R eleased to the public October 4, 2011

.

[Type text] 

## White Paper 

# Availability of Resources for Clean

Air Projects

by
James E. Staudt, Ph.D., CFA Andover Technology Partners 112 Tucker Farm Road North Andover, MA 01845 www.AndoverTechnology.com

October 1, 2010
© Copyright 2010 Andover Technology Partners, all rights reserved

Previously available only with permission of the author.
Released to the public, October 4, 2011R eleased to the public October 4, 2011

.



## 1 Andover Technol ogy Partners



## Abstract
Availability of Resources for Clean Air Projects © Copyright 2010 Andover Technology Partners, all rights reserved The ability of power plants and other emission s sources to comply with clean air regulations within a given time frame is limited in part by the resources available for implementing the necessary modificat ions to the facility. The resources include labor, materials, and equipment. In this White Paper the assumptions used to assess the ability of power plants to comply with the Clean Air Interstate Rule (CAIR) within the regulatory time frame were examine d. Assumptions were tested for their reasonableness against actual data and experience

. This White Paper will demonstrate that the assumed limitations on labor that US EPA and representatives of the utility industry expected would limit the ability of the air pollution control (APC) industry to respond to the CAIR were not realized

. It was determined that US
EPA underestimated t he ability of the APC industry to respond to CAIR in its final 2005 analysis
used for the CAIR. Estimates of labor demand in the final CAIR analysis were significantly higher than previous estimates by US EPA. In light of these higher expected demand lo adings, the assumptions regarding the availability of labor were demonstrated in this White Paper to be too limiting and, by imposing a “hard cap” on labor availability, did not take into account the dynamic nature of U.S. labor markets , which US EPA had a cknowledged in the past

. Also, assumptions by US EPA and the representatives of the utility industry regarding the timing of orders relative to the finalization of the CAIR proved to be incorrect. As a result, both US EPA and representatives of the utili ty industry underestimated the ability of the APC industry to support the utility industry in its response to the CAIR. Other assumptions regarding supply and demand for other resources that were not envisioned to be limiting generally proved to be
consis tent with experience.
The findings of this White Paper have implications for future clean a ir initiatives and how the timing of these in itiatives should be assessed. To this end, i t may be benef icial to reexamine the topic of resource supply and demand, particularly with regard to labor , and develop assumptions that better reflect the demand and supply characteristics of the market for power plant labor

.R eleased to the public October 4, 2011

.



## 2 Andover Technol ogy Partners 

## Availability of Resources for Clean Air Projects

James E. Staudt, Ph.D., CFA Andover Technology Part ners © Copyright 2010, Andover Technology Partners, all rights reserved A vailable only with written permission of the author.

1.0 Introduction
The Clean Air Interstate Rule (CAIR) created demand for NOx control systems and flue gas desulfurization systems, primarily Selective Catalytic Reduction (SCR) and Limestone Forced Oxidation (LSFO) systems, and other types of technology as well.
The resources necessary for retrofit of SCR and LSFO systems include the following:

 Construction/craft labor, parti cularly boilermakers

 Engineers to design the systems

 Construction Materials, such as steel plate, alloy steel, fabricated steel components, structural steel, and concrete

 Engineered equipment and specialty materials, such as slurry pumps, fans, motors and catalyst

 Reagents, especially limestone and ammonia

I n the time lead ing up to finalization of CAIR, US EPA and the Utility Air Resources Group (UARG

– an advocacy group for some electric utility companies) and the Institute of Clean Air Companies (ICAC

– an organization that represents most of the suppliers of air pollution control technology) examined this issue

.
This White Paper will review

 the analysis by US EPA on feasibility of meeting CAIR

 the analysis by UARG on feasibility of meeting CAIR,

 and the analysis by ICAC on feasibility of meeting CAIR

 how these predictions compared to what actually occurred, and

 why there were some significant differences between predictions and actual performance
The section on the analysis by US EPA will include discussion of the CAIR rule and will be the longest of the three. It will describe the results of analysis of US EPA, UARG and ICAC performed prior to finalizing the CAIR rule. This paper will then exami ne how the predictions by US EPA, UARG, and ICAC compared with what actually occurred based upon actual new
order data

– and that the actual capabilities of the companies to respond to CAIR far exceededR eleased to the public October 4, 2011

.



## 3 Andover Technol ogy Partners the estimates of US EPA and UARG. Then, using the ac tual new order information on scrubbers and SCRs and the resource modeling information by these groups, the paper shows that resources will be readily available after CAIR Phase I installations for future clean air projects

. Finally, this paper briefly di scusses other resources needed for clean air projects and how US EPA’s assumptions regarding these generally held true.

2.0 US EPA’s Analysis

US EPA’s CAIR set phased

- in budgets on NOx and SO 2 for states in the eastern half of
the United States that are e xpected to be mainly met through reductions in power plant
emissions. As shown in Figure 1 , CAIR covers 28 eastern states and the District of Columbia

. CAIR emission “ caps ” are phased in, with Phase I complete by January 1, 2010 and Phase II is
intended t o be complete by January 1, 2015 . CAIR allows states to participate in a “cap

- and

trade” program that allows compliance either through control of emissions or through the use of pollutant emission allowances that may be banked for future use and/or trade d between affected

sources

. So, in this sense, the “caps” are not real “caps” on emissions. Under CAIR, emissions “caps” can , and are expected to be , exceeded as a result of the use of banked allowances. It is important to note that CAIR was remanded by the courts, and several key aspects of CAIR are expected to be revised as a result of US EPA’s Transport Rule.

Figure 1

. CAIR Affected States and Emission “Caps” 1R eleased to the public October 4, 2011

.



## 4 Andover Technol ogy Partners Before US EPA finalizes a rule, they analyze the impact on the economy and

– in the case of rules that affect the utility industry

– the impact on the utility industry. These impacts include the impact on the cost to produce electricity, whether there wil l be any significant disruptions in the electricity or fuel markets, and other effects. For CAIR, US EPA assessed whether the electric utility industry was capable of complying with CAIR in the time allowed.
Figures 2a and 2 b are taken from the US Envir onmental Protection Agency’s (US EPA)

on

- line information regarding the CAIR and reflect the results of analysis completed in 2005

. 2 The blue lines show the “caps” and the red lines show the predicted actual emissions. As shown, according to this US EPA analysis, actual emissions under CAIR were expected to exceed the “caps” for several years (beyond 2020) due to the use of “banked” emissions allowances. The figures are annotated to show the schedule for emission reductions un der CAIR . As shown, in
the five

- year period between 2005 and 2010 US EPA anticipated that national SO 2 emissions
would be reduced by roughly 4 million tons. By comparison, in the five

- year period between 2010 and 2015 US EPA anticipated that CAIR would cause SO 2 emissions to be reduced by only
about another 1 million tons. This is one indication that the retrofit ac tivities between 2010 and
2015 we re expected by US EPA be much less intense than in the period prior to 2010.

