1

An Assessment of the Feasibility 

of Retrofits

for the Toxics Rule

U.S. Environmental Protection Agency

Office of Air and Radiation

March 9, 2011
2

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 thousand 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

WetFGDeq Wet FGD equivalent - The amount of an APC technology

expressed as its GW equivalent in wet FGD technology
3

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 what 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 retrofits 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 sector 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

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

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

aggregation of APC systems to achieve timely compliance with 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 resulting in a significant underestimate of what was 

ultimately achieved in practice1

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

analyses of either plants or supply chains on a national scale, such analyses miss the mark 
4

because no single planner can be responsible for the strategies of competitive participants in the 

supply chain, much less for owner compliance strategies at all affected units. In reality, the 

sector will benefit from the creative interaction of a multitude of actors in the marketplace 

developing routes to compliance. For the purposes of this 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-thanaverage” project outcomes as regards cost and schedule. In developing a broad-scale estimate, 

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

been considered at an appropriate level of detail. 

RECENTLY DEMONSTRATED DEPLOYMENT CAPABILITIES OF THE APC 

SUPPLY CHAIN

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

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

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

Data System (NEEDS)

2

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 supply chain. 

Source: EPA, NEEDSv4.10PTR

0.0

10.0

20.0

30.0

40.0

SCR, GW FGD, GW New Coal, GW
5

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

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

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

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

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

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

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

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

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

historic levels.

RETROFIT PROJECTIONS FOR TOXICS RULE

Table 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 24 GW of coal-fired generating 

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

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

receive more than one APC technology. 

APC Technology Wet FGD Dry FGD

(with FF*) SCR FF DSI

(Trona, etc) ACI

Retrofit GW 0 24 3 143 56 93

Source: EPA, derived from IPMv4.10PTR

* Note: 24 GW of FF included with DryFGD is in addition to the 143 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 cannot be fully considered in IPM modeling 

would influence plant owner decisions on how to apply any of these systems on individual units. 

Therefore, although IPM projections based on “model plants” have proven to be excellent 

predictors of economic 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 RETROFIT DEPLOYMENTS (GW WetFGDeq)

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

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

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

for the Toxics Rule. Such a single metric permits assessment of the overall combined feasibility

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

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

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

from Table 1 into an “equivalent wet FGD capacity” (WetFGDeq). The total (70 GW 

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

of this conversion is that retrofitting 24 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 equivalence factors are computed as the ratio of the capital cost of each technology to that of 

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

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

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

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 conditions. They do not directly represent the relative 

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

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

the highest capital cost, uses the most supply chain resources, and requires the longest schedule 

for deployment. Use of the single WetFGDeq 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 70
7

TRENDS IN TOTAL RETROFIT DEPLOYMENT EFFORT (GW WetFGDeq)

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

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

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

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

separately identified drivers, but the portion 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 NOx and 

2010 for SO2. Solely CAIR-driven APC deployments of about 13 GW WetFGDeq occurred 

within two and a half years after CAIR’s finalization in mid-2005, showing that at least 40% of

total CAIR-only APC effort through 2010 was sufficiently planned for installation to start before 

or immediately upon finalization of the rule.

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

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

Environmental Retrofit Project Database: November 2010 Update." 

ADDITIONAL SUPPLY CHAIN RESOURCES

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

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

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

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

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

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

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

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

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

0.0

10.0

20.0

30.0

40.0

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

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

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

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

Source: EPA

SCHEDULE OUTLOOK FOR RETROFIT INSTALLATIONS

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

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

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

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

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

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

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

example of an “early mover” making major early APC deployment decisions, leading to 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. “Early 

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

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

installations in a short period of time. EPA clearly saw this early mover advantage occur with 
9

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

the APC supply chain for the Toxics Rule. 

