add itional APC deployments for that rule will not adversely impact th e feasibility of retrofits for the Toxics Rule

. Moderate Future Deployment Historical peak annual APC deployments were nearly 30 GW WetFGDeq in 2009. Average year

- on

- year growth in annual d eployments over the 3

- year period from 2006 to the peak in 2009 was 45%. A renewed ramp

- up in deployment capability starting in11 early 2011 would be starting from roughly the same reduced level of activity that preceded the sustained ramp

- up for CAIR

. With these observations EPA developed a “moderate” APC deployment scenario, as follows (see Table 4):

**•** W ithin three years (by early 2014) a moderate effort by the supply chain could put in service APC retrofits of at least 20 GW WetFGDeq. This is significantly less than the nearly 30 GWeq deployed in a similar time frame under CAIR. This initializing assumption is supported by EPA engineering staff interaction with the supply chain community and informal appraisals of the current activity and preparedness of the sector. Th e starting point assumption directly influences the computation of what proportion of retrofit effort is "on time" in 2015 and what proportion is "late" and would require the

one

- year extension to January 2016. This Moderate scenario expresses EPA’s current expectation of what is reasonably achievable while recognizing that there is no definitive way to project how many controls will be on time and how many will require the extension. Completion of this scenario by 2016 seems a reasonable expec tation since the Toxics Rule is not projected to require use of wet FGD, the most time

- and resource

consuming APC technology. Note that although this WetFGDeq analytical concept appears to suggest that nothing is deployed until 2014 ; in reality there woul d likely be deployed increasing amounts of DSI, activated carbon injection ( ACI ) , and fabric filter ( FF ) technology starting in the earliest years, 2012 and 2013, and continuing throughout the program. Dry FGD retrofits could begin coming online sometime in 2013.

**•** With further deployment growth at the 3

- year average 45% annual growth rate previously witnessed in the ramp

- up for CAIR, an additional 28 GWeq can be deployed by early 2015 , making a cumulative deployment of 48 GWeq. A further 2 2 GWeq is completed by January 2016, thus meeting the Toxics Rule cumulative goal of 7 0 GW WetFGDeq.

EPA views this moder ate 5

- year ramp

- up as a reasonable and achievable deployment scenario
, without anticipating that the sector may find more productive routes to effective and efficient compliance not yet reflected in the historic record

.12 Table 4: APC Deployment Scenarios, Cumulative GW WetFGDeq

Source: EPA
The relative magnitudes of past and projected annual APC and New Coal deployments are depicted in Figure 4, where the incremental GWeq of APC for the Toxics Rule under a moderate 5

- year ramp

- up are added to projected APC deployments without the Rule. This visual representation of the relative magnitudes of the resources involved supports the reasonableness of EPA ’ s expectation that timel y compliance is achievable in this moderate ly paced scenario

. Figure 4: Online Year for Toxics Rule APC Annual Additions in 5

- Year Ramp

- up Scenario

Source: EPA

More Aggressive Future Deployment It is conceivable that the supply chain could begin immediately to ramp up its capabilities over three years to the same peak deployment rate achieved for CAIR, and to continue ramping up at an aggressive pace through a final year of APC deployments. Con ceivably, it would not “throttle back” its resource growth; it would tap all available sources until all resources that are needed are in place to produce 7 0 GW WetFGDeq of deployments by early 2015. Under this more aggressive 4

- year ramp

- up scenario, 28 G Weq

c ould be in service by early 2014 (40% more than in the moderate scenario, but about equal to the CAIR peak), with an additional 4 2 GWeq placed into service by early 2015 ( 5 0 % more than the previous year). Cumulative GW WetFGDeq Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16

5-year ramp-up 20 48 70

4-year ramp-up 28 70 Moderate-paced increase in

resources Aggressive increase in

resource s

0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 New Coal, GW WetFGDeq Toxics Rule APC, GW WetFGDeq APC, GW WetFGDeq13 EFFECT OF RETROFIT UNIT SIZES
It is useful to consider whether a difference in the past and future average size of the units involved, and thereby a difference in the number of unique units or projects involved, might significantly affect the feasibility results. NEEDS data indicate th at the peak APC deployment of 38 actual GW in 2009 (Figure 1) involved a peak of 66 unique units. The average size unit built anew or retrofitted in 2009 with APC systems was therefore about 575 MW. Not all of those units were managed as unique projects, a s some were part of continuing multi

