MEMORANDUM | 31 March 2011 

TO Ellen Kurlansky 

FROM Jason Price, Nadav Tanners, and Jim Neumann (IEc) and Roy Oommen (ERG) 

SUBJECT Employment Impacts Associated with the Manufacture, Installation, and Operation of 

Scrubbers 

EPA expects that a wide range of current and upcoming regulatory actions pursued under 

the authority of the Clean Air Act (CAA) could significantly increase the demand for flue 

gas desulfurization (FGD, commonly referred to as scrubbers). Under the combined 

requirements of more stringent NAAQS standards, regional haze requirements, a revised 

Clean Air Interstate Rule, and Section 112 MACT rules, FGD may be the most costeffective compliance strategy for affected emissions sources. Therefore, a full 

understanding of the economic impacts associated with the manufacture, installation, and 

operation of scrubbers is critical to an assessment of the impacts of these rules. Among 

these impacts is the employment effect associated with the production, installation, and 

operation of scrubbers in response to CAA requirements. 

The purpose of this memorandum is to present the average employment impacts 

associated with the manufacture, installation, and operation of a scrubber. These perscrubber employment impacts may inform the assessment of regulatory impacts for 

upcoming CAA regulations. The employment impacts estimated in this memorandum 

include both direct and indirect impacts. Direct employment impacts include labor used 

by scrubber manufacturers, fabricators, and users, whereas indirect impacts include labor 

employed in the production of inputs to scrubber production, as well as labor employed 

by vendors that support scrubber operations. 

We estimate employment impacts for a series of model scrubber installations, defined in 

terms of their size and application (e.g., electric utilities versus industrial boilers). 

Exhibit 1 summarizes our employment estimates for each model scrubber. As indicated 

in the exhibit, employment impacts are most significant for large scrubbers installed at 

electric utilities. 

In the sections that follow, we provide a detailed specification of the model scrubbers that 

we used for this analysis, summarize our methods for estimating the direct and indirect 

employment impacts for each model scrubber, and present recommendations for applying 

our results in a regulatory setting. 

 

INTRODUCTION 
 

 2 

EXHIBIT 1. SUMMARY OF EMPLOYMENT IMPACTS PER MODEL SCRUBBER 

MODEL SCRUBBER 

MODEL SCRUBBER 

DESCRIPTION 

ONE-TIME 

EMPLOYMENT IMPACTS 

(ANNUAL EQUIVALENT 

FTEs)2

RECURRING ANNUAL 

EMPLOYMENT IMPACTS 

(FTEs PER YEAR)3

Model Scrubber 1 Medium/Large Utility 

Boilers 848 – 1,001 103 

Model Scrubber 2 Small Utility Boilers 409 – 493 39 

Model Scrubber 3A1

Large Industrial/ 

Institutional Boilers 

(method 1) 

333 – 400 29 

Model Scrubber 3B1

Large Industrial/ 

Institutional Boilers 

(method 2) 

77 - 91 16 

Model Scrubber 4 

Small- and Medium-Sized 

Industrial/Institutional 

Boilers 

40 – 48 6 

Notes: 

1.As described in later sections of this document, Model Scrubbers 3A and 3B are different 

analytic variants of the same model scrubber. Both represent scrubbers at large industrial 

boilers, but we estimate employment impacts for Model Scrubber 3A based on one 

methodology and Model Scrubber 3B based on another. 

2.One-time employment impacts reflect the labor required for the manufacturing and 

installation of each model scrubber, including the labor required to produce scrubber 

components (e.g., the absorber vessel) that scrubber makers purchase from other firms. 

3.Recurring employment impacts include labor required for the operation, maintenance, and 

administrative support for each scrubber over its full lifetime of operation. 

The guiding principles that informed the specification of model scrubbers for this analysis 

were to (1) capture the range of scrubbers likely to be installed in response to various 

emissions control requirements and (2) reflect significant per-scrubber employment 

impact variation. To that end, we define the model scrubbers for this analysis in terms of 

their size (i.e., capacity of the controlled combustion unit) and the type of boiler to which 

each scrubber is applied for acid gas control. We distinguish between scrubbers at 

electric utilities and scrubbers installed on industrial/ institutional boilers because of the 

significant differences between the two in terms of construction and labor requirements.1

 

The scrubber market is similarly segmented along these lines, such that many companies 

that manufacture large scrubber units for utilities do not manufacture scrubbers for 

smaller industrial sources and vice versa. 

 

1

 In addition, as indicated below, installation represents most of the direct one-time labor associated with EGU scrubbers, 

whereas manufacturing makes up most of the direct one-time labor associated with industrial boiler scrubbers. 

MODEL 

SCRUBBERS 
 

 3 

MODEL SCRUBBERS FOR ELECTRIC UTILITIES 

We define the model scrubbers for electric utilities based on a prior ERG analysis. For 

Alberta’s Clean Air Strategic Alliance, ERG conducted a review of the USEPA Clean Air 

Market Division’s database and specified three model units defined in terms of their size: 

small (25-100 MW), medium (100-500 MW), and large (> 500 MW).2

 ERG’s analysis of 

wet FGD systems for these units identified a clear difference in the capital cost per 

energy output ($/MW) between wet FGD systems applied to small utility units (25 - 100 

MW) and those applied to medium to larger units (100 – 1,000 MW). Assuming that this 

difference in capital costs is indicative of differences in labor requirements, we specify 

two model scrubbers consistent with these capacity ranges, as indicated in Exhibit 2. 

MODEL SCRUBBERS FOR INDUSTRIAL BOILERS 

The model scrubbers for industrial boilers are based on EPA’s previous analysis of the 

costs associated with the MACT standards for these sources. To estimate the costs of the 

industrial boiler MACT, EPA specified a series of model units based on Federal and state 

databases and survey data compiled by the Agency for these units.3

 These model units 

were differentiated by size (as well as other factors not relevant to this analysis) into the 

following categories: < 10 million Btu per hour (MMBtu/hr), 10-100 MMBtu/hr, 100-

250 MMBtu/hr, and > 250 MMBtu/hr. EPA’s assessment of the scrubber-related costs 

for these model units found a significant difference in total annualized cost between units 

with capacity greater than 250 MMBtu/hr—most of which burned coal as their primary 

fuel—and those with capacity less than 250 MMBtu/hr—most of which used residual fuel 

oil or process gas as their primary fuel. This difference in costs reflects: (1) higher flue 

gas flow rates from larger units that will require larger control devices, and (2) high 

pollutant concentrations in coal relative to residual fuel oil or process gas, requiring more 

expensive controls with higher reduction efficiencies. Assuming that this difference in 

costs is indicative of differences in labor requirements, we specify two model scrubbers 

for units installed at industrial/institutional boilers: one for scrubbers installed at smalland medium-sized industrial boilers (50-250 MMBtu/hr) and a second for scrubbers at 

large industrial boilers (250-500 MMBtu/hr), as shown in Exhibit 2. 

 

2

 ERG, Electricity Framework 5 Year Review – Control Technologies Review. Final Report. Prepared for Clean Air Strategic 

Alliance of Alberta, Canada. January 21, 2009. 

3

 A summary of these units is available in Jeanette Alvis Christy Burlew, and Roy Oommen, Eastern Research Group. 

“Development of Model Units for the Industrial/ Commercial/ Institutional Boilers and Process Heaters National Emission 

Standards for Hazardous Air Pollutants”. Memorandum to Jim Eddinger, U.S. EPA. October 2002. 
 

 4 

EXHIBIT 2. SUMMARY OF MODEL SCRUBBERS 

MODEL 

NO. BOILER TYPE/APPLICATION 

BOILER SIZE 

(IN TYPICAL UNITS 

FOR APPLICATION) 

BOILER SIZE 

(STANDARDIZED TO 

MMBTU/HR) 

1 Utility Boilers (Medium and Large) 100–1,000 MW 980-9,800 MMBtu/hr 

2 Utility Boilers (Small) 25-100 MW 245 -980 MMBtu/hr 

3 Industrial/Institutional Boilers (Large) 250-500 MMBtu/hr 250-500 MMBtu/hr 

4 Industrial/Institutional Boilers (Smalland Medium-Sized) 50-250 MMBtu/hr 50-250 MMBtu/hr 

In this section, we present our analysis of the direct employment impacts associated with 

scrubber manufacturing, installation, and operation. These direct impacts include labor 

expended by scrubber producers for the manufacturing and installation of scrubbers and 

the labor required (on an annual basis) for the operation of a scrubber. We note that these 

direct employment impacts do not include labor associated with the production of 

material inputs used (purchased) by scrubber manufacturers or labor employed by 

vendors that support scrubber operations (e.g., firms that assist with FGD gypsum 

disposal). 

