1



# An Assessment **of the Feasibility**  **of Retrofits for the**  **Mercury and Air Toxics**  **Standards Rule** 

**U.S. Environmental Protection Agency Office of Air and Radiation** 

**FINAL DRAFT**  **11/ 2**  **2 /11** 

**Novem ber__** **, 2011**2 

### Abbreviations and Glossary ACI Activated Carbon Injection

– controls mercury APC Air Pollution Control(s)

– ACI , DSI, FGD, etc CAIR Clean Air Interstate Rule CSAPR Cross State Air Pollution Rule DSI Dry

Sorbent Injection

– controls acid gasses ESP Electrostatic Precipitator

– controls particulates FF Fabric Filter (baghouse)

– controls particulates FGD Flue Gas Desulfurization

– controls SO 2 

### and acid gasses GW Gigawatt(s)

– one thousand MW GWeq GW(s) of WetFGDeq HAPS Hazardous Air Pollutants IPM Integrated Planning Model MATS Mercury

and Air Toxics Standards MW Megawatt(s)

– one million watts (1000 kilowatts) NEEDS National Electric Energy Data Sy stem SCR Selective Catal ytic Reduction

– controls nitrogen oxides WetFGDeq Wet FGD equivalent - The amount of an APC technolo gy

expressed as its GW equivalent in wet FGD technology3



# An Assessment of the Feasibility of Retrofits **for the Mercury and Air**  **Toxics Standards**  **Rule PREFACE**  This paper summarizes an EPA assessment of the feasibility of retrofitting various air pollution control (APC ) technologies to coal - fired power plant units in the U.S. for power sector compliance with EPA’s Mercury and Air Toxics Standards Rule (MATS) . Fo llowing are key dates associated with the Rule:
 December 2011

– Final  February 2015

– Statutory Compliance Deadline  February 2016

– Compliance Deadline with extension from permitting authorities EPA has projected the quantity of each APC technology that may need to be newl y retrofitted and in service b y the compliance date(s). EPA used the latest version of its IPM model to anal yz e which APC technologies would likely be used, and in what quantitie s, to achieve compliance with MATS . **Result: EPA’s assessment shows that**  **a reasonable, moderately paced effort of the power sector**  **and supporting industry , including some early starts,**  **would result in the**  **majority of**  **the needed retrofits being installed b y**  **February 2015 with**  **the possibility of some**  **installations needing up to an additional year**  **for completion .**  **In order for all retrofits to be completed by**  **February 2015,**  **mo re**  **projects would have to start early and the s ector would**  **have to engage in a more aggressive**  **deployment program.**  **In the event that individual projects cannot be completed by the**  **February 2015 statutory deadline for compliance, the**  **Clean Air Act offers affected sources the opportunity to apply for a one -** **year extension. ANALYTICAL APPROA**  **CH** S ite - specific feasibility

studies are typically performed before owners commit to an APC retrofit plan for a unit or plant . However, an assessment of the feasibility of retrofitting a sector- wide aggregation of APC sy stems to achieve timel y compliance w ith MATS on a national scale cannot replicate the same level of detailed anal ys is of either specific plants or of individual components of the APC “supply chain.” Various detailed anal ys es of the supply chain have been conducted for past rules, usually res ulting in a significant underestimate of what was ultimately achieved in practice 1



### . Aside from the difficulties of making detailed “bottom - up” anal ys es of either plants or suppl y chains on a national scale, such anal ys es miss the mark because no single pl anner can be responsible for the strategies of competitive participants in the supply chain,4



### much less for owner compliance strategies at all affected units . In reality, the sector will benefit from the creative interaction of a multitude of actors in the marketplace developing routes to compliance. For the purposes of this Rule, this assessment adopts a broad - scale, order- ofmagnitude estimate of what appears reasonabl y feasible nationwide based on the pattern of power sector deplo ym ent activity in the recent past. EPA recognizes that a wide range of site specific conditions will result in a range of “better - than - average” and “worse - than - average” project outcom es as regards cost and schedule. In developing a broad - scale estimate, the influence of differences in local factors and in past, current, and future circumstances has been considered at an appropriate level of detail. **RECENTLY DEMONSTRATE D DEPLOYMENT CAP**  **ABILITIES OF THE APC SUPPLY CHAIN**  Annual GW capacity

additions are plotted in Figure 1 for the two most resource intensive APC sy stems: flue gas desulfurization ( FGD ) and selective catal ytic reduction ( SCR) . Figure 1 data reflect the year that systems went into service. These data are from the National Electric Energy Data Sy stem (NEEDS ) 2 

### , as provided by plant owners and updated by EPA. They

include both retrofitted APC and s ys tems installed as part of new coal plant construction. The FGD component is a sum of wet and dry FGD technologies. Dry

FGD comprises about 12% of total 1990 - 2011 FGD additions. Annual installations of new coal - fired power plant capacity are also plotted to indicate the size of its role in contributing to APC additions. Although there have been no new coal power projects ordered in the past two years, several are still in construction. The supply chain for coal power plants is thus an active and applicable set of resources (including engineers, manufacturers, fabrication shops, craft lab or, construction managers, etc.) that could be tapped to rapidl y enlarge the APC supply chain. Figure 1: FGD, SCR, and Coal Plant Annual GW Additions, New and Retrofit

