2010 Primary Sulfur Dioxide (SO2)

National Ambient Air Quality Standard (NAAQS)

Technical Analyses and Information Supporting the

Designation Recommendation for Oklahoma

OG&E’s Public Statements on Commitments to Meet EPA’s 

Regional Haze FIP Requirements

Muskogee Generating Station: Conversion of Units 4 & 5 to Natural Gas

Sooner Generating Station: Installation of Dry Scrubbers on Units 1 & 2

As Provided by Usha-Maria Turner, Director of Corporate Environmental

Oklahoma Gas and Electric Company

On July 7, 2015

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OG&E’s Public Statements on the Conversion of Muskogee Units 4 & 5 to 

Natural Gas.

The U.S Environmental Protection Agency (EPA) finalized requirements for certain coal-fired 

units in Oklahoma under the Regional Haze program on December 28, 20111. In that rule, EPA 

took final action in disapproving the 2010 State Implementation Plan (SIP) limit for sulfur 

dioxide (SO2) and established new limits (rolling, 30-day SO2 emission limit of 0.06 lbs/mmBtu )

under a Federal Implementation Plan (FIP) for these units in Oklahoma including 4 owned and 

operated by OG&E: Muskogee units 4 & 5; Sooner units 1 & 2.

To comply with the Oklahoma Regional Haze FIP, OG&E plans to install Dry, Flue Gas 

Desulfurization systems (commonly called dry “scrubbers”) along with baghouse/fabric filter 

technology, on Sooner Units 1 and 2. While installing that same technology at Muskogee Units 

4 and 5 would meet the FIP’s SO2 emission limits, OG&E plans to convert the boilers at 

Muskogee Units 4 and 5 from utilizing low sulfur coal to utilizing natural gas exclusively and will 

meet the SO2 limits by ceasing the combustion of sulfur-containing coal at these two units.2 

OG&E has made this commitment to gas conversion on Muskogee Units 4 & 5 in several public 

documents including:

1. 10Q filing before the Securities Exchange Commission (SEC)3.

“On August 6, 2014, OG&E filed an application with the OCC for approval of its plan to 

comply with EPA’s MATS and Regional Haze FIP while serving the best long-term 

interests of customers in light of future environmental uncertainties. The application 

seeks approval of the environmental compliance plan and for a recovery mechanism for 

the associated costs. The environmental compliance plan includes installing dry 

scrubbers at Sooner Units 1 and 2 and the conversion of Muskogee Units 4 and 5 to 

natural gas.”

2. Integrated Resource Planning 2014 Update4filing with the Oklahoma Corporation 

Commission (OCC):

 

1

Federal Register. Vol. 76, No. 249. Wednesday, December 28, 2011 p 81728

2

Direct Testimony of Usha-Maria Turner before the OCC, page 5. Available at 

http://imaging.occeweb.com/AP/CaseFiles/occ5129575.pdf

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nd quarter 2014 10Q. Commission File Number: 1-12579; August 7th 2014. The Company reiterated this plan in 

the subsequent quarterly SEC 10Q filings as well as in the annual 10K filed with the SEC on February 26, 2015. All 

filings available at http://phx.corporate-ir.net/phoenix.zhtml?c=106374&p=irol-sec.

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Integrated Resource Plan (IRP) – 2014 Update; page 5. Filed August 6, 2014 with the OCC. Available at 

http://phx.corporate-ir.net/phoenix.zhtml?c=106374&p=irol-utilityreg
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“OG&E takes very seriously its responsibility to provide reliable, reasonably priced power 

produced in an environmentally responsible way. This IRP reflects OG&E’s plan to meet 

federal mandates in a way that minimizes the impact on customers. Unfortunately, all 

alternatives available to the Company increase customer costs. After carefully 

considering all these factors, OG&E has decided to convert two coal-fired units at the 

Muskogee Power Plant to natural gas, add scrubbers to the coal-fired units at the Sooner 

power plant, and other pollution control equipment...”

3. Testimony of Usha-Maria Turner filed before the Oklahoma Corporation Commission 

(OCC) cause number PUD 2014002295

OG&E plans to convert Muskogee units 4 & 5 to natural gas before the deadline of January 4, 

2019 and OG&E plans to submit the permit application to the Oklahoma DEQ closer in time to 

the need. Prior to the start of operation of these units on natural gas, the pipeline supply to the 

facility has to be expanded in order to run these two units on solely natural gas.

 

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Supra at 2