As indicated above, the model scrubbers specified for this analysis distinguish between 

scrubbers at electric utilities and scrubbers at industrial boilers. Because electric 

generating units (EGUs) are typically much larger than industrial boilers and can more 

easily realize economies of scale, electric utilities often construct scrubber support 

systems on-site, such as more complex waste handing and disposal systems, reagent 

handling systems, and limestone grinding systems. Industrial sources generally rely upon 

external vendors for these support functions. Large industrial boilers, which are similar 

in size to small utility units, may use either method depending on the cost over the 

lifetime of the equipment. To address this uncertainty, we estimate employment impacts 

for large industrial boilers (Model Scrubber 3) using two methodologies: one in which we 

assume that large industrial units construct scrubber support systems onsite and another in 

which we assume that these units rely on external vendors for this support. For reporting 

purposes, we designate the former as Model Scrubber 3A and the latter as Model 

Scrubber 3B. 

Exhibit 3 summarizes the approach that we employed to estimate the direct employment 

impacts associated with the manufacture, installation, and operation of each model 

scrubber. As indicated in the exhibit, the main steps of our approach are as follows: 

 

DIRECT 

EMPLOYMENT 

IMPACTS 
EXHIBIT 3. SCHEMATIC OF METHODOLOGY FOR ESTIMATING DIRECT SCRUBBER LABOR REQUIREME

1. For the operator labor associated with EGU model scrubbers, the CUECost program directly estimates the annual num

Maintenance and administrative support labor for EGU model scrubbers is estimated based on the approach depicted in th

Scrubber 

Parameters

Capital Cost for

Model Scrubbers

Industry Input on 

Labor as a Percent of 

Scrubber Mfg. and 

Installation Costs

Mfg. and Installation 

Labor Cost for

Model Scrubbers

Labor for the Mfg. 

and Installation of 

Each Model Scrubber

BLS Wage & 

Benefit Data

CUE Cost Model 

and OAQPS Cost 

Manual Algorithms

Annual Labor Costs 

for Operation,

Maintenance, and Support

of each Model Scrubber1

Annual Cost per 

O&M Employee

Annual Operating,

Maintenance, and Support 

Labor for Model Scrubbers
 

 6 

1. Input model scrubber parameters into EPA’s CUECost Program (for scrubbers at 

EGUs) and the cost algorithms included in the OAQPS control cost manual (for 

industrial boiler scrubbers) to estimate the capital costs associated with each 

model scrubber.4

,

5

2. Based on industry input on the labor costs reflected in the total cost of a scrubber, 

estimate the labor costs associated with the manufacture and installation of each 

model scrubber. 

3. Using wage and fringe benefit data from the Bureau of Labor Statistics (BLS), 

translate manufacturing and installation labor costs for each model scrubber into 

estimates of the labor required for manufacturing and installation, measured as 

full-time equivalents (FTEs). 

4. Estimate operating and maintenance labor based on O&M data generated by 

CUECost and the OAQPS cost manual algorithms. We generate separate 

estimates for operator labor, maintenance labor, and administrative support labor. 

We discuss each component of the analysis in greater detail below. 

ESTIMATION OF SCRUBBER CAPITAL COSTS 

The first step in our assessment of direct labor requirements is to estimate the total 

investment cost (i.e., upfront capital cost) for each model scrubber. For scrubbers at 

electric utilities, we generate these estimates with EPA’s CUECost program, whereas our 

estimates for industrial boiler scrubbers are based on the cost algorithms contained in the 

OAQPS control cost manual. The CUECost program was developed by EPA for analysis 

of the costs associated with nitrous oxide (NOx), sulfur dioxide (SO2), and particulate 

matter (PM) controls at coal-fired utility boilers. The OAQPS control cost manual 

provides detailed information on point source and stationary area source air pollution 

controls for volatile organic compounds (VOCs), PM, NOx, SO2, and other acid gases. 

Estimation of the capital costs for each model scrubber requires the specification of data 

inputs for the CUECost Program and the algorithms contained in the OAQPS control cost 

manual. In particular, representative capacity and SO2 control efficiency values were 

necessary for each model scrubber. Based on our previous experience with electric utility 

and industrial boilers scrubbers, we selected the representative capacity values included 

in Exhibit 4. The control efficiency for scrubbers may range from 90 to 99 percent. For 

this analysis, we assumed a control efficiency of 95 percent. For other data inputs 

required by CUECost (e.g., coal type and properties, flue gas temperature, etc.), we used 

the default values included in the program. Similarly, for other data inputs required by 

 

4

 Detailed information on the CUECost Program is available in R. Keeth, R. Blagg, C. Burklin, B. Kosmicki, D. Rhodes, and T. 

Waddell, Coal Utility Environmental Cost (CUECost) Workbook User’s Manual Version 1.0, prepared for U.S. EPA. 

Information on the OAQPS cost algorithms is available in U.S. EPA, OAQPS, EPA Air Pollution Control Cost Manual, Sixth 

Edition, January 2002. 

5

 Capital costs for Model Scrubber were estimated with both CUECost and the OAQPS cost algorithms. 
 

 7 

the cost algorithms contained in the OAQPS cost manual (e.g., temperature, inlet sulfur 

loading, etc.), we used default inputs previously developed by ERG for another analysis.6

 

EXHIBIT 4. REPRESENTATIVE CAPACITY FOR EACH MODEL SCRUBBER 

MODEL 

NUMBER SIZE RANGE 

TYPICAL SIZE 

(IN TYPICAL UNITS 

FOR APPLICATION) 

TYPICAL SIZE 

(STANDARDIZED TO 

MMBTU/HR) 

1 100 MW – 1,000 MW 750 MW 7,350 MMBtu/hr 

2 25-100 MW 100 MW 980 MMBtu/hra

3A and 3B 250 – 500 MMBtu/hr 500 MMBtu/hr 500 MMBtu/hr 

4 50 – 250 MMBtu/hr 100 MMBtu/hr 100 MMBtu/hr 

Based on the inputs entered into CUECost and the OAQPS cost manual algorithms, we 

estimate that the capital costs for the model scrubbers range from $7.1 million for small 

scrubbers installed on industrial boilers to $116 million for scrubbers fitted to large EGU 

boilers, as indicated in Exhibit 5. 

ESTIMATION OF DIRECT LABOR COSTS FOR THE MANUFACTURE AND INSTALLATION 

OF EACH MODEL SCRUBBER 

A key step in our assessment of direct scrubber employment impacts is estimation of the 

labor costs reflected in the total capital cost associated with each model scrubber. These 

labor costs reflect the cost of employing engineers, iron and steel workers, and 

boilermakers to manufacture and install each scrubber. Based on input from various 

industry sources, we estimate these labor costs as a percentage of the total investment 

costs for each model scrubber. Exhibit 6 summarizes the estimates that we obtained from 

these sources. As the exhibit indicates, the estimates that we obtained vary significantly, 

ranging from 25 percent of capital costs to 50 percent. However, most of the scrubber 

manufacturers and installers included in Exhibit 6 indicated that labor represents 40 to 50 

percent of capital costs. Moreover, Babcock and Wilcox, which manufactures and

installs scrubbers for both utilities and industrial boilers, specified that precise range and 

provided the most detailed information on scrubber costs.7

 Accordingly, this analysis 

reports labor costs associated with scrubber manufacturing and installation (and the 

associated employment impacts) as a range, based on the 40 to 50 percent range that we 

obtained from industry. 

 

6

 Roy Oommen, Eastern Research Group. “Methodology for Estimating Control Costs for the Industrial, Commercial, and 

Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants.” Memorandum to Jim 

Eddinger, U.S. Environmental Protection Agency, OAQPS. October 2002. 

