MEMORANDUM

From: Office of Air Qual ity Planning and Standards U.S. Environmental Protection Agency To: EGU NSPS Docket (EPA-HQ-OAR-2011-0044)
Date: November, 2012 Subject: Incremental Control Co st, Energy, and Environmental Imp acts of Revisions to Electric Utility Steam Generating Unit NSPS under 40 CFR Part 60 subpart Da

Introduction The New Source Performance Standards (NSPS) unde r 40 CFR 60 subpart Da presently regulate the emissions of filterable particulate matter (PM), sulfur dioxide (SO 2 ), and nitrogen oxides (NO X ) from new, modified, and reconstructed el ectric utility steam generating units (EGUs), as defined in the rule. The Clean Air Act (CAA) section 111(b)(1)(B) requi res the U.S. Environmental Protection Agency (EPA) to periodically review and, if appropriate, revise NSPS to re flect improvements in emissions reduction methods. The EPA revise d the NSPS for EGUs for PM, SO 2 , and NO X on February 16, 2012, (77 FR 9304) to reflect the performance achieva ble by the best demonstrated technologies for controlling thes e pollutants. NSPS are required under CAA section 111 to reflect the application of the best system of emissions reductions that EPA has determined to be adequately demonstrated (taking into account the cost of achieving such reductions, any non-air quality he alth and environmental impacts and energy requirements). The purpose of this memorandum is to provide additional analys is of the achievability and the cost, non-air quality environmental, and ener gy impacts of the revised PM emissions standard. Impacts Estimate General Approach PM Control technologies for steam generating un its are based on pre-combustion controls, postcombustion controls, or a combination of approaches. Pre-combustion controls re move ash from the fuel before it is burned, and post-combustion controls rem ove PM from the flue gases before the gases are released to the atmosphere. To comp ly with the EGU NSPS, affected ow ners/operators of new coal-fired EGUs need to install post-combustion air pollution cont rols to meet the emissions standard for filterable PM. The specific control configurations used for an individual EGU will depend on site-specific factors including type and characteristics of the coal burned and the type of boiler used to burn the coal. The costs to install and operate these controls will be incurred regardless of the revisions to the PM emissions standard. Consequently, th e control configuration used for a new coal-fired EGU to meet the previous EGU NSPS represents the reference point or “regulatory baseline” fr om which the additional control costs and associated non-air quality and ener gy impacts of complying with the current emissions standard are determined. Cost, non-air quality environmental, and energy impacts estimates were prepared for hypothetical “model plants” representative of the coal-fired EGUs and associated control system configurations that may be build in the United States in the foreseeable future. The basis for the PM control system cost estimates is a combination of control algorithms and procedures developed by the EPA Clean Air Markets Division (CAMD) (available a t: www.epa.gov/airmarkets/progsregs/epaipm/docs/append5_5.pdf) and the Coal Utility Environm ental Cost (CUECost) model (available at http://www.epa.gov/ttncatc1/products.html). The capital costs for the control systems were annualized using a capital recovery factor that assumes an interest rate of 7% a nd a period of 20 years. All costs are expressed as 2009 dollars. In addition, since the IPM co st procedures are primar ily intended to estimatecosts of retrofitting controls to existing units, the co sts estimated by the IPM are reduced a retrofit factor of 0.77 to account for the controls being insta lled at model plants representing new EGUs. The costing algorithms and procedures used for this impact analysis are in tended to provide “study estimate” costs. Cost values obtained by this type of cost estimation method are on the order of ± 30% of the presumed actual costs for the control system bei ng modeled. The model plant EGUs selected for this impact analysis do not represent spec ific actual coal-fired electric ut ility power plant cu rrently operating or under construction in the United States. Furthermore, the control costs estimat ed by this analysis are not intended to be directly applied to a specific coal-fired electric utility power plan t location. Actual control costs for a given coal-fired EGU project will be determined by the detailed site-specific factors, and therefore can be higher or lower than the cost s presented in this memorandum. However, the cost and impact values derived from a model plant analys is provide reasonable estimates for the purpose of evaluating the impacts of revisi ons to the existing EGU NSPS. Model Plant EGU Descriptions Costs for installing and operating th e air pollution controls were estimated by assigning specific air pollution control configurations to seven model plants representing EGUs varyi ng in characteristics of the coal burned, boiler types, and generating capac ity. Five of the model plant EGUs represent pulverized coal-fired (PC-fired) boilers burning either bituminous co al, subbituminous coal, or lignite. The coal types were selected for these model plan t EGUs to represent a ty pical low-sulfur, mediumsulfur, and high-sulfur content coal that would be burned in a new EGU. Two additional model plant EGUs represent boilers that use fluidized-bed co mbustion (FBC) technology a nd burn lignite or coal refuse. The boiler sizes were sel ected to approximately span the range of typical coal-fired EGUs expected to be built in the United States. Boiler sizes are expressed in terms of the model plant EGU’s gross electricity output in megawatts electric (MWe). The model plant EGU configurations defined for the im pact analysis are described in Table 1. All of the model plant EGUs, with the excep tion of the 100 MW size boilers, ar e projected to have a gross efficiency of 38% (8,979 Btu/kWh) and assumed to be operated as base load units with an annual capacity factor of 85%. Supercriti cal steam turbines are not available below a pproximately 200 MW and coal refuse-fired EGUs tend to be less efficient than EGUs burning higher rank coals. To account for this, the 100 MW subbituminous and coal refuse-fired boilers were projected to have gross efficiencies of 36% (9,478 Btu/kWh) and 34% (10,035 Btu/kWh) re spectively and annual capacity factors of 85%.Table 1. Coal-fired EGU “Model Plant” Configurations

