**CAMD Facility Name Unit ID** **CAMD/NEEDS/EIA Verified Scrubber**  **Scrubber**

**Online Year** 

Oklaunion Power Station1 Wet Scrubber 1986
Limestone LIM1 Wet Scrubber 1985
Limestone LIM2 Wet Scrubber 1986 W A Parish WAP5 W A Parish WAP6 W A Parish WAP7 W A Parish WAP8Wet Scrubber 1982 Big Brown 1 Big Brown 2 Gibbons Creek Steam Electric Station 1 Wet Scrubber Upgrade 4/2011 1983 Welsh Power Plant 1 Welsh Power Plant 2 Welsh Power Plant 3 Martin Lake 1 Wet Scrubber 1977 Martin Lake 2 Wet Scrubber 1978 Martin Lake 3 Wet Scrubber 1979 Monticello 1 Monticello 2
Monticello 3 Wet Scrubber 1978Coleto Creek 1

Sam Seymour 1 Wet scrubber operational 1/2011 Sam Seymour 2 Wet scrubber operational 3/2011 Sam Seymour 3 Wet Scrubber upgrade 3/2012 1988 J T Deely 1 J T Deely 2
San Miguel SM-1 Wet Scrubber 1982
Harrington Station 061B Harrington Station 062B Harrington Station 063B Tolk Station 171B Tolk Station 172B

Sandow 4 Wet Scrubber 1981
Optim Energy Twin OaksU1 Reagent Injection Optim Energy Twin OaksU2 Reagent Injection J K Spruce BLR1 Wet Scrubber 1992
J K Spruce BLR2 Wet Scrubber 2009

H W Pirkey Power Plant 1 Wet Scrubber 1985

Sandow Station 5A Dry Scrubber 2009Sandow Station 5B Dry Scrubber 2009 Permits should be examined to confirm control status, discover emission limits, and any special restrictions or conditions. "Make existing enforceable" is no additional control but recommends we examine the historic emissions for a reasonable lower monthly lbs/MMBtu and place that limit in a FIP. In many cases, additional NOx combustion controls could also be investigated for installation (e.g., Sam Seymour). "Optimize existing [scrubber/SCR]" recommends we investigate what improvements can be made to upgrade the existing equipment, including replacing the absorber, or for SCR, adding additional catalyst. Potential high and low control scenarios do not consider visibility benefits and merely represent the possible range of control options.**CAMD NOx Control(s) NOx Comb**  **Control (existing**  **accord. To NEEDS)**  **SCR**

**Online Year**  **SNCR Online**  **Year**

Low NOx Burner Technology (Dry Bottom only) LNB
Overfire Air LNC3 Overfire Air Selective Catalytic Reduction LNB + OFA2000 Selective Catalytic Reduction LNB + OFA2000 Selective Catalytic Reduction LNC3 1999 Selective Catalytic Reduction LNC3 2000 Low NOx Burner Technology w/ Separated OFA<br>Selective Non-catalytic Reduction LNC2 2008 Low NOx Burner Technology w/ Separated OFA<br>Selective Non-catalytic Reduction LNC2 2008 Low NOx Burner Technology w/ Closed-coupled OFA LNC2 Low NOx Burner Technology w/ Overfire Air LNBO Low NOx Burner Technology w/ Overfire Air LNB + OFA Low NOx Burner Technology w/ Overfire Air LNBO Low NOx Burner Technology w/ Separated OFA LNC2 Low NOx Burner Technology w/ Separated OFA LNC2 Low NOx Burner Technology w/ Separated OFA LNC2 Low NOx Burner Technology w/ Separated OFA<br>Selective Non-catalytic Reduction LNC2 2009 Low NOx Burner Technology w/ Separated OFA<br>Selective Non-catalytic Reduction LNC2 2008 Low NOx Burner Technology w/ Overfire Air<br>Selective Non-catalytic Reduction LNBO 2008Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC3Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC3Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC3Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC3Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC1Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC1 Overfire Air<br>Low NOx Burner Technology (Dry Bottom only) LNB + OFA Low NOx Burner Technology w/ Separated OFA<br>Overfire Air OFALow NOx Burner Technology w/ Closedcoupled/Separated OFA<br>Overfire Air OFALow NOx Burner Technology w/ Closedcoupled/Separated OFA<br>Overfire Air LNC3 Overfire Air OFA Overfire Air OFA Low NOx Burner Technology w/ Separated OFA<br>Selective Catalytic Reduction LNC2 2010

Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC1 Selective Catalytic Reduction LNB + OFA2009 Low NOx Burner Technology (Dry Bottom only)<br>Low NOx Burner Technology w/ Overfire Air LNBO Selective Non-catalytic Reduction 2009Selective Non-catalytic Reduction 2009 Permits should be examined to confirm control status, discover emission limits, and any special restrictions or conditions. "Make existing enforceable" is no additional control but recommends we examine the historic emissions for a reasonable lower monthly lbs/MMBtu and place that limit in a FIP. In many cases, additional NOx combustion controls could also be investigated for installation (e.g., Sam Seymour). "Optimize existing [scrubber/SCR]" recommends we investigate what improvements can be made to upgrade the existing equipment, including replacing the absorber, or for SCR, adding additional catalyst. Potential high and low control scenarios do not consider visibility benefits and merely represent the possible range of control options.**Comments on Potential Controls**

Baseload unit that burns SUB (probably PRB). Has an older scrubber that is partially bypassed and could potentially be operated more efficiently or upgraded. Ideally would gather more information from 114 letter. No SNCR/SCR.