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

EPA projects that the future average unit size retrofitted for the Toxics Rule will be about 300 MW . However, that does not necessarily mean that there will be proportionately more APC projects to be managed simultaneously

. T he limited time for compliance will likely necessitate parallel retrofitting activities at many multi

- unit plants, with such plant

- wide effor ts managed most efficiently as single projects. Furthermore, with smaller average unit sizes being retrofitted in the future, there will likely be many plants (projects) where multiple smaller units share an APC system. Although it is not possible to accur ately predict the future numbers of APC systems that will be uniquely deployed to single units, or to multiple units, it is clear that the sharing of APC systems by multiple smaller units, done to minimize resource needs and capital cost, could significant ly limit the number of APC systems and projects involved. Shared APC systems will allow the overall effort to be more manageable than otherwise, and should require relatively fewer supply chain resources.
A higher number of projects might be expected to i mpact project management and supervisory labor to some greater degree than craft labor. However, many of the projects will be installing fabric filters and less complex technologies
, any of which are far less complex than the wet FGD systems installed for CAIR . They will entail far fewer co mponent suppliers, less process

e ngineering effort
, fewer technical specifications, etc. A typical fabric filter project is therefore far less difficult to manage or supervise than a typical wet scrubber project. Likewise they are easier to construct and will require relatively less craft labor. Thus, a lthough there may be more APC projects, they will be far easier to manage, and should require relatively fewer skilled personnel than CAIR experience and the WetFGDeq metric might suggest.
Referring again to Figure 4, EPA expects that the combined underutilized resources for the APC and New Coal supply chains, possibly supplemented with underutilized resources from the gas combined

- cycle business line, will be adequate to s upport a moderately paced APC deployment scenario.14 Appendix - Wet FGD Retrofit Timelines

Plant Name Unit ID Capacity (MW) PROJ START (CAMD findings) PROJ FINISH (CAMD Findings) PROJ Duration (months) Reference CAMD SO 2 Control Start

Date
Asheville 1 191 Sep-03 Nov-05 26 (web site: http://www.powergenworldwide.com/index/display/articledisplay/277709/articles/powerengineering/-/2006/11/best-coal-fired-projects.html) Construction start Sept 2003. Unit #1 complete Nov 2005; unit #2 complete 2006. Detail design to Start-up: 26 months. (web site: http://progressenergy.com/aboutus/news/article.asp?id=1428 2 ) unit 2 on-line May 25, 2006; unit #1 on-line Nov 2005. 11/6/2005

Killen Station 2 615 Mar-05 Jun-07 28 (web site: http://www.bv.com/News_3_Publications/News_Releases/2005/0503.aspx) B&V announcement - alliance w DP&L for Killen & Stuart stations to utilize scrubber tecnology - May 3, 2005 . (web site: http://www.thefreelibrary.com/Black+%26+Veatch%27s+Largest+CT-121+Scrubber+Project+in+North+America+...- a0166786209) B&V start-up of a CT-121 WFGD for Killen unit#2 - July 25, 2007

. 5/24/2007

Brandon Shores 1 643 Jun-07 Dec-09 29 (web site: http://www.highbeam.com/doc/1G1-165318616.html) Construction start June 20, 2007 . (web site: http://www.constellation.com/vcmfiles/Constellation/Files/scrubber_factsheet.pdf) Unit#1 connected Dec 2009; unit #2 connected Mar 2010. 11/21/2009

Crist 7 472 May-07 Jan-10 32 (web site: http://www.bv.com/wcm/press_release/05072007_1374.aspx) B&V selected by Gulf Pwr Comp to provide EPC for CT-121 WFGD at Plant Crist station; all units will be scrubbed; unit 4,5,6,7 - announ May 7, 2007