2.1 US EPA’s Projections of Retrofit Activity According to Reference 2 (US EPA’s October 2005 analysis of CAIR), in response to CAIR US EPA’s expected retrofits of roughly 90,000 MW of new FGD systems and 37,000 MW of new SCR systems by 2020. An additional 22,700 MW of SCR and FGD was expected for

new power p lants. US EPA expected 36,000 MW of FGD and 15,000 MW of SCR to be completed by 2010 for Phase I. According to US EPA, this Phase I effort was expected to be performed over a period, due to the timing of the rulemaking, to be 3.25 years for the FGD syste ms and 2.25 years for the SCRs 3

– resulting in an intense retrofit period prior to 2010. So, when EPA issued CAIR EPA anticipated an average of over 11,000 MW of FGD retrofit activity per year (36,000/3.25) prior to 2010. On the other hand, after 2010 t here are a full five years available for Phase II retrofit activity before the 2015 Phase II date, resulting in an average 7,260 MW of FGD retrofit activity per year

– a 34% drop in activity for FGD after 2010 . According to US EPA’s analysis in 2005, EPA expected that the retrofits in the second phase (after 2010) would be smaller units, resulting in more actual retrofit projects in the period after 2010 than before (186 versus 153). 3 However, due to the compressed schedule prior to 2010, this stillR eleased to the public October 4, 2011

.



## 5 Andover Technol ogy Partners

Fig ure 2 a. US EPA’s Projections of SO 2 emissions

. 2

Figure 2 b

. US EPA’s Projections of NOx emissions 2 FGD s

SCRs

Most NOx reductions to be complete by 2010 Most SO 2 reductions to be complete by 2010R eleased to the public October 4, 2011

.



## 6 Andover Technol ogy Partners results in significantly fewer projects anticipated per year after 2010 (21% fewer projects per year) . Therefore, US EPA anticipated that the level of retrofit activity expected would peak in the period prior to 2010 and drop off to a lower level after this peak

. It is important to note that previous estimates by US EPA (estimates made prior to 2005) actually projected more retrofits (49 GW of FGD versus 36 GW and 24 GW of SCR versus 15 GW) prior to 2010 and fewer retrofits after 2010

. Therefore, US EPA original ly anticipated much more activity prior to 2010 with a much steeper drop in activity at the end of Phase I . The difference is the result of changes in modeling assumptions. According to Reference 4 , modeling of various multipollutant bills under consider ation by Congress was performed in 2005, including modeling of the CAIR/CAMR/CAVR with an additional constraint (one not used in prior analysis) of a hard limit on labor supply (what we will refer to as a “hard cap”) that
was lower than some earlier US EPA estimates and using labor demand estimates based up on UARG comments that indicated higher labor demand than earlier US EPA estimates. This additional constraint to US EPA’s analysis had the effect of artificially limiting the number of
retrofits that cou ld be performed prior to 2010 and explains the shift in results between the 2004 modeling and the 2005 modeling. The following section describes the background of this analysis in somewhat more detail.

2.2 Background on US EPA’s Assessment of the Supply of Pollution Control Technologies In 2002 US EPA examined the engineering and economic factors associated with a multipollutant emissions rule. 5 In this study US EPA concluded that the availability of construction materials, engineered equipment and reag ents was more than adequate to meet the needs of the utility industry should there be a significant amount of retrofit activity for a multipollutant rule. At the time, US EPA was evaluating President Bush’s proposed Clear Skies Act, which would have impos ed SO 2 and NOx emissions requirements on utility boilers in a manner similar to the CAIR. The study determined that supply of engineered equipment, construction materials (steel, concrete, etc.) and reagents was more than adequate. According to the analy sis, the sole area that had any risk of a tightening of resource supply, and thereby limiting retrofit activity, was the area of specialized construction labor, particularly boilermakers. Unlike most other construction trades, the boilermaker trade is fai rly specialized to the power industry and a few other industries (petrochemical, shipbuilding). Therefore, it is typically theR eleased to the public October 4, 2011

.



## 7 Andover Technol ogy Partners trade that is most limiting. However, the 2002 analysis showed that there were more than adequate resources, including boilerma kers, to meet the expected demand posed by the Clear
Skies Act

. In 2004, and in support of CAIR (then called the IAQR), US EPA again examined the availability of boilermaker labor in light of the most recent projections of retrofits. 6 According
to this me mo the demand for boilermakers in advance of the Phase I CAIR compliance dates would be most heavily concentrated in the 18

- month period from March 2008 to October 2009 as equipment was installed prior to the Phase I CAIR SO 2 Compliance date of January 1, 2010. US EPA’s analysis showed that there was adequate boilermaker labor to support the peak in boilermaker demand projected by US EPA. Nevertheless, later in this document this issue o f when the peak in labor demand would be from CAIR retrofits is revi sited

.
In March 2005, and in response to comments on the proposed CAIR, US EPA issued a revised analysis using a more thorough analysis of the supply of boilermakers by US EPA and more conservative assumptions of labor demand that were based on information provided by the Utility Air Resources Group (UARG, an advocacy group for the electric power industry)

. 7 , 8 Previous estimates by US EPA were based upon boilermaker demand requirements provided by companies that build FGD and SCR systems that were descri bed in Reference 5. This new analysis by US EPA using UARG’s more conservative (higher) boilermaker demand estimates included sensitivity testing in ten different scenarios to examine the effect of different assumptions. Two of the ten cases assumed a fa r more rapid retrofit effort than projected by US EPA or even required to comply with the rules as written. Of the ten cases tested, in eight of them US EPA estimated that there would be adequate boilermaker labor to meet the 2010 CAIR requirement. The o nly cases that showed a shortfall in labor were the two cases that assumed
scenarios that entailed a far more rapid retrofit effort than projected by US EPA or even required to comply with the rules as written. Hence, under any expected scenario, US EPA’s analysis showed that there would be an adequate supply of boilermaker labor. In fact, using the original
boilermaker demand estimates described in Reference 5 , all ten of the scenarios would have shown ample supply of boilermakers for the Phase I demand. The original boilermaker d emand estimates used by US EPA were developed through discussions with companies that have
constructed dozens of scrubbers and SCRs in the US while the UARG estimates for scrubber labor are based upon six data points provided by owners. However, recognizing that there isR eleased to the public October 4, 2011

.