7

 Personal communication with Phil Blazer, Babcock and Wilcox, January 5, 2010. 
 

 8 

EXHIBIT 5. MODEL SCRUBBER COSTS AND DIRECT LABOR REQUIREMENTS 

MODEL 

SCRUBBER 

1 

MODEL 

SCRUBBER 

2 

MODEL 

SCRUBBER 

3A 

MODEL 

SCRUBBER 

3B 

MODEL 

SCRUBBER 

4 

 SIZE RANGE 

980-9,800 

MMBtu/hr 

245 -980 

MMBtu/hr 

250-500 

MMBtu/hr 

250-500 

MMBtu/hr 

50-250 

MMBtu/hr 

COST 

ESTIMATES 

CAPITAL COST 

(MILLION $) 

$116 $56.7 $45.9 $13.5 $7.13 

LABOR COST – 

FABRICATION 

(MILLION $) 

$15.5 - 

$19.3 $7.6 - $9.5 $6.1 - $7.7 $3.6 - $4.5 $1.9 - $2.4 

LABOR COST – 

INSTALLATION 

(MILLION $) 

$30.9 - 

$38.7 

$15.1 - 

$18.9 

$12.2 - 

$15.3 $1.8 - $2.3 $1.0 - $1.2 

ANNUAL LABOR 

COST – O&M 

(MILLION $) 

$9.7 $4.0 $3.1 $0.45 $0.19 

DRECT 

LABOR 

ESTIMATES 

FABRICATION 

LABOR (ANNUAL 

EQUIVALENT 

FTES) 

128 - 160 63 - 78 51 - 63 30 - 37 16 - 20 

INSTALLATION 

LABOR (ANNUAL 

EQUIVALENT 

FTES) 

510 - 638 249 - 312 202 - 252 30 - 37 16 - 20 

O&M AND 

ADMINISTRATIVE 

SUPPORT LABOR 

(FTE PER YEAR) 

103 39 29 11 5 
 

 9 

EXHIBIT 6. MANUFACTURING AND INSTALLATION LABOR AS A PERCENTAGE OF 

SCRUBBER CAPITAL COST 

VENDOR ESTIMATE OF DIRECT LABOR FOR MANUFACTURING AND 

INSTALLATION AS A PERCENT OF SCRUBBER INVESTMENT COSTS 

Babcock and Wilcox 40 to 50 percent 

Babcock Power 40 percent 

Siemens (Wheelabrator, Inc.) 40 to 45 percent 

Paramount Fabricators 25 percent 

AE&E Von Roll 50 percent 

Nol-Tec 50 percent 

Hitachi 50 percent 

Our analysis also divides labor costs between fabrication labor and installation labor. 

Based on input received from industry sources, we assume that fabrication 

(manufacturing) accounts for two-thirds of the labor costs reflected in the investment cost 

for each industrial boiler scrubber and that installation accounts for one-third.8

 For 

scrubbers constructed on electric utility boilers, these figures are reversed (i.e., 

installation represents two-thirds of labor costs and fabrication represents one-third) 

because more assembly occurs at the boiler site for these large scrubbers. Exhibit 5 

summarizes our estimates of the labor costs associated with fabrication and installation 

for each model scrubber. 

ESTIMATION OF MANUFACTURING AND INSTALLATION LABOR FOR EACH MODEL 

SCRUBBER 

To translate the total direct labor costs associated with fabrication and installation of 

scrubbers into employment impacts, we estimate the allocation of labor costs among 

different types of laborers. Based on industry input, we estimate that mechanical and 

chemical engineers account for approximately 85 percent of the labor costs of fabrication, 

while structural iron and steel workers account for the remaining 15 percent.9

 We 

estimate that 100 percent of the labor costs of installation are attributable to work 

performed by boilermakers. To translate the costs associated with each kind of laborer to 

annual equivalent FTE, we use mean annual wage data from the Bureau of Labor 

Statistics (BLS), adjusted to account for total compensation (including total paid leave, 

insurance, and other benefits) using BLS data on average benefits for jobs in the 

manufacturing sector.10 Exhibit 7 presents the estimates of annual wages and total 

 

8

 Personal communication with Phil Blazer, Babcock and Wilcox, October 2009. 

9

 Based on personal communication with Tony Licata, Babcock Power. November 29, 2009. 

10 Data on wages for chemical and mechanical engineers, structural iron and steel workers, and boilermakers came from BLS, 

National Compensation Survey: Occupational Earnings in the United States, 2008 (Table 4). Total compensation data are 

from BLS, Employer Costs for Employee Compensation-June 2009, September 10, 2009. 
 

 10 

compensation that we used to estimate the direct employment impacts of scrubber 

fabrication and installation. 

EXHIBIT 7. ANNUAL WAGES AND TOTAL COMPENSATION FOR LABOR RELATED 

TO SCRUBBER FABRICATION AND INSTALLATION 

OCCUPATION MEAN ANNUAL WAGE 

TOTAL ANNUAL 

COMPENSATION 

Mechanical and chemical engineers $85,006 $128,350

Structural iron and steel workers $59,224 $89,422

Boilermakers $40,169 $60,651

Using the total annual compensation values listed in Exhibit 7, we estimated the number 

of annual equivalent FTEs that would be associated with the range of labor cost estimates 

presented in Exhibit 5. We estimate that the number of annual equivalent FTEs 

associated with scrubber fabrication ranges from 16 at small industrial scrubbers 

(assuming 40 percent of capital costs are labor) to 160 at large EGU scrubbers (assuming 

50 percent of capital costs are labor). Similarly, we estimate that the number of annual 

equivalent FTEs associated with scrubber installation ranges from 16 at small industrial 

scrubbers (assuming 40 percent of capital costs are labor) to 638 at large EGU scrubbers 

(assuming 50 percent of capital costs are labor). Exhibit 8 presents the estimated labor 

requirements for manufacturing and installation by labor category. 

EXHIBIT 8. MODEL SCRUBBER MANUFACTURING AND INSTALLATION LABOR 

REQUIREMENTS BY EMPLOYMENT CATEGORY 

MODEL ID 

MANUFACTURING LABOR FTEs INSTALLATION LABOR FTEs 

ENGINEERS 

IRON/STEEL 

WORKERS BOILERMAKERS 

1-Utility, large 103-129 25-31 510 - 638 

2-Utility, small 50-63 12-15 249 - 312 

3A-Industrial w/Utility costs 41-51 10-12 202 - 252 

3B-Industrial, large 24-30 6-7 30 - 37 

4-Industrial, small 13-16 3-4 16 - 20 

DIRECT LABOR IMPACTS RELATED TO MODEL SCRUBBER OPERATION, 

MAINTENANCE, AND ADMINISTRATIVE SUPPORT 

In addition to manufacturing and installation labor, we also estimate the number of annual 

full-time equivalents necessary for the operation, maintenance, and support of each model 

scrubber. Exhibit 9 summarizes the outputs generated by the CUECost Program and the 
 

 11 

OAQPS cost manual algorithms that are relevant to these labor categories. Our approach 

for estimating the annual number of FTEs for each category is as follows: 

 Operating Labor: We employ two different approaches to estimate the annual 

number of FTEs necessary for the operation of each model scrubber: one 

approach for electric utility scrubbers and a second for scrubbers at industrial 

boilers. For electric utility scrubbers, we rely on CUECost’s estimates of the 

number of operators associated with each model scrubber. Because the cost 

algorithms in the OAQPS control cost manual do not estimate the number of 

operators for the industrial boiler model scrubbers, we use an alternative 

approach for these units. More specifically, we assume that the labor costs per 

scrubber operator used in CUECost ($62,400) for electric utility scrubbers apply 

to industrial boiler scrubbers as well. We then apply this value to the operating 

labor cost for industrial boilers, as presented in Exhibit 9. 