. NOTE: use CAMD SO2 control start date 1/1/2010

Brandon Shores 2 643 Jun-07 Mar-10 32 (web site: http://www.highbeam.com/doc/1G1-165318616.html) Construction start June 20, 2007. (web site: http://www.constellation.com/vcmfiles/Constellation/Files/scrubber_factsheet.pdf) Unit#1 connected Dec 2009; unit #2 connected Mar 2010. 1/1/2010

Asheville 2 185 Sep-03 May-06 33 (web site: http://www.powergenworldwide.com/index/display/articledisplay/277709/articles/powerengineering/-/2006/11/best-coal-fired-projects.html) construction start Sept 2003; unit#1 complete Nov 2005; unit #2 complete 2006. Detail design to Start-up: 26 months. (web site: http://progressenergy.com/aboutus/news/article.asp?id=142 82 ) unit 2 on-line May 25, 2006; unit #1 on-line Nov 2005. Wansley 1 891 Jan-06 Oct-08 33 (web site: http://www.times-herald.com/Local/Scrubber-project-planned-at-Yates-596100) Wansley constrction begin - Jan 2006

. (Meag Power Current vol.2: issue 1, 2009) Wansley unit 1 scrubber completed Oct 2008; unit #2 by next mid april). 10/1/2008

Mitchell 2 800 Mar-04 Jan-07 34 (web site: http://www.babcock.com/library/pdf/pch570.pdf) per B&W: Project award mar 2004; unit 2 operational Jan 07, unit 1 operational Apr 07. 2x800 Mw units 1/15/2007

Warrick 2 136 Jul-05 May-08 34 (web site: http://www.thefreelibrary.com/Alcoa+Investing+%24375+Million+for+Warrick%2c+IN+Facilitiesa0134312217) Alcoa announces investment in WFGDs for Warrick July 22, 2005 . (web site: https://www.alcoa.com/locations/usa_warrick/en/info_page/power_plant.asp) Dec 2008, all 4 units completed - WFGD'd installed - final scrubber installed in Dec 2008; project start 2005. (web site: https://www.insideindianabusiness.com/newsitem.asp?ID=29541) the first scrubber went on-line 5/27/2008

. (web site: http://www.alcoa.com/locations/usa_warrick/en/news/newsletters/june08.asp#0) Unit #2 identified. 4/12/2008

Fort Martin Power Station 1 552 Mar-07 Feb-10 35 (web site: http://findarticles.com/p/articles/mi_m0EIN/is_2007_March_15/ai_n27304049/) Allegheny Pwr announces EPC contract w WGI for scrubber at Fort-Martin station - March 15, 2007 . (web site: http://newsblaze.com/story/2010020408561700001.bw/topstory.html) Allegheny Pwr announce completion of scrubber project for Fort Martin station - Feb 04, 2010

. 10/31/2009

Fort Martin Power Station 2 555 Mar-07 Feb-10 35 (web site: http://findarticles.com/p/articles/mi_m0EIN/is_2007_March_15/ai_n27304049/) Allegheny Pwr announces EPC contract w WGI for scrubber at Fort-Martin station - March 15, 2007 . (web site: http://newsblaze.com/story/2010020408561700001.bw/topstory.html) Allegheny Pwr announce completion of scrubber project for Fort Martin station - Feb 04, 2010

. 8/26/2009

Miami Fort 7 500 Jun-04 Apr-07 35 (web site: http://www.mcilvainecompany.com/utility/subscriber/DefaultOLD.htm) McIlvaine #821 (4/27/2007) Miami-Fort unit #7 WFGD operating; (personal note: worked on proj, proj start June 2004) 4/1/2007

Monroe 4 775 Jul-06 Jun-09 35 (web site: http://www.redorbit.com/news/business/560181/washington_group_international_to_retrofit_scrubbers_at_det roit_edison_power/index.html) WGI selected to provide EPC for WFGD's on Monroe units 3&4 - 5 july 2006. (web site: http://www.tradingmarkets.com/.site/news/Stock%20News/2657108/) Monroe unit #4 WFGD operational June 2009