## 8 Andover Technol ogy Partners some uncertainty in all of these estimates, it is reasonable to test other estimates, such as those provided by UARG.
In October 2005 US EPA issued a further revised analysis of the scrubbers and SCRs that would be installed for CAIR, but now assuming labor demand similar to UARG’s and with a hard cap on the labor available such that the labor would become the limiting factor in the number of retrofits that could be performed. 4 This analysis, with far more conservative assumptions about labor demand and availability than previous US EPA estimates is the analysis that eventually was referenced in the final CAIR rule. This assumption of a hard cap for labor was a significant departure in approa ch from previous analyses because it did not consider the dynamic nature of the labor market and the use of alternatives to on

- site craft labor, which had
been discussed in Reference 7 by US EPA.
The Dynamic Nature of the Market for Labor
The assumption of a hard cap on labor is a simplifying assumption that can be misleading because the market for labor is dynamic. It is important to keep in mind that, frequently, during periods of high demand, certain statistics may suggest that the dema nd for craft labor will exceed the “nominal” availability of labor. That is because these statistics compare local union enrollment versus demand and make specific assumptions about hours available which do not capture the dynamic nature of the real labor market. This “apparent” shortfall in supply is made up for in several ways, most of which are discussed further in Reference 7 by US EPA:

 Overtime

– Because demand for boilermaker labor is not steady, boilermakers will work overtime during periods of hig h demand

.  Non

- Union labor

– Most boilermakers are members of the International Brotherhood of Boilermakers (IBB). But, some are not. Local craft labor supply is normally developed from IBB union enrollment statistics, which do not reflect the additional s upply of non

union craft labor that may be used in some locations. The ability of an owner to use non

union labor on site will vary. But, even if one owner cannot use a “merit shop” constructor on site, the fact that another company can will help free u p union labor.

 Non

- Local labor

– Because of the seasonal nature of boilermaker work, boilermakers will often travel to a different location for work. In fact, according to the IBB, in 2003 there were over 1300 Canadian union boilermakers w orking on NOx S IP Call projects in the United States.

 Other boilermaker sources

– Boilermakers work in other fields than power , such as refining/petrochemical, shipbuilding, metals industries and other construction trades. US EPA’s analysis assumed that no more than 35 % of the assumed number of boilermakers were available for power plant environmental retrofit projects. However, in periods ofR eleased to the public October 4, 2011

.



## 9 Andover Technol ogy Partners high demand the International Brotherhood of Boilermakers is capable of shifting some of its members in its 420 lodges to where the need is and, if need be, training them for power plant applications.

 New Boilermakers

– Between 1999 and 2001, boilermakers increased by 35% mostly by new members (not retired members coming back). This was in response to new demand from SCRs being in stalled for the NOx SIP Call. 7

 Alternative fabrication

– The fabrication of the equipment can be modified so that some activities that would otherwise have to be done on site by union boilermakers can be done at fabrication shops by non

- union workers, of ten at significant savings and with a reduction in demand for union boilermakers. This is an alternative to using union craft labor that is often chosen at facilities that can receive large fabricated components and can reduce overall cost by reducing on site construction efforts

. As a result, although some statistics may suggest that there isn’t enough labor to perform projects , the projects nevertheless are completed in time because these statistics alone don’t capture the dynamic nature of the labor market. In fact, this will be demonstrate d later in this document with a “look back” analysis of CAIR Phase I and the NOx SIP Call.

2.3 US EPA’s estimate of the time nec essary to install the equipment to meet the requirement Installing FGD and SCR systems are the most time

- consuming projects required for CAIR Compliance . Of the specific projects, the most time consuming of these would be
installation of multi

- unit FGD or SCR systems. Th e multi

- unit FGD installations inv olve multiple units ducted to a single absorber. SCR installations typically require SCR on each
boiler.

In Reference 5 , US EPA examined the time necessary for various types of FGD and SCR
inst allations. As shown in Figure 3 , US EPA anticipates a single FGD system to require 27 months. For a more complex project, such as multiple absorbers on multiple units at one site US EPA anticipated that it could require 36 months from initial assessment of technolo gies to completion of commissioning.R eleased to the public October 4, 2011

.



## 10 Andover Technol ogy Partners Figure 3

. Schedule for Retrofit of a Single FGD at a Single Plant 5

In Reference 5 , US EPA also examined the time necessary for ret rofit of SCR systems. Figure 4 shows the schedule for retrofit of SCR at a sing le boiler. This retrofit is projected to require about 21 months. Now, if there were multiple SCRs at one plant, the retrofit project for the plant would take longer. In Reference 5 US EPA estimates that if 7 SCRs are installed on one site, it could take 35 months.
It is fair to say that opinions vary on how long it takes to bui ld an FGD system or SCR system. Certainly, the time will vary depending upon the particular facility.R eleased to the public October 4, 2011

.



## 11 Andover Technol ogy Partners Figure 4

. Schedule for Retrofit of SCR a Single Boiler 5

3.0 UARG ’s Assessment of the Time Needed to Respond to CAIR

Reference 8 is a study by UARG of the feasibility of complying with the CAIR rule. UARG wished to address comments made by the Inst itute of Clean Air Companies (see later in this document) that represents most of the suppliers of air pollution control technology. ICAC also provided input to US EPA on their 2004 CAIR analysis. Table 1 shows projected retrofit needs (in MW of equipment) to meet Phase I requirements of the proposed rule. Keep in mind that US EPA has made other estimates since then and perhaps UARG has made other estimates
as well. Table 2 is taken from Reference 8 and shows estimated distribution of labor over a project life from initiation. The table provides two pieces of information. First, it shows the estimated time for an SCR or FGD project from the time a supplier receives an order. T here is some engineering p erformed prior to the supplier receiving an order. So, the total project time for the utility potentially longer

– anywhere from a few months to perhaps a year. Second, the
table shows how the boilermaker demand would be distributed over the time of the project. One of UARG’s criticisms was that it did not believe that US EPA or ICAC adequately addressedR eleased to the public October 4, 2011

.