Source: EPA, NEEDSv4.10PTR 0. 0 10. 0 20. 0 30. 0 40. 0 SCR , GW FGD , GW New Coal, GW5



### The large, rather abrupt peaks in annual SCR additions (2 000 and 2003) for compliance with the NOx SIP Call are apparent in Figure 1. A more gradual build up to the historic 2009 peak for annual FGD additions in anticipation of the Clean Air Interstate Rule ( CAIR) is also apparent. These data depict a recent major ramp - up in the APC deploy ment capabilities of all industry participant s, including plant owners, the APC supply chain, and state and local permitting agencies. These expanded APC capabilities are still ac tive today , even if not fully utilized. EPA believes that in today ’s post - recession economy it is reasonable to expect that these experienced capabilities can be quickly re - engaged, can quickly

return to production at historic rates, and can be quickly

augmented b y additional available resources to increase production rates beyond historic levels. **RETROFIT PROJECTIONS FOR**  **MATS** Table 1 shows the types and quantities of APC retrofits that EPA has projected the sector to adopt for MATS compliance. “Retrofit GW ” refers to the total generating capacity of coal - fired units that are projected to receive each APC technology . For example, the table shows that the Rule may require the retrofitting of dry FGD s ys tems to 2 0 GW of coal - fired generating capacity . A sum of the Retrofit GW capacities across the categories in Table 1 would be greater than the amount of generating capacity affected by

retrofits because many

generating units will elect to install more than one APC technology . Table 1: MATS Retrofit Technologi es and GW Capacity required b y 2015 for Coal - fired Units **APC Technology**  **Wet**

**FGD Dry FGD** 

**w/ FF*** **SCR FF**  **DSI ACI**  **FGD up**  **grades** ****** **ESP**

**up grades**  ******* **Retrofit GW**  **0 20**  **0 85**  **44 99**  **63 34**  Source: EPA, derived from IPMv4.10_MATS * 17 GW of FF included with DryFGD is in addition to the 85 GW of FF installed for PM control or in conjunction with DSI or ACI. ** 63 GW of existing FGDs are assumed to be upgraded to achieve adequate HCl removal ***34 GW of existing ESPs are assumed to be upgraded to achieve adequate PM removal 

### At any particular coal - fired power plant it is possible that none or several of these APC technologies might be retrofitted for MATS compliance. Depending on the plant, they might be retrofitted to each individual unit, or some to one unit but not others, and some might be sized to serve multiple units at a plant. Under MATS , plant operators have the flexibility to design for plant - wide compliance with the rule’s emission rates, rather than requiring each unit to meet the specified standards exact ly , which further increases the likely diversity of compliance strategies that may reduce cost and time for implementation. These and many other site - and ownerspecific factors that cannot be fully considered in IPM modeling would influence plant owner de cisions on how to apply any of these s ys tems on individual units. Therefore, although IPM projections based on “model plants” have proven to be excellent predictors of economic6



### technology

deploy ments on a state - wide, regional, and national basis, they are not intended and should not be interpreted as authoritative projections for any single plant or unit. **METRIC FOR TOTAL RET ROFIT DEPLOYMENTS (G** **W WetFGDeq)**  EPA has adopted a single metric to represent all APC technologies in this analysis. Use of a single m etric facilitates an extrapolation of historic deploy ment rate data for wet and dry FGD and SCR to assess feasible future deploy ment rates needed for the retrofit technologies projected for MATS . Such a single metric permits assess ment of the overall combined feasibility of all APC retrofits projected . This metric should be regarded as “average,” not capturing the specifics of any particular site, but representing average difficulty across many projects. As shown in Table 2, EPA converted the projected Retrofit GW capacities of each technology from Table 1 into an “equivalent wet FGD capacity” (WetFGDeq). The total ( 64 GW WetFGDeq) is the future APC deploy ment goal for this retrofit feasibility analy sis. One example of this conversion is that retrofitting 2 0 GW of dry FGD s ys tems is considered roughl y equivalent in terms of cost and resources to the retrofitting of 1 6 GW of wet FGD s ys tems. The e quivalence factor s are computed as the ratio of the capital cost of each technology to that of a wet FGD s ys tem . C apital cost includes the installed and commissioned retrofit project elements (engineering, equipment, construction labor, project management, etc.), excluding only financing costs and owner’s “home office” costs. The capital costs are derived from IPMv4. 10_MATS technology

assumptions for single - unit sy stems . Table 2: MATS Retrofit Technologies and GW WetFGDeq Capacity **APC Technology Retrofit** 

**GW Equivalence** 

**Factor WetFGDeq** 

**GW Wet FGD**  0 1 0 **Dry FGD** 20 0.8 16 **SCR** 0 0.4 0 **FF** 85 0.3 26 **DSI** 44 0.1 4 **ACI** 99 0.02 2 **FGD Upgrade**  63 0. 2 1 3 **ESP Upgrade** 34 0.1 3 **Total 6**  **4** Source: EPA Note: Some values may not add exactly due to rounding. 