Model Plant Boiler Type Coal Burned Gross Generating

Capacity (MWe) Gross Heat Rate (Btu/kWh) Annual Capacity

Factor

A PC Low sulfur Subbituminous (Wyoming PRB) 100 9,478 85%

B PC Low sulfur Subbituminous (Wyoming PRB) 500 8,979 85%

C PC Medium sulfur Bituminous (Armstrong, PA) 500 8,979 85%

D PC High sulfur Bituminous (No. 6 Illinois) 500 8,979 85%

E PC Lignite (Bryan Texas) 500 8,979 85%

F FB Lignite (North Dakota) 400 8,979 85%

G FB Coal refuse 100 10,035 85%

The regulatory baseline defined for each model plan t used for the incremental impact analysis is presented in Table 2. The regulator y baseline PM emissions rate is the controlled emissions rate assuming the use of a fabric filter with an air to cloth ratio of 4.0 for PM control for all units. Table 2. Coal-fired EGU “Model Plant” Regulatory PM Baseline

Model Plant Emissions Rate (lb/MMBtu) Emissions Rate (lb/MWh) PM Emissions (tons) PM Controls Assumption Annual Fabric Filter Costs ($/y) Electricity Use (MWh)
A 0.015 0.142 53 Fabric Filter 1,767,000 4,382

B 0.015 0.135 251 Fabric Filter 6,157,000 18,988

C 0.015 0.135 251 Fabric Filter 6,639,000 20,734

D 0.015 0.135 251 Fabric Filter 6,750,000 21,141

E 0.015 0.135 251 Fabric Filter 7,156,000 22,631

F 0.015 0.135 201 Fabric Filter 5,174,000 15,492

G 0.015 0.151 56 Fabric Filter 1,769,000 4,370

PM Emissions Control Impacts
Controls for filterable PM are well established, and the PM control that would be used by any new coalfired EGU would be use of a fabric filter (i.e., baghouse) or an electros tatic precipitator (ESP). Either of control devices can achieve the high control efficienci es needed to meet the existing limit and control for both coarse and fine filterable PM. For the impact analysis, the PM emissions regulatory baseline is assumed to be 0.015 lb/MMBtu and is defined to be installation of fabric filters on all units. It is assumed that to meet the amended PM emissions limit of 0.090 lb/MWh, this fabric filter would need to reduce the number of holes in the bag material and improve the main tenance practices by increasing the frequency of bag replacements to once every 3 years in stead of the baseline of once every 5 years. Table3 shows the annual cost of the more frequent bag replacement schedule . The cost effec tiveness is the total annual cost per ton of PM reduction co mpared to the baseline fabric filter.