## 12 Andover Technol ogy Partners unevenness in the demand for craft labor on a project, and the possibility that this demand would peak to levels where the supply might not meet demand.

Table 1

. Summary of FGD, SCR Retrofit Capacity Required To Meet Phase 1 (2010) of CAIR: Various Studies (from Ref. 8 )

Note that the length of time for an FGD project is shown as nine quarters, or 27 months and for an SCR it is seven quarters or 21 months. UARG actually stated in Ref. 8 that the 27 month and 21 month schedules for FGD and SCR, respectively, were too short by 5 months for FGD and 3 months for SCR. However, UARG used it in the analysis presented in comments to
US EPA describe d in the next paragraph. Of course, there might also be some additional engineering preceding the order. But, using the schedule fro m Table 2 , this suggests that for a utility to have a scrubber installed by January 1, 2010 the facility owner would have to place the order by the end of the third quarter 2007. Even if the preceding engineering effort were a year long, that means that t he effort would require about 39 months, or roughly 3 1⁄4 years. Of course, not all projects are the same and some might be shorter and some longer.
UARG used the preceding information to estimate how long it would take to install the expected number of scr ubbers and SCRs for Phase I CAIR compliance. In their analysis UARG
set a firm limit (a “hard cap”) to the availability of boilermaker craft labor and used estimated demands for boilermakers that were higher than what the US EPA originally used and higher
than that offered in Reference 5 . In UARG’s analysis, if the demand for labor exceeded the firm limit they input on supply, then the work would be delayed to the next quarter. Hence

Table 2

. from Ref. 8R eleased to the public October 4, 2011

.



## 13 Andover Technol ogy Partners Figure 5

. Projected Boilermaker employment 9 “shortages” in labor would contribute to project delays. UARG examine d “optimistic” and “probable” scenarios with the following results:

 The “optimistic” (optimistic being UARG’s characterization) case assumed that utility orders started on January 1, 2006, after the date when UARG assumed State Implementation Plans would be finalized, which resulted in a completion date for all projects at the end of 2010.

 The “probable” (probable being UARG’s characterization) case assumed that utility orders occurred on July 1, 2006, six months after assumed finalization of State Impleme ntation Plans, which resulted in a completion date for all projects in the first quarter of 2011. Another way to look at UARG’s analysis is that, with the limitations they imposed on boilermaker labor and for the timing of when orders were placed, for all of these retrofits to be complete by January 1, 2010, the first orders had to start no later than January 1, 2005.

As will be shown , UARG’s predictions significantly underestimat ed the actual ability of
the APC industry to respond.

4.0 ICAC’s Assessment of the Time Needed to Respond to CAIR

Reference 9 is a study by ICAC that examined the availability of boilermaker labor to complete the anticipated retrofit requirements of the proposed Interstate Air Quality Rule

– IAQR, which later became known as CAIR . At that time the IAQR was a two

- phase program similar to the final CAIR rule. US EPA had anticipated at the time * that:

 49 GW of FGD and 24 GW of SCR would be needed by 2010 for the proposed IAQR

 63 GW of FGD and 46 GW of SCR (inclusive of the installa tions for 2010) by 2015
According to ICAC, the National
Association of Construction Boilermaker Employers (NACBE)

– an association of the companies that employ boilermakers †

– anticipated the number of boilermakers to grow to nearly 30,000 during the construction period for the CAIR , as

* US EPA periodically updated their estimates † Many of ICAC’s member companies are also member companies of NACBER eleased to the public October 4, 2011

.



## 14 Andover Technol ogy Partners shown in Figure 5 . This increase was a direct result of the increased demand for boilermakers
that would result from CAIR. ICAC also discuss ed the various ways boilermakers are used in the clean air projects and methods of construction that can reduce the demand for boilermakers.

ICAC performed an analysis of the IAQR (later called CAIR) and determined that:

 There was adequate capacity in the industry to execute all 63 GW of FGD and 46 GW of SCR US EPA estimated at the time would be needed by 2015

 Capacity, in fact, was sufficient to install all 63 GW of FGD and 46 GW of SCR by 2010.
In other words, according to ICAC, all of the CAIR

- related retrofit activity anticipated by US EPA for 2015 could actually be completed by 2010. Of course, there would likely be additional work after 2010 to address new units and controls necessary to address emissions
increases due to generation growth. But, this would be at a lower level of intensity. So, when comparing ICAC’s projections to those of US EPA’s 2005 projections or UARG’s projections, ICAC anticipated that there was adequate capacity to handle a much larger surge in construction activity prior to 2010 than either US EPA or UARG anticipated. Because the number of existing plants to be retrofit is finite, this surge prior to 2010 naturally implies that activity would drop off rapidly after 2010.

In the next section the actual experience in responding to CAIR is examined

.

5.0 Comparison of Actual Retrofit activity to the US EPA, UARG and ICAC Projections On the subject of feasibility this White Paper has, so far, discussed what was being projected prior to the fina lization of the CAIR rule. This was to provide background on the factors believed to impact the industry’s ability to comply with the CAIR rule and also to show that different parties examined this subject of feasibility extensively from their perspective s. However, with the benefit of having real information to compare to the predictions, it is usefu l to examine how the predictions compare to the actual results.
The intensive construction anticipated by US EPA, UARG, and ICAC , in fact, progressed

as expe cted. There was a very high level of activity in the years leading up to the 2010 CAIR
deadline for SO 2 . This is also consistent with the expected peak in activity in that time

. Although lead times on equipment and materia l and prices on these items had increased due toR eleased to the public October 4, 2011

.