### WetFGDeq values are intended to approximately represent the relative GWeq capacity, capital cost, and supply

chain deploy

ment resources associated with APC technologies individually and in total, on the basis of current market conditions . They do not directl y represent the relative calendar times required to install individual technologies. Wet FGD was selected as the “base” technology

for this metric because it has been widely deployed, is f

amiliar to the industry , has the highest capital cost, uses the most supply chain resources, and requires the longest schedule7



### for deplo ym ent. Use of the single WetFGDeq metric is intended to allow the public to more readil y visualize and consider a complex set of relationships among many factors ( including site conditions, APC designs, and supply chains ), and to consider the aggregate level of effort projected for the sector to reach overall MATS compliance . **TRENDS IN TOTAL RETR OFIT DEPLOYMENT EFFO**  **RT (GW WetFGDeq)**  Figure 2 shows the total annual historical APC additions from Figure 1 and current APC commitments for the future using the WetFGDeq metric. Figure 2 reveals the pattern of retrofit deploy ment driven solely by CAIR, showing separately the WetFGDeq of APC capacity installed for other reasons. Note that the retrofit capacity depicted as “ other” in Figure 2 has separately identified drivers, but the portion of that “other” capacity deployed inside the CAIR region may

have also been timed in coordination with that rule. Figures 1 and 2 both demonstrate the sector’s earl y deplo ym ent of APC contro ls in advance of CAIR compliance deadlines of 2009 for NO x 

### and 2010 for SO 2 

### . Solely CAIR - driven APC deploy ments of about 13 GW WetFGDeq occurred within two and a half years after CAIR’s finalization in mid - 2005, showing that at least 40 % of total CAIR - only APC effort through 20 10 was sufficiently planned for installation to start before or immediatel y upon finalization of the rule . Figure 2: Historical / Projected APC and New Coal Annual Additions

Source: EPA (NEEDS) through 2011; Data beyond 2011 d erived with permission from IHS CERA "Announced Environmental Retrofit Project Database: November 2010 Update." 

### ADDITIONAL SUPPLY CHAIN RESOURCES EPA estimates that on a GWeq basis, a new coal - fired plant would have at least 5 times more resources invo lved than a new retrofit wet FGD s ystem. This is illustrated in Figure 3, which is similar to Figure 2 except that the actual GW values for New Coal have been converted to GW WetFGDeq. The comparable GWeq values indicate that there may now be as many under utilized and potentially

available New Coal resources as were being used in the APC supply chain at its 0.0 10.0 20.0 30.0 40.0 APC CAIR only, GW W etFGDeq APC other, GW W etFGDeq New Coal, GW8



### peak. The currently available APC resource pool might thus be up to twice as large as would otherwise be expected, and well able to support a major ramp - up of its deploy ment capabilities. Although not quantified here, there is a similar, available, and to some extent transferrable resource pool that has until recently been supporting large annual deploy ments of the gas turbine combined - cycle power plant business line. NEEDSv4.10 PTR shows gas combined - cycle capacity additions of 7 GW (actual) in 2009, 3 GW in 2010, and 7 GW for 2011. Figure 3: Historical / Projected APC and New Coal Annual Additions

Source: EPA 

### SCHEDULE OUTLOOK FOR **RETROFIT INSTALLATIONS**  APC Retrofit Planning EPA thinks it likely that the majority

of coal - fired power plant owners performed site - specific APC retrofit studies sometime prior to or in the seven years since CAIR was proposed in 2004. CAIR has remained in effect and will transition in 2012 to the recentl y finalized Cross State Air Pollution Rule (CSAPR) , which continues to focus the industry on retrofit planning . All owners have long been aware that a MATS Rule would be forthcoming and that it would have a complian ce date three years after the final rule is effective, as mandated by statutory language in the Clean Air Act . EPA therefore expects that many owners have already determined which of their units would eventually get some combination of APC systems . Such ex isting preparatory

work should make it possible for many owners to quickly

take steps toward making commitments for these sy stems. Earl y Movers CAIR was proposed in early 2004 and finalized in mid - 2005. It established compliance dates in 2009 for NO x 

### and 2010 for SO 2 

### . As discussed above, Figures 1 and 2 show that a significant fraction of “earl y mover” plant owners must have done their planning and made commitments well in advance of the CAIR final rule date . Southern Company ’s earl y 2003 commitment to a large program of APC retrofits, well in advance of CAIR’s finalization, is one example of an “earl y mover” making major earl y APC deploy ment decisions, leading to 8 , 000 MW of installed wet FGD sy stems on 14 units . 3 

### Subsequent commitments from many more 0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0GWWetFGDeq APC, GW W etFGDeq New Coal, GW W etFGDeq9