 Administrative Support Labor: As indicated in Exhibit 7, CUECost and the 

OAQPS cost algorithms estimate the administrative labor costs associated with 

each model scrubber but not the annual number of administrative FTEs. To 

translate these costs into FTEs, we assume an annual labor cost of $49,600 based 

on data from BLS.11 

 Maintenance Labor: Both CUECost and the OAQPS control cost algorithms 

generate maintenance cost outputs that do not distinguish between labor and 

materials cost. The CUECost documentation, however, indicates that the model 

estimates administrative labor based on the following equation:12

(1) Admin. Labor = 0.3 (Operating Labor + Maintenance Labor) 

To estimate labor costs associated with maintenance, we solve Equation 1 for 

maintenance labor, using the administrative labor and operating labor cost 

estimates generated by CUECost and the OAQPS cost manual algorithms for 

each model scrubber as inputs. Although Equation 1 represents the approach 

employed by CUECost for estimating administrative labor costs for EGU

scrubbers, we assume that the relationship reflected in Equation 1 applies to 

industrial boiler scrubbers as well. To convert annual maintenance labor costs to 

annual FTEs, we assume that the labor costs per scrubber operator used in 

CUECost ($62,400 per year) applies to scrubber maintenance workers as well. 

 

11 Labor cost estimate for administrative workers derived from Bureau of Labor Statistics (BLS), “National Compensation 

Survey: Occupational Earnings in the United States, 2008,” and BLS, “Employer Costs for Employee Compensation —June 

2009,” September 10, 2009. 

12 CUECost Program is available in R. Keeth, R. Blagg, C. Burklin, B. Kosmicki, D. Rhodes, and T. Waddell, Coal Utility 

Environmental Cost (CUECost) Workbook User’s Manual Version 1.0, prepared for U.S. EPA, Table 3-2. 
 

 12 

EXHIBIT 9. CUECOST AND OAQPS COST MANUAL OUTPUTS RELATED TO ANNUAL 

OPERATION, MAINTENANCE, AND SUPPORT LABOR 

MODEL 

SCRUBBER 1 

MODEL 

SCRUBBER 2 

MODEL 

SCRUBBER 3A 

MODEL 

SCRUBBER 3B 

MODEL 

SCRUBBER 4 

Operator Labor 

(Annual FTEs) 37 9 6 Not estimated1

Not 

estimated1

Operating Labor 

Cost (million $) $2.3 $0.59 $0.37 $0.45 $0.19 

Maintenance Labor 

and Material Costs 

(million $) 

$5.9 $2.9 $2.4 $0.17 $0.09 

Administrative and 

Support Labor Cost 

(million $) 

$1.4 $0.53 $0.40 $0.152

 $0.072

Notes: 

1. Impacts for Model Scrubbers 3B and 4 were estimated with the OAQPS control cost manual 

algorithms, which do not generate estimates of the operator labor (measured in annual FTEs) 

required for scrubber operations. 

2. The OAQPS cost algorithms report these values as the cost of administrative support, without 

specifically indicating that these are labor costs. Because overhead is reported as a separate 

line item in the detailed results for Model Scrubbers 3B and 4, we assume that the cost of 

administrative support reported by the OAQPS cost manual algorithms reflects only the cost 

of administrative support labor. 

 

Based on the approach outlined above, we generated estimates of the annual FTEs 

associated with the operation, maintenance, and administrative support for each model 

scrubber, as summarized in Exhibit 10. 

EXHIBIT 10. DIRECT OPERATION, MAINTENANCE, AND SUPPORT LABOR 

(FTEs PER YEAR) 

MODEL 

SCRUBBER 1 

MODEL 

SCRUBBER 2 

MODEL 

SCRUBBER 3A 

MODEL 

SCRUBBER 3B 

MODEL 

SCRUBBER 4 

Operator Labor 37 9 6 7 3 

Maintenance Labor 38 19 15 1 1 

Administrative 

Support Labor 28 11 8 3 1 

Total 103 39 29 11 5 
 

 13 

In this section, we present our analysis of the indirect employment impacts associated 

with scrubber manufacturing, installation, and operation. These indirect impacts include 

both upstream impacts and downstream impacts. Upstream impacts include the labor 

expended to produce the individual scrubber components purchased by scrubber 

manufacturers. According to the industry sources that we contacted, scrubber 

manufacturers typically rely on other vendors or sub-contractors to produce the individual 

components of a scrubber (e.g., the absorber vessel), while the scrubber manufacturers 

themselves design and assemble the various components. Indirect downstream impacts 

include labor expended (on an annual basis) by third-party vendors to support the 

operation of a scrubber. 

Our analysis of indirect employment impacts mirrors our analysis of direct employment 

impacts in that we first use EPA’s CUECost Program (for EGU scrubbers) and the cost 

algorithms included in the OAQPS control cost manual (for industrial boiler scrubbers) to 

obtain estimates of capital costs and operating costs for each model scrubber examined. 

To estimate upstream employment impacts, we use industry-specific employment/output 

ratios to estimate the labor associated with the production of each scrubber component, 

measured as annual equivalent FTEs. To estimate downstream employment impacts, we 

use BLS wage and benefits data to translate costs of O&M material inputs and waste 

disposal into annual FTE estimates. We discuss our analysis of these impacts in greater 

detail below. 

ESTIMATION OF UPSTREAM INDIRECT LABOR FOR EACH MODEL SCRUBBER 

The CUECost model and OAQPS cost algorithms that we use to estimate the total capital 

costs for each model scrubber also provide estimates of the costs associated with 

individual scrubber components. For EGU scrubbers, CUECost identifies these 

components as reagent feed systems, SO2 removal systems, flue gas handling systems, 

waste/byproduct handling systems, and support equipment. For industrial scrubbers, the 

OAQPS control cost algorithms identify these components as pumps, mixing tanks, SO2

removal systems, and ductwork. A portion of the capital costs reported for each of these 

items reflects labor expended by scrubber manufacturers for their design, assembly, and 

installation. As indicated above, the input that we received from industry suggests that 

the labor costs of scrubber producers may represent between 40 and 50 percent of the 

capital costs reported for a scrubber. Therefore, similar to our assessment of direct labor 

costs, we estimate the purchased equipment cost for each scrubber component as a range. 

The low end assumes that 50 percent of the reported scrubber equipment cost is labor 

(and the remaining 50 percent is the purchased equipment cost), and the high end 

assumes that 40 percent of the reported cost is labor (and the remaining 60 percent is the 

purchased equipment cost). Exhibit 11 presents the total equipment costs provided by the 

CUECost model and the OAQPS cost algorithms, as well as the range of purchased 

equipment costs that we used to estimate upstream labor impacts. 

For each type of scrubber equipment, we assigned a specific industry or industries (as 

classified by NAICS codes), which we judged to be primarily responsible for the 

production of that input. As an example, we assume that the fabricated pipe and pipe 

INDIRECT 

EMPLOYMENT 

IMPACTS 
 

 14 

fitting manufacturing industry is responsible for the production of flue gas handling 

systems. For each industry code assigned, we use employment and output data from the 

2002 Economic Census Manufacturing Industry Series to determine the number of annual 

equivalent FTEs associated with a particular unit of production. By multiplying these 

unit values by the estimated purchase cost of each scrubber component, we developed 

estimates of the labor involved in producing each component. For scrubber components 

where we assigned multiple industries (e.g., waste/byproduct handling systems produced 

by both the cement manufacturing industry and the fabricated structural metal 

manufacturing industry), we developed a range of labor estimates. Based on the annual 

equivalent FTEs per unit of output for these industries and the estimated purchased cost 

of equipment, we developed the upstream labor estimates presented in Exhibit 11. 

