CAMD Facility Name Unit ID

CAMD/NEEDS/EIA 

Verified Scrubber

Scrubber 

Online 

Year

Oklaunion Power Station 1

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 WAP8

Wet 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 1978
Coleto 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 Oaks U1

Reagent Injection

Optim Energy Twin Oaks U2

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 2009
Sandow Station 5B Dry Scrubber 2009

Permits should be examined to confirm control status, discover emission limits, and any special re

"Make existing enforceable" is no additional control but recommends we examine the historic em

"Optimize existing [scrubber/SCR]" recommends we investigate what improvements can be made 

Potential high and low control scenarios do not consider visibility benefits and merely represent t
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 + OFA 2000

Selective Catalytic Reduction LNB + OFA 2000

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 2008
Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC3

Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC3

Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC3

Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC3

Low NOx Burner Technology w/ Closedcoupled/Separated OFA LNC1

Low 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 OFA

Low NOx Burner Technology w/ Closedcoupled/Separated OFA<br>Overfire Air OFA

Low 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 + OFA 2009

Low NOx Burner Technology (Dry Bottom 

only)<br>Low NOx Burner Technology w/ Overfire 

Air

LNBO

Selective Non-catalytic Reduction 2009
Selective Non-catalytic Reduction 2009

confirm control status, discover emission limits, and any special restrictions or conditions.

o additional control but recommends we examine the historic emissions for a reasonable lower monthly lbs/MMBtu and place that limit 

R]" recommends we investigate what improvements can be made to upgrade the existing equipment, including replacing the absorber, or 

cenarios 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.
onable lower monthly lbs/MMBtu and place that limit in a FIP. In many cases, additional NOx combustion controls could also be investiga

xisting equipment, including replacing the absorber, or for SCR, adding additional catalyst.

 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.


rols could also be investigated for installation (e.g., Sam Seymour).
Oklaunion Power 1

Wet Scrubber 1986 LNB LNB N/A Y

Limestone LIM1 Wet Scrubber 1985 Overfire Air LNC3 N/A Y

Limestone LIM2 Wet 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 WAP8 Wet 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/SOFA LNC1 SCR?

J T Deely 2

LNB w/ Closedcoupled/SOFA LNC1 SCR?

San Miguel SM-1 Wet Scrubber 1982 OFA LNB (Dry 

Bottom only) LNB + OFA N/A

Harrington 

Station 061B LNB w/ SOFA OFA N/A

Harrington 

Station 062B

LNB w/ Closedcoupled/SOFA OFA N/A

Harrington 

Station 063B

LNB w/ Closedcoupled/SOFA LNC3 N/A

Tolk Station 171B OFA OFA N/A

Tolk Station 172B OFA OFA N/A

Sandow 4

Wet Scrubber 1981 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 Scrubber 1992 LNB w/ Closedcoupled/SOFA LNC1 N/A

J K Spruce BLR2 Wet Scrubber 2009 SCR LNB + OFA 2009

H W Pirkey 

Power 1

Wet Scrubber 1985

LNB (Dry 

Bottom only) 

LNB w/ OFA 

LNBO N/A Y

Sandow Station 5A Dry Scrubber 2009 SNCR 2009 

Sandow Station 5B Dry Scrubber 2009 SNCR 2009 

14
Well 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.