### owners encouraged a continuing expansion of the supply chain, with further increases in annual deploy ments. EPA anticipates that this pattern will be repeated for the MATS R ule. “ E arl y movers” making commitments in advance of the Rule are better positioned to avoid any potential increase in APC sy stem costs when the supply chain ramps up to deploy a new peak in retrofit installations in a short period of time . EPA clearl y saw this earl y mover advantage occur wi th CAIR, and e arl y movers may have already

triggered the beginning of a major new ramp - up of the APC supply

chain for the MATS Rule . Benchmarking to a New Coal Plant Schedule A ctual schedule durations for APC retrofits have varied widel y from plant to plant , as will be discussed later. There are many reasons for such variability , and for the fact that some retrofit projects apparently had lengthy schedules of 4 years or more. EPA believes that almost all future APC retrofits can be completed far more quickly than were historical APC projects. EPA’s perspective on this matter derives in part from a comparison of past APC schedules to the project schedule for an entire new coal - fired unit , including its APC sy stems. Springervil le Unit 3, for example , is a 400 MW coal - fired unit that became operational in July 2006, some 33 months after the turnkey engineering - construction contractor was given a notice to proceed with engineering. 4 

### Springerville was clearly on an accelerated sche dule, as its original planned schedule was about 38 months . The main point here is that ty pical schedules for large complex power projects can be significantly accelerated. Because the scope of the work involved for an entire new coal unit is at least five times that of a retrofit wet FGD s ys tem, EPA believes that even the most complex retrofit APC project can be significantl y accelerated as well. EPA therefore also believes that its schedule assumptions used in CSAPR , 27 months for retrofitted wet FGD and 21 months for dry FGD, remain reasonable expectations for both CSAPR and MATS . Retrofit Project Schedules The recently surveyed wet FGD project schedules shown in Table 3 are not all representative of the shorter project schedules that EPA expects to be prevalent under the MATS Rule. Some of these projects were conducted in a period of regulatory uncertainty without a strong driver for accelerated retrofit completion, tie - in, and subs equent operation

– particularl y where initiating such operation increases marginal operating costs without a certain regulatory

benefit. Factors that will likely accelerate project schedules under MATS include the use of overtime and/or two - shift work sch edules during construction, and 5 - or 6 - day work weeks, instead of the 4 - day x10 - hr schedules often used to minimize cost when time is not of the essence . Increased use of offsite modularization and pre - fabrication of APC components can also shorten schedules and reduce job hours. Also, m any of the wet FGD projects performed in response to CAIR or to other legal actions in the same time frame took longer to perform than under normal market conditions due to the initial high demand for a large number of comp lex wet FGD s ys tems in a short period of time. Extended lead times in the 2007/2008 time period, as high as 18 months for key wet FGD engineered equipment ( such as large recycle pumps, large motors, and chimneys ) contributed to extended wet FGD project dur ation s. Increased lead times quickly subsided as the supply chain processed the initial influx of orders f or this equipment.10



### Neither CSAPR nor MATS , however, as shown in Table 1, is projected to require a significant number of large, complex wet FGD sy stem s. The relativel y much simpler dry FGD, fabric filter, and other even simpler dry sorbent injection ( DSI) and ACI s ys tems that may be required under the MATS rule will take significantl y less time to plan, design, install, and commission than wet FGDs. Ta ble 3: Recent Wet FGD Project Deploy ment Schedules **Wet FGD Projects Schedules (without**  **planning)** 1 3 26 – 35 months 8 37 – 5 2 mo nths Source: EPA (see Appendix A) 

### Motivation for MATS Rule Compliance There is a notable difference between CAIR and the MATS Rule as regards incentives for plant owners to be earl y movers - making retrofit commitments in advance of the final rule date. CAIR included provisions for the banking and trading of emission allowances, and thus offered unit owners the flexibility to deliberate over time varying compliance strategies that could be offset by allowance purchases if eventual emissions exceeded allowance allocations to that unit. The MATS Rule , on the other hand, does not offer trading flexibility and requires plant - level compliance as soon as the regulatory period begins . Compliance planning under MATS will involve assessment of the long - term differences between the costs of keeping in service an existing unit with newl y retrofitted controls and the costs of building and operating a new generating unit that complies. In some cases , it may be possible for owners to delay a retrofit decision until after the MATS Rule is final and still be able to make the necessary

deploy ments in good time. In some other cases, however, any delay in making a retrofit commitment may compromise a unit’s ability to meet the statutory MATS Rule compliance deadline. Therefore, the rational expectation should be that affected unit owners would have be en more motivate d to move earl y on retrofit planning decisions in advance of the MATS Rule than they

were to anticipate actions under previous trading - based regulations. Ultimately , affected plant owners should already have factored in the risk of noncompliance with the MATS Rule as they

planned the futures of their coal units. **DEVELOPMENT OF APC D EP**  **LOYMENT SCENARIOS** Current Supply

Chain Activity Current activity levels for various participants in the supply chain depend on when their particular activity (engineering, manufacturing, fabrication, construction, etc) occurs in an APC project schedule. As shown in Figure 3, the deploy ment rate is currentl y in a second year of decline . Therefore, the activity level of front - end engineering and shop fabrication resources has by now decreased more than that of construction resources (relativel y), and both have decreased very significantly. Overall, the current activity level of front - end resources is supporting committed projects that will likely come on - line in the 2013 - 2015 tim e frame, corresponding to an annual baseline deployment rate of 10 GW WetFGDeq or less . Not shown in Figure 3 are any additional deployments that may be made b y 2014 in response to CSAPR . EPA’s IPM anal ys is for CSAPR projected a need for at most 6 GW of FGD11