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

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

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

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

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

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

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

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

contractor was given a notice to proceed with engineering.5

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 completion, tie-in, and subsequent operation –

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

regulatory benefit. Factors that will likely accelerate project schedules under the Toxics Rule 

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

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

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

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

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

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

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

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

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

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

Neither the proposed Transport Rule nor the Toxics Rule, however, as shown in Table 1, is 

projected to require a significant number of large, complex wet FGD systems. The relatively 

much simpler dry FGD, fabric filter, and other even simpler dry sorbent injection (DSI) and ACI 

systems that may be required under the Toxics rule will take significantly 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 the scope of the work involved for an entire new coal unit is at least five times that of a 

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

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

in 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)

13 26 – 35 months

8 37 – 52 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 the banking and 

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

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

emissions exceeded allowance allocations to that unit. The 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 rational 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 DEPLOYMENT SCENARIOS

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

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

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

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

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

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

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

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

less. Not shown in Figure 3 are any additional deployments that may be made by 2014 in 

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 additional APC 

deployments for that rule will not adversely impact the 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 deployments over the 3-year period 

from 2006 to the peak in 2009 was 45%. A renewed ramp-up in deployment capability starting in 
11

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): 

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

service APC retrofits of at least 20 GW WetFGDeq. 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. 

The starting point assumption directly influences the computation of what proportion of 

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

one-year extension to 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 expectation since the 

Toxics Rule is not projected to require use of wet FGD, the most time- and resourceconsuming APC technology. Note that although this WetFGDeq analytical concept 

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

deployed increasing amounts of DSI, activated carbon injection (ACI), 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 22 GWeq is completed 

by January 2016, thus meeting the Toxics Rule cumulative goal of 70 GW WetFGDeq. 

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

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

compliance not yet reflected in the historic record.
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 timely compliance is achievable in this moderately 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. Conceivably, it would not “throttle back” its resource growth; it would tap all 

available sources until all resources that are needed are in place to produce 70 GW WetFGDeq of 

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

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

the CAIR peak), with an additional 42 GWeq placed into service by early 2015 (50% 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 

resources

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 WetFGDeq
13

EFFECT OF RETROFIT UNIT SIZES

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

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

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

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

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

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

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

EPA projects that the future average unit size retrofitted for the 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. The limited time for compliance will likely necessitate 

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

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

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

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

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

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

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

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

fewer supply chain resources. 

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

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

fabric filters and less complex technologies, any of which are far less complex than the wet FGD 

systems installed for CAIR. They will entail far fewer component suppliers, less process 

engineering effort, fewer technical specifications, etc. A typical fabric filter project is therefore

far less difficult to manage or supervise than a typical wet scrubber project. Likewise they are 

easier to construct and will require relatively less craft labor. Thus, although there may be more 

APC projects, they will be far easier to manage, and should require relatively fewer skilled 

personnel than CAIR experience and the WetFGDeq metric might suggest. 

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

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

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

scenario.
14

Appendix - Wet FGD Retrofit Timelines

Plant Name Unit ID Capacity 

(MW)

PROJ START 

(CAMD 

findings)

PROJ FINISH 

(CAMD 

Findings)

PROJ 

Duration 

(months)

Reference

CAMD SO2 

Control Start 

Date

Asheville 1 191 Sep-03 Nov-05 26 (web site: http://www.powergenworldwide.com/index/display/articledisplay/277709/articles/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=14282) unit 2 on-line May 25, 2006; unit #1 on-line Nov 2005.

11/6/2005

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

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

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

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

5/24/2007

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

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

unit #2 connected Mar 2010. 

11/21/2009

Crist 7 472 May-07 Jan-10 32 (web site: http://www.bv.com/wcm/press_release/05072007_1374.aspx) B&V selected by 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=14282) unit 2 on-line May 25, 2006; unit #1 on-line Nov 2005.

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

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

by next mid april).

10/1/2008

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

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

1/15/2007

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

4/1/2010
15

 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 standard 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 would 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 al, Implementation Strategies for Southern Company FGD Projects, 2010 Mega Symposium , Paper#68

5

Best Coal-fired Projects , Springerville Unit 3 Expansion Project, Power Engineering, November 2006, 

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

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