## 15 Andover Technol ogy Partners the increased demand and other factors , the projects were executed, and a few are still being completed

. However, there was actually far more activity than any of the partie s expected. In fact, in 2007 US EPA modified its estimate for t he retrofits anticipated to be installed by 2010

–

a nd this estimate was significantly higher than previous estimates. This estimate factor ed in projects that ha d been announced and committed to

. In early 2007 US EPA revised its estimates
that at least 55,000 MW of new FGD capacity was committed by 2009 and estimate d about 80,000 MW of new FGD by 2010. This compares to US EPA’s late 2005 estimate of about 36,000 MW by 2010 and 72000 MW by 2015 . In other words, with real project info rmation, US
EPA anti cipated more FGD to be installed by 2010 than they previously expected to be installed by 2015

. The greater amount of retrofit activity prior to 2010 means that the rate of installation
should drop off even more dramatically after the Phase I CAIR deadline than US EPA had anticipated when the CAIR rule was finalized. With a finite number of boilers to retrofit, more activity before 2010 means less activity after 2010. Fig ure 6 shows estimated average installation rates using US EPA’s 2007 projections divi ded by US EPA’s assumed execution period of 3.25 years for pre

- 2010 retrofits of both SCR and FGD, ‡ respectively, and 10 years for the 2010 to 2020 period. As shown, both SCR and FGD installation activity are projected to drop off to about a third of thei r pre

- 2010 level in the period from 2010

- 2020. Keep in mind that a large proportion of the post

- 2010 retrofit activity is associated with new units that are likely to occur later in the period , or may not occur at all due to project cancellations

. Recalli ng UARG’s projectio ns, they projected that about 43,000 MW of FGD and 46,000
MW of SCR’s would be needed but could not be installed before 2010. They expected that these
could not be installed before the end of 2010 at the earliest. So, in reality FGD is being installed at a much faster rate than UARG anticipated or US EPA anticipated in 2005. And, SCR’s were also installed at a faster rate than either US EPA or UARG anticipated could be installed in that
time.

‡ The pre

- 2010 execution period is based on an assumed start of activity at the end of 2006 and the final Phase I CAIR deadline of January 1, 201 0 for SO 2 .R eleased to the public October 4, 2011

.



## 16 Andover Technol ogy Partners Figure 6 . Estimat e of FGD and SCR installation rate in MW of capacity per year from US EPA

2007 projection

– developed from data in Reference 10

Clearly, ICAC’s estimate was the closest because they anticipated that all of the scrubbers and SCRs US EPA anticipated as ne cessary by 2015 could be performed by 2010, resulting in a much higher level of activity prior to 2010 and a lower level of activity after 2010.
Keep in mind that, except for the CAIR emission level requirements, there were three assumptions that were comm on to both the UARG analysis and the late 2005 US EPA analysis that predicted only 36,000 MW of scrubbers by 201 0. These assumptions relate to

 The timing of orders

 The time it takes to fill an order (UARG used US EPA’s estimate in their analysis although they state that they believe somewhat more time is needed)

 Assumptions regarding the demand for and availability of resources, especially craft labor §

E ach of these is examined in the following sections.

§ UARG did assume a less even demand for labor than did US EPA. However, with regard to total labor demand, US EPA’s 2005 estimates were developed from those of UARG. And, both assumed a hard cap on labor supply.R eleased to the public October 4, 2011

.



## 17 Andover Technol ogy Partners 5.1 Timing of orders

. Figures 7 and 8 show the historical and projected new orders for Flue Gas Desulfurization (both wet and dry) and SCR from the Institute of Clean Air Companies’(ICAC) 2006 Annual Market Outlook. ICAC is the trade association for suppliers of air pollution
control techn ology companies that includes nearly every supplier of air pollution control to the electric utility industry. This data is provided with the permission of ICAC

. New orders show when the contract was signed. The project would be completed and the equipm ent brought on line at a later point. Clearly, 2005 and 2006 are the peak years for new
FGD orders. In other words, new FGD orders peaked in 2005 and 2006 and have been dropping
off since . Both UARG and US EPA assumed that no orders would be placed unti l after the State Impleme ntation Plans required under CAI R were finalized , or at the end of 2006 at the earliest

. Clearly, a large number of utility customers did not wait until that time. Figur e 9 shows the data of Figure 7 another way

– cumulative or ders by the end of the year

. By the end of 2005 nearly 60,000 MW of FGD was ordered, which is when UARG and US EPA assumed the first orders would actually be placed. And, by the end of 2006, 86,000 MW

- nearly all of the FGD US EPA’s 2005 projections ant icipated would be needed by 2020

- were ordered. As shown , th e cumulative orders in Figure 9 start to level off near 2009 because the new orders ar e slowing down per Figure 7 . It stands to reason that if the orders were placed at an earlier date than
UAR G and US EPA projected, they will also be completed by an earlier date than UARG and US EPA projected.
The drop off of expected new orders has clear impl ications for later buyers . First, t he “seller’s market” that was experienced at the height of new order activity has become a “buyer’s
market” as the a vailable new customers drop ped off and the companies with built

- up engineering capacity compete for the reduced amount of future business. Second, as will be shown in the next few pages, craft labor has become increasingly available in the years after the peak in
demand for Phase I retrofits , making it easier to hire labor for scrubber and SCR projects.R eleased to the public October 4, 2011

.



## 18 Andover Technol ogy Partners Figure 7.

Figure 8.R eleased to the public October 4, 2011

.



## 19 Andover Technol ogy Partners 5.2 The time it takes to fulfill an order

Even in early 2007 , companies had been accepting new orders while planning to have these control systems op erating prior to 2010. Table 3 shows several an nouncements of scrubbers, some as late as spring 2007, when most of the analysis for this paper was p erformed

. As shown, these projects we re apparently being committed to be performed in the roughly 2

- 3 year time period that is shown in Table 2 . So, these companies and their utility customers expect ed that they would execute these pro jects in this time

. Of course, since then CAIR was
vacated and later remanded , and this may have had an effect on some of these projects.

Table 3 . Some Wet FGD Order Announcements, Including Start Up Dates Supplier Plant Announcement Start Up Reference Babcock Power Cholla 4

Cholla 3 October 2006 Mid 2008 Mid 2009 11

Ghent 1, 3, 4 Dec 2005 2007

- 2009 12 Brown 1, 2, 3 Babcock & Wilcox Hatfield’s Ferry July 2006 2009 13
Washington Group Fort Martin December 22, 2006 2009 14

, 15

Alstom Spurlok 1 November 21, 2006 2009 16

Wheelabrator Keystone November 13, 2006 2009 17

Black&Veatch Chiyoda Crist April 4, 2007 2009 18 Figure 9.R eleased to the public October 4, 2011

.



## 20 Andover Technol ogy Partners 5.3 Availability of Resources
The resources necessary to build scrubbers and SCRs include:

 Craft labor, especially boilermakers

 Engineering labor to design the equipment

 Construction materials, especially steel, concrete, etc.