### retrofits b y 2014 . This is an amount that has likely already accelerated a ramp - up in supply chain activity , but, as discussed below, is well within the previously demonstrated capabilities of the supply chain, even when added to retrofits that may be needed for MATS. Moderate Future Deplo yment Historical peak annual APC deploy ments were nearl y 30 GW WetFGDeq in 2009. Average ye ar- on - ye ar growth in annual deplo ym ents over the 3 - ye ar period from 2006 to the peak in 2009 was 45%. A renewed ramp - up in deploy ment capability , likel y already started in early

2011 , would have start ed from roughl y the same reduced level of activity that preceded the sustained ramp - up for CAIR . With these observations EPA developed a “moderate” APC deplo yment scenario, as follows (see Table 4):
 W ithin three years (b y early 2014) a moderate effort by the suppl y chain could put in service APC retrofits of at least 20 GW WetFGDeq for MATS . This is significantly less than the nearl y 30 GWeq deployed in a similar time frame under CAIR , and leaves demonstrated capability

for limited additional deploy ments under CSAPR as well . This initializing assumption is supported by EPA engineering staff interaction with the supply chain community

and informal appraisals of the current ac tivity and preparedness of the sector. Th e starting point assumption directly influences the computation of what proportion of retrofit effort is "on time" in 2015 and what proportion is "late" and would require the one - ye ar extension to February 2016. This Moderate scenario expresses EPA’s current expectation of what is reasonabl y achievable while recognizing that there is no definitive way

to project how many

controls will be on time and how many will require the extension. Completion of this scenario b y 2016 seems a reasonable expectation since the MATS is not projected to require use of wet FGD, the most time and resource - consuming APC technology . Note that although this WetFGDeq anal ytical concept appears to suggest that nothing is deployed until 201 4 ; in reality there would likely be deployed increasing amounts of DSI, activated carbon injection (ACI) , fabric filter (FF ) technology , and upgrades of existing FGD and ESP starting in the earliest ye ars, 2012 and 2013, and continuing throughout the program. Dry FGD retrofits could begin coming online sometime in 2013.
 With a small further growth in the supply chain deploy

ment rate, an additional 2 4 GWeq can be deployed by

e arl y 2015 , making a cumulative deplo ym ent of 4 4 GWeq. A further 2 0 GWeq is completed by February 2016, thus meeting the MATS Rule cumulative projection of 6 4 GW WetFGDeq. EPA views this moderate 5 - ye ar ramp - up as a reasonable and achievable deploy ment sc enario , without anticipating that the sector may find more productive routes to effective and efficient compliance not yet reflected in the historic record .12



### Table 4: APC Deploy

ment Scenarios, Cumulative GW WetFGDeq **Cumulative GW WetFGDeq**  **Jan -**  **11 Jan**  **- 12**  **Jan -**  **13 Jan**  **- 14**  **Jan -**  **15 Jan**  **- 16**  **5 -** **year ramp -**  **up** Moderate - paced increase in resources 20 4 4 6 4 **4 -** **year ramp -**  **up** Aggressive increase in resource s 28 6 4 Source: EPA 

### The relative magnitudes of past and projected annual APC and New Coal deploy ments are depicted in Figure 4, where the incremental GWeq of APC for the MATS Rule under a moderate 5 - ye ar ramp - up are added to projected APC deploy ments without the Rule. This visual representation of the relative magnitudes of the resources involved supports the reasonableness of EPA ’ s expectation that timely compliance is achievable in this moderate ly paced scenario . Figure 4: Online Year for MATS Rule APC Annual Additions in 5 - Year Ramp - up Scenario

Source: EPA 

### More Aggressive Future Deploy ment Itis conceivable that the supply chain could begin immediately

to ramp up its capabilities over three years to the same peak deploy ment rate achieved for CAIR, and to continue ramping up at an aggressive pace through a final year of APC deploy

ments. Conceivably , it would not “throttle back” its resource growth; it would tap all available sources until all resources that are needed are in place to produce 6 4 GW WetFGDeq of deploy ments by earl y 2015. Under this more aggressive 4 - year ramp - up scenario, 28 GWeq c oul d be in service b y early 2014 (40% more than in the moderate scenario, but about equal to the CAIR peak), with an additional 3 6 GWeq needing to be placed into service by early 2015. 0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0GWWetFGDeq New Coal, GW W etFGDeq MATS Rule APC, GW W etFGDeq APC, GW W etFGDeq13