EXHIBIT 11. MODEL SCRUBBER COSTS AND INDIRECT LABOR REQUIREMENTS 

MODEL 

SCRUBBER 

1 

MODEL 

SCRUBBER 

2 

MODEL 

SCRUBBER 

3A 

MODEL 

SCRUBBER 

3B 

MODEL 

SCRUBBER 

4 

SIZE RANGE 

980-9,800 

MMBtu/hr 

245 -980 

MMBtu/hr 

250-500 

MMBtu/hr 

250-500 

MMBtu/hr 

50-250 

MMBtu/hr 

COST 

ESTIMATES 

TOTAL EQUIPMENT 

COSTS (MILLION $) 

$82.5 $40.5 $32.8 $6.8 $3.4 

PURCHASED COST OF 

EQUPMENT (MILLION 

$) 

$41.3 - 

$49.5 

$20.2 – 

$24.3 

$16.4 – 

$19.7 

$3.4 - 

$4.1 

$1.7 - 

$2.1 

O&M INPUT AND 

DISPOSAL COSTS 

(MILLION $) 

n/a n/a n/a $0.62 $0.17 

INDIRECT 

LABOR 

ESTIMATES 

UPSTREAM 

LABOR 

(ANNUAL 

EQUIV. FTE )1

LOW 

174-203 82-103 67-84 15-17 7-9 

HIGH 210-243 97-124 80-101 18-19 9-11 

DOWNSTREAM LABOR 

(FTES PER YEAR) 

n/a n/a n/a 4 1 

Notes: 

1.The low values for upstream labor assume that 50 percent of the reported scrubber 

equipment cost is labor (and the remaining 50 percent is the purchased equipment cost), and 

the high end assumes that 40 percent of the reported cost is labor (and the remaining 60 

percent is the purchased equipment cost). 

 
 

 15 

ESTIMATION OF DOWNSTREAM INDIRECT LABOR FOR EACH MODEL SCRUBBER 

In addition to the labor required to produce individual scrubber components, we also 

estimate the annual labor expended by vendors who provide support services for the 

routine operation of scrubbers. As described above, industrial boiler scrubbers typically 

rely on external vendor support for waste handing and disposal systems, reagent handling 

systems, and limestone grinding systems, whereas electric utilities perform these 

functions onsite. Our assessment of downstream labor associated with these activities is 

therefore limited to scrubbers installed at industrial boilers.Output from the OAQPS cost 

algorithms include the annual cost of chemical inputs—lime and dibenzylideneacetone 

(dba)—as well as the annual cost of gypsum disposal, as presented in Exhibit 11. 

Information provided by industry sources suggests that labor costs represent 

approximately 30 percent of the costs associated with lime and 45 percent of the costs 

associated with dba and gypsum disposal.13 Based on this information and the estimated 

costs for each of these items, we estimated the total annual costs of labor associated with 

these downstream activities. To translate these labor costs to annual FTEs, we obtained 

wage and total compensation data for chemical workers (used for lime and dba) and 

refuse collectors (applied to gypsum disposal) from the Bureau of Labor Statistics (BLS), 

as summarized in Exhibit 12. Exhibit 11 presents our estimates of downstream labor for 

each model scrubber. 

EXHIBIT 12. ANNUAL WAGES AND TOTAL COMPENSATION FOR LABOR RELATED TO 

CHEMICAL O&M INPUTS AND WASTE DISPOSAL 

OCCUPATION MEAN ANNUAL WAGE 

TOTAL ANNUAL 

COMPENSATION 

Chemical processing machine setters, 

operators, and tenders $44,285 $66,866

Refuse and recyclable material 

collectors $26,888 $40,598

Source: Estimates derived from Bureau of Labor Statistics (BLS), “National Compensation 

Survey: Occupational Earnings in the United States, 2008,” and BLS, “Employer Costs for 

Employee Compensation —June 2009,” September 10, 2009. 

Exhibit 13 summarizes the results of our analysis. As indicated in the exhibit, the 

estimated employment impacts for EGU scrubbers are much greater than those for 

industrial boiler scrubbers. This reflects the large size of EGU scrubbers relative to 

scrubbers fitted to industrial boilers. The results in Exhibit 13 also show that the direct 

employment impacts associated with scrubber installation exceed the direct 

manufacturing impacts for EGU scrubbers, whereas the two are roughly the same for 

industrial boiler scrubbers. The difference in the distribution of direct labor impacts for 

EGU scrubbers versus industrial boiler scrubbers is consistent with the input we received 

 

13 Personal communication with Bob Roden, Carmeuse Lime & Stone; Mike Schantz, Chemical Lime; and Lance Steron, 

Headwaters. October 2009 

SUMMARY AND 

DISCUSSION OF 

RESULTS 
 

 16 

from industry representatives indicating that larger utility scrubbers are typically shipped 

as components and assembled at the plant. In contrast, industrial boiler scrubbers are 

more frequently shipped as whole units or as fewer components. 

As indicated above, we examined the employment impacts for Model Scrubber 3 using 

both EPA CUECost Program (reported as Model Scrubber 3A) and the OAQPS control 

cost manual cost algorithms (reported as Model Scrubber 3B). The former assumes that a 

boiler installs extensive scrubber support systems onsite, whereas the latter assumes that 

the unit contracts with off-site vendors for this support. The results in Exhibit 13 suggest 

that the one-time employment impacts for Model Scrubber 3 depend significantly on 

facilities’ decisions with respect to these support systems; these impacts are greater under 

the 3A assumptions than 3B by more than a factor of four. We suspect that the difference 

reflects not just the presence or absence of scrubber support equipment but also 

differences in the methodology employed by CUECost and the OAQPS cost manual 

algorithms. For example, CUECost may assume that each scrubber is highly customized, 

whereas the OAQPS cost algorithms may assume that industrial boiler scrubbers are more 

standardized. Identifying the key differences would require a detailed review of 

CUECost and the OAQPS control cost manual, which is outside the scope of this 

document. 

 The values presented in Exhibit 13 do not account for the portion of the U.S. scrubber 

market that is supplied by foreign manufacturers. However, we believe that effect of this 

omission on our results is negligible. Communications with industry sources suggest that 

virtually all manufacture of FGD scrubbers installed in the U.S. occurs domestically, due 

to the prohibitive cost of shipping such large pieces of equipment.14 In addition, nearly 

all materials used in scrubber manufacture are produced domestically as well, with few 

exceptions.15 However, one industry source did predict that off-shore fabrication of 

scrubbers may become viable in the future if demand emerges for smaller (i.e., shopassembled) scrubbers for industrial applications.16

The employment estimated in this document also do not account for induced employment 

effects. Laborers employed for scrubber fabrication, installation, and operational 

activities would spend their wages on goods and services, leading to additional 

employment impacts among the providers of these goods and services (and their 

suppliers). 

 

 

14 Personal communication with David Foerter, Institute of Clean Air Companies, December 10, 2009. 

15 Personal communication with Phil Blazer, Babcock and Wilcox, January 5 2010. For wet scrubbers, agitators and parts of 

the ball mill are purchased abroad; for dry scrubbers, atomizers are purchased abroad. 

16 Ibid, January 10, 2010. 
EXHIBIT 13. SUMMARY OF DIRECT AND INDIRECT EMPLOYMENT IMPACTS, BY MODEL SCRUBBER 

MODEL SCRUBBER 1 MODEL SCRUBBER 2 MODEL SCRUBBER 3A MODEL SCRUBBER 3

MODEL SCRUBBER DESCRIPTION 

 EGU Scrubber  Capacity: 980 – 

9,800 MMBtu/hr 

 EGU Scrubber  Capacity: 245 -980 

MMBtu/hr 

 Industrial Boiler 

Scrubber 

 Capacity: 250-500 

MMBtu/hr 

 Analyzed with 

CUECost 

 Industrial Boiler 

Scrubber 

 Capacity: 250-50

MMBtu/hr 

 Analyzed with 

OAQPS cost manual algorithm

DIRECT EMPLOYMENT IMPACTS 

Manufacturing Labor (Annual Equiv. FTE) 128 - 160 63 - 78 51 – 63 30 – 37 Installation Labor (Annual Equiv. FTE) 510 - 638 249 – 312 202 – 252 30 – 37 Operation, Maintenance, and Administrative Support Labor (Annual FTEs) 

103 39 29 11 

INDIRECT EMPLOYMENT IMPACTS 

Upstream Manufacturing Labor (Annual Equiv. FTE) 174 – 243 82 – 124 67 – 101 15 – 19 Downstream Vendor Labor (Annual FTEs) n/a n/a n/a 4 

Total One-Time Employment Impacts per Model Scrubber (Annual Equiv. FTE)1 848 – 1,001 409 – 493 333 – 400 77 – 91 Annual Recurring Employment Requirements per Model Scrubber (FTEs) per year)2

103 39 29 16 

Notes: 

1. Total one-time employment impacts do not reflect the sum of the range of direct and indirect one-time employment impacts be

estimated a range of impacts based on the percentage of capital costs that are attributable to labor. Taking Model Scrubber 1 a

assume that labor costs are 40 percent of total capital costs, we estimate direct employment impacts to total 638 FTEs and indiimpacts—which are related to the 60 percent of capital costs that are not attributable to direct labor—to be between 210 and 2

848 – 881 FTEs. Likewise, under the 50-percent-labor scenario, we estimate direct employment impacts to be 798 FTEs and indimpacts to be between 174 and 203 FTEs, for a total of 972 – 1,001 FTEs. Accordingly, the full range of one-time employment imScrubber 1 is 848 - 1,001 FTEs. 