 Engineered equipment, such as pumps, valves, motors, catalyst, etc.
Craft Labor has been a major concern and will be examined in detail.
Craft Labor

Craft laborers are the skilled workers that are directly involved in building the equipment. As noted in previous parts of this report, UARG and US EPA tend to view boilermaker availability a s the most critical craft labor availability issue . This is because of the specialized nature of this trade for power plant applications. Other crafts can often be drawn from the broader construction industry. So, supply of these other craft labor trades is normally less of a concern than supply of boilermakers. And, this is why US EPA a nd UARG put so much effort into analyzing boilermaker availability prior to finalizing the CAIR rule by US EPA and others.

With information regarding the actual orders and installations, it is possible to make
estimates of the boilermaker demand from CAIR retrofits

. Taking the information regarding actual and projected SCR and FGD projects and the boilermak er demand estimates of UARG and US EPA, estimate s of boilermaker demand were developed . This use d boilermaker time loading as shown in Table 4 and the b oilermaker demand estimating factors shown in Table 4

.

Table 4

. Boilermaker demand estimating factors, in Boilermaker years/MW SCR FGD US EPA 2005 demand loading* 0.344 0.270 US EPA 2004 demand loading 0.175 0.152
* US EPA developed loading numbers in 2005 based on UARG information. So, these are from Reference 7 (by US EPA). But, Reference 8 (UARG’s comments) provided the source for Reference 7

.
Since the order data available is annual order data, it is necessary to make projections of labor demand by year. Therefore, the information f rom Table 2 , which breaks the demand down by quarter, was used to develop estimates of boilermaker demand by year as shown in Table 5

. Note that by spreading the labor in this way, it effectively assumes that all orders for a given yearR eleased to the public October 4, 2011

.



## 21 Andover Technol ogy Partners Figure 10. are placed on December 31 of that year. This will postpone the demand (and the estimated peak) as well as the completion date from what woul d happen if the actual start date were used.

Table 5 . Assumed distribution of boilermaker demand Project Year SCR FGD Year of order 0% 0% First year after order 20% 0% Second year after order 80% 94% Third year after order 0% 6% Total 100% 100%
Figure 10 shows the estimates of demand loading for boilermakers for US clean air retrofits as well as pollution control on new units using ICAC’s reported orders and the

assump tions outlined in Tables 3 and 4 . The units are boilermaker

- years and are equivalent to a boilermaker working 1685 hours per year. As shown, the demand for boilermakers peaks in the period from 2007 to 2009 and falls off quickly after that. The drop off that starts in 2009 and
continu es to 2010 would not be affected by the lack of new order data for 2010. And, the further drop in 2011 is only minimally affected by the fact that there is no 2010 new order estimate because there would not be much boilermaker demand in that first year af ter the order. So, through 2011 on this figure should be a pretty good indicator of what one should expect for
boilermaker demand trends for SCR and FGDs.

In its 2004 estimate (prior to adopting UARG’s assumptions for boilermaker
labor a nd hard caps on labor in 2005), US EPA projected a peak
in boilermaker labor demand during the mid 2008 to mid
2009. 6 This, of course, is consistent with the prediction in Figure 1 0

.R eleased to the public October 4, 2011

.



## 22 Andover Technol ogy Partners The National Association of Construction Boilermaker Employers (NACBE) makes statistics on boilermaker manhours available on its web site. Figure 11 shows the historical
trends in boilermaker manhours

. The figure shows the peak in 2002 associated with NOx SIP Call activity that was preceded by a rapid run up in demand of m ore than 16 mill ion manhours from 1997 to 2002. The figure also shows the more recent 2008 peak is consistent with the trend of Figure 10, with the peak in demand in 2008 and falling off in 2009. First and second quarter
2010 data from NACBE shows that 2 010 will drop off more

– again consistent with Figure 10. Bear in mind that Figure 11 includes demand for all boilermaker work while Figure 10 is only
for SCRs and FGDs from CAIR.

Figure 11

. Historical Total Boilermaker Manhours 19

The IBB had 26,696 members in 2002. 7 There was substantial growth in the time
between 1999

– when there were about 16,000

– and 2002. This was thanks to increased demand for boilermakers due to the NOx SIP Call and, according to IBB, new boilermakers joi ning the ranks. In other words, the dynamic behavior of the US labor market was driving resources (skilled laborers) to where they were needed (boilermakers)

. In their 2005 CAIR analysis US EPA asserted that 35% of total union boilermaker enrollment can be made available for clean air projects. 7 So, if the enrollment is 26,000 union boilermakers

– EPA’s conservative
assessment from Reference 7

- t hen 9,100 union boilermakers were available for CAIR , notR eleased to the public October 4, 2011

.



## 23 Andover Technol ogy Partners including other sources as described in earlier in this report. ** As shown in Figure 10 , this 9,100 number may have been reached at the peak year of 2008 (using US EPA’s 2005 boilermaker demand based on UARG’s estimates). But, for all other years it remained below 9,100. Using US EPA’s 2004 estimates of boilermaker loading, the demand fo r boilermakers
would have remained well below the 9,100 level for all years.
But, this 9 , 100 boilermaker “hard cap” on labo r is likely a faulty assumption as will be
shown in the following paragraphs. W e can look to the past to test this

. We can learn from previous peaks in demand

. To appreciate how the market responds to sudden surges in labor demand, it is worth examining how the boilermaker labor market responded during t he NOx SIP Call when SCR’s were added to roughly 1/3 of the US coal fired fleet capacity. Figure 12 shows the SIP Call SCR installation in MW by year taken from
Reference 8 . As shown, there is a large peak of SCRs being placed into service in 2003. It i s possible to estimate how many boilermakers were needed to achieve this installation level in a
similar manner as Figure 1 0

. Figure 13 shows the results.

Figure 12

. SCR Installations for the NOx SIP Call 8

** However, if boilermaker labo r increases to 30,000, as expected by NACBE in Fig. 5 , then 35% of this is 10,500.R eleased to the public October 4, 2011

.



## 24 Andover Technol ogy Partners Figure 1 3

. Look

- Back Estimate of Boile rmaker demand based on Figure 12

.

As shown in Figure 1 3 , the demand for boilermakers should have peaked in the 2003 time period †† . Even if the 2002 and 2003 levels are averaged, they average about 10,000 boilermakers using the 2005 US EPA demand loading , well above the 9100 boilermaker level that equates to the hard cap consistent with US EPA’s 2005 assumptions (35% of 26,000). It appears that boilermaker activity peaked well above the “apparent” supply (if US EPA’s 2005 demand loadings are used)

. Eith er the 2005 US EPA boilermaker demand loadings are too high, the “hard cap” on labor is too low (or the “hard cap” concept simply incorrect)
, the labor market is dynamic and companies and workers adjust as needed to meet the needs , or all of the
above

.
In fact , going forward, buyers of air pollution control equipment will be at an advantageous position to pick up recently experienced craft labor and construction managers as the Phase I CAIR projects are completed and labor has become increasingly available. The recent experience of these skilled laborers and construction managers will also likely translate into excellent productivity.