### EFFECT OF **RETROFIT UNIT SIZES**  It is useful to consider whether a difference in the past and future average size of the units involved, and thereb y a difference in the number of unique units or projects involved, might significantl y affect the feasibility results. NEEDS data indicate th at the peak APC deploy ment of 38 actual GW in 2009 (Figure 1) involved a peak of 66 unique units. The average size unit built anew or retrofitted in 2009 with APC systems was therefore about 575 MW. Not all of those units were managed as unique projects, a s some were part of continuing multi - unit projects at some plants, and a few shared an APC sy stem with one or two other units at the same plant. EPA projects that the future average unit size retrofitted for the MATS Rule will be about 300 MW . However, th at does not necessaril y mean that there will be proportionately more APC projects to be managed simultaneously . The limited time for compliance will likely necessitate parallel retrofitting activities at many multi - unit plants, with such plant - wide efforts managed most efficiently

as single projects. Furthermore, with smaller average unit sizes being retrofitted in the future, there will likely be many plants (projects) where multiple smaller units share an APC system. Although it is not possible to accurat ely predict the future numbers of APC sy stems that will be uniquely

deployed to single units, or to multiple units, it is clear that the sharing of APC systems by

multiple smaller units, done to minimize resource needs and capital cost, could significantl y limit the number of APC sy stems and projects involved. Shared APC sy stems will allow the overall effort to be more manageable than otherwise, and should require relatively fewer supply

chain resources. A higher number of projects might be expected to imp act project management and supervisory labor to some greater degree than craft labor. However, many of the projects will be upgrading existing sy stems and/or installing fabric filters and less complex technologies , any of which are far less complex than the wet FGD s ys tems installed for CAIR . They will entail far fewer co mponent suppliers, less process engineering effort , fewer technical specifications, etc. A ty pical upgrade or fabric filter project is therefore far less difficult to manage or supervise than a ty pical wet scrubber project. Li kewise they are easier to construct and will require relativel y less craft labor. Thus, although there may be more APC projects, they will be far easier to manage, and should require relativ ely fewer skilled personnel than CAIR experience and the WetFGDeq metric might suggest. Referring again to Figure 4, EPA expects that the combined underutilized resources for the APC and New Coal suppl y chains, possibly supplemented with underutilized re sources from the gas combined - cycle business line, will be adequate to support a moderatel y paced APC deploy ment scenario.14 **Appendix - Wet FGD Retr ofit Timelines** 

**Plant Name Unit I**  **D Capacit**  **y (MW)**  **PR OJ** **START**

**(CAMD findings)**  **PROJ FINISH**

**(C AM**  **D Findings)**  **PROJ**

**Du ra**  **ti on**  **(months) Referenc** **e CAMD SO**  **2 Cont**  **rol Start Dat**  **e** As hevi lle 1 191 Se p-03 Nov-0 5 26 (web s it e: http://www.power genworl dw id e.c om/i nde x/di sp lay/art icle di sp lay/277709/art icle s/ pow er en gi neer in g/-/2006/11/be st -coa l- fi re d-proj ec ts .html ) **Construction st ar**  **t Sept 2003.** **Unit #1 c omplete Nov 2005;**  uni t #2 compl ete 2006. Deta il des ig n to Sta rt -up: 26 m onths . (we b s it e: h ttp://progres sen er gy.com/a boutus /news /a rt icle .a sp ?i d= 1428 2 **)** uni t 2 on-l in e Ma y 25, 2006;**unit #1 on-line**  **N ov 2**  **005.** 11/ 6/ 2005

Ki lle n Sta ti on 2 615 Ma r-05 Jun-07 28 (web s it e: http://www.bv.c om/News _3 _P ubli cat io ns /News _Rel ea se s/ 2005/0503.as px) **B&V announce ment -**  **al liance w DP&L for Kille**  **n & Stuart st at**  **ions to ut ilize scr**  **ubbe r tec**  **nology - May 3 ,**  **2005** . (web s it e: http://www.thefreel ib rary. com /Bl ack +%2 6+Vea tc h%27s +La rg es t+CT-12 1+Scrubbe r+ Proje ct +i n+ North+Amer ica+ ...- a0166786209) B&V **st ar**  **t- up of a CT-12**  **1 WFGD for Killen unit#2 - July 25, 2007** . 5/ 24/ 2007