Table 3. Fabric Filter Costs with In creased Frequency of Bag Replacement

Model Plant Annual Costs ($/y) PM Emissions (tons) Incremental Cost Effectiveness ($/ton PM)

A 1,804,000 34 1,900

B 6,315,000 167 1,900

C 6,812,000 167 2,100

D 6,926,000 167 2,100

E 7,345,000 167 2,300

F 5,303,000 134 1,900

G 1,799,000 34 1,400

These incremental costs are considered acceptable, es pecially considering that the majority of the reductions will be fine PM. The only secondary envi ronmental impacts would be the disposal of the extra bag material and the incr emental PM that is collected. To provide additional analysis, we also estimated the cost of using a secondary control device after the fabric filter as an alternate to the more freque nt bag replacement schedule. To meet the amended PM emissions limit, it is assumed that the addition of a wet electrostatic precipitator (WESP) downstream of the fabric filter would reduce additional filterable PM that is not collected by the fabric filter and be sufficient to achieve the require d higher performance level.

The current version of the IPM does not include a costing model for WESPs. Therefore, the WESP costs are estimated using the results from an EPA sensitivity analysis for the Clean Air Interstate Rule (CAIR) (available at: http://www.epa.gov/cair/pdfs/0053-2263.pdf ). The EPA estimated the cost impacts for CAIR using the IPM. The cost method provided cap ital, fixed O&M, and variable O&M costs as a function of EGU size. A scaling factor was provided, as the base unit of the method was a 500 MW unit. The WESP costs from the CAIR analysis were in 2002 dollars. To calculate 2009 dollars, the Chemical Engineering Price Costing Index (CEPCI) was used for th e capital cost, and an inflation rate of 2.5% per year was used for the variable O&M and fixed O&M costs.

For those coal-fired EGUs us ing wet scrubber systems for SO 2 emissions control to meet the existing EGU NSPS, it is assumed that the wastewater from the WESP would be recycled to the wet scrubber. Coal-fired EGUs without an exis ting wastewater treatment system capable of handling the additional wastewater stream from the WESP would need to build and operate a suitable wastewater treatment system. Costs for such a system are not included in the analysis. Table 4 presents the estimated incremental impact s of revising the EGU NSPS PM emissions limit for all of the model plant EGUs relative to impacts of using only a fabric filter to meet the existing PM emissions limit. While these costs are higher than im proved fabric filter maintenance, the cost impact analysis for all model plant EGUs does not account for the benefit of additional SO 2 and condensable PM emissions reduction that would occur with the use of the WESP.Table 4. Secondary WESP Control System Annual Impacts

Model Plant WESP Annual Costs PM Emission Reduction

(tons) Incremental Cost Effectiveness ($/ton PM)

A 806,000 19 42,400

B- E 2,579,000 84 30,700

F 2,193,000 67 32,700

G 806,000 22 36,600

Alternate PM Emissions Control Impacts Analysis A separate analysis was done assuming an ESP was the preferred primary baseline control device for the bituminous and lignite-fired PC units. To estimate th e cost impacts under this scenario, we estimated the costs for 2 different approaches. Th e first approach would be to desi gn a larger ESP with an improved capture efficiency to achieve the amended PM standar d. The alternate approach is to design a relatively inefficient ESP to control the PM emissions down to 0.10 lb/MMBtu followed by either a WESP or a polishing fabric filter with an air to cloth ratio of 6.0 to reduce emissions down to 0.090 lb/MWh. We used the same ESP cost model as in the 2005/ 2006 NSPS amendments updated to 2009 dollars to evaluate the incremental cost eff ectiveness of the amended standard compared to the existing NSPS. Table 5 shows the differences for the two ESP designs.