. note: scrubber is a ceramic vessel (tile w concrete). 5/4/2009

Clay Boswell 3 351 Feb-07 Mar-10 37 (web site: http://www.redorbit.com/news/business/840682/minnesota_power_awards_boswell_energy_center_retrofit_co ntract/index.html); Award 14 Feb 2007. (http://hamon-researchcottrell.com/news_20100601) Completed Mar 2010 10/30/2009

Mitchell 1 800 Mar-04 Apr-07 37 (web site: http://www.babcock.com/library/pdf/pch570.pdf) per B&W: Project award mar 2004; unit 2 operational Jan 07, unit 1 operational Apr 07 . Two 800 MW units. 1/1/2007

Warrick 1 136 Jul-05 Oct-08 39 (web site: http://www.thefreelibrary.com/Alcoa+Investing+%24375+Million+for+Warrick%2c+IN+Facilitiesa0134312217) Alcoa announces investment in WFGDs for Warrick July 22, 2005

. (use CAMD SO2 control start date) 10/15/2008

Wansley 2 892 Jan-06 Apr-09 39 (web site: http://www.times-herald.com/Local/Scrubber-project-planned-at-Yates-596100) Wansley constrction begin - Jan 2006

. (use CAMD SO2 control start date) 4/1/2009

Bowen 3BLR 902 Jan-05 May-08 40 (web site: http://findarticles.com/p/articles/mi_m0EIN/is_2005_May_2/ai_n13664268/) scrubber contract signed Jan 2005 - Chiyoda JBR. (http://www.georgiapower.com/environment/air_quality.asp) Bowen scrubber commercial operating May 2008

. 1/1/2008

Monroe 3 795 Jul-06 Nov-09 41 (web site: http://www.redorbit.com/news/business/560181/washington_group_international_to_retrofit_scrubbers_at_det roit_edison_power/index.html) WGI selected to provide EPC for WFGD's on Monroe units 3&4 - 5 july 2006; (web site: http://www.tradingmarkets.com/.site/news/Stock%20News/2657108/) unit #3 WFGD operational 16 Nov 2009. note - ceramic wfgd vessel (tile w concrete). 11/1/2009

E W Brown 1 94 Dec-05 Apr-10 52 (web site: http://www.corporatenews.net/_client/RL24592/Ghent-Brown%20FGD%20Final.pdf) contract award EPC (WFGD) Gent units 1,3,4 & EW Brown units 1,2,3 98% SO2 Removal. Award Dec 2005. [note: will use CAMD SO2 control date - 4/1/2010) 4/1/2010

E W Brown 2 160 Dec-05 Apr-10 52 (web site: http://www.corporatenews.net/_client/RL24592/Ghent-Brown%20FGD%20Final.pdf) contract award EPC (WFGD) Gent units 1,3,4 & EW Brown units 1,2,3 98% SO2 Removal. Award Dec 2005. [note: will use CAMD SO2 control date - 4/1/2010) 4/1/201015 1 Staudt, Availability of Resources for Clean Air Projects , October 1, 2010 (available from Andover Technology Partners, www.AndoverTechnology.com )

2 National Electric Energy Data System

3 The 2010 Information Collection Request (ICR) for the Toxics Rule provided data showing that some capacity without existing fabric filters successfully meet the total PM emissions rate standard in the proposed Toxics Rule. The data do not, however, fully reveal why certain units without existing fabric filters meet the PM standa rd while others also without fabric filters reported emissions data which would fail the proposed Toxics Rule PM standard. As such, EPA originally examined the feasibility of a conservative scenario in which all capacity without existing fabric filters wo uld be required to install that retrofit for total PM compliance (about 54 GW beyond the projection in Table 1 above). EPA determined that such a conservative scenario would not change the key feasibility conclusions offered in this paper.

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

5 Best Coal

- fired Projects , Springerville Unit 3 Expansion Project , Power Engineering, November 2006, http://www.powergenworldwide.com/index/display/articledispl ay/277709/articles/power

- engineering/

- /2006/11/best

- coal

- fired

- projects.html