Bra ndon Shore s 1 643 Jun-07 Dec -09 29 (web s it e: http://www.hi ghbea m.com/doc/1G1-165318616.html ) **Const ruc**  **ti on start June 20, 2007**  . (web s it e: http://www.c ons tel lat ion.com /vcmfi le s/ Cons tel lat io n/Fi le s/ scrubbe r_ fa ct sh eet.pd f) **Un it**  **#1 c** **onne ct**  **ed Dec 2**  **009;** uni t #2 connected Ma r 2010. 11/ 21/ 2009 Cri st 7 472 Ma y-0 7 Ja n-10 32 (web s it e: http://www.bv.c om /wc m/ pr es s_ re le ase/05072007_ 1374. asp x) B&V s el ec ted by Gul f Pwr Comp to provi de EPC for CT-121 WFGD at Pl antCri sts ta ti on;al l uni ts w ill bes crubbe d; uni t 4,5,6 ,7 - **announ May 7 ,**  **2007** . NO TE: us e CA MD SO2 control s ta rtda te 1/ 1/2010 Bra ndon Shore s 2 643 Jun-07 Ma r- 10 32 (web s it e: http://www.hi ghbea m.com/doc/1G1-165318616.html ) **Const ruc**  **ti on start June 20, 2007.**  (web s it e: http://www.c ons tel lat ion.com /vcmfi le s/ Cons tel lat io n/Fi le s/ scrubbe r_ fa ct sh eet.pd f) U ni t#1 conne ct ed Dec 2009; **unit #2 c onne**  **ct ed Mar 2010.**  1/ 1/2010 As hevi lle 2 185 Se p-03 Ma y-06 33 (web s it e: http://www.power genworl dw id e.c om/i nde x/di sp lay/art icle di sp lay/277709/art icle s/ pow er en gi neer in g/-/2006/11/be st -coa l- fi re d-proj ec ts .html ) **co nstruction st**  **ar t**  **Se pt 2003;**  uni t#1 com plete Nov 2005; **unit #2 c omplete 2006.**  Deta il des ig n to Star t-up: 2 6 m onths . (web s it e: h ttp ://progre ssen er gy.com/a boutus /news /a rt icle .a sp ?i d= 142 82 **) unit 2 on-line May 25, 2006;**  uni t #1 on-l in e No v 2005. Wa ns ley 1 891 Ja n-06 Oct -08 33 (web s it e: http://www.ti mes -he ra ld. com /Loc al/ Scrubbe r- pr oj ec t-pl an ne d-a t-Ya tes -596100) **Wa nsley constrc**  **tion begin - Jan 20**  **06** . (Mea g Power Cur re ntvol .2 : i ssu e 1 , 2009) **Wa nsley unit**  **1 scrubber comple**  **ted Oc**  **t 2008;**  uni t #2 by next mi d apri l) . 10/ 1/ 2008 Mi tc hel l 2 800 Ma r-04 Ja n-07 34 (web s it e: http://www.ba bcock.com /l ib ra ry/pdf/pch570. pdf) pe r B&W: **Proj ec** **t a wa**  **rd mar 2004; unit 2 ope**  **ra ti**  **onal Jan 07 ,**  uni t 1 opera ti ona l Apr 07. 2x800 Mw uni ts 1/ 15/ 2007 Wa rrick 2 136 Jul -05 Ma y-08 34 (web s it e: http://www.thefreel ib rary. com /Al coa+ Inve st in g+%2 4375+ Mi llio n+ for+Warrick% 2c+ IN +Fa cilit ie sa0134312217) **Alc oa** **announces investm ent in WFGDs for Warric**  **k July 2 2, 2005**  . (web s it e: https ://www.a lco a. com/l oca ti ons/us a_ wa rri ck/e n/i nfo_pa ge/power_pl ant .a sp ) Dec 2008, al l 4 uni ts com pleted - WFGD'd i ns ta lle d - fi nal scrubbe r in st alle d i n Dec 2008;**project start 2005.** (web s it e: https ://www.i ns id ei ndi anabusine ss. com /news it em.a sp ?I D=2 9541) **the first scrubber went on-line 5/27/2008** . (web s it e: http://www.a lco a. com /l oca ti ons /us a_ wa rrick/e n/news /news letter s/ june 08.as p#0 ) Uni t #2 i denti fi ed . 4/ 12/ 2008

Fort Ma rt in Pow er Sta ti on 1 552 Ma r-07 Feb -10 35 (web s it e: http://fi ndart icle s. com /p/a rt icle s/ mi _m0 EI N/ is_2007_ Ma rch_ 15/ ai_ n27304049/) **Alleghe ny Pwr**  **an nounc** **es E**  **PC c ont**  **ra ct**  **w WGI for scrubber at Fort-Ma**  **rtin sta tion - March 15, 2007**  . (web s it e: http://news bl az e.c om /s tor y/2 010020408561700001. bw/tops to ry. ht ml ) Al legheny Pwr **an nounc** **e co**  **mpl etion of**  **scr ubbe**  **r proj ec** 

**t for Fort Martin st**  **at ion - Feb 04,** **2010** . 10/ 31/ 2009

Fort Ma rt in Pow er Sta ti on 2 555 Ma r-07 Feb -10 35 (web s it e: http://fi ndart icle s. com /p/a rt icle s/ mi _m0 EI N/ is_2007_ Ma rch_ 15/ ai_ n27304049/) **Alleghe ny Pwr**  **an nounc** **es E**  **PC c ont**  **ra ct**  **w WGI for scrubber at Fort-Ma**  **rtin sta tion - March 15, 2007**  . (web s it e: http://news bl az e.c om /s tor y/2 010020408561700001. bw/tops to ry. ht ml ) Al legheny Pwr **an nounc** **e co**  **mpl etion of**  **scr ubbe**  **r proj ec** 

**t for Fort Martin st**  **at ion - Feb 04,** **2010** . 8/ 26/ 2009

Mi am i For t 7 500 Jun-04 Ap r- 07 35 (web s it e: http://www.mc ilv ain ec ompa ny. com /uti lity/subs crib er /Defa ul tO LD.htm) Mc Ilv aine#8 21 **(4/27/2007) Miam**  **i-Fort unit**  **#7 WFGD ope**  **ra ti**  **ng;** (per so na l note: worked on proj , **proj start June**  **2 004)**  4/ 1/2007 Monroe 4 775 Jul -06 Jun-09 35 (web s it e: http://www.r edorbi t.c om/news /bus in es s/ 560181/w ashin gton_group_i nter na ti ona l_ to_r etr ofi t_s crubbe rs _a t_d et roi t_ed iso n_power/i ndex.html ) **WGI se**  **le ct**  **ed to provide EPC for WFGD's on Monroe unit s 3&4 - 5 july 2006.**  (web s it e: http://www.tra di ngma rkets .c om/.s it e/n ews /Stock%20News /2657108/) Monroe **unit #4 WFGD**  **ope ra**  **ti onal June 2009**  . note: s crubbe r i s a ce ra mi c ve sse l (ti lew c oncrete). 5/4/2009