2. Recurring employment impacts include labor required for the operation, maintenance, and administrative support for each scru
 

 18 

With respect to the application of these employment impact estimates in a policy setting, 

we recommend the following: 

 Distinguish between one-time and recurring labor requirements: The 

production and installation of a scrubber represents a one-time occurrence, 

whereas the operation and maintenance of a scrubber are ongoing activities. 

Because of this temporal inconsistency, one-time employment impacts should be 

reported separately from annual impacts. The two are additive in that they 

represent distinct components of the employment effect, but they cannot be added 

together because they are measured in different units. 

 Net employment impacts: While air pollution regulations may create jobs related 

to the manufacture, installation, and operation of scrubbers, the resources 

expended on scrubbers may divert resources from other uses, potentially reducing 

the number of jobs in other parts of the economy. Under these circumstances, the 

net employment impact associated with scrubbers would be less than the 

estimates presented in Exhibit 13. The magnitude of this effect, however, is 

uncertain and depends on a number of factors, including the extent to which 

resources expended on scrubbers would have otherwise been used by affected 

companies for production activities domestically or overseas. Related to this 

issue, scrubbers may replace existing emissions controls at facilities affected by a 

new rulemaking. In such cases, the recurring employment impacts associated 

with scrubbers should be estimated net of the recurring employment effects 

associated with the existing control technology. 

 Recognition of uncertainty: We recommend that EPA note the uncertainties 

surrounding our results when using them in the context of a regulatory impact 

analysis. These uncertainties include: 

o Lack of clarity on the share of scrubber capital costs that reflects labor 

costs associated with scrubber manufacturing and installation. 

o The use of a model scrubber approach. Actual employment impacts for 

individual scrubbers may deviate from these estimates due to sitespecific characteristics and other factors not accounted for in our 

analysis. 

o Incomplete estimates for indirect employment impacts. The indirect 

employment estimates presented in this document are not comprehensive 

because they only reflect one step in the production/value chain (i.e., 

firms that provide parts and materials to scrubber manufacturers). 

Therefore, we may underestimate the full indirect employment impacts 

associated with scrubber production. For example, our estimates do not 

include workers in steel mills producing metal sheets for scrubber 

components or laborers in the iron mines that supply steel mills. 
 

 A-1 

APPENDIX 

The analysis presented in the main body of this memo estimates the average employment 

impacts associated with the manufacture, installation, and operation of flue gas 

desulfurization (FGD) scrubbers. This appendix describes our efforts to assess the 

reasonableness of these estimates by consulting the following sources: 

1) Published estimates of the number of one-time and permanent jobs associated 

with the installation of scrubbers at large utility boilers; 

2) Input provided by industry experts on the estimates in the main body of this 

memorandum; and 

3) Other data sources with information related to key inputs used in our analysis. 

Through this process, we obtained information on the labor impacts associated with the 

installation, operation, and maintenance of FGD scrubbers at electric utility boilers of 

various sizes. We were not able to obtain validating information for industrial boilers. 

Based on our communications with industry experts, employment data for industrial 

boiler scrubbers are difficult to obtain given that these units generally install shopfabricated scrubbers, rather than the field-fabricated scrubbers commonly installed at 

electric utility boilers.17 We also did not find information that would allow us to validate 

our estimates of the direct employment impacts of ongoing administrative support for 

scrubber operation and maintenance, or for upstream or downstream indirect employment 

impacts. Accordingly, this appendix focuses on the manufacture and installation labor, 

operator labor, and maintenance labor estimates for utility boilers (Model Scrubbers 1 

and 2). These values are highlighted in grey in Exhibit A-1. 

Overall, our findings are as follows: 

 One-time employment impacts: We found that our estimates of the direct 

employment impacts of scrubber manufacture and installation at medium/large 

utilities were on the high end of the range of reported values from recent scrubber 

installations, though still generally consistent with the observations of industry 

experts. 

 Ongoing employment impacts: Numerous sources suggested that our estimates 

of the employment impacts of scrubber operations and maintenance at 

medium/large and small utilities may overstate these impacts, exceeding actual 

employment impacts by factors ranging from two to four. 

 

17 Personal communication with Robert Hilton, Alstom Power. March 31, 2011. 
 

 A-2 

EXHIBIT A-1. IEc ESTIMATES OF DIRECT EMPLOYMENT IMPACTS FOR 

SCRUBBERS INSTALLED AT ELECTRIC UTILITY BOILERS 

MEDIUM/LARGE 

UTILITY BOILERS 

(MODEL SCRUBBER 1) 

SMALL UTILITY BOILERS 

(MODEL SCRUBBER 2) 

SIZE RANGE 100-1000 MW 25-100 MW 

TYPICAL SIZE (USED IN CUECOST MODELING) 750 MW 100 MW 

MANUFACTURING LABOR (ANNUAL 

EQUIVALENT FTEs) 

128 – 160 63 – 78 

INSTALLATION LABOR (ANNUAL EQUIVALENT 

FTEs) 

510 – 638 249 – 312 

OPERATOR LABOR (FTE PER YEAR) 37 9 

MAINTENANCE LABOR (FTE PER YEAR) 38 19 

ADMINISTRATIVE SUPPORT LABOR (FTE PER 

YEAR) 

28 11 

Source: Compiled from main body of memorandum. 

As a first step in assessing the reasonableness of the employment impacts developed in 

the main body of this memorandum, we obtained published estimates of the actual 

number of jobs created by installations of scrubbers at medium and large utilities. Chad 

Whiteman, formerly at the Institute of Clean Air Companies, served as our primary 

source of such estimates. Between 2005 and 2009, Mr. Whiteman collected published 

estimates of both the maximum number of construction jobs on site during scrubber 

installation and the number of permanent jobs created at utilities for operation and 

maintenance of scrubbers.18 We also obtained information on the employment impacts of 

a scrubber installed at a coal-fired plant in New Hampshire from Dr. Lisa Shapiro at 

Gallagher, Callahan and Gartrell, P.C. In 2009, Dr. Shapiro prepared a report estimating 

the total economic impacts of the planned construction of a wet FGD scrubber at 

Merrimack Station in Bow, New Hampshire.19 Construction of the scrubber began in 

2009, and Dr. Shapiro has since confirmed the 2009 report’s estimates of the direct 

employment impacts of the scrubber’s installation with observed data.20 Finally, we 

obtained additional information on the employment impacts of scrubber installations at 

other large utility boilers from press releases and other publicly available documents. 

From these sources, we obtained 14 estimates of the number of jobs required for the 

 

18 Personal communication with Chad Whiteman, formerly of the Institute of Clean Air Companies. March 31, 2011. 

19 Shapiro, Lisa. “The Economic Impacts of Constructing a Scrubber at Merrimack Station.” Prepared for Public Service 

Company of New Hampshire, March 13, 2009. Available at 

http://www.gcglaw.com/resources/economic/pdfs/scrubber.pdf. 

20 Personal communication with Lisa Shapiro, Gallagher, Callahan and Gartrell, P.C. March 28, 2011. 

PUBLISHED 

ESTIMATES 
 

 A-3 

installation of scrubbers at medium and large utility boilers, and ten estimates of the jobs 

created for ongoing operation and maintenance of FGD scrubbers. These estimates are 

presented in Exhibits A-2 and A-3. Based on the descriptions of the jobs involved at each 

scrubber installation, we assume that these estimates do not include the employment 

impacts of manufacturing the scrubber units. Note that none of the sources described 

above provided information on the employment impacts of installing scrubbers at small 

utility boilers (e.g., smaller than 100 MW). 