Table 5. Incremental Impacts of Improved ESP Performance

Model Plant Baseline (0.015 lb/MMBtu) Amended Standard (0.090 lb/MWh) Incremental Cost Effectiveness

($/ton PM) Specific Collection Area (SCA, ft2/1,000 acfm) Annual Costs ($/y) Electricity Use (MWh) Specific Collection Area (SCA, ft2/1,000 acfm) Annual Costs ($/y) Electricity Use (MWh)

C 391 5,797,000 19,258 444 6,318,000 20,734 6,200

D 501 6,956,000 22,303 560 7,532,000 23,977 6,900

E 1,203 14,042,000 42,125 1,336 15,249,000 45,816 14,400

Table 5 shows that for facilities with ash charac teristics amenable to collection by an ESP, the incremental costs are cost effective.Tables 6 and 7 show the costs for a less efficient E SP used in combination with a secondary WESP and fabric filter.

Table 6. Incremental Impacts of Secondary WESP

Model Plant ESP (0.10 lb/MMBtu) WESP Annual Costs ($/y) Incremental Cost Effectiveness

($/ton PM) Specific Collection Area (SCA, ft2/1,000 acfm) Annual Costs ($/y) Electricit y Use (MWh)

C 186 3,515,000 10,610 2,579,000 3,500

D 265 4,403,000 12,729 2,579,000 310

E 681 8,921,000 24,446 2,579,000 (30,300)

Table 7. Incremental Impacts of Polishing Fabric Filter

Model Plant ESP (0.10 lb/MMBtu) Fabric Filter Incremental Cost Effectiveness

($/ton PM) Specific Collection Area (SCA, ft2/1,000 acfm) Annual Costs ($/y) Electricity Use (MWh) Annual Costs ($/y) Electricity Use (MWh)

C 186 3,515,000 10,610 5,161,000 17,253 34,300

D 265 4,403,000 12,729 5,248,000 17,592 32,100

E 681 8,922,000 24,446 5,562,000 18,832 5,300

The calculated incremental cost effectiveness in Ta bles 6 and 7 combine results from different cost models and increase the uncertainty of the results. Ho wever, the results indicate that a combination of different controls may offe r the lowest overall costs.Control of Filterable PM Emissions Particulate matter (PM) may be clas sified by particle size and as eith er filterable or condensable PM. Filterable PM originates from ash in the fuel , incomplete combustion products, and flue gas desulfurization (FGD) reaction products. Filterable PM consists of in combustible inert matter (ash), and condensable PM consists of gases that will c ondense into a liquid or solid upon reaching ambient temperature. For coal-fired bo ilers, condensable PM may contain sulfuric and nitric acids, high molecular weight organics, and other compounds. To tal suspended particulate (TSP) encompasses all sizes of filterable PM. Particulate matter that is less than 10 microns in aerodynamic diameter is generally referred to as PM 10 . All particulate matter emitted from a controlled EGU stack is expected to be less than 10 microns in size. Particulate matter that is less than 2.5 microns in aerodynamic diameter is referred to as PM 2.5 . Condensable PM is included in this category because it is expected that all condensable PM is less than 2.5 microns in the atmosphere. Filterable PM 2.5 and condensable PM are considered direct PM 2.5 emissions. In addition to direct PM 2.5 emissions, indirect PM 2.5 , or secondary PM 2.5 , is formed when precursors such as SO 2 , NO X , VOCs, and ammonia form PM 2.5 through reactions in the atmosphere. The amended subpart Da filterable PM emissions sta ndard for owners/operators of new facilities is 0.090 lb/MWh gross energy output. PM Control Technologies The following is a brief summary of some of th e PM control technologies , including propriety technologies. This summary is not intended to be a comprehensive list of av ailable technologies. The performance values given here are those that have been provided by the technology provider in publically available sources. Incl usion of a technology in this summa ry is not intended to be an endorsement of that technology by the US EPA the US Government

Mechanical/Inertial Collector s (Cyclones/Multicyclones) . A cyclone is a cylindric al vessel, usually with a conical bottom. The flue gas enters the vessel ta ngentially and sets up a rotary motion whirling in a circular or conical path. The part icles are 'thrown' against the walls by the centrifugal force of the flue gas motion where they impinge and eventually settle into hoppers. The removal efficiency is between 75 and 99% for particle sizes between 1.0 and 100 μm. Cyclones are robust tec hnologies that can deal with the cyclic operation a nd load changes. However, their effici ency is moderate when compared with an ESP or fabric filter.