Same as above but with older scrubber with a bypass. Ideally would gather more info in a 114 letter.

Baseload unit that burns PRB. Well performing wet scrubber that is a model for other PRB units.

Unit 3 is a baseload unit that burns SUB (probably PRB) and LIG in proportions that favor SUB (1-2 to 1). Older scrubber with bypass. Ideally would gather more info in a 114 letter. No SNCR/SCR. Existing SNCR. Baseload units that burn a mix of LIG and SUB (probably PRB) approx. equally. Have older scrubbers that are partially bypassed and could potentially be operated more efficiently or upgraded. Ideally would gather more information from 114 letter. No SNCR/SCR. No SCR/SNCR.

Baseload units that burn SUB (probably PRB). No scrubbers. No SNCR/SCR.

Baseload that burns a mix of LIG and SUB (probably PRB) that strongly favor LIG (3-5 to 1). Older scrubbers with bypasses. Ideally would gather more info in a 114 letter. No SCR/SNCR.
Units 1 and 2 are baseload units and burn SUB (probably PRB) and LIG in proportions that favor SUB (2-3 to 1). No scrubber. Existing SNCR. Baseload units that burn SUB (probably PRB). SCRs are some of the best performing in the country, but fluctuate due to relaxed permit limits.

Baseload units that burn a mix of LIG and PRB in varying proportions that favor LIG. No scrubbers. Existing SNCR.Baseload units that burn SUB (probably PRB). No scrubbers. No SNCR/SCR.

Baseload unit that burns lignite. Older scrubber that apparently does not have a bypass. After scrubbing, SO2 controlled to about the level of uncontrolled PRB. Ideally would gather more info in a 114 letter. No SNCR/SCR.

Baseload unit that burns LIG. Has an older scrubber with a bypass. Ideally would gather more info in a 114 letter. SCR installed in 2010, which has shown the potential to limit NOx to below 0.04 lbs/MMBtu on a monthly average, but usually operates above that.

Baseload unit that burns PRB. Older scrubber with no bypass that performs very well. No SCR/SNCR. Baseload unit that burns PRB. 2009 scrubber with no bypass.**Suspect CAMD data problem as many months with SO2 below 0.01 lbs/MMBtu.** SCR in 2009 that performs very well. Baseload unit that burns LIG. Older scrubber with bypass that has shown the ability to control SO2 to below 0.06 lbs/MMBtu on a monthly basis, although typically operated much looser. Ideally would gather more info in a 114 letter. No SCR/SNCR. Baseload units that burn SUB (probably PRB) with some small amounts of BIT in 2011 and 2010. No scrubbers. No SNCR/SCR.

Baseload units that burn LIG with small amounts of PC in 2011. Dry scrubber. Mobetec literature states ROFA for NOx (check permit), which has shown the ability to control NOx very well, although typical NOx emissions are higher.

Two smaller baseload units that share a steam turbine and burn LIG. 2009 dry scrubbers with no bypass that have controlled SO2 to below 0.06 lbs/MMBtu on a monthly basis, although typically operated much looser. Very well performing SNCR Baseload units that burn PRB. Units 1 and 2 got new wet scrubbers in 2011. Unit 3 got a wet scrubber upgrade in 2012. All three perform very well and are models for other PRB units. No SCR/SNCR, but recent sophisticated upgrades to the existing NOx combustion controls perform extremely well and are also models for other PRB units. Baseload units that burn PRB. No scrubbers.**Based on sudden NOx emissions decrease mid 2011, suspect both units retrofitted with SCR, but can't confirm.**  **Mayor Castro and others have made statements that Deely will close in 2018.**