EXHIBIT A-2. PROJECT EMPLOYMENT DATA FOR INSTALLATION OF FGD SCRUBBERS AT 

MEDIUM AND LARGE CAPACITY ELECTRIC UTILITY BOILERS 

COMPANY POWER PLANT 

CAPACITY 

(MW) 

MAXIMUM 

NUMBER 

OF JOBS 

ON SITE1 SOURCE 

Minnesota Power Taconite Harbor Energy Center 225 450 1 

Alabama Electric 

Cooperative 

Charles R. Lowman Power Plant, Unit 

1 

258 600 1 

Sunbury Generation Sunbury Generation 425 300 1 

Public Service of NH Merrimack Power Station 460 300-5002 2 

Reliant Energy Cheswick Generating Station 580 300 1 

Constellation Energy Brandon Shores Power Plant 643 300 1 

American Electric Power Connesville Generating Station, unit 4 780 500 1 

Tennessee Valley Authority Bull Run 881 245 1 

Tennessee Valley Authority Paradise Fossil Power Plant, Unit 3 977 300 1 

Ameren Sioux Power Plant 986 600 3 

Allegeny Energy Fort Martin Power Plant 1,107 350 1 

Reliant Energy Keystone Power Plant 1,700 800 1 

Allegheny Energy Hatfield Ferry 1,710 3503 4 

Duke Energy Belews Creek Power Plant 2,240 950 5 

Sources: 

1. Information collected from publicly available sources by Chad Whiteman, formerly at the 

Institute for Clean Air Companies. 

2. Information obtained from the Public Service of New Hampshire by Lisa Shapiro, Gallagher, 

Callahan and Gartrell, P.C. 

3. “Ameren’s $600M Sioux Plant scrubbers open.” St. Louis Business Journal. November 4, 2010. 

Available at http://www.bizjournals.com/stlouis/news/2010/11/04/amerens-600m-siouxplant-scrubbers.html. 

4. “Hatfield’s Ferry Power Station Scrubber Project.” Available at 

http://www.alleghenyenergy.com/Newsroom/Scrubber.Hat.2page.pdf. 

5. “Duke emission-scrubbers running at Belews Creek.” Winston-Salem Journal. June 3, 2008. 

Available at http://www2.journalnow.com/news/2008/jun/03/duke-emission-scrubbersrunning-at-belews-creek-ar-381454. 

Notes: 

1. Except where otherwise noted, estimates of on-site jobs created are based on observation of 

actual scrubber construction. 

2. 300 workers were observed on site. An additional 200 off-site workers (including designers and 

delivery personnel) were estimated based on a review of the project’s contracts. 

3. Number of jobs projected before construction began. 
 

 A-4 

As Exhibit A-2 shows, at the 14 scrubber installations for which we collected data, the 

direct employment impacts of installation ranged from 245 to 950 FTEs, with an average 

of 464 FTEs. In the main body text, scrubbers installed at medium and large utility 

boilers are represented with a model scrubber installation covering a size range of 100-

1,000 MW. For the ten utility boilers in the exhibit with capacities between 100 and 

1,000 MW, the average number of on-site jobs required for scrubber installation is 405. 

By comparison, our estimate of 510-638 annual equivalent FTEs for a model scrubber 

installed at a 750-MW boiler is on the high side of the observed range, exceeding the 

average by between 105 and 233 FTEs. 

As shown in Exhibit A-3, the number of jobs created for the operation and maintenance 

of installed scrubbers at the ten utility boilers examined ranged from 15 to 55 FTE per 

year, with an average of 28.5 FTEs. At the seven boilers with capacities between 100 and 

1,000 MW (i.e., with capacity consistent with the Model Unit analyzed in the analysis in 

the main body text), the average number of O&M jobs created was 25.7 FTEs. Our 

estimate of 75 FTEs created for the O&M of scrubbers installed at medium to large utility 

boilers falls outside the range presented in Exhibit A-3 and exceeds the average number 

of O&M jobs at comparable boilers by a factor of nearly three. 

In addition to obtaining observational data on the actual number of jobs created for the 

installation, operation, and maintenance of scrubbers at utility boilers, we also solicited 

input from industry experts. We contacted representatives of scrubber manufacturers, 

industry associations, and utility companies, though most were unable to comment on our 

estimates. The information that we present in this section draws from two representatives 

of Alstom Power:21 

 James Yann, Managing Director for North American Environmental Control 

Systems 

 Robert Hilton, Vice President of Power Technologies for Government Affairs 

In testimony delivered to the U.S. Senate Committee on Environment and Public Works 

during a joint hearing entitled “Clean Air Act and Jobs,” Mr. Yann noted that a wet flue 

gas desulfurization installation on a 500-600 MW unit will provide “the equivalent of 

about 775 full time jobs... not including jobs provided for all the equipment suppliers and 

delivery services involved in delivering materials and equipment to the site.”22 Assuming 

that this estimate includes labor for both manufacture and installation of scrubbers, this 

number falls within the range of 638 to 798 annual equivalent FTEs reported in the main 

body text. 

 

21 Alstom Power supports the power generation industry through the design, manufacture, servicing, and supply of products 

and systems. According to Mr. Yann’s recent Senate testimony, Alstom Power is the world’s largest air pollution control 

company. 

22 Testimony of James Yann, Managing Director for North American Environmental Control Systems, before the U.S. Senate 

Committee on Environment and Public Works, Subcommittees on Clean Air and Jobs. March 17, 2011. 

INDUSTRY 

EXPERTS 
 

 A-5 

EXHIBIT A-3. ESTIMATES OF JOBS REQUIRED FOR OPERATION AND MAINTENANCE OF 

FGD SCRUBBERS AT INDIVIDUAL MEDIUM AND LARGE ELECTRIC UTILITY BOILERS 

COMPANY POWER PLANT 

CAPACITY 

(MW) 

NEW JOBS 

FOR 

SCRUBBER 

O&M1 SOURCE 

Sunbury Generation Sunbury Generation 425 15 1 

Reliant Energy Cheswick Generating Station 580 202 2 

Constellation Energy Brandon Shores Power Plant 643 20 1 

Duke Energy Marshall Steam Station 670 25 1 

American Electric Power Connesville Generating Station, 

unit 4 

780 40 1 

Tennessee Valley Authority Paradise Fossil Power Plant, 

Unit 3 

977 40 1 

Ameren Sioux Power Plant 986 20 3 

PPL Mountour 1,6253 30 1 

American Electric Power Kammer-Mitchell 1,6324 55 1 

Reliant Energy Keystone Power Plant 1700 20 1 

Sources: 

1. Information collected from publicly available sources by Chad Whiteman, formerly at the 

Institute for Clean Air Companies. 

2. “Springdale Power Plant To Get $250M Scrubber.” Pittsburgh Tribune-Review. July 6, 2006. 

Available at http://www.pittsburghlive.com/x/pittsburghtrib/news/s_460793.html. 

3. “Ameren’s $600M Sioux Plant Scrubbers Open.” St. Louis Business Journal. November 4, 

2010. Available at http://www.bizjournals.com/stlouis/news/2010/11/04/amerens-600msioux-plant-scrubbers.html. 

Notes: 

1. Except where otherwise noted, estimates of new jobs created for operation and 

maintenance of scrubbers are based on observation of actual scrubbers in operation. 

2. Number of jobs projected before scrubber was installed. 

3. Combined capacity for two units at the Montour plant that operated FGDs in 2009, 

according to DOE’s Form EIA-923 Database. 

4. Combined capacity for two units at the Mitchell plant that operated FGDs in 2009, 

according to DOE’s Form EIA-923 Database. 

Communication with Mr. Hilton confirmed that our overall estimate of the direct 

employment impacts of manufacturing and installing scrubbers at medium and large 

utilities was in line with Mr. Yann’s testimony.23 Mr. Hilton also commented on other 

values that we used in our memorandum to estimate direct employment impacts of 

scrubber fabrication and installation, noting that our estimates of scrubber capital costs 

for a 750-MW utility boiler were lower than he would expect, as were our estimates of 

 

23 Personal communication with Robert Hilton, Vice President of Power Technologies for Government Affairs, Alstom Power. 

March 30, 2011. 
 