Wet Scrubber . The basic principle of wet scrubbers desi gned for PM control is to provide sufficient contact between the flue gas and scrubbing liquid to f acilitate removal of the PM. Venturi scrubbers are the most commonly used scrubber for particle co llection and are capable of achieving the highest particle collection efficiency of a ny wet scrubbing system. In a venturi scrubber, water is injected into the flue gas stream at the venturi throat to form fine droplets. Fly ash particles impact with the droplets forming a wet by-product which then generally require s disposal. Many of the wet particulate scrubbers are designed to control both SO 2 and particulates by utilizing the alka line fly ash as sorbent. Lime or some other sorbent is fr equently used to boost SO 2 removal efficiencies. In general, venturi scrubbers in combination with a mechanical collector are not exp ected to reduce PM emissions to the level required by the NSPS. In addition, venturi scrubbers tend to have relatively high en ergy consumption and do not control filterable PM 2.5 as well as a comparable ESP or fabric filter. Flue Gas Desulfurization (FGD) . FGD technologies designed for SO 2 control are also capable of reducing acid gases that are considered condensable particulate matter. An FGD is not a primary PM control technology; however FGD t echnology is a feasible control t echnology for reducing condensable PM emissions.Dry Electrostatic Precipitator (ESP) . An ESP is a PM control technol ogy that utilizes electrical charges to attract particulate matter present in the gas stre am. An ESP consists of negatively charged discharge electrodes and positively charged collection plates. The negatively charged electrodes create a corona of electrical charges transmitting a negative charge to the particulat e matter in the gas stream. The negatively charged particulate matter is then attracted to the ESP’s positively ch arged collection plate. Particulate matter accumulates on the collection plate un til the plate is mechani cally “rapped” causing the PM to fall into hoppers. The PM that collects in th e hoppers is then removed by the ash handling system. An ESP consists of a series of the electri cal fields described above in order to capture any PM that may be re-entrained in the flue gas stream during rapping. Some emissions during rapping of the last field are unavoidable. An ESP can be located eith er upstream of the air pre- heater (hot-side ESP) or downstream of the air pre-heater (c old-side ESP). Either location se lected for the ESP operates at a temperature above the dew point of condensable particulate matter. E SPs are intentionally operated at high temperatures to prevent corrosion problems that can result from condensable acid gases. Particulate removal efficiencies in ESPs can be improved by flue gas conditioning. Flue gas conditioning involves injecting conditioning agents such as el emental sulphur, ammonia (NH 3 ), and sulphur trioxide (SO 3 ) into the flue gas prior to the ESP. The removal efficiency is between 99.00 and 99.99% for particle sizes between 0.01 and 100 μm. Wet Electrostatic Precipitator (WESP) . A WESP operates in saturate d flue gas conditions, where the flue gas is below the dew point of many acid gases a nd other condensable PM. The collector plates of a WESP are washed with water. The process eliminat es the need for rapping as the liquid film removes any deposited fly ash particles. Thus, problems with re-entrainment, fly ash re sistivity, and capture of fine particles become obsolete. A WESP is a feasib le control technology for reducing fine filterable and condensable PM emissions. However, WESPs require saturation of the flue gas stream with water and generate waste water and sludge. The power required colle cting particulate matter in the WESP and the pressure loss across the WESP are the main operati ng costs of the WESP syst em. A WESP system may increase the amount of