Baseload units that burn SUB (probably PRB). No scrubbers. No SNCR/SCR."Make existing enforceable" is no additional control but recommends we examine the historic emissions for a reasonable lower monthly lbs/MMBtu and place that limit in a FIP. In many cases, additional NOx combustion controls could also be investigated for installation (e.g., Sam Seymour). "Optimize existing [scrubber/SCR]" recommends we investigate what improvements can be made to upgrade the existing equipment, including replacing the absorber, or for SCR, adding additional catalyst. Potential high and low control scenarios do not consider visibility benefits and merely represent the possible range of control options. monthly basis, although typically operated much looser. Very well performing SNCR that is model for other LIG SNCRs, typically controls NOx to below 0.07 lbs/MMBtu."Make existing enforceable" is no additional control but recommends we examine the historic emissions for a reasonable lower monthly lbs/MMBtu and place that limit in a FIP. In many cases, additional NOx combustion controls could also be investigated for installation (e.g., Sam Seymour).Oklaunion Power 1 Wet Scrubber 1986 LNB LNB N/A Y

Limestone LIM1Wet Scrubber 1985 Overfire Air LNC3 N/A Y Limestone LIM2Wet Scrubber 1986 Overfire Air N/A Y W A Parish WAP5 SCR LNB + OFA 2000 W A Parish WAP6 SCR LNB + OFA 2000 W A Parish WAP7 SCR LNC3 1999 W A Parish WAP8Wet Scrubber 1982 SCR LNC3 2000 Y Big Brown 1 LNB/SOFA SNCR LNC2 2008 Big Brown 2 LNB/SOFA SNCR LNC2 2008
Gibbons Creek 1 Wet Scrubber Upgrade 4/2011 1983 LNB w/ Closedcoupled OFA LNC2 N/A Welsh Power 1 LNB w/ OFA LNBO N/A Welsh Power 2 LNB w/ OFA LNB + OFA N/A Welsh Power 3 LNB w/ OFA LNBO N/A Martin Lake 1 Wet Scrubber 1977 LNB w/ SOFA LNC2 N/A Y Martin Lake 2 Wet Scrubber 1978 LNBw/ SOFA LNC2 N/A Y Martin Lake 3 Wet Scrubber 1979 LNB w/ SOFA LNC2 N/A Y Monticello 1 LNB w/ SOFA SNCR LNC2 2009 Monticello 2 LNB w/ SOFA SCNR LNC2 2008 Monticello 3 Wet Scrubber 1978 LNB w/ OFA SNCR LNBO 2008 Y Coleto Creek 1 LNB w/ Closedcoupled/SOFA LNC3 N/A Sam Seymour 1 Wet scrubber 2011 LNB w/ Closedcoupled/SOFA LNC3 N/A Sam Seymour 2 Wet scrubber 2011 LNB w/ Closedcoupled/SOFA LNC3 N/A 1988/ 2011 J T Deely 1 LNB w/ Closedcoupled/SOFALNC1 SCR? J T Deely 2 LNB w/ Closedcoupled/SOFALNC1 SCR? San Miguel SM-1Wet Scrubber1982 OFA LNB (Dry Bottom only) LNB + OFA N/A Harrington Station 061B LNB w/ SOFAOFA N/A Harrington Station 062B LNB w/ Closedcoupled/SOFAOFA N/A Harrington Station 063B LNB w/ Closedcoupled/SOFALNC3 N/A Tolk Station 171B OFA OFA N/A Tolk Station 172B OFA OFA N/A Sandow 4 Wet Scrubber1981 LNB w/ SOFA SCR LNC2 2010 Y Twin Oaks U1 Reagent Injection N/A **NOx Comb Control (existing per**  **NEEDS) Facility Name** **Unit ID CAMD/NEEDS/**  **EIA Verified Scrubber**  **Scrubber**

**Online Year**  **CAMD NOx**

**Control(s)**

Sam Seymour 3 Wet Scrubber LNB w/ Closedcoupled/SOFA LNC3 N/A **SCR/SNCR Online**  **Year Scrubber** 

**Bypass**Twin Oaks U2 Reagent Injection N/A J K Spruce BLR1 Wet Scrubber1992 LNB w/ Closedcoupled/SOFALNC1 N/A J K Spruce BLR2 Wet Scrubber2009 SCR LNB + OFA 2009 H W Pirkey Power 1 Wet Scrubber1985 LNB (Dry Bottom only) LNB w/ OFA LNBO N/A Y Sandow Station5A Dry Scrubber2009 SNCR 2009 Sandow Station5B Dry Scrubber2009 SNCR 2009

14Well performing wet scrubber that is a model for other PRB units.

SCR installed in 2010, which has shown the potential to limit NOx to below 0.04 lbs/MMBtu on a monthly average, but usually operates above that. Dry scrubber. Mobetec literature states ROFA for NOx, which has shown the ability to control NOx very well, although typical NOx emissions are higher. new wet scrubbers perform very well. recent sophisticated upgrades to the existing NOx combustion controls perform extremely well
No scrubbers. sudden NOx emissions decrease mid 2011, suggest SCR, but can't confirm. Possible commitment to shutdown in 2018 **Comments on Potential Controls**scrubber with bypass has ability to control SO2 to below 0.06 lbs/MMBtu on a monthly basis,

although typically operated much looser. very well, although typical NOx emissions are higher.