 A-6 

the total annual compensation of boilermakers and of mechanical and chemical engineers. 

If these values are indeed too low, it is possible that they would have offsetting effects on 

our estimate of the total direct employment impacts of scrubber manufacture and 

installation. Increasing capital costs would increase the direct labor costs for scrubber 

manufacture and installation (assuming that the percent of capital costs attributable to 

labor remains constant), thereby increasing direct employment impacts. However, 

increasing total annual compensation for engineers and boilermakers would reduce the 

number of annual equivalent FTEs associated with a particular direct labor cost. 

Exhibit A-4 shows how the estimate of the employment impacts of scrubber installation 

changes when the total annual compensation for boilermakers increases from $60,000 

(the value used in the main body text, based on mean annual wage data from the Bureau 

of Labor Statistics) to $100,000 (the value suggested by Mr. Hilton, based on review of 

wages posted by the Boilermakers Local 169).24 As the exhibit shows, increasing total 

annual compensation for boilermakers by $40,000 decreases employment impacts for 

medium/large utility boilers by 201-251 FTEs and for small utility boilers by 98-123 

FTEs. The illustrative analysis in Exhibit A-4, however, leaves the average capital cost 

of a scrubber unchanged relative to the values used in the main body text, as Mr. Hilton 

did not provide an alternative estimate for this cost. 

EXHIBIT A-4. COMPARISON OF EMPLOYMENT IMPACTS OF SCRUBBER 

INSTALLATION, USING TOTAL ANNUAL COMPENSATION FOR BOILERMAKERS OF 

$60,000 AND $100,000. 

MEDIUM/LARGE UTILITY 

BOILERS (MODEL 

SCRUBBER 1) 

SMALL UTILITY BOILERS 

(MODEL SCRUBBER 2) 

INSTALLATION LABOR ASSUMING $60,000 

TOTAL ANNUAL COMPENSATION FOR 

BOILERMAKERS (ANNUAL FTEs) 

510 – 638 249 - 312 

INSTALLATION LABOR ASSUMING $100,000 

TOTAL ANNUAL COMPENSATION FOR 

BOILERMAKERS (ANNUAL FTEs) 

309 – 387 151 - 189 

Mr. Hilton also noted that our estimates of the operating, maintenance, and administrative 

and support labor impacts of FGD scrubbers significantly overestimated the true labor 

requirements of such systems. Mr. Yann’s testimony also noted that labor requirements 

for operation and maintenance of scrubbers at large utility boilers can range from 10 to 30 

FTEs, much less than the 75 FTEs estimated in the main text. Mr. Hilton recognized that 

 

24 Email communication with Robert Hilton, Vice President of Power Technologies for Government Affairs, Alstom Power. 

March 30, 2011. Boilermaker wages are posted at 

http://www.boilermakerslocal169.com/PDF%20FILES/LOCAL%20AREA%20WAGES%2001%2001%202011.pdf. 
 

 A-7 

models such as the CUECost Program used in our analysis assume that operating and 

maintenance costs are a flat percentage of total capital costs, but noted that in his 

experience, scrubber operation is largely automated, with a typical FGD unit requiring no 

more than eight operators. Furthermore, he noted that utilities usually use the general 

maintenance pool for the entire plant to perform maintenance on scrubber systems, 

making it difficult to determine the extent to which scrubbers actually require additional 

maintenance personnel.25 Mr. Hilton supported his estimates by contacting two large 

utilities with wet scrubber systems, one with 12 total personnel (including a supervisor, 

operators, maintenance personnel, a computer tech, and a chemist), and the other with 16 

(excluding maintenance, which comes out of the plant’s overall maintenance pool).26 

We consulted two additional sources to assess the reasonableness of our O&M labor 

estimates for scrubbers at small, medium, and large utility boilers. Using formulas from 

the Integrated Planning Model (IPM), we first checked to see if the operating labor cost 

estimates generated by the CUECost program were consistent with other models used by 

EPA.27 For model scrubbers at 750-MW and 100-MW utility boilers, the IPM formulas 

for operating labor costs produced estimates identical to those generated by CUECost, 

suggesting that CUECost simply uses the IPM formulae or vice-versa. 

We also reviewed the U.S. Energy Information Administration’s Form EIA-923 database, 

which collects information on power plant generation and fuel consumption, as well as 

data on flue gas particulate (FGP) and FGD control operations. We selected 367 utility 

boilers from the database (1) that operated scrubbers in 2009 and (2) for which we could 

conclusively identify the capacity of the generating unit associated with the scrubber. Of 

these 367 boilers, 137 had capacities less than 100 MW, corresponding to the small utility 

boilers in our analysis, and the remaining 230 had capacities between 100 MW and 1,000 

MW, corresponding to the medium/large utility boilers in the analysis. On average, the 

selected boilers with capacities between 100 MW and 1,000 MW spent about $980,000 

on operating labor for scrubbers in 2009, while the selected boilers with capacities less 

than 100 MW spent an average of $154,000. These numbers are substantially lower than 

the CUECost program’s estimates of $2,310,000 and $590,000 for medium/large utility 

boilers and small utility boilers, respectively. Exhibit A-5 shows how our estimates of 

operating labor requirements decrease when the average operating labor costs for each 

boiler type from the Form EIA-923 data are used in place of the CUECost estimates. The 

revised estimate of 16 FTEs for operation of scrubbers at medium/large utilities is 

consistent with the values supplied by industry experts. If we adjust maintenance and 

administrative support labor (the other two categories of permanent employment) in 

 

25 Ibid. 

26 Email communication with Robert Hilton, Vice President of Power Technologies for Government Affairs, Alstom Power. 

March 30, 2011. 

27 IPM formulas were obtained from Documentation Summary for EPA Base Case 2004 Using IPM (V.2.1.9) (2004 Update). 

Appendix 5.1: SO2 Scrubber Engineering Cost Equations. Available at http://www.epa.gov/airmarkets/progsregs/epaipm/docs/bc5emission.pdf. 

OTHER DATA 

SOURCES 
 

 A-8 

proportion to the decrease in operating labor, our estimates of total recurring annual 

employment impacts would decrease from 103 and 39 FTEs per year for medium/large 

and small utility boilers, respectively, to 44 and 10 FTEs. 

EXHIBIT A-5. OPERATING LABOR REQUIREMENTS FOR SCRUBBERS AT SMALL AND 

MEDIUM/LARGE UTILITY BOILERS USING LABOR COST ESTIMATES DERIVED FROM 

CUECOST AND LABOR COST DATA OBTAINED FROM THE FORM EIA-923 DATABASE

MEDIUM/LARGE 

UTILITY BOILERS 

(MODEL SCRUBBER 1) 

SMALL UTILITY BOILERS 

(MODEL SCRUBBER 2) 

ORIGINAL ESTIMATES 

BASED ON CUECOST 

OUTPUTS 

OPERATING LABOR 

COST (THOUSAND $) 

$2,310 $590 

OPERATING LABOR 

(ANNUAL FTES) 

37 9 

REVISED ESTIMATES 

USING FORM EIA-923 

AVERAGE OPERATING 

LABOR COSTS 

OPERATING LABOR 

COST (THOUSAND $) 

$980 $153 

OPERATING LABOR 

(ANNUAL FTES) 

16 5 

The information presented in this appendix suggests that our employment impacts 

estimates for scrubber manufacturing and installation are fairly consistent with other 

estimates. While near the high end of the range, our estimates of employment impacts for 

scrubber installation (excluding manufacture) are within the range of values reported for 

specific scrubber installation projects at medium/large utility boilers. In addition, our 

overall estimates of employment impacts of scrubber installation and manufacturing at 

medium/large utility boilers are consistent with testimony recently delivered by an 

industry expert before the U.S. Senate Committee on Environment and Public Works. 

While the available data suggest that our employment impact estimates for scrubber 

manufacturing and installation are reasonable, the sources that we consulted indicate that 

we may overestimate the labor required to operate and maintain scrubbers at 

medium/large capacity electric utility boilers. This may reflect the overestimation of 

scrubber operating and maintenance costs in EPA’s CUECost model. 

CONCLUSION