Cl ay Bos wel l 3 351 Fe b-07 Ma r- 10 37 (web s it e: http://www.r edorbi t.c om/news /bus in es s/ 840682/m in nes ot a_ pow er _a wa rd s_ bos wel l_ener gy_c enter _r etr ofit_c o ntra ct/i nde x. ht ml ); **Awa rd 14 Feb 2007.**  (http://ha mo n-r es ea rchcottr el l. com /news _2 0100601) **Com plet**  **ed M ar**  **2010** 10/ 30/ 2009

Mi tc hel l 1 800 Ma r-04 Ap r- 07 37 (web s it e: http://www.ba bcock.com /l ib ra ry/pdf/pch570. pdf) pe r B&W: **Project award mar 2004;** uni t 2 oper at io na l J an 07, **unit 1**  **ope ra**  **tional Apr 07** . Two 800 MW uni ts . 1/ 1/2007 Wa rrick 1 136 Jul -05 Oct -08 39 (web s it e: http://www.thefreel ib rary. com /Al coa+ Inve st in g+%2 4375+ Mi llio n+ for+Warrick% 2c+ IN +Fa cilit ie sa0134312217) **Alc oa** **announces investm ent in WFGDs for Warric**  **k July 2 2, 2005**  . (useCAMD SO2 control s ta rt da te) 10/ 15/ 2008 Wa ns ley 2 892 Ja n-06 Ap r- 09 39 (web s it e: http://www.ti mes -he ra ld. com /Loc al/ Scrubbe r- pr oj ec t-pl an ne d-a t-Ya tes -596100) **Wa nsley constrc**  **tion begin - Jan 20**  **06** . **(use CAM**  **D SO2 c ont**  **rol start dat e)**  4/ 1/2009 Bowen 3BL R 902 Ja n-05 Ma y-08 40 (web s it e: http://fi ndart icle s. com /p/a rt icle s/ mi _m0 EI N/ is_2005_ Ma y_2/ ai_ n13664268/) **scrubber c ont**  **ra ct**  **signed Jan 20 05 - Chiyoda JBR.**  (http://www.georgi ap ower.c om/e nvi ronm ent/a ir_qual ity.a sp ) Bowen s crubbe r **com merc**  **ial oper at**  **ing May 2 008**  . 1/ 1/2008 Monroe 3 795 Jul -06 Nov-0 9 41 (web s it e: http://www.r edorbi t.c om/news /bus in es s/ 560181/w ashin gton_group_i nter na ti ona l_ to_r etr ofi t_s crubbe rs _a t_d et roi t_ed iso n_power/i ndex.html ) **WGI se**  **le ct**  **ed to provide EPC for WFGD's on Monroe unit s 3&4 - 5 july 2006;**  (web s it e: http://www.tr adin gma rkets .c om /.s it e/ news /Stoc k%20N ews /2 657108/) **unit #3 WFGD operational 1**  **6 Nov 2009.**  note - cera mi c wfgd ves se l (ti lew c oncrete) . 11/ 1/ 2009

E W Brow n 1 94 De c-05 Ap r- 10 52 (web s it e: http://www.corpor at enews .n et/_c lie nt/RL24 592/Ghe nt-Br own%20FGD%20Fi na l. pdf) contract award EP C (WFGD) Gent uni ts 1,3,4 & EW Brown uni ts 1,2,3 98% SO2 Re mova l. **Awa rd**  **Dec 2005.** [note: wi ll us e CA MD SO 2 cont rol da te - 4 /1/2010) 4/ 1/2010
E W Brow n 2 160 De c-05 Ap r- 10 52 (web s it e: http://www.corpor at enews .n et/_c lie nt/RL24 592/Ghe nt-Br own%20FGD%20Fi na l. pdf) contract award EP C (WFGD) Gent uni ts 1,3,4 & EW Brown uni ts 1,2,3 98% SO2 Re mova l. **Awa rd**  **Dec 2005.** [note: wi ll us e CA MD SO 2 cont rol da te - 4 /1/2010) 4/ 1/201015 1 Staudt, Availability of Resources for Clean Air Projects , October 1, 2010 (available from Andover Technology Partners, www.AndoverTechnology.com ) 2 National Electric Energy Data System 3 Huggins, et al, Implementation Strategies for Southern Company FGD Projects , 2010 Mega Symposium , Paper#68 4 Best Coal-

fired Projects , Springerville Unit 3 Expansion Project, Power Engineering, December 2006, http://www.powergenworldwide.com/index/display/articledisplay/277709/articles/power - engineer ing/- /2006/11/best - coal - fired - projects.html