waste water that requires treatment and the WESP system auxiliary power will consume approximately 0.5% of th e gross output primarily due to additional power requirements for collection. Fabric Filter Baghouse (FF) . A fabric filter baghouse is a PM collect ion device that utilizes fabric filters or “bags” to collect PM. The design for a fabric filter is fairly simple. The flue gas enters an enclosure that contains compartmentalized groups of bags. The bags are operated in a manner to allow for cleaning, maintenance, and repair of one compartm ent (or group of bags) at a time. A compartment within the fabric filter includes th e bags as the filter media, a tube sheet that supports the bags, a PM dislodging mechanism, and a hopper to collect the accumu lated PM. As the flue gas enters the fabric filter enclosure, PM accumulates on the bags and a “filter cake” is formed. The “filter cake” will continue to accumulate on the bags until the pressu re drop across a compartment has increased to a specified limit. Once the specified pressure drop has been attained the PM is removed by placing the compartment in cleaning mode. Several methods fo r cleaning a fabric filter compartment include reverse gas fabric filters (RGFF), reverse air with mech anical shakers, and pulse je t fabric filter (PJFF). Each of the above cleaning methods is capable of removing the PM that has accumulated on the fabric filter. Once removed, the PM is collected by the ash hoppers. In a dry FGD application, the baghouse operates at lower temperatures due to the cooling in the dry FGD. This lower operating temperature may increase the condensation and theoretically in creases control of condensable PM. A FF has a higher pressure drop and greater energy penalty than an ESP. The specific fabric for an FF is selected based on th e operating parameters, pollutant characteristics, and mechanical operation. The EPA has an Environm ental Technology Verification (ETV) program to verify innovative pollution c ontrol technologies. The verified fabric filter products indicate the fabriccan achieve PM 2.5 emission levels as low as 0.0001 lb/MMBtu. The list of fabric f ilter products include felted bags and high efficiency microfiber felts, in trinsically coated (IC) bags, and membrane bags. Felted filters are often used on PJFF and do not require an initial filter cake to collect fine particulates. Felted filters are generally 2 to 3 times thicker th an woven filters, which improves fine particle collection. High efficiency microfiber felts are similar to felted fibers, but they use ultra-fine fibers to enhance fine particulate matter control. Intrinsically coated filters are made from fibers that are coated, usually with a fluoro-polymer, such as Teflon®. These filters are highly durable and have a smaller pore size between fibers, which improves filterable PM 2.5 control. Membrane filters have a polytetrafluoroethylene (PTFE) co ating, such as Teflon®, on the fabr ic, as opposed to the individual fibers. This also provides e nhanced control for filterable PM 2.5 . However, the use of either intrinsically coated or membrane bags tends to inhibit the fi lter cake formation. The filter cake formation can increases the effectiveness of the FF for controlling PM 2.5 precursors and condensable PM 2.5
. Reactant/Sorbent Injection . Injection technologies to control conde nsable PM emissions utilize injection of a sorbent or reactant. The most common inj ection chemicals include sodium bisulfite (NaHSO 3 ), sodium carbonate (Na 2 CO 3 ) or trona, and hydrated lime (Ca(OH) 2 ). Ammonia (NH 3 ) and magnesium hydroxide (Mg(OH) 2 ) have also been used. The sorbents or r eactants utilize their physical and chemical properties to react with or adsorb condensable PM (e.g., H 2 SO 4 ) to produce a solid byproduct that can be collected in the particulate control system. Sorbent injection is typi cally installed between the SCR and a fabric filter or ESP.