†† It actually peaked in 2002, but the late prediction in Figure 13 is an anomaly of the model assumption that 80% of the labor is in the second year after order placement an d that th e unit starts up at the end of that second year.R eleased to the public October 4, 2011

.



## 25 Andover Technol ogy Partners Engineering labor to design the equipment
Engineering labor has not been raised as an issue that limits the ability of the APC industry to respond to clean air initiatives. This is likely because this has not been a problem. There are numerous suppliers of APC equipment . As a result, if one supplier becomes busy, there are several other options. Moreover, for owners t hat are building multiple scrubbers, standardization of equipment design between scrubbers is often performed. As a result this reduces process

- specific changes between units , which reduces the demands on process engineers. This approach also results in benefits to the users in terms of standardization of operator training, spare parts and maintenance practices across facilities.
Availability and Cost of Materials
Materials such as steel, alloys, cement and fiberglass used in construction are traded globally , and US EPA assumed that availability of these materials would not be a limiting factor
for CAIR

. Demand from retrofit projects in the US, while significant, are relatively small compared to the glob al marketplace. As a result, price is much more of a concern than availability. During this last decade these materials experience d escalation that caught many by surprise. This was largely a result of rapidly increasing demand for these materials from As ian markets, especially China , where the equivalent of two power plants were being built each week

. 20 Recent indexes show a significant drop off from the peak that occurred around mid 2008.

Cost escalation was an industry

- wide issue

– not isolated to scru bbers and SCRs. Figure
14 is from the 2007 US Department of Energy, Energ y Information Administration’s Annual Energy Outlook. The figure shows costs trends of power plant construction in “real” terms, adjusted for inflation. As shown there was a significant increase in electric power plant
construction costs in the period from about 2003 to 2006, and other data shows that this
continued into 2008 , which correlates with the increase in power plant construction commodity prices. Figure 15 , which is also from the Annual Energy Outlook shows trends for a range of
commodities

– and the trend is across all major power plant construction materials. It is also notable that while costs are higher than they were in the recent past, they are also about where they were in 1973 in real dollar terms. According to these indices, adjusted for inflation, power plant construction costs have remained within a roughly ± 20% range for the past 30+ years.R eleased to the public October 4, 2011

.



## 26 Andover Technol ogy Partners Figure 15. Trends in Real (inflation adjusted) S pecific Construction Commodities, from 2007 EIA Annual Energy Outlook Figure 14

. Trends in Real (inflation adjusted) Electr ic Utility Construction Costs, from 2007 EIA Annual Energy OutlookR eleased to the public October 4, 2011

.



## 27 Andover Technol ogy Partners Engineered Equipment
EPA determined that availability of engineered equipment would not be the limiting factor in the installation of SCR and scrubber systems in a multipollutant rule 5 and this generally proved to be the case although during the CAIR phase I retrofit period lead times on some engineered equipment items became longer. Items such as large recycle pumps, large electric motors to drive the pumps, and othe r such specialized equipment did see lead times increase significantly; however, this period of time where lead times became prolonged did not persist. This is partly because in response to demand, manufacturers expanded capacity or companies looking to b uy this equipment found alternative suppliers, but it is also because “the rat passed through the snake” as suppliers worked to fill orders and free up shop space for new customers. Moreover, China has now become a manufacturer of large recycle pumps as t hey
installed scrubbers on their coal

- fired power plants. In a similar manner, in anticipation of the increased demand for SCR catalyst from the NOx SIP Call, many catalyst vendors increased capacity. So, experience has shown that supply of engineered eq uipment has not in general been a serious impediment to completion of clean air projects.
In both the case of the NOx SIP Call and in the case of Phase I of CAIR, the industry responde d to the increase in demand by increasing supply. Moreover, it is unlik ely that the
demand for SCRs or wet FGD systems experienced during the NOx SIP Call or Phase I of CAIR will be experienced ever again because both programs entailed retrofit of a large portion of the coal fleet in a few short years , and there are now fe wer plants remaining to retroft this equipment
in the future

.

6.0 Role of other technologies
Thus far, this White Paper has focused on scrubbers and SCR as the primary technologies of concern. This is because these are the most capital intensive technologies that were likely to be used for compliance with the CAIR, NOx SIP Call or US EPA’s recent ly proposed Transport
Rule , and therefore use of these technologies would put the greatest strain on available resources;
h owever, there are other, less capital intensive, technologies or approaches that can be used for emissions compliance. Use of these less capital intensive technologies can reduce the need for
scrubbers and SCR and relieve the strain on resources somewhat. For example, dry sorbentR eleased to the public October 4, 2011

.



## 28 Andover Technol ogy Partners injection (DSI) is a technology that reduces SO 2 through injection of Trona, Sodium Bicarbonate or Hydrate d Lime upstream of a particulate control device. DSI does not generally provide the
SO 2 reductions that are possible with scrubbers; however, the reductions are nevertheless significant

– typically in the range of 50% or more. Moreover, t hese technologie s can be implemented very quickly

– typically within one year.
For NOx control, selective non

- catalytic reduction (SNCR) is a proven approach to achieve NOx reductions in the range of about 25% (varies based up on application), and can be implemented in und er a year. Compared to scrubbers and SCR, b oth SNCR and DSI require relatively little in terms of labor resources.
It may also be possible to improve the scrubber performance of many older scrubbers that were installed in the 1970’s and 1980’s. For exam ple, limestone forced oxidation wet scrubber system upgrades at the Vectren Culley Station Units 2 & 3, E.On’s Trimble County Unit 1, and Michigan South Central Power’s Endicott Station resulted in removal efficiencies in the range of 98% being achieved fo r each of these units. 21 , 22 , 23 Upgrades such as these can also be implemented very quickly and inexpensively when compared to installation of a new scrubber and they are probably better suited than FGD to the remaining unscrubbed plants that tend to be smaller in capacity.