COHPACTM . The COHPAC TM technology combines an ESP with a high air to cloth ratio FF. The FF is placed in a separate casing downstr eam of the ESP (known as COHPAC I) or within the existing ESP's casing by replacing one or more fields of collect ing plates with FF modules (COHPAC II). The technology is based on the fact that a FF collects higher levels of partic ulate-and finer particulate-than an ESP of equivalent size. The FF acts as a "polishing device". Advanced Hybrid Particulate Collector . The Advanced Hybrid Particulate Collector (AHPC) utilizes both electrostatic collection and filt ration in a unique geometric config uration that achieves PM control with much less collection area than conventional PM devices. The de sign configuration of AHPC is unique because, instead of placing the ESP and FFB secti ons in series, the filter bags are placed directly between the ESP collection plates. The collection plat es are perforated (45% ope n area) to allow dust to reach the bags. However, since th e particles become charged before they pass through the plates, over 90% of the PM mass is collected on th e plates before it reaches the bags. When pulses of air are used to clean the filter bag surfaces, the disl odged particles are thrown back into the ESP fields where they have another opportunity to be collected on the plates . Tests to date show that the AHPC provides over 99.99% particulate collection efficiency for all particle sizes, at a cost that is competitive with or lower than existing technologies.

Max-9TM . The Max-9TM technology is an electrostatic precipitator/pul se-jet baghouse hybrid, employing high voltage discharge electrodes to charge the PM, but with fabric filters instead of collecting plates in the casing. Dust particles in the gas are charged by the discharge elect rodes, and are attracted to the grounded metal cage inside the filter element. The ne gatively charged particle s repel each other on the filter surface, resulting in a highly porous filter cake. The Max-9TM ESFF technology is reported to provide high collection efficiency while operating at significantly lo wer system pressure drop than a comparable FF.