These lower

- cost approaches for SO 2 and NOx control that can be implemented quickly lend themselves well to the flexibility that has been incorporated into US EPA’s criteria pollutant regulations . These methods do not require large co mmitments of capital. Utility companies can implement these methods and delay or avoid installation of more capital intensive technologies. Although SNCR has been incorporated into US EPA’s analysis in the past, DSI and scrubber upgrades have not

.R eleased to the public October 4, 2011

.



## 29 Andover Technol ogy Partners 7.0 Implications of this Analysis

This White Paper assessed the demands on resources for constructing air pollution control equipment in response to clean air initiatives . It focused on NOx and SO 2 control equipment, par ticularly SCR and FGD systems; how ever, the lessons apply to other equipment that may be needed for future clean air programs. By examining US EPA’s analysis of the capabilities of the air pollution cont rol industry to respond to CAIR, it was determined that US
EPA underestimated the abil it y of the industry to respond to CAIR in its 2005 analysis published
with the rule . This was largely a result of assumptions that US EPA made regarding the demand
for labor and the availability of labor to install the equipment that US EPA projected woul d be necessary for the industry to comply with CAIR. The assumption s regarding labor were demonstrated to be too conservative and did not take into account the dynamic nature of U.S

. labor markets , which US EPA had previously acknowledged, by imposing a “ hard cap” on labor availability. Assumptions regarding timing of orders also proved to be incorrect. A ssumptions regarding other resources that were not envisioned to be limiting generally proved to be consistent with experience. The findings of this Wh ite Paper have implications for future clean air initiatives and how the timing of these initiatives should be assessed. To this end, it may be beneficial to reexamine the topic of resource supply and demand, particularly with regard to labor, and develop assumptions that better reflect the demand and supply characteristics of the market for power plant labor. Looking to the future , in addition to SCR and FGD systems, there are other technologies that are likely to play an increased role in future NOx and SO 2 reductions and will require less significant outlays of capital as w ell as construction resources. These lower

- cost approaches for
SO 2 and NOx control can be implemented quickly , may be better economic choices for smaller
unit s , and lend themselves well to the flexibility that has been incorporated into US EPA’s criteria pollutant regulations.R eleased to the public October 4, 2011

.



## 30 Andover Technol ogy Partners References

1 US EPA, “Clean Air Interstate Rule

– Reducing Power Plant Emissions for Cleaner Air, Healthier People, and a Strong America”, March, 2005, http://www.epa.gov/cair/charts_files/cair_final_pres entation.pdf 2 US EPA, “Multi

- Pollutant Regulatory Analysis: CAIR/CAMR/CAVR”, October 2005, http://www.epa.gov/airmarkets/progsregs/cair/docs/cair_camr_cavr.pdf 3 Federal Register/Vol. 70, No. 91/Thursday, May 12, 2005, pp 25215

- 25225. 4 US EPA, “Feasibility of Installing Pollution Controls to Meet Phase I Requirements of Various Multi

- Pollutant Legislative Proposals”, October 2005; http://www.epa.gov/airmarkets/progsregs/cair/docs/feasibility.pdf 5 US EPA, “Engineering and Economic Fact ors Affecting the Installation of Control Technologies for Multipollutant Strategies” , EPA

- 600/R

- 02/073, October 2002 6 US EPA, Clean Air Markets Division, “An Analysis of the Impact of Boilermaker Labor Availability on the Installation of Pollution Cont rol Equipment”, January 28, 2004 7 US EPA, Technical Support Document for the Final Clean Air Interstate Rule, “Boilermaker Labor Analysis and Installation Timing”, EPA Docket Number: OAR

- 2003

- 0053, March 2005, http://www.epa.gov/cair/pdfs/finaltech05.pdf 8 J. E. Cichanowicz, Michael Hein, Jim Marchetti, Consultants to UARG, “ANALYSIS OF CAIR COMPLIANCE SCHEDULE: A RESPONSE TO ICAC ESTIMATES” , July 26, 2004 9 Institute of Clean Air Companies, “ IAQR Projected 2015 Control Technologies can be Installed by 20 10”, March 30, 2004 10 Air Emissions Cap and Trade Programs An Update , Presentation for National Association of Regulatory Utility Commissioners, U.S. Environmental Protection Agency Office of Air and Radiation February 18, 2007 11 http://www.babcockpower.com /index.php?option=news&coid=17&task=viewnews&sid=88&Itemid=56 12 http://www.babcockpower.com/index.php?option=news&coid=17&task=viewnews&sid=75&Itemid=56 13 THE BABCOCK & WILCOX COMPANY AWARDED SCRUBBER CONTRACT FOR ALLEGHENY ENERGY BARBERTON, Ohio, July 14, 2006, announcement on Babcock and Wilcox web site, www.babcock.com 14 McIlvaine, UTILITY E

- ALERT #804

– December 22, 2006 15 http://www.pr

- inside.com/rss/washington

- group

- international

- to

- perform

- clean

- air

- retrofit

- services

- at

- allegheny

energy

- power

- plant

- r66820.htm 16 http://www.environment.power.alstom.com/home/news/press_releases/28049.EN.php?languageId=EN&dir=/hom e/news/press_releases/ 17 http://www.wapc.com/news_Reliant_Keystone.htm 18 http://www.pensacolanewsjournal.com/apps/pbcs.dll/article?AID=/20070404/NEWS01/704040344/1006 19 National Association of Construction Boilermaker Employer Web site: http://www.nacbe.com/manhour.html 20 McIlvaine , March 20, 2007, 650,000 MW Of Chinese Coal

- fired Boilers In Operation Or Under Development 21 Quatidamo, M., Erickson, C., Langone, J., “SO2 Removal Enhancement to the Vectren, Culley Generating Station Units 2&3 Wet Flue Gas Desulfurization System”, ICAC Forum ’05, Baltimore MD, March 7

- 10, 2005 22 Erickson, C., Jasinski, M., VanGansbeke, L., “Wet Flue Gas Desulfurization (WFGD) Upgrade at the Trimble County Generation Station Unit 1”, EPRI

- DOE

- EPA

- AWMA Combined Power Plant Air Pollutant Control Mega Sympo sium, Baltimore, MD., August 28

- 31, 2006 23 Silva, A., Williams, P., Balbo, J., “WFGD Case Study

– Maximizing SO 2 Removal by Retrofit with Dual Tray Technology,” EPRI

- DOE

- EPA

- AWMA Combined Power Plant Air Pollutant Control Mega Symposium, Baltimore, MD., Au gust 28

- 31, 2006