PM Control Performance Figure 1 shows the filterable PM emission rates for coal-fired electric generating units with the lowest PM emission rates, as reported to EPA as part of the EGU NESHAP information collection request (ICR). We used all performance data that was subm itted. Figure 1 only includes facilities that reportedmore than 1 performance test. The 99% and 99.9% confidence level emission rates were calculated assuming the data was normally distributed and a dding 2.57 and 3.39 standard de viations to the mean emissions rate respectively. The data shows that the amended standard is currently being achieved by electric generating units burning a variety of fuels, using differentboiler designs, and using various control strategies.11Figure 1: Filterable PMPerformance Test DataFacility NameCAMDfacilityIDBoilerIDMaximumEmissionsRate(lb/MMBtu)MinimumEmissionsRate(lb/MMBtu)MeanEmissionsRate(lb/MMBtu)Number ofPerformanceTestsStandardDeviation(lb/MMBtu)99%ConfidenceEmissionsRate(lb/MMBtu)99.9%ConfidenceEmisisonsRate(lb/MMBtu)UnittypeFuelTypeFuelAshContent(%)Elevation(feet) PM Control NOX ControlVermilion Power Station 897 2 0.0020 0.0010 0.0014 3 0.0005 0.0028 0.0032 PC SUB 5.2 807 ESPVermilion Power Station 897 1 0.0020 0.0010 0.0014 3 0.0005 0.0028 0.0032 PC SUB 5.2 807 ESPSpringerville Generating Station 8223 4 0.0019 0.0008 0.0012 3 0.0006 0.0028 0.0033 PC SUB 13.3 Fabric Filter SCRMercer Generating Station 2408 2 0.0020 0.0008 0.0012 3 0.0007 0.0030 0.0035 PC BIT 4.7 30 Fabric Filter SCRSalem Harbor 1626 4 0.0030 0.0020 0.0027 3 0.0006 0.0042 0.0046 PC BIT 4.1 ESPHavana 891 9 0.0027 0.0010 0.0019 2 0.0012 0.0050 0.0061 PC SUB 5.2 653 ESP SCRNorth Valmy 8224 1 0.0040 0.0025 0.0034 3 0.0007 0.0053 0.0059 PC BIT 9.0 4,341 Fabric FilterSpringerville Generating Station 8223 TS3 0.0044 0.0006 0.0019 5 0.0015 0.0057 0.0069 PC SUB 13.3 5,617 Fabric Filter SCRMilton R Young 2823 B1 0.0045 0.0035 0.0040 2 0.0007 0.0058 0.0064 Cyclone LIG 12.6 1,647 ESPCope Station 7210 COP1 0.0036 0.0016 0.0026 2 0.0014 0.0063 0.0074 PC BIT 8.3 226 Fabric Filter SCRNorthside 667 2A 0.0046 0.0014 0.0029 6 0.0013 0.0063 0.0074 CFB PC 1.5 30 Fabric Filter SNCRRio Bravo Poso 10769 1 0.0054 0.0008 0.0022 5 0.0018 0.0069 0.0084 CFB Fabric Filter SNCRAllen S King 1915 1 0.0076 0.0071 0.0074 2 0.0004 0.0083 0.0085 Cyclone SUB 5.6 837 Fabric Filter SCRMilton R Young 2823 B2 0.0062 0.0044 0.0053 2 0.0013 0.0086 0.0096 Cyclone LIG 12.6 1,647 ESPMonroe 1733 4 0.0070 0.0027 0.0050 10 0.0015 0.0088 0.0101 PC SUB 6.1 627 ESP SCRBoswell Energy Center 1893 2 0.0100 0.0100 0.0100 2 0.0000 0.0100 0.0100 PC SUB 7.3 1,184 Fabric Filter SNCRLaramie River 6204 2 0.0083 0.0047 0.0066 5 0.0014 0.0102 0.0113 PC SUB 6.2 3,957 ESPH L Spurlock 6041 3 0.0065 0.0010 0.0036 4 0.0026 0.0103 0.0124 CFB BIT 12.7 889 Fabric Filter SNCRMartin Drake 492 6 0.0009 0.0008 0.0008 2 0.0001 0.0011 0.0012 PC BIT 8.3 6,171 Fabric FilterMercer Generating Station 2408 1 0.0010 0.0009 0.0009 3 0.0001 0.0011 0.0012 PC BIT 4.7 30 Fabric Filter SCRSandow Station 52071 5A 0.0010 0.0007 0.0008 2 0.0002 0.0014 0.0016 CFB LIG Fabric Filter SNCRNorthside 667 1A 0.0030 0.0007 0.0013 6 0.0009 0.0035 0.0042 CFB PC 1.5 30 Fabric Filter SNCRJ T Deely 6181 1 0.0033 0.0019 0.0026 2 0.0010 0.0052 0.0060 PC SUB 6.6 794 Fabric FilterJ T Deely 6181 2 0.0033 0.0019 0.0026 2 0.0010 0.0052 0.0060 PC SUB 6.6 794 Fabric FilterGallatin 3403 3 0.0043 0.0033 0.0038 2 0.0007 0.0057 0.0062 PC SUB 5.8 591 ESPGallatin 3403 4 0.0043 0.0033 0.0038 2 0.0007 0.0057 0.0062 PC SUB 5.8 591 ESPWidows Creek 50 6 0.0047 0.0023 0.0033 4 0.0010 0.0059 0.0067 PC BIT 9.4 689 ESPMarshall 2727 4 0.0051 0.0038 0.0047 3 0.0007 0.0066 0.0072 PC BIT 8.4 768 ESP SNCRCentralia 3845 BW21 0.0057 0.0011 0.0032 6 0.0015 0.0070 0.0082 PC SUB 12.3 200 ESPSt. Clair 1743 3 0.0060 0.0028 0.0043 7 0.0012 0.0073 0.0082 PC SUB 4.8 627 ESPCentralia 3845 BW22 0.0063 0.0009 0.0030 6 0.0021 0.0083 0.0100 PC SUB 12.3 200 ESPPleasant Prairie 6170 1 0.0062 0.0045 0.0053 2 0.0012 0.0084 0.0094 PC SUB 6.3 692 ESP SCRSt. Clair 1743 1 0.0080 0.0077 0.0078 2 0.0002 0.0084 0.0086 PC SUB 4.8 627 ESPBelle River 6034 1 0.0070 0.0054 0.0062 2 0.0011 0.0091 0.0101 PC SUB 4.7 627 ESPSt. Clair 1743 2 0.0063 0.0009 0.0031 4 0.0025 0.0094 0.0114 PC SUB 4.8 627 ESPCumberland 3399 2 0.0067 0.0043 0.0055 2 0.0016 0.0097 0.0111 PC BIT 7.2